2019 Inflation Adjustments for Key International Issues

by John Anthony Castro, J.D., LL.M.

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Introduction

2019 Inflation Adjustments for Individuals in the International Tax Arena.

Background

This week the IRS published Revenue Procedure 2018-57, setting the inflation adjustments for 2019. For international tax matters, these are some of the key adjustments:

  • $168,000. IRC § 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 IRC § 877A(g)(1). This amount is up from $165,000 in 2018. See Rev. Proc. 2017-58.
  • $725,000. IRC § 877A(a)(3)(a). The amount that can be excluded from the mark-to-market gain upon expatriation of a covered expatriate. This amount is up from $713,000 in 2018. See Rev. Proc. 2017-58.
  • $105,900. IRC § 911(b)(2)(D)(i). Foreign earned income exclusion. This amount is up from $104,100 in 2018. See Rev. Proc. 2017-58.
  • $15,000. IRC § 2503. The amount of the annual gift tax exclusion for gifts to any person. This amount is the same as in 2018. See Rev. Proc. 2017-58.
  • $155,000. IRC § 2523(i). The amount of the annual gift tax exclusion for gifts to non-citizen spouses. This amount is up from $152,000 in 2018. See Rev. Proc. 2017-58.
  • $16,388. IRC § 6039F. Notice of large gifts received from foreign persons. This amount is up from $16,111 in 2018. See Rev. Proc. 2017-58.

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About the Author

John Anthony Castro, J.D., LL.M., is the Managing Partner of Castro & Co., the author of International Taxation in Plain English as well as International Estate Planning in Plain English, an esteemed graduate of Georgetown University Law Center in Washington DC, an OPM Fellow at Harvard Business School, and an internationally recognized tax attorney with offices in New York, Los Angeles, Miami, Chicago, Dallas, and Washington DC.

To provide feedback on this article or suggest an idea for a future article, please contact Tiffany Michelle Hunt, J.D., LL.M., Director of Tax Planning at Castro & Co., at T.Hunt@CastroAndCo.com.


Bluebook Citation: John Anthony Castro, 2019 Inflation Adjustments for Key International Issues, Castro Int’l Tax Blog (June 24, 2019).

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