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Part 5. Collecting Process

Chapter 21. International and Insular Issues

Section 1. Overview

5.21.1  Overview

5.21.1.1  (02-17-2009)
Introduction

  1. This section of the Internal Revenue Manual defines matters that specifically relate to international collection issues. In today's global economy, there are an increasing number of taxpayers who travel and work overseas. United States taxpayers, residents of the U.S., and U.S. businesses are becoming more and more involved in international transactions.

  2. The United States 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 revenue officer is very important in ensuring taxpayer compliance with the tax laws and reducing the tax gap.

  3. This IRM provides specific procedural guidance for international revenue officers. These procedures may also have applications that domestic revenue officers may find useful.

  4. This IRM does not encompass all international collection issues. International collection issues such as Mutual Collection Assistance Request (MCAR), Courtesy Investigations, International Currently Not Collectible Closing Code 06, Treasury Enforcement Communication System (TECS), Initial Contact, and special rules on mailing correspondence are covered in other parts of the IRM.

5.21.1.2  (02-17-2009)
Definition of an International Case

  1. An international case is a taxpayer or business having a current address outside the United States. The primary factor that determines an international case is the address of the taxpayer.

  2. Although the address of the taxpayer or business is a key factor, it is not the only factor in determining if the case is an international case. Usually, if the taxpayer has a domestic address, the case is assigned to a domestic collection group. However, there are exceptions where the case may have a domestic address but the case is an international case.

  3. The following are examples of an international case where the taxpayer has a domestic address.

    Example:

    A taxpayer resides abroad but uses his power of attorney's (POA) domestic address as his official address. This is usually the case in countries where the mail system is unreliable. The taxpayer uses his POA's domestic address to ensure that he receives his mail from the Internal Revenue Service.

    Example:

    A taxpayer who uses a mail forwarding service, a mail drop box or PO Box while residing outside the United States. Some taxpayers live on the Mexican or Canadian side of the border, but cross the border daily to pick up their mail sent to the U.S. address.

5.21.1.2.1  (02-17-2009)
Difference Between Domestic ATAT and International ATAT Cases

  1. More and more cases are identified as abusive tax avoidance transactions (ATAT) cases with the promotion of abusive schemes by taxpayers and promoters, and these cases are making their way into revenue officers' inventories. The process of determining the difference between an ATAT domestic case and an ATAT international case depends on the address of the taxpayer.

  2. A taxpayer with a current international address involved in an abusive scheme is an international ATAT case.

    1. See IRM 5.1.6.1.4,Account Transfers to International, for more information on transferring cases to international.

  3. Generally, domestic ATAT cases:

    1. are identified through Issue Management Teams which identify promoters, preparers, and participants.

    2. are developed by Examination and other Operating Divisions and functions.

  4. Generally, international ATAT cases:

    1. are identified by an international revenue officer or a direct result of an examination function examination.

    2. are developed on taxpayers attempting to avoid paying U.S. taxes.

    Note:

    Coordination between international revenue officers and ATAT revenue officers is essential in identifying domestic and foreign assets, and can provide both functions with valuable information.


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