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Open Recommendations

Carbon Capture Tax Credit: Actions Needed to Improve Federal Administration and Evaluation of Tax Expenditure
GAO-26-107711
Aug 06, 2026
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7 Open Recommendations
Agency Affected Recommendation Status
Congress Congress should consider directing agencies to collect and analyze data to answer key questions about the performance of the 45Q credit, such as how well it is working to achieve specific goals, how efficiently it is performing, and how it compares to other policy tools. (Matter for Congressional Consideration 1)
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, 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.
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)
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, 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)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of Energy The Secretary of Energy, in coordination with IRS, should adjust the 45Q credit guidance on LCAs to clarify which GREET model data are acceptable for use with a 45Q credit LCA and how and when they can be used. (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, 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)
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
GAO-26-108115
Jul 21, 2026
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6 Open Recommendations
Agency Affected Recommendation Status
Department of the Treasury The Secretary of the Treasury should direct agency officials in coordination with relevant IRS officials to include in regulatory economic analyses specific cost and benefit estimates to inform regulatory alternatives the agency is considering. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of the Treasury The Secretary of the Treasury should direct agency officials in coordination with relevant IRS officials to include in regulatory economic analyses estimated changes in federal revenues to inform regulatory alternatives the agency is considering. (Recommendation 2)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of the Treasury The Secretary of the Treasury should direct agency officials in coordination with relevant IRS officials to summarize improved cost, benefit, and revenue estimates for regulatory decisions, when such estimates are made. (Recommendation 3)
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 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 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.

2025 Tax Filing: Management of Agency Reforms and Workforce Planning Needed to Address Severe Risks to Future IRS Operations
GAO-26-108116
Mar 16, 2026
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3 Open Recommendations
1 Priority
Agency Affected Recommendation Status
Internal Revenue Service
Priority Rec.
The Commissioner of Internal Revenue should develop and implement a plan for addressing the agency's correspondence inventory backlog. (Recommendation 1)
Open
IRS neither agreed nor disagreed 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 establish an implementation team to manage the agency's reform efforts and provide and receive timely, quality information that meets the needs of leadership and staff. (Recommendation 2)
Open
IRS neither agreed nor disagreed 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 As IRS develops a strategic workforce plan to align with Treasury's strategic plan for fiscal years 2026 through 2030, the Commissioner of Internal Revenue should build off IRS's workforce plan for fiscal years 2024 through 2026 that was finalized in June 2024 and incorporate plans to address the loss of thousands of filing season staff. IRS's new plan should include for filing season operations (1) long-term strategies to achieve programmatic goals, (2) mechanisms to track progress toward achieving those goals, and (3) capacity-building efforts for essential positions. (Recommendation 3)
Open
IRS neither agreed nor disagreed with this recommendation. We will update the status of this recommendation when IRS provides its 180-day letter (expected in fall 2026).

Disaster Assistance: SBA Should Take Steps to Make Data Sharing with IRS More Efficient
GAO-26-107682
Mar 03, 2026
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1 Open Recommendations
Agency Affected Recommendation Status
Small Business Administration The Administrator of SBA should take steps to improve the efficiency of data sharing with IRS for the Disaster Loan Program. These steps could include seeking statutory authority for direct access to tax data under section 6103(l) of the Internal Revenue Code or implementing new technologies to reduce manual processing. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
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