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# Expatriation
- URL: https://university.heavnn.io/glossary/expatriation/
- Published: 2026-10-18T08:30:00.000Z
- Updated: 2026-10-18T08:29:59.000Z
- Description: Expatriation refers to the act of leaving a country of citizenship or residence, which United States tax law defines as relinquishing citizenship or long-term residence.
- Author: Heavnn
- Tags: #glossary, #Import 2026-10-11 07:56

## What Is Expatriation?

Expatriation refers to the act of leaving a country of citizenship or residence, which United States tax law defines as relinquishing citizenship or long-term residence.

*Also known as: Renunciation of Citizenship, Loss of Nationality.*

## How Expatriation works

Expatriation in the general sense covers any permanent move abroad, but in United States tax law expatriation occurs on a specific date, either when a citizen relinquishes citizenship or when a long-term resident ceases to be a lawful permanent resident, and that date starts the expatriation tax tests. A citizen is treated as relinquishing citizenship on the earliest of renunciation before a consular officer, a signed statement to the Department of State, a certificate of loss of nationality or a court cancelling naturalisation, with the first two events requiring later confirmation. A person becomes a covered expatriate by exceeding the average net income tax test, holding net worth of USD 2 million or more, or failing to certify five years of tax compliance on Form 8854\. Covered expatriates face the mark-to-market regime of section 877A, subject to statutory exceptions.

## Expatriation vs Expatriation Tax

Unlike Expatriation Tax, which is the charge applied to covered expatriates, Expatriation is the underlying act of giving up citizenship or long-term residence, which may or may not lead to any tax.

## Example

Illustrative example: A dual national living in Country B renounces United States citizenship at a consulate, and the Department of State later issues a certificate of loss of nationality. The renunciation date becomes the expatriation date, and Form 8854 then shows whether the covered expatriate tests are met.

## Common misconception

**Myth:** Renouncing United States citizenship immediately ends all United States tax filing duties.

**Reality:** Expatriates generally still file Form 8854 for the expatriation year, and covered expatriates may owe tax on gains deemed realised under section 877A.

## Frequently asked questions

### What is expatriation for US tax purposes?

For United States tax purposes, Expatriation is the relinquishment of citizenship or the end of lawful permanent residence by a long-term resident, effective on the expatriation date defined in Internal Revenue Code section 877A.

### Does renouncing citizenship trigger the expatriation tax?

Renouncing citizenship triggers the United States expatriation tax only for covered expatriates, meaning individuals meeting the income tax test or the USD 2 million net worth test, or failing to certify compliance, subject to statutory exceptions.

## Related terms

- [Expatriation Tax](https://university.heavnn.io/glossary/expatriation-tax/) — Most confused: the tax, not the act
- [Covered Expatriate](https://university.heavnn.io/glossary/covered-expatriate/) — Status deciding whether expatriation is taxed
- [Expatriate](https://university.heavnn.io/glossary/expatriate/) — Person who has expatriated
- [Citizenship-Based Taxation](https://university.heavnn.io/glossary/citizenship-based-taxation/) — Reason US citizens consider expatriation
- [Exit Tax](https://university.heavnn.io/glossary/exit-tax/) — Wider family of departure taxes

## Related guides

- [US expat tax reform debate](https://university.heavnn.io/trumps-tax-agenda-reignites-debate-over-u-s-expat-tax-reform/) — US expatriate tax reform context
- [Global tax reform and US digital nomads](https://university.heavnn.io/global-tax-reform-why-u-s-digital-nomads-should-care/) — Tax context for US nomads abroad

## Sources

- [26 U.S.C. 877A (2024 edition, subject to later amendments), govinfo.gov](https://www.govinfo.gov/content/pkg/USCODE-2024-title26/html/USCODE-2024-title26-subtitleA-chap1-subchapN-partII-subpartA-sec877A.htm?ref=university.heavnn.io)
- [IRS: Expatriation tax](https://www.irs.gov/individuals/international-taxpayers/expatriation-tax?ref=university.heavnn.io)

*Last verified: 2026-10-08\. This entry is general information, not tax or legal advice; rules vary by country and change over time.*