Check the certification
We review CP508C, the certified periods, account records and any exclusion that may apply.
The IRS certified your tax debt to the State Department
We review the certification, your tax records and any travel documents to identify an available request for reversal.
How it works
Document an available resolution
We assess payment, an accepted agreement or offer, hearing rights and hardship based on your facts.
Request reversal and follow up
After engagement and authorization, we submit the supported request; the IRS decides certification and the State Department decides passport action.
Which sounds like you?
What certification means
IRC §7345, enacted by the Fixing America's Surface Transportation (FAST) Act of 2015, Pub. L. 114-94, §32101, requires the IRS to report qualifying seriously delinquent federal tax debt through Treasury to the State Department. Certification is that report, not an IRS decision to issue or revoke a passport. The State Department generally denies issuance or renewal and may revoke or limit an existing passport under 22 U.S.C. §2714a.
CP508C tells you certification has already occurred; it is not an advance warning. Under IRM 5.19.25, it goes by regular mail to your last known address, not to your representative even if Form 2848 is on file. An account transcript, the IRS record of account activity, may show transaction code TC 971 AC 626 for certification and TC 972 AC 626 for reversal.
A current passport may remain usable until the State Department acts, but do not assume it remains valid. A denied new or renewal application generally has a 90-day hold described in the State Department's Letter to allow resolution. If you are overseas, contact the U.S. Embassy or Consulate about a limited-validity passport for direct return to the United States.
The debt threshold and other requirements
The existing 2026 threshold is more than $66,000, including tax, penalties and interest, under IRC §7345(b)(1). It adjusts annually under IRC §7345(f); the earlier figures were $64,000 in 2025 and $62,000 in 2024. All periods count together: $30,000 for 2022 plus $40,000 for 2023 totals $70,000.
Trust Fund Recovery Penalty liabilities under IRC §6672, personally owed business taxes and assessed civil penalties may count. That penalty concerns personal responsibility for certain unpaid business trust-fund taxes. A high balance alone is not enough; the other requirements also must be met.
- The IRS has assessed, or formally recorded, federal tax liability against an individual.
- The debt remains legally enforceable, including under the IRC §6502 collection statute expiration date (CSED), the deadline to collect.
- The balance exceeds the inflation-adjusted threshold at certification.
- A Notice of Federal Tax Lien under IRC §6323 has been filed and IRC §6320 hearing rights have lapsed or been exhausted, or a levy under IRC §6331 has been issued.
- No statutory exclusion under IRC §7345(b)(2) or applicable discretionary exclusion under IRM 5.19.25.5 applies.
A lien is the government's legal claim against property; a levy takes property to pay tax. Missing requirements, expired collection authority or an overlooked exclusion may support correction. The IRS and, where appropriate, a court decide whether certification was erroneous.
Ways certification can be reversed
Decertification is reversal under IRC §7345(c) of the certification under IRC §7345(a). The IRS sends CP508R, Reversal of Certification, and notifies the State Department; statutory 30-day notification rules apply to qualifying reversal events. Paying only enough to fall below $66,000 does not itself require reversal.
Pay the certified debt in full
Full payment includes tax, penalties and interest. Once the liability is fully satisfied, the applicable reversal and notification rules govern. Passport processing remains a separate State Department step.
Obtain an accepted payment agreement
An installment agreement (IA) under IRC §6159 allows monthly payments; Form 9465 is a request for that agreement. Once approved and paid as required, the certified periods may fall within IRC §7345(b)(2)(A)(i). A pending request alone does not establish this exclusion.
A certified balance exceeds $66,000, so a streamlined agreement at $50,000 or less requires first reducing the balance to $50,000. Otherwise, an agreement may require a financial statement on Form 433-F or Form 433-A. The existing 1–3-business-day online agreement and 7–14-day decertification examples in the FAQ are estimates, not commitments or evidence that your case qualifies.
