Understanding Your CP47A Notice

What this notice is about

You elected to defer payment of your IRC Section 965 net tax liability.

What you need to do

  • Follow the instructions in your notice carefully.
  • Make timely annual installment payments as required by IRC Section 965(h).

Frequently asked questions

Will I be penalized if I can't pay the full installment amount by the due date?

Yes.  You may be penalized for failure to pay and the full amount of your net tax liability may become due immediately.

Can I choose how to apply an overpayment if I pay more than the installment amount?

No. We’ll apply it to the remaining net tax liability until it is paid in full.  We can only refund or apply credit-elect payments or credits exceeding the full income tax liability.

What should I do if I disagree with the notice?

Call the toll-free number listed on your notice to review your account with a representative. Have your account information available when you call.

Helpful Information

How to Calculate Section 965 Amounts and Elections Available to Taxpayers PDF

Need Help?

  • You can authorize someone to contact the IRS on your behalf.
  • If you can’t find what you need online, call the IRS number at the top of your notice or letter.