Free · cited to the IRS
Leaving the United States
Every other country on this site lets you stop being tax resident by leaving it. The United States does not. The obligation follows the passport, and the only door out is expatriation, which is priced and filed. This is the whole record, cited, before anyone personalises it for you.
- USD 2 million
- Net worth test
- Internal Revenue Service
- USD 890,000
- Exclusion amount, 2025
- Internal Revenue Service
- 8 of 15 years
- Green card, long-term
- Internal Revenue Service
- USD 10,000/yr
- Missing Form 8854
- Internal Revenue Service
Sources verified 2026-08-20
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Why moving does not end it
There is no departure date that stops the obligation and no set of ties to sever. For a citizen the status ends one way, and it is a deliberate legal act rather than a change of address.
Worldwide, always
A US citizen or resident alien is taxed on worldwide income from all sources and must report all taxable income and pay tax under the Internal Revenue Code, wherever they live. Moving is not an event the tax code recognises.
Internal Revenue Service
7 acts, with intent
INA Section 349 lists seven potentially expatriating acts. An act only counts if performed voluntarily and with the intention of relinquishing US nationality, and the outcome is a Certificate of Loss of Nationality rather than an automatic status change.
U.S. Department of State
The earliest of 4
For a citizen the expatriation date is the earliest of four events: renouncing before a diplomatic or consular officer, furnishing a statement of relinquishment, the State Department issuing a Certificate of Loss of Nationality, or a court cancelling a naturalisation certificate.
Internal Revenue Service
8 of 15 tax years
A green card is not outside this. You are a long-term resident if you were a lawful permanent resident in at least 8 of the last 15 tax years ending with the year you stop being treated as one, and a long-term resident who gives up that status is treated as expatriating.
Internal Revenue Service
The earliest of 4
For a long-term resident the date is the earliest of filing Form I-407 to abandon status, a final administrative or judicial determination of abandonment, a removal order, or beginning to be treated as resident of a treaty country without waiving the treaty benefits.
Internal Revenue Service
What the exit actually costs
Expatriation is a taxable event for anyone who meets one of three tests. The charge is not on what you sold. It is on what you owned on the day before you left.
Deemed sold, day before
IRC 877A imposes a mark-to-market regime: all property of a covered expatriate is deemed sold for its fair market value on the day before the expatriation date. Nothing has to change hands for the gain to be taxed.
Internal Revenue Service
USD 890,000
The gain the deemed sale would otherwise put in your income is reduced, but not below zero, by an exclusion amount. It was USD 600,000 in 2008 and is adjusted for inflation each year. For calendar year 2025 it is USD 890,000.
Internal Revenue Service
USD 206,000, 2025
First test: your average annual net income tax for the 5 years ending before expatriation is above an inflation-adjusted figure. It was USD 190,000 for 2023, USD 201,000 for 2024 and USD 206,000 for 2025. Note this is tax paid, not income earned.
Internal Revenue Service
USD 2 million
Second test: your net worth is USD 2 million or more on the date of expatriation or termination of residency. This figure carries no inflation adjustment, so it has caught steadily more people every year since 2008.
Internal Revenue Service
5 years certified
Third test, and the one with no dollar figure attached: you fail to certify on Form 8854 that you complied with all federal tax obligations for the 5 years preceding expatriation. Paperwork alone can make you a covered expatriate at any level of wealth.
Internal Revenue Service
Leaving is half the question.
Everything above is the published record, and it is true of anyone leaving the United States. The other half is yours alone: where you would go, which residence routes you actually qualify for, and then which of these rules bite your profile, in what order, and by when. That is your Exit Plan, and it starts from your free matches.
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What you have to file
Two filing regimes run alongside each other, on different dates, to different agencies. Missing either is expensive in its own right, separately from any tax owed.
Form 8854
Form 8854 is the initial and annual expatriation information statement. The initial one is attached to your income tax return and filed by that return's due date. Owing no tax does not remove the deadline.
Internal Revenue Service
USD 10,000/yr
Failing to file Form 8854 carries a penalty of USD 10,000 a year unless you can show reasonable cause. It is also the third covered-expatriate test, so the same omission can both fine you and change your tax status.
