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Exit Tax Planning Strategies: How to Reduce Taxes Before Renouncing U.S. Citizenship

April 28, 2026

Giving up your U.S. citizenship or your green card residency status can result in a hefty tax bill. Here’s what you need to know about the exit tax and how advanced planning can help you avoid it.

Quick Takeaways

  • The U.S. exit tax can apply when U.S. Citizens renounce their citizenship and when green card holders that are long-term residents give up their green cards; potentially resulting in triggering tax on unrealized worldwide gains.
  • The tax applies if your income, net worth, or prior tax compliance meets certain thresholds.
  • Advance planning, such as managing income timing, reducing net worth, and ensuring U.S. tax compliance for the prior 5 years can significantly limit or avoid exit tax exposure.
  • Proper tax compliance and professional guidance are critical, as exit tax planning often requires years of preparation.

Why It Matters 

When the tax applies, all your worldwide property will be deemed sold for fair market value on the day before the termination date. If total gains exceed an exclusion amount, they’re generally subject to the 15% to 20% for capital gains tax (and possibly the 3.8% net investment income tax) and ordinary income tax rates for ordinary income property. The inflation-adjusted exclusion amount for 2026 is $910,000. 

Will You Be Hit with the Exit Tax?

The exit tax is a one-time tax on worldwide unrealized gains. The tax applies to a “covered expatriate.” A covered expatriate is a U.S. citizen who relinquish citizenship, or a “long-term resident” who terminate their green card status and meets certain criteria”

Long-term residents are generally those who have been lawful permanent U.S. residents for at least eight of the previous 15 tax years ending with the tax year in which they give up their green card status. 

The criteria for a covered expatriate status is met if any of the following three tests are met on the date of expatriation:  

  • Your average annual net income tax for the five years ending before the termination of residency is $211,000 or higher for 2026 (adjusted annually for inflation),
  • Your net worth is $2 million or more on the date you terminate residency, or
  • You don’t certify on IRS Form 8854 that you’ve complied with all U.S. federal tax obligations for the five years preceding the termination.

How Can You Minimize Your Exposure?

The best way to avoid exit tax liability is to steer clear of the three triggers described above. For instance, you could make strategic moves to reduce your average annual net income. Possible income-reduction strategies include deferring income until after your termination date (for example, hold off on selling your business or exercising stock options) and accelerating deductions. 

Alternatively, making gifts to charities or to friends or family could reduce your net worth below the $2 million threshold. When transferring U.S.-based assets to individuals, though, you’ll need to evaluate the gift tax implications and timing. Transfers to irrevocable trusts can trim your net worth, too.

Even if you fall under the net income and net worth thresholds for the exit tax, failing to comply with all your federal tax obligations during the prior five years could leave you liable. Before terminating residency, ensure that you’ve filed complete federal tax returns for those years. If the total value of your foreign financial accounts exceeded $10,000 at any point during those calendar years, you also should have submitted Foreign Bank and Financial Account Reports (FBARs). It is important to note that there are many other forms that could apply. 

A detailed filing analysis may be required. If you’ve missed filing deadlines, you may qualify for relief under Streamlined Filing Compliance Procedures or IRS voluntary disclosure programs.

Don’t Go It Alone

Clearly, terminating your residency shouldn’t be a hasty decision. It can take years to implement the necessary steps to preempt an exit tax bill. 

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John Trejo

John Trejo, CPA

Manager, International Tax Services

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