2011-10-24
Last week the IRS published Revenue Procedure 2011-52, setting forth inflation adjusted items for 2012. In the international arena, some of the important inflation adjustments include:
$151,000 --- 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 $147,000 in 2011. See Rev. Proc. 2010-40.
$651,000 --- 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 $636,000 in 2011. See Rev. Proc. 2010-40.
$95,100 --- Code § 911(b)(2)(D)(i) --- Foreign earned income exclusion. This amount is up from $92,900 in 2011. See Rev. Proc. 2010-40.
$13,000 --- Code § 2503 --- The amount of the annual gift tax exclusion for gifts to any person. This amount is the same at $13,000 as in 2011. See Rev. Proc. 2010-40.
$139,000 --- Code § 2523(i) --- The amount of the annual gift tax exclusion for gifts to non-citizen spouses. This amount is up from $136,000 in 2011. See Rev. Proc. 2010-40.
$14,723 --- Code § 6039(F) --- Notice of large gifts received from foreign persons. This amount is up from $14,375 in 2011. See Rev. Proc. 2010-40.