The IRS whistleblower program rewards people who report tax cheating, but whistleblowers have long complained the program runs slowly and gives them little recourse when the IRS lowballs an award. This bill makes five changes: it lets the Tax Court fully re-examine award decisions instead of deferring to the IRS, lets whistleblowers stay anonymous in court unless a judge finds a strong public reason to name them, requires the IRS's annual report to list the top 10 tax avoidance schemes whistleblowers exposed, adds interest on awards the IRS sits on for more than a year after collection, and fixes a cross-reference so attorney's fees stay deductible. The changes mostly affect tax whistleblowers, their lawyers, and IRS administrators handling these cases.
Transparency & Accountability
- Tax Court review standard — Changed to de novo review with newly discovered evidence allowed
- Whistleblower anonymity — Election to proceed anonymously in Tax Court added
- Annual whistleblower report — Must now list top 10 tax avoidance schemes disclosed
- Whistleblower award interest — Accrues if IRS delays preliminary recommendation past 12 months
Congressional Summary
IRS Whistleblower Program Improvement ActThis bill modifies provisions of the Internal Revenue Code relating to whistleblower awards and protections.Specifically, the billrevises the standard for review of whistleblower awards in the Tax Court to require a de novo review (rather than the current abuse of discretion review) based on the administrative record established at the time of the whistleblower award determination and any new or previously unavailable evidence,allows whistleblowers anonymity in proceedings before the Tax Court (unless a societal interest in disclosing a whistleblower's identity outweighs potential harm to the whistleblower),modifies the Internal Revenue Service (IRS) whistleblower report to require inclusion of a list and description of up to 10 of the top tax avoidance schemes disclosed by whistleblowers, andrequires payment of interest on mandatory whistleblower awards if the IRS fails to provide timely notice to a whistleblower of an award recommendation.The bill also allows payments of the attorney fees of whistleblowers to be deducted when calculating adjusted gross income for tax purposes regardless of whether the whistleblower award was paid through the mandatory or the discretionary whistleblower award program. (Under current law, the deduction is limited to attorney fees paid in connection with mandatory awards.)
Legislative Subjects
Details
- Congress
- 119th
- Chamber
- House
- Status
- summarized
- Action
- Received in the Senate and Read twice and referred to the Committee on Finance.
- Action Date
- 2026-04-28
- Date Added
- 2026-04-23
- Source
- Congress.gov →
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