Assessment of the IRS’s Individual Taxpayer Identification Number Program

Date Issued

Friday, March 27, 2026

Submitting OIG

Treasury Inspector General for Tax Administration

Agencies Reviewed/Investigated

Internal Revenue Service

Report Number

2026-400-016

Report Type

Audit

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

$3,934,002

Report updated under NDAA 5274

Open Recommendations

This report has 6 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
The Chief, Taxpayer Services, should regularly provide training to tax examiners covering credit eligibility requirements and appropriate account actions to take for ITIN holders based on the applicable tax year.
2	No	$0	$3,934,002
The Chief, Taxpayer Services, should review the 1,769 tax returns where the IRS allowed credits for ITIN holders who were potentially ineligible and make associated corrections, as necessary.
3	No	$0	$0
The Chief, Taxpayer Services, should update PATH Act implementation guidance in Notice 2016-48 to define the issuance date of an ITIN as either the original issuance date or the renewed issuance date, if applicable, for those ITINs that have expired.
4	No	$0	$0
The Chief, Taxpayer Services, should update the ITIN Policy Section guidelines to require on-site reviews of high-risk CAAs to be completed periodically to ensure adequate oversight.
5	No	$0	$0
The Chief, Taxpayer Services, should establish a process for the ITIN Unit to regularly share its observations of potentially questionable CAA activities or patterns with the ITIN Policy Section.
6	No	$0	$0
The Chief, Taxpayer Services, should establish a process for the ITIN Policy Section to review and consider the ITIN Unit’s potentially questionable CAA referrals when selecting CAAs for compliance reviews and processing applications.