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.37 Expatriation to Avoid Tax. For calendar year 2026, 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 $211,000. .38 Tax Responsibilities of Expatriation. For taxable years beginning in 2026, 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 $910,000 pursuant to § 877A(a)(3). .39 Foreign Earned Income Exclusion. For taxable years beginning in 2026, the foreign earned income exclusion amount under § 911(b)(2)(D)(i) is $132,900. .40 Debt Instruments Arising Out of Sales or Exchanges. For calendar year 2026, a qualified debt instrument under § 1274A(b) has stated principal that does not exceed $7,462,600, and a cash method debt instrument under § 1274A(c)(2) has stated principal that does not exceed $5,330,500. .41 Limitation on Aggregate Decrease in Value of Qualified Real Property in Decedent's Gross Estate. For an estate of a decedent dying in calendar year 2026, if the executor elects to use the special use valuation method under § 2032A for qualified real property, the aggregate decrease in the value of qualified real property resulting from electing to use § 2032A for purposes of the estate tax cannot exceed $1,460,000. .42 Annual Exclusion for Gifts and Annual Exception for Covered Gifts and Covered Bequests Received from a Covered Expatriate. (1) For calendar year 2026, the first $19,000 of gifts to any person (other than gifts of future interests in property) are not included in the total amount of taxable gifts under § 2503 made during that year.

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.37 Expatriation to Avoid Tax. For calendar year 2026, 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 $211,000. .38 Tax Responsibilities of Expatriation. For taxable years beginning in 2026, 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 $910,000 pursuant to § 877A(a)(3). .39 Foreign Earned Income Exclusion. For taxable years beginning in 2026, the foreign earned income exclusion amount under § 911(b)(2)(D)(i) is $132,900. .40 Debt Instruments Arising Out of Sales or Exchanges. For calendar year 2026, a qualified debt instrument under § 1274A(b) has stated principal that does not exceed $7,462,600, and a cash method debt instrument under § 1274A(c)(2) has stated principal that does not exceed $5,330,500. .41 Limitation on Aggregate Decrease in Value of Qualified Real Property in Decedent's Gross Estate. For an estate of a decedent dying in calendar year 2026, if the executor elects to use the special use valuation method under § 2032A for qualified real property, the aggregate decrease in the value of qualified real property resulting from electing to use § 2032A for purposes of the estate tax cannot exceed $1,460,000. .42 Annual Exclusion for Gifts and Annual Exception for Covered Gifts and Covered Bequests Received from a Covered Expatriate. (1) For calendar year 2026, the first $19,000 of gifts to any person (other than gifts of future interests in property) are not included in the total amount of taxable gifts under § 2503 made during that year.