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9.3 STATUS OF THE 42 OPERATING DIVISION PROVISIONS

0121 Publ 5426 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States

The TFAO took primary responsibility for the three TFA provisions addressed in this report:

  • Comprehensive Taxpayer Experience Strategy (TFA §1101)

  • Comprehensive Training Strategy (TFA §2402)

  • Modernization of IRS Organizational Structure (TFA §1302)

In addition to developing these three strategies, the TFAO coordinated with offices across the IRS to oversee the implementation of the other 42 provisions of the Act. Table 9.3.1 explains how we measured the status of the 42 Operating Division provisions of the TFA. Table 9.3.2 summarizes each of these provisions and their status.

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The COVID-19 pandemic has delayed the implementation of some of these provisions, including this report. The delivery of the following provisions were impacted:

  • On April 17th, 2020, the IRS notified The Senate Finance and House Ways and Means

Committees the following provisions, planned for delivery in July 2020 would need to be delayed until December of that same year.

  • Section 1101 – Comprehensive Taxpayer Experience Strategy

  • Section 2402 – Comprehensive Training Strategy

  • Section 1302 – Modernization of IRS Organizational Structure

  • As of December 2020, the IRS was on track to timely implement the vast majority of TFA

provisions. Nonetheless, disruptions due to the COVID-19 pandemic or other constraints have posed challenges for fully implementing the following TFA provisions by the statutory due dates noted below in parentheses. We will continue to work on these provisions to ensure their complete implementation.

  • Section 1205, which prohibits the IRS from using private collection agencies

to recover delinquent taxes from individuals whose income is substantially all supplemental security income benefits or disability insurance benefit payments or individuals whose adjusted gross income is below 200% of the poverty level. (Original delivery date: December 31, 2020).

  • Section 2008, which requires the IRS to develop and implement case management

guidelines to reduce taxpayer burden for stolen identity refund fraud cases within one year of enactment of the TFA (Original delivery date: July 1, 2020).

  • Section 2302, which requires the IRS to publish guidance establishing uniform

standards and procedures for accepting electronic signatures for disclosure and other authorizations for practitioners within six months of enactment of the TFA (Original delivery date: January 1, 2020).

  • Section 2304, which requires the IRS to authenticate users of electronic services

accounts beginning 180 days after the date of enactment of the TFA (Original delivery date: January 1, 2020).

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