Hundreds of thousands of Americans stand to be denied new or renewed passports under a 2015 law requiring the IRS and State Department to deny passports to Americans with more than $51,000 in overdue tax debt.

An IRS spokesman told The Wall Street Journal that as many as 362,000 Americans fall under the category of those with outstanding debt for whom the State Department should deny passport applications or renewals.

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The State Department confirmed separately to the Journal that some passports had already been denied under the enforcement, as the IRS sends the names of those with outstanding debt in batches to the agency.

For now, agency officials stressed that they are just denying applications for new or renewed passports, and were not revoking passports from any Americans with outstanding debt.

The new law's effects are already noticeable, according to an IRS spokesman, who told the Journal that 220 people had handed over $11.5 million to repay their full debts as of late June, while 1,400 others had set up payment plans to reduce their debts.

IRS Division Commissioner Mary Beth Murphy added to the Journal that one debtor in particular had paid $1 million in tax debts specifically to avoid passport denial.

The law contains some exceptions, including for victims of identity theft and those claiming “innocent-spouse” relief or who live in a federally declared disaster zone.

Critics of the plan, including National Taxpayer Advocate Nina Olson, say the notices to debtors often come at the same time the State Department is notified of the taxpayer's debt, in some cases leaving not enough time to resolve tax issues before passport problems occur.