Expatriation List Q3 2026: 1,331 Entries and the Exit Tax Tests

What the Q3 2026 notice says, and what it does not

The notice opens with one sentence of scope: “This listing contains the name of each individual losing United States citizenship (within the meaning of section 877(a) or 877A) with respect to whom the Secretary received information during the quarter ending September 30, 2026.” Long-term residents, meaning green-card holders who ended that status, are treated as if they had been citizens who lost citizenship. It runs 19 pages in the Federal Register (pages 68602-68620), is signed October 27, 2026 and was filed for publication on October 29, 2026.

Three limits matter before anyone reads a trend into the number:

• It is a count of when the IRS received information, not of when people left. The quarter is the one in which the Secretary “received information,” and 26 U.S.C. 6039G(d) feeds that list from State Department certificates of loss of nationality and from immigration records of abandoned green cards. A person can expatriate in one quarter and be listed in a later one (our reading).
• It prints names and nothing else. The columns are last name, first name and middle name or initials. There is no net worth, no tax paid, no country and no indication of who is a covered expatriate. We do not reproduce any name on this page.
• It is not unique people across time. We counted printed entries, one per person per notice. We did not match names across quarters.

How we counted: each entry begins with a last name at the left margin; an entry whose middle names wrap onto a second line is one entry, and a few entries print without the dotted leader, so counting dotted lines alone undercounts by one in two of the seven notices we checked against. The 35 counts are in the CSV.

Entries are our count of each printed list; the days column is our arithmetic. Section 6039G(d) says the Secretary shall publish “not later than 30 days after the close of each calendar quarter.” Six of the eight notices above met it; the list for the quarter ending December 31, 2024 came out 34 days after quarter end and the list for the quarter ending September 30, 2025 came out 48 days after quarter end. The Q4 2026 list would be due by January 30, 2027 on the same rule (our reading).

Nine years of lists: 2018 to 2026

Counting entries by the quarter each notice covers gives this series (our arithmetic from the printed lists; the Q4 2023 notice is assigned to December 31, 2023 as the correction directs):

What the series shows, and what it does not:

• 2026 is running above 2025 and 2024. The nine-month total of 4,574 compares with 3,935 in 2025 (up 16.2%) and 4,184 in 2024, and only 2020's 6,048 was higher. The Q4 2026 notice will decide whether the year passes 2025's 4,889 (our arithmetic).
• Third quarters vary widely. The Q3 2026 notice of 1,331 is the third largest of nine Q3 notices since 2018, behind 2024 (2,123) and 2025 (1,593), and far above 2019 (183).
• The quarter-to-quarter swings are large. Lists of 344 (Q1 2024) and 2,123 (Q3 2024) are six months apart. Because the lists follow when the IRS receives information, we draw no conclusion about why people leave, and the notices give no reason.

Who is a covered expatriate in 2026

Section 877A(g)(1)(A) defines a covered expatriate as one who meets any of the three tests in section 877(a)(2). Our table puts the 2026 figure beside each:

The two indexed figures have moved every year. These are the numbers in each year's inflation revenue procedure:

Rev. Proc. 2025-32 states that the exclusion applies “For taxable years beginning in 2026” and that the amount includible by reason of section 877A(a)(1) “is reduced (but not below zero) by $910,000 pursuant to § 877A(a)(3).” The statute's own base is $600,000, indexed (877A(a)(3)(A)-(B)). We did not find the 2027 figures published as of November 2, 2026; they will come in the next inflation revenue procedure.

The net-worth test counts more than a balance sheet. The Instructions for Form 8854 (2025) say a person is considered to own “any interest in property that would be taxable as a gift under chapter 12” had it been transferred immediately before expatriation, valued under section 2512, and the balance sheet must list each partnership separately with its EIN. The same instructions add that a person whose net worth was $2 million or more at any point in the five prior years, but under $2 million on the expatriation date, must say so and attach an explanation of the change. Interests in real estate funds, LLCs and trusts therefore go into the test at their fair market value, and for illiquid interests that value has to be supported (our reading).

What the exit tax does to what you own

For a covered expatriate the main rule is one sentence in 26 U.S.C. 877A(a)(1): “All property of a covered expatriate shall be treated as sold on the day before the expatriation date for its fair market value.” Gain is taken into account in the taxable year of the deemed sale, losses only as otherwise allowed, and the wash-sale rule of section 1091 does not apply (877A(a)(2)). Three categories are carved out of that rule and taxed differently (877A(c)):

Paying later. Section 877A(b) lets a taxpayer elect, property by property and irrevocably, to defer the payment of the additional tax until the return for the year the property is disposed of. The conditions are “adequate security,” a bond or letter of credit, and an irrevocable waiver of treaty rights that would block assessment or collection (877A(b)(4)-(5)). Interest runs during the deferral (877A(b)(7)), and the deferral ends no later than the return for the year of death (877A(b)(3)). The Form 8854 instructions say the election is made in Part II, Section D.

A worked example (our arithmetic)

Assumed facts, not a real person: net worth $4,000,000, so the person is covered on the net-worth test whatever the income tax test says. Two assets on the day before expatriation: an interest in an unlisted real estate fund worth $1,000,000 with adjusted basis $600,000 (gain $400,000), and an interest in a rental LLC worth $800,000 with basis $300,000 (gain $500,000). Federal law only; no state tax, no foreign tax.

