The IRS said it would not apply the deadline to new requests or those currently under consideration. Those whose requests were denied based on the expiration of the period may reapply via IRS Form 8857 if the collection statute of limitations for the tax years involved has not expired. The agency will also apply the new rule to cases in suspense and it will not impose the limit in any pending litigation involving equitable relief. Where litigation is final, the agency will suspend collection action under certain circumstances

Moe policy and program changes will be implemented in the fall with additional guidance to be given. Regulations will be issued to formally end the two-year limit.