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.36 Tax on Insurance Companies Other than Life Insurance Companies. For taxable years beginning in 2022, under § 831(b)(2)(A)(i) the amount of the limit on net written premiums or direct written premiums (whichever is greater) is $2,450,000 to elect the alternative tax for certain small companies under § 831(b)(1) to be taxed only on taxable investment income. .37 Expatriation to Avoid Tax. For calendar year 2022, under § 877A(g)(1)(A), unless an exception under § 877A(g)(1)(B) applies, an individual is a covered expatriate if the individual’s “average annual net income tax” under § 877(a)(2)(A) for the five taxable years ending before the expatriation date is more than $178,000. .38 Tax Responsibilities of Expatriation. For taxable years beginning in 2022, the amount that would be includible in the gross income of a covered expatriate by reason of § 877A(a)(1) is reduced (but not below zero) by $767,000 pursuant to § 877A(a)(3). .39 Foreign Earned Income Exclusion. For taxable years beginning in 2022, the foreign earned income exclusion amount under § 911(b)(2)(D)(i) is $112,000. .40 Debt Instruments Arising Out of Sales or Exchanges. For calendar year 2022, a qualified 0debt instrument under § 1274A(b) has stated principal that does not exceed $6,289,500, and a cash method debt instrument under § 1274A(c)(2) has stated principal that does not exceed $4,492,500. .41 Unified Credit Against Estate Tax. For an estate of any decedent dying in calendar year 2022, the basic exclusion amount is $12,060,000 for determining the amount of the unified credit against estate tax under § 2010. .42 Valuation of Qualified Real Property in Decedent's Gross Estate. For an estate of a decedent dying in calendar year 2022, if the executor elects to use the special use