U.S. Passport Revocation and Application Denial: IRS Collection Weapon in Action

U.S. citizens that have racked up unpaid tax liabilities may be risking their ability to travel using a passport. Pursuant to Section 32101 of the Fixing America’s Surface Transportation (FAST) Act, the Internal Revenue Service (IRS) can request that the U.S. Secretary of State (State Department) deny, revoke, or limit a passport if an individual has seriously delinquent tax debts totaling more than $64,000 (as of 2025), including penalties, interest, civil penalties, and business taxes owed as part of an individual’s tax liability. The IRS has collected over $1.2 billion through this enforcement tool.

Seriously Delinquent Tax Debts
Seriously delinquent tax debts do not include:

• debts being paid timely through IRS-approved installment agreements
• debts being paid timely with an offer in compromise accepted by the IRS
• report of foreign bank and financial account (FBAR) penalties
• settlement agreements entered into with the Department of Justice
• child support
• those suspended because of a request for innocent spouse relief or where collections are suspended due to due process hearings

In addition, the IRS will not certify anyone as owing seriously delinquent tax debt who:

• has an account that’s been determined to be “not currently collectible” due to hardship
  has a pending request with the IRS for an installment agreement or offer in compromise
  has been accepted as a victim of tax-related identity theft
  is in bankruptcy
  is located within a federally declared disaster area
  has an IRS accepted adjustment that will fully satisfy their tax debt
• has a pending request with the IRS for an installment agreement or offer in compromise
• has been accepted as a victim of tax-related identity theft
• is in bankruptcy
• is located within a federally declared disaster area
• has an IRS accepted adjustment that will fully satisfy their tax debt

Certification of military members serving in designated combat zones or participating in a contingency operation will be postponed by the IRS.

If a taxpayer makes a promise to pay, but fails to follow through, or has offshore assets or include and refused to pay the tax debt, the IRS may recommend revocation.

Reversal and Revocation Processes
Prior to certifying an individual as having seriously delinquent tax debt to the State Department, the IRS must have filed a Notice of Federal Tax Lien and all administrative remedies under the law must have lapsed or been exhausted or, the IRS must have issued a levy in their efforts to collect the debts. The IRS will send taxpayer notice 6152, which is a final warning, and the taxpayer will have 30 days to resolve the issue. Once all legally enforceable actions have been taken, the IRS can certify to the State Department that the taxpayer is seriously delinquent.

The IRS  will send notice CP508C to the taxpayer only at the time it certifies seriously delinquent tax debt to the State Department. If the taxpayer applies for or tries to renew a passport, the State Department will issue a letter notifying the taxpayer that the application will remain open for 90 days, allowing the taxpayer to make payment arrangements with IRS, pay the debt in full, or resolve other issues related to the certification. If the taxpayer complies with those conditions within the allotted time, the IRS reverse revocation, notify the State Department, and send taxpayer notice CP508R. This will take place within 30 days of the debt resolution. If the taxpayer has not addressed the debt, the State Department will notify taxpayer that the application for a passport has been denied and closed. It is important to note that reducing the debt below the seriously delinquent threshold does not trigger a reversal of certification.

To expedite the reversal, the taxpayer can use the IRS Document Upload Tool to submit proof of payment. There are also instructions on notice CP508R for submitting documentation by mail.

Impact of Passport Denial or Revocation
Taxpayers that rely on a passport for their livelihood, such as those whose employment requires travel outside the United States, could face immediate and severe impacts to having their passport revoked or application denied. There is no hardship exemption for job loss or travel necessity once certification occurs.
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If you or your client are at risk of a passport revocation or application denial, immediate strategic intervention is essential. This includes negotiating installment agreements, submitting Offers in Compromise, or contesting improper certification through IRS administrative channels. Price Kong Tax Controversy Specialist Mark Sullivan helps taxpayers navigate issues related to seriously delinquent debts. He can be reached at [email protected] or 602.776.6382.