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Expatriation & exit tax

Renouncing citizenship or handing back a Green Card: covered expatriate tests, exit tax modelling and Form 8854.

Tower Bridge and the City of London at dusk

Leaving the system without paying more than the exit costs.

Renouncing citizenship or surrendering a long-held Green Card is a tax event. Handled carelessly it triggers a deemed sale of everything you own.

Planned properly, most people leave cleanly.

What we do

01

Covered expatriate testing

The net worth, tax liability and compliance tests that decide whether the exit tax applies at all.

02

Exit tax modelling

What a deemed disposal would actually cost, before any appointment is booked.

03

Pre-exit planning

Steps that can change the outcome, which almost all have to happen before you renounce.

04

Form 8854

The expatriation statement, plus the final-year return that has to accompany it.

Why us

Timing decides the bill

Almost every lever here operates before expatriation. Afterwards, the position is fixed.

Anyone considering renunciation should model it a year out rather than a month out.

When it comes to questions that cross two tax systems, you need specialists who work in both every day. Meet the team that make it happen.

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Frequently asked

Will I have to pay an exit tax?

Only if you are a covered expatriate under one of three tests. Many people are not, but compliance failures alone can make you one.

Does giving up a Green Card count?

It can. Long-term residents — broadly, Green Card holders for eight of the last fifteen years — are treated much like citizens on exit.

Who is a covered expatriate?

Someone meeting a net worth test, an average tax liability test, or who cannot certify five years of compliance. Any one of the three is enough.

What does the exit tax charge?

A deemed sale of worldwide assets on the day before expatriation, with an exemption amount, plus specific treatment for pensions and deferred compensation.

Does it apply to green card holders?

To long-term residents, yes — broadly those holding the card for eight of the last fifteen years. Surrendering the card can trigger it exactly as renouncing would.

Can I renounce if I am not up to date?

You can renounce, but failing to certify five years of compliance makes you a covered expatriate regardless of your wealth. Catching up first is usually the cheaper order.

Renouncing citizenship or handing back a Green Card: covered expatriate tests, exit tax modelling and Form 8854.

Key contact

Tell us what you are trying to solve and we will put the right specialist on the call.

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Your situation

None of this is required, but it lets us put the right specialist on your reply instead of asking these questions back.

How can we help?

Please do not send tax reference numbers or documents yet — we will agree a secure route first.

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