Published: August 27, 2024 | Last Updated: February 3, 2026

Reduce Compliance Challenges for Taxpayers Abroad

Background

Taxpayers abroad face significant challenges in meeting their U.S. tax obligations and they are plagued by a complex tax code and declining levels of IRS customer service. They can be liable for severe penalties for failing to file or incorrectly filing their tax returns and complicated international information returns, of which they may not be aware. Yet, they have no access to in-person IRS assistance and almost no ability to access free return preparation assistance. Additionally, taxpayers abroad often encounter significant delays in receiving correspondence from or sending correspondence to the IRS and have insufficient timeframes in which to respond to key IRS notices, which causes them to lose critical administrative, due process, and judicial rights. Other challenges include difficulties in obtaining Individual Taxpayer Identification Numbers and checking on their application status, access to only one dedicated IRS telephone line (that is not toll-free), language barriers, problems accessing online resources, and limited payment and refund options. Despite the multitude of challenges facing taxpayers abroad, the IRS offers only limited assistance, and many IRS systems are still not compatible with the needs of this population. The complexity of U.S. tax laws and the lack of accessible IRS customer service and assistance burdens taxpayers, especially those abroad, causes frustration, and impedes compliance. To protect taxpayer rights and improve voluntary compliance for this population, the IRS needs to educate and assist taxpayers abroad, improve customer service options, and reduce the challenges these taxpayers face.

Highlights

Status

Activities

Activity 1: Meet with stakeholders and representatives for international taxpayers to better understand the difficulties they face in complying with their U.S. tax obligations and make recommendations to the IRS to reduce compliance burdens.

Activity 2: Work with the IRS to identify which IRS forms and publications individual taxpayers abroad use most and recommend the IRS prioritize them for translation into languages other than English.

Activity 3: Review IRM provisions and IRS correspondence products to identify circumstances in which taxpayers abroad do not have sufficient time to respond and make recommendations to the IRS to revise such notices and procedures to provide additional time.

Activity 4: Review the FAQs about international individual tax matters on IRS.gov applicable to U.S. taxpayers abroad and provide specific suggestions to the IRS about how to improve that content to make it more helpful to taxpayers abroad.

Activity 1: TAS interviewed stakeholders and representatives of international taxpayers while conducting research and reviews for the 2024 Most Serious Problem (MSP) “Civil Penalty Administration” and “Criminal Voluntary Disclosure”. The feedback received was included in the 2024 MSPs. Recommend activity be closed.

Activity 2: Following TAS’s recommendation, the IRS began evaluating whether taxpayers abroad should be classified as limited English proficiency (LEP). On March 1, 2025, Executive Order (EO) 14,244 was signed Designating English as the Official Language of the United States. This rescinded EO 13,166, which required agencies to provide LEP services, and suspend existing guidance.

Activity 3: TAS actively engaged in data-gathering efforts to ensure taxpayers abroad have sufficient time to respond to IRS correspondence. In addition, TAS reviewed Internal Revenue Manual (IRM) provisions through Internal Management Document process to support this work. TAS is considering addressing this issue on its next Annual Report to Congress, proposing administrative recommendations to the IRS. TAS is also making Legislative recommendations which, if enacted, would lessen compliance challenges with respect to IIRs. Additionally, TAS is considering including recommendations in the Purple Book dealing specifically with hardships from mail delays for taxpayers abroad.

Activity 4: TAS is actively reviewing the IRS’s FAQs related to international tax issues for U.S. Taxpayers living abroad. This work is ongoing, with TAS evaluating the content and identifying opportunities to recommend improvements that would make the information clearer and more helpful for taxpayers overseas.

1st Quarter Actions Completed

TAS continues to participate in data gathering calls to ensure taxpayers abroad are provided sufficient time to respond to IRS correspondence.

TAS has conducted and continues to conduct reviews of the Internal Revenue Manual (IRM) provisions through the Internal Management Document process.

The Taxpayer Advocate Service (TAS) will initiate work on activity number 4 by March 31, 2025.

2nd Quarter Actions Completed

TAS interviewed stakeholders and representatives of international taxpayers while conducting research and reviews for the 2024 Most Serious Problem (MSP) “Civil Penalty Administration” and “Criminal Voluntary Disclosure”. The feedback received was included in the 2024 MSPs. TAS recommended to the IRS that they identify which forms and publications individual taxpayers abroad use the most. The IRS first needs to initiate a research study to know if the population is considered limited English proficient (LEP), and which languages would apply to this population. It will then tailor language-related initiatives and services geared toward this population. The Withholding, Exchange, and International Individual Compliance (WEIIC) Practice Area continues to look at this request to see if a study is something they have the resources for and that can assist with the recommendation. TAS continued to participate in data gathering calls to ensure taxpayers abroad have sufficient time to respond to IRS correspondence. TAS conducts reviews of the Internal Revenue Manual (IRM) provisions through the Internal Management Document process. TAS conducted reviews of the IRS’s FAQs about international individual tax matters applicable to U.S. taxpayers abroad. TAS continues to look for opportunities to provide specific suggestions to the IRS about how to improve that content to make it more helpful to taxpayers abroad.

3rd Quarter Actions Completed

TAS recommended that the IRS determine which forms and publications are most used by taxpayers living abroad. Additionally, TAS advised the IRS to assess whether this population should be classified as limited English proficiency and to identify which languages are relevant to better customize language services and initiatives. The Withholding, Exchange, and International Individual Compliance Practice Area is currently reviewing whether it has the necessary resources to carry out this study and support the recommendation.
TAS Actively participated in data-gathering efforts to ensure taxpayers living abroad are given enough time to respond to IRS correspondence. Additionally, TAS reviewed the Internal Revenue Manual provisions through the Internal Management Document process to support this work.

TAS is actively reviewing the IRS’s FAQs related to international tax issues for U.S. Taxpayers living abroad. This work is ongoing, with TAS evaluating the content and identifying opportunities to recommend improvements that would make the information clearer and more helpful for taxpayers overseas.

Next Steps

TAS will continue to work with the IRS to identify which IRS forms and publications individual taxpayers abroad use most. TAS will evaluate the content and identifying opportunities to recommend improvements that would make the information clearer and more helpful for taxpayers overseas.

Return to FY26 Objective Statuses