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Published:   |   Last Updated: April 29, 2025

Enhance IRS Transparency by Improving Applicable Technology, Sufficiently Explaining Modernization Progress, and Providing Straightforward Guidance on Tax Law

Objective

Background

Technology is not the only area of concern for IRS transparency. The IRS must be proactive in issuing guidance on tax law that is clear and timely and that adequately reflects input from stakeholders while fully complying with the notice-and-comment requirements of the Administrative Procedure Act.26 As the IRS continues to implement its Strategic Operating Plan (SOP), it needs to provide stakeholders with meaningful updates on its progress without overstating successes or minimizing setbacks. These updates must include performance metrics and specific deadlines that objectively report progress toward all initiatives in the SOP, not just modernization efforts the IRS currently prioritizes.

Highlights

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Status

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Expected Completion Date

09/30/2025

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Activities

Activity 1: Make internal recommendations through TAS’s cross-functional working groups and the IRS Advisory Counsel and external recommendations through public speeches, blogs, Reports to Congress, and other avenues that the IRS be transparent when providing updates on its plans for modernization and its progress toward meeting modernization initiatives.

Activity 2: Through membership on the Data and Analytics Strategic Integration Board, the AI Assurance Team, or other cross-functional groups involved in AI oversight, review IRS uses of AI to ensure that they comply with government-wide standards on taxpayer rights and data privacy.

Activity 3: Conduct listening sessions and other forms of outreach with external stakeholders to identify areas in which the IRS has not provided taxpayers with guidance and information that is timely and clear and that adequately incorporates stakeholder feedback. Use internal meetings, blogs, and Reports to Congress to advocate for the IRS to promptly address these issues.

Activity 4: Participate on cross-functional teams implementing the IRS Inflation Reduction Act Strategic Operating Plan, evaluate planned initiatives, and make administrative recommendations to maximize protection of taxpayer rights and minimize IRS burden imposed on taxpayers. Participate on cross-functional teams implementing the IRS Inflation Reduction Act Strategic Operating Plan, evaluate planned initiatives, and make administrative recommendations to maximize protection of taxpayer rights and minimize IRS burden imposed on taxpayers.

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Actions Completed

1st Quarter

TAS established an internal Artificial Intelligence (AI) Collaborative Team that convenes monthly to discuss the IRS’s role in the AI landscape. The team is currently managing three active Information Gathering Projects (IGPs) focused on:

  1. Researching the IRS’s use of AI, including compliance initiatives developed or derived from AI and data analytics models, with an emphasis on identifying and addressessing potential biases.
  2. Examining how the tax industry and broader business community leverage AI for online filing services.
  3. Investigating how the IRS protects and utilizes its own data, as well as its approach to using data acquired from third parties to enhance compliance and outcomes.

TAS has embedded two representatives in the IRS AI Assurance Team (AIAT). This cross-functional team plays a critical role of ensuring the IRS adheres to all relevant AI policies, regulations, and ethical standards. Additionally, TAS released a blog that details how stakeholders can use TAS’s Systemic Advocacy Management System (SAMS) to submit issues of concern. TAS also held listening sessions with external stakeholders to discuss each of the ten Most Serious Problems (MSP) affecting the IRS. The feedback gathered during these sessions is documented in the Annual Report to Congress (ARC) which includes recommendations for the IRS to promptly address.

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Actions Completed

2nd Quarter

TAS continues to advocate and make recommendations to the IRS on how to address transparency. For example, TAS advocated by providing comments on the Taxpayer Assistance and Service Act, draft legislation that incorporates many of the National Taxpayer Advocate’s legislative proposals. The bill would enhance IRS’s transparency and communication with taxpayers in numerous ways, including clarifying the language of notices, codifying a dashboard to inform taxpayers of backlogs, expanding access to callback technology, and expanding the information available through taxpayer online accounts.

TAS participates on the Artificial Intelligence (AI) Assurance Team. However, the team is currently suspended pending additional guidance from the Office of Management and Budget and the Department of the Treasury regarding AI governance activities. We will continue to monitor during next quarter.

TAS continues to educate and gather feedback from external stakeholders. TAS established a series of seminars and listening sessions with Low Income Tax Clinic (LITC) practitioners to discuss the most serious problems (MSPs) from the 2024 Annual Report to Congress and obtain feedback on how practitioners are experiencing those issues. TAS employees regularly attended external conferences, such as bar associations like the American Bar Association, industry-related groups such as the Council for Electronic Revenue Communication Advancement, and advisory committees such as the Taxpayer Advocacy Panel and the IRS Advisory Council. TAS also performed external education to educate the public how to submit systemic issues they may be having with the IRS.

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Next Steps

TAS will continue to work within the Artificial Intelligence (AI) Collaborative Team and gather additional research.