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Tax Strategy: The impact of cuts and the shutdown on the IRS

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Starting with the Inflation Reduction Act in 2022, the Internal Revenue Service started to feel it finally had the resources to start upgrading its antiquated technology systems, beef up enforcement activities to reduce uncollected taxes, and improve customer service.

In 2025, all of that has come to an end.

Between January and May 2025, staffing was reduced from around 103,000 employees to around 77,000, or around 25%. The nearly $80 billion in funding from the Inflation Reduction Act has been gradually reduced to $37.6 billion.

As of this writing, in the face of the federal government shutdown due to lack of approval of a federal budget for the 2026 fiscal year, after maintaining staff for the first week of the shutdown, the IRS has announced the furlough of around 34,000 employees, or about 46% of its current workforce. The IRS intends to use remaining funding from the Inflation Reduction Act to retain 39,878 employees for essential functions.

Although we had known the numbers of reduced staffing, it was not clear what functions were impacted by the reductions. Now, however, the Treasury Inspector General for Tax Administration has released a report dated Oct. 15, 2025, which adds some detail to those numbers. The report is titled “Management and Performance Challenges Facing the IRS for Fiscal Year 2026.”

Reduced workflow and budget

In addition to the reduced Inflation Reduction Act funding, the Fiscal Year 2026 IRS proposed budget lowers annual funding by 20%. The TIGTA report states that the IRS has already spent $13.8 billion (or 37%) of its remaining Inflation Reduction Act funding.

The functions that the IRS has identified that it is trying to maintain during the shutdown are e-filing systems, payment processing, issuance of automatic refunds (especially for direct deposit), testing of tax filing systems for the upcoming tax filing season, processing remittances, and updating tax forms. Sufficient staff is also being maintained to keep technology operating. Automated notices such as collections, intent to levy, and warnings of asset seizures may continue to be issued.

Areas that the IRS has identified as receiving little to no support during the continuing shutdown include in-person and phone contact, audit correspondence, staff associated with enforced collections, the Taxpayer Advocate Service (with only 93 employees retained), paper return processing, payments, and correspondence.

The US Capitol in Washington, DC
The US Capitol in Washington, DC, on Nov. 4, 2025

Pete Kiehart

The Large Business & International Division was estimated to be losing 74% of its staff, the Small Business/Self-Employed Division 67% of its staff, and the Tax-Exempt and Government Entities Division 84% of its staff. The Tax Court at present stated that it was still open for filings but that there were potential cancellations of trial sessions.

The TIGTA report states that the information technology staff has lost 25% of its people. The IRS placed 48 senior IT employees on administrative leave, 26 of whom were in key management positions or were individuals specifically recruited for their expertise in restructuring efforts. The TIGTA report states that half of the IRS’s 700 business systems are legacy systems requiring replacement.

While the IRS has made some progress with individual tax processing systems, it has abandoned some other modernization efforts. The agency is hoping that integrating AI capabilities into its systems may help; however, it still has not adopted cloud computing.

Improving operational efficiencies

The IRS is hoping that the federal government program to eliminate paper checks will help with its efficiency. It is also hoping to automate processing of amended tax returns. Although the agency’s Document Upload Tool permits online responses to mailed notices, the IRS must still print out those responses for review.

Protecting taxpayer data

TIGTA faults the IRS for failure to terminate access to systems by departing employees. New efforts by the Trump administration to expand interagency document sharing have resulted in some instances of the IRS transferring inaccurate data. The IRS was also criticized for careless disposal of sensitive documents.

Implementing tax law changes

TIGTA stated that the IRS had assessed an estimated $591 million in penalties and interest on 403,711 tax accounts for employers who failed to timely pay their deferred Social Security taxes. The IRS computers also were incorrectly rejecting tax returns claiming the Clean Vehicle Credit, largely due to late submissions by dealers.

TIGTA stated that it reviewed nearly 1,000 tax returns with signs of potential identity theft involving recovery of erroneously paid Employee Retention Credits. The IRS was also developing a strategy to try to effectively remove certain tax benefits from noncitizens.

While the IRS has made some progress in addressing virtual currencies and high-income nonfilers, it has yet to take enforcement action against an estimated 150,000 individuals with $13.2 billion in gambling winnings and tax debts of $1 billion in taxes, interest and penalties who failed to file tax returns. The agency also continues to struggle with challenging fact situations involving refundable tax credits such as the Additional Child Tax Credit, the Earned Income Tax Credit, the American Opportunity Tax Credit, and the new Premium Tax Credit.

Depending on how long the shutdown lasts, the IRS may be unable to finalize 2025 forms, instructions and publications in time for a normal start to the 2026 tax filing season.

Taxpayer services and rights

TIGTA found that the recent positive IRS statistics on telephone responses and wait times only included the most utilized phone lines and did not include many other phone lines with less favorable statistics. The IRS decided to discontinue self-service kiosks at Taxpayer Assistance Centers after finding that nearly one-half were inoperable. And it is trying to use voicebots to try to reduce wait times and to develop some of the artificial intelligence tools used by private collection agencies.

Impact on taxpayers

While the government is shut down, obligations of taxpayers under the tax law remain. In general, filing deadlines remain in effect. Interest and penalties continue to accrue on unpaid balances due.

Often the IRS has delayed the start of tax filing season, such as during COVID, when the agency was also shut down, or to allow it to reflect last-minute legislative changes at the end of the tax year, or due to federally declared natural disasters for the areas affected by those disasters.

It is possible that, as this shutdown continues, it could result in a later-than-normal start to the 2026 tax filing season. After some initial hints that the tax filing season would be delayed due to efforts to incorporate the One Big Beautiful Bill Act, those indications were superseded by an announcement that the date of the start of the tax filing season has not yet been set.

Tax planning

Taxpayers should assume all tax deadlines remain in effect unless specially announced otherwise. To ensure timely processing of tax returns and receipt of refunds, taxpayers should file electronically and set up for direct deposit of any tax refunds. Any need for human intervention will delay the processing and any refund.

It is possible that IRS online accounts may not continue to be accessible during the shutdown. Taxpayers should create documentation for all communications and submissions to establish timely compliance.

If taxpayers need action taken by the IRS, such as transcripts and powers of attorney, they should make those requests as soon as possible in anticipation of possible further deterioration of IRS support.

They should try to structure any direct deposit installment agreements online without the need for IRS approval.

Taxpayers and tax professionals should expect more delayed responses to notices, refund processing, and audit resolutions.

Taxpayers should try to make any required statutory payments online. They may wish to consider making other tax payments as well, even for items in dispute, to cut off the continued accumulation of interest and penalties should the IRS ultimately win on the disputed issues.

Should the shutdown continue for some time — as seemed possible as we went to press — it is also likely that the issues discussed above will continue for some period of time after the shutdown ends. Following the COVID shutdown, the IRS required many months to get through the stacks of correspondence that had accumulated unread. Especially with a reduced staff, taxpayers should anticipate the possibility that these slowdowns will continue for a period of time somewhat in proportion to the period of the shutdown.

Summary

Hopefully, by the time that this column is being read, the shutdown will be over and many of the furloughed IRS employees will have returned to work.

It is still likely, however, that the effects of the reduced staff, reduced funding, and the shutdown will be felt during the 2026 tax filing season and perhaps beyond.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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