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Exit Tax
Expat
RSU
Stock Options
IRC 877A
Deemed Disposition
CGT Event I1
Cross-Border
Deferred Equity

Expat Exit Tax Calculator: Stock Options & RSUs

Estimate exit tax on unvested RSUs, stock options, and deferred equity when relocating from the US, Canada, or Australia. Interactive calculator plus jurisdiction rules.

18 min read

An expat exit tax calculator estimates the tax you may owe when a country treats your equity as sold—or your employment benefit as crystallized—because you stopped being a tax resident. For tech employees with unvested RSUs, in-the-money stock options, and deferred equity, the number depends on which country you are leaving, what is already vested, and whether you trigger a deemed disposition regime. Use the Expat Exit Tax Calculator for a dollar estimate, then read the jurisdiction sections below before you resign.

As of August 2026, we compared eight public relocation-tax resources and found none that modeled unvested RSU FMV and option spread in the same worksheet as §877A covered-expatriate tests—the gap this calculator and guide fill. Verified against IRS Publication 519 (2025) and Form 8854 instructions, accessed 23 August 2026.

$910K

2026 US mark-to-market exclusion on net deemed gain for covered expatriates

Rev. Proc. 2025-32; aggregate across all assets—not per lot. A Stripe engineer with $1.4M built-in gain on vested + unvested equity could owe federal tax on ~$490K of net gain before state layers

Data point: 2026 US mark-to-market exclusion on net deemed gain for covered expatriates equals $910K. Context: Rev. Proc. 2025-32; aggregate across all assets—not per lot. A Stripe engineer with $1.4M built-in gain on vested + unvested equity could owe federal tax on ~$490K of net gain before state layers

Which tool to use—and when

Methodology (23 August 2026): We mapped the employee relocation lifecycle (notice → last residency day → post-move vesting → dual-country filing) against CRA, ATO, and IRS primary guidance, then encoded the overlapping FMV inputs into the Expat Exit Tax Calculator.

Your questionUse thisWhen
How much exit tax on my equity if I leave the US?Expat Exit Tax Calculator (US mode)Before renouncing citizenship or abandoning a long-term green card
What if I emigrate from Canada with Shopify/Couche-Tard RSUs?Calculator (Canada mode) + Section 128.1 section belowBefore CRA departure return
What if I leave Sydney/Melbourne for the US?Calculator (Australia mode) + CGT event I1 sectionBefore ceasing Australian tax residency
Do I still owe California after I move?California sourcing guideState tail tax—not exit tax, but often confused
US citizen staying abroad (not expatriating)?International equity planningWorldwide US filing without §877A

US exit tax (IRC §877A) on stock options and RSUs

When you relinquish US citizenship or end long-term US residency (green card held in 8 of the prior 15 tax years), you may be a covered expatriate if any one of three tests applies on your expatriation date:

Test2026 thresholdSource
Net worth≥ $2,000,000 worldwideIRC §877(a)(2)
Average annual US net income tax> $211,000 (5-year average)Rev. Proc. 2025-32
Tax complianceFailure to certify 5 years on Form 8854IRC §877(a)(2)(C)

Covered expatriates are subject to mark-to-market under IRC §877A(a): all worldwide property is treated as sold at fair market value the day before expatriation. Net gain is taxed after a $910,000 exclusion (2026, inflation-indexed).1

How equity fits the deemed sale

InstrumentTypical §877A treatment (simplified)Planning note
Vested employer sharesBuilt-in gain = FMV − basisBasis may be low if acquired via ISO/NSO exercise or RSU vest
Unvested RSUsOften included in mark-to-market propertyFMV × unvested shares can be large at late-stage startups
Unexercised NSOs/ISOsSpread at FMV minus strike is gain elementISO AMT history does not eliminate exit tax on deemed sale
Eligible deferred compMay defer with Form W-8CE (30-day deadline)30% withholding on later distributions
Ineligible deferred compTaxed immediately at FMVMany private-company RSU plans fall here
Net deemed gain     = Σ (FMV − adjusted basis) across worldwide property + option/RSU elements
Taxable exit gain   = max(0, Net deemed gain − $910,000)    [2026 exclusion]
Estimated US tax    ≈ Taxable exit gain × blended LTCG/ordinary rate proxy

Where I'm less sure—employer plans that are foreign nonqualified deferred compensation under §877A(d) may escape immediate mark-to-market if they meet eligibility tests. Your mileage will vary depending on whether the issuer is a US corporation and whether the plan is documented as a non-grantor trust arrangement; do not assume Carta's label matches §877A buckets.

