Section 877A can treat your worldwide property as sold the day before you leave — whether or not you actually sell anything. Three tests decide whether it applies to you at all.
This is a screening, not a calculator: it tells you which test is triggered and why, quoted from the statute itself. It does not compute what you would owe — that needs the fair market value of your specific assets, which no tool can establish reliably.
Triggered if your average annual net income tax for the 5 years before expatriation exceeds $211,000 (2026 figure, adjusted annually from a $124,000 base — 26 U.S.C. § 877 (1/10)).
Triggered if your net worth is $2,000,000 or more — fixed by statute, not inflation-adjusted (26 U.S.C. § 877 (1/10)).
Triggered by failing to certify, under penalty of perjury, 5 years of US tax compliance (Form 8854) — 26 U.S.C. § 877 (1/10). This alone is enough, regardless of wealth or income.
Knowing which test is triggered is the frame. Inside it sit the fair market value of each asset, the deferral election's conditions, Form 8854 itself, and whatever your destination country does with the same facts. That is what the paid assistant is for — over a corpus of more than a million sourced provisions.
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