Form 8938 versus FBAR threshold checker
Test your foreign assets against both US reporting thresholds at once.
Open itThree tests decide whether renouncing citizenship or surrendering a green card triggers a mark-to-market charge, and failing any one of them is enough. Enter your figures and this names the tests you fail and estimates the charge.
Your position at the expatriation date
US$
Worldwide assets less liabilities, valued on the day. Interests in trusts and pensions are included on their own rules.
US$
Two million dollars, and it is not indexed. Editable in case it changes.
US$
Net income tax, not income and not tax paid. Take it from the five returns.
US$
The indexed figure for 2025. Change it to the figure for your own expatriation year.
Untick if any of the five years is unfiled or incorrect. This test alone makes you covered, whatever your net worth.
US$
Market value less basis across everything, as if sold the day before expatriation.
US$
The indexed figure for 2025. Change it to the figure for your own year.
%
Blend of the capital gains rate and the investment income surtax where it applies. Your own figure.
Estimated mark-to-market charge
—
Status —
Covered expatriate —
Net worth test —
Average tax test —
Certification test —
Headroom below the net worth threshold—
Headroom below the average tax threshold—
Net unrealised gain—
Exclusion—
Taxable gain—
Charge at the rate you entered—
Effective rate on the whole gain—
Tests failed—
Which tests were failed
- Enter your figures above and this fills in.
Any one of three, and the third has nothing to do with money
You are a covered expatriate if your net worth reaches two million dollars, or your average annual net income tax over the five preceding years exceeds the indexed threshold, or you cannot certify five years of full tax compliance. They are alternatives, not a cumulative test, and the third one has no dollar figure attached at all.
That third test is the one that catches people who are nowhere near the money thresholds. An expatriate of modest means with two unfiled years is a covered expatriate, and the mark-to-market charge applies to their whole unrealised gain. Fixing the filing history before the expatriation date is therefore usually the cheapest planning available.
What the charge actually reaches
A covered expatriate is treated as having sold everything they own the day before expatriating, at market value. The net gain across all property is reduced by an indexed exclusion and the remainder is taxable. Deferred compensation, specified tax-deferred accounts and interests in non-grantor trusts each follow their own rules rather than the mark-to-market one, so the estimate here covers ordinary property only.
Both money thresholds move: the average tax figure and the exclusion are indexed annually, and the prefilled values here are the 2025 figures. Change them to the ones for your own expatriation year before relying on the output. The two-million net worth figure is statutory and is not indexed.
Worked example
A long-term green card holder with a net worth of 1.8 million dollars, average annual net income tax of 190,000 over the five preceding years, and 1.4 million of net unrealised gain.
- Net worth is under two million and the average tax is under the indexed threshold, so both money tests pass.
- If she can certify five years of compliance, she is not a covered expatriate and no charge arises.
- Untick the certification box and she becomes covered on that ground alone. The 1.4 million gain, less the exclusion, becomes taxable.
The swing between those two states, on the same assets, is the entire argument for cleaning up the filing history first.
What this calculator assumes
- The two-million net worth figure is statutory and unindexed. The average tax threshold and the exclusion are indexed annually and are prefilled with the 2025 figures — change them to the ones for your year.
- Deferred compensation, specified tax-deferred accounts and non-grantor trust interests follow separate rules and are not modelled here.
- Certain dual citizens from birth and certain people who expatriate before a specified age are outside the money tests. This tool does not test those exceptions.
- An election to defer the charge against security exists. It is not modelled, and it comes with interest and a waiver of treaty benefits.
An estimate, not advice. This is an estimate built from what you typed, not advice on your file. Nothing here reads your documents, checks your treaty article or looks at the year you are actually in. Where the number matters, we agree a fixed fee in writing before any work starts.
Where these figures come from
- current guidance Expatriation tax — IRS
- 2025 instructions Instructions for Form 8854 — IRS
- current guidance Relief procedures for certain former citizens — IRS
Any figure prefilled in the panel above is stated with the year it belongs to and can be changed. Rates and thresholds move; a calculator that asks you for the current one stays right, and one that hides a guess does not.
Files that look like this one
Case study 1
Covered expatriate status assessed before a client renounced US citizenship
A client considering renouncing US citizenship needed to understand whether they would be classified as a covered expatriate before proceeding, given the significant exit-tax consequence that classification carries. We reviewed the client's net worth, tax liability history and compliance certification against the relevant tests, and the client proceeded with a clear understanding of their status and its consequence.
