The US Exit Tax: Why Roger Ver’s $50M Lesson Matters for Everyday Expats

Thinking of renouncing your U.S. citizenship after years of living stateside? Maybe you’ve built a successful career, accumulated assets, and now want to return to Australia or move elsewhere. Sounds simple, right? Well, meet the U.S. exit tax, the IRS’s way of saying, “Not so fast.”

What Is the Exit Tax?

When you give up U.S. citizenship or long-term residency, the IRS treats you as if you sold everything you own worldwide the day before you leave. That includes:

  • Your U.S. investments
  • Australian property
  • Retirement accounts (yes, both U.S. plans and Australian superannuation)
  • Even that Bitcoin you bought in 2013

You pay tax on the unrealized gains, minus an exclusion (about $890,000 in 2025). Anything above that? Taxed at capital gains rates.

Who Gets Caught by the Exit Tax?

You’re a covered expatriate if you hit any one of these:

  1. Net worth ≥ $2 million (including superannuation and global assets)
  2. Average U.S. tax liability ≥ $206,000 over the past 5 years
  3. Failure to certify tax compliance for the last 5 years (Form 8854)

Behind on your filings? You’re in the club, even if you don’t meet the wealth or income tests.

Roger Ver’s $50M Lesson: An Extreme Example

Roger Ver, aka “Bitcoin Jesus,” renounced U.S. citizenship in 2014. Fast forward to October 2025: after a year of legal drama, he agreed to pay $50 million in back taxes and penalties under a deferred-prosecution deal to settle allegations of dodging the U.S. exit tax. No jail time, but a hefty bill.

His case is extreme with hundreds of millions in crypto gains, but the principle applies to everyday expats. It’s surprisingly easy to cross the $2 million net worth threshold if you’ve spent years building assets in both the U.S. and Australia. Remember:

  • The $2 million test is per person, not per couple
  • It includes U.S. retirement accounts (401(k), IRA) and Australian superannuation
  • Property holdings and investment portfolios count too

Combine these with a successful career and some market growth, and you might find yourself classified as a covered expatriate, even if you don’t feel “ultra-wealthy.” And if you miss filing obligations for any of the last five years, you’re automatically in the danger zone.

Why the Exit Tax Matters for Everyday Expats?

Even if you’re not a crypto mogul, the exit tax can bite hard. Many Australians living in the U.S. are surprised to learn that their global wealth, including retirement savings, can trigger this tax. Planning ahead is key.

Planning Ahead: How to Manage the U.S. Exit Tax?

The U.S. Exit Tax isn’t something to fear—it’s something to account for and manage. With careful planning, Australian expats can navigate the U.S. Exit Tax effectively, making informed decisions, avoiding surprises, and ensuring a smooth, tax-efficient transition out of the U.S., paying only what is owed.

Contact Us

If managing your financial affairs across borders is starting to feel overwhelming, you’re definitely not alone. It’s a complex space, and having the right support can make all the difference. At Atlas Wealth Group, we specialise in supporting Australian expats with cross-border tax planningsuperannuation, and wealth managementContact us to arrange a consultation with a qualified adviser who specializes in Australian expat financial planning to get personalised guidance tailored to your circumstances.

 

Stay updated on current issues with Atlas Wealth Groups’ podcast, Atlas Weekly Recap or check out Expat Chat.

 

 

Disclaimer: This article is intended for informational purposes only and does not constitute legal or financial advice. Individuals should consult licensed professionals when seeking guidance regarding their financial circumstances.

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