Quick Answer

Does the US exit tax apply to unvested RSUs?

For covered expatriates, unvested RSUs and unexercised options are generally part of the worldwide mark-to-market calculation—the deemed sale captures built-in value the day before expatriation unless a specific deferral regime applies. The 2026 exclusion of $910,000 applies to net gain across all assets in aggregate.

Source: IRC §877A; IRS Expatriation Tax guidance

Canada departure tax and employee equity

When you cease Canadian tax residency, Section 128.1 of the Income Tax Act triggers a deemed disposition of most capital property at FMV—often called departure tax. You file Form T1243 (calculation) and may elect to defer payment with Form T1244 (security may be required for large balances).2

What happens to RSUs and options

AssetDeparture tax (typical)Later Canadian tax
Vested shares in a brokerage accountDeemed sold at FMV — capital gain included (50% taxable)Future sale as non-resident may trigger Part XIII withholding
Unexercised employee stock optionsGenerally excluded from deemed dispositionEmployment benefit taxed under Section 7 at exercise
Unvested RSUs (not yet delivered)Plan-dependent; often employment income at vest, not 128.1T4 reporting when benefit becomes fixed

Steel-man: "Canada taxes my unvested RSUs on departure because Compass Abroad says options are deemed disposed."
Best case for that view: Some advisers treat restricted shares differently from unexercised options; CCPC versus public-company plans diverge.
Rebuttal: CRA and major firms (Grant Thornton, SiLaw) consistently list unexercised employee stock options as excluded under subsection 128.1(10)—tax waits for exercise. Unvested RSUs that are not yet shares may still create a large future Canadian wage inclusion tied to Canadian workdays, not a departure-day capital gain. Map your grant agreement before you assume 128.1 catches everything.

For US citizens in Toronto or Vancouver, layer the Canada equity guide for US persons on top of departure planning.


Australia CGT event I1 and ESS interests

When you cease Australian tax residency, CGT event I1 (ITAA 1997 s.104-160) treats most non-taxable Australian property assets as disposed at market value. You may:

  1. Accept the deemed disposal and pay CGT in your departure-year return, or
  2. Elect to disregard the deemed disposal—assets stay in the Australian CGT net until actual sale (with foreign-resident discount apportionment).

Employee share scheme (ESS) interests follow deferred taxing points and foreign income apportionment—not the same line as a vanilla ASX ETF holding. Unvested awards may accelerate when employment risk ends; cross-border moves split income by where duties were performed.3

See the Australia ESS guide and Australia country overview.


Expat exit tax calculator: inputs and formulas

The Expat Exit Tax Calculator uses the same FMV worksheet for all three jurisdictions:

InputSource documentWhy it matters
Vested shares — total FMVBroker statement + 409A/last tradeDrives mark-to-market / I1 gain
Vested shares — aggregate basisTrade confirms, Form 3921, RSU vest slipsReduces built-in gain
Unvested RSU / deferred equity FMVEquity portal (Carta, Shareworks)US §877A often includes; CA/AU may not
In-the-money option spread(FMV − strike) × optionsDeemed gain element for US; CA often deferred
Marginal rate %Your federal + surcharge proxyConverts gain → cash estimate
Built-in gain (all modes) = max(0, Vested FMV − Vested basis) + Unvested FMV + Option spread

US taxable gain         = max(0, Built-in gain − $910,000)   [if covered expatriate]
Canada taxable income   = 50% × Built-in gain on vested shares only (simplified)
Australia taxable gain    = 50% × Built-in gain on eligible CGT assets (discount assumed)

Anecdotally, employees who enter only vested brokerage FMV and forget unvested RSU FMV understate US exit tax by six figures—I have not tested every late-stage unicorn cap table, but the pattern shows up repeatedly in cross-border intake questionnaires.


Worked example: James, staff engineer leaving the US for Portugal

James (fictional composite) holds:

  • 12,000 vested shares of a late-stage US startup: FMV $42/share, aggregate basis $8/share → built-in gain $408,000
  • 18,000 unvested RSUs: FMV $42/share → $756,000 deemed element
  • ISO spread: $95,000 in-the-money on unexercised grants
  • Net worth $3.1M; average US tax $168,000; fully compliant
LineAmount
Total built-in gain$1,259,000
Less §877A exclusion (2026)($910,000)
Taxable deemed gain$349,000
Federal tax proxy at 23.8%≈ $83,062

Taken position for James: Expatriation is viable but not "tax-free"—the unvested RSU block drives the bill more than vested shares. He models whether Form W-8CE deferral applies to any tranche before picking his expatriation date. Pair with Portugal IFICI considerations for the arrival side.


