Yes, even if you are not a “covered expatriate” under the Exit Tax tests and don’t owe any Exit Tax, you must file Form 8854. The Form 8854 is required for US citizens as part of the filings to end their US tax residency. It is also required for long-term permanent residents who held their green card in at least 8 of the last 15 years. On this form, you show that you don’t meet the thresholds to be a covered expatriate. And you certify that your past 5 years’ worth of filings were complete and accurate.
