Section 877A (US Mark-to-Market Exit Tax)

Internal Revenue Code §877A imposes a deemed-disposal exit tax on US 'covered expatriates' who renounce US citizenship or terminate long-term US permanent residence. Triggered when any of three tests is met: average annual net income tax above an inflation-adjusted threshold (~USD 201,000 for 2024), net worth at expatriation of USD 2 million or more, or failure to certify five years of US tax compliance on Form 8854. Covered expatriates are deemed to have sold all property at fair market value the day before expatriation; gains above an inflation-adjusted exclusion (~USD 866,000 for 2024) are taxable at applicable capital-gains rates. Specified tax-deferred accounts, deferred compensation, and certain trust interests receive special treatment. Form 8854 is the operative filing.