Page 18
18 years beginning in 2024, under § 831(b)(2)(A)(i) the amount of the limit on net written premiums or direct written premiums (whichever is greater) is $2,800,000 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 2024, 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 $201,000. .38 Tax Responsibilities of Expatriation. For taxable years beginning in 2024, 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 $866,000 pursuant to § 877A(a)(3). .39 Foreign Earned Income Exclusion. For taxable years beginning in 2024, the foreign earned income exclusion amount under § 911(b)(2)(D)(i) is $126,500. .40 Debt Instruments Arising Out of Sales or Exchanges. For calendar year 2024, a qualified debt instrument under § 1274A(b) has stated principal that does not exceed $7,098,600, and a cash method debt instrument under § 1274A(c)(2) has stated principal that does not exceed $5,070,500. .41 Unified Credit Against Estate Tax. For an estate of any decedent dying in calendar year 2024, the basic exclusion amount is $13,610,000 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 2024, if the executor elects to use the special use valuation method under § 2032A for qualified real property, the aggregate decrease in the value of