Form 8854

Department of the Treasury 

Internal Revenue Service

Initial and Annual Expatriation Statement

For calendar year 2019 or other tax year beginning , 2019, and ending , 20 

▶ Go to www.irs.gov/Form8854 for instructions and the latest information. ▶ Please print or type.

OMB No. 1545-0074

2019

Attachment 

Sequence No. 112

Name Identifying number (see instructions)

 General Information. Part I For all filers.

1 Mailing address and telephone number where you can be reached after expatriation

2 Address of principal foreign residence (if different from line 1)

3 Country of tax residence (if different from line 2)

4 Check the box that applies. See instructions.

Initial expatriation statement for persons who expatriated in 2019. Complete Part II.

Annual expatriation statement for persons who expatriated before 2019. Complete Part III.

5 Date of expatriation under section 877A(g)(3) for expatriating citizens and long-term residents. See instructions.

Citizen 

Long-term resident 

Long-term resident with dual residency in a treaty country. Date commencing to be treated, for tax purposes, as a 

resident of the treaty country

6 List all countries (other than the United States) of which you are a citizen. 

a Name of country

b Date you became a citizen of each country listed in line 6a

7 How you became a U.S. citizen By birth By naturalization

8 Date you became a U.S. lawful permanent resident

Part II Initial Expatriation Statement for Persons Who Expatriated in 2019

Section A Expatriation Information

1 Enter your U.S. income tax liability (after foreign tax credits) for the 5 tax years ending before the date of expatriation.

1st Year 

Before Expatriation

$

2nd Year 

Before Expatriation

$

3rd Year 

Before Expatriation

$

4th Year 

Before Expatriation

$

5th Year 

Before Expatriation

$

2 Enter your net worth on the date of your expatriation for tax purposes . . . . . . . . . . $

 3 Did you become at birth a U.S. citizen and a citizen of another country, and do you continue to be a citizen 

of, and taxed as a resident of, that other country? . . . . . . . . . . . . . . . . . . . Yes No

4 If you answered “Yes” to question 3, have you been a resident of the United States for not more than 10 of

the last 15 tax years? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

5 Were you under age 181/2 on the date you expatriated and have you been a U.S. resident for not more than 

10 years? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

6 Do you certify under penalties of perjury that you have complied with all of your tax obligations for the 5 

preceding tax years? See instructions . . . . . . . . . . . . . . . . . . . . . . . Yes No

For Paperwork Reduction Act Notice, see the separate instructions. Cat. No. 24126N Form 8854 (2019)
Form 8854 (2019) Page 2

Section B Balance Sheet

List in U.S. dollars the fair market value and the U.S. adjusted basis of your assets and liabilities as of your expatriation date. For more 

details, see the separate instructions.

Assets (a) Fair market 

value (FMV)

(b) U.S. adjusted 

basis

1 Cash, including bank deposits . . . . . . . . . . .

2 Marketable stock and securities issued by U.S. companies .

3 Marketable stock and securities issued by foreign companies

4 Nonmarketable stock and securities issued by U.S. companies 

5 Nonmarketable stock and securities issued by foreign companies

a Separately state stock issued by foreign companies that would 

be controlled foreign corporations if you were still a U.S. citizen 

or permanent resident. See instructions . . . . . . . .

b 

 

Provide the name, address, and EIN, if any, of any such company

6 Pensions from services performed in the United States . . .

7 Pensions from services performed outside the United States .

8 Partnership interests. See instructions . . . . . . . .

9 Assets held in trust. See instructions . . . . . . . . .

10 Beneficial interests in trusts not included in line 9. See instructions

11 Intangibles used in the United States . . . . . . . . .

 12 Intangibles used outside the United States . . . . . . .

 13 Loans to U.S. persons . . . . . . . . . . . . . .

14 Loans to foreign persons . . . . . . . . . . . . .

 15 Real property located in the United States . . . . . . .

 16 Real property located outside the United States . . . . .

17 Business property located in the United States. . . . . .

18 Business property located outside the United States . . . .

19 Other assets. See instructions . . . . . . . . . . .

20 Total assets. Add lines 1 through 5 and lines 6 through 19. Don’t 

include amounts on line 5a in this total . . . . . . . .

Liabilities Amount

21 Installment obligations. . . . . . . . . . . . . .

22 Mortgages, etc. . . . . . . . . . . . . . . . .

23 Other liabilities. See instructions . . . . . . . . . .

24 Total liabilities. Add lines 21 through 23 . . . . . . . .

25 Net worth. Subtract line 24 from line 20, column (a) . . . .

Form 8854 (2019)
Form 8854 (2019) Page 3

Section C Property Owned on Date of Expatriation

Don’t complete Section C if: 

• Your average net income tax liability for the 5 tax years immediately before expatriation (see line 1 in Section A) wasn’t more 

than $168,000, your net worth (see line 2 in Section A) was under $2 million, and you checked “Yes” on line 6 in Section A;

• In Section A, you checked “Yes” on lines 3, 4, and 6; or

• In Section A, you checked “Yes” on lines 5 and 6. 

