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Form 8854: Initial and Annual Expatriation Statement
IRS Form 8854 is the Initial and Annual Expatriation Statement, which helps individuals come into compliance with U.S. income tax requirements to avoid being treated as a covered expatriate under section 877A. Failure to file correctly may result in a penalty of $10,000 for that year.
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IRS Form 8854 - Initial and Annual Expatriation Statement
IRS Form 8854 is the Initial and Annual Expatriation Statement, which helps individuals come into compliance with U.S. income tax requirements to avoid being treated as a covered expatriate under section 877A. Failure to file correctly may result in a penalty of $10,000 for that year.
Risk Radar
Scan points- 1Failure to include all required information results in a $10,000 penalty for that year unless reasonable cause is proven.
- 2Filing without attaching the initial Form 8854 to the required income tax return.
- 3Forgetting to provide adequate security (such as a bond) when filing an annual statement.
- 4Failing to make an irrevocable waiver of any treaty rights under section 877A.
- 5Submitting the form using the wrong Part II or Part III based on the year of expatriation.
Plain English
This form is used by people who have become citizens of another country but still have U.S. tax obligations. It helps prove that the individual has taken steps to comply with American tax laws and avoid penalties associated with leaving the United States. Filing this statement ensures the person meets their reporting requirements regarding their foreign citizenship status.
Submission Date
- Filing date: 2025-12-01 12:10:05
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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Glossary Terms
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What this form is for
- Use this form when you initially file Form 8854 (Parts I and II) because you relinquished U.S. citizenship in 2025 or you are a long-term resident who terminated residency in 2025.
- Do not use it when you filed annual Form 8854 (Parts I and III) if you did not expatriate before 2025, or if the required conditions regarding deferred tax payments, eligible deferred compensation items, or nongrantor trust interests were not met.
- Check a related form when filing your original tax return (Form 1040-NR, Form 1040, or Form 1040-SR) for attachment.
Form selector
Use this form or another form?
Dual-citizens and certain minors
They may qualify for an exception regarding covered expatriate status, but they must file Form 8854 to certify compliance with all federal tax obligations for the five tax years preceding the date of expatriation.
✓ Check instructions regarding Covered expatriate status.
Filing annual Form 8854 (Parts I and III)
This is required if you expatriated before 2025 and previously filed a Form 8854 concerning tax deferral, eligible deferred compensation, or an interest in a nongrantor trust.
✓ Check the requirement criteria listed on Part III.
Initial filing with citizenship relinquishment
Attach your initial Form 8854 (Parts I and II) to your tax return for the year that includes the expatriation date.
✓ Check the due date of your income tax return.
Deadline or filing window
Initial Form 8854 must be attached to and filed with the income tax return by the due date of that return. If an annual statement is required but no tax return is needed, it must be sent by the date the Form 1040-NR (or Form 1040 or 1040-SR) would have been due, including extensions.
Before you submit
- 1For initial filing, submit Form 8854 by the due date of your relevant tax return, such as Form 1040 or Form 1040-NR.
- 2The original Form 8854 must be sent to the specific address listed under Where To File; this location also accepts tax deferral agreement requests.
- 3Ensure Part I includes both your principal foreign residence and your current mailing address following expatriation. Parts II and III require tax details.
- 4If you fail to file Form 8854 or include incorrect information, a penalty of $10,000 will be owed for that year unless reasonable cause is proven.
- 5When filing annually, confirm the specific requirements against your corresponding return; reporting obligations are subject to change and should be re-checked.
How to file this form
- 1Complete the initial or annual Form 8854 by addressing the specific required Parts (I, II, and III) based on whether you are reporting an initial expatriation or fulfilling annual requirements.
- 2If attaching to a tax return, attach your completed Form 8854 (initial or annual) to Form 1040-NR, Form 1040, or Form 1040-SR for the relevant year and file by that return's due date.
- 3If not attaching it to a tax return, send your original Form 8854 to the specific address listed on the form by the due date of the related income tax return (including extensions).
- 4If electing to defer payment of any tax due, include the completed tax deferral agreement request along with adequate security and the required waiver when mailing the documents.
Known limitations
- 1The average annual net income tax liability threshold for determining a covered expatriate is $206,000.
- 2For 2025, if an individual is a covered expatriate, the net gain that must otherwise be included in income is reduced by $890,000.
- 3The Form 8854 does not apply to filing requirements for those who do not have an initial or annual reporting requirement under section 877A.
- 4An interest in property includes money or other property, but excludes deferred compensation items and specified tax deferred accounts.
Field map
Compact field-by-field guide
Entity Info
1 items
Name and taxpayer ID of the entity claiming the credit.
Credit Info
1 items
Type of credit or incentive being claimed.
