Exit Tax on Crypto Assets for US Expatriates: What You Need to Know in 2026

Exit Tax on Crypto Assets for US Expatriates: What You Need to Know in 2026
Diana Pink 22 January 2026 10

Renouncing U.S. citizenship sounds like a fresh start-until you face the exit tax on your cryptocurrency. If you’ve held Bitcoin since 2013, mined Ethereum in 2017, or accumulated altcoins over the years, the IRS doesn’t see you as just leaving the country. They see you as selling everything the day before you walk away-and they want their cut.

Who Actually Pays the Exit Tax?

Not everyone who gives up their U.S. passport or long-term residency pays this tax. Only covered expatriates do. And to be one, you have to hit at least one of these three thresholds in 2025:

  • Your net worth is $2 million or more on the day you renounce
  • Your average annual U.S. income tax over the past five years was over $206,000
  • You can’t prove you’ve filed all your U.S. tax returns for the last five years
If you’re not hitting any of these, you’re off the hook. No exit tax. Simple. But if you are? Welcome to the most complicated part of leaving: the deemed sale.

The Deemed Sale: What the IRS Pretends Happened

The IRS doesn’t wait for you to actually sell your crypto. On the day before you renounce, they treat every Bitcoin, Ethereum, Solana, NFT, and stablecoin you own as if you sold it all at once. That’s called a deemed sale.

They calculate your gain by subtracting your cost basis-what you paid for it, plus fees-from the fair market value (FMV) on that exact day. If you bought 1 BTC for $100 in 2013 and it’s worth $70,000 the day before you leave, you’ve got a $69,900 gain. Even if you never touched it. Even if you still hold it.

The good news? The first $890,000 of total net capital gains across all your assets (not just crypto) is tax-free. That exclusion is adjusted yearly for inflation. The bad news? If your crypto gains alone push you past that number, you pay tax on everything above it.

Why Crypto Makes This So Much Harder

Crypto isn’t like stocks or real estate. It’s messy. And the IRS knows it.

  • Cost basis is often lost: 61.3% of Bitcoin transactions in 2023 involved wallets where the original purchase price is unknown. If you bought crypto in 2012 using a now-dead wallet or an exchange that shut down, good luck proving what you paid.
  • Valuation is volatile: A coin can swing 20% in a few hours. The IRS requires precise FMV at the exact moment of deemed sale-not an average, not a guess. You need timestamped data from reputable exchanges.
  • Early adopters get crushed: Someone who mined 50 BTC in 2011 for $200 in electricity costs now faces a $3.5 million gain. The $890,000 exclusion? Gone in one asset.
  • Foreign exchanges trigger extra forms: If your crypto is on Binance, Kraken, or any non-U.S. exchange and the total value across all foreign accounts hit $10,000 at any point during the year, you must file an FBAR. If it’s over $50,000 on year-end, you file FATCA Form 8938. Miss one, and penalties start at $10,000.

And the IRS isn’t bluffing. In 2023, the Tax Court sided with them in IRS v. Dao, ruling that taxpayers must produce full transaction histories-even for crypto acquired over a decade ago.

Someone organizing crypto records and filing tax forms with a professional, calendar showing 2026.

What You Have to File

The exit tax isn’t optional. You must file Form 8854-Initial and Annual Expatriation Statement-with your final U.S. tax return. This form asks for:

  • A full list of all your worldwide assets
  • The FMV of each on the day before expatriation
  • Your cost basis for each asset
  • Your net worth calculation
  • Your certification of tax compliance

And you have to keep all supporting documents for six years. That means:

  • Exported transaction histories from every exchange and wallet
  • Screenshots of FMV at the exact time of deemed sale
  • Proof of cost basis (blockchain explorers, old emails, receipts)
  • Records of any crypto losses you used to offset gains

Without this, the IRS can assume your cost basis is zero. That means your entire portfolio value becomes taxable gain. And they’ll do it.

Real Stories: People Who Got Hit-and Those Who Didn’t

On Reddit, u/CryptoExpat2025 wrote: “I mined 50 BTC in 2011. Electricity cost $200. The IRS wants me to pay tax on $3.5 million. My exclusion vanished on the first 0.5 BTC.” He paid $780,000 in exit tax.