Internal Revenue Service
USD 10,000 aggregate
A US person must file an FBAR if their foreign financial accounts exceed USD 10,000 in aggregate at any time during the calendar year. It is a high-water mark across all accounts together, not a year-end balance and not a per-account figure.
Internal Revenue Service
FinCEN Form 114
The FBAR is FinCEN Form 114, filed electronically through FinCEN's BSA E-Filing System and not with your tax return. It is due April 15, with an automatic extension to October 15 if that date is missed.
Internal Revenue Service
June 15, automatic
Living abroad gets you an automatic two-month extension, to June 15 for a calendar-year filer, and Form 4868 can push it to October 15. The extension is on filing, and it does not stop the obligation existing.
Internal Revenue Service
The four that catch people
USD 2 million
Net worth of USD 2 million on the expatriation date makes you a covered expatriate on its own, with no inflation adjustment to the threshold.
Internal Revenue Service
USD 890,000
The deemed-sale gain is reduced by USD 890,000 for calendar year 2025. Everything above that is taxable in the year you go.
Internal Revenue Service
USD 206,000
Average annual net income tax above USD 206,000 for 2025, measured over the 5 years before you leave, is the first of the three tests.
Internal Revenue Service
USD 10,000/yr
Not filing Form 8854 costs USD 10,000 a year and can make you a covered expatriate regardless of your wealth.
Internal Revenue Service
What people get wrong about leaving the United States
- Wrong
Once I live abroad and pay tax there, I am done with the IRS.
The rule
A US citizen is taxed on worldwide income from all sources wherever they live, and must report it and pay under the Internal Revenue Code. Living abroad changes the filing calendar and nothing about the obligation.
Internal Revenue Service
- Wrong
The exit tax is a rich person's problem, so it will not touch me.
The rule
Two of the three covered-expatriate tests are financial and the third is not. Failing to certify five years of tax compliance on Form 8854 makes you a covered expatriate at any level of wealth.
Internal Revenue Service
- Wrong
Handing back a green card is an immigration formality, not a tax event.
The rule
If you held it in at least 8 of the last 15 tax years you are a long-term resident, and giving up that status is treated as expatriating. The same mark-to-market regime applies as to a citizen who renounces.
Internal Revenue Service
- Wrong
I can renounce by post, or my other citizenship does it automatically.
The rule
INA Section 349 requires an expatriating act performed voluntarily and with the intention of relinquishing US nationality, and the result is a Certificate of Loss of Nationality. Acquiring another citizenship is not by itself the end of the first.
U.S. Department of State
What people ask before they start
Do I have to keep filing a US return while I live abroad?
Yes. You are taxed on worldwide income from all sources and must report it wherever you live. Living abroad gives you an automatic two-month extension to June 15 for a calendar-year filer, and Form 4868 extends that to October 15.
Internal Revenue Service
What makes someone a covered expatriate?
Any one of three tests. Average annual net income tax over the 5 years before you go above USD 206,000 for 2025, net worth of USD 2 million or more on the date, or failing to certify five years of tax compliance on Form 8854.
Internal Revenue Service
What is the exit tax actually charged on?
All property of a covered expatriate is deemed sold at fair market value on the day before the expatriation date. The gain that would otherwise be included is reduced, but not below zero, by USD 890,000 for calendar year 2025.
Internal Revenue Service
Does giving up a green card trigger the same thing?
It can. A long-term resident is someone who was a lawful permanent resident in at least 8 of the last 15 tax years ending with the year they stop being treated as one, and giving up that status is treated as expatriating.
Internal Revenue Service
What is an FBAR and when is it due?
FinCEN Form 114, required when foreign financial accounts exceed USD 10,000 in aggregate at any point in the calendar year. It is filed through FinCEN's BSA E-Filing System rather than with your return, due April 15 with an automatic extension to October 15.
Internal Revenue Service
This is the general record. Your dates are what make it a plan.
Everything above is true of anyone leaving the United States, which is why it is free. What it cannot tell you is which of these applies to you, in what order, against your assets and the date you actually go. That sequencing is the Exit Plan, and it does not cover US persons yet. It opens to them once OmniFlag can cite the US exit rules.
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OmniFlag helps you research and plan. It is not a law firm or tax advisor and does not give legal or tax advice. Confirm anything you act on with a licensed professional before you file it.