IRS RESPONSE TO RECOMMENDATION: The IRS agrees that taxpayers abroad should be better informed about their U.S. tax obligations. We recognize that taxpayers have the right to know what they need to do to comply with tax laws and are entitled to clear explanations of the law and IRS procedures. We continue to look for opportunities to improve services delivered to this taxpayer base. A goal of the IRS is to ensure that all taxpayers with an obligation to pay U.S. tax have the education and assistance that they need. At the same time, the IRS must leverage its resources to focus on the most efficient and effective ways to provide taxpayer service as we address our compliance risks.

The IRS will leverage a range of communication channels, including IRS.gov, social media platforms, webinars, and stakeholder partnerships, to deliver consistent, accessible, and actionable information to international audiences. Content will be aligned across channels to reinforce key messages and ensure taxpayers receive timely and accurate information regardless of how they engage with the IRS. In addition, the IRS will continue to expand and enhance digital content and online resources to improve usability and navigation for taxpayers living abroad.

The IRS has Webpages on IRS.gov that are consistently being updated as needed to provide useful for international taxpayers.

The following webpages are currently available for issues related to international individual taxpayers:

• IRSvideos – YouTube (https://www.youtube.com/@irsvideos/search) – this link has several topics videos specifically related to international taxation;
• Practice Units | Internal Revenue Service (https://www.irs.gov/businesses/corporations/practice-units) – this link contains information designed to help taxpayers living abroad, resident aliens, nonresident aliens, residents of U.S. territories and foreign students; and
• International taxpayers | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers) – this page has links to international individuals and international businesses. The links include:
  • Foreign persons | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/foreign-persons)
  • Dispute resolution | Internal Revenue Service (https://www.irs.gov/businesses/dispute-resolution)
  • Individuals living or working in a U.S. Territory | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/individuals-living-or-working-in-a-us-territory)
  • U.S. citizens and resident aliens abroad | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad)
  • Foreign Account Tax Compliance Act (FATCA) | Internal Revenue Service (https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca)
  • Individual taxpayer identification number (ITIN) | Internal Revenue Service (https://www.irs.gov/tin/itin/individual-taxpayer-identification-number-itin)
  • Contact my local office internationally | Internal Revenue Service (https://www.irs.gov/help/contact-my-local-office-internationally)
  • Withholding foreign partnership and foreign trust | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/withholding-foreign-partnership-and-foreign-trust)
  • Reminder to U.S. owners of a foreign trust | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/reminder-to-us-owners-of-a-foreign-trust)
  • Foreign trust reporting requirements and tax consequences | Internal Revenue Service (https://www.irs.gov/businesses/international-businesses/foreign-trust-reporting-requirements-and-tax-consequences)
  • Gifts from foreign person | Internal Revenue Service (https://www.irs.gov/businesses/gifts-from-foreign-person)
  • Certain taxpayers related to foreign corporations must file Form 5471 | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/certain-taxpayers-related-to-foreign-corporations-must-file-form-5471)
  • Form 926 – Filing requirement for U.S. transferors of property to a foreign corporation | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/form-926-filing-requirement-for-us-transferors-of-property-to-a-foreign-corporation)
  • Delinquent international information return submission procedures | Internal Revenue Service (https://www.irs.gov/individuals/international-taxpayers/delinquent-international-information-return-submission-procedures)
  • International information reporting penalties | Internal Revenue Service (https://www.irs.gov/payments/international-information-reporting-penalties)

Additionally, the IRS will continue to develop educational letters, update relevant IRS.gov websites, and hold external webinars to further enhance international taxpayers’ awareness of their U.S. tax and IIR reporting obligations.

CORRECTIVE ACTION: The IRS will leverage a range of communication channels, including IRS.gov, social media platforms, webinars, and stakeholder partnerships, to deliver consistent, accessible, and actionable information to international audiences. Content will be aligned across channels to reinforce key messages and ensure taxpayers receive timely and accurate information regardless of how they engage with the IRS. In addition, the IRS will continue to expand and enhance digital content and online resources to improve usability and navigation for taxpayers living abroad.

Additionally, the IRS will continue to develop educational letters, update relevant IRS.gov websites, and hold external webinars to further enhance international taxpayers’ awareness of their U.S. tax and IIR reporting obligations.

