IRS Shutdown: What’s Next?
October 9, 2025As of October 8, 2025, the IRS has closed "most" operations and furloughed "non-core" employees. However, the IRS shutdown does not extend or otherwise affect any taxpayer-side deadline or compliance obligation. So, for example, taxpayers should file their income tax returns, pay estimated taxes and make any necessary elections (such as "S" and "Section 83(b)" elections) as required under existing guidelines.
The shutdown's collateral damage to "non-core" IRS functions remains to be seen. Online services are expected to remain available, including online return filing, transcript requests and EIN applications (except as noted below). However, taxpayers should anticipate delays in any "non-core" action requiring significant input from an IRS employee, such as resolving any audit, seeking a private letter ruling, obtaining "501(c)(3)" tax-exempt status or requesting late filing relief.
In particular, additional time may be required to get an EIN for a foreign-owned or foreign-controlled entity when the online EIN application process cannot be used (for example, when no U.S. individual is available or willing to sign the online EIN application). Even when the IRS reopens for business, service delays are likely to persist until the IRS can work its way through any backlog accumulated during the shutdown period.
If you have any questions or need additional guidance, please reach out to our Tax Department.
Louis Tuchman at +1 212 592 1490 or [email protected]
Mark A. Limardo at +1 212 592 1494 or [email protected]
Michael H. Kessel at +1 212 592 1502 or [email protected]
Fred R. Green at +1 212 592 5910 or [email protected]
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