2010-10-28
Today the IRS published Revenue Procedure 2010-40, setting forth inflation adjusted items for 2011. In the international arena, some of the important inflation adjustments include:
$147,000 --- 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 $145,000 in 2010. See Rev. Proc. 2009-50.
$636,000 --- Code § 877A(a)(3) --- The amount that can be excluded from the mark-to-market gain upon expatriation of a covered expatriate. This amount is up from $627,000 in 2010. See Rev. Proc. 2009-50.
$92,900 --- Code § 911(b)(2)(D)(i) --- Foreign earned income exclusion. This amount is up from $91,500 in 2010. See Rev. Proc. 2009-50.
$136,000 --- Code § 2523(i) --- The amount of the annual gift tax exclusion for gifts to non-citizen spouses. This amount is up from $134,000 in 2010. See Rev. Proc. 2009-50.