Worked example: Aisha, senior PM emigrating from Canada to Texas

Aisha departs Canada for a Dallas role:

  • 4,500 vested shares (public tech employer): FMV C$185/share, ACB C$62/share → gain C$553,500
  • Unvested RSUs: FMV C$420,000 (not in 128.1 model)
  • Unexercised options: excluded until exercise
  • Marginal combined rate proxy 48%
LineAmount
Deemed capital gainC$553,500
Taxable income (50% inclusion)C$276,750
Estimated departure tax≈ C$132,840

She files T1161 (property > C$25,000), T1243, and evaluates T1244 deferral with CRA security requirements. Taken position: Aisha's cash need is C$133K on departure for vested stock alone—unvested RSUs remain a future wage event, not today's departure tax.


Original research: expat exit tax calculator feature matrix

On 23 August 2026, we audited eight public resources for whether they accept unvested RSU FMV, option spread, and jurisdiction-specific thresholds in an interactive worksheet (standard scenario: $850K vested gain, $400K unvested FMV, $250K option spread):

ResourceUnvested RSU inputOption spread inputUS §877A exclusionCanada 128.1 / T1244 noteAustralia I1 / ESS note
VestingStrategy Expat Exit Tax CalculatorYesYesYes ($910K)Yes (options excluded note)Yes (ESS caveat)
Greenback expatriation tax guideProse onlyProse onlyYesNoNo
CPA Validated §877A guide (2026)No interactiveNoYesNoNo
Tax Exodus Canada departure tax blogNoPartial proseNoYesNo
Skybound CGT event I1 guideNoNoNoNoYes (prose)
TurboTax international help centerNoNoPartialNoNo
HR Block cross-border articlesNoNoPartialPartialNo
Carta relocation webinar materialsPartial (FMV concepts)NoNoNoNo
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US vs Canada vs Australia: equity exit tax at a glance

TopicUnited States (§877A)Canada (128.1)Australia (I1 + ESS)
TriggerExpatriation (citizenship / long-term GC)Cease tax residencyCease tax residency
Vested sharesMark-to-marketDeemed dispositionCGT event I1 (or defer election)
Unvested RSUsUsually in MTM baseOften future employment incomeESS deferred taxing point / apportionment
Unexercised optionsSpread in MTMTypically excluded until exerciseESS rules; not standard I1 shares
Key exclusion / deferral$910K net gain (2026)T1244 deferral with securityI1 disregard election (all-or-nothing)
Primary forms8854, W-8CET1161, T1243, T1244Income tax return + ESS schedules

Pros and cons: accelerate vesting vs leave awards unvested

Pre-departure equity timing strategies

Recommended: Depends on jurisdiction — no universal winner

FeatureAccelerate vesting / exercise before departureKeep awards unvested through departure date
US §877A exposureCrystallizes ordinary wage income pre-expatriation; may reduce MTM base if already taxedUnvested FMV often still in MTM for covered expatriates
Canada departure taxMay convert future wage into present capital gain on sharesOptions often stay out of 128.1; RSUs taxed later on Canadian workdays
Cash flowRequires cash for exercise and immediate tax withholdingDefers cash tax but may concentrate exit-tax risk
Employer consentNeeds HR/legal approval; may be impossible pre-IPONo negotiation friction

Taken position: For US covered expatriates with >$910K combined built-in gain, negotiating partial acceleration only helps if it shifts value from MTM property into already-taxed wages—run the calculator both ways. For Canada, accelerating option exercise before departure can be worse than leaving options unexercised (excluded from 128.1). Do not copy a US playbook into Toronto without redoing the model.


Working checklist


Verdict: calculate before you hand in notice

The expat exit tax calculator search intent is not academic—it is "will I owe six figures if I move?" The answer is often yes when unvested equity FMV meets US §877A or when Canadian vested holdings hit 128.1, but the opposite can be true for unexercised Canadian options or Australian ESS deferrals.

Taken position: Run the Expat Exit Tax Calculator with honest FMV (including unvested RSUs) the week you start exploring relocation—not after HR processes your resignation. If US mode shows covered-expatriate exposure above the $910,000 exclusion, treat Form 8854 and W-8CE deadlines as hard constraints. If Canada mode shows a six-figure departure tax on vested shares only, price T1244 security before you book flights.

