What Is Form 4852 and When Do I Need a Substitute W-2?

Form 4852 is the IRS substitute for a missing or incorrect Form W-2 or Form 1099-R. You file it when your employer or payer either never sent you the form or sent one with wrong information, and you cannot get it corrected before the filing deadline.

According to the IRS, Form 4852 lets you report your wages, retirement distributions, and taxes withheld using your own records when the official form is unavailable. It attaches directly to your Form 1040 and serves as a substitute for the missing document.

The most common situations where you may need Form 4852:

Your employer never issued a W-2 (common with foreign employers, closed businesses, or companies with outdated mailing addresses)
Your W-2 contains errors, and the employer will not issue a corrected W-2c
Your 1099-R is missing or incorrect from a pension plan, IRA, or retirement account

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For Americans living abroad, this form comes up far more often than it does for domestic filers, and the stakes of getting it wrong are higher. Here is what you need to know.

Why Is Form 4852 So Common for Expats?

Domestic taxpayers usually deal with Form 4852 only in rare circumstances, such as when a company goes out of business. For Americans abroad, the problem is structural. Several common expat scenarios make missing or incorrect W-2s a recurring issue.

1. Foreign Employers Do Not Issue W-2s

If you work for a non-U.S. company, your employer has no obligation to issue a W-2. In most cases, you do not need Form 4852, as foreign employment income is reported directly on Form 1040, Line 1h. However, some expats work for a U.S.-based company that pays through a foreign subsidiary, creating confusion about which entity should issue the W-2. When neither the U.S. parent nor the foreign subsidiary provides the form, Form 4852 may be the only option.

Read our comprehensive guide on filing without a W-2 for more details.

2. U.S. Employers Lose Track of Overseas Addresses

Employers are required to mail W-2 forms by January 31. But when your mailing address is in another country, international delivery can take weeks, or forms may never arrive. If you have moved multiple times abroad, your former employer may still have a years-old address on file. By the time you realize the form is missing, follow up with your employer, and wait for a reissue, you may be past the filing deadline.

3. Retirement Plan Administrators Send Incorrect 1099-Rs

Expats receiving pension distributions, IRA withdrawals, or annuity payments sometimes receive 1099-R forms with incorrect withholding amounts or distribution codes. If the payer will not correct the form and you cannot get a response in time, Form 4852 can substitute for the incorrect 1099-R so you can file accurately.

4. Closed or Unresponsive Businesses

If your former U.S. employer has shut down, merged, or simply stopped responding to your requests, there may be no way to obtain a W-2 at all. The IRS can attempt to contact the employer on your behalf (call +1 800-829-1040), but if that fails, Form 4852 is the fallback.

What Are the Risks of Filing Form 4852 Without Professional Help?

Form 4852 requires you to estimate your income and withholding based on whatever records you have, such as pay stubs, bank deposits, or prior-year W-2s. The IRS expects those estimates to be reasonable and well-documented. For expat returns, the margin for error is wider, and the consequences are more significant.

1. Estimated Income Directly Affects Your FEIE and FTC Calculations

This is the biggest risk most expats do not think about. The income figure you report on Form 4852 flows directly into your Foreign Earned Income Exclusion and Foreign Tax Credit calculations. If you overestimate your income, you may overpay taxes or trigger unnecessary complexity. If you underestimate, you risk an IRS notice, penalties, and having to amend your return later.

For the 2025 tax year, the FEIE allows you to exclude up to $130,000 of foreign earned income. If your estimated wages are close to that threshold, even a small error can mean the difference between owing $0 and owing several thousand dollars.

2. Currency Conversion Adds Another Layer

If your employer paid you in a foreign currency, you need to convert those amounts to U.S. dollars to complete Form 4852. The IRS expects you to use a consistent method, either daily exchange rates for each paycheck or the annual average rate. Using the wrong approach, or mixing methods, can create discrepancies that draw IRS scrutiny. Your Greenback accountant can apply the right conversion method and document it properly.

3. Withholding Estimates Must Account for Both Countries

When filling out Form 4852, you need to report federal income tax withheld. But if your U.S. employer withheld taxes through a foreign payroll system, or if you had taxes withheld by a foreign government instead, the withholding picture is more complicated than a typical domestic W-2. Reporting the wrong withholding amount can result in underpayment penalties or delayed refunds.

4. You May Need to Amend Later

If your employer eventually sends the correct W-2 or 1099-R after you file with Form 4852, you are required to compare the two. If the amounts differ, you must file an amended return using Form 1040-X. For expats, an amended return is not just a simple correction because the new income figures may change your FEIE calculation, your Foreign Tax Credit, your self-employment tax, or your state filing requirements.

5. The IRS Scrutinizes Form 4852 Returns More Closely

The IRS has stated it will challenge taxpayers who use Form 4852 improperly. Because the form relies on self-reported estimates rather than employer-verified data, returns filed with Form 4852 may be subject to additional review. This makes thorough documentation and accurate calculations especially important.

What Steps Does the IRS Require Before You Can File Form 4852?

The IRS does not allow you to skip straight to Form 4852. You must first take specific steps to obtain the missing or corrected form, and you must document those efforts on Line 10 of the form.

Step	What to Do	When
1	Contact your employer or payer directly to request the missing or corrected form	As soon as you notice the form is missing or incorrect
2	Follow up if no response	By the end of February
3	Call the IRS at +1 800-829-1040 (or 267-941-1000 for Americans abroad) and provide your employer’s information so the IRS can contact them	After February, if the employer has not responded
4	If the form still has not arrived, use Form 4852 with your best estimates based on pay stubs, bank records, or prior-year forms	When filing your return

On Line 10, you will need to explain what you did, when you did it, and what response you received. The more detailed your documentation, the better protected you are if the IRS questions your return.

Can I E-File with Form 4852?

You can e-file a return that includes Form 4852 if you know the employer’s Employer Identification Number (EIN). Most tax preparation software and e-file providers support this. However, if you do not have the EIN, you will need to paper-file your return by mail.

For Americans abroad, paper filing adds weeks to processing time. Returns mailed from overseas to the IRS generally take 8 to 12 weeks to process, compared to about 3 weeks for an e-filed return. If possible, locating the EIN from a prior-year W-2, a pay stub, or your employer’s records can save you months of waiting.

How Does Greenback Handle Form 4852 for Expats?

When you work with Greenback, you do not need to figure out Form 4852 on your own. Your accountant handles the entire process, from verifying whether you even need the form to preparing accurate estimates and documenting your efforts.

Determining whether Form 4852 is necessary: In many expat situations, it is not the right answer. If you work for a foreign employer that does not issue W-2s, your income is reported directly on your Form 1040 without needing a substitute form. If you have a correctable situation, your Greenback accountant may be able to help you get the right documents before resorting to Form 4852.
Calculating accurate income and withholding estimates: Your accountant uses your pay stubs, bank records, employment contracts, and foreign tax documents to build accurate estimates. For multi-currency situations, they apply the correct IRS-approved conversion method and document it in your return.
Coordinating with your full expat return: The income on Form 4852 flows into your FEIE, FTC, self-employment tax, and state tax filing. Greenback ensures these calculations all align, so you are not filing a patchwork return where one form contradicts another.
Handling amended returns if the original form arrives later: If a corrected W-2 or 1099-R shows up after filing, your accountant compares it against what was reported and handles the Form 1040-X amendment if needed, including recalculating any affected exclusions or credits.

What Should I Do Next?

If you are missing a W-2 or 1099-R, or if you received one with incorrect information, the first step is to contact your employer or payer directly. If you cannot get the form corrected in time, working with an accountant who specializes in expat returns ensures your Form 4852 is prepared accurately and your full return stays consistent.

No matter how late, messy, or complex your return may be, we can help. You will have peace of mind, knowing that your taxes were done right.

If you are ready to be matched with a Greenback accountant, click the get started button below. For general questions about missing tax documents or working with Greenback, contact us, and one of our Customer Champions will be happy to help.

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This article is for informational purposes only and does not constitute tax, legal, or accounting advice. Every taxpayer’s situation is unique. For guidance specific to your Form 4852 filing and tax return, contact Greenback to speak with an expat tax specialist.