Tax preparation · checked 15 October 2026
PRE-LAUNCHThe tax review belongs before the oath.
The tax question is not simply whether you own more than a particular amount. The review also considers your prior US tax liability, your compliance history, the kind of assets you hold and the date on which expatriation occurs for tax purposes. A qualified US tax professional should resolve those questions before you commit to the consular step.
Published by Bitcoin Lawyer
In this guide6 sections
Three tests need separate answers.
The IRS describes three routes to covered-expatriate status. The financial tests and the compliance certification are separate; passing one does not answer the others. Limited exceptions exist for qualifying dual citizens at birth and certain minors, but they do not remove the need for the required compliance certification. Ask the tax professional to document whether an exception actually applies.
The figures below are for a 2026 expatriation. They are screening facts, not a calculation of tax due. For another year, use the applicable year’s primary IRS materials. The average-tax test concerns net income tax liability, not salary, turnover, total assets or the amount of tax withheld from a paycheck.
| 2026 test | Threshold or requirement |
|---|---|
| Average annual net US income tax | More than $211,000 across the five tax years before expatriation. |
| Net worth | $2 million or more on the expatriation date. |
| Compliance certification | Failure to certify on Form 8854 compliance with all federal tax obligations for the five preceding tax years. |
Source: IRS expatriation guidance and Revenue Procedure 2025-32, sections 3.37 and 3.38. Checked 15 October 2026.
A deemed sale is not the same as selling everything.
For a covered expatriate, the general mark-to-market regime treats relevant property as sold at fair market value on the day before expatriation. That can create a tax calculation without an actual sale producing cash. The 2026 exclusion amount is $910,000 of gain under the applicable rule. It is not an extra net-worth allowance, a blanket exemption for every asset or a promise that the first $910,000 of your portfolio is untaxed.
Deferred compensation, specified tax-deferred accounts and interests in nongrantor trusts have separate rules. This is why a useful review classifies assets before calculating a headline number. It must also consider funding for any liability and how subsequent transactions will be recorded. The appropriate treatment depends on the facts and the governing rules.
Give the tax professional evidence they can use.
Five-year filing history
Gather filed returns, relevant information returns, amendments and available tax records. Mark gaps explicitly. A missing document and an unfiled obligation are different problems; the professional needs to know which one exists before anyone certifies compliance.
Asset and liability schedule
List ownership, estimated value, acquisition date, cost basis and supporting documents. Include business interests, real property, pensions, trusts and digital assets. For Bitcoin, preserve acquisition and disposal records and reconcile transfers between your own wallets so they are not mistaken for unexplained purchases or sales.
Questions that change the analysis
Identify dual citizenship at birth, substantial US residence history, gifts or inheritances involving US persons, deferred compensation and complex ownership. Do not reorganize assets simply to change a screening result without advice: transfers can create their own legal, reporting and tax consequences.
The CLN and the tax file have different jobs.
The Certificate of Loss of Nationality documents the nationality determination. It is not a tax-clearance certificate. Confirm the relevant expatriation date, final return obligations and Form 8854 deadline with the tax professional. Any continuing filings should remain on a named calendar after the consular work ends.
A responsible coordinator keeps that calendar and the document requests aligned. The tax professional makes the tax determinations and prepares the work agreed in their engagement. While the US exit line is pre-launch, you may ask about preparation through the free contact route; no paid session is required to raise an initial question.
Before you decide
Common questions.
If I am below $2 million, can I skip the review?
No. The average-tax and compliance tests remain separate, and the filing obligations still need to be determined.
Does renunciation erase an existing tax debt?
No. Do not treat a nationality change as cancellation of existing liabilities or a substitute for resolving outstanding filings.
Your next step
Turn the guide into a working list.
US exit remains pre-launch. You can ask about the opening without paying for a session. A screening call can establish whether present planning work is suitable.