1.20 Expatriation Tax
U.S. citizens who have renounced their citizenship and long-term U.S. residents who end their residency are considered expatriates subject to special tax rules. You are considered a long-term resident for purposes of these rules if you give up lawful permanent residency (“green card”) after holding it for at least eight of the prior 15 years. Form 8854 must be filed if the expatriation date was on or after June 4, 2004. Individuals who expatriated after June 3, 2004 and before June 17, 2008 are subject to different tax consequences than individuals who expatriate after June 16, 2008.
Expatriation after June 16, 2008.
If you expatriated after June 16, 2008, you are subject to a “mark-to-market” tax if any of the following is true: (1) your average annual net income tax liability for the five years ending before the date of expatriation exceeds an annual ceiling, which is $151,000 for expatriations ...
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