@Wallaby , I don't believe you are correct -- all they have done is raise the bar for covered individual. This is from the instructions for form 8854
"
You must file your initial Form 8854 (Parts I and II) if you relinquished your U.S. citizenship in 2023 or you are a long-term resident (LTR), defined below, and terminated your residency in 2023.
You must file your annual Form 8854 (Parts I and III) if you expatriated before 2023 and you:
-
Deferred the payment of tax,
-
Have an item of eligible deferred compensation, or
-
Are a beneficiary of a nongrantor trust. "
Your earlier question about where to enter your net-worth ---- I show below the appropriate portion opf form 8854 --->
Part II Initial Expatriation Statement for Persons Who Expatriated in 2023
Section A Expatriation Information
1 Enter your U.S. income tax liability (after foreign tax credits) for the 5 tax years ending before the date of your expatriation.
Caution: These amounts are not your balance due. See instructions.
1st Year
Before Expatriation
$
2nd Year
Before Expatriation
$
3rd Year
Before Expatriation
$
4th Year
Before Expatriation
$
5th Year
Before Expatriation
$
2 Enter your net worth on the date of your expatriation for tax purposes . . . . . . . . . . . $
3 Did you become at birth a U.S. citizen and a citizen of another country, and do you continue to be a citizen
of, and taxed as a resident of, that other country? . . . . . . . . . . . . . . . . . . . Yes N
-- the copy function did not copy the format -- but you can look at the form itself.
I also think that perhaps you should visit the IRS section at the embassy nearest to you and see what they suggest . I think they might look upon this as a case where it was a mistake that you forgot to file a form 8854 along with your return for the year you renounced the LTR.
Good luck
pk
Does this solve your issue ?
