IRC section 877A. 2026 figures

US exit tax calculators: what does the exit tax cost?

Renouncing US citizenship or giving up a long-held green card triggers a deemed sale of everything you own the day before you go, but only if you are a covered expatriate. On $5,000,000 of net unrealized gain, after the 2026 exclusion of $910,000, that is $4,090,000 taxable and about $818,000 of tax at a 20% long-term rate. Enter your own figures below.

Net worth on the expatriation date

Worldwide assets less liabilities, valued as if sold at fair market value.

Average annual net income tax, 5 years before expatriation

Your US federal income tax liability, averaged over the 5 tax years ending before the expatriation date. Not your income.

Can you certify 5 years of federal tax compliance on Form 8854?

Net unrealized gain on worldwide property

Fair market value less basis, netted across gain and loss assets, on the day before the expatriation date.

Assumed federal rate on the deemed gain

The maximum long-term capital gains rate is 20%. Collectibles, section 1250 gain and ordinary-income assets are taxed differently, and the net investment income tax may apply on top.

Estimated mark-to-market exit tax

$818,000

Net unrealized gain, less the 2026 exclusion of $910,000, at the rate you set. Deferred compensation, tax-deferred accounts and non-grantor trusts are taxed under separate rules and are not included.

Have these figures reviewed by a tax adviser

Covered expatriate status	Covered expatriate
Test met (first that applies)	Net worth test, $2,000,000
Section 877A(a)(3) exclusion applied	$910,000
Gain subject to the exit tax	$4,090,000
Effective rate on the whole gain	16.36%

US section 877A exit tax by net unrealized gain, 2026

Last updated 2026-08-15

The mark-to-market charge on a covered expatriate, computed at each level of net unrealized gain after the 2026 exclusion of $910,000, at a 20% long-term capital gains rate. Deferred compensation, IRAs and non-grantor trusts are excluded, they run under separate rules.

Computed with the formulas this page's calculator uses: gain less the section 877A(a)(3) exclusion of $910,000 for 2026 (Rev. Proc. 2025-32 s4.38), taxed at 20%, the maximum long-term capital gains rate per IRS Topic 409. Assumes covered expatriate status and that all gain is long-term capital gain.

US section 877A exit tax by net unrealized gain, 2026
Net unrealized gain	Exclusion applied	Gain subject to tax	Exit tax at 20%	Effective rate on the gain
$1,000,000	$910,000	$90,000	$18,000	1.8%
$2,000,000	$910,000	$1,090,000	$218,000	10.9%
$3,000,000	$910,000	$2,090,000	$418,000	13.93%
$5,000,000	$910,000	$4,090,000	$818,000	16.36%
$10,000,000	$910,000	$9,090,000	$1,818,000	18.18%
$25,000,000	$910,000	$24,090,000	$4,818,000	19.27%
$50,000,000	$910,000	$49,090,000	$9,818,000	19.64%

For a 2026 expatriation date, the section 877A(a)(3) exclusion is $910,000 and the average annual net income tax test is $211,000, both set by Rev. Proc. 2025-32.
The $2,000,000 net worth test is written into section 877(a)(2)(B) as a fixed figure and is not adjusted for inflation, so it catches more people every year in real terms.
A covered expatriate with $5,000,000 of net unrealized gain faces roughly $818,000 of mark-to-market tax at a 20% long-term rate, an effective 16.36% on the whole gain once the exclusion is applied.

Cite this page

“US section 877A exit tax by net unrealized gain, 2026”, Expatriation Tax Calculator, https://expatriationtaxcalculator.com/ (updated 2026-08-15). Computed with the formulas this page's calculator uses: gain less the section 877A(a)(3) exclusion of $910,000 for 2026 (Rev. Proc. 2025-32 s4.38), taxed at 20%, the maximum long-term capital gains rate per IRS Topic 409. Assumes covered expatriate status and that all gain is long-term capital gain.

