Last week the I.R.S. published Revenue Procedure 2011-52, setting forth inflation adjusted items for 2012.  In the international arena, some of the important inflation adjustments include:

$151,000 — Code § 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 Code § 877A(g)(1).  This amount is up from $147,000 in 2011.  See Rev. Proc. 2010-40.

$651,000 — Code § 877(a)(1) — The amount that can be excluded from the mark-to-market gain upon expatriation of a covered expatriate.  This amount is up from $636,000 in 2011.  See Rev. Proc. 2010-40.

$95,100 — Code § 911(b)(2)(D)(i) — Foreign earned income exclusion.  This amount is up from $92,900 in 2011.  See Rev. Proc. 2010-40.

$13,000 — Code § 2503 — The amount of the annual gift tax exclusion for gifts to any person.  This amount is the same at $13,000 as in 2011.  See Rev. Proc. 2010-40. 

$139,000 — Code § 2523(i) — The amount of the annual gift tax exclusion for gifts to non-citizen spouses.  This amount is up from $136,000 in 2011.  See Rev. Proc. 2010-40. 

$14,723 — Code § 6039(F) — Notice of large gifts received from foreign persons.  This amount is up from $14,375 in 2011.  See Rev. Proc. 2010-40.

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