2025-10-12
This week the IRS published Revenue Procedure 2025-32, setting forth inflation adjusted items for 2026. Some of the important inflation adjustments in the international arena include:
$211,000 --- Code §877(a)(2)(A) --- The average annual net income tax that must be imposed for the five taxable years ending before the date of the loss of United States citizenship (or cessation of long-term permanent residency) for an individual to be considered a “covered expatriate” under Code § 877A(g)(1). This amount is up from $206,000 in 2025.
$910,000 --- Code §877A(a)(1) --- The amount that can be excluded from the mark-to-market gain upon expatriation of a covered expatriate. This amount is up from $890,000 in 2025.
$132,900 --- Code §911(b)(2)(D)(i) --- Foreign earned income exclusion. This amount is up from $130,000 in 2025.
$19,000 --- Code §2503 --- The amount of the annual gift tax exclusion for gifts to any person. This amount is the same as in 2025.
$194,000 --- Code §2523(i) --- The amount of the annual gift tax exclusion for gifts to non-citizen spouses. This amount is up from $190,000 in 2025.
$20,573 --- Code §6039F --- Notice of large gifts received from foreign persons. This amount is up from $20,116 in 2025.
$66,000 --- Code §7345 --- Amount of a serious delinquent tax debt. This amount is up from $64,000 in 2025.