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2025 Inflation Adjustments for Individuals in the International Tax Arena

2024-10-22

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Today the IRS published Revenue Procedure 2024-40, setting forth inflation adjusted items for 2025. Some of the important inflation adjustments in the international arena include:

$206,000 --- 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 $201,000 in 2024.

$890,000 --- 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 $866,000 in 2024.

$130,000 --- Code §911(b)(2)(D)(i) --- Foreign earned income exclusion. This amount is up from $126,500 in 2024.

$19,000 --- Code §2503 --- The amount of the annual gift tax exclusion for gifts to any person. This amount is up from $18,000 in 2024.

$190,000 --- Code §2523(i) --- The amount of the annual gift tax exclusion for gifts to non-citizen spouses. This amount is up from $185,000 in 2024.

$20,116 --- Code §6039F --- Notice of large gifts received from foreign persons. This amount is up from $19,570 in 2024.

$64,000 --- Code §7345 --- Amount of a serious delinquent tax debt. This amount is up from $62,000 in 2024.

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