correspondence audit — TaxYork US & UK expat tax specialists

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Introduction: Why a Correspondence Audit Reaches Americans in Britain

An IRS correspondence audit is an examination of your US tax return that the Internal Revenue Service conducts entirely by post, and for an American living in London, Edinburgh or the Home Counties it usually arrives weeks after the date printed on it. The letter lists the items the examiner questions, tells you what evidence to send, and sets a deadline measured from the notice date rather than the day it lands on your doormat. Consequently, many British-resident filers lose half their response time before they have even opened the envelope.

Furthermore, the stakes for high earners are rarely small. A correspondence audit of an expat return almost always targets the large-value items that keep US tax at or near zero, namely the foreign tax credit on Form 1116, the foreign earned income exclusion on Form 2555, and the foreign asset disclosures on Form 8938. If you fail to answer, the examiner simply disallows the item. For a City banker whose UK tax wipes out the US liability every year, a disallowed credit can turn a nil return into a six-figure bill overnight.

What a Correspondence Audit Is

A correspondence audit is the IRS's most common form of examination. The official IRS guidance on audits explains that the agency conducts audits either by mail or in person, and that it will notify you by mail rather than by telephone. In a mail audit, a campus examiner reviews one or a handful of specific items and asks you to substantiate them with documents. By contrast, an office audit requires you to attend an IRS office, while a field audit brings an agent to your home, business or representative's premises.

Importantly, the narrow scope of a correspondence audit is both its strength and its danger. It is narrow because the examiner only looks at the listed items. However, it is dangerous because the process runs almost entirely on deadlines and paperwork, and an unanswered letter converts automatically into an assessment. The IRS explains the whole process in Publication 3498-A, The Examination Process (Audits by Mail), which you should read alongside the letter itself.

Why UK-Resident Filers Are Selected

Americans in Britain attract examination for structural reasons rather than because they have done anything wrong. For instance, a high-earning expat return typically combines a large foreign income figure, a credit or exclusion that offsets almost all of it, and several information returns reporting UK bank, pension and investment accounts. Automated selection filters flag those combinations because they produce large tax effects from a few lines.

Additionally, UK banks report American account holders to HMRC under FATCA, and HMRC passes that data to the IRS each year. When the reported balances do not match your Form 8938, or when UK interest and dividends visible to the IRS do not appear on your return, the mismatch invites a letter. In our experience working with UK-resident Americans, the most frequent triggers are an unsupported Form 1116, a physical presence test that looks marginal, and a Form 8938 that omits a Stocks and Shares ISA, a Self-Invested Personal Pension or a workplace pension.

The Correspondence Audit Letter Sequence

Every correspondence audit follows a predictable chain of letters, and knowing where you are in that chain tells you exactly how much time you have left. The IRS numbers each letter, so the reference in the top right corner of the first page is your map. Therefore, before you gather a single document, identify the letter number, the notice date and the response date.

Letter 566 and the Initial Request

The correspondence audit normally opens with Letter 566, the initial contact letter. It tells you that your return has been selected for examination, lists the specific items under review, and asks for supporting documents by a stated date, usually 30 days from the notice date. Frequently, the letter encloses Form 4564, an information document request, or a list of acceptable evidence for each item.

Notably, the IRS sometimes combines the first contact with a proposed assessment, especially where it believes the item is plainly unsupported. In that case the opening letter already includes a report of proposed changes. Consequently, you must read every enclosure, because a combined letter starts the 30-day appeal clock at the same time as the documentation clock. Publication 3498-A confirms that if you do not reply by the due date, the IRS will disallow the identified items and interest will keep accruing.

Form 4549, Form 886-A and the 30-Day Letter 525

If the examiner does not accept your evidence, the next stage of the correspondence audit is Letter 525, commonly called the 30-day letter. It encloses Form 4549, the report of income tax examination changes, which shows the adjusted income, the recalculated tax, any penalty and the interest to date. Often, it also encloses Form 886-A, which sets out the examiner's explanation of each adjustment in narrative form.

At this point you have three choices. You can sign Form 4549 and pay, you can send further evidence and an explanation, or you can request a conference with the examiner's manager or a review by the Independent Office of Appeals. Crucially, you should never sign the agreement page if you disagree or plan to appeal, because a signed Form 4549 consents to immediate assessment and waives your right to petition the Tax Court on those items.

Letter 3219 and the 150-Day Window Abroad

If the correspondence audit remains unresolved after the 30-day letter, the IRS issues a statutory notice of deficiency, which a mail audit usually generates as Letter 3219. For a taxpayer in the United States, section 6213 of the Internal Revenue Code allows 90 days to petition the Tax Court. However, where the notice is addressed to a person outside the United States, the period extends to 150 days.

Nevertheless, the extra time is not generous in practice. International post can consume a fortnight in each direction, and the IRS cannot extend the Tax Court deadline even while you continue talking to the examiner. We explain the mechanics of that stage in our guide to the 150-day notice of deficiency window for Americans abroad. Ultimately, if you miss it, the tax is assessed and your remaining options move to collection and audit reconsideration.

How a Correspondence Audit Differs From a CP2000 Notice

Many Americans in Britain confuse a CP2000 notice with a correspondence audit, yet the two are legally different. A CP2000 comes from the Automated Underreporter programme, which compares your return with third-party information such as Forms 1099 and FATCA data. It proposes a change but is not technically an examination, and it gives taxpayers with a foreign address 60 days to reply.

By contrast, a correspondence audit is a formal examination under the IRS's examination function. The examiner can ask for evidence of any listed item, not just items reported by a third party, and the letters carry examination appeal rights. The difference matters for eligibility too. An examination is the event that closes penalty-relief routes for older years, whereas the effect of a matching notice is less clear-cut and needs case-specific advice. Therefore, check the letter number carefully before you decide how serious the problem is.

What the IRS Questions in an Expat Correspondence Audit

A correspondence audit of a UK-resident American rarely concerns itemised deductions or charitable gifts. Instead, it concentrates on the international provisions that do the heavy lifting on an expat return. Each of those provisions has its own evidence standard, and the examiner will expect documents in a form the IRS recognises.

Foreign Tax Credits on Form 1116

The foreign tax credit is the most valuable single line on most high-earner expat returns, and therefore the most examined. The IRS instructions on Form 1116 and the foreign tax credit require you to prove that you paid or accrued the foreign tax, that the tax is a creditable income tax, and that you placed each amount in the correct basket. In a correspondence audit, the examiner typically asks for proof of payment, a computation reconciling UK tax to the US calendar year, and a breakdown by category of income.

Moreover, three errors recur in the returns we review. First, many preparers include UK National Insurance in the credit, yet social security contributions paid under the US-UK totalisation agreement are not creditable. Second, the UK tax year runs from 6 April to 5 April, so a calendar-year US return needs UK tax apportioned across two UK years. Third, dividend and interest tax often sits in the wrong basket after the high-tax kickout. Consequently, a credit that looks correct in total can still fail line by line.

The Foreign Earned Income Exclusion on Form 2555

Where you claim the exclusion instead of the credit, the correspondence audit focuses on eligibility. The Form 2555 guidance requires either a full tax year of bona fide residence abroad or 330 full days outside the United States in a 12-month period. The examiner may ask for passport stamps, travel records, a UK tenancy or mortgage statement, council tax bills, and evidence that your tax home is in Britain.

In particular, the physical presence test fails on small margins. A banker who counts 332 days but forgets two New York deal trips can drop below 330 days, and the exclusion then disappears in full. Additionally, if the IRS discovers that you never made a valid election, a late election may be barred, which is why high earners in Britain are generally better served by the foreign tax credit in any event.

Form 8938, FBAR and the 40% Penalty

A correspondence audit that touches foreign assets carries a sharper penalty than an ordinary adjustment. Under section 6662 of the Internal Revenue Code, the accuracy-related penalty is normally 20% of the underpayment. However, subsection (j) doubles it to 40% for an undisclosed foreign financial asset understatement, meaning any underpayment tied to an asset you should have reported on Form 8938, Form 3520, Form 5471 or a similar information return.

Similarly, the examiner may notice accounts that appear in FATCA data but not on your FBAR. The FBAR is a Treasury filing rather than an income tax return, and the FinCEN guidance on reporting foreign accounts makes clear that it is due separately. The IRS comparison of Form 8938 and FBAR requirements shows how the two overlap. Accordingly, if a correspondence audit reveals a missed FBAR, you need a strategy for the Title 31 exposure, not just the income tax item. Our FBAR and FATCA compliance service handles precisely that.

Capital Gains, PFICs and UK Funds

Investment income is the fourth common target. A correspondence audit may ask you to prove the cost basis of shares sold through a UK platform, because UK brokers do not issue Form 1099-B and rarely report basis in dollars. You will need contract notes for both purchase and sale, converted at the spot rate on each trade date, since the IRS treats every leg separately.

Furthermore, UK unit trusts, OEICs and most UCITS funds are passive foreign investment companies for US purposes. If your return reported fund gains as ordinary capital gains without Form 8621, the examiner can recompute the tax under the excess distribution regime, which adds an interest charge. Similarly, ISA income and gains remain fully taxable in the United States. In our experience, an examiner who asks about one UK fund often follows up on the rest of the portfolio, so prepare the full picture before you reply.

Building Your Correspondence Audit Response From Britain

A well-built response to a correspondence audit reads like a short legal brief. It answers every listed item, it attaches evidence in the order the examiner asked for it, and it explains any figure that does not match a document on its face. Above all, it arrives before the deadline.

Clocks, Post and the Document Upload Tool

The response date on a correspondence audit letter runs from the notice date, not the delivery date. Therefore, the first practical step is to log the date on the letter, calculate the deadline, and decide how you will deliver. The IRS now accepts correspondence examination responses through its Document Upload Tool, as its page on the correspondence examination and audit reconsideration process confirms. The tool accepts PDF, JPG and PNG files, which removes international postal risk entirely.

Alternatively, where you must post originals of a signed statement or the letter asks for a paper reply, use a courier. Only the US Postal Service and the services on the IRS list of designated private delivery services benefit from the timely mailing rule, and Royal Mail is not on that list. As a result, a Royal Mail item posted in time but delivered late counts as late. Additionally, Publication 3498-A allows faxed replies where the letter provides a number, provided you put your name and taxpayer identification number on every page.

Translating UK Evidence Into IRS Terms

UK tax paperwork does not map neatly onto US forms, so part of any correspondence audit response is translation. An examiner in Austin or Ogden will not recognise a P60, a P11D or a tax year overview without explanation. Consequently, you should attach a short schedule that identifies each document, states the UK tax year it covers, and shows how you arrived at the US figure.

For the foreign tax credit, the strongest evidence is HMRC's own computation. You can obtain an SA302 tax calculation and a tax year overview from your HMRC online account for each relevant year. Pair those with P60s and payslips to show PAYE actually withheld during the calendar year. Furthermore, state the exchange rate you used; the IRS publishes yearly average currency exchange rates and accepts any rate applied consistently. For 2024, the published pound rate was 0.783, meaning £1 converted to roughly $1.277.

Extensions, Scope and Representation

If you cannot meet the deadline, call the number on the letter before it passes and ask for more time. Publication 3498-A expressly invites that call, and in practice examiners usually grant a single 30-day extension on a correspondence audit where you explain the international delay. Record the name of the person you spoke to, the date and the new deadline, and confirm it in writing with your upload.

Equally important is scope. Answer the questions asked and nothing more, because volunteering unrelated material can widen the examination. If you appoint a representative, file Form 2848, Power of Attorney and Declaration of Representative, so the examiner can speak to your adviser directly. For an American working long hours in London, representation also solves the time-zone problem, because the IRS international line and campus examiners work US Eastern and Central hours, which run into the British evening.

No IRS Office in London

Occasionally, taxpayers ask whether they can meet an examiner in person. In theory, you can ask for an interview, and Publication 3498-A offers a telephone conference with the examiner. In practice, however, the IRS closed its overseas attaché offices, including London, in 2015, so there is no local office to visit. A correspondence audit of a UK resident therefore stays on paper and on the telephone.

Consequently, your written file does all the persuading. We recommend a covering letter of two to four pages that restates each question, gives a one-paragraph answer, and cross-refers to numbered exhibits. Examiners handle large caseloads, and a response they can verify in twenty minutes closes faster than a bundle of unexplained bank statements. Moreover, a clear index protects you later, because Appeals and the Tax Court will read the same exhibits.

Statute of Limitations, Penalties and Interest in a Correspondence Audit

Every correspondence audit sits inside a limitation period, and the penalty and interest consequences depend on how long the IRS has and how the understatement arose. Accordingly, you should check whether the year is still open before you decide how hard to fight a particular item.

The Three-Year Rule and Its Exceptions

Section 6501 of the Internal Revenue Code generally gives the IRS three years from the later of the due date or the filing date to assess additional tax. However, the period extends to six years where you omit more than 25% of gross income, and also where you omit more than $5,000 of income attributable to a foreign financial asset that should have appeared on Form 8938.

More significantly for expats, section 6501(c)(8) keeps the whole year open until three years after you file a required international information return such as Form 8938, Form 5471, Form 3520 or Form 8621. Consequently, a missing form can leave a correspondence audit window open indefinitely. Moreover, where a year is close to expiry, the examiner may ask you to sign Form 872 to extend it; you can refuse or limit the extension, but refusal often prompts an immediate notice of deficiency on the unresolved items.

Accuracy Penalties and Reasonable Cause

The standard penalty in a correspondence audit is the 20% accuracy-related penalty. It applies where the understatement exceeds the greater of $5,000 or 10% of the tax required to be shown, or where the examiner finds negligence. As noted above, the rate rises to 40% for undisclosed foreign financial asset understatements.

Nevertheless, you can defeat the penalty by showing reasonable cause and good faith. Reliance on a competent adviser who had full information, a genuinely uncertain point of law, or a clear computational error in otherwise careful records can each support relief. Therefore, include a short penalty statement with your substantive response rather than waiting for the 30-day letter. The Taxpayer Bill of Rights also guarantees your right to challenge the IRS position and be heard.

Interest, Deposits and Stopping the Clock

Interest on any deficiency runs from the original due date of the return, which for expats is 15 April even though the automatic extension allows filing until 15 June. Consequently, a correspondence audit closing in late 2026 on a 2024 return carries more than eighteen months of interest. You cannot negotiate interest away except where an IRS error or delay caused it.

However, you can stop it. Section 6603 lets you make a deposit against a disputed amount, which halts further interest on that sum and remains refundable if you win. For a high earner confident of the outcome but facing a long appeal, a deposit is often the cheapest insurance available.

Record-Keeping on Both Sides of the Atlantic

Because a correspondence audit can reach back three, six or more years, your records must survive at least that long. The IRS asks you to keep the records used to prepare a return for at least three years after filing, but that minimum is unsafe for anyone with foreign assets. FBAR records must be kept for five years, and an unfiled information return keeps the year open indefinitely.

Meanwhile, HMRC sets its own windows. Employees filing Self Assessment generally keep records for 22 months after the end of the tax year, while landlords and the self-employed keep them for five years after the 31 January filing deadline. Those UK periods are shorter than the US exposure. Accordingly, we advise UK-resident Americans to keep P60s, SA302s, contract notes and year-end statements for at least seven years, and to download HMRC calculations annually before the online account archives them.

Disagreeing With the Correspondence Audit Result

A proposed adjustment is not a final assessment. If the examiner rejects your evidence, the correspondence audit offers several escalation routes, and choosing the right one depends on the amount at stake and the strength of your documents.

Manager Conference and Appeals

Your first step is usually a telephone conference with the examiner, followed by a request to speak to the examiner's manager. If that fails, you can ask for your case to go to the Independent Office of Appeals, which operates separately from the examination function. Where the total proposed change in tax, penalties and interest is $25,000 or less for each period, Publication 3498-A permits a small case request using Form 12203, Request for Appeals Review.

Above that figure, you need a formal written protest prepared under Publication 5, Your Appeal Rights. Notably, Appeals expects all your evidence to have reached the examiner first. If you provide substantial new documentation at the appeal stage, Appeals will send the case back to examination. As a result, the best appeal is one built during the correspondence audit itself.

Tax Court and Audit Reconsideration

If Appeals does not resolve the matter, the notice of deficiency gives you the right to petition the US Tax Court without paying the tax first. For a UK resident, that means 150 days rather than 90. Furthermore, Tax Court petitions frequently settle with IRS counsel before trial.

Alternatively, where you missed the correspondence audit deadlines entirely and the tax has already been assessed, audit reconsideration lets you reopen the assessment by presenting the evidence you never sent. The IRS will consider it only while the liability remains unpaid, and it is not an appeal right. We cover the process in detail in our guide to IRS audit reconsideration for Americans in Britain.

The Taxpayer Advocate Service

If the IRS loses your response, fails to act, or a deadline threatens serious hardship, the Taxpayer Advocate Service can intervene. It is an independent organisation within the IRS, and its international taxpayer help page lists a dedicated overseas telephone line and fax number. In practice, the Advocate cannot overturn a correct adjustment, but it can force a stalled correspondence audit back onto the examiner's desk.

The UK Consequences of a US Correspondence Audit

A correspondence audit does not stay on the American side of the Atlantic. The outcome can change your UK credit position, close compliance routes you might otherwise have used, and expose earlier gaps in your filing history. Therefore, treat every US examination as a cross-border event.

Compliance Routes Close the Moment an Examination Opens

The single most important consequence of a correspondence audit for anyone with older gaps is loss of access to the IRS's penalty-relief programme for non-wilful filers. The IRS Streamlined Filing Compliance Procedures state that if the IRS has initiated a civil examination of your returns for any year, regardless of whether it relates to foreign assets, you are not eligible. Consequently, a Letter 566 on your 2024 return can shut the door on regularising missed FBAR filings from 2019.

Furthermore, the IRS withdrew its Delinquent FBAR Submission Procedures in July 2026, so there is no longer a published penalty-free route for late FBARs alone. That makes timing critical. If you know about missed US tax returns or missed FBAR filings, you should address them before any letter arrives, which is why our US tax returns for expats engagements always begin with a full compliance review.

When a US Adjustment Changes Your UK Credit

Where the IRS adjusts tax on US-source income, such as US rental profits, US dividends or earnings from US workdays, the change can alter the credit HMRC allowed for that US tax on your Self Assessment return. Under section 80 of the Taxation (International and Other Provisions) Act 2010, if a foreign tax adjustment makes your UK credit excessive, you must notify HMRC within one year, and a penalty up to the excess applies if you do not.

Conversely, if the correspondence audit increases US tax on US-source income, you may be entitled to additional UK relief. Section 79 of the same Act allows a claim within six years from when all material determinations have been made, in the UK or elsewhere. Similarly, on the US side, section 905(c) requires you to notify the IRS when a later HMRC enquiry changes the UK tax you credited. Our tax treaty optimisation service coordinates both sets of adjustments.

Missed UK Returns and Missed Reporting Discovered Mid-Audit

Gathering evidence for a correspondence audit often exposes problems nobody had noticed. For example, pulling the SA302 may reveal that a UK Self Assessment return was never filed for a year with untaxed dividends, or that a pension or ISA never appeared on Form 8938. HMRC's approach to such omissions is set out through HMRC's official guidance, and UK time limits run separately from the IRS limitation period.

Consequently, we recommend fixing each disclosure gap in the correct order. The US examination must be answered on its own terms, while missed UK tax returns and missed reporting of pension, investment account or ISA holdings may need a separate disclosure to HMRC or a corrected US information return. Handling those issues together, rather than piecemeal, avoids contradicting yourself between the two authorities.

Dual Nationals and Accidental Americans

A correspondence audit is not confined to Americans who moved to London for work. Dual national US-UK citizens born in Britain, and accidental Americans who only discovered their status when a bank asked for a Form W-9, receive examination letters too. Often, these taxpayers filed their first US returns recently, sometimes several years at once, and the returns show large UK pensions, ISAs and property holdings for the first time.

In our experience, the examiner's questions for this group focus on items the taxpayer has never had to explain before. For example, a UK workplace pension may have been reported as tax-free because HMRC treats it that way, or a main-residence gain may have been omitted because UK private residence relief exempted it in full. However, the US home sale exclusion is capped at $250,000 per person, and UK pension contributions only escape US tax within the limits of the treaty. Consequently, a first-time filer needs a response that explains the US treatment clearly, not simply the UK position.

Moreover, a correspondence audit for a dual national can touch a joint return with a non-US spouse who elected US residency. That spouse's worldwide income and accounts then fall within the examination, which surprises many couples. Therefore, confirm whose items the letter questions, and whether both spouses signed the return, before sending anything that concerns a partner's own assets.

A Worked Case Study: A £423,000 Banker's Correspondence Audit

The following illustrative case study shows how a correspondence audit unfolds for a typical high-earning American in London. Names and details are invented, but the figures follow the rules described above.

Daniel is a US citizen and a managing director at an investment bank in Canary Wharf. His 2024 salary and bonus totalled £423,000, which converts to $540,230 at the IRS 2024 average rate of 0.783. His US return claimed a foreign tax credit of $214,000 in the general category, which eliminated his US tax entirely and carried the unused excess forward. On 3 August 2026, the IRS issued Letter 566, asking him to substantiate the foreign taxes claimed and to reconcile them to the calendar year.

The letter went to a Chelsea flat Daniel had left in the spring, and the forwarding service delivered it on 21 August. By then, eighteen of his thirty days had gone. Moreover, Daniel was about to fly to Singapore for a fortnight. He contacted us on 22 August, and we filed Form 2848 the same day, called the examiner, and secured a 30-day extension to 2 October 2026.

Next, we rebuilt the credit from primary evidence. We downloaded SA302 calculations and tax year overviews for 2023/24 and 2024/25, collected his P60s and twelve monthly payslips, and apportioned the PAYE actually withheld between 1 January and 31 December 2024. That exercise showed UK income tax of £157,100, or $200,630. The difference from the $214,000 claimed was £10,470, or $13,370, of employee National Insurance that the original preparer had included, which the totalisation agreement makes non-creditable.

We therefore conceded the National Insurance point in our covering letter, explained the apportionment method, and uploaded 23 indexed PDFs through the Document Upload Tool on 26 September. The examiner accepted the reconstruction in full. Because Daniel's UK income tax still exceeded his tentative US tax of roughly $154,350, the adjustment produced no additional tax at all; it simply reduced his foreign tax credit carryforward by $13,370. Form 4549 showed a nil deficiency, and Daniel signed it.

Now consider the alternative. Had Daniel ignored the letter, the examiner would have disallowed the entire $214,000 credit. The resulting deficiency of about $154,350, plus a 20% accuracy-related penalty of $30,870 and roughly $15,000 of interest, would have exceeded $200,000. Furthermore, the open examination would have blocked any penalty-relief route for two unreported UK accounts that our review also identified. Instead, because the correspondence audit closed with no deficiency, we could address those accounts properly afterwards.

How TaxYork Can Help

TaxYork provides comprehensive US and UK tax preparation and compliance for Americans in Britain, including dual national US-UK families, accidental Americans and high-net-worth investors. When a correspondence audit letter arrives, we act as your authorised representative under Form 2848, calculate the true deadline, and negotiate any extension directly with the examiner.

Furthermore, we rebuild the questioned items from HMRC and bank evidence, prepare a response the examiner can follow, and draft any penalty relief statement. Where the examination exposes missed US tax returns, missed FBAR filings or unreported pension and ISA holdings, we prepare the corrected filings on both sides of the Atlantic. We also handle related letters such as CP2000 notices, which differ from a full examination and are covered in our CP2000 guide for American expats.

Finally, if a correspondence audit has already turned into an assessment and collection has begun, we guide you through the next stage, including the collection due process hearing for Americans in Britain and the Collection Appeals Program.

Conclusion

A correspondence audit is a paper exercise with real money attached. For Americans in the UK, the danger lies less in the questions than in the clock, because the deadline runs from the notice date and international post consumes much of it. The examiner will focus on the foreign tax credit, the foreign earned income exclusion and foreign asset reporting, and an unanswered letter becomes a disallowance by default.

Therefore, act on the day the letter arrives. Log the notice date, appoint a representative, request more time if you need it, and rebuild the questioned items from HMRC evidence converted at a consistent rate. Above all, remember that an open examination closes the door on penalty-relief routes for older gaps, so the smartest defence against a correspondence audit is complete, accurate filing before the IRS ever writes.

Contact Us

If you have received an IRS audit letter, or you want your returns reviewed before one arrives, book a consultation with our US-UK tax specialists. You can also email hello@taxyork.com or call 020 3488 8606. We will review the letter, confirm your deadline and set out the response plan within one working day.

Disclaimer

This article provides general information about IRS correspondence examinations and US-UK cross-border taxation. It does not constitute tax, legal or financial advice, and it does not create a professional relationship. The case study is illustrative, and its names, figures and outcomes are invented to demonstrate how the rules apply. Tax law changes frequently, and your position depends on your own facts. You should obtain professional advice before acting on any matter discussed here. Written by the TaxYork Expert Team — US-UK tax specialists.

Frequently Asked Questions

A correspondence audit is an IRS examination conducted entirely by mail. The IRS sends a letter, usually Letter 566, listing specific items on your return and asking for supporting documents by a set date. It is the most common audit type, and it usually targets one or two items rather than your whole return.

Most correspondence audit letters give 30 days from the notice date printed on the letter, not from the day you receive it. Americans in the UK often lose a fortnight to international post. If you need more time, call the number on the letter before the deadline, as a single 30-day extension is commonly granted.

The IRS disallows the questioned items, issues a 30-day letter with Form 4549, and then sends a statutory notice of deficiency. If you still do nothing, the tax, a 20% or 40% accuracy penalty and interest are assessed. Collection then follows, potentially including levies on US accounts and passport certification.

A straightforward correspondence audit typically closes within three to six months of your response, but cases involving foreign tax credits or appeals can run for a year or more. Delays in international post and IRS processing backlogs lengthen the timeline, so uploading documents electronically through the IRS Document Upload Tool saves significant time.

The IRS generally has three years from filing to assess additional tax. The period extends to six years for a substantial omission of income, including more than $5,000 from foreign financial assets. If you never filed a required form such as Form 8938 or Form 3520, the year stays open until three years after you file it.

Common triggers include a large foreign tax credit without clear support, a marginal physical presence test for the foreign earned income exclusion, and mismatches between FATCA data from UK banks and your Form 8938 or FBAR. Unreported ISA income and UK pensions omitted from information returns are also frequent causes of IRS letters.

Generally not. The IRS states that once it has initiated a civil examination of your returns for any year, you are ineligible for its streamlined penalty-relief procedures, even if the audit has nothing to do with foreign accounts. That is why resolving missed FBAR and missed US tax returns before any letter arrives matters so much.

Not legally, but for high earners it is usually worthwhile. A representative appointed on Form 2848 can speak to the examiner, negotiate extensions and translate UK documents such as SA302s and P60s into IRS terms. Where a foreign tax credit or foreign asset penalty is at stake, professional preparation often prevents a six-figure disallowance.

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