HIGHLIGHTS: American Rescue Plan Act: Review of the Reconciliation of the Child Tax Credit
Final Audit Report issued on June 14, 2023 Report Number 2023-47-035
The
American Rescue Plan Act
of 2021
provided taxpayers the
ability to receive up to one half of
the estimated Tax Year 2021 Child
Tax Credit in advance payments
between July and December 2021.
The IRS issued 216.9 million
advance payments totaling
$93.5 billion. The IRS estimated
the advance payments based on
prior year tax return information
and information reported through
its nonfiler tools.
This audit was initiated to assess
processes and procedures to
ensure that taxpayers properly
reconciled the advance Child Tax
Credit payments on their Tax
Year 2021 tax return.
Impact on Tax Administration
TIGTA previously reported that the
IRS erroneously issued 3.3 million
advance payments to 1.5 million
taxpayers who were not eligible to
receive an advance payment. The
IRS’s reconciliation process
addressed both potentially
ineligible taxpayers and eligible
taxpayers who had not received
advance payments when they filed
their Tax Year 2021 tax return.
However, our review showed that
as of October 12, 2022,
approximately 4.1 million taxpayers
who were issued about $9 billion
in advance payments had not yet
filed a tax return.
The IRS created an automated process to recalculate the Child Tax
Credit, including the amount of advance payments posted to a
taxpayers’ tax account. This process identified 3.8 million tax returns
that contained a discrepancy between the IRS calculated Child Tax
Credit amount and the amount claimed by the taxpayer that required
resolution. TIGTA’s review of the reconciliation process of tax returns
processed through May 5, 2022, identified:
• 6,833 taxpayers who potentially received $10.5 million in
excess Child Tax Credit because tax examiners incorrectly
resolved error conditions that allowed more Child Tax Credit
than what the taxpayer was eligible to claim on their tax
return.
• 105 taxpayers who did not receive all of their eligible Child Tax
Credit, resulting in the taxpayers not receiving an estimated
$139,000 in Child Tax Credit.
Further, in response to TIGTA’s concerns, the IRS developed a process
to identify undeliverable advance payments that occurred after
taxpayers filed their Tax Year 2021 tax return. As of October 12, 2022,
the IRS reissued payments to 7,877 taxpayers totaling $5.4 million.
What TIGTA Recommended
TIGTA made seven recommendations to the IRS including: identifying
and reviewing the instances where taxpayers received more or less
Child Tax Credit than they were eligible to receive, sending letters to
taxpayers with advance Child Tax Credit payments who have yet to file
a Tax Year 2021 tax return, and creating a process to recover
potentially erroneous advance payments.
The IRS agreed with four of the seven recommendations and partially
agreed with another. The IRS did not agree to identify additional
taxpayers with excess Child Tax Credits or to develop a process to
recover erroneous advance payments on nonfilers. TIGTA continues to
believe that taxpayers received excess Child Tax Credit after the IRS
implemented a programing change and that processes are needed to
recover erroneous advance payments totaling $1 billion.