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US Certification Reasons to Refer a Case to P&A

Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States

(1) There are several circumstances where a case needs to be referred to Planning and Analysis (P&A) to be reviewed before it can be processed. The following list provides situations in which cases need to be sent to P&A:

If:

IRM

IMF/BMF

A return is unpostable

IRM 21.8.4.2(6)

Both

Reconsideration Request

IRM 21.8.4.2(12)IRM 21.8.4.4.12.1.1(12)IRM 21.8.4.4.12.1.2(19)IRM 21.8.4.4.12.1.3(19) IRM 21.8.4.4.12.2 (24) IRM 21.8.4.4.12.4(38)IRM 21.8.4.4.12.6(17)IRM 21.8.4.4.12.9.4(12)

Both

Applicant or Spouse has a Visa

IRM 21.8.4.4.12.5(14)

IMF

There is IDT on the applicant's account

Local Procedures

Both

There are NMF indicators on the account

IRM 21.8.4.4.11(6)

Both

Individual Applicant and/or spouse has an ITIN

Local Procedures

IMF

A Form 2555 or Form 1116 are attached to the return used to verify

Local Procedures

Both

There are invalid FIPS codes

IRM 21.8.4.4.6(2)

BMF

No letter applies when more information is needed

IRM 21.8.4.4.9(7)

Both

Certification is requested for the same country the business is incorporated in

IRM 21.8.4.4.12.1(5)

BMF

Processing foreign claims forms that are not listed in the IRM

IRM 21.8.4.4.14(5)

Both

External Reach-ins

Local Procedures

Both

Exempt Organizations not required to file that can prove residency a different way

IRM 21.8.4.4.12.4(27)

BMF

A trust agreement is not attached and/or there is a question whether the administrator of the employee plan is a qualified custodian bank

IRM 21.8.4.4.12.2(13)

BMF

Any issue that cannot be resolved with the 21.8.4 IRM for Form 8802 Instructions

IRM 21.8.4.2(8)

Both

Unable to determine if applicant is entitled to certification based on provided information

IRM 21.8.4.2.1.5(6)

Both

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▸Contents — Internal Revenue Manual Part 21. Customer Account Services

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