Net worth test expatriation: Covered Expatriate Thresholds
The Covered Expatriate Thresholds carries 8 published figures read from 4 sources' own pages, from 124,000 to 2,000,000 USD, read 7 November 2026.
- 5124,000 to 436,667
- 1436,667 to 749,333
- 1749,333 to 1,062,000
- 1,062,000 to 1,374,667
- 1,374,667 to 1,687,333
- 11,687,333 to 2,000,000
Bands
| Bucket | Value |
|---|---|
| 124,000 to 436,667 | 5 figures |
| 436,667 to 749,333 | 1 figure |
| 749,333 to 1,062,000 | 1 figure |
| 1,062,000 to 1,374,667 | 0 figures |
| 1,374,667 to 1,687,333 | 0 figures |
| 1,687,333 to 2,000,000 | 1 figure |
4 of the 9 named sources read in full publish a figure; 5 publish none, read 7 November 2026.
By test
| Breakdown | Median | Range | Sources |
|---|---|---|---|
| testaverage annual net income tax liability (expatriation on or after 17 June 2008) | 162,000USD | 162,000 to 162,000USD | 1 |
| testaverage annual net income tax liability (expatriation on or before 3 June 2004) | 124,000USD | 124,000 to 124,000USD | 1 |
| testaverage annual net income tax liability (2025) | 206,000USD | 206,000 to 206,000USD | 1 |
| testsection 877A(a)(3) exclusion (2025) | 890,000USD | 890,000 to 890,000USD | 1 |
| testsection 877A(a)(3) exclusion (2009) | 600,000USD | 600,000 to 600,000USD | 1 |
| testaverage annual net income tax liability (2009) | 145,000USD | 145,000 to 145,000USD | 1 |
| testaverage annual net income tax liability (2016) | 161,000USD | 161,000 to 161,000USD | 1 |
| testnet worth | 2,000,000USD | 2,000,000 to 2,000,000USD | 1 |
Every figure, with its source
One row per published figure: the figure as the source's own page publishes it, the page, and the day it was read. A figure that is not on a page we read is not on this one.
| Source | Figure | Breakdown | Read |
|---|---|---|---|
| IRS Relief procedures for certain former citizens | 2,000,000USD | net worth | 2026-11-07 |
| IRS Instructions for Form 8854 (current revision) | 890,000USD | section 877A(a)(3) exclusion (2025) | 2026-11-07 |
| Internal Revenue Bulletin 2009-45 (Notice 2009-85, guidance for expatriates under section 877A) | 600,000USD | section 877A(a)(3) exclusion (2009) | 2026-11-07 |
| IRS Instructions for Form 8854 (current revision) | 206,000USD | average annual net income tax liability (2025) | 2026-11-07 |
| IRS Expatriation tax | 162,000USD | average annual net income tax liability (expatriation on or after 17 June 2008) | 2026-11-07 |
| IRS Relief procedures for certain former citizens | 161,000USD | average annual net income tax liability (2016) | 2026-11-07 |
| Internal Revenue Bulletin 2009-45 (Notice 2009-85, guidance for expatriates under section 877A) | 145,000USD | average annual net income tax liability (2009) | 2026-11-07 |
| IRS Expatriation tax | 124,000USD | average annual net income tax liability (expatriation on or before 3 June 2004) | 2026-11-07 |
The sentence each figure was read from (8)
- IRS Relief procedures for certain former citizens, read 2026-11-07:
Additionally, at the time of my expatriation in 2018, my average annual net income tax for the five tax years prior to my year of expatriation did not exceed the threshold in IRC 877(a)(2)(A), and my net worth was less than $2,000,000.
- IRS Instructions for Form 8854 (current revision), read 2026-11-07:
Increase in threshold for net unrealized gain on property. For 2025, if you are a covered expatriate, the net gain that you must otherwise include in your income is reduced by $890,000.
- Internal Revenue Bulletin 2009-45 (Notice 2009-85, guidance for expatriates under section 877A), read 2026-11-07:
Gain and loss from the deemed sale must be taken into account at that time (subject to a $600,000 exclusion amount, which will be indexed for inflation) unless the individual elects to defer payment of the tax by providing security and waiving treaty rights that would prevent assessment or collection of the deferred tax.
- IRS Instructions for Form 8854 (current revision), read 2026-11-07:
The average annual net income tax liability for the 5 tax years ending before your expatriation date, which is used to determine whether an individual is a covered expatriate, has increased to $206,000.
- IRS Expatriation tax, read 2026-11-07:
Your average annual net income tax for the 5 years ending before the date of expatriation or termination of residency is more than a specified amount that is adjusted for inflation ($162,000 for 2017, $165,000 for 2018, $168,000 for 2019, $171,000 for 2020, $172,000 for 2021, $178,000 for 2022, $190,000 for 2023, $201,000 for 2024, and $206,000 for 2025).
- IRS Relief procedures for certain former citizens, read 2026-11-07:
The individual has an average annual net income tax liability of the five years preceding the year of expatriation that exceeds a specified amount adjusted for inflation (for example, $161,000 for 2016, $162,000 for 2017, $165,000 for 2018, and $168,000 for 2019) (“average income tax liability test”), The individual has a net worth of $2 million or more as of the expatriation date (“net worth test
- Internal Revenue Bulletin 2009-45 (Notice 2009-85, guidance for expatriates under section 877A), read 2026-11-07:
(1) has an average annual net income tax liability for the five preceding taxable years ending before the expatriation date that exceeds a specified amount that is adjusted for inflation ($145,000 in 2009) (the “tax liability test”);
- IRS Expatriation tax, read 2026-11-07:
Your average annual net income tax for the last 5 tax years ending before the date of the expatriation act is more than $124,000, or
Read in full, publishes no figure
5 named sources were read in full on the dates shown and print no usable figure. They are counted, never filled in.
