WHAT THE LAW DOINCongress, in plain words

H.R. 7959 · 119th Congress

IRS Whistleblower Program Improvement Act

Passed HouseTaxation
IntroducedMar 17, 2026
Passed HouseApr 27, 2026
Passed SenateNot yet
To PresidentNot yet
Became lawNot yet

Where it stands

Passed House. Latest step, Apr 28, 2026: Received in the Senate and Read twice and referred to the Committee on Finance. The House passed it 346–10. It would change 2 sections of existing law and would add 1 new provisions of its own.

How this bill changes the law

Sourced

H.R. 7959 would change 2 sections of existing law, and would create 1 new provision of its own. Read from the bill text as sent to the Senate (Apr 28, 2026).

26 U.S.C. 7623 Expenses of detection of underpayments and fraud, etc.

  • (b) Awards to whistleblowers added to · Sec. 2(a), Sec. 2(b), Sec. 3(a), Sec. 5(a) · see the words

26 U.S.C. 62 Adjusted gross income defined

New provisions of the bill's own

  • Sec. 4 Modification of IRS whistleblower report
What the words would change: every change, in place (6)

Today's wording of each part of the law, with what would be struck out and added. Each change also gives the bill's own instruction, word for word.

  1. 26 U.S.C. 7623(b)changedby H.R. 7959 Sec. 2(a)

    …described in the preceding sentence, the Whistleblower Office shall deny any award. (4) Appeal of award determination. Any determination regarding an award under paragraph (1), (2), or (3) may, within 30 days of such determination, be appealed toreviewed by the Tax Court (and the Tax Court shall have jurisdiction with respect to such matter). (5) Application of this subsection. This subsection shall apply with respect to any action— (A) against any taxpayer, but in the case of any…

    The bill says: by striking "appealed to" and inserting "reviewed by", and

    Bill text · Current law (26 U.S.C. 7623)

  2. 26 U.S.C. 7623(b)addedby H.R. 7959 Sec. 2(a)

    The bill says: by adding at the end the following: "Any review by the Tax Court under the preceding sentence shall be de novo and shall be based on the administrative record established at the time of the original determination and any additional newly discovered or previously unavailable evidence.".

    Bill text · Current law (26 U.S.C. 7623)

  3. 26 U.S.C. 7623(b)changedby H.R. 7959 Sec. 2(b)

    …(a)(2), then the Whistleblower Office may appropriately reduce such award. If such individual is convicted of criminal conduct arising from the role described in the preceding sentence, the Whistleblower Office shall deny any award. (4) AppealReview of award determination. Any determination regarding an award under paragraph (1), (2), or (3) may, within 30 days of such determination, be appealed to the Tax Court (and the Tax Court shall have jurisdiction with respect to such matter).…

    The bill says: The heading of paragraph (4) of section 7623(b) is amended by striking "Appeal" and inserting "Review".

    Bill text · Current law (26 U.S.C. 7623)

  4. 26 U.S.C. 7623(b)added (D)by H.R. 7959 Sec. 3(a)

    (D) Whistleblower anonymity before the Tax Court.— Notwithstanding sections 7458 and 7461, a whistleblower may elect to proceed anonymously before the Tax Court for all proceedings under this section absent a finding by the Tax Court that a societal interest exists for disclosing the whistleblower’s identity which exceeds the potential harm disclosure could cause to the whistleblower.

    The bill says: Paragraph (6) of section 7623(b) is amended by adding at the end the following new subparagraph:

    Bill text · Current law (26 U.S.C. 7623)

  5. 26 U.S.C. 7623(b)added (7)by H.R. 7959 Sec. 5(a)

    (7) Interest.—(A) In general.— If the Secretary has not provided notice to an individual described in paragraph (1) of a preliminary award recommendation before the applicable date, the amount of any award under this subsection shall include interest from such date at the overpayment rate under section 6621(a).(B) Exception.— No interest shall accrue under this paragraph after the date on which the Secretary provides notice to the individual of a preliminary award recommendation.(C) Applicable date.— For purposes of this paragraph, the applicable date is the date that is 12 months after the first date on which—(i) all of the proceeds resulting from actions subject to the award recommendation have been collected, and(ii) either—(I) the statutory period for filing a claim or suit for refund has expired, or(II) the taxpayers subject to the actions and the Secretary have agreed with finality to the tax or other liabilities for the periods at issue, and either the taxpayers have waived the right to file a claim or suit for refund or any claim or suit for refund has been resolved.

    The bill says: Section 7623(b) is amended by adding at the end the following new paragraph:

    Bill text · Current law (26 U.S.C. 7623)

  6. 26 U.S.C. 62(a)(21)(A)(i)changedby H.R. 7959 Sec. 6(a)

    The bill says: Section 62(a)(21)(A)(i) is amended by striking "7623(b)" and inserting "7623".

    Bill text · Current law (26 U.S.C. 62)

From the bill's official text on GovInfo and the U.S. Code, 2024 edition, which may not yet show changes made since.

What it does

Sourced

IRS Whistleblower Program Improvement Act

This bill modifies provisions of the Internal Revenue Code relating to whistleblower awards and protections.

Specifically, the bill

• revises 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, and

• requires 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.)

Official summary by the Congressional Research Service (Introduced in House, Mar 17, 2026).

Our plain-language breakdown, with what it means for you and the case for and against, is written once a bill starts to move.

What has happened

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  1. Apr 27, 2026Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by the Yeas and Nays: (2/3 required): 346 - 10 (Roll no. 138). (text: CR H3104) Roll call recordLibrary of Congress
  2. Apr 9, 2026Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-606.Library of Congress
  3. Mar 17, 2026Introduced in HouseLibrary of Congress

Show all 17 recorded actions

Recorded votes

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  1. Apr 27, 2026 · HousePassed 346–10
    On Motion to Suspend the Rules and Pass, as Amended · needed two-thirds
    R 162 yes, 9 noI 1 yes, 0 noD 183 yes, 1 noEach member · Record

Cosponsors

  • Vern Buchanan R-FL-16
  • Carol D. Miller R-WV-1
  • Nathaniel Moran R-TX-1
  • Adrian Smith R-NE-3
  • Mike Thompson D-CA-4