The IRS Taxpayer Advocate Service (TAS) has issued a memorandum (TAS-13-0721-0009)[1] which states that TAS will not accept most advance child tax credit (Adv. CTC) cases. The memorandum explains the advance child tax credit provision, found in the American Rescue Plan Act of 2021, as follows:

Section 9611(a) of the American Rescue Plan Act, Public Law 117-2 (2021), signed into law on March 11, 2021, amended Internal Revenue Code (IRC) section 24 to create special rules for the Child Tax Credit (CTC) applicable to only calendar year 2021 and added new IRC section 7527A to provide for periodic advance payments of the CTC to eligible individuals in calendar year 2021. The Adv CTC payments will commence July 15, 2021 and end by December 31, 2021. During this time IRS programming will use tax year 2020 return data (or 2019, if 2020 is not available) to generate monthly payments totaling up to 50 percent of the taxpayer's projected 2021 CTC amount. Taxpayers who have not filed a 2020 or 2019 federal income tax return and do not have a filing requirement can use the “Child Tax Credit Non-filer Sign up Tool” on irs.gov to file a 2020 tax return. Eligible taxpayers who do not want to receive Adv CTC can elect to unenroll to decline the advanced payments using the CTC UP. The CTC UP also allows eligible taxpayers to check enrollment, and future updates will allow taxpayers to change other items such as address, bank information, and life event changes.[2]

The memorandum states:

Under our current IRMs, TAS does not accept cases in which we cannot expedite or improve assistance to taxpayers. Consistent with this guidance, TAS will not accept stand-alone Adv CTC cases.[3]

More specifically, the memorandum provides:

TAS will not accept cases involving stand-alone Adv CTC issues from any source, including congressional offices. Stand-alone Adv CTC issues include, but are not limited to:

Unenrollment
Use of the Non-Filer Sign-up Tool
Adv CTC payment inquiries
IRS Online Account accessibility, such as IRS username, ID.me, etc.[4]

Rather, the TAS expects taxpayers to access other IRS resources, noting:

It is anticipated that IRS phone assistors will be able to help taxpayers make changes to their Adv CTC and the IRS will be rolling out a number of self-help tools over the next six months. The IRS Child Tax Credit Update Portal (CTC UP) allows taxpayers to check if they are enrolled and unenroll. The CTC UP will soon allow taxpayers to change their address or bank information and update information with life events such as adding an additional child or changing their income qualification. At this time, TAS cannot expedite resolution for these issues.[5]

However, this does not mean that cases with other issues that are preventing the taxpayer from receiving the advance child tax credit will not be taken on by the TAS simply due to there being an impact on qualification to receive the advance child tax credit:

TAS will continue to accept cases meeting normal case criteria where the taxpayer is attempting to resolve a problem that is preventing the taxpayer from receiving Adv CTC. During the intake process, employees will review the taxpayer's account in IDRS along with IRM 21.6.3.4.1.24.2, Advance CTC, to determine if there are any Tax Module or Entity conditions that are postponing Adv CTC payments. Generally, resolution of these issues will allow the Adv CTC payments to begin, so in these situations TAS can accept the case to resolve the underlying Tax Module or Entity conditions that will in turn allow the Adv CTC payments. IRS programming will then recompute the monthly payment amounts based on the remaining number of months within the year. These situations are not considered stand-alone Adv CTC cases.[6]

As well, the memorandum notes that TAS may change its position on dealing with stand-alone advance child tax credit cases:

TAS will continue to monitor IRS developments in Adv CTC processing and will re-evaluate this determination as the situation changes.

…

TAS will continue to monitor IRS’s implementation of the Adv CTC. The Deputy National Taxpayer Advocate may modify or rescind this guidance at any time by notifying TAS employees through the issuance of a TAS Welcome Screen article discussing the change in guidance.[7]

[1] TAS-13-0721-0009, “Interim Guidance — Advance Child Tax Credit”, July 2, 2021 (released July 8, 2021), https://www.taxnotes.com/tax-notes-today-federal/credits/tas-not-accepting-most-advance-child-tax-credit-cases/2021/07/08/76rsp (retrieved July 8, 2021, subscription required)

[2] TAS-13-0721-0009, “Interim Guidance — Advance Child Tax Credit”, July 2, 2021

[3] TAS-13-0721-0009, “Interim Guidance — Advance Child Tax Credit”, July 2, 2021

[4] TAS-13-0721-0009, “Interim Guidance — Advance Child Tax Credit”, July 2, 2021

[5] TAS-13-0721-0009, “Interim Guidance — Advance Child Tax Credit”, July 2, 2021

[6] TAS-13-0721-0009, “Interim Guidance — Advance Child Tax Credit”, July 2, 2021

[7] TAS-13-0721-0009, “Interim Guidance — Advance Child Tax Credit”, July 2, 2021