How does the mark-to-market exit tax actually work? What assets are included and what's the exclusion?
I'm a covered expatriate with a net worth around $3.5 million, including my LLC, a house in California, stock investments, and some cryptocurrency. If the IRS treats me as if I sold everything the day before I expatriate, how exactly is the tax calculated? Is there an exemption? What about my house — I'm not actually selling it. And what about my crypto? This all seems incredibly complicated.
Related Questions
What is the U.S. expatriation tax (exit tax) and who does it apply to?
I've been a U.S. green card holder for 12 years and I own a profitable LLC. I'm considering renouncing my green card and moving back to my home country permanently. A friend told me there's an 'exit t...
What happens to my 401(k) and deferred compensation when I expatriate?
I have about $800,000 in my 401(k), $200,000 in a traditional IRA, and I'm owed about $300,000 in deferred compensation from my former employer. I'm surrendering my green card next year. My tax attorn...
I'm renouncing U.S. citizenship. What is Form 8854 and the exit tax?
I've been a dual citizen (U.S. and Australia) my whole life but have lived in Australia since I was 5. I've decided to renounce my U.S. citizenship because the annual filing obligations and FATCA repo...
What is a PFIC and how does it affect U.S. persons investing in foreign companies?
I'm a U.S. citizen and I hold shares in a foreign investment fund that a friend recommended. I just learned about something called PFIC — Passive Foreign Investment Company — and the penalties for not...
My father was a non-resident alien who owned U.S. real estate. Do we need to file Form 706-NA?
My father recently passed away. He was a citizen of Mexico and never lived in the U.S., but he owned a vacation condo in Texas worth about $400,000. He also had a U.S. brokerage account with about $15...
What is Previously Taxed Income (PTI) and how does IRC 959 work for CFC distributions?
My CFC has been operating for several years and I've been including Subpart F and GILTI income on my U.S. tax return. Now the CFC is about to distribute a large dividend. My understanding is that I sh...
What is Subpart F income and how does it apply to foreign-owned business structures?
I've been reading about Subpart F income in the context of CFC rules and I'm confused about how it fits in with GILTI. I'm a U.S. citizen running a business through a foreign corporation. Some of the ...
Do I owe Australian CGT if I sell my U.S. LLC membership interest?
I've been running my U.S. LLC for three years and I'm considering selling a 50% membership interest to a business partner. The LLC has appreciated significantly in value. Will Australia tax the capita...
What is the Base Erosion and Anti-Abuse Tax (BEAT) and who does it affect?
Our company is a U.S. subsidiary of a large foreign multinational. Our CFO mentioned we might be subject to something called BEAT — the Base Erosion Anti-Abuse Tax. I looked it up and it seems very co...
I sold a small U.S. business on a note while living abroad. Does Form 6252 still work if I am a foreign seller and the deal included goodwill, equipment, and inventory?
I am based in Germany and sold a U.S. e-commerce business for about $310,000. The buyer paid $60,000 at closing and signed a three-year note for the rest. The deal included brand goodwill, a customer ...
Have a similar question?
ForeignLLCTax members get expert answers with IRS citations. One CPA consultation costs $200+. Full access is $9.99/month.
Become a Member — $9.99/moDisclaimer: All content on ForeignLLCTax.com is created by a tax professional and is provided for general educational and informational purposes only. It does not constitute tax, legal, or accounting advice, and should not be relied upon as such. Every tax situation is different — for advice specific to your circumstances, please consult a licensed CPA, Enrolled Agent, or tax attorney. By using this website, purchasing a subscription, or accessing any tools or services, you acknowledge that no client-professional relationship is established between you and ForeignLLCTax.com or its operators. This website is not affiliated with the IRS.
