SECTION 1. SHORT TITLE; ETC. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Taxpayer First Act of 2018’’. 
(b) AMENDMENT OF 1986 CODE.—Except as other-
wise expressly provided, whenever in this Act an amend-
ment or repeal is expressed in terms of an amendment 
to, or repeal of, a section or other provision, the reference 
shall be considered to be made to a section or other provi-
sion of the Internal Revenue Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents for 
this Act is as follows: 
Sec. 1. Short title; etc. 
TITLE I—PUTTING TAXPAYERS FIRST 
Subtitle A—Independent Appeals Process 
Sec. 1001. Establishment of Internal Revenue Service Independent Office of 
Appeals. 
Subtitle B—Improved Service 
Sec. 1101. Comprehensive customer service strategy. 
Sec. 1102. IRS Free File Program. 
Sec. 1103. Low-income exception for payments otherwise required in connection 
with a submission of an offer-in-compromise. 
Subtitle C—Sensible Enforcement 
Sec. 1201. Internal Revenue Service seizure requirements with respect to struc-
turing transactions. 
Sec. 1202. Exclusion of interest received in action to recover property seized by 
the Internal Revenue Service based on structuring transaction. 
Sec. 1203. Clarification of equitable relief from joint liability. 
Sec. 1204. Modification of procedures for issuance of third-party summons. 
Sec. 1205. Private debt collection and special compliance personnel program. 
Sec. 1206. Reform of notice of contact of third parties. 
Sec. 1207. Modification of authority to issue designated summons. 
Sec. 1208. Limitation on access of non-Internal Revenue Service employees to 
returns and return information. 
Subtitle D—Organizational Modernization 
Sec. 1301. Office of the National Taxpayer Advocate. 
Sec. 1302. Modernization of Internal Revenue Service organizational structure.
Subtitle E—Other Provisions 
Sec. 1401. Return preparation programs for applicable taxpayers. 
Sec. 1402. Provision of information regarding low-income taxpayer clinics. 
Sec. 1403. Notice from IRS regarding closure of taxpayer assistance centers. 
Sec. 1404. Rules for seizure and sale of perishable goods restricted to only per-
ishable goods. 
Sec. 1405. Whistleblower reforms. 
Sec. 1406. Customer service information. 
Sec. 1407. Misdirected tax refund deposits. 
TITLE II—21ST CENTURY IRS 
Subtitle A—Cybersecurity and Identity Protection 
Sec. 2001. Public-private partnership to address identity theft refund fraud. 
Sec. 2002. Recommendations of Electronic Tax Administration Advisory Com-
mittee regarding identity theft refund fraud. 
Sec. 2003. Information sharing and analysis center. 
Sec. 2004. Compliance by contractors with confidentiality safeguards. 
Sec. 2005. Report on electronic payments. 
Sec. 2006. Identity protection personal identification numbers. 
Sec. 2007. Single point of contact for tax-related identity theft victims. 
Sec. 2008. Notification of suspected identity theft. 
Sec. 2009. Guidelines for stolen identity refund fraud cases. 
Sec. 2010. Increased penalty for improper disclosure or use of information by 
preparers of returns. 
Subtitle B—Development of Information Technology 
Sec. 2101. Management of Internal Revenue Service information technology. 
Sec. 2102. Internet platform for Form 1099 filings. 
Sec. 2103. Streamlined critical pay authority for information technology posi-
tions. 
Subtitle C—Modernization of Consent-Based Income Verification System 
Sec. 2201. Disclosure 
of 
taxpayer 
information 
for 
third-party 
income 
verification. 
Sec. 2202. Limit redisclosures and uses of consent-based disclosures of tax re-
turn information. 
Subtitle D—Expanded Use of Electronic Systems 
Sec. 2301. Electronic filing of returns. 
Sec. 2302. Uniform standards for the use of electronic signatures for disclosure 
authorizations to, and other authorizations of, practitioners. 
Sec. 2303. Payment of taxes by debit and credit cards. 
Sec. 2304. Requirement that electronically prepared paper returns include scan-
nable code. 
Sec. 2305. Authentication of users of electronic services accounts. 
Subtitle E—Other Provisions 
Sec. 2401. Repeal of provision regarding certain tax compliance procedures and 
reports. 
Sec. 2402. Comprehensive training strategy.
TITLE III—MISCELLANEOUS PROVISIONS 
Subtitle A—Reform of Laws Governing Internal Revenue Service Employees 
Sec. 3001. Electronic record retention. 
Sec. 3002. Prohibition on rehiring any employee of the Internal Revenue Serv-
ice who was involuntarily separated from service for mis-
conduct. 
Sec. 3003. Notification of unauthorized inspection or disclosure of returns and 
return information. 
Subtitle B—Provisions Relating to Exempt Organizations 
Sec. 3101. Mandatory e-filing by exempt organizations. 
Sec. 3102. Notice required before revocation of tax exempt status for failure to 
file return. 
Subtitle C—Tax Court 
Sec. 3301. Disqualification of judge or magistrate judge of the Tax Court. 
Sec. 3302. Opinions and judgments. 
Sec. 3303. Title of special trial judge changed to magistrate judge of the Tax 
Court. 
Sec. 3304. Repeal of deadwood related to Board of Tax Appeals. 
TITLE I—PUTTING TAXPAYERS 
FIRST 
Subtitle A—Independent Appeals 
Process 
SEC. 1001. ESTABLISHMENT OF INTERNAL REVENUE SERV-
ICE INDEPENDENT OFFICE OF APPEALS. 
(a) IN GENERAL.—Section 7803 is amended by add-
ing at the end the following new subsection: 
‘‘(e) INDEPENDENT OFFICE OF APPEALS.— 
‘‘(1) ESTABLISHMENT.—There is established in 
the Internal Revenue Service an office to be known 
as the ‘Internal Revenue Service Independent Office 
of Appeals’. 
‘‘(2) CHIEF OF APPEALS.—
‘‘(A) IN GENERAL.—The Internal Revenue 
Service Independent Office of Appeals shall be 
under the supervision and direction of an offi-
cial to be known as the ‘Chief of Appeals’. The 
Chief of Appeals shall report directly to the 
Commissioner of the Internal Revenue Service 
and shall be entitled to compensation at the 
same rate as the highest rate of basic pay es-
tablished for the Senior Executive Service under 
section 5382 of title 5, United States Code. 
‘‘(B) APPOINTMENT.—The Chief of Ap-
peals shall be appointed by the Commissioner of 
the Internal Revenue Service without regard to 
the provisions of title 5, United States Code, re-
lating to appointments in the competitive serv-
ice or the Senior Executive Service. 
‘‘(C) QUALIFICATIONS.—An individual ap-
pointed under subparagraph (B) shall have ex-
perience and expertise in— 
‘‘(i) administration of, and compliance 
with, Federal tax laws, 
‘‘(ii) a broad range of compliance 
cases, and 
‘‘(iii) management of large service or-
ganizations.
‘‘(3) PURPOSES AND DUTIES OF OFFICE.—It 
shall be the function of the Internal Revenue Service 
Independent Office of Appeals to resolve Federal tax 
controversies without litigation on a basis which— 
‘‘(A) is fair and impartial to both the Gov-
ernment and the taxpayer, 
‘‘(B) promotes a consistent application and 
interpretation of, and voluntary compliance 
with, the Federal tax laws, and 
‘‘(C) enhances public confidence in the in-
tegrity and efficiency of the Internal Revenue 
Service. 
‘‘(4) RIGHT OF APPEAL.—The resolution proc-
ess described in paragraph (3) shall be generally 
available to all taxpayers. 
