IRS RESPONSE TO RECOMMENDATION: A survey of individual taxpayers to determine which aspects of the IRS ITIN application process are especially burdensome and unnecessary. Advocacy groups that represent the taxpayer’s perspective as well as the IRS Advisory Council have provided feedback of the ITIN experience. Many of the concerns identified were addressed through process improvements, including the implementation of a new document authentication process that allows the return of authenticated original documents earlier in the applications processing. Taxpayer guidance was revised for the Form W-7, Application for IRS Individual Taxpayer Identification Number, and instructions to include a table aiding taxpayers in the determination of acceptable medical and school records. The ITIN-related content on IRS.gov was updated to include a frequently asked questions section. The IRS continues to explore development of modernization and automation efforts with the ITIN application process.

CORRECTIVE ACTION: N/A

TAS RESPONSE: TAS commends the initiatives to alleviate taxpayer burden by returning original authenticated documents significantly earlier in the process than ever before. Furthermore, TAS applauds the IRS for its efforts to refine and streamline the ITIN application process. To better understand the effectiveness of these vital improvements, an internal survey designed by subject matter experts could provide crucial insights into the impact of these changes and help identify any lingering challenges that may still impose difficulties on taxpayers.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: The IRS has paused existing efforts to expand Certifying Acceptance Agent services and conduct other ITIN-related activities.

CORRECTIVE ACTION: N/A

TAS RESPONSE: TAS recognizes the need to pause the expansion of Certifying Acceptance Agent services and other ITIN related activities. However, we believe that when the opportunity arises, adopting a strategic approach to identify regions with high concentrations of ITIN applicants will facilitate assisting the highest number of taxpayers. By promoting and expanding VITA sites that provide CAA services, we can enhance support for taxpayers and streamline ITIN application process. This initiative will not only improve accessibility but also strengthen our collective efforts in combating the challenges associated with ITINs.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A

IRS RESPONSE TO RECOMMENDATION: The IRS will identify and, if found, fix systemic problems that relate to erroneous deactivations.

CORRECTIVE ACTION: The IRS will identify and, if found, fix systemic problems that relate to erroneous deactivations.

TAS RESPONSE: TAS supports the IRS initiatives aimed at identifying and resolving systemic issues linked to erroneous deactivations. As outlined in the TAS Research Report referenced here, we have developed a process for detecting potentially erroneous deactivations of ITINs. This methodology can be further refined and expanded to effectively identify and eliminate systemic problems related to these deactivations. By taking these proactive steps, the IRS can ensure greater accuracy and reliability in their processes, ultimately enhancing the trust and confidence in their systems.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 6/30/2026

IRS RESPONSE TO RECOMMENDATION:Taxpayers filing returns using deactivated ITINs are notified through Math Error notices about the issue with their ITINs. The notice explains that if they don’t qualify for a social security number, they can apply for an ITIN and how to obtain a Form W-7, Application for IRS Individual Taxpayer Identification Number. The letter also provides contact information to discuss their options with a customer service representative. The letter identifies TAS and Low-Income Taxpayer Clinics as an additional source for taxpayers to obtain assistance. The IRS will explore opportunities for enhanced taxpayer outreach through existing outreach platforms.

CORRECTIVE ACTION: The IRS will explore opportunities for enhanced taxpayer outreach through existing outreach platforms.

TAS RESPONSE: TAS recognizes existing methods to notify taxpayers of issues with their ITIN through math error notices and lauds IRS efforts to explore opportunities for enhanced taxpayer outreach. TAS would emphasize the benefit to the taxpayer to be given explicit information on the steps necessary to secure the potentially lost tax credits associated with deactivated dependent ITINs.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): 8/31/2025