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Open Recommendations (10 total)

Carbon Capture Tax Credit: Actions Needed to Improve Federal Administration and Evaluation of Tax Expenditure

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4 Open Recommendations
Agency Affected Recommendation Status
Internal Revenue Service The Commissioner of Internal Revenue, in coordination with DOE, should modify the IRS/DOE memorandum of understanding (MOU) to provide taxpayers, with appropriate limitations, an opportunity to modify elements of their LCAs prior to rejection, rather than having to resubmit their LCAs and restart the process. (Recommendation 5)
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When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Internal Revenue Service The Commissioner of Internal Revenue, in coordination with DOE, should determine the feasibility, including the costs and benefits, of developing a Greenhouse gases, Regulated Emissions, and Energy use in Technologies (GREET) model for common 45Q utilization pathways, allowing an LCA process that can be submitted upon tax return filing without prior review, similar to the 45V and 45Z credits. (Recommendation 3)
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When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Internal Revenue Service The Commissioner of Internal Revenue, in coordination with DOE, should continue creating additional comparison product system technology baselines, including by implementing a process for taxpayers to request specific technology baselines, similar to the process for requesting provisional emissions rates for the 45V and 45Z credits. (Recommendation 2)
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When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Internal Revenue Service The Commissioner of Internal Revenue, in coordination with DOE, should determine the minimum time period of production system direct data needed to determine the displacement factor in the LCA pre-approval, and update guidance to allow for taxpayers that meet that minimum to submit an LCA for pre-approval prior to the end of the tax year. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Tax Regulations: Opportunities Exist to Improve Economic Analysis and Taxpayer Engagement

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3 Open Recommendations
Agency Affected Recommendation Status
Internal Revenue Service The Commissioner of Internal Revenue should direct agency officials in coordination with relevant Treasury officials to establish policies and procedures for public regulatory hearings that enhance virtual participation options. (Recommendation 5)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Internal Revenue Service The Commissioner of Internal Revenue should direct agency officials in coordination with relevant Treasury officials to establish policies and procedures for the efficient identification, documentation, and disposition of mass public comments, including comments written with the assistance of AI, on proposed tax regulations, consistent with legal requirements. (Recommendation 4)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Internal Revenue Service The Commissioner of Internal Revenue should direct agency officials, in coordination with relevant Treasury officials, to establish policies and procedures for public regulatory hearings that ensure documentation of important public comments made at hearings not otherwise documented through other means. (Recommendation 6)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

IRS Financial Reporting: Improvements Needed in Information System and Other Controls

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1 Open Recommendations
Agency Affected Recommendation Status
Internal Revenue Service The Commissioner of Internal Revenue should improve and implement procedures to properly account for nonproduction costs and report nonproduction costs that are material to the financial statements. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Artificial Intelligence: IRS Actions Needed to Address Skills Gaps, Information Quality, and Strategic Management

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2 Open Recommendations
Agency Affected Recommendation Status
Internal Revenue Service The Commissioner of Internal Revenue should ensure IRS's internal guidance related to the AI inventory is comprehensive, including the job aids for AI use case owners and checklist the AI governance office uses to verify inventory entries. (Recommendation 3)
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IRS agreed with this recommendation. We will update the status of this recommendation when IRS provides its 180-day letter (expected in fall 2026).
Internal Revenue Service The Commissioner of Internal Revenue should ensure internal communications about AI governance clarify that all AI unclassified use cases, including contracted and sensitive law enforcement AI, are subject to AI inventory requirements, with limited exceptions. (Recommendation 4)
Open
IRS agreed with this recommendation. We will update the status of this recommendation when IRS provides its 180-day letter (expected in fall 2026).