‘‘(5) LIMITATION ON DESIGNATION OF CASES 
AS NOT ELIGIBLE FOR REFERRAL TO INDEPENDENT 
OFFICE OF APPEALS.— 
‘‘(A) IN GENERAL.—If any taxpayer which 
is in receipt of a notice of deficiency authorized 
under section 6212 requests referral to the In-
ternal Revenue Service Independent Office of 
Appeals and such request is denied, the Com-
missioner of the Internal Revenue Service shall 
provide such taxpayer a written notice which—
‘‘(i) provides a detailed description of 
the facts involved, the basis for the deci-
sion to deny the request, and a detailed ex-
planation of how the basis of such decision 
applies to such facts, and 
‘‘(ii) describes the procedures pre-
scribed under subparagraph (C) for pro-
testing the decision to deny the request. 
‘‘(B) REPORT TO CONGRESS.—The Com-
missioner of the Internal Revenue Service shall 
submit a written report to Congress on an an-
nual basis which includes the number of re-
quests described in subparagraph (A) which 
were denied and the reasons (described by cat-
egory) that such requests were denied. 
‘‘(C) PROCEDURES FOR PROTESTING DE-
NIAL OF REQUEST.—The Commissioner of the 
Internal Revenue Service shall prescribe proce-
dures for protesting to the Commissioner of the 
Internal Revenue Service a denial of a request 
described in subparagraph (A). 
‘‘(D) NOT APPLICABLE TO FRIVOLOUS PO-
SITIONS.—This paragraph shall not apply to a 
request for referral to the Internal Revenue 
Service Independent Office of Appeals which is
denied on the basis that the issue involved is a 
frivolous position (within the meaning of section 
6702(c)). 
‘‘(6) STAFF.— 
‘‘(A) IN GENERAL.—All personnel in the 
Internal Revenue Service Independent Office of 
Appeals shall report to the Chief of Appeals. 
‘‘(B) ACCESS
TO
STAFF
OF
OFFICE
OF 
THE CHIEF COUNSEL.—The Chief of Appeals 
shall have authority to obtain legal assistance 
and advice from the staff of the Office of the 
Chief Counsel. The Chief Counsel shall ensure 
that such assistance and advice is provided by 
staff of the Office of the Chief Counsel who 
were not involved in the case with respect to 
which such assistance and advice is sought and 
who are not involved in preparing such case for 
litigation. 
‘‘(7) ACCESS TO CASE FILES.— 
‘‘(A) IN GENERAL.—In any case in which 
a conference with the Internal Revenue Service 
Independent Office of Appeals has been sched-
uled upon request of a specified taxpayer, the 
Chief of Appeals shall ensure that such tax-
payer is provided access to the nonprivileged
portions of the case file on record regarding the 
disputed issues (other than documents provided 
by the taxpayer to the Internal Revenue Serv-
ice) not later than 10 days before the date of 
such conference. 
‘‘(B) TAXPAYER ELECTION TO EXPEDITE 
CONFERENCE.—If the taxpayer so elects, sub-
paragraph (A) shall be applied by substituting 
‘the date of such conference’ for ‘10 days before 
the date of such conference’. 
‘‘(C) SPECIFIED
TAXPAYER.—For pur-
poses of this paragraph— 
‘‘(i) IN GENERAL.—The term ‘speci-
fied taxpayer’ means— 
‘‘(I) in the case of any taxpayer 
who is a natural person, a taxpayer 
whose adjusted gross income does not 
exceed $400,000 for the taxable year 
to which the dispute relates, and 
‘‘(II) in the case of any other 
taxpayer, a taxpayer whose gross re-
ceipts do not exceed $5,000,000 for 
the taxable year to which the dispute 
relates.
‘‘(ii) 
AGGREGATION
RULE.—Rules 
similar to the rules of section 448(c)(2) 
shall apply for purposes of clause (i)(II).’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The following provisions are each amended 
by striking ‘‘Internal Revenue Service Office of Ap-
peals’’ and inserting ‘‘Internal Revenue Service 
Independent Office of Appeals’’: 
(A) Section 6015(c)(4)(B)(ii)(I). 
(B) Section 6320(b)(1). 
(C) Subsections (b)(1) and (d)(3) of sec-
tion 6330. 
(D) Section 6603(d)(3)(B). 
(E) Section 6621(c)(2)(A)(i). 
(F) Section 7122(e)(2). 
(G) Subsections (a), (b)(1), (b)(2), and 
(c)(1) of section 7123. 
(H) Subsections (c)(7)(B)(i), and (g)(2)(A) 
of section 7430. 
(I) Section 7522(b)(3). 
(J) Section 7612(c)(2)(A). 
(2) Section 7430(c)(2) is amended by striking 
‘‘Internal Revenue Service Office of Appeals’’ each 
place it appears and inserting ‘‘Internal Revenue 
Service Independent Office of Appeals’’.
(3) The heading of section 6330(d)(3) is 
amended by inserting ‘‘INDEPENDENT’’ after ‘‘IRS’’. 
(c) OTHER REFERENCES.—Any reference in any pro-
vision of law, or regulation or other guidance, to the Inter-
nal Revenue Service Office of Appeals shall be treated as 
a reference to the Internal Revenue Service Independent 
Office of Appeals. 
(d) SAVINGS PROVISIONS.—Rules similar to the rules 
of paragraphs (2) through (6) of section 1001(b) of the 
Internal Revenue Service Restructuring and Reform Act 
of 1998 shall apply for purposes of this section (and the 
amendments made by this section). 
(e) EFFECTIVE DATE.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall take effect on the date of the en-
actment of this Act. 
(2) 
ACCESS
TO
CASE
FILES.—Section 
7803(e)(7) of the Internal Revenue Code of 1986, as 
added by subsection (a), shall apply to conferences 
occurring after the date which is 1 year after the 
date of the enactment of this Act.
Subtitle B—Improved Service 
SEC. 1101. COMPREHENSIVE CUSTOMER SERVICE STRAT-
EGY. 
(a) IN GENERAL.—Not later than the date which is 
1 year after the date of the enactment of this Act, the 
Secretary of the Treasury shall submit to Congress a writ-
ten comprehensive customer service strategy for the Inter-
nal Revenue Service. Such strategy shall include— 
(1) a plan to provide assistance to taxpayers 
that is secure, designed to meet reasonable taxpayer 
expectations, and adopts appropriate best practices 
of customer service provided in the private sector, 
including online services, telephone call back serv-
ices, and training of employees providing customer 
services; 
(2) a thorough assessment of the services that 
the Internal Revenue Service can co-locate with 
other Federal services or offer as self-service op-
tions; 
(3) proposals to improve Internal Revenue Serv-
ice customer service in the short term (the current 
and following fiscal year), medium term (approxi-
mately 3 to 5 fiscal years), and long term (approxi-
mately 10 fiscal years);
(4) a plan to update guidance and training ma-
terials for customer service employees of the Internal 
Revenue Service, including the Internal Revenue 
Manual, to reflect such strategy; and 
(5) identified metrics and benchmarks for quan-
titatively measuring the progress of the Internal 
Revenue Service in implementing such strategy. 
(b) UPDATED GUIDANCE
AND TRAINING MATE-
RIALS.—Not later than 2 years after the date of the enact-
ment of this Act, the Secretary of the Treasury (or the 
Secretary’s delegate) shall make available the updated 
guidance and training materials described in subsection 
(a)(4) (including the Internal Revenue Manual). Such up-
dated guidance and training materials (including the In-
ternal Revenue Manual) shall be written in a manner so 
as to be easily understood by customer service employees 
of the Internal Revenue Service and shall provide clear 
instructions. 
SEC. 1102. IRS FREE FILE PROGRAM. 
