You're a covered expatriate also if: " You fail to certify on Form 8854 that you have complied with all federal tax obligations for the 5 tax years preceding t

You're a covered expatriate also if: " You fail to certify on Form 8854 that you have complied with all federal tax obligations for the 5 tax years preceding the date of your expatriation. " I agree you should pay up your taxes but this will not only recover the due taxes but it will take more.