- IRS Publication 519, U.S. Tax Guide for Aliens, read 2026-09-12: every candidate on the page was refused
- Internal Revenue Bulletin 2025-45 (carries Rev. Proc. 2025-32, the 2026 inflation-adjusted items), read 2026-09-12: every candidate on the page was refused
- Rev. Proc. 2025-32 (IRS drop copy), read 2026-09-20: every candidate on the page was refused
- IRS About Form 8854, read 2026-09-12: read in full and no accepted figure on the page
- 26 U.S.C. 877A (LII republication), read 2026-09-12: read in full and no accepted figure on the page
Methodology
Every row is a verbatim sentence read from the named source's own page through our fetch service on the date shown, hash-pinned to the stored read (the sha of the page's visible text; the raw page is mirrored to R2).
4 of the 9 named sources that could be read published a usable figure; 5 published none and are recorded as not published, never filled in; 0 could not be read (blocked, dead or unreachable) and count nowhere.
The headline figures (median, minimum, maximum, quartiles) are over ONE figure per source for each breakdown it prices, in USD (a source's median where its page yielded several accepted sentences for one breakdown), so a page that gives figures for several breakdowns gives one for each and N counts 8 figures, never sentences; 70 candidate sentence(s) were refused by a reviewer with the reason recorded.
The fuller derivation this dataset is chartered to grow into (not yet what the figures above are; they are each source's own published figure as read): one row per expatriation year since 2008 carrying all four numbers that decide the charge - the average annual net income tax liability threshold, the $2,000,000 net worth test, the section 877A(a)(3) exclusion amount and the section 2801 annual exclusion - each quoted from the IRS document that set it for that year, with the inflation step between years computed across the series.
Nobody publishes the four as one dated series: the IRS states the current year on its expatriation page and buries prior years in each year's Revenue Procedure and each year's Form 8854 instructions, so the year-by-year table, the cumulative drift of the income test since 2008 and the answer to 'which year's numbers apply to me' are ours and are derived across the whole run of documents.
70 candidate sentences on these pages were refused by a reviewer; each refusal and its reason is recorded in the review ledger.
Sources (9)
- IRS Expatriation tax(the publisher's own terms; quoted for reporting and comment)
- IRS Instructions for Form 8854 (current revision)(the publisher's own terms; quoted for reporting and comment)
- Internal Revenue Bulletin 2009-45 (Notice 2009-85, guidance for expatriates under section 877A)(the publisher's own terms; quoted for reporting and comment)
- IRS Relief procedures for certain former citizens(the publisher's own terms; quoted for reporting and comment)
- IRS Publication 519, U.S. Tax Guide for Aliens(the publisher's own terms; quoted for reporting and comment)
- Internal Revenue Bulletin 2025-45 (carries Rev. Proc. 2025-32, the 2026 inflation-adjusted items)(the publisher's own terms; quoted for reporting and comment)
- Rev. Proc. 2025-32 (IRS drop copy)(the publisher's own terms; quoted for reporting and comment)
- IRS About Form 8854(the publisher's own terms; quoted for reporting and comment)
- 26 U.S.C. 877A (LII republication)(the publisher's own terms; quoted for reporting and comment)
Cite or embed this figure
The Covered Expatriate Thresholds carries 8 published figures read from 4 sources' own pages, from 124,000 to 2,000,000 USD, read 7 November 2026.
4 of the 9 named sources read in full publish a figure; 5 publish none, read 7 November 2026.
Covered Expatriate Thresholds, test average annual net income tax liability (expatriation on or after 17 June 2008): median 162,000 USD across 1 source, read 7 November 2026.
Covered Expatriate Thresholds, test average annual net income tax liability (expatriation on or before 3 June 2004): median 124,000 USD across 1 source, read 7 November 2026.
Covered Expatriate Thresholds, test average annual net income tax liability (2025): median 206,000 USD across 1 source, read 7 November 2026.
Covered Expatriate Thresholds, test section 877A(a)(3) exclusion (2025): median 890,000 USD across 1 source, read 7 November 2026.
Covered Expatriate Thresholds, test section 877A(a)(3) exclusion (2009): median 600,000 USD across 1 source, read 7 November 2026.
Covered Expatriate Thresholds, test average annual net income tax liability (2009): median 145,000 USD across 1 source, read 7 November 2026.
Covered Expatriate Thresholds, test average annual net income tax liability (2016): median 161,000 USD across 1 source, read 7 November 2026.
Covered Expatriate Thresholds, test net worth: median 2,000,000 USD across 1 source, read 7 November 2026.
Cite as: "expatriationtaxcalculator.com Covered Expatriate Thresholds", updated 2026-11-08, https://expatriationtaxcalculator.com/datasets/covered-expatriate-thresholds/.
Download the CSV (8 rows, computed 2026-11-08)
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Questions this data answers
Am I a covered expatriate - do I fail the net worth test, the average annual net income tax test or the five-year certification test - and what are the thresholds and the mark-to-market exclusion for my expatriation year?
The Covered Expatriate Thresholds carries 8 published figures read from 4 sources' own pages, from 124,000 to 2,000,000 USD, read 7 November 2026.
Where do the figures in the Covered Expatriate Thresholds come from?
Every figure is quoted from its source's own page and dated (last read 7 Nov 2026). 9 named sources were read and 4 publish a figure; the 5 that publish none are recorded as not published, never estimated.