Case study 2
Exit-tax exposure modelled for a client close to the covered expatriate thresholds
A client's net worth sat close to the threshold that would trigger covered expatriate status, and they wanted to understand whether steps taken before expatriation could affect the outcome. We modelled the client's position against the relevant tests, and the client made an informed decision about the timing of their expatriation relative to their asset position.
Case study 3
Compliance certification reviewed to avoid inadvertent covered expatriate status
A client who otherwise fell below the net-worth and tax-liability thresholds was at risk of covered expatriate status solely through a compliance certification requirement they had not addressed. We reviewed the client's filing history against the certification requirement, helped bring any outstanding items current, and the client avoided the classification on that basis.
Case study 4
A Group File That Had to Describe the Whole Group
The master file is a picture of the business rather than of one company, and it has to agree with what each local file says. Assembling it surfaces inconsistencies between entities that nobody had compared.
Read how this one runs
Case study 5
Gains on Indian Shares Held From Abroad
Holding period and instrument decide the character of the gain, and the deduction at source applies before any of that is considered. The return is where the position is corrected.
Read how this one runs
Case study 6
The Year of Leaving India
The departure year carries a transition status with its own treatment of foreign income, and the position for the following years follows from how it is set. Getting the first year right saves arguing about the rest.
Read how this one runs
Case study 7
Selling Into the US Without an Entity, and Filing in Several States
State obligations are set by each state, and a treaty does not reach them. The review measures activity against each state's own thresholds and separates the states where registration is required from the ones where it is not.
Read how this one runs
Case study 8
Interest and Penalties Put to a Relief Application
Relief is discretionary and is decided on the circumstances that caused the delay, evidenced year by year. The application is built from the same chronology the filings rest on, so the two cannot contradict each other.
Read how this one runsAll case studies — every published engagement in one place.
Core International & Cross-Border Tax Services
International Tax Planning & Advisory
Strategy and compliance for income, assets and families spread across borders.
One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.
U.S. & Cross-Border Tax Returns
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.
Expat & Emigration Tax
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.
Non-Resident Canadian Tax
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.
Transfer Pricing & BEPS
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.
Tax Treaties & Withholding
Relief is only as good as the paperwork claiming it — we build treaty positions that survive review on both sides.
Cross-Border Estates & Trusts
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.
Global Investments & Reporting
Information returns carry the sharpest penalties — $25 a day whether or not any tax is owing. We keep them clean and on time.
Cross-Border Corporate Tax
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.
India Tax for NRIs & Returning Residents
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.
Canadian Tax with a Foreign Element
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.
UAE Tax for Expats & Their Home Country
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.
Industries & Client Types We Serve Worldwide
Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies
Global E-commerce & Marketplaces
- Foreign VAT / GST / sales tax registrations
- Marketplace withholding reviews
- Inventory nexus & PE analysis
- Multi-currency books reconciled
Who We Serve:
Technology & SaaS
- Cross-border revenue sourcing & withholding
- IP structuring with real substance
- Equity for cross-border teams
- U.S. expansion: entity & PE setup
Who We Serve:
Professional Services Firms
Firms and partners working across borders meet Regulation 105 withholding, PE risk on long engagements and per-country payroll for travelling staff.
A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
- Reg 105 / 102 waivers
- Permanent establishment risk
- Partner mobility planning
- Cross-border withholding recovery
Who We Serve:
Cross-Border Real Estate
- Section 216 rental returns
- FIRPTA withholding recovery
- Section 116 clearance
- Treaty credit optimization
Who We Serve:
Importers, Exporters & Manufacturers
- Transfer pricing documentation (s.247)
- Customs value vs transfer price
- Foreign affiliate reporting (T1134)
- Country-by-country reporting
Who We Serve:
Athletes, Artists & Entertainers
- Reg 105 & U.S. CWA agreements
- Multi-state & country calendars
- Touring income allocation
- Royalty & image-rights withholding
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Remote Workers & Digital Nomads
- Residency analysis before moving
- Employer payroll exposure
- Totalization & social security
- Foreign tax credits
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Investment Funds & Holding Companies
- Treaty access & PPT reviews
- FAPI & surplus computations
- Withholding-efficient routing
- Governance & substance
Who We Serve:
