Form 2848 for expats is the IRS power of attorney an American abroad signs so a US tax professional can speak to the IRS, receive notices and act for them. Only attorneys, CPAs and enrolled agents get full representation rights. Taxpayers abroad send it online or to the IRS International CAF Team, and each spouse signs a separate form.
For Americans in the UK and UAE, the IRS is a long way off. International phone lines are slow, notices arrive weeks late and a missed reply can turn into an assessment. A properly drafted Form 2848 lets your adviser deal with all of that directly. This guide explains who can be named, how to complete the form, how it differs from Form 8821, and how it fits alongside HMRC agent authorisation.
What Form 2848 for expats does
Form 2848, Power of Attorney and Declaration of Representative, authorises a named individual to represent you before the IRS. According to the IRS Instructions for Form 2848, a representative can receive and inspect your confidential tax information and perform acts you could perform yourself, such as replying to a notice. Additionally, you can choose whether the representative receives copies of IRS notices.
Form 2848 for expats versus Form 8821
Many expats sign the wrong form. Form 8821, Tax Information Authorization, lets a person see your tax information but not represent you. In contrast, Form 2848 lets them act. The difference matters the moment the IRS questions a foreign tax credit or a streamlined submission.
| Feature (IRS instructions, rev. 09/2021) | Form 2848 | Form 8821 |
|---|---|---|
| Purpose | Representation before the IRS | Access to tax information only |
| Who can be named | Individuals eligible to practise before the IRS, such as attorneys, CPAs and enrolled agents | Any individual or organisation |
| Can reply to notices and negotiate | Yes | No |
| Can receive transcripts and notices | Yes | Yes |
| Representative signs a declaration | Yes, Part II | No |
Who can represent you
Part II of Form 2848 lists the categories of eligible representative. Attorneys, CPAs and enrolled agents have unlimited representation rights before all IRS offices. However, unenrolled return preparers can represent you only in an examination of a return they prepared and signed, and never before IRS Appeals or a revenue officer. A UK chartered accountant without a US credential falls into neither group. Our comparison of an enrolled agent, CPA and chartered accountant explains why that distinction matters.
Completing the form from abroad
Form 2848 is short, but small errors cause the IRS to reject it. Most rejections come from line 3, the signature dates or the wrong submission address.
Line 3: describing the matters
Line 3 must state the type of tax, the form number and the specific years. The IRS does not accept general references such as "all years". For instance, an expat catching up under the streamlined procedures might list "Income, 1040, 2022, 2023, 2024 and 2025" on one line, naming each year rather than a vague range. Furthermore, the Centralized Authorization File will not record future years more than three years after 31 December of the year the IRS receives the form.
Signatures and the 60-day rule
You sign and date the form first, or your representative does. If you sign first, your representative generally must sign within 45 days, but the IRS extends this to 60 days for taxpayers outside the US. Forms sent by fax or post need handwritten signatures. Consequently, if you sign electronically, the form must be submitted through the IRS online tool.
Joint filers and multiple representatives
Married couples filing jointly each sign their own Form 2848, even when they name the same adviser. Similarly, a new form recorded on the CAF generally revokes earlier powers of attorney for the same matters, unless you tick line 6 to keep them. If you are moving to a new adviser, our guide to switching your US-UK tax accountant covers the hand-over.
Submitting Form 2848 from the UK or UAE
You have three routes. The fastest is the IRS online submission service at IRS.gov/Submit2848, which needs an IRS Secure Access account and is usually used by your representative. Alternatively, you can fax or post the form.
The International CAF Team
Taxpayers who live outside the US send faxed or posted forms to the International CAF Team in Philadelphia, as set out in the Where To File chart in the IRS instructions. Do not use the Memphis or Ogden addresses meant for US residents. Above all, keep a copy with the fax confirmation, because CAF processing can take several weeks.
