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2023 Inflation Adjustments for Individuals in the International Tax Arena

2022-10-20

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This week the IRS published Revenue Procedure 2022-38, setting forth inflation adjusted items for 2023. In the international arena, some of the important inflation adjustments include:

$190,000 --- 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 $178,000 in 2022.

$821,000 --- 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 $767,000 in 2022.

$120,000 --- Code §911(b)(2)(D)(i) --- Foreign earned income exclusion. This amount is up from $112,000 in 2022.

$17,000 --- Code §2503 --- The amount of the annual gift tax exclusion for gifts to any person. This amount is up from $16,000 in 2022.

$175,000 --- Code §2523(i) --- The amount of the annual gift tax exclusion for gifts to non-citizen spouses. This amount is up from $164,000 in 2022.

$18,567 --- Code §6039F --- Notice of large gifts received from foreign persons. This amount is up from $17,339 in 2022.

$59,000 --- Code §7345 --- Amount of a serious delinquent tax debt. This amount is up from $55,000 in 2022.

Tags: 877A Individual Expatriation, 911 Foreign Earned Income Exclusion, 2501 Gifts, Authority - Revenue Procedures, Other - Inflation Adjustments