1a Do you have any eligible deferred compensation items? Checking the “Yes” box is an irrevocable waiver 

of any right to claim any reduction in withholding for such eligible deferred compensation item under any 

treaty with the United States . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

b Do you have any ineligible deferred compensation items? If “Yes,” you must include in income the

present value of your account on the day before your expatriation date . . . . . . . . . . . . Yes No

c Do you have any specified tax deferred accounts? If “Yes,” you must include in income the entire 

account balance on the day before your expatriation date . . . . . . . . . . . . . . . . . Yes No

d Do you have an interest in a nongrantor trust? Checking the “Yes” box is a waiver of any right to claim 

any reduction in withholding on any distribution from such trust under any treaty with the United States 

unless you make the election below . . . . . . . . . . . . . . . . . . . . . . . . Yes No

Check this box to elect under section 877A(f)(4)(B) to be treated as having received the value of your entire interest in the 

trust (as determined for purposes of section 877A) as of the day before your expatriation date. Attach a copy of your 

valuation letter ruling issued by the IRS. See instructions.

2 Recognition of gain or loss on the deemed sale of mark-to-market property. Caution: Don’t include in column (a) any 

property described on line 1a, 1b, 1c, or 1d. 

Complete column (g) only if you are deferring tax on gain from any property listed in column (a).

(a) 

Description of property

(b) 

Fair market value

on day before date

of expatriation

(c) 

Cost or other

basis*

(d) 

Gain or (loss). 

Subtract (c) 

from (b)

(e) 

Gain after

allocation of the

exclusion amount

(see instructions)

(f) 

Form or Schedule

on which gain

or loss is reported

(g) 

Amount of tax

deferred (attach

computations)

3 Total. Add the amounts in column (d) and column (e) . . .

4 Total tax deferred. Add the amounts in column (g). Enter here 

and on Part II, Section D, line 5 . . . . . . . . .

* You must identify as “(h)(2)” any property for which you are making the special basis election under section 877A(h)(2). This election is irrevocable. 

See the instructions for Part II, Section C, line 2, column (c).

Form 8854 (2019)
Form 8854 (2019) Page 4 

Section D Deferral of Tax

Election to defer tax. You can defer tax only if you have provided adequate security. Adequate security is described 

in the instructions.

1 Are you electing to defer tax under section 877A(b)?

Checking the “Yes” box is an irrevocable waiver of any right under any treaty of the United States 

that would prevent assessment or collection of any tax imposed because of section 877A . . . . . . Yes No

If you checked the “Yes” box, continue to line 2. Otherwise, don’t complete lines 2 through 5.

2 Enter the total tax you would have reported, absent the deferral election, on Form 1040 or 

1040-SR, line 15, for the part of the year including the day before the expatriation date absent the

deferral election . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

3 Enter the total tax for the same part of the tax year determined without regard to the amounts 

attributable to section 877A(a). Attach computation . . . . . . . . . . . . . . . . 3

4 Subtract line 3 from line 2. This is the amount of tax eligible for deferral . . . . . . . . 4

5 Enter the total tax deferred from Part II, Section C, line 4, column (g) . . . . . . . . . . 5

• If you are filing Form 1040 or 1040-SR, enter this amount in brackets to the left of the entry 

space for line 15. Identify as “EXP.”

• If you are filing Form 1040-NR, enter this amount in brackets to the left of the entry space for line

61. Identify as “EXP.”

Part III Annual Expatriation Statement for Persons Who Expatriated Before 2019

• If you made an election to defer the payment of tax, complete line 1.

• If you have an item of eligible deferred compensation, complete line 2.

• If you have an interest in a nongrantor trust, complete line 3.

1 Complete columns (a), (b), and (c) for all property on which you deferred tax on a prior year Form 8854. Complete column (d) 

for any property you disposed of in 2019 and see the instructions for Part III. 

(a) 

Description of property

(b) 

Amount of mark-to-market gain or 

(loss) reported on prior year 

Form 8854

(c) 

Amount of tax deferred on prior year 

Form 8854

(d) 

Date of disposition (if any) 

Form 8854 (2019)
Form 8854 (2019) Page 5 

Part III Annual Expatriation Statement for Persons Who Expatriated Before 2019 (continued)

2 Did you receive any distributions of eligible deferred compensation items for 2019? . . . . . . . . Yes No

If “Yes,” enter the amount of distribution(s) and amount withheld at source, if any, below.

Amount of distribution Amount withheld at source, if any 

1

2

3

3 Did you receive any distributions from a nongrantor trust for 2019? . . . . . . . . . . . . . . Yes No

If “Yes,” enter the amount of distribution(s) and amount withheld at source, if any, below.

Amount of distribution Amount withheld at source, if any 

1

2

3

Sign Here

Under penalties of perjury, I declare that I have examined this form, including accompanying schedules and statements, and to the 

best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than filer) is based on all information 

of which preparer has any knowledge.

Your signature Date

Paid 

Preparer 

Use Only

Print/Type preparer’s name Preparer’s signature Date Check if 

self-employed 

PTIN

Firm’s name ▶

Firm’s address ▶

Firm’s EIN ▶

Phone no. 

Form 8854 (2019)