Behind the numbers

The three covered expatriate tests are in section 877(a)(2), applied by section 877A(g)(1): net worth of $2,000,000 or more (a fixed statutory figure, not inflation adjusted), average annual net income tax above an inflation-adjusted amount, or failure to certify 5 years of federal tax compliance on Form 8854 (IRS).
The income tax test amount is $211,000 for a calendar year 2026 expatriation date, set by Rev. Proc. 2025-32 section 4.37. The IRS expatriation page still lists figures up to $206,000 for 2025; use the year your expatriation date falls in.
The exclusion is $910,000 for taxable years beginning in 2026 under section 877A(a)(3) (Rev. Proc. 2025-32 section 4.38). It is a once in a lifetime allowance and is allocated pro rata across gain assets, per section 3.C of Notice 2009-85.
Section 877A treats all property as sold at fair market value the day before the expatriation date. Losses are taken into account, so the input here is the net figure across your whole balance sheet.
The tax rate is an input, not a computed result. Section 877A does not set its own rate: the deemed gain enters gross income and is taxed under the normal rules, so the character of each asset matters. The maximum long-term capital gains rate is 20% (IRS Topic 409), with 28% and 25% maxima for collectibles and unrecaptured section 1250 gain, and the net investment income tax may apply on top. Take advice before relying on any single rate.
Deferred compensation items, specified tax deferred accounts such as IRAs and 529 plans, and interests in non-grantor trusts are outside this calculation. They are handled by sections 877A(d), (e) and (f), which impose 30% withholding on eligible deferred compensation and on non-grantor trust distributions to covered expatriates (Notice 2009-85).
The two statutory exceptions in section 877A(g)(1)(B), for certain dual citizens from birth and for people relinquishing before age 18 and a half, are not modelled here. They disapply only the net worth and income tax tests: the Form 8854 certification test still has to be met (Form 8854 instructions).

Expatriation Tax Calculator is an independent information site operated by Ellul Solutions Ltd. It is not affiliated with the Internal Revenue Service, the Department of State or any government body, and nothing here is tax or legal advice. Section 877A turns on valuations, asset character and elections that a calculator cannot see, confirm your position with a US cross-border tax adviser before acting.

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Straight answers

Who pays the US exit tax?

Covered expatriates. You are one if, on expatriation, your net worth is $2,000,000 or more, or your average annual net income tax for the 5 preceding years exceeds $211,000 for a 2026 expatriation date, or you cannot certify 5 years of federal tax compliance on Form 8854.

How much is the US exit tax?

There is no separate rate. Section 877A treats all your property as sold at fair market value the day before you expatriate, reduces the resulting gain by $910,000 for 2026, and taxes the rest under normal rules. At a 20% long-term capital gains rate, $5,000,000 of net unrealized gain produces about $818,000 of tax.

What is the exit tax exclusion amount for 2026?

$910,000, set by Rev. Proc. 2025-32 section 4.38 for taxable years beginning in 2026. It was $890,000 for 2025. The exclusion is once in a lifetime and is allocated pro rata across your gain assets.

Is the $2 million net worth threshold going up?

Not automatically. Unlike the income tax test and the exclusion amount, the $2,000,000 net worth figure in section 877(a)(2)(B) carries no inflation adjustment and has been unchanged since 2004.

Are my IRA and pension caught by the exit tax?

Not by the mark-to-market rule. Specified tax deferred accounts such as IRAs and 529 plans are treated as distributed under section 877A(e), and eligible deferred compensation is instead subject to 30% withholding on each payment under section 877A(d). Those are separate regimes with separate arithmetic.

Can I pay the exit tax later?

Yes, by irrevocable election under section 877A(b), property by property. Notice 2009-85 requires a bond or other security acceptable to the Commissioner, charges interest at the section 6621 underpayment rate for the deferral period, and requires a waiver of treaty rights that would block collection.

Worth knowing

Every figure sourced and dated.

Am I a covered expatriate? The three tests for 2026
Net worth of $2,000,000, average annual net income tax above $211,000 for 2026, or failure to certify on Form 8854. Meet any one and the exit tax applies.
The 877A exclusion amount for 2026: $910,000
The section 877A(a)(3) exclusion is $910,000 for taxable years beginning in 2026. How it is allocated across assets, and why it is once in a lifetime.
Form 8854: the certification that decides your status
Form 8854 is where you certify 5 years of federal tax compliance. Fail to file it, or fail to certify, and you are a covered expatriate whatever your net worth.

Sources

Model the charge before you set a date

The expatriation date decides the year, the year decides the exclusion.

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