S4639119th CongressWALLET

IRS Whistleblower Program Improvement Act

Sponsored By: Senator Grassley, Chuck [R-IA]

Introduced

Summary

Strengthen protections and pay whistleblowers who expose tax wrongdoing. This bill would expand anonymity in Tax Court, change how courts review award decisions, exempt awards from sequestration, add interest when payments are delayed, and update IRS reporting and fee rules.

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  • Would let whistleblowers proceed anonymously in Tax Court unless the court finds a societal interest in disclosure that outweighs harm. It would also make Tax Court review de novo based on the administrative record and allow newly discovered evidence.
  • Would exempt whistleblower awards from any sequestration reductions and require interest to accrue if the IRS does not issue a preliminary award notice within 12 months after all proceeds are collected and liabilities are final, with interest at the IRS overpayment rate.
  • Would make the IRS annual whistleblower report include a list and descriptions of up to 10 top tax-avoidance schemes disclosed by whistleblowers. It would also correct a tax-code cross-reference so attorney fee deductions apply to awards under section 7623.

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Bill Overview

Analyzed Economic Effects

4 provisions identified: 4 benefits, 0 costs, 0 mixed.

Attorney fee deduction for whistleblowers

This bill would change an Internal Revenue Code cross-reference so attorney fees tied to whistleblower claims are treated under section 7623 rather than only 7623(b). If enacted, this could let taxpayers who paid lawyers for whistleblower claims take an above-the-line deduction for those fees. The change would apply to tax years ending after enactment.

Stronger Tax Court protections for whistleblowers

This bill would change how Tax Court reviews whistleblower award cases. The court would review these cases de novo using the original administrative record and could consider newly discovered evidence. Whistleblowers could proceed anonymously in Tax Court unless the court finds a stronger public interest in disclosure. These rules would apply to petitions pending or filed on or after enactment.

Better payment protections for whistleblowers

This bill would add two protections for whistleblower awards. First, if the IRS delays notice of a preliminary award past an "applicable date," the award would earn interest from that date at the IRS overpayment rate; interest would stop once the IRS gives notice. The applicable date is generally 12 months after collection and final resolution of refund or liability issues, and the rule would take effect 180 days after enactment (with a special catch-up rule). Second, whistleblower awards would be exempt from reductions under any future federal sequestration order issued after enactment.

IRS report on top tax schemes

This bill would require the IRS annual whistleblower report to include a list and short descriptions of the top tax avoidance schemes disclosed by whistleblowers each year. The list could include up to 10 schemes. The rule would apply to reports for fiscal years ending after enactment.

Sponsors & CoSponsors

Sponsor

Grassley, Chuck [R-IA]

IA • R

Cosponsors

  • Sen. Wyden, Ron [D-OR]

    OR • D

    Sponsored 5/21/2026

  • Sen. Collins, Susan M. [R-ME]

    ME • R

    Sponsored 6/1/2026

  • Sen. Hassan, Margaret Wood [D-NH]

    NH • D

    Sponsored 6/1/2026

Roll Call Votes

No roll call votes available for this bill.

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