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Part 5. Collecting Process

Chapter 21. International and Insular Issues

Section 1. Expanded Definition of International Field Collection (FC) Program Casework

5.21.1 Expanded Definition of International Field Collection (FC) Program Casework

Manual Transmittal

July 01, 2026

Purpose

(1) This transmits a revision of IRM 5.21.1, Expanded Definition of International Field Collection (FC) Program Casework, for collection employees.

Material Changes

(1) IRM 5.21. name changed from "International and Insular Issues" to "International Collection" .

(2) IRM 5.21.1 name changes to from "Overview" to "Expanded Definition of International Field Collection (FC) Program Casework."

(3) IRM 5.21.1 updated to expand the definition of an International FC program case.

(4) IRM 5.21.1 added sources of International inventory.

(5) IRM 5.21.1.3 incorporates IGM SBSE-01-1124-00, Interim Guidance on Assignment of Form 706-NA Estate Tax Cases to International non-ATAT Revenue Officers issued on 11-6-2024. This adds identified MFT 52 cases as sources of International inventory.

(6) IRM 5.21.1 updated to expand indicators requiring an International Field Compliance Manager consultation.

(7) IRM 5.21.1 updated to include additional International Inventory, such as military addresses.

Effect on Other Documents

IRM 5.21.1, dated October 19, 2017, is superseded.

Audience

Revenue officers (ROs) in SB/SE Field Collection (FC)

Effective Date

(07-01-2026)

Thomas D. Kramer
Director, Collection Policy

5.21.1.1 (10-19-2017)

Program Scope and Objectives

  1. Purpose. This IRM provides specific procedural guidance for International Field Collection (FC) revenue officers (ROs). These procedures may also be of interest for those outside of the International FC program.

  2. Audience. The audience is ROs in Small Business/Self-Employed (SB/SE) FC.

  3. Policy Owner. The Director of Collection Policy is responsible for issuing policy for the International FC program.

  4. Program Owner. The program owner is Collection Policy, Global Strategic Compliance, an organization within the SB/SE Division.

  5. Primary Stakeholders. The primary stakeholder is SB/SE Collection.

  6. Program Goals. The goal of this IRM is to provide fundamental knowledge and procedural guidance for working international FC program cases.

5.21.1.1.1 (10-19-2017)

Background

  1. This IRM section defines matters that specifically relate to international collection issues. In today's global economy, an increasing number of taxpayers (TPs) live, work or conduct business overseas. United States (U.S.) citizens, residents of the U.S., and U.S. businesses are becoming more and more involved in international transactions. The U.S. is one of a very few countries in the world that taxes its citizens and residents on their worldwide income. The role of an International RO is essential in ensuring TP compliance with the tax laws and reducing the tax gap and is expanding in scope based on the expansion of international impact.

5.21.1.1.2 (10-19-2017)

Authority

  1. Congress has delegated to the IRS the responsibility of administering the tax laws, known as the Internal Revenue Code, found in Title 26 of the United States Code. Congress enacts these tax laws, and the IRS enforces them.

5.21.1.1.3 (10-19-2017)

Roles and Responsibilities

  1. The Director, Collection Policy, is the executive responsible for the policy and procedures utilized by Collection personnel.

  2. FC RO Group Managers (RO GM) and Field Compliance Managers (FCM) are responsible for ensuring compliance with the guidance and procedures described in this IRM.

5.21.1.1.4 (10-19-2017)

Program Management and Review

  1. Collection Policy will conduct ad hoc International program reviews as necessary to verify compliance with Internal Revenue Manual (IRM) requirements and to address Treasury Inspector General for Tax Administration/U.S. Government Accountability Office findings.

  2. FC RO GMs conduct case reviews to ensure compliance with this IRM.

  3. The International FCM and Area Director conduct operational reviews annually to evaluate program delivery and conformance to administrative and compliance requirements.

5.21.1.1.5 (10-19-2017)

Program Controls

  1. RO GMs, as well as FCMs and Area Directors, are required to approve certain RO case actions. The IRM outlines when approval is required and the level of approval necessary.