But u/SmartExpat on r/expats shared a different path: “I timed my renunciation after a 15% market drop. I used $400,000 in crypto losses from 2024 to offset gains. I held $1.8 million in crypto. I paid $0.” How? Documentation. Timing. Strategy.

Greenback Tax Services found that 37.2% of expatriation cases in Q1 2025 involved crypto complications. Those who worked with crypto-savvy tax professionals had an 89.7% satisfaction rate. Those who didn’t? Often ended up overpaying-or facing audits.

A tiny figure walks away from a mountain of crypto coins split by the 0,000 tax exclusion line.

What’s Coming Next

The IRS isn’t slowing down. In 2025, they added 12 new examiners just to handle crypto exit tax cases. Total specialists now: 37. The Treasury’s 2025-2026 Priority Guidance Plan lists “specific rules for cryptocurrency cost basis determination” as a Tier 1 priority. That means new guidance is coming-probably within the next year.

Congress is also looking at changes. H.R. 3892, the Expatriation Tax Modernization Act of 2025, proposes:

  • Raising the exclusion to $1.2 million in 2026
  • Creating a special cost basis rule for crypto acquired before 2014
  • Allowing tax-free transfers to family members before expatriation

But there’s a darker possibility: some lawmakers want to remove the $890,000 exclusion for crypto entirely. If that passes, every dollar of crypto gain above zero would be taxed. No buffer. No mercy.

And by 2027, experts predict the IRS will require crypto exchanges to report expatriating users’ holdings directly-just like they do for U.S. taxpayers on Form 1099-B.

What You Should Do Now

If you’re thinking about renouncing, here’s your action plan:

  1. Start 12+ months in advance: Don’t wait until your passport appointment. You need time to organize everything.
  2. Track every transaction: Use tools like Koinly, TokenTax, or Chainalysis Reactor to reconstruct your cost basis. If you can’t prove it, the IRS will assume it’s zero.
  3. Time your exit: Wait for a market dip. Use losses from previous years to offset gains. Even a 10% drop can push you under the $890,000 threshold.
  4. Gift crypto before you leave: You can gift up to $19,000 per person in 2025 without triggering gift tax. Spread holdings to family members who are U.S. citizens or residents. That reduces your taxable base.
  5. Hire a specialist: Not just any CPA. Someone who understands both international tax law AND cryptocurrency. The American Institute of CPAs says 87.3% of successful cases involved dual-certified advisors.
  6. File everything: Form 8854. FBAR. FATCA. Final 1040. Don’t skip one. The IRS cross-references everything.

Leaving the U.S. is a personal decision. But the exit tax on crypto? That’s a financial earthquake. You can’t ignore it. You can’t wing it. And you definitely can’t hope it goes away.

The system is harsh. But it’s not unknowable. With the right preparation, you can walk away without losing half your life’s work.

Is the exit tax only for crypto, or does it apply to all assets?

The exit tax applies to all worldwide assets, not just crypto. That includes stocks, real estate, bank accounts, business interests, and even art. Crypto is just one part of the total. The $890,000 exclusion covers your net capital gains across all assets combined. So if you have $500,000 in stock gains and $400,000 in crypto gains, you’re at $900,000 total-$10,000 is taxable. But if you have $900,000 in crypto alone, you still owe tax on $10,000.

Can I avoid the exit tax by selling my crypto before renouncing?

Yes-but it’s tricky. If you sell your crypto before expatriation, you pay regular capital gains tax on it, not the exit tax. But you still have to file Form 8854 and report the sale. The key is timing: if you sell and pay the tax before renouncing, the IRS won’t double-tax you. However, if you sell right before expatriation and then renounce, you may still be subject to exit tax if your gains push you over the threshold. The safest move is to plan the sale at least 3-6 months before renunciation and document everything.

What happens if I don’t file Form 8854?

You’re still a covered expatriate-even if you don’t file. The IRS can retroactively apply the exit tax, plus penalties and interest. Worse, you’ll lose your right to re-enter the U.S. as a non-immigrant without paying the tax first. Your passport will be flagged, and you may be denied visas for years. Filing Form 8854 isn’t optional-it’s the only way to legally close the chapter.

Do I still owe U.S. taxes after I renounce?