TAS RESPONSE: TAS is encouraged by the IRS’s acknowledgement that taxpayers abroad need to be better informed about their U.S. tax obligations and its agreement to continue to look for opportunities to improve services delivered to this taxpayer base. There are millions of Americans residing abroad who are subject to complex U.S. tax laws and reporting requirements, but may be unfamiliar with what they need to do to comply. While IRS.gov features related information, some content is difficult to find or may be outdated. A search of “international taxpayers” on the IRSvideos – YouTube home page yields several videos but many are unrelated to international topics. And the first four videos, although relevant to taxpayers living abroad, are between six and 11 years old and contain disclaimers that the information may not be current due to COVID-19 tax relief and recent tax law changes. Similarly, the practice units referenced in the IRS Action response, appear to be job aids and training materials for IRS employees. As such, it seems unlikely that taxpayers living abroad would even be aware of the existence of these resources or how to find them.

TAS fully supports the IRS’s commitment to continue to develop educational letters, update relevant IRS.gov websites, and hold external webinars to increase international taxpayers’ awareness of their U.S. tax and IIR reporting obligations. TAS urges the IRS to also keep in mind the accessibility and ease of use of these materials. If taxpayers living abroad cannot find, access and understand these materials, the utility of these products is minimal.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

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

IRS RESPONSE TO RECOMMENDATION: The IRS recognizes that U.S. taxpayers living abroad face unique challenges in meeting their filing obligations and that access to reliable assistance is important. Currently, IRS offers free tax preparation services on military bases overseas, but these services are limited to military personnel. IRS will explore opportunities to expand access to free tax preparation assistance for taxpayers living abroad. This includes looking at potential partnerships with international organizations and considering whether remote or virtual support options could be feasible. IRS will also explore working with U.S. consulates and other international partners to better understand how services might be extended to taxpayers overseas. Any future efforts will depend on prioritization, secure technology, and partnership capacity. Expanding in this area would also require volunteers to be trained to handle the complexities of international tax rules and treaty provisions, which can be challenging.

CORRECTIVE ACTION: IRS will explore opportunities to expand access to free tax preparation assistance for taxpayers living abroad. This includes looking at potential partnerships with international organizations and considering whether remote or virtual support options could be feasible. IRS will also explore working with U.S. consulates and other international partners to better understand how services might be extended to taxpayers overseas. Any future efforts will depend on prioritization, secure technology, and partnership capacity. Expanding in this area would also require volunteers to be trained to handle the complexities of international tax rules and treaty provisions, which can be challenging.

TAS RESPONSE: TAS applauds the IRS’s commitment to explore the possibilities of expanding free tax preparation and assistance services to taxpayers living abroad. Helping taxpayers comply with their tax obligations is beneficial to everyone. TAS understands the IRS still faces barriers to implementing this recommendation; however, we urge the IRS to continue working to provide free and reliable assistance to these taxpayers. By expanding these services, the IRS would provide overseas taxpayers with crucial, long-overdue support. TAS looks forward to receiving details regarding the IRS’s efforts in implementing this recommendation.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

IRS RESPONSE TO RECOMMENDATION: The IRS and other federal agencies rely on CSPs to conduct identity verification and credential issuance for access to online government services. The IRS currently uses ID.me for access to IRS online accounts that require identity verification. Through ongoing coordination with the IRS, ID.me expanded their service offerings to support U.S. taxpayers living abroad (https://help.id.me/hc/en-us/articles/4415907236375-Verify-with-ID-me-if-you-live-outside-the-U-S-and-have-an-SSN).

The IRS is committed to supporting international taxpayer access to online services and will update written guidance on IRS.gov to describe more clearly how the identity proofing process works, especially for online applications which require a higher level of security and privacy. To reduce the burden on taxpayers living abroad as they navigate through the identity verification process, the IRS plans to update guidance on the ‘How to Register’ page with a section for users that live outside the U.S. These updates will include links to the CSP’s step-by-step instructions. Additionally, the IRS plans to update the Secure Access Digital Identity (SADI) sign-in page with a prominent link to the ‘How to Register’ page.

To gain further insight into identity verification options, the IRS will conduct market research on capabilities that could improve the identity proofing process for international taxpayers. Also, the IRS will conduct an analysis of the identity verification process for international taxpayers to inform improvement to the CSP’s offerings.

CORRECTIVE ACTION: The IRS is committed to supporting international taxpayer access to online services and will update written guidance on IRS.gov to describe more clearly how the identity proofing process works, especially for online applications which require a higher level of security and privacy. To reduce the burden on taxpayers living abroad as they navigate through the identity verification process, the IRS plans to update guidance on the ‘How to Register’ page with a section for users that live outside the U.S. These updates will include links to the CSP’s step-by-step instructions. Additionally, the IRS plans to update the Secure Access Digital Identity (SADI) sign-in page with a prominent link to the ‘How to Register’ page.

To gain further insight into identity verification options, the IRS will conduct market research on capabilities that could improve the identity proofing process for international taxpayers. Also, the IRS will conduct an analysis of the identity verification process for international taxpayers to inform improvement to the CSP’s offerings.

