IRS Passport Revocation – 2025 Definite Guide – Part II

Leave a Comment / 1. The IRS Collections Process, Passport Revocation / By

5. The State Department’s Role: What Happens After IRS Certification

Once the IRS certifies your debt under §7345, the ball moves to the U.S. Department of State (DOS). This is where passport consequences become real.

Application Denial

If you apply for a new passport or a renewal, the State Department will check your name against the IRS certification database. If you are flagged:

  • DOS will place your application on hold for 90 days.
  • During that time, you must resolve your IRS account (pay, agreement, exclusion).
  • If unresolved after 90 days, your application will be denied.

Revocation of Existing Passport

If you already hold a valid passport, DOS has the authority to revoke it. This is more serious and less predictable. Typically, revocation follows if:

  • The IRS issues Letter 6152 recommending revocation.
  • DOS deems your situation sufficiently non-compliant or urgent.

In practice, DOS tends to revoke fewer passports than it denies applications — but the risk is real.

Limited Validity Passports

If you’re abroad and your passport is revoked, DOS may issue you a limited-validity passport. This document allows you to travel back to the United States, but nowhere else. Imagine being in Europe for business and being told the only ticket you can buy is to New York. That’s not just inconvenient — it’s potentially devastating to careers and families.

No Negotiation with DOS

It’s important to stress: DOS does not negotiate with taxpayers. Their role is ministerial. If the IRS certification exists, DOS will act on it. If the IRS sends a reversal (CP508R), DOS updates its records. That’s the extent of it.

For this reason, arguing with passport agencies is wasted effort. The fix lies with the IRS.

6. Resolution Strategies in Detail

When facing passport certification, resolution paths fall into five main categories. Each has its own mechanics, timelines, and pitfalls.

1. Full Payment

The most straightforward solution: pay your balance in full. Once payment posts, the IRS will issue CP508R and notify DOS within about 30 days. In practice, this is rarely possible for high-balance taxpayers, but it’s the cleanest fix.

Pitfalls:

  • Large payments by check can take weeks to clear.
  • Bank wires or EFTPS are faster, but must be documented carefully.
  • If you’re close to the threshold, paying “just under” is not enough. Certification remains until the account is fully satisfied or an alternative agreement is in place.

2. Installment Agreement (IA)

An IRS-approved payment plan removes you from certification. Even partial payment agreements count.

Key Points:

  • The IA must be formally accepted. Proposals don’t protect you.
  • Compliance is required: all tax returns filed, current on withholding or estimated payments.
  • Streamlined IAs (balances up to $250,000) can be approved quickly and are often the fastest resolution.

Pitfalls:

  • Taxpayers often file an IA request and assume it’s effective immediately. Until IRS issues acceptance, you remain certified.
  • Defaulting on an IA reinstates certification.

3. Offer in Compromise (OIC)

An OIC is a negotiated settlement for less than the full amount owed. If your OIC is pending or accepted, you are protected.

Key Points:

  • Submitting Form 656 with the application fee and initial payment officially makes your OIC “pending.”
  • While under review (which can take 9–12 months), certification is suspended.
  • If accepted, you remain protected. If rejected, certification resumes.

Pitfalls:

  • OICs require strict eligibility and compliance. Many are returned for technical errors.
  • A returned OIC does not suspend certification. It must be “pending.”

4. Currently Not Collectible (CNC)

If you can prove financial hardship — that paying taxes would leave you unable to cover basic living expenses — the IRS may classify your account as CNC.

Key Points:

  • Requires detailed financial disclosure (Form 433-A or 433-F).
  • CNC status excludes you from certification.
  • This is often the best option for retirees, unemployed taxpayers, or those with health crises.

Pitfalls:

  • IRS reviews CNC periodically. If your financial situation improves, certification risk returns.

5. Bankruptcy

Filing bankruptcy excludes you from certification, as tax debts in bankruptcy are legally uncollectible during the proceeding.

Pitfalls:

  • Bankruptcy is a serious decision, with long-term credit and legal implications.
  • Not all tax debts are dischargeable.

7. Expedited Decertification: When Travel Cannot Wait

One of the most urgent scenarios I’ve faced is clients with imminent international travel who suddenly discover their passport application is blocked. Fortunately, there is a process for expedited decertification, but it’s narrow and documentation-heavy.

The Criteria

  • You must have a pending passport application with DOS.
  • DOS must have placed your application on hold because of IRS certification.
  • You must prove imminent travel (within 45 days).

The Process

  1. Secure Proof of Travel. Airline tickets, itineraries, or official invitations.
  2. Obtain the DOS Denial/Hold Letter. DOS must confirm they’ve placed your application on hold.
  3. Submit to IRS. Provide proof to the IRS unit handling certification.
  4. Request Expedited Decertification. IRS will, in some cases, reverse certification in less than the usual 30 days. I’ve seen it shortened to 7–14 days.

Limits

  • This process does not apply if you already hold a valid passport. It applies only to pending applications.
  • Travel must be imminent and documented.
  • IRS discretion is absolute; there is no statutory right to expedition.

Practitioner Example

A client needed to attend a family wedding overseas. His passport renewal was on hold. With proof of travel and a partial pay installment agreement accepted, we secured expedited decertification in 10 days. Without professional intervention, he would have missed the event.

8. Practical Timelines & Escalation

Understanding timelines is essential. Clients often panic when they receive CP508C, thinking revocation is immediate. In reality, the process unfolds over weeks to months.

Day 0: IRS Certification (CP508C Issued)

  • You are officially certified.
  • DOS is notified.

Days 1–30: Initial Response Window

  • DOS may hold pending applications for 90 days.
  • IRS awaits your action (payment, IA, OIC, CNC).

Day 30–90: State Department Hold

  • If you applied for a passport, DOS is holding your application.
  • If no resolution, DOS will deny after 90 days.

Beyond 90 Days: Escalation

  • IRS may issue Letter 6152, recommending DOS revoke your existing passport.
  • At this point, you are days to weeks from losing the document.

Decertification Window

  • Once resolved, IRS typically issues CP508R within ~30 days.
  • Expedited cases may be resolved in 7–21 days.

Practitioner Insight

One client ignored CP508C until the State Department denied her renewal. She assumed paying $10,000 (bringing her balance under the threshold) would suffice. It didn’t. Certification stood. Only after we secured a streamlined installment agreement did the IRS issue CP508R. Her renewal was approved six weeks later — but she missed critical business travel.

The lesson: partial payments don’t solve certification. Agreements do.

📌 General IRS Passport Revocation Guidance

📌 Notices (CP508C, CP508R, Letter 6152)

📌 Resolution Strategies

📌 State Department Role

📌 Expedited & Special Situations

    Related Posts

    Leave a Comment

    Your email address will not be published. Required fields are marked *