As of October 8, 2025, the IRS has shuttered most operations and furloughed more than 30,000 employees due to the ongoing federal government shutdown.
According to Accounting Today and the official IRS Employee Emergency News, only “excepted and exempt” functions remain active. Primarily data security, criminal enforcement, and core IT infrastructure.
For the title and real estate community, this pause matters. Many FIRPTA-related filings, including Forms 8288, 8288-A, and 8288-B, rely on IRS units that are not currently operating.
The Taxpayer Advocate Service and correspondence functions are also suspended.
In practical terms, that means any withholding submissions, refund requests, or ITIN-linked processing already in the queue will remain in limbo until funding is restored and staff return.
The Treasury contingency plan confirms that just 53.6 % of the IRS workforce (≈ 39,870 employees) are designated as “excepted” or “exempt.” Everyone else is on furlough until further notice.
For closing agents and withholding agents, now’s the time to:
• Document submission and payment dates clearly.
• Communicate early with foreign sellers about expected delays.
• Stay tuned for IRS reopening updates and new processing backlogs.
This is a developing situation with direct implications for FIRPTA compliance, title operations, and year-end closings.
