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2020 Inflation Adjustments for Individuals in the International Tax Arena

2019-11-18

Last week the IRS published Revenue Procedure 2019-44, setting forth inflation adjusted items for 2020. In the international arena, some of the important inflation adjustments include:

$171,000 --- 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 $168,000 in 2019.

$737,000 --- 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 $725,000 in 2019.

$107,600 --- Code § 911(b)(2)(D)(i) --- Foreign earned income exclusion. This amount is up from $105,900 in 2019.

$15,000 --- Code § 2503 --- The amount of the annual gift tax exclusion for gifts to any person. This amount is the same as in 2019.

$157,000 --- Code § 2523(i) --- The amount of the annual gift tax exclusion for gifts to non-citizen spouses. This amount is up from $155,000 in 2019.

$16,649 --- Code § 6039F --- Notice of large gifts received from foreign persons. This amount is up from $16,388 in 2019.

Tags: 877A Individual Expatriation, 911 Foreign Earned Income Exclusion, Authority - Revenue Procedures, Other - Inflation Adjustments