(a) IN GENERAL.— 
(1) The Secretary of the Treasury, or the Sec-
retary’s delegate, shall continue to operate the IRS 
Free File Program as established by the Internal 
Revenue Service and published in the Federal Reg-
ister on November 4, 2002 (67 Fed. Reg. 67247),
including any subsequent agreements and governing 
rules established pursuant thereto. 
(2) The IRS Free File Program shall continue 
to provide free commercial-type online individual in-
come tax preparation and electronic filing services to 
the lowest 70 percent of taxpayers by adjusted gross 
income. The number of taxpayers eligible to receive 
such services each year shall be calculated by the In-
ternal Revenue Service annually based on prior year 
aggregate taxpayer adjusted gross income data. 
(3) In addition to the services described in 
paragraph (2), and in the same manner, the IRS 
Free File Program shall continue to make available 
to all taxpayers (without regard to income) a basic, 
online electronic fillable forms utility. 
(4) The IRS Free File Program shall continue 
to work cooperatively with the private sector to pro-
vide the free individual income tax preparation and 
the electronic filing services described in paragraphs 
(2) and (3). 
(5) The IRS Free File Program shall work co-
operatively with State government agencies to en-
hance and expand the use of the program to provide 
needed benefits to the taxpayer while reducing the 
cost of processing returns.
(b) INNOVATIONS.—The Secretary of the Treasury, 
or the Secretary’s delegate, shall work with the private 
sector through the IRS Free File Program to identify and 
implement, consistent with applicable law, innovative new 
program features to improve and simplify the taxpayer’s 
experience with completing and filing individual income 
tax returns through voluntary compliance. 
SEC. 1103. LOW-INCOME EXCEPTION FOR PAYMENTS OTH-
ERWISE REQUIRED IN CONNECTION WITH A 
SUBMISSION OF AN OFFER-IN-COMPROMISE. 
(a) IN GENERAL.—Section 7122(c) is amended by 
adding at the end the following new paragraph: 
‘‘(3) 
EXCEPTION
FOR
LOW-INCOME
TAX-
PAYERS.—Paragraph (1), and any user fee otherwise 
required in connection with the submission of an 
offer-in-compromise, shall not apply to any offer-in- 
compromise with respect to a taxpayer who is an in-
dividual with adjusted gross income, as determined 
for the most recent taxable year for which such in-
formation is available, which does not exceed 250 
percent of the applicable poverty level (as deter-
mined by the Secretary).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to offers-in-compromise submitted 
after the date of the enactment of this Act.
Subtitle C—Sensible Enforcement 
SEC. 1201. INTERNAL REVENUE SERVICE SEIZURE RE-
QUIREMENTS 
WITH 
RESPECT 
TO 
STRUC-
TURING TRANSACTIONS. 
Section 5317(c)(2) of title 31, United States Code, 
is amended— 
(1) by striking ‘‘Any property’’ and inserting 
the following: 
‘‘(A) IN GENERAL.—Any property’’; and 
(2) by adding at the end the following: 
‘‘(B) INTERNAL
REVENUE
SERVICE
SEI-
ZURE
REQUIREMENTS
WITH
RESPECT
TO 
STRUCTURING TRANSACTIONS.— 
‘‘(i) PROPERTY DERIVED FROM AN IL-
LEGAL
SOURCE.—Property may only be 
seized by the Internal Revenue Service 
pursuant to subparagraph (A) by reason of 
a claimed violation of section 5324 if the 
property to be seized was derived from an 
illegal source or the funds were structured 
for the purpose of concealing the violation 
of a criminal law or regulation other than 
section 5324. 
‘‘(ii) NOTICE.—Not later than 30 
days after property is seized by the Inter-
nal Revenue Service pursuant to subpara-
graph (A), the Internal Revenue Service 
shall— 
‘‘(I) make a good faith effort to 
find all persons with an ownership in-
terest in such property; and 
‘‘(II) provide each such person so 
found with a notice of the seizure and 
of the person’s rights under clause 
(iv). 
‘‘(iii) EXTENSION OF NOTICE UNDER 
CERTAIN
CIRCUMSTANCES.—The Internal 
Revenue Service may apply to a court of 
competent jurisdiction for one 30-day ex-
tension of the notice requirement under 
clause (ii) if the Internal Revenue Service 
can establish probable cause of an immi-
nent threat to national security or personal 
safety necessitating such extension. 
‘‘(iv) POST-SEIZURE
HEARING.—If a 
person with an ownership interest in prop-
erty seized pursuant to subparagraph (A) 
by the Internal Revenue Service requests a 
hearing by a court of competent jurisdic-
tion within 30 days after the date on which
notice is provided under subclause (ii), 
such property shall be returned unless the 
court holds an adversarial hearing and 
finds within 30 days of such request (or 
such longer period as the court may pro-
vide, but only on request of an interested 
party) that there is probable cause to be-
lieve that there is a violation of section 
5324 involving such property and probable 
cause to believe that the property to be 
seized was derived from an illegal source or 
the funds were structured for the purpose 
of concealing the violation of a criminal 
law or regulation other than section 
5324.’’. 
SEC. 1202. EXCLUSION OF INTEREST RECEIVED IN ACTION 
TO RECOVER PROPERTY SEIZED BY THE IN-
TERNAL 
REVENUE 
SERVICE 
BASED 
ON 
STRUCTURING TRANSACTION. 
(a) IN GENERAL.—Part III of subchapter B of chap-
ter 1 is amended by inserting before section 140 the fol-
lowing new section:
‘‘SEC. 139H. INTEREST RECEIVED IN ACTION TO RECOVER 
PROPERTY SEIZED BY THE INTERNAL REV-
ENUE SERVICE BASED ON STRUCTURING 
TRANSACTION. 
‘‘Gross income shall not include any interest received 
from the Federal Government in connection with an action 
to recover property seized by the Internal Revenue Service 
pursuant to section 5317(c)(2) of title 31, United States 
Code, by reason of a claimed violation of section 5324 of 
such title.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for part III of subchapter B of chapter 1 is amended by 
inserting before the item relating to section 140 the fol-
lowing new item: 
‘‘Sec. 139H. Interest received in action to recover property seized by the Inter-
nal Revenue Service based on structuring transaction.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to interest received on or after the 
date of the enactment of this Act. 
SEC. 1203. CLARIFICATION OF EQUITABLE RELIEF FROM 
JOINT LIABILITY. 
(a) IN GENERAL.—Section 6015 is amended— 
(1) in subsection (e), by adding at the end the 
following new paragraph: 
‘‘(7) STANDARD AND SCOPE OF REVIEW.—Any 
review of a determination made under this section
shall be reviewed de novo by the Tax Court and shall 
be based upon— 
‘‘(A) the administrative record established 
at the time of the determination, and 
‘‘(B) any additional newly discovered or 
previously unavailable evidence.’’; and 
(2) by amending subsection (f) to read as fol-
lows: 
‘‘(f) EQUITABLE RELIEF.— 
‘‘(1) IN
GENERAL.—Under procedures pre-
scribed by the Secretary, if— 
‘‘(A) taking into account all the facts and 
circumstances, it is inequitable to hold the indi-
vidual liable for any unpaid tax or any defi-
ciency (or any portion of either), and 
‘‘(B) relief is not available to such indi-
vidual under subsection (b) or (c), 
the Secretary may relieve such individual of such li-
ability. 
‘‘(2) LIMITATION.—A request for equitable re-
lief under this subsection may be made with respect 
to any portion of any liability that— 
‘‘(A) has not been paid, provided that such 
request is made before the expiration of the ap-
plicable period of limitation under section 6502, 
or 
‘‘(B) has been paid, provided that such re-
quest is made during the period in which the 
individual could submit a timely claim for re-
fund or credit of such payment.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to petitions or requests filed or 
pending on or after the date of the enactment of this Act. 
