Form 8854 (Initial and Annual Expatriation Statement)

The IRS form that US citizens renouncing citizenship and long-term green-card holders ending residency must file in the year of expatriation. Establishes whether the expatriating individual is a 'covered expatriate' under IRC §877A and reports the §877A mark-to-market exit-tax computation. Form 8854 is filed alongside the final dual-status year tax return (Form 1040 + Form 1040-NR). Failure to file timely automatically classifies the expatriating individual as a covered expatriate, triggering the exit tax regardless of whether the wealth or income tests would otherwise be met. Key dates: the certification of 5-year tax compliance is the most-litigated element; missing tax filings in the prior 5 years can default the individual into covered status.