When the form goes elsewhere
Sometimes you need the authorisation for a matter the CAF does not record, such as a specific one-off issue. In that case you tick line 4 and send the form directly to the IRS office handling the matter. Your representative should tell you which route applies before you sign.
Matching it with HMRC authorisation
A US power of attorney means nothing to HMRC. If your adviser also handles your UK Self Assessment, you authorise them separately on the UK side. According to GOV.UK guidance on authorising a tax agent, Self Assessment authorisation is done through HMRC online agent authorisation or the paper form 64-8.
One adviser, two authorisations
For an American in London, the cleanest arrangement is one firm holding both authorisations. As a result, when HMRC amends a UK return, the same team can file a foreign tax redetermination with the IRS. Our guide to foreign tax redeterminations after a UK refund shows why that link matters.
The UAE side
The UAE has no personal income tax return, so most Americans in Dubai need no UAE individual authorisation. However, if you own a UAE company, the Federal Tax Authority's EmaraTax platform has its own process for appointing a tax agent registered with the UAE Federal Tax Authority.
A worked example: an IRS notice in Dubai
Consider an illustrative client, Michael, a US citizen working in Dubai. He received a CP2000 notice proposing extra tax on US brokerage income, with a 30-day response window. The letter reached Dubai 19 days after its date.
Michael signed a Form 2848 electronically the same day, naming his enrolled agent for income tax, Form 1040, for the year in question. His representative submitted it online, called the IRS once the authorisation was recorded and asked for more time. The agent then sent the corrected basis figures. Without the form, Michael would have been calling the IRS from Dubai himself, against a deadline he had almost missed.
Next steps
Sign Form 2848 before you need it, not after a notice arrives. A standing authorisation for the current and recent years means your adviser can act within days. If you have already received an IRS letter, our IRS streamlined filing page explains how back-year problems are usually resolved.
Choosing the right representative is part of choosing the right adviser. If you want a dual US-UK team authorised with both the IRS and HMRC, book a consultation with Tranzesta. We will review your position and prepare the authorisations with you.
Frequently Asked Questions
What is Form 2848 for expats?
Form 2848 for expats is the IRS Power of Attorney and Declaration of Representative signed by an American living abroad. It lets an eligible US tax professional represent them before the IRS, receive notices and reply on their behalf. Taxpayers outside the US submit it online or to the IRS International CAF Team in Philadelphia.
Can a UK chartered accountant sign Form 2848?
No, a UK chartered accountant cannot act as a full representative on Form 2848 unless they also hold a US credential such as CPA, attorney or enrolled agent. The IRS limits unenrolled return preparers to examinations of returns they prepared and signed. A chartered accountant without US status can be named on Form 8821 to receive information only.
How long does an expat have to get a representative to sign Form 2848?
A taxpayer living outside the US who signs Form 2848 first gives the representative 60 days to sign. For taxpayers inside the US the period is 45 days, according to the IRS Instructions for Form 2848. Forms sent by fax or post need handwritten signatures, while electronically signed forms must be submitted online.
Where do Americans in the UK send Form 2848?
Americans living in the UK send Form 2848 through the IRS online submission service at IRS.gov/Submit2848, or by fax or post to the International CAF Team in Philadelphia. The Memphis and Ogden addresses in the instructions apply only to taxpayers living in the US. Matters not recorded on the CAF go to the IRS office handling the case.
Does Form 2848 let my adviser deal with HMRC?
No, Form 2848 authorises representation before the IRS only and has no effect with HMRC. For UK Self Assessment, a client authorises an agent through HMRC online agent authorisation or the paper form 64-8. An American in the UK who wants one firm to handle both systems needs both authorisations in place.
Do Americans in Dubai need a tax agent authorisation in the UAE?
Most Americans working in Dubai need no UAE individual tax authorisation, because the UAE has no personal income tax return on salary. A US citizen who owns a UAE company is different, because the company may need a tax agent appointed through the Federal Tax Authority's EmaraTax platform for corporate tax or VAT.
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