SEC. 1204. MODIFICATION OF PROCEDURES FOR ISSUANCE 
OF THIRD-PARTY SUMMONS. 
(a) IN GENERAL.—Section 7609(f) is amended by 
adding at the end the following flush sentence: 
‘‘The Secretary shall not issue any summons described in 
the preceding sentence unless the information sought to 
be obtained is narrowly tailored to information that per-
tains to the failure (or potential failure) of the person or 
group or class of persons referred to in paragraph (2) to 
comply with one or more provisions of the internal revenue 
law which have been identified for purposes of such para-
graph.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to summonses served after the date 
of the enactment of this Act.
SEC. 1205. PRIVATE DEBT COLLECTION AND SPECIAL COM-
PLIANCE PERSONNEL PROGRAM. 
(a) CERTAIN TAX RECEIVABLES NOT ELIGIBLE FOR 
COLLECTION UNDER TAX COLLECTION CONTRACTS.— 
Section 6306(d)(3) is amended by striking ‘‘or’’ at the end 
of subparagraph (C) and by inserting after subparagraph 
(D) the following new subparagraphs: 
‘‘(E) a taxpayer substantially all of whose 
income consists of disability insurance benefits 
under section 223 of the Social Security Act or 
supplemental security income benefits under 
title XVI of the Social Security Act (including 
supplemental security income benefits of the 
type described in section 1616 of such Act or 
section 212 of Public Law 93–66), or 
‘‘(F) a taxpayer who is an individual with 
adjusted gross income, as determined for the 
most recent taxable year for which such infor-
mation is available, which does not exceed 200 
percent of the applicable poverty level (as deter-
mined by the Secretary).’’. 
(b) DETERMINATION
OF INACTIVE TAX RECEIV-
ABLES ELIGIBLE FOR COLLECTION UNDER TAX COLLEC-
TION CONTRACTS.—Section 6306(c)(2)(A)(ii) is amended 
by striking ‘‘more than 1⁄3 of the period of the applicable
statute of limitation has lapsed’’ and inserting ‘‘more than 
2 years has passed since assessment’’. 
(c) MAXIMUM LENGTH OF INSTALLMENT AGREE-
MENTS
OFFERED
UNDER
TAX
COLLECTION
CON-
TRACTS.—Section 6306(b)(1)(B) is amended by striking 
‘‘5 years’’ and inserting ‘‘7 years’’. 
(d) CLARIFICATION THAT SPECIAL COMPLIANCE 
PERSONNEL PROGRAM ACCOUNT MAY BE USED
FOR 
PROGRAM COSTS.— 
(1) IN GENERAL.—Section 6307(b) is amend-
ed— 
(A) in paragraph (2), by striking all that 
follows ‘‘under such program’’ and inserting a 
period; and 
(B) in paragraph (3), by striking all that 
follows ‘‘out of such account’’ and inserting 
‘‘for other than program costs’’. 
(2) COMMUNICATIONS, SOFTWARE, AND TECH-
NOLOGY COSTS TREATED AS PROGRAM COSTS.—Sec-
tion 6307(d)(2)(B) is amended by striking ‘‘tele-
communications’’ and inserting ‘‘communications, 
software, technology’’. 
(3) 
CONFORMING
AMENDMENT.—Section 
6307(d)(2) is amended by striking ‘‘and’’ at the end 
of subparagraph (A), by striking the period at the
end of subparagraph (B) and inserting ‘‘, and’’, and 
by inserting after subparagraph (B) the following 
new subparagraph: 
‘‘(C) reimbursement of the Internal Rev-
enue Service or other government agencies for 
the cost of administering the qualified tax col-
lection program under section 6306.’’. 
(e) EFFECTIVE DATES.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall apply to tax receivables identified 
by the Secretary (or the Secretary’s delegate) after 
December 31, 2019. 
(2) 
MAXIMUM
LENGTH
OF
INSTALLMENT 
AGREEMENTS.—The amendment made by subsection 
(c) shall apply to contracts entered into after the 
date of the enactment of this Act. 
(3) USE OF SPECIAL COMPLIANCE PERSONNEL 
PROGRAM ACCOUNT.—The amendment made by sub-
section (d) shall apply to amounts expended from 
the special compliance personnel program account 
after the date of the enactment of this Act.
SEC. 1206. REFORM OF NOTICE OF CONTACT OF THIRD 
PARTIES. 
(a) IN GENERAL.—Section 7602(c)(1) is amended to 
read as follows: 
‘‘(1) GENERAL
NOTICE.—An officer or em-
ployee of the Internal Revenue Service may not con-
tact any person other than the taxpayer with respect 
to the determination or collection of the tax liability 
of such taxpayer unless such contact occurs during 
a period (not greater than 1 year) which is specified 
in a notice which— 
‘‘(A) informs the taxpayer that contacts 
with persons other than the taxpayer are in-
tended to be made during such period, and 
‘‘(B) except as otherwise provided by the 
Secretary, is provided to the taxpayer not later 
than 45 days before the beginning of such pe-
riod. 
Nothing in the preceding sentence shall prevent the 
issuance of notices to the same taxpayer with respect 
to the same tax liability with periods specified there-
in that, in the aggregate, exceed 1 year. A notice 
shall not be issued under this paragraph unless 
there is an intent at the time such notice is issued 
to contact persons other than the taxpayer during 
the period specified in such notice. The preceding
sentence shall not prevent the issuance of a notice 
if the requirement of such sentence is met on the 
basis of the assumption that the information sought 
to be obtained by such contact will not be obtained 
by other means before such contact.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to notices provided, and contacts 
of persons made, after the date which is 45 days after 
the date of the enactment of this Act. 
SEC. 1207. MODIFICATION OF AUTHORITY TO ISSUE DES-
IGNATED SUMMONS. 
(a) IN GENERAL.—Paragraph (1) of section 6503(j) 
is amended by striking ‘‘coordinated examination pro-
gram’’ and inserting ‘‘coordinated industry case pro-
gram’’. 
(b) REQUIREMENTS FOR SUMMONS.—Clause (i) of 
section 6503(j)(2)(A) is amended to read as follows: 
‘‘(i) the issuance of such summons is 
preceded by a review and written approval 
of such issuance by the Commissioner of 
the relevant operating division of the Inter-
nal Revenue Service and the Chief Counsel 
which— 
‘‘(I) states facts clearly estab-
lishing that the Secretary has made
reasonable requests for the informa-
tion that is the subject of the sum-
mons, and 
‘‘(II) is attached to such sum-
mons,’’. 
(c) ESTABLISHMENT THAT REASONABLE REQUESTS 
FOR INFORMATION WERE MADE.—Subsection (j) of sec-
tion 6503 is amended by adding at the end the following 
new paragraph: 
‘‘(4) ESTABLISHMENT THAT REASONABLE RE-
QUESTS FOR INFORMATION WERE MADE.—In any 
court proceeding described in paragraph (3), the 
Secretary shall establish that reasonable requests 
were made for the information that is the subject of 
the summons.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to summonses issued after the date 
of the enactment of this Act. 
SEC. 1208. LIMITATION ON ACCESS OF NON-INTERNAL REV-
ENUE SERVICE EMPLOYEES TO RETURNS 
AND RETURN INFORMATION. 
