International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Wednesday, October 1, 2014

The IRS' International Collection Efforts Not Up to Par, TIGTA Audit Finds


TigtasealInternational tax noncompliance remains a significant area of concern for the IRS. However, the IRS’s collection efforts need to be enhanced to ensure that delinquent international taxpayers become compliant with their U.S. tax obligations.

TIGTA’s review found that the IRS has not provided effective management oversight to International Collection, which contributed to several control weaknesses in the program.  For example, International Collection does not have:

  • Adequate policies, procedures, position descriptions, or the training needed to ensure that international revenue officers can properly work International Collection cases.
  • A specifc inventory selection process that ensures that the International Collection cases with the highest risk are worked.
  • Performance measures and enforcement results reported separately from Domestic Collection.
  • A process to measure the value of the "Customs Hold" as an enforcement tool.


TIGTA recommended that the IRS: 1) develop a formal International Collection Strategic plan; 2) update International Collection guidance to provide specific policies and procedures to international revenue officers; 3) evaluate and update the current international revenue officer position descriptions; 4) develop a formal International Collection training plan using Subject Matter Experts to develop and teach international specific courses; 5) evaluate the International Collection inventory selection criteria; 6) develop separate performance measures and track specific enforcement results for International Collection; and 7) continue to pursue direct access to the Customs Hold information.

IRS officials agreed with all of TIGTA’s recommendations and have taken or plan to take corrective actions.  However, while the IRS has implemented some corrective actions to improve the selection of international collection inventory, develop separate performance measures, and track enforcement results, TIGTA does not believe that the IRS’s completed corrective actions fully addressed the recommendations.

Link to the The TIGTA IRS Report on International Collection Efforts

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