Form 8854 Exit Tax Calculations and Reporting: Minimizing the IRC 877A Expatriation Tax
Determining Covered Expatriates, Navigating the Mark-to-Market Tax on Unrealized Gains, Reporting Elections
Recording of a 110-minute CPE webinar with Q&A
This webinar will provide tax advisers and compliance professionals with a practical guide to the calculations and reporting requirements needed for U.S. taxpayers and exiting green card holders. The panel will discuss the rules of Section 877A, as well as strategies for minimizing the impact of expatriation taxes. The panel will also address the complexities of Form 8854.
Outline
- Exit tax provisions of Section 877A
- Who is a covered expatriate?
- The 3 tests
- The exceptions
- Determining net worth when trust assets are involved
- Components of Form 8854
- Reporting expatriating acts
- Part III—prior year mark-to-market calculations prior year deferrals
- Part IV—current year expatriation
- Net worth and tax liability
- Property owned on date of expatriation
- Eligible and ineligible deferred compensation items
- Tax-deferred accounts
- Trust interests and elections
- Mark-to-market calculations
- Part V—balance sheet and income statement
- The inheritance tax under Section 2801
- Pre-exit planning strategies
Benefits
The panel will review these and other key issues:
- Which taxpayers are subject to section 877A and must file Form 8854
- How to calculate the mark-to-market tax on capital gains
- The types of deferred compensation that are subject to the exit tax
- How to defer exit tax payments
- Strategies for avoiding or minimizing the taxes imposed under Section 877A
Faculty

Philip D. W. Hodgen
Attorney
Hodgen Law
Mr. Hodgen specializes in the international tax arena. He counsels clients on international tax issues arising when... | Read More
Mr. Hodgen specializes in the international tax arena. He counsels clients on international tax issues arising when clients deal with multiple tax systems, tax planning, cross-border businesses and investments. He frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, and other professional groups.
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Ann M. Seller
Kohnen & Patton
Ms. Seller's work focuses primarily in estate planning and probate administration. As part of her practice, she... | Read More
Ms. Seller's work focuses primarily in estate planning and probate administration. As part of her practice, she concentrates on international aspects of estate planning including the creation of wills and trusts for multi-national families, estate and gift tax issues that arise with the ownership of cross border property, and advising clients about the U.S. Expatriation Tax.
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