(a) IN GENERAL.—Section 7602 is amended by add-
ing at the end the following new subsection: 
‘‘(f) LIMITATION ON ACCESS OF PERSONS OTHER 
THAN INTERNAL REVENUE SERVICE OFFICERS AND EM-
PLOYEES.—The Secretary shall not, under the authority 
of section 6103(n), provide any books, papers, records, or 
other data obtained pursuant to this section to any person 
authorized under section 6103(n), except when such per-
son requires such information for the sole purpose of pro-
viding expert evaluation and assistance to the Internal 
Revenue Service. No person other than an officer or em-
ployee of the Internal Revenue Service or the Office of 
Chief Counsel may, on behalf of the Secretary, question 
a witness under oath whose testimony was obtained pursu-
ant to this section.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section— 
(1) shall take effect on the date of the enact-
ment of this Act; and 
(2) shall not fail to apply to a contract in effect 
under section 6103(n) of the Internal Revenue Code 
of 1986 merely because such contract was in effect 
before the date of the enactment of this Act. 
Subtitle D—Organizational 
Modernization 
SEC. 1301. OFFICE OF THE NATIONAL TAXPAYER ADVO-
CATE. 
(a) TAXPAYER ADVOCATE DIRECTIVES.—
(1) IN GENERAL.—Section 7803(c) is amended 
by adding at the end the following new paragraph: 
‘‘(5) TAXPAYER
ADVOCATE
DIRECTIVES.—In 
the case of any Taxpayer Advocate Directive issued 
by the National Taxpayer Advocate pursuant to a 
delegation of authority from the Commissioner of 
the Internal Revenue Service— 
‘‘(A) the Commissioner or a Deputy Com-
missioner shall modify, rescind, or ensure com-
pliance with such directive not later than 90 
days after the issuance of such directive, and 
‘‘(B) in the case of any directive which is 
modified or rescinded by a Deputy Commis-
sioner, the National Taxpayer Advocate may 
(not later than 90 days after such modification 
or rescission) appeal to the Commissioner and 
the Commissioner shall (not later than 90 days 
after such appeal is made) ensure compliance 
with such directive as issued by the National 
Taxpayer Advocate or provide the National 
Taxpayer Advocate with a detailed description 
of the reasons for any modification or rescission 
made or upheld by the Commissioner pursuant 
to such appeal.’’.
(2) REPORT TO CERTAIN COMMITTEES OF CON-
GRESS
REGARDING
DIRECTIVES.—Section 
7803(c)(2)(B)(ii) is amended by redesignating sub-
clauses (VIII) through (XI) as subclauses (IX) 
through (XII), respectively, and by inserting after 
subclause (VII) the following new subclause: 
‘‘(VIII) identify any Taxpayer 
Advocate Directive which was not 
honored by the Internal Revenue 
Service in a timely manner, as speci-
fied under paragraph (5),’’. 
(b) NATIONAL TAXPAYER ADVOCATE ANNUAL RE-
PORTS TO CONGRESS.— 
(1) INCLUSION
OF
MOST
SERIOUS
TAXPAYER 
PROBLEMS.—Section 
7803(c)(2)(B)(ii)(III) 
is 
amended by striking ‘‘at least 20 of the’’ and insert-
ing ‘‘the 10’’. 
(2) COORDINATION WITH TREASURY INSPECTOR 
GENERAL
FOR
TAX
ADMINISTRATION.—Section 
7803(c)(2) is amended by adding at the end the fol-
lowing new subparagraph: 
‘‘(E) COORDINATION WITH TREASURY IN-
SPECTOR
GENERAL
FOR
TAX
ADMINISTRA-
TION.—Before beginning any research or study, 
the National Taxpayer Advocate shall coordi-
nate with the Treasury Inspector General for 
Tax Administration to ensure that the National 
Taxpayer Advocate does not duplicate any ac-
tion that the Treasury Inspector General for 
Tax Administration has already undertaken or 
has a plan to undertake.’’. 
(3) STATISTICAL SUPPORT.— 
(A) IN GENERAL.—Section 6108 is amend-
ed by adding at the end the following new sub-
section: 
‘‘(d) STATISTICAL SUPPORT FOR NATIONAL TAX-
PAYER ADVOCATE.—The Secretary shall, upon request of 
the National Taxpayer Advocate, provide the National 
Taxpayer Advocate with statistical support in connection 
with the preparation by the National Taxpayer Advocate 
of 
the 
annual 
report 
described 
in 
section 
7803(c)(2)(B)(ii). Such statistical support shall include 
statistical studies, compilations, and the review of infor-
mation provided by the National Taxpayer Advocate for 
statistical validity and sound statistical methodology.’’. 
(B) DISCLOSURE
OF
REVIEW.—Section 
7803(c)(2)(B)(ii), as amended by subsection 
(a), is amended by redesignating subclause 
(XII) as subclause (XIII) and by inserting after 
subclause (XI) the following new subclause:
‘‘(XII) with respect to any statis-
tical information included in such re-
port, include a statement of whether 
such statistical information was re-
viewed or provided by the Secretary 
under section 6108(d) and, if so, 
whether the Secretary determined 
such information to be statistically 
valid and based on sound statistical 
methodology.’’. 
(C) CONFORMING
AMENDMENT.—Section 
7803(c)(2)(B)(iii) is amended by adding at the 
end the following: ‘‘The preceding sentence 
shall not apply with respect to statistical infor-
mation provided to the Secretary for review, or 
received from the Secretary, under section 
6108(d).’’. 
(c) SALARY OF NATIONAL TAXPAYER ADVOCATE.— 
Section 7803(c)(1)(B)(i) is amended by striking ‘‘, or, if 
the Secretary of the Treasury so determines, at a rate 
fixed under section 9503 of such title’’. 
(d) EFFECTIVE DATE.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by
this section shall take effect on the date of the en-
actment of this Act. 
(2) SALARY
OF
NATIONAL
TAXPAYER
ADVO-
CATE.—The amendment made by subsection (c) 
shall apply to compensation paid to individuals ap-
pointed as the National Taxpayer Advocate after the 
date of the enactment of this Act. 
SEC. 1302. MODERNIZATION OF INTERNAL REVENUE SERV-
ICE ORGANIZATIONAL STRUCTURE. 
(a) IN GENERAL.—Not later than September 30, 
2020, the Commissioner of the Internal Revenue Service 
shall submit to Congress a comprehensive written plan to 
redesign the organization of the Internal Revenue Service. 
Such plan shall— 
(1) ensure the successful implementation of the 
priorities specified by Congress in this Act; 
(2) prioritize taxpayer services to ensure that 
all taxpayers easily and readily receive the assistance 
that they need; 
(3) streamline the structure of the agency in-
cluding minimizing the duplication of services and 
responsibilities within the agency; 
(4) best position the Internal Revenue Service 
to combat cybersecurity and other threats to the In-
ternal Revenue Service; and
(5) address whether the Criminal Investigation 
Division of the Internal Revenue Service should re-
port directly to the Commissioner. 
(b) REPEAL OF RESTRICTION ON ORGANIZATIONAL 
STRUCTURE OF INTERNAL REVENUE SERVICE.—Para-
graph (3) of section 1001(a) of the Internal Revenue Serv-
ice Restructuring and Reform Act of 1998 shall cease to 
apply beginning 1 year after the date on which the Com-
missioner of the Internal Revenue Service submits to Con-
gress the plan described in subsection (a). 
Subtitle E—Other Provisions 
SEC. 1401. RETURN PREPARATION PROGRAMS FOR APPLI-
CABLE TAXPAYERS. 
(a) IN GENERAL.—Chapter 77 is amended by insert-
ing after section 7526 the following new section: 
‘‘SEC. 7526A. RETURN PREPARATION PROGRAMS FOR AP-
PLICABLE TAXPAYERS. 
