# 119-s-5477: Federal Receivership Fairness Act

119-s-5477, Federal Receivership Fairness Act, is a 119th Congress bill sponsored by Sen. Young, Todd [R-IN] (R-IN); status introduced; PRIA reads it as touching household money (as of 2026-10-10).

- Canonical: https://policyrisk.com/legislation/119-s-5477
- As of: 2026-10-10
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-s-5477
- Congress: 119
- Title: Federal Receivership Fairness Act
- Status: introduced
- Introduced: 2026-09-23
- Sponsor: Sen. Young, Todd [R-IN] (R-IN)
- Cosponsors: 1
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2026-10-10

## Summary

**Gives federal and state-court receivers and the courts that oversee them explicit power to have federal tax liability for a receivership estate decided in court.** It sets how receivers can seek rulings, who can be bound, and key timing limits for IRS review. - Receivers and receivership estates: A court-appointed receiver can ask the court to decide the amount or legality of any federal tax, penalty, or addition to tax by filing a return and a formal determination request. The court cannot decide taxes already contested and adjudicated before the receivership, and it must respect time limits such as 120 days for refund requests and 60/180-day windows tied to IRS examination selection and completion. - IRS, the federal government, and recovery rules: After a court determination the Secretary of the Treasury may assess the tax against the receivership estate, the person or entity in receivership, or successors. The bill narrows sovereign-immunity protections so the Secretary can be brought into these proceedings and so offsets are allowed against the Secretary's claims that are property of the estate. - Courts and scope limits: In state or D.C. receivership cases federal tax determinations must be adjudicated by the U.S. District Court for the district where the proceeding is pending, not by state courts. The law excludes bankruptcy trustees and executors whose tax rights are governed by other law.

## Cosponsors (1)

- Sen. Warner, Mark R. [D-VA] (D-VA), 2026-09-23T00:00:00.000Z

## Provisions PRIA read

- Claim priority rules for receiverships: mixed, low. If enacted, the bill would update federal laws so receivership cases under the new rule are added to the federal declaratory judgment statute and treated like bankruptcy cases for certain priority and claim rules. This would change how courts and claimants sort competing claims and government prior…
- Courts can decide receivership taxes: mixed, low. If enacted, the court that appointed a receiver would be able to decide federal tax amounts, penalties, and additions tied to that receivership. This would apply even if the tax was previously assessed, paid, or contested, subject to exceptions. The rule would not apply to taxes finally decided bef…
- IRS claims in receivership cases: mixed, low. If enacted, after a receivership court decides tax owed, the IRS could assess that tax against the receivership estate, the person or entity in receivership, successors, or entities arising from the receivership, subject to other law. If the IRS asserts a claim in the receivership, it would be trea…
- Receiver filing and timing rules: mixed, low. If enacted, a receiver who asks the IRS to decide unpaid receivership taxes would need to file a tax return and a written request where the IRS says. If the IRS does not select the return for examination within 60 days, paying the tax shown would discharge liability. If the IRS selects the return,…

## Related bills

- 119-s-2975: PIPELINE Safety Act of 2025
- 119-s-1748: Kids Online Safety Act
- 119-s-1541: SHIPS for America Act of 2025
- 119-s-789: Critical Minerals Security Act of 2025
- 119-s-3597: National Quantum Initiative Reauthorization Act of 2026
- 119-s-4943: Outcomes-Based Financing (OBF) for Students Act

## Sources
- [119-s-5477 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/5477)

## Related
- [119-s-2975: PIPELINE Safety Act of 2025](https://policyrisk.com/legislation/119-s-2975)
- [119-s-1748: Kids Online Safety Act](https://policyrisk.com/legislation/119-s-1748)
- [119-s-1541: SHIPS for America Act of 2025](https://policyrisk.com/legislation/119-s-1541)
- [119-s-789: Critical Minerals Security Act of 2025](https://policyrisk.com/legislation/119-s-789)
- [119-s-3597: National Quantum Initiative Reauthorization Act of 2026](https://policyrisk.com/legislation/119-s-3597)
- [119-s-4943: Outcomes-Based Financing (OBF) for Students Act](https://policyrisk.com/legislation/119-s-4943)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-s-5477 (as of 2026-10-10).