If you expatriated after June 16, 2008, new expatriation rules apply to you if any of the following statements apply.
* Your average annual net income tax for the 5 years ending before the date of expatriation or termination of residency is more than $139,000 (if you expatriated or terminated residency before January 1, 2009).
* Your net worth is $2 million or more on the date of your expatriation or termination of residency.
* You fail to certify on Form 8854 that you have complied with all U.S. federal tax obligations for the 5 years preceding the date of your expatriation or termination of residency.