‘‘(a) ESTABLISHMENT OF VOLUNTEER INCOME TAX 
ASSISTANCE MATCHING GRANT PROGRAM.—The Sec-
retary shall establish a Community Volunteer Income Tax 
Assistance Matching Grant Program under which the Sec-
retary may, subject to the availability of appropriated 
funds, make grants to provide matching funds for the de-
velopment, expansion, or continuation of qualified return
preparation programs assisting applicable taxpayers and 
members of underserved populations. 
‘‘(b) USE OF FUNDS.— 
‘‘(1) IN GENERAL.—Qualified return prepara-
tion programs may use grants received under this 
section for— 
‘‘(A) ordinary and necessary costs associ-
ated with program operation in accordance with 
cost principles under the applicable Office of 
Management and Budget circular, including— 
‘‘(i) wages or salaries of persons co-
ordinating the activities of the program, 
‘‘(ii) developing training materials, 
conducting training, and performing qual-
ity reviews of the returns prepared under 
the program, 
‘‘(iii) equipment purchases, and 
‘‘(iv) vehicle-related expenses associ-
ated with remote or rural tax preparation 
services, 
‘‘(B) outreach and educational activities 
described in subsection (c)(2)(B), and 
‘‘(C) services related to financial education 
and capability, asset development, and the es-
tablishment of savings accounts in connection 
with tax return preparation. 
‘‘(2) REQUIREMENT OF MATCHING FUNDS.—A 
qualified return preparation program must provide 
matching funds on a dollar-for-dollar basis for all 
grants provided under this section. Matching funds 
may include— 
‘‘(A) the salary (including fringe benefits) 
of individuals performing services for the pro-
gram, 
‘‘(B) the cost of equipment used in the 
program, and 
‘‘(C) other ordinary and necessary costs 
associated with the program. 
Indirect expenses, including general overhead of any 
entity administering the program, shall not be 
counted as matching funds. 
‘‘(c) APPLICATION.— 
‘‘(1) IN GENERAL.—Each applicant for a grant 
under this section shall submit an application to the 
Secretary at such time, in such manner, and con-
taining such information as the Secretary may rea-
sonably require.
‘‘(2) PRIORITY.—In awarding grants under this 
section, the Secretary shall give priority to applica-
tions which demonstrate— 
‘‘(A) assistance to applicable taxpayers, 
with emphasis on outreach to, and services for, 
such taxpayers, 
‘‘(B) taxpayer outreach and educational 
activities relating to eligibility and availability 
of income supports available through this title, 
including the earned income tax credit, and 
‘‘(C) specific outreach and focus on one or 
more underserved populations. 
‘‘(3) AMOUNTS TAKEN INTO ACCOUNT.—In de-
termining matching grants under this section, the 
Secretary shall only take into account amounts pro-
vided by the qualified return preparation program 
for expenses described in subsection (b). 
‘‘(d) PROGRAM ADHERENCE.— 
‘‘(1) IN GENERAL.—The Secretary shall estab-
lish procedures for, and shall conduct not less fre-
quently than once every 5 calendar years during 
which a qualified return preparation program is op-
erating under a grant under this section, periodic 
site visits—
‘‘(A) to ensure the program is carrying out 
the purposes of this section, and 
‘‘(B) to determine whether the program 
meets such program adherence standards as the 
Secretary shall by regulation or other guidance 
prescribe. 
‘‘(2) ADDITIONAL REQUIREMENTS FOR GRANT 
RECIPIENTS
NOT
MEETING
PROGRAM
ADHERENCE 
STANDARDS.—In the case of any qualified return 
preparation program which— 
‘‘(A) is awarded a grant under this section, 
and 
‘‘(B) is subsequently determined— 
‘‘(i) not to meet the program adher-
ence standards described in paragraph 
(1)(B), or 
‘‘(ii) not to be otherwise carrying out 
the purposes of this section, 
such program shall not be eligible for any additional 
grants under this section unless such program pro-
vides sufficient documentation of corrective meas-
ures established to address any such deficiencies de-
termined. 
‘‘(e) DEFINITIONS.—For purposes of this section—
‘‘(1) QUALIFIED
RETURN
PREPARATION
PRO-
GRAM.—The term ‘qualified return preparation pro-
gram’ means any program— 
‘‘(A) which provides assistance to individ-
uals, not less than 90 percent of whom are ap-
plicable taxpayers, in preparing and filing Fed-
eral income tax returns, 
‘‘(B) which is administered by a qualified 
entity, 
‘‘(C) in which all volunteers who assist in 
the preparation of Federal income tax returns 
meet the training requirements prescribed by 
the Secretary, and 
‘‘(D) which uses a quality review process 
which reviews 100 percent of all returns. 
‘‘(2) QUALIFIED ENTITY.— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
entity’ means any entity which— 
‘‘(i) is an eligible organization, 
‘‘(ii) is in compliance with Federal tax 
filing and payment requirements, 
‘‘(iii) is not debarred or suspended 
from Federal contracts, grants, or coopera-
tive agreements, and
‘‘(iv) agrees to provide documentation 
to substantiate any matching funds pro-
vided pursuant to the grant program under 
this section. 
‘‘(B) ELIGIBLE ORGANIZATION.—The term 
‘eligible organization’ means— 
‘‘(i) an institution of higher education 
which is described in section 102 (other 
than subsection (a)(1)(C) thereof) of the 
Higher Education Act of 1965 (20 U.S.C. 
1002), as in effect on the date of the en-
actment of this section, and which has not 
been disqualified from participating in a 
program under title IV of such Act, 
‘‘(ii) an organization described in sec-
tion 501(c) and exempt from tax under 
section 501(a), 
‘‘(iii) a local government agency, in-
cluding— 
‘‘(I) a county or municipal gov-
ernment agency, and 
‘‘(II) an Indian tribe, as defined 
in section 4(13) of the Native Amer-
ican Housing Assistance and Self-De-
termination Act of 1996 (25 U.S.C.
4103(13)), including any tribally des-
ignated housing entity (as defined in 
section 4(22) of such Act (25 U.S.C. 
4103(22))), tribal subsidiary, subdivi-
sion, or other wholly owned tribal en-
tity, 
‘‘(iv) a local, State, regional, or na-
tional coalition (with one lead organization 
which meets the eligibility requirements of 
clause (i), (ii), or (iii) acting as the appli-
cant organization), or 
‘‘(v) in the case of applicable tax-
payers and members of underserved popu-
lations with respect to which no organiza-
tions described in the preceding clauses are 
available— 
‘‘(I) a State government agency, 
or 
‘‘(II) an office providing Cooper-
ative Extension services (as estab-
lished at the land-grant colleges and 
universities under the Smith-Lever 
Act of May 8, 1914). 
‘‘(3) APPLICABLE TAXPAYERS.—The term ‘ap-
plicable taxpayer’ means a taxpayer whose income
for the taxable year does not exceed an amount 
equal to the completed phaseout amount under sec-
tion 32(b) for a married couple filing a joint return 
with three or more qualifying children, as deter-
mined in a revenue procedure or other published 
guidance. 
‘‘(4) UNDERSERVED
POPULATION.—The term 
‘underserved population’ includes populations of per-
sons with disabilities, persons with limited English 
proficiency, Native Americans, individuals living in 
rural areas, members of the Armed Forces and their 
spouses, and the elderly. 
‘‘(f) SPECIAL RULES AND LIMITATIONS.— 
‘‘(1) DURATION OF GRANTS.—Upon application 
of a qualified return preparation program, the Sec-
retary is authorized to award a multi-year grant not 
to exceed 3 years. 
‘‘(2) AGGREGATE
LIMITATION.—Unless other-
wise provided by specific appropriation, the Sec-
retary shall not allocate more than $30,000,000 per 
fiscal year (exclusive of costs of administering the 
program) to grants under this section. 