5.21.1.1.6 (10-19-2017)

Acronyms

  1. This table lists commonly used acronyms and their definitions:

    Acronym Definition
    ATAT Abusive Tax Avoidance Transaction
    FATCA Foreign Account Tax Compliance Act
    FCM Field Compliance Managers
    ICS Integrated Collection System
    IDRS Integrated Data Retrieval System
    IRM Internal Revenue Manual
    MFT Master File Tax
    POA Power of Attorney
    RO Revenue Officer
    RO GM Revenue Officer Group Manager
    SB/SE Small Business/Self-Employed
    TECS TECS
    TIN Taxpayer Identification Number
5.21.1.1.7 (10-19-2017)

Related Resources

  1. Additional information and guidance on international collection issues can be found in the following IRM sections.

    • See the additional chapters of IRM 5.21, International Collection on international field collection program procedures.

    • See IRM Part 5, Collecting Process, for additional information on general FC issues such as initial contact, courtesy investigations, special rules on mailing correspondence, TECS, and international currently not collectible closing code 06.

    • Additional information can also be found at Knowledge Management, Collection Floor, International Tools and Actions.

5.21.1.2 (10-19-2017)

Expanded Definition of an International Case

  1. Servicewide, a TP’s account is defined as an international case when the primary mailing address is associated with a country outside the United States. International cases are not aligned by domestic ZIP code. These cases may include addresses with APO, FPO, or DPO designations, or other indicators of a non-domestic location, and are routed through a shared international inventory rather than standard geographic group queues

  2. Furthermore, in FC, the definition of an international case can be expanded to be defined by case

    • Location,

    • Tax type, and/or

    • Attributes.

  3. The location, tax type and account attributes are evaluated together to determine whether a TP account should be treated as an international case.

  4. These identified cases require consideration for assignment to International FC revenue officers (ROs), who receive specialized training to effectively work complex, international collection issues.

  5. There may be instances when a FC case has international tax types and/or attributes but is assigned to the General FC program based on a domestic mailing address. In these circumstances, additional consideration and consultation is needed for appropriate case assignment by the RO group manager (GM).

5.21.1.2.1 (10-19-2017)

IDRS Universal Location Codes

  1. The Integrated Data Retrieval System (IDRS) assigns universal location codes based on the TP’s address of record.

  2. Universal location code "9835" identifies a case with an international address and is based on the country listed in the taxpayers address of record, designating the territory.

  3. Universal location codes can be viewed on IDRS command codes INOLE and ENMOD, please see the CCJA - IDRS Command Code Job Aid for additional information.

5.21.1.2.2 (10-19-2017)

Expanded International Case Definition - International Attributes without an International Address

  1. In certain situations, cases with a domestic mailing address may still qualify as International FC program cases.

  2. These cases may be assigned or reassigned to the International program based on the presence of international attributes.

5.21.1.3 (10-19-2017)

Sources of International Program Cases

  1. Cases that meet international attributes or which have a primary mailing address not aligned to a domestic Zip Code are systemically displayed in the International FC program queue for assignment to an International RO.

  2. The Form 706-NA (MFT 52) cases with international addresses that have an IRS assigned internal revenue service number (IRSN) that starts with "9". The Form 706-NA (MFT 52) cases with international addresses that are being redirected to International ROs have an IRS assigned internal revenue service number (IRSN) that starts with "9".

5.21.1.3.1 (10-19-2017)

Domestic Address with International Attributes

  1. Cases with a domestic address are systemically assigned as domestic cases.

  2. If a domestic case contains certain international attributes, it will be reviewed for classification and reassignment to the FC International program.

5.21.1.3.2 (10-19-2017)

Tax Return Exceptions Requiring International Assignment Consideration

  1. A case may require manual assignment to the International FC program if it includes any of the following tax return types that involve complex international tax issues requiring specialized training such as:

    • MFT 52 – Form 706 - NA, U.S. Estate (and Generation-Skipping Transfer) Tax Return. This applies to Form 706-NAs which are identified by a Taxpayer Identification Number (TINs) that starts with a "9" , or

    • MFT 17 – Form 8288, U.S. Withholding Tax Return for Dispositions by Foreign Persons of U.S. Real Property Interests, and

    • MFT 12 - Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons.

