Guide

The 877A exclusion amount for 2026: $910,000

Updated

The exit tax is not charged on your whole deemed gain. A fixed slice comes off first, and how that slice is spread across your assets changes the answer.

Talk to a specialist The expatriation date decides the year, the year decides the exclusion.

$

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

$

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

$

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

%

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.

Covered expatriate statusCovered 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 gain16.36%

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How this calculator works
  • The three covered expatriate tests are in section 877(a)(2), applied by section 877A(g)(1). First, net worth of $2,000,000 or more (a fixed statutory figure, not inflation adjusted). Second, average annual net income tax above an inflation-adjusted amount. Third, 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 rate is an input, not computed. Section 877A sets no rate: the deemed gain joins gross income under normal rules, so asset character matters. Long-term gains top out at 20% (IRS Topic 409), collectibles at 28%, unrecaptured section 1250 gain at 25%. Net investment income tax may also apply. Take advice before relying on one 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).

The 2026 figure

For taxable years beginning in 2026, the amount includible in a covered expatriate's gross income under section 877A(a)(1) is reduced by $910,000, but not below zero (Rev. Proc. 2025-32 s4.38). The statutory base is $600,000, adjusted for inflation each year since 2008 and rounded to the nearest $1,000 (section 877A(a)(3)).

Exclusion amount by year, as published by the IRS
YearExclusion amountSource
2025$890,000IRS expatriation tax page
2026$910,000Rev. Proc. 2025-32 s4.38

The IRS expatriation tax page had not been updated with the 2026 figures when this page was last checked. Rev. Proc. 2025-32 is the primary source for a 2026 expatriation date, and it is the one we compute from.

How the exclusion is allocated

It is not simply subtracted from the total. Section 3.C of Notice 2009-85 requires the exclusion to be allocated pro rata to each item of built-in gain property. Each asset's share is the exclusion times the ratio of its built-in gain to the total built-in gain of all gain assets. No asset's share can exceed its built-in gain.

That matters when you elect to defer the tax on some assets and not others under section 877A(b), because the exclusion has already been spread before the election is made. It also means the total charge is the same whether you hold one asset or twenty, but the per-asset numbers on Form 8854 are not.

Once in a lifetime

Notice 2009-85 states that each individual is eligible for only one lifetime exclusion amount. A covered expatriate may later become a US citizen or long-term resident again and expatriate a second time. The exclusion on that second expatriation is limited to the unused portion of the first.

Deferring the tax

Section 877A(b) allows an irrevocable election to defer payment of the mark-to-market tax, property by property, until that property is disposed of. Notice 2009-85 sets the conditions:

  • The taxpayer must furnish a bond or other security acceptable to the Commissioner, conditioned on payment.
  • Interest is charged for the deferral period at the section 6621 rate applicable to individual underpayments.
  • The taxpayer must also waive treaty rights that would prevent collection.

Want this reviewed by a cross-border tax adviser?

Tell us roughly where you stand and we will introduce you to up to three firms, each a US expatriation tax specialist who handles section 877A matters.

Next: where to reach you.

  • Free, no obligation
  • Your details go to at most three advisers
  • No marketing lists, ever

Questions, answered directly

What is the exit tax exclusion amount for 2026?

$910,000. Rev. Proc. 2025-32 section 4.38 sets the section 877A(a)(3) exclusion at $910,000 for taxable years beginning in 2026, up from $890,000 for 2025.

Can I use the exclusion twice?

No. Notice 2009-85 states each individual is eligible for only one lifetime exclusion amount. On a second expatriation you get only the unused balance of the first.

Sources

This site's own datasets, every figure quoted from its source and dated:

  • 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.
  • The Departure Tax by Country carries 5 published figures read from 2 sources' own pages, from 16 to 365 day, read 7 November 2026.
  • 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.
  • The Expatriation Filing and Fees carries 4 published figures read from 2 sources' own pages, from 450 to 2,350 USD, read 7 November 2026.
  1. IRS. Expatriation tax
  2. IRS. Rev. Proc. 2025-32, 2026 inflation-adjusted items, sections 4.37 and 4.38
  3. IRS. Instructions for Form 8854
  4. IRS. Notice 2009-85, guidance for expatriates under section 877A
  5. 26 U.S. Code section 877A, tax responsibilities of expatriation
  6. 26 U.S. Code section 877, expatriation to avoid tax
  7. IRS. Topic no. 409, capital gains and losses
  8. IRS. Relief procedures for certain former citizens

Model the charge before you set a date

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

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