# Expatriation Tax Calculator

> Exit tax calculator for 2026: the three covered expatriate tests, the $910,000 mark-to-market exclusion and the deemed sale charge under IRC section 877A.

## Key facts

- 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.

## Key pages

- [US exit tax calculators: what does the exit tax cost?](https://expatriationtaxcalculator.com/): the main tool, answer above the fold.
- [Am I a covered expatriate? The three tests for 2026](https://expatriationtaxcalculator.com/covered-expatriate-test/): 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](https://expatriationtaxcalculator.com/exit-tax-exclusion-amount/): 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](https://expatriationtaxcalculator.com/form-8854/): 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.
- [US section 877A exit tax by net unrealized gain, 2026](https://expatriationtaxcalculator.com/#data): original data table, updated 2026-08-15.
- [Full site content as markdown](https://expatriationtaxcalculator.com/llms-full.txt)

## Data

- US section 877A exit tax by net unrealized gain, 2026. Methodology: 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.
- Last updated: 2026-08-15. Every figure cites its source inline.
- Source: IRS. Expatriation tax: https://www.irs.gov/individuals/international-taxpayers/expatriation-tax
- Source: IRS. Rev. Proc. 2025-32, 2026 inflation-adjusted items, sections 4.37 and 4.38: https://www.irs.gov/pub/irs-drop/rp-25-32.pdf
- Source: IRS. Instructions for Form 8854: https://www.irs.gov/instructions/i8854
- Source: IRS. Notice 2009-85, guidance for expatriates under section 877A: https://www.irs.gov/pub/irs-drop/n-09-85.pdf
- Source: 26 U.S. Code section 877A, tax responsibilities of expatriation: https://www.law.cornell.edu/uscode/text/26/877A
- Source: 26 U.S. Code section 877, expatriation to avoid tax: https://www.law.cornell.edu/uscode/text/26/877
- Source: IRS. Topic no. 409, capital gains and losses: https://www.irs.gov/taxtopics/tc409
- Source: IRS. Relief procedures for certain former citizens: https://www.irs.gov/individuals/international-taxpayers/relief-procedures-for-certain-former-citizens

## Citation

Cite as: "US section 877A exit tax by net unrealized gain, 2026", Expatriation Tax Calculator, https://expatriationtaxcalculator.com/ (updated 2026-08-15).

## About

- Expatriation Tax Calculator is an 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.
- Operated by Ellul Solutions Ltd. Contact: enquiries@expatriationtaxcalculator.com