‘‘(g) PROMOTION OF PROGRAMS.— 
‘‘(1) IN GENERAL.—The Secretary shall pro-
mote tax preparation through qualified return prepa-
ration programs through the use of mass commu-
nications and other means. 
‘‘(2) PROVISION OF INFORMATION REGARDING 
QUALIFIED RETURN PREPARATION PROGRAMS.—The 
Secretary may provide taxpayers information regard-
ing qualified return preparation programs receiving 
grants under this section. 
‘‘(3) VITA GRANTEE REFERRAL.—Qualified re-
turn preparation programs receiving a grant under 
this section are encouraged, in appropriate cases, 
to— 
‘‘(A) advise taxpayers of the availability of, 
and eligibility requirements for receiving, advice 
and assistance from qualified low-income tax-
payer clinics receiving funding under section 
7526, and 
‘‘(B) provide information regarding the lo-
cation of, and contact information for, such 
clinics.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for chapter 77 is amended by inserting after the item re-
lating to section 7526 the following new item: 
‘‘Sec. 7526A. Return preparation programs for applicable taxpayers.’’.
SEC. 1402. PROVISION OF INFORMATION REGARDING LOW- 
INCOME TAXPAYER CLINICS. 
(a) IN GENERAL.—Section 7526(c) of the Internal 
Revenue Code of 1986 is amended by adding at the end 
the following new paragraph: 
‘‘(6) PROVISION OF INFORMATION REGARDING 
QUALIFIED LOW-INCOME TAXPAYER CLINICS.—Not-
withstanding any other provision of law, officers and 
employees of the Department of the Treasury may— 
‘‘(A) advise taxpayers of the availability of, 
and eligibility requirements for receiving, advice 
and assistance from one or more specific quali-
fied low-income taxpayer clinics receiving fund-
ing under this section, and 
‘‘(B) provide information regarding the lo-
cation of, and contact information for, such 
clinics.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 1403. NOTICE FROM IRS REGARDING CLOSURE OF 
TAXPAYER ASSISTANCE CENTERS. 
Not later than 90 days before the date that a pro-
posed closure of a Taxpayer Assistance Center would take 
effect, the Secretary of the Treasury (or the Secretary’s 
delegate) shall—
(1) make publicly available (including by non- 
electronic means) a notice which— 
(A) identifies the Taxpayer Assistance 
Center proposed for closure and the date of 
such proposed closure; and 
(B) identifies the relevant alternative 
sources of taxpayer assistance which may be 
utilized by taxpayers affected by such proposed 
closure; and 
(2) submit to Congress a written report that in-
cludes— 
(A) the information included in the notice 
described in paragraph (1); 
(B) the reasons for such proposed closure; 
and 
(C) such other information as the Sec-
retary may determine appropriate. 
SEC. 1404. RULES FOR SEIZURE AND SALE OF PERISHABLE 
GOODS RESTRICTED TO ONLY PERISHABLE 
GOODS. 
(a) IN GENERAL.—Section 6336 of the Internal Rev-
enue Code of 1986 is amended by striking ‘‘or become 
greatly reduced in price or value by keeping, or that such 
property cannot be kept without great expense’’.
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to property seized after the date 
of the enactment of this Act. 
SEC. 1405. WHISTLEBLOWER REFORMS. 
(a) MODIFICATIONS
TO DISCLOSURE RULES
FOR 
WHISTLEBLOWERS.— 
(1) IN GENERAL.—Section 6103(k) is amended 
by adding at the end the following new paragraph: 
‘‘(13) DISCLOSURE TO WHISTLEBLOWERS.— 
‘‘(A) IN
GENERAL.—The Secretary may 
disclose, to any individual providing information 
relating to any purpose described in paragraph 
(1) or (2) of section 7623(a), return informa-
tion related to the investigation of any taxpayer 
with respect to whom the individual has pro-
vided such information, but only to the extent 
that such disclosure is necessary in obtaining 
information, which is not otherwise reasonably 
available, with respect to the correct determina-
tion of tax liability for tax, or the amount to be 
collected with respect to the enforcement of any 
other provision of this title. 
‘‘(B) UPDATES
ON
WHISTLEBLOWER
IN-
VESTIGATIONS.—The Secretary shall disclose to 
an individual providing information relating to
any purpose described in paragraph (1) or (2) 
of section 7623(a) the following: 
‘‘(i) Not later than 60 days after a 
case for which the individual has provided 
information has been referred for an audit 
or examination, a notice with respect to 
such referral. 
‘‘(ii) Not later than 60 days after a 
taxpayer with respect to whom the indi-
vidual has provided information has made 
a payment of tax with respect to tax liabil-
ity to which such information relates, a no-
tice with respect to such payment. 
‘‘(iii) Subject to such requirements 
and conditions as are prescribed by the 
Secretary, upon a written request by such 
individual— 
‘‘(I) information on the status 
and stage of any investigation or ac-
tion related to such information, and 
‘‘(II) in the case of a determina-
tion of the amount of any award 
under section 7623(b), the reasons for 
such determination.
Clause (iii) shall not apply to any information 
if the Secretary determines that disclosure of 
such information would seriously impair Fed-
eral tax administration. Information described 
in clauses (i), (ii), and (iii) may be disclosed to 
a designee of the individual providing such in-
formation in accordance with guidance provided 
by the Secretary.’’. 
(2) CONFORMING AMENDMENTS.— 
(A) 
CONFIDENTIALITY
OF
INFORMA-
TION.—Section 6103(a)(3) is amended by strik-
ing ‘‘subsection (k)(10)’’ and inserting ‘‘para-
graph (10) or (13) of subsection (k)’’. 
(B) PENALTY
FOR
UNAUTHORIZED
DIS-
CLOSURE.—Section 7213(a)(2) is amended by 
striking ‘‘(k)(10)’’ and inserting ‘‘(k)(10) or 
(13)’’. 
(C) COORDINATION WITH AUTHORITY TO 
DISCLOSE
FOR
INVESTIGATIVE
PURPOSES.— 
Section 6103(k)(6) is amended by adding at the 
end the following new sentence: ‘‘This para-
graph shall not apply to any disclosure to an in-
dividual providing information relating to any 
purpose described in paragraph (1) or (2) of
section 7623(a) which is made under paragraph 
(13)(A).’’. 
(b) PROTECTION AGAINST RETALIATION.—Section 
7623 is amended by adding at the end the following new 
subsection: 
‘‘(d) CIVIL ACTION TO PROTECT AGAINST RETALIA-
TION CASES.— 
‘‘(1) ANTI-RETALIATION WHISTLEBLOWER PRO-
TECTION FOR EMPLOYEES.—No employer, or any of-
ficer, employee, contractor, subcontractor, or agent 
of such employer, may discharge, demote, suspend, 
threaten, harass, or in any other manner discrimi-
nate against an employee in the terms and condi-
tions of employment (including through an act in the 
ordinary course of such employee’s duties) in re-
prisal for any lawful act done by the employee— 
‘‘(A) to provide information, cause infor-
mation to be provided, or otherwise assist in an 
investigation regarding underpayment of tax or 
any conduct which the employee reasonably be-
lieves constitutes a violation of the internal rev-
enue laws or any provision of Federal law relat-
ing to tax fraud, when the information or as-
sistance is provided to the Internal Revenue 
Service, the Secretary of Treasury, the Treas-
ury Inspector General for Tax Administration, 
the Comptroller General of the United States, 
the Department of Justice, the United States 
Congress, a person with supervisory authority 
over the employee, or any other person working 
for the employer who has the authority to inves-
tigate, discover, or terminate misconduct, or 
‘‘(B) to testify, participate in, or otherwise 
assist in any administrative or judicial action 
taken by the Internal Revenue Service relating 
to an alleged underpayment of tax or any viola-
tion of the internal revenue laws or any provi-
sion of Federal law relating to tax fraud. 
