Public Comment on Application of PRWORA to Certain Federal Refundable Tax Credits

Public Comment submitted to the IRS opposing the new rule that would radically change who can receive vital tax credits, excluding many immigrants who currently work, pay taxes, and meet existing eligibility requirements.

Published Oct 5, 2026

Re: IRS-2026-1057-0001. Comments in Response to: Application of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 to the Refunded Portion of Certain Federal Refundable Tax Credits

The National Immigration Law Center writes to express our strong opposition to the Notice of Proposed Rulemaking, “Application of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 to the Refunded Portion of Certain Federal Refundable Tax Credits” (proposed rule) the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) published in the Federal Register on August 20, 2026.

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