Complete an accepted offer
An offer in compromise (OIC) under IRC §7122 asks the IRS to accept less than the full balance, using Form 656. An accepted offer being paid as required may fall within IRC §7345(b)(2)(A)(ii); merely submitting an offer is not acceptance. Confirm the decision in the IRS acceptance Letter.
Use an available hearing or spouse-relief right
Collection Due Process (CDP) is the formal Appeals hearing for eligible collection issues. For Letter LT11 or Letter 1058, Form 12153 generally must be requested within 30 days from the printed notice date, not receipt. A timely request suspends covered collection under IRC §6330(e)(1), with the IRC §7345(b)(2)(B)(i) exclusion applying only to covered periods.
Form 8857 requests innocent spouse relief under IRC §6015, which addresses responsibility for a spouse's tax. A qualifying collection suspension can bring debt within IRC §7345(b)(2)(B), with the IRC §7345(c)(2) 30-day notification rule relevant to the request. Review the tax periods and procedural status rather than assuming every request reverses every certified period.
Document hardship or another exclusion
Currently not collectible (CNC) status means the IRS finds no present ability to pay after allowable living expenses. IRM 5.19.25.5 provides discretionary passport exclusions for qualifying hardship accounts, combat-zone service, a pending adjustment that will satisfy the debt and identity-theft hardship. Form 433-A supports the financial review; Department of Justice settlement agreements may also provide an exclusion where applicable.
If international travel is approaching
The 45-day travel criterion concerns requesting expedited handling, not a promise of passport return within 45 days. Standard IRS notification may take up to 30 days after a qualifying resolution, plus State Department processing. Expedited notification may take a few business days in eligible cases, but neither agency's timing is guaranteed.
- Provide proof of international travel within the next 45 days.
- Confirm an open or pending passport application with the State Department.
- Document a qualifying IRC §7345(c) resolution.
- Contact the IRS Passport Program with the request and supporting records.
- Include the State Department denial Letter, booked tickets, meeting invitations or family-emergency evidence, and resolution confirmation.
If a passport was revoked and no new application is pending, review the application requirement before requesting expedited handling. A new application may start the State Department's 90-day hold. Even travel in 21 days does not change the eligibility requirements or guarantee completion before departure.
If you believe the certification is wrong
IRC §7345(e) permits a petition in U.S. Tax Court or a complaint in U.S. District Court challenging erroneous certification or a failure to reverse. Grounds may include an unmet threshold, unexhausted IRC §6320 rights, an IRC §7345(b)(2) exclusion or an unenforceable assessment. Filing a challenge does not itself reverse certification.
The existing case reference Garcia v. Commissioner, 164 T.C. No. 8 (May 19, 2025), describes de novo review, meaning review anew rather than only of the agency record. Spencer v. Commissioner (January 2026, $1.6M Trust Fund Recovery Penalty certification upheld) and Shaban v. Commissioner, T.C. Memo. 2026-24 (brother's embezzlement claims), are also retained references. These examples do not predict an outcome in another case.
Tax Court petitions are filed in Washington, D.C., including through its DAWSON electronic filing system. Tax Court–admitted counsel handles court representation; our IRS administrative engagement does not imply admission to that court. The IRS decides certification and the State Department decides passport action.
Fees and engagement
Free — Free Notice Decoder / free path. The free decoder explains your notice from its type and date. No documents are uploaded at the free step. $97 — Notice Review. Send us your IRS notice along with your own transcripts. We tell you what the notice is, what it means, and what the issues appear to be at a high level. This is information, not tax advice. $497 — Case Analysis. We pull your transcripts, analyze your whole situation, and give you a written do-it-yourself plan. $1,000 — Representation. Power of attorney (Form 2848) and we represent you before the IRS. Flat $1,000. The $97 Notice Review is credited toward the $497 Case Analysis. Fixed fees, confirmed in writing before work begins. Not a guarantee of any IRS outcome. We never charge a percentage of tax saved.