For 10 years after renunciation, you’re subject to U.S. tax on any income or gains from U.S.-source assets. This includes rental income from U.S. property, dividends from U.S. stocks, or interest from U.S. bank accounts. If you’re a covered expatriate, you’re also subject to a 30% withholding tax on gifts you make to U.S. citizens or residents. That’s why many people transfer assets to non-U.S. entities before leaving.

Can I renounce if I owe back taxes?

No. You must be fully compliant with U.S. tax obligations for the past five years to renounce. That means filing all missing returns and paying any taxes, penalties, or interest owed. The IRS will not issue a Certificate of Loss of Nationality (CLN) until you’ve submitted all required forms and paid in full. If you’re behind, start the Streamlined Filing Compliance Procedures immediately-it’s your only legal path to get back on track.

What if I hold NFTs or DeFi tokens?

The IRS treats NFTs and DeFi tokens as property, just like Bitcoin. They’re included in the deemed sale. Valuing them is harder-there’s no centralized market. You need independent appraisals or valuation from the most liquid marketplace available. The IRS issued Notice 2025-41 in May 2025 requiring this for DeFi assets. If you can’t prove value, they’ll assume it’s zero, and you’ll owe tax on the full amount. Keep screenshots of trading activity, blockchain timestamps, and third-party valuations.

10 Comments

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    steven sun

    January 23, 2026 AT 10:59
    bro i just sold half my btc last week bc i heard this was coming. 15% drop was my sign. now i just chillin with the rest and waitin for the next pump. dont let the tax man steal your dreams 😎
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    tim ang

    January 24, 2026 AT 01:42
    this is why you gotta keep records like your life depends on it. i used tokentax to track every single tx since 2016. even the ones from that sketchy exchange that shut down in 2018. i saved screenshots of every price at the time. it was a pain but now i sleep easy. you can do this!
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    katie gibson

    January 24, 2026 AT 05:04
    so the IRS is basically saying if you were smart enough to buy bitcoin when it was worth less than a coffee, you’re now a criminal? 🤡 i mean, come on. they want you to pay taxes on money you never even touched. this isn’t taxation, it’s extortion with a spreadsheet. and don’t even get me started on the ‘deemed sale’ nonsense. it’s like they’re playing pretend with your life.
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    Ashok Sharma

    January 25, 2026 AT 18:39
    This is very important for people who want to leave USA. You must keep all records. Even small transaction. Use good tools. Do not wait until last minute. Start early. It is not easy but possible. Many people do this successfully with help of good advisor.
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    Margaret Roberts

    January 27, 2026 AT 01:15
    this whole thing is a scam. the government knows people are getting rich off crypto and now they’re panicking. they’ll invent new rules every year until we’re all broke. next they’ll tax your thoughts if you think about crypto. mark my words.
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    Harshal Parmar

    January 27, 2026 AT 10:57
    hey i know it sounds scary but honestly? this is your chance to clean up your whole financial life. i had like 12 wallets from 2013 to 2021, all mixed up. i spent 3 months organizing everything with koinly, found 3 lost coins i forgot about, and even got a refund from a 2015 tax return i never filed. now i feel free. you don’t have to be perfect, just consistent. one step at a time. you got this!
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    Darrell Cole

    January 28, 2026 AT 09:29
    The notion that cost basis can be lost is absurd. Every transaction is on chain. If you cannot prove it you are either incompetent or attempting fraud. The IRS is correct to assume zero basis. Any argument otherwise is legally indefensible and financially irresponsible. You should have kept records. End of story.
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    Matthew Kelly

    January 29, 2026 AT 14:37
    i used to think this was all overkill until i saw a friend get hit with a $200k bill bc he didn't file fbars. now i use a crypto tax pro + backup drive + cloud sync. i even printed out my 2017 mining receipts. it's weird but it works. 🙏
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    Dave Ellender

    January 31, 2026 AT 04:48
    I’ve been through this process. It’s not pleasant, but it’s manageable. The key is documentation, timing, and not rushing. I filed Form 8854 six months before my appointment. I didn’t panic. I just worked through it. It’s a marathon, not a sprint.
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    Adam Fularz

    February 1, 2026 AT 01:05
    you people are so naive. the exit tax is just the beginning. they’re building a global crypto tracking system. next they’ll link your wallet to your passport. then your biometrics. then your dreams. this isn’t tax policy. this is social control dressed up in accounting jargon.

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