The $910,000 is a single amount for all gain properties. The Form 8854 instructions allocate it among the gain properties in proportion to each one's share of the total gain (Step 2 of their Xavier example, which uses the 2025 figure of $890,000). With three assets the gain left to tax is the same $590,000 however it is allocated. Whether $0 or $590,000, the person still has to value each interest on a single date, which for a non-traded fund or a private LLC means an appraisal or a documented NAV (our reading).

If you expect to receive money from someone who left

The exit tax is not only the leaver's problem. Section 2801(a) imposes on a US citizen or resident who receives a covered gift or bequest from a covered expatriate “the highest rate of tax specified in the table contained in section 2001(c)” on its value, and section 2801(b) says the tax “shall be paid by the person receiving such gift or bequest.” For 2026 it applies only to covered gifts and bequests received in the calendar year above $19,000 (Rev. Proc. 2025-32, section 4.42(3)). Transfers that would qualify for the spousal or charitable deduction are not covered, and property shown on a timely filed gift or estate tax return is excluded (2801(e)(2)-(3)). Our pages on gifts to a non-citizen spouse and what heirs owe by asset cover the neighbouring rules, and the 2026 estate tax exemption page covers the $15,000,000 exclusion that applies to US persons.

Reporting and penalties

Section 6039G(a)-(b) requires an individual to whom section 877(b) or 877A applies to provide a statement with a taxpayer identification number, foreign address, countries of residence and citizenship, “information detailing the income, assets, and liabilities” and the days spent in the United States. Section 6039G(c) sets a penalty of $10,000 for failing to file, or filing incorrect information, unless the failure is due to reasonable cause and not willful neglect. In practice the statement is Form 8854. For an initial filing the instructions say to attach it to the income tax return for the year that includes the expatriation date. The instructions also describe annual statements in some later years. Foreign accounts are a separate set of reports; see our FBAR and Form 8938 thresholds page.

Decision points, and who actually does the work

Nothing on the list tells a reader what to do. The decision is for someone with a passport or green card who is considering leaving, or who owns US real estate, fund interests and retirement accounts and has a relative who might. Three questions drive the cost, in this order (our reading of the sources above):

1. Is the person a covered expatriate at all? The $2,000,000 net-worth test is the one that catches most investors with real estate; the income-tax test and the compliance certification can catch others. Every property is treated as sold on the day before the expatriation date at fair market value, and only the first $910,000 of net gain is excluded in 2026.
2. What is each holding worth on that day, and what is its basis? For a fund interest with no market, a private LLC or a rental, that is an appraisal or a documented NAV, and the basis records for each asset.
3. Can any tax be deferred, and on what security? The section 877A(b) election needs a bond or letter of credit and is irrevocable.

The work is done by a US tax specialist who prepares Form 8854 and the deemed-sale return, a valuation professional for illiquid interests, and, for the receiving side, an estate lawyer who knows section 2801. A general financial adviser can help with the whole balance sheet and the order of steps; the return itself is not theirs to file.

This is analysis of public documents, not investment, legal or tax advice.

What a reader can do with this

• Use the list as a count, not a verdict. 1,331 entries is the IRS's own tally of people it learned about in the quarter ending September 30, 2026; the notice gives no wealth or tax data.
• Run the three tests with your own numbers before any move: five-year average net income tax against $211,000, net worth against $2,000,000, and whether five years of returns are filed and correct.
• Get a dated fair market value for every illiquid holding (non-traded fund shares, LLC and partnership interests, rentals) and the basis file for each; the deemed sale is priced on one day.
• Check retirement accounts separately: an IRA is treated as distributed in full, and deferred compensation is withheld at 30%.
• If you may inherit or be given money by someone who is leaving, read section 2801 and the $19,000 annual threshold; the tax is the recipient's.
• Compare the next notice. The list for the quarter ending December 31, 2026 completes the year; we will compare it with 2025's 4,889.

FAQ

Sources, read and saved on November 2, 2026: Federal Register notices “Quarterly Publication of Individuals, Who Have Chosen To Expatriate”, 35 notices covering the quarters ending March 31, 2018 through September 30, 2026, including FR Doc. 2026-22229 (91 FR 68602, October 30, 2026), 2026-14841, 2026-07839, 2026-01251, 2025-19980, 2025-13831, 2025-07076 and 2025-02075, with correction notices 2024-20543 and 2026-01095 (federalregister.gov); Rev. Proc. 2025-32, Rev. Proc. 2024-40, Rev. Proc. 2023-34, Rev. Proc. 2022-38 and Rev. Proc. 2021-45 (irs.gov); 26 U.S.C. 877, 877A, 2801 and 6039G, United States Code 2024 edition (govinfo.gov); Instructions for Form 8854 (2025) (irs.gov). Entry counts are our counts of the printed lists, the percentages, sums and rankings are our arithmetic, and the worked example uses assumed figures. No individual named in a notice is reproduced. This is analysis of public documents, not investment, legal or tax advice.