- Resolution work, including IA and CNC applications
- Fixed by work type and amount owed
- Offer in Compromise submission
- Fixed by work type and amount owed
- Expedited decertification request
- Fixed by work type and amount owed
- Tax Court §7345(e) petition (erroneous certification)
- Fixed by work type and amount owed
- CDP filing on certified period (where §6330 window still open)
- Fixed by work type and amount owed
Case Analysis is $497 regardless of balance owed, tax years, complexity or urgency. The $97 Notice Review is credited toward the $497 Case Analysis. Phase 2 work is priced in the published ranges on our IRS fee page, or quoted in writing after the Case Analysis. Fixed fees, confirmed in writing before work begins. Not a guarantee of any IRS outcome. We never charge a percentage of tax saved.
The court-related fee description does not include a promise that this firm will appear in court; any court engagement requires appropriately admitted counsel. The engagement letter is the controlling document; no specific outcome or timeline is guaranteed. Decertification timing depends on IRS processing and State Department coordination.
Texas CPAs are bound by the rules of the Texas State Board of Public Accountancy.
Common questions
Timing examples below are not guarantees; eligibility, IRS decisions and State Department processing control the result.
How much tax debt actually triggers passport certification?
The 2026 threshold under IRC §7345(b)(1) is more than $66,000, including tax, penalties, and interest.
The threshold adjusts annually for inflation under §7345(f).
All tax periods aggregate toward the threshold — a taxpayer with $30,000 in unpaid 2022 tax and $40,000 in unpaid 2023 tax has $70,000 in aggregate seriously delinquent debt.
Trust Fund Recovery Penalty assessments under IRC §6672 count fully.
Will paying my debt below the $66,000 threshold trigger decertification?
No.
The IRS has been explicit: paying the debt below the threshold does not trigger decertification.
The §7345(b)(2) exclusions are the operative decertification triggers — installment agreement, accepted OIC, timely CDP request, innocent spouse request, or full satisfaction.
I have an international flight in 21 days — what's my fastest path?
The fastest practical path is typically a Streamlined Installment Agreement (if balance qualifies under $50,000 with all returns filed), which can be approved in 1-3 business days through the Online Payment Agreement tool.
Once approved, expedited decertification with travel documentation can produce decertification in approximately 7-14 days from engagement.
Engage immediately with all financial documentation ready.
Does the IRS notify my representative when I'm certified?
No.
Per IRM 5.19.25, the IRS sends CP508C by regular mail to the taxpayer's last known address only — and does not send a copy to the taxpayer's power of attorney even when Form 2848 is on file.
Practitioners should proactively pull account transcripts and check for TC 971 AC 626 (passport certification posted).
Can my passport be revoked while I'm overseas?
Yes — but under FAST Act §32101 and applicable State Department policy, the State Department typically issues a limited-validity passport valid only for direct return to the United States.
Once back in the U.S., you must resolve the IRS debt to trigger decertification before applying for a regular passport.
Contact the U.S.
Embassy or Consulate for limited-validity passport assistance.
Can I challenge the IRS certification if I believe it's wrong?
Yes — under IRC §7345(e) by filing a petition in U.S.
Tax Court or a complaint in U.S.
District Court.
In Garcia v.
Commissioner, 164 T.C.
No. 8 (2025), the Tax Court held that passport certification challenges are reviewed de novo.
Grounds for challenge include: the threshold not actually exceeded, §6320 administrative rights not exhausted, a §7345(b)(2) statutory exclusion in place, or the underlying assessment not legally enforceable.
Who handles your request
Ebot Mbi, CPA, EA · Texas CPA #127163 · IRS Enrolled Agent, authorized by the U.S. Department of the Treasury under Circular 230. Office: 4425 W Airport Fwy, Ste 595, Irving, TX 75062. Email: admin@ebotcpa.com.