# Exit tax deferred compensation withholding (3 figures)

> The Exit Tax Computation Rules carries 3 published figures read from 3 sources' own pages, from 18,000 to 600,000 USD, read 7 November 2026.

Expatriation Tax Calculator · https://expatriationtaxcalculator.com/datasets/exit-tax-computation-rules/ · computed 2026-11-08

**Range of the published figures:** 18,000 to 600,000 USD (range 18,000 to 600,000 USD; 3 published figures; 3 of 6 sources read publish one).

3 of the 6 named sources read in full publish a figure; 3 publish none, read 7 November 2026.

## By rule

| Breakdown | Median | Range | Sources |
|---|---|---|---|
| rule section 2801 annual exclusion (2025) | 18,000 USD | 18,000 to 18,000 USD | 1 |
| rule section 2801 succession tax rate | 40 % | 40 to 40 % | 1 |
| rule deemed sale exclusion amount (2009) | 600,000 USD | 600,000 to 600,000 USD | 1 |
| rule eligible deferred compensation withholding | 30 % | 30 to 30 % | 1 |
| rule section 2801 annual exclusion (2026) | 19,000 USD | 19,000 to 19,000 USD | 1 |

## Every figure, with its source

One row per source: the figure the source's own page publishes, the page, and the day it was read.

| Source | Figure | Breakdown | Read |
|---|---|---|---|
| [Internal Revenue Bulletin 2009-45 (Notice 2009-85)](https://www.irs.gov/irb/2009-45_IRB) | 600,000 USD | deemed sale exclusion amount (2009) | 2026-11-07 |
| [IRS Instructions for Form 708 (United States Return of Tax for Gifts and Bequests Received From Covered Expatriates)](https://www.irs.gov/instructions/i708) | 19,000 USD | section 2801 annual exclusion (2026) | 2026-11-07 |
| [Federal Register: Guidance Under Section 2801 (final regulations, TD 10027)](https://www.federalregister.gov/documents/2025/01/14/2025-00284/guidance-under-section-2801-regarding-the-imposition-of-tax-on-certain-gifts-and-bequests-from) | 18,000 USD | section 2801 annual exclusion (2025) | 2026-11-07 |
| [Federal Register: Guidance Under Section 2801 (final regulations, TD 10027)](https://www.federalregister.gov/documents/2025/01/14/2025-00284/guidance-under-section-2801-regarding-the-imposition-of-tax-on-certain-gifts-and-bequests-from) | 40 % | section 2801 succession tax rate | 2026-11-07 |
| [Internal Revenue Bulletin 2009-45 (Notice 2009-85)](https://www.irs.gov/irb/2009-45_IRB) | 30 % | eligible deferred compensation withholding | 2026-11-07 |

## The sentence each figure was read from (5)

- [Internal Revenue Bulletin 2009-45 (Notice 2009-85)](https://www.irs.gov/irb/2009-45_IRB), 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 708 (United States Return of Tax for Gifts and Bequests Received From Covered Expatriates)](https://www.irs.gov/instructions/i708), read 2026-11-07: "The $19,000 amount is subject to an annual inflation adjustment for calendar years after 2026."
- [Federal Register: Guidance Under Section 2801 (final regulations, TD 10027)](https://www.federalregister.gov/documents/2025/01/14/2025-00284/guidance-under-section-2801-regarding-the-imposition-of-tax-on-certain-gifts-and-bequests-from), read 2026-11-07: "recipient during the calendar year exceeds the amount of the inflation-adjusted annual exclusion under section 2503(b) of the Code ($18,000 for 2024), the section 2801 tax is computed by multiplying the excess by the highest estate tax rate specified in section 2001(c) of the Code in effect on the d"
- [Federal Register: Guidance Under Section 2801 (final regulations, TD 10027)](https://www.federalregister.gov/documents/2025/01/14/2025-00284/guidance-under-section-2801-regarding-the-imposition-of-tax-on-certain-gifts-and-bequests-from), read 2026-11-07: "recipient during the calendar year by the dollar amount of the per-donee exclusion in effect under section 2503(b) for that calendar year ($18,000 in 2024) (section 2801(c) amount), and then multiplying the net amount by the highest estate or gift tax rate in effect during that calendar year (40 percent in 2024)."
- [Internal Revenue Bulletin 2009-45 (Notice 2009-85)](https://www.irs.gov/irb/2009-45_IRB), read 2026-11-07: "The covered expatriate must notify the payor of his or her covered expatriate status by submitting Form W-8CE to the trustee on the earlier of (1) the day prior to the first distribution on or after the expatriation date or (2) 30 days after the expatriation date. Section 877A(g)(1)(C) provides that in the case of any covered expatriate who is subject to tax as a citizen or resident of the United"