TAS RESPONSE: TAS appreciates the IRS’s commitment to resolve the verification challenges faced by U.S. taxpayers abroad. The IRS’s plan to update guidance on the “How to Register” page and step-by-step instructions is a good step in assisting taxpayer abroad. The IRS’s commitment to conduct market research on capabilities that could improve the identity-proofing process for international taxpayers and to conduct an analysis of the identity verification process for international taxpayers to inform improvement is also encouraging. TAS urges the IRS to continue to focus on evaluating the expansion and refinement of identity proofing options that meet the unique needs of this population.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

IRS RESPONSE TO RECOMMENDATION: The IRS has engaged in communication campaigns to educate taxpayers about the Executive Order 14247, Modernizing Payments To and From America’s Bank Account, which requires all government disbursement to be issued electronically. More than 95 percent of all individual taxpayers currently receive refunds through electronic means. The IRS will continue emphasizing the benefits and safety of direct deposit. The IRS also leverages Individual Online Account to securely provide banking information when it is not included on their tax returns.

Currently, international taxpayers are unable to receive electronic payments unless they have a domestic bank account. In implementing the Executive Order, the IRS provided international taxpayers a waiver for paper refunds. At this time, there is no scalable or cost-effective solution to support electronic payments for international taxpayers. The IRS is evaluating low-cost and convenient options to enable direct deposit refunds and electronic payment capabilities for international taxpayers and will assess current internal limitations affecting this population. The IRS will evaluate data collected during the filing season, incorporate lessons learned, and consider further actions through 2027.

CORRECTIVE ACTION: The IRS is evaluating low-cost and convenient options to enable direct deposit refunds and electronic payment capabilities for international taxpayers and will assess current internal limitations affecting this population. The IRS will evaluate data collected during the filing season, incorporate lessons learned, and consider further actions through 2027.

TAS RESPONSE: TAS recognizes that electronic payments can improve speed and security in financial transactions and supports IRS efforts to modernize, particularly efforts that reduce the IRS’s dependence on paper. However, for many taxpayers living abroad, electronic payments are not possible and receiving a paper check remains their only option. As there is no scalable or cost-effective solution to support electronic payments to international taxpayers at this time, TAS urges the IRS to implement a process to request an exemption before or at the time of the filing or streamline the exemption process for these taxpayers until it can provide accessible alternatives to them. TAS also encourages the IRS to prioritize evaluating low-cost and convenient options to enable direct deposit refunds and electronic payment capabilities for taxpayers living abroad.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

IRS RESPONSE TO RECOMMENDATION: The IRS will continue to expand electronic filing capabilities for forms commonly used by taxpayers living abroad, consistent with broader modernization efforts and available resources. Increasing e-filing availability remains a priority to improve accessibility and reduce processing delays.

The IRS, however, cannot commit at this time to implementing electronic options for requesting the discretionary two-month extension of time to file. Implementation would require system changes and coordination across multiple platforms and will be considered as part of future modernization initiatives.

CORRECTIVE ACTION: The IRS will continue to expand electronic filing capabilities for forms commonly used by taxpayers living abroad, consistent with broader modernization efforts and available resources. Increasing e-filing availability remains a priority to improve accessibility and reduce processing delays.

TAS RESPONSE: TAS fully supports the IRS’s commitment to expanding electronic capabilities for taxpayers living abroad. Taxpayers abroad continue to face challenges: international mailing delays, time zone differences, and limited access to IRS services. Without an electronic method to request a discretionary two-month extension, taxpayers must continue to rely on less efficient processes that may increase burden and create barriers to compliance. TAS encourages the IRS to evaluate opportunities to incorporate this functionality into future modernization initiatives to improve accessibility for taxpayers abroad. TAS will continue to monitor this issue and advocate for administrative and technological improvements for taxpayers living abroad.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Open

DUE DATE FOR ACTION (if left open): Ongoing

IRS RESPONSE TO RECOMMENDATION: The date on which the IRS closes the MeF system is based on the facts and circumstances of each individual filing season.

CORRECTIVE ACTION: N/A

TAS RESPONSE: The IRS’s response is disappointing and fails to provide any concrete reasons why it is unwilling to consider TAS’s recommendation. Paper filing is a problem for not only taxpayers abroad, but also for the IRS itself. While the IRS may be unwilling to extend the e-filing window for taxpayers abroad, its failure to even consider other options for these taxpayers reflects a cavalier disregard for the circumstances and difficulties taxpayers abroad face in meeting their tax obligations. We urge the IRS to reconsider its response and at the minimum explore alternative ways in which taxpayers living abroad could submit returns through electronic means after the close of the MeF system.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Not Adopted

OPEN or CLOSED: Closed

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