Form 8854: The Initial and Annual Expatriation Statement
Published November 8, 2026
Form 8854 is the Initial and Annual Expatriation Statement. It applies under section 877A to U.S. citizens who give up citizenship and to long-term residents who end their residency. The form asks for facts about the person's assets, taxes, and citizenship history.
This post is general information from the IRS form and its instructions. It does not say whether a particular person is a covered expatriate. It does not give tax advice for a particular taxpayer. Expatriation can raise questions under several rules. A qualified tax professional should review a specific case.
What counts as expatriation
The instructions say a person is considered to have relinquished U.S. citizenship on the earliest of several dates. Those include two dates. One is the date a renunciation was made before a diplomatic or consular officer. The other is the date a signed statement of voluntary relinquishment was given to the State Department. The instructions explain each date.
The instructions also explain long-term resident status. They also explain when a lawful permanent resident is treated as no longer a resident. Check those rules in the instructions before you decide.
Who must file the initial statement
The 2025 instructions say you must file the initial Form 8854, Parts I and II, if you relinquished your U.S. citizenship in 2025 or if you are a long-term resident who ended residency in 2025.
Who must file the annual statement
You must file the annual Form 8854, Parts I and III, if you expatriated before 2025 and you deferred the payment of tax, have an item of eligible deferred compensation, or are a beneficiary of a nongrantor trust. The annual statement covers the reporting that continues after expatriation.
What Part II asks
Section A asks for your U.S. income tax liability after foreign tax credits for the five tax years before expatriation. It also asks for your net worth on the expatriation date. It asks whether your assets and liabilities changed significantly in the five years before that date. The form then asks yes or no questions. One question asks you to certify, under penalties of perjury, that you complied with all federal tax obligations for the five preceding tax years.
Section B is a balance sheet. You list the fair market value and the U.S. adjusted basis of your assets and liabilities on the expatriation date. Pensions and deferred compensation are listed at present value, as the form explains.
Dual citizens and treaty residents
The instructions describe exceptions for certain dual citizens. These are people who were born with U.S. citizenship and another citizenship. They still are taxed as residents of that other country. The instructions say the exception applies only if both requirements are met. The instructions also cover a lawful permanent resident. That person is treated as a resident of a treaty country and does not waive the treaty benefits.
Gather the figures before you start
Collect your tax returns for the five tax years before expatriation. Gather your balance sheet information and the dates of each citizenship or residency change. Section A and Section B ask for these figures, so having them ready avoids guessing.
Mistakes to avoid
- Skipping Section A because the answers seem unclear. Read the instructions for each question.
- Using the wrong expatriation date. The instructions explain the earliest date rule.
- Filing Part II when only the annual Part III applies, or the other way around.
- Certifying tax compliance without checking every return for the five preceding years.
For reporting foreign financial accounts, read Form 8938: Reporting Foreign Financial Assets to the IRS. For foreign corporation holdings, read Form 5471: Reporting Interests in Foreign Corporations.
Keep the records behind each figure. They include balance sheet values, tax returns for the five years, and the dates of each change.
Sources: Sources: IRS, Form 8854, Initial and Annual Expatriation Statement (2025) (https://www.irs.gov/pub/irs-pdf/f8854.pdf); Instructions for Form 8854 (2025) (https://www.irs.gov/pub/irs-pdf/i8854.pdf) This is general information, not advice about your specific return.
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