What does Preamble of IRS Whistleblower Program Improvement Act do?

This bill amends the Internal Revenue Code of 1986. The bill aims to improve the treatment of whistleblowers.

What does SHORT TITLE; ETC. of IRS Whistleblower Program Improvement Act do?

This Act is formally titled the 'IRS Whistleblower Program Improvement Act'. Amendments within this Act are to be interpreted as references to sections or provisions of the Internal Revenue Code of 1986, unless otherwise specified. For the purposes of this Act, the term 'Secretary' refers to the Secretary of the Treasury or their delegate.

What does STANDARD AND SCOPE OF REVIEW OF WHISTLEBLOWER AWARD of IRS Whistleblower Program Improvement Act do?

This section amends section 7623(b) of the Internal Revenue Code. It changes the process for appealing whistleblower awards to a 'de novo' review by the Tax Court. The Tax Court review will be based on the administrative record and any newly discovered or previously unavailable evidence. The heading of paragraph (4) of section 7623(b) is amended to reflect the change from 'Appeal' to 'Review'. These amendments apply to petitions pending on or filed on or after the date of enactment of this Act.

What does WHISTLEBLOWER PRIVACY PROTECTIONS. of IRS Whistleblower Program Improvement Act do?

This section amends section 7623(b) of the Internal Revenue Code. It allows a whistleblower to elect to proceed anonymously before the Tax Court. The Tax Court may require disclosure of the whistleblower's identity if a societal interest outweighs potential harm to the whistleblower. The amendment applies to petitions pending on or filed after the enactment of this Act.

What does MODIFICATION OF IRS WHISTLEBLOWER REPORT. of IRS Whistleblower Program Improvement Act do?

This section modifies Section 406(c) of division A of the Tax Relief and Health Care Act of 2006. The modification requires reports to include a list and descriptions of the top tax avoidance schemes disclosed by whistleblowers, not exceeding 10 per year. The amendments apply to reports for fiscal years ending after the enactment of this Act.

What does INTEREST ON WHISTLEBLOWER AWARDS. of IRS Whistleblower Program Improvement Act do?

This section amends Section 7623(b) of the Internal Revenue Code to provide for interest on whistleblower awards. Interest accrues on awards if the Secretary has not provided notice of a preliminary award recommendation before the applicable date. The applicable date is 12 months after proceeds from actions subject to the award recommendation have been collected and either the statutory period for filing a claim has expired or the taxpayers and Secretary have agreed to the liabilities. Interest does not accrue after the Secretary provides notice of a preliminary award recommendation. The amendments take effect 180 days after the date of enactment of this Act. If the Secretary has not provided notice and the applicable date has passed as of the enactment date, the applicable date is adjusted to 12 months after the enactment date.

What does CORRECTION REGARDING DEDUCTIONS FOR ATTORNEY'S FEES. of IRS Whistleblower Program Improvement Act do?

This section amends Section 62(a)(21)(A)(i) of the Internal Revenue Code. The amendment strikes '7623(b)' and inserts '7623'. The amendment applies to taxable years ending after the date of enactment of this Act.

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IRS Whistleblower Program Improvement Act

Last updated: 4/28/2026 · Introduced: 3/17/2026

Author: Mike Kelly (R-PA)

TL;DR (AI)

This bill revises the IRS whistleblower program by requiring the Tax Court to conduct a 'de novo' review of whistleblower award appeals, considering new evidence.
The bill allows whistleblowers to remain anonymous in Tax Court proceedings unless a compelling societal interest outweighs the potential harm to the whistleblower.
The IRS must report on the top tax avoidance schemes disclosed by whistleblowers, and whistleblower awards will accrue interest if the IRS does not provide a preliminary award recommendation within a specified timeframe.

119th Congresspassed houseS. 3931(In Committee)Official page

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