What is an IRS CP59 notice, and why do expats receive them?

A CP59 is the IRS nonfiler notice, meaning the IRS has income records for you (W-2s, 1099s, or foreign information reports) but no tax return on file for that year. Expats are frequent CP59 recipients because many do not realize U.S. citizens must file on worldwide income regardless of where they live. A CP59 is not a bill or an audit. It is the IRS asking you to either file the missing return or explain why you were not required to file. For the full IRS explanation, see CP59 notice.

• CP59 is a nonfiler inquiry, not a penalty notice or audit
• Respond promptly by filing the missing return or explaining why filing was not required
• Expats who owe no tax after applying the FEIE or FTC still must file to claim those benefits
• Ignoring a CP59 leads to escalating enforcement: the IRS may file a Substitute for Return (SFR) on your behalf without applying exclusions or credits

Why expats get CP59 notices:

How to respond:

• If you need to file, submit the missing return as soon as possible. Attach Form 2555 for the FEIE or Form 1116 for the FTC. Include Form 15103 (Return Delinquency) if one was enclosed with your notice.
• If you already filed, send a copy of your return with proof of filing (certified mail receipt or e-file confirmation) to the address on the notice.
• If you were not required to file, respond in writing explaining why (income below the filing threshold, for example) and attach supporting documentation.

If you have multiple years of unfiled returns, the Streamlined Filing Compliance Procedures let you catch up on three years of returns and six years of FBARs, with reduced or eliminated penalties for non-willful filers. Do not wait for additional notices. Filing with the IRS before the deadline escalates and preserves your eligibility for penalty relief.

For a full overview of catch-up options, see our IRS Amnesty Program Guide.