The expatriation tax applies to U.S. citizens who have renounced their citizenship and long-term residents who have ended their U.S. resident status for federal tax purposes—covered expatriates are subject to mark-to-market on worldwide property.

— IRS International Taxpayers, Expatriation Tax, checked 23 August 2026


Frequently Asked Questions

What is an expat exit tax on stock options and RSUs?

Answer: It is the tax triggered when a country treats you as having sold—or received—a benefit from equity because you stopped being a tax resident. The US uses IRC §877A mark-to-market for covered expatriates; Canada uses deemed disposition under Section 128.1; Australia uses CGT event I1 plus separate ESS rules for employee awards.

Source: IRS Expatriation Tax

How do I calculate exit tax on unvested RSUs?

Answer: For US covered expatriates, include unvested RSU FMV in the worldwide mark-to-market base minus your aggregate $910,000 exclusion (2026). For Canada, unvested RSUs often are not part of departure tax—they may be taxed as employment income when they vest based on Canadian service days. Use the Expat Exit Tax Calculator with the unvested FMV field and read the jurisdiction notes in the results panel.

Does leaving the US trigger exit tax if I keep my green card?

Answer: Only if you are a long-term resident (green card in 8 of the prior 15 years) and a covered expatriate. Simply moving abroad while remaining a US resident alien for tax purposes does not trigger §877A—you continue worldwide US taxation under normal rules.

What is the 2026 US exit tax exclusion amount?

Answer: $910,000 of net gain from the deemed sale of worldwide property (Rev. Proc. 2025-32). It applies in aggregate, not per asset. The average annual US net income tax test for covered expatriate status is $211,000 for 2026.

Are Canadian stock options taxed on departure?

Answer: Unexercised employee stock options are generally excluded from the Section 128.1 deemed disposition. Tax typically arises under Section 7 when you exercise. Vested shares in a brokerage account are usually subject to departure tax.

Source: Grant Thornton — Leaving Canada

What happens to ESS awards when I leave Australia?

Answer: CGT event I1 may deem disposal of shares you already hold. ESS interests follow deferred taxing points and may be apportioned between Australian and foreign employment. Flag unvested equity to both Australian and destination-country advisers before ceasing residency.

Source: ATO — Employee share schemes

Can I defer exit tax?

Answer: US: eligible deferred compensation may defer with Form W-8CE; mark-to-market property generally does not. Canada: Form T1244 may defer departure tax until actual sale (security often required). Australia: you may elect to disregard CGT event I1 and remain in the Australian CGT net until disposal.

Is this calculator personalized tax advice?

Answer: No. The Expat Exit Tax Calculator is an educational model with simplified rates and exclusions. Consult a cross-border CPA before expatriating, emigrating, or accelerating equity.


Footnotes


Primary Sources

SourceTypeURL
IRS Expatriation TaxGovernmentirs.gov
IRC §877AStatutelaw.cornell.edu
Form 8854 InstructionsGovernment formirs.gov
Canada ITA s.128.1Statutejustice.gc.ca
Grant Thornton — Leaving CanadaProfessionalrcgt.com
ATO Employee Share SchemesGovernmentato.gov.au
ITAA 1997 CGT event I1Statuteato.gov.au

Disclaimer: This guide discusses legal tax optimization strategies only and is not personalized tax, legal, or immigration advice. Exit tax outcomes depend on residency facts, plan documents, and treaty positions. Consult qualified cross-border professionals before relinquishing citizenship, emigrating, or accelerating equity.


Last Updated: August 2026 | Research Team: VestingStrategy

Footnotes

  1. IRC §877A(a); IRS Rev. Proc. 2025-32 (2026 exclusion $910,000; tax liability threshold $211,000).

  2. Income Tax Act (Canada) s.128.1; CRA departure tax guidance; Form T1243/T1244.

  3. ITAA 1997 s.104-160 (CGT event I1); ATO ESS materials on deferred taxing points and foreign income apportionment.

Disclaimer

This article is for educational purposes only and discusses legal tax optimization strategies. Tax evasion is illegal and is not discussed or recommended. The information provided does not constitute tax, legal, or financial advice.

Tax laws vary by jurisdiction and change frequently. Always consult a qualified tax professional (CPA, tax attorney, or enrolled agent) before making decisions based on this content. The authors and operators of this website accept no liability for actions taken based on this information.