## Read in full, publishes no figure

- [IRS Instructions for Form 8854 (current revision)](https://www.irs.gov/instructions/i8854), read 2026-09-12: every candidate on the page was refused
- [IRS Expatriation tax](https://www.irs.gov/individuals/international-taxpayers/expatriation-tax), read 2026-10-10: every candidate on the page was refused
- [26 U.S.C. 2801 (LII republication)](https://www.law.cornell.edu/uscode/text/26/2801), read 2026-09-19: 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). 3 of the 6 named sources that could be read published a usable figure; 3 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 in USD (a source's median where its page yielded several accepted sentences), so N counts sources, never sentences; 44 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 charging rule - deemed sale, eligible deferred compensation, ineligible deferred compensation, specified tax-deferred account, non-grantor trust, the deferral election with its security and treaty waiver, and the section 2801 succession tax on the recipient - each with its rate, its base and its authority quoted verbatim with the effective date. The derivation is the JOIN nobody publishes: the total charge on one asset mix computed across all seven rules at once, which is what a calculator is, plus the second-order figure - what the same estate costs a US heir under section 2801 after expatriation versus before - that appears in no single IRS document.

## Sources

- [Internal Revenue Bulletin 2009-45 (Notice 2009-85)](https://www.irs.gov/irb/2009-45_IRB) (the publisher's own terms; quoted for reporting and comment)
- [IRS Instructions for Form 708 (United States Return of Tax for Gifts and Bequests Received From Covered Expatriates)](https://www.irs.gov/instructions/i708) (the publisher's own terms; quoted for reporting and comment)
- [Federal Register: Guidance Under Section 2801 (final regulations, TD 10027)](https://www.federalregister.gov/documents/2025/01/14/2025-00284/guidance-under-section-2801-regarding-the-imposition-of-tax-on-certain-gifts-and-bequests-from) (the publisher's own terms; quoted for reporting and comment)
- [IRS Instructions for Form 8854 (current revision)](https://www.irs.gov/instructions/i8854) (the publisher's own terms; quoted for reporting and comment)
- [IRS Expatriation tax](https://www.irs.gov/individuals/international-taxpayers/expatriation-tax) (the publisher's own terms; quoted for reporting and comment)
- [26 U.S.C. 2801 (LII republication)](https://www.law.cornell.edu/uscode/text/26/2801) (the publisher's own terms; quoted for reporting and comment)

## Cite or embed

- The Exit Tax Computation Rules carries 3 published figures read from 3 sources' own pages, from 18,000 to 600,000 USD, read 7 November 2026.
- 3 of the 6 named sources read in full publish a figure; 3 publish none, read 7 November 2026.
- Exit Tax Computation Rules, rule section 2801 annual exclusion (2025): median 18,000 USD across 1 source, read 7 November 2026.
- Exit Tax Computation Rules, rule section 2801 succession tax rate: median 40 percent across 1 source, read 7 November 2026.
- Exit Tax Computation Rules, rule deemed sale exclusion amount (2009): median 600,000 USD across 1 source, read 7 November 2026.
- Exit Tax Computation Rules, rule eligible deferred compensation withholding: median 30 percent across 1 source, read 7 November 2026.
- Exit Tax Computation Rules, rule section 2801 annual exclusion (2026): median 19,000 USD across 1 source, read 7 November 2026.

Cite as: "expatriationtaxcalculator.com Exit Tax Computation Rules", updated 2026-11-08, https://expatriationtaxcalculator.com/datasets/exit-tax-computation-rules/.

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