‘‘(2) ENFORCEMENT ACTION.— 
‘‘(A) IN GENERAL.—A person who alleges 
discharge or other reprisal by any person in vio-
lation of paragraph (1) may seek relief under 
paragraph (3) by— 
‘‘(i) filing a complaint with the Sec-
retary of Labor, or 
‘‘(ii) if the Secretary of Labor has not 
issued a final decision within 180 days of 
the filing of the complaint and there is no 
showing that such delay is due to the bad 
faith of the claimant, bringing an action at
law or equity for de novo review in the ap-
propriate district court of the United 
States, which shall have jurisdiction over 
such an action without regard to the 
amount in controversy. 
‘‘(B) PROCEDURE.— 
‘‘(i) IN GENERAL.—An action under 
subparagraph (A)(i) shall be governed 
under the rules and procedures set forth in 
section 42121(b) of title 49, United States 
Code. 
‘‘(ii) EXCEPTION.—Notification made 
under section 42121(b)(1) of title 49, 
United States Code, shall be made to the 
person named in the complaint and to the 
employer. 
‘‘(iii) BURDENS OF PROOF.—An ac-
tion brought under subparagraph (A)(ii) 
shall be governed by the legal burdens of 
proof set forth in section 42121(b) of title 
49, United States Code, except that in ap-
plying such section— 
‘‘(I) ‘behavior described in para-
graph (1)’ shall be substituted for ‘be-
havior described in paragraphs (1)
through (4) of subsection (a)’ each 
place it appears in paragraph (2)(B) 
thereof, and 
‘‘(II) ‘a violation of paragraph 
(1)’ shall be substituted for ‘a viola-
tion of subsection (a)’ each place it 
appears. 
‘‘(iv) STATUTE
OF
LIMITATIONS.—A 
complaint under subparagraph (A)(i) shall 
be filed not later than 180 days after the 
date on which the violation occurs. 
‘‘(v) JURY TRIAL.—A party to an ac-
tion brought under subparagraph (A)(ii) 
shall be entitled to trial by jury. 
‘‘(3) REMEDIES.— 
‘‘(A) IN
GENERAL.—An employee pre-
vailing in any action under paragraph (2)(A) 
shall be entitled to all relief necessary to make 
the employee whole. 
‘‘(B) COMPENSATORY
DAMAGES.—Relief 
for any action under subparagraph (A) shall in-
clude— 
‘‘(i) reinstatement with the same se-
niority status that the employee would 
have had, but for the reprisal,
‘‘(ii) the sum of 200 percent of the 
amount of back pay and 100 percent of all 
lost benefits, with interest, and 
‘‘(iii) compensation for any special 
damages sustained as a result of the re-
prisal, including litigation costs, expert wit-
ness fees, and reasonable attorney fees. 
‘‘(4) RIGHTS RETAINED BY EMPLOYEE.—Noth-
ing in this section shall be deemed to diminish the 
rights, privileges, or remedies of any employee under 
any Federal or State law, or under any collective 
bargaining agreement. 
‘‘(5) NONENFORCEABILITY OF CERTAIN PROVI-
SIONS WAIVING RIGHTS AND REMEDIES OR REQUIR-
ING ARBITRATION OF DISPUTES.— 
‘‘(A) WAIVER
OF
RIGHTS
AND
REM-
EDIES.—The rights and remedies provided for 
in this subsection may not be waived by any 
agreement, policy form, or condition of employ-
ment, including by a predispute arbitration 
agreement. 
‘‘(B) PREDISPUTE
ARBITRATION
AGREE-
MENTS.—No predispute arbitration agreement 
shall be valid or enforceable, if the agreement
requires arbitration of a dispute arising under 
this subsection.’’. 
(c) EFFECTIVE DATE.— 
(1) IN GENERAL.—The amendments made by 
subsection (a) shall apply to disclosures made after 
the date of the enactment of this Act. 
(2) CIVIL PROTECTION.—The amendment made 
by subsection (b) shall take effect on the date of the 
enactment of this Act. 
SEC. 1406. CUSTOMER SERVICE INFORMATION. 
The Secretary of the Treasury (or the Secretary’s 
delegate) shall provide helpful information to taxpayers 
placed on hold during a telephone call to any Internal Rev-
enue Service help line, including the following: 
(1) Information about common tax scams. 
(2) Information on where and how to report tax 
scams. 
(3) Additional advice on how taxpayers can pro-
tect themselves from identity theft and tax scams. 
SEC. 1407. MISDIRECTED TAX REFUND DEPOSITS. 
Section 6402 is amended by adding at the end the 
following new subsection: 
‘‘(n) MISDIRECTED DIRECT DEPOSIT REFUND.—Not 
later than the date which is 6 months after the date of 
the enactment of the Taxpayer First Act of 2018, the Sec-
retary shall prescribe regulations to establish procedures 
to allow for— 
‘‘(1) taxpayers to report instances in which a 
refund made by the Secretary by electronic funds 
transfer was erroneously delivered to an account at 
a financial institution for which the taxpayer is not 
the owner; 
‘‘(2) coordination with financial institutions for 
the purpose of— 
‘‘(A) identifying erroneous payments de-
scribed in paragraph (1); and 
‘‘(B) recovery of the erroneously trans-
ferred amounts; and 
‘‘(3) the refund to be delivered to the correct 
account of the taxpayer.’’. 
TITLE II—21ST CENTURY IRS 
Subtitle A—Cybersecurity and 
Identity Protection 
SEC. 2001. PUBLIC-PRIVATE PARTNERSHIP TO ADDRESS 
IDENTITY THEFT REFUND FRAUD. 
The Secretary of the Treasury (or the Secretary’s 
delegate) shall work collaboratively with the public and 
private sectors to protect taxpayers from identity theft re-
fund fraud.
SEC. 2002. RECOMMENDATIONS OF ELECTRONIC TAX AD-
MINISTRATION ADVISORY COMMITTEE RE-
GARDING IDENTITY THEFT REFUND FRAUD. 
The Secretary of the Treasury shall ensure that the 
advisory group convened by the Secretary pursuant to sec-
tion 2001(b)(2) of the Internal Revenue Service Restruc-
turing and Reform Act of 1998 (commonly known as the 
Electronic Tax Administration Advisory Committee) stud-
ies (including by providing organized public forums) and 
makes recommendations to the Secretary regarding meth-
ods to prevent identity theft and refund fraud. 
SEC. 2003. INFORMATION SHARING AND ANALYSIS CENTER. 
(a) IN GENERAL.—The Secretary of the Treasury (or 
the Secretary’s delegate) may participate in an informa-
tion sharing and analysis center to centralize, standardize, 
and enhance data compilation and analysis to facilitate 
sharing actionable data and information with respect to 
identity theft tax refund fraud. 
(b) DEVELOPMENT OF PERFORMANCE METRICS.— 
The Secretary of the Treasury (or the Secretary’s dele-
gate) shall develop metrics for measuring the success of 
such center in detecting and preventing identity theft tax 
refund fraud. 
(c) DISCLOSURE.—
(1) IN GENERAL.—Section 6103(k), as amend-
ed by this Act, is amended by adding at the end the 
following new paragraph: 
‘‘(14) DISCLOSURE OF RETURN INFORMATION 
FOR PURPOSES OF CYBERSECURITY AND THE PRE-
VENTION
OF
IDENTITY
THEFT
TