The IRS will not speak to your accountant without this

Figures relate to tax year 2025-26 (UK) · 2025 (US)

A notice lands in your London letterbox. Your accountant reads it, picks up the phone, and gets nowhere.

The IRS will not discuss your affairs with anybody who has no authority. Form 2848 is how you grant it.

However, the form is narrow by design. It covers only the years and the forms you write on it, so a vague one is almost as useless as none.

Key takeaways

• Form 2848 lets a named person act for you with the IRS.
• It covers only the years and forms you list on it.
• Not everyone can be appointed, and a UK accountant often cannot.
• Form 8821 only allows access, not action.
• An older authority for the same years is replaced unless you say otherwise.
• Processing a Form 2848 takes weeks, so file it before you need it.
• You can revoke a Form 2848 at any time.
• It does nothing for HMRC, which has its own system.

What is Form 2848?

A power of attorney for tax matters. You name a representative, list the years and the forms, and sign. According to IRS guidance on representation, that person can then speak for you, receive notices and argue your case. It does not give them access to your bank accounts or anything outside tax.

It is narrow, deliberately.

Tax only, and only what you list.

Who can you appoint?

Only certain categories of person, which catches people out abroad. Attorneys, certified public accountants and enrolled agents can all represent you. A British chartered accountant generally cannot, however good they are, because the authority comes from American professional standing rather than skill.

Our guide to enrolled agents and CPAs in the UK covers who qualifies.

So check the credential before signing.

What does it actually let them do?

Speak, sign and negotiate within the scope you set. They can call the IRS, receive copies of notices, respond to examinations and agree adjustments. Signing a return on your behalf is possible but needs specific authority, so it is not automatic and you should spell it out if you want it.

Most people never need the signing power.

But it has to be stated if you do.

How is it different from Form 8821?

One grants action and the other grants sight. Form 8821 lets somebody see your information and receive copies, but they cannot argue, negotiate or represent you. It suits a lender or a second adviser who needs visibility without authority, and it is quicker to put in place.

Access is not the same as representation.

If they need to argue, use the power of attorney.

Which years should you list?

Only the ones you mean, but do not be stingy. A blanket future authority is not allowed beyond a limited forward window, so listing a sensible range of past years plus the current one is the usual approach. Years you leave off are simply outside the authority.

Our guide to the statute of limitations covers which years still matter.

Missing years are the commonest defect.

Which forms should you list?

The ones at issue, named precisely. An authority covering the income tax return does not extend to the account reporting regime or to an information form, because those sit in different parts of the system. Americans abroad often need several lines rather than one.

Our guide to Form 8938 and FATCA reporting covers the other forms.

One line rarely covers an expat case.

A worked example

Take an illustrative example. An American in Cardiff receives a notice about her 2021 return, raising a proposed charge of $4,200.

Her adviser files an authority covering the income tax return for 2021 only.

The examination then widens to a foreign company form for the same year.

Because that form was never listed, the adviser cannot discuss it and the firm must file a second authority, costing six weeks while the deadline runs.

Two authorities, two purposes

How do you submit it from abroad?

Online where possible, by fax or post otherwise. The online route is fastest but needs the representative to hold an account with the right access, which many smaller firms do not. From Britain the practical answer is usually that your representative submits it rather than you.

Our guide to the IRS online account from the UK covers access.

So leave the filing to the adviser.

How long does processing take?

Weeks rather than days, and longer in busy periods. Until it is recorded on the system, a telephone call will still get nowhere. That lag is why filing one when a notice arrives is already too late for the deadline printed on the notice.

File it before the trouble starts.

In our practice this is the single biggest delay.

Does it replace an earlier authority?

For the same years and forms, yes, unless you tick the box to keep the old one. People changing adviser often revoke their previous representative without meaning to, which is usually fine. It is not fine where two firms are handling different matters at once.

Tick the retention box if both should continue.

Otherwise the newest one wins.

How do you revoke one?

By sending a copy marked as revoked, or a signed statement naming the representative. Simply ending the engagement does not remove the authority, so a former adviser can still receive your notices for years. Tidying this up when you change firms is worth the ten minutes.

Our guide to IRS letters after streamlined filing covers who receives post.

Revocation is a positive act.

Does it expire?

Not on its own, though the IRS eventually removes very old records. An authority for a closed year effectively dies with the year. One covering a live dispute carries on until the matter ends or somebody revokes it, so review the list occasionally.

Old authorities linger longer than people expect.

Check what is on file when you switch adviser.

Do you need one to set up a payment plan?

Only if somebody else is arranging it for you. You can negotiate an instalment arrangement yourself without any authority at all. Where an adviser is doing the talking, they need the power of attorney first, and the plan cannot be agreed until it is on record.

Our guide to IRS payment plans from abroad covers the options.

Representation and payment are separate questions.

What about a joint return?

Each spouse signs separately, because the authority is personal. A single form covering both of you is not valid, so couples need two. This surprises people who assume a joint return produces a joint authority, and it delays matters when only one has signed.

Our guide to a non-resident alien spouse covers joint filing.

Two people, two forms.

Can you appoint a family member?

In limited circumstances, yes. A family member can represent you in narrow situations, but the general rule points to qualified professionals. For most expat matters the practical answer is a licensed representative, because an examination needs somebody who can argue the technical position.

Good intentions do not create authority.

The credential is what the IRS checks.

Does it help with an identity problem?

It helps your representative get involved, which matters a great deal. Identity issues take months and involve several departments, so somebody able to chase on your behalf saves real time. The authority does not shortcut the process itself.

Our guide to the identity protection PIN covers the process.

Representation speeds it, nothing more.

What if you have an ITIN rather than a number?

The form still works, with the identifying number you actually hold. You can appoint a representative for a spouse or dependant who holds an individual taxpayer identification number. The number simply has to match what the IRS has on record for that person.

Our guide to ITIN applications from the UK covers the number.

Mismatched numbers cause rejection.

Does HMRC accept it?

Not at all, because Britain runs its own agent authorisation. An adviser acting for you here needs a separate arrangement through the HMRC system, which is unrelated and has its own delays. Americans here often need both, set up in parallel.

Our guide to an HMRC enquiry for US filers covers the British side.

Two systems, two authorisations.

What if the representative moves firm?

The authority follows the person rather than the firm, which can be awkward. If your representative leaves, their new employer has no standing until you file afresh. Firms usually handle this, but it is worth checking rather than assuming continuity.

Ask who exactly is named on the form.

A firm name alone is not enough.

Can more than one person be named?

Yes, and for a complex case that is sensible. Several representatives can appear on one form, which lets a team cover holidays and time zones. Notices normally go to the first two listed, so put the people who actually read post at the top.

Order on the form matters.

So think about who receives the letters.

Does it cover state tax too?

No, and this is a frequent gap. Each state runs its own authorisation, with its own form and its own processing. Somebody with a lingering California or New York issue needs that state's paperwork as well as the federal version.

Our guide to state tax after you leave covers the state risk.

Federal authority stops at the federal line.

What records should you keep?

A signed copy, the date it was submitted, and a note of which years and forms it covers. Those three answer the question that always arises later, which is whether the adviser can act on a new issue. Keep it with the engagement letter.

Diarise a review when the dispute ends.

Then revoke what is no longer needed.

Does Form 2848 help if you are being examined?

It is close to essential. An examination runs on deadlines, document requests and telephone calls, and without the authority on record your representative cannot engage with any of it. So the first step in almost every examination we handle is getting a Form 2848 recorded before anything substantive happens at all.

Because the clock does not pause while you file it.

So the form goes in on day one.

Can you use Form 2848 for a refund claim?

Yes, and it is often worth doing. Where an adviser is chasing an old refund or pressing an amended return through the system, the authority lets them ring and find out what has actually happened to it. Refund enquiries otherwise disappear into a queue nobody can see from Britain.

Our guide to amending a US return covers the claim itself.

But the money still arrives at your own bank.

What happens to Form 2848 if you die?

The authority ends, because it was personal to you. An executor dealing with the final return has to establish their own standing, which runs through a different process entirely. Families often discover this when they try to use an adviser who had handled matters for years beforehand.

Our guide to an American executor's UK duties covers the role.

So the estate starts again from scratch.

Is a Form 2848 needed for a simple question?

Not if you are asking it yourself. You can ring the IRS about your own affairs without any paperwork, and for a straightforward query that is often quickest. The authority matters only when somebody else needs to do the asking, or when the matter will take months rather than minutes.

So weigh the delay against the convenience.

But the queues from abroad are long.

Does Form 2848 give access to your transcripts?

It does, and that is often the most useful part. A representative can pull your account transcripts and see exactly what the IRS holds, which years reached the system and what the IRS charged. For somebody catching up after years abroad, that picture is usually where the work has to start.

Our guide to requesting a tax transcript from abroad covers the records.

Because guessing what the IRS holds wastes months.

What does it cost to put one in place?

Nothing to the IRS, because there is no filing fee at all. The cost sits with your adviser's time in drawing it correctly and chasing it onto the system. Against a six week delay in the middle of an examination, that is an hour very well spent, so it is rarely worth economising on.

So the real cost is the waiting, not the form.

Because nobody can act until it lands.

How to complete and file it

1. Check the person you want is eligible to represent you.
2. List every year the matter could possibly touch.
3. List every form, not just the income tax return.
4. Decide whether they need authority to sign anything.
5. Decide whether an earlier authority should survive.
6. Sign it yourself, with your spouse signing their own.
7. Let the representative submit the Form 2848 by the fastest route open to them.
8. Diarise a revocation once the matter is finished.

Mistakes and penalties we see with Form 2848

The first is naming one year when the examination can easily widen to three.

The second is listing the income tax return and forgetting the foreign information forms.

The third is filing it the week a deadline falls, when processing takes longer than that.

The fourth is leaving an old adviser authorised for years after the engagement ended.

How US UK Tax Accountants helps

We put the authority in place early and draw it widely enough to cover where an expat enquiry usually goes, which is rarely where it starts.

Then we deal with the correspondence directly. Our US federal returns service covers the filings behind it.

If a notice has arrived and nobody can speak to the IRS for you, get in touch today rather than next week.

Last reviewed 22 October 2026. This article is general information and not personal tax advice, and IRS procedures change over time.

For the neighbouring question, Telling the IRS that somebody else is in charge now walks through it in detail.