8854 Initial and Annual Expatriation Statement OMB No.

1545-0074

2020
Form
For calendar year 2020 or other tax year beginning , 2020, and ending , 20
Department of the Treasury ▶ Go to www.irs.gov/Form8854 for instructions and the latest information. Attachment
Internal Revenue Service ▶ Please print or type. Sequence No. 112
Name Identifying number (see instructions)

Part I General Information. 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 2020. Complete Part II.
Annual expatriation statement for persons who expatriated before 2020. 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 2020

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 2nd Year 3rd Year 4th Year 5th Year
Before Expatriation Before Expatriation Before Expatriation Before Expatriation 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 (2020)
Form 8854 (2020) 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 (b) U.S. adjusted

value (FMV) 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 (2020)
Form 8854 (2020) 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 $171,000, 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).
(e)
(a) (b) (c) (d) Gain after (f) (g)
Description of property Fair market value Cost or other Gain or (loss). allocation of the Form or Schedule Amount of tax
on day before date basis* Subtract (c) exclusion amount on which gain deferred (attach
of expatriation from (b) (see instructions) or loss is reported 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 (2020)
Form 8854 (2020) 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 24, 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 24. Identify as “EXP.”

• If you are filing Form 1040-NR, enter this amount in brackets to the left of the entry space for line
24. Identify as “EXP.”
Part III Annual Expatriation Statement for Persons Who Expatriated Before 2020
• 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 2020 and see the instructions for Part III.
(a) (b) (c) (d)
Description of property Amount of mark-to-market gain or Amount of tax deferred on prior year Date of disposition (if any)
(loss) reported on prior year Form 8854
Form 8854

Form 8854 (2020)

Form 8854 (2020) Page 5
Part III Annual Expatriation Statement for Persons Who Expatriated Before 2020 (continued)
2 Did you receive any distributions of eligible deferred compensation items for 2020? . . . . . . . . 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 2020? . . . . . . . . . . . . . . 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

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.
Sign Here
Your signature Date

Print/Type preparer’s name Preparer’s signature Date PTIN

Paid Check if
self-employed
Preparer
Firm’s name ▶ Firm’s EIN ▶
Use Only
Firm’s address ▶ Phone no.
Form 8854 (2020)