This bill changes several rules for the IRS whistleblower program. It requires Tax Court review of award decisions to be de novo and based on the administrative record plus any newly discovered or previously unavailable evidence. It lets whistleblowers remain anonymous in Tax Court unless the Court finds a stronger societal interest in disclosure than the harm to the whistleblower. The IRS annual whistleblower report must list and describe up to 10 top tax avoidance schemes disclosed by whistleblowers. The bill adds a rule that whistleblower awards may include interest at the overpayment rate from a defined “applicable date” when collections and finality conditions are met, with interest stopping once the IRS gives notice of a preliminary award recommendation. It also corrects a cross-reference so an attorney’s-fee deduction provision points to section 7623 instead of 7623(b).
The bill sets different effective dates for its provisions: the Tax Court review and anonymity rules apply to petitions pending on or filed on or after enactment; the reporting change applies to fiscal years ending after enactment; the interest rule takes effect 180 days after enactment with a special rule for certain pending matters; the attorney-fee correction applies to taxable years ending after enactment.
No publicly available information about costs, spending, or budgetary effects is included in the bill text.
No publicly available information about supporters' stated reasons or arguments is included in the bill text.
No publicly available information about opponents' stated reasons or arguments is included in the bill text.