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International & Expat

US Expatriation & Covered-Expatriate Exit Tax Planning

Renounce US citizenship — but plan to minimize the §877A mark-to-market exit tax first.

Overview

US citizens/long-term green-card holders (8+ years) can renounce/relinquish, ending future US tax obligation. Covered expatriates (>$2M net worth, >$200K avg tax, or non-compliant) face §877A mark-to-market exit tax on ALL unrealized gains above ~$890K exclusion. Planning: gift below thresholds pre-expatriation, time low-income year, use §877A(g)(1) 2018-plus grandfathered pension, deferred-tax election on illiquid assets. Retain estate/GST tax on future US gifts to US persons (§2801).

Best fit
Long-term UHNW expatsAccidental AmericansDual citizens permanently settled abroad
Estimated impact
Millions in future US tax obligations eliminated

Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.

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