5.21.1.3.3 (10-19-2017)

International FC GM Consult

  1. Other factors may warrant case transfer to the International FC program. Consultation with an International FC RO GM is required to determine if a transfer or OI is appropriate for a case with international case attributes such as but not limited to:

    • Domestic address but it becomes known that the TP resides internationally

    • Foreign or dual-status citizenship of the TP

    • References to tax treaty claims made by the TP or Power of Attorney (POA)

    • History of travel outside of the U.S.

  2. Additionally, FC RO GM consultation is required to determine if a transfer or an OI is appropriate on cases involving tax returns such as but not limited to:

    • Form 2555, Foreign Earned Income

    • Form 8833, Treaty-Based Return Position Disclosure (IRC 6114 or 7701(b))

    • Form Form 8804 , Annual Return for Partnership Withholding Tax, or Form 8805, Foreign Partner's Information Statement of Section 1446 Withholding Tax

    • Form 8288-A, Statement of Withholding on Dispositions by Foreign Persons

    • Form 8938, Statement of Specified Foreign Financial Assets

    • Form 8966, FATCA Report

    • Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts

    • Form 3520-A, Annual Return of Foreign Trust With a U.S. Owner

    • Form 1116, Foreign Tax Credit

5.21.1.3.4 (10-19-2017)

International Resources

  1. For consultation contacts with International RO GMs, follow the research path from Knowledge Management Virtual Library, Collection Floor, International Tools and Actions, under the International Resources chapter.

    Note:

    For Courtesy Investigations, please see IRM 5.1.8, Courtesy Investigations.

5.21.1.4 (07-01-2026)

Examples of cases with domestic addresses requiring International RO GMs consultation

  1. The list below includes examples of situations where a case would require consultation with an International RO GM to determine if it would need to be transferred to the International FC program:

    • TP resides abroad but uses a power of attorney’s domestic address to receive IRS correspondence.

    • TP uses a US mail forwarding service, PO Box, or mail drop while residing abroad.

    • TP has a domestic address but there are FATCA form indicators present.

    • TP resides in Mexico or Canada and uses a fixed US address while crossing the border on a regular basis.

    • TP files domestic tax return with Form 2555 attachment, demonstrating significant foreign presence.

    • Business TP has an international parent corporation but uses a domestic subsidiary’s address.

5.21.1.5 (07-01-2026)

Additional International Inventory

  1. Additional categories of cases are designated to the International program for international RO assignment, such as Military cases and certain ATAT cases.

5.21.1.5.1 (07-01-2026)

International Military Mail Cases

  1. Military mail cases use a domestic address format but are aligned as an international case for assignment purposes based on zip code format.

  2. A typical military mailing address includes:

    • Taxpayer Name

    • Foreign Postal Service Center + Military Identifier

    • APO/FPO/DPO, AP/AA/AE ZIP

5.21.1.5.2 (07-01-2026)

Military Address Identifiers

  1. Military "States" :

    • AA - Armed Forces Americas

    • AE - Armed Forces Europe

    • AP - Armed Forces Pacific

  2. Military "City" Equivalents:

    • APO - Army Post Office

    • FPO - Fleet Post Office

    • DPO - Diplomatic Post Office

  3. Each military state is assigned a specific ZIP code range based on TP location.

  4. APO, FPO, and DPO addresses function similarly to post office boxes but are located overseas on military bases or at U.S. embassies.

5.21.1.6 (10-19-2017)

Abusive Tax Avoidance Transaction (ATAT) Cases

  1. FC cases that contain ATAT special project or civil penalty codes but have an international address of record are worked by International ATAT ROs in the International FC program.

  2. Address-based determination

    • ATAT cases with an international address are classified as international ATAT cases.

    • These cases are systemically assigned to the International FC GM hold file for International ATAT RO assignment.

  3. For additional information on ATAT cases, see IRM 5.20.1, Abusive Tax Avoidance Transactions.