Calculation
2 items
The base amount used to calculate the credit.
Calculated credit amount after applying formulas and limitations.
Certification
1 items
Detailed breakdown supporting the credit calculation.
Signatures
1 items
Sign and date the form.
Almost done reviewing the fields?
Fillable formOpen in Editor->The form revision date is 20/25 edition. Guidance updates include new information regarding section 2801 tax, the average annual net income tax liability threshold of $206,000 for five tax years, and a reduced net unrealized gain threshold of $890,000 for 2025.
What changed or needs a fresh check
- Edition date — confirm the revision date reads 20/25.
- Fee — Not stated in the official source.
- Mailing address — Confirm that you send your original Form 8854 (or tax deferral agreement request) to the address listed on the form.
- Signature — The requirement for signing or dating is not specifically detailed.
Quick Facts
Downloads
After you file
- 1Retain books or records relating to the form or its instructions as long as their contents may become material in the administration of any Internal Revenue law.
- 2If required to file a Form 1040-NR (or Form 1040 or 1040-SR), attach your annual Form 8854 to that form when sending it.
- 3If you are not required to file a Form 1040-NR (or Form 1040 or 1040-SR), send the Form 8854 by the date the required tax return would have been due (including extensions).
- 4Keep copies of the initial and annual Form 8854, especially if you are sending a copy to another address (e.g., when filing with a related return).
Sources
- SRCInstructions p.1 — To file initial Form 8854 (Parts I and II), use it if you relinquished your U.S. citizenship in 2025 or are a long-term resident (LTR) who terminated residency in 2025.
- SRCInstructions p.1 — File annual Form 8854 (Parts I and III) if you expatriated before 2025 AND meet specific criteria, including reporting an interest in a nongrantor trust on a previous Form 8854.
- SRCInstructions p.2 — A penalty of $10,000 applies for failure to file or incorrect information on any Form 8854 required under section 877A, unless due to reasonable cause and not willful neglect.
- SRCInstructions p.3 — If you are not required to file an income tax return, send your original Form 8854 by the date your Form 1040-NR (or Form 1040 or 1040-SR) would have been due.
- SRCInstructions p.3 — When filing annual Form 8854 with a related tax return, send a copy of that form to the address listed in Where To File.
- SRCInstructions p.3 — The original initial or annual Form 8854 must be sent to the specific address provided under Where To File.
- SRCInstructions p.1 — An LTR is defined as having been a lawful permanent resident of the United States for at least 8 of the last 15 tax years ending with the year.
Common confusion points
Do I need to file my annual Form 8854 even if I expatriated recently?
You must file your initial Form 8854 (Parts I and II) if you relinquished your U.S. citizenship in 2025 or if you are a long-term resident (LTR) who terminated residency in 2025.
Do I only send my annual Form 8854 if I had problems reporting previous years?
Must I file a Form 8854 for every year I am filing other taxes?
What happens if I miss the deadline or fill out the form incorrectly?
Are there special rules for long-term residents (LTRs)?
Workflow map
Related forms and next steps
Before
Current
After
Often used with
⚠ If something goes wrong
- FinCEN Form 114, may be required if you were a U.S. person for any portion of 25.
- Form 8938, may be required if you were a U.S. person for any portion of 25.
Questions about IRS Form 8854
What is IRS Form 8854 used for?
This form is used by people who have become citizens of another country but still have U.S. tax obligations. It helps prove that the individual has taken steps to comply with American tax laws and avoid penalties associated with leaving the United States. Filing this statement ensures the person meets their reporting requirements regarding their foreign citizenship status.
Who must file IRS Form 8854?
Individuals who are subject to section 877A and wish to come into compliance with U.S. income tax and reporting requirements can file Form 8854.
What information does IRS Form 8854 require?
Part I collects general information, including the mailing address after expatriation and principal foreign residence. Parts II and III require specific details related to previous or current tax deferrals and compensation items.
When is IRS Form 8854 due?
For initial filing, the Form 8854 must be filed by the due date of the relevant income tax return (Form 1040, 1040-SR, or 1040-NR). Annual filings vary depending on whether a corresponding tax return is required.
Where do I file IRS Form 8854?
The original initial or annual Form 8854 must be sent to the address listed under Where To File. Tax deferral agreement requests are also sent to this same address.
How do I complete IRS Form 8854?
For initial filing, attach Form 8854 to the corresponding income tax return (Form 1040, 1040-SR, or 1040-NR). Annual filers must provide adequate security and make an irrevocable waiver of any rights under U.S. treaties before submitting the statement.
What happens if IRS Form 8854 is filed incorrectly?
If an individual fails to file Form 8854, or if the form contains incorrect information, a penalty of $10,000 will be owed for that year, unless reasonable cause and not willful neglect is proven.
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