All Roll Calls
Yes: 346 • No: 10
119-hr-7959119th CongressWALLET
IRS Whistleblower Program Improvement Act
Sponsored By: Representative Kelly, Mike [R-PA-16]
Passed House
Summary
Strengthens whistleblower privacy and clarifies how IRS whistleblower awards are reviewed and paid. The law tightens anonymity rules, sets a clearer court review standard, and creates rules for interest when award decisions take a long time.
Show full summary
- Whistleblowers and claimants: Whistleblowers can stay anonymous in Tax Court unless the court finds a strong societal reason to disclose identity. Awards may earn interest for delayed preliminary notices at the IRS overpayment rate. The interest rule takes effect 180 days after enactment and uses a 12‑month timing test tied to collection and final resolution.
- Tax Court and claim process: Tax Court review of award determinations is de novo. Judges consider the original administrative record plus any newly discovered or previously unavailable evidence. This applies to petitions pending or filed on or after enactment.
- IRS reporting and attorneys: The IRS annual whistleblower report must list and describe up to 10 top tax avoidance schemes reported that year. The law also clarifies that attorney fees tied to whistleblower claims are deductible under the whistleblower code reference for taxable years ending after enactment.
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Bill Overview
Analyzed Economic Effects
3 provisions identified: 3 benefits, 0 costs, 0 mixed.
Interest on delayed tax whistleblower awards
The bill would add interest to covered IRS whistleblower awards when the IRS misses the preliminary award notice deadline. That deadline would generally fall 12 months after all related proceeds are collected and refund rights are settled. Refund rights would be settled when the refund-filing period expires, or tax liabilities are finally agreed and refund claims are waived or resolved. Interest would run from the deadline until notice, using the tax overpayment rate under section 6621(a). The change would take effect 180 days after enactment. For cases already past the deadline then without notice, the deadline would reset to 12 months after that effective date.
Stronger court protections for tax whistleblowers
The bill would require the Tax Court to review covered whistleblower award decisions anew. Review would use the original agency record plus newly discovered or previously unavailable evidence. Whistleblowers would be allowed to stay anonymous unless the court finds public interest in disclosure outweighs potential harm to them. These changes would cover petitions pending on enactment day or filed afterward.
Broader legal fee deduction for whistleblowers
The bill would extend the attorney fee deduction to more types of IRS whistleblower awards. The deduction would cover fees tied to awards under the full whistleblower section, not just its mandatory award program. Eligible whistleblowers would subtract covered fees when figuring adjusted gross income. The change would apply to tax years ending after enactment.
Sponsors & CoSponsors
Sponsor
Kelly, Mike [R-PA-16]
PA • R
Cosponsors
Rep. Thompson, Mike [D-CA-4]
CA • D
Sponsored 3/17/2026
Rep. Miller, Carol D. [R-WV-1]
WV • R
Sponsored 3/24/2026
Rep. Buchanan, Vern [R-FL-16]
FL • R
Sponsored 3/24/2026
Rep. Moran, Nathaniel [R-TX-1]
TX • R
Sponsored 3/24/2026
Rep. Smith, Adrian [R-NE-3]
NE • R
Sponsored 3/24/2026
Roll Call Votes
house vote • 4/27/2026
On Motion to Suspend the Rules and Pass, as Amended
Yes: 346 • No: 10