01. International Tax

We provide tailored solutions to complex global businesses doing business in the U.S. Small or multinational, we guide clients through the maze of complex U.S. international tax rules.

02. Offshore Tax Compliance

We assist clients with specialized counsel to fix noncompliance with international tax reporting and penalties. FBAR, forms 8938, 8621, 3520, 926, 5471 and 5472 are among the most common forms that we solve through compliance programs such as streamlined procedures, Voluntary Disclosure Program or the Delinquent International Information Return Submission Procedures (DIIR).

03. Small Business Tax Planning

We assist small and medium businesses with efficient tax structuring to improve efficiencies. Proper tax election, s-corp elections and partnership planning are some of the main solutions offered.

04. Controversy Tax

We guide and represent clients before the IRS including examinations and appeals, as well as represent clients in Tax Court or Federal Courts.

05. Tax Debt Resolution

We help clients to face harsh collection activities, including liens, levies and obtaining a collection alternative such as an offer in compromise, installment payment plans, among others.

06. IRS Criminal Investigations

Our Firm provides representation before IRS Criminal Investigation Division, including Malta Pension Plans and summons.

07. High Net Worth & Family Offices

Assistance with estate planning for select clients and those with cross-border operations, planning for inheritance taxes, and gift taxes in the USA.

08. Start-Ups & Business Tax

No matter how small the idea, we assist clients with the best tax planning and alternatives for their business.

09. Crypto Tax

Our Firm provides tax planning and tax advice on crypto assets and crypto events, including mining, forks, rewards, and disposition/exchange of crypto.

10. BOI Report- Corporate Transparency Act

We assist business owners, CPA and tax preparation firms to file the Beneficial Ownership Information (BOI) report with the FinCEN.

IRS Notice CP504: What It Is and What To Do

IRS Notices

08.20.2025

IRS Notice CP504, also referred to as the Final Notice, is a formal communication indicating that the taxpayer has failed to address an outstanding federal tax debt. It means the IRS has not received payment for a tax balance previously assessed. The taxpayer will have already received earlier notices, and this one signals that the situation is escalating.

CP504 is not just another reminder—it is a Notice of Intent to Levy under Internal Revenue Code Section 6331(d). It serves as a final warning before the IRS takes aggressive collection actions, such as levying state tax refunds or initiating federal liens. Understanding the content and consequences of Notice CP504 is critical to avoiding severe financial repercussions.

What does Notice CP504 include?

    • Amount due: Including original tax liability, interest, and penalties.
    • Due date: Generally 30 days from the date on the notice.
    • Payment instructions: Via electronic methods, check, or money order to the U.S. Treasury.
    • Legal warnings: If no action is taken, the IRS may levy state tax refunds and begin further enforcement efforts.

Potential IRS actions following CP504

Several things may happen if the taxpayer fails to respond, such as:

    • State tax refund levy: Immediate seizure without further notice.
    • Federal levy: On wages, bank accounts, retirement accounts, business and personal assets, and even Social Security benefits.
    • Federal Tax Lien (NFTL): Public record claim on all property owned by the taxpayer, damaging credit and financial credibility.
    • Passport revocation or denial: For certain seriously delinquent tax debts under IRC § 7345.

What if the taxpayer disagrees?

The CP504 notice can be challenged through the following means:

    • Collection Appeals Program (CAP): Submit Form 9423 to request a review before collection.
    • Collection Due Process (CDP) hearing: If eligible, request a hearing under IRC § 6330.
    • Request for penalty or interest abatement: File Form 843 or provide a written explanation with supporting documentation.

Taxpayers should read the notice carefully and gather relevant financial records (e.g., canceled checks, corrected returns) before contacting the IRS.

Relevance for Taxpayers

Notice CP504 is one of the last opportunities to resolve a tax debt before the IRS enforces collection by legal means. Failure to act can result in wage garnishment, property seizure, credit damage, and restricted international travel.

For individuals and businesses alike, this notice represents a point of no return. Once the IRS initiates a levy or files a lien, reversing the process becomes legally and procedurally more difficult. Responding promptly—either by paying, negotiating a payment plan, or pursuing an appeal—can preserve financial stability and legal standing.

We Can Help!

CP504 is a critical warning that must not be ignored. If you’ve received this notice, time is of the essence.

At JH Tax Law, our team can help you evaluate your options, challenge the IRS’s position when warranted, and ensure compliance with all applicable legal procedures to prevent further collection actions. Contact our office for a confidential consultation today.