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Why it matters

Issue Statement: IRS operations has experienced many delays in processing amended returns. Taxpayers can use the limited “where’s my amended return?” (“WMAR”) online tool and get a general statement on how it takes for processing (i.e., up to 16 weeks). In reality, the timeframes are taking much longer (upwards of 264 days on average) to process, requiring taxpayers to ultimately contact the IRS about the delay. This delay is a burden on taxpayers, especially those expecting a refund. These delayed taxpayers also unnecessarily add to IRS taxpayer services burdens and lead to lower overall taxpayer service. The IRS would be able to serve more taxpayers if they are able to provide better communication to taxpayers about the status of their amended return. To that end, the TCC has provided two initial recommendations to improve status updates to taxpayers who file an amended return.

Goal Statement: To increase awareness of the status of filed amended returns.

Why it matters

Issue Statement: The Committee has developed a message which taxpayers will hear, on several Internal Revenue Service (IRS) telephone lines, providing the option to either stay on hold for XX minutes or have the IRS callback, within a specified period of time, when Customer Service Representatives (CSRs) are available.

Goal Statement: Develop a script to be used for the Customer Callback technology (CCB).

Why it matters

Issue Statement: Nearly half of FFI 8966s do not contain valid TIN/SSNs. This makes matching filers’ returns with 8966s very difficult. IRS believes that if filers reported the GIINs on their 8938s in their individual returns (now optional) this would facilitate matching. IRS would like this to be mandatory but Treasury mgt. is concerned by compliance issues. To assist filers, IRS has developed an online “FFI download tool”. TIGTA has endorsed this. But the tool works badly (I’ll explain if asked) and must remain optional. There is a simple solution. FFIs should include their GIINs on their monthly statements, much as most now include BICs and IBANs. The cost for FFIs is trivial and filers will have the necessary information right at hand.

Goal Statement: To determine how to make it possible for taxpayers to supply their foreign financial institution’s Global Intermediary Identification Number (GIIN) on Form 8938.

Why it matters

Issue Statement: Nearly half of FFI 8966s do not contain valid TIN/SSNs. The reason is not recalcitrant banks since banks can do nothing about the problem.

Rather, there are 2 sources: (1) filers have no SSN and find it difficult to obtain one; and (2) they have one but resist disclosing it to FFIs with no concern for the security issues involved. A simple solution is for IRS to issue ITINs to expats, accidental Americans and dual nationals on demand. This would cut SSA, for whom FATCA-related issues are distractions from their core mission and which is subject to its own legal and political constraints which make it difficult for them to be helpful, out of the picture. Since IRS issues ITINs on its own for no purpose but tax processing there are no administrative or practical issues involved in doing this. I have no idea whether enabling legislation might be needed, but such legislation would be uncontroversial and so a trivial attachment to some larger bill when convenient can easily do the job. If the grace period for FATCA compliance is extended for two years that would allow a year for accidentals and dual nationals to obtain ITINs without raising SSN-related issues or concerns, and a second year for 8966 reporting to proceed with ITINs.

Goal Statement: To determine if the IRS needs to issue an individual tax identification number (ITIN) to each American living overseas who requests one.

Why it matters

Issue Statement: Dear Sir or Madam: Because of the implementation of FATCA (Foreign Account Tax Compliance Act) globally in concert with the US practice of Citizenship Based Taxation, it is expected that all US citizens are to file their US tax declarations and pay any monies owed to the IRS. As a result of FATCA, a rapidly growing population of Accidental Americans has come to the forefront plus those previously unidentified Americans who have never lived in the United States. Nevertheless, they are expected to follow US law where they live. Many in the aforementioned populations especially the Accidental American population do not speak, read, or write English or other more common languages. In order for these individuals to comply properly to US law, it is necessary for the IRS to expand its breadth of languages offered for the forms and instructions. The languages offered need to include French, German, Italian, Japanese, Arabic, etc. so that adherence to US law can be respected. I deal with a growing number of these individuals around the world as I speak three languages and I can confirm that it is exceedingly difficult for compliance since the IRS forms and instructions are not available in their native tongue. It is important to note that the vast majority of these individuals cannot afford the US tax compliance professional costs and fees in order to comply therefore it is imperative that they have at their disposal the necessary documents in their native tongue. Since the expectation is full compliance with the US tax system, when will the IRS forms and instructions be available in the languages needed? I look forward to your reply. Sincerely, Keith
REDMOND American Overseas / Accidental American Global Advocate

Goal Statement: To determine if the IRS needs to develop instructions, forms, publication and other documentation in a much wider variety of foreign languages and to develop the capacity to communicate (including by telephone) with taxpayers living overseas in a much wider variety of foreign languages.

Why it matters

Project Statement: Determine if the Form 8867: Paid Preparer’s Due Diligence Checklist clearly communicates appropriate guidance to the public.

Goal Statement: The goal of this project is to review and make recommendations to the IRS that will enhance customer service and improve the taxpayer’s experience.

Why it matters

Issue Statement: I am a US citizen residing in New Zealand. I need to access my IRS account to see how much money has been credited to me. I have tried to register on-line at this site: https://sa.www4.irs.gov/eauth/pub/es_general.jsp But since I do not have US-based contact details, I am unable to register. This means I have effectively no way to view my account other than a long phone call to the IRS audit people who will only reveal a limited amount of information. The registration process needs to be made available to international US taxpayers.

The question from the group was whether there was one or more options for people to be “validated” without personally appearing. There was push-back from the IRS to the suggestion that tax practitioners should be allowed to use a POA or something similar to validate a client. (While most practitioners are honest, there have apparently been over 3,000 practitioners sanctioned over the years and we’re all familiar with the “refund mills” run by some.) In any case, there was a suggestion that a “certified acceptance agent” could be used to perform this validation. While I’ll admit I have no idea what a certified acceptance agent is (or how you become one), the IRS seemed to think there might be some merit in this idea.

Goal Statement: To make it possible for taxpayers living outside the United States to be able to create and access an online account with the IRS.

Why it matters

Issue Statement: The suggestion is for the IRS to review other ways to verify identity from low-income taxpayers. The current process discriminates against them. Low-income people move from place to place for various reasons. In order to get a 6-digit number via text to complete the process, the taxpayer must have a mortgage loan number (they may not own a home), a credit card number (they do not always have credit cards and debit cards are not permissible), auto loans (they may not have a car and therefore use public transportation), a cell phone with major carriers (many have prepaid cell phones). Low income people need their refund and many can’t verify their identity by using the on-line option because they cannot provide the required information to obtain a 6-digit pin number.

Also taxpayers who have been the victim of identity theft are now receiving CP 5747C letters, requiring them to physically appear in person at an IRS office to prove their identity. Not only does this apparently cause a lot of concern to those who receive this letter, it also requires them to make an appointment. A couple of matters were raised: first, taxpayers who are not proficient in English may just go directly to an IRS office without understanding they need to make an appointment, or what specific documents to bring with them; and second, this requirement to physically present oneself can be a terrible inconvenience to some taxpayers given the hours when IRS offices are open (surgeons and medical professionals were one example) or the distance required to get to one.

The question from the group was whether there was one or more options for people to be “validated” without personally appearing. There was push-back from the IRS to the suggestion that tax practitioners should be allowed to use a POA or something similar to validate a client. (While most practitioners are honest, there have apparently been over 3,000 practitioners sanctioned over the years and we’re all familiar with the “refund mills” run by some.) In any case, there was a suggestion that a “certified acceptance agent” could be used to perform this validation. While I’ll admit I have no idea what a certified acceptance agent is (or how you become one), the IRS seemed to think there might be some merit in this idea.

Goal Statement: To determine if the current IRS requirements for verifying identity have a disproportionate effect on taxpayers or might be impossible for low-income taxpayers to achieve. If true then making changes to any guidance that would ensure taxpayers the ability to acquire an Identity Protection Personal Identification Number (IP PIN) needs to be implemented in all applicable instructions, forms, and guides. Also to determine if the IRS requirements for taxpayers who are victims of identity theft to appear in person at an IRS office may be overly burdensome.

Why it matters

Project Statement: Evaluate clarity and completeness of tip reporting instructions for self-employed taxpayers.

Goal Statement: The goal of this project is to recommend to the IRS that current instruction in Pub. 531 be revised to clarify tip reporting requirements for self-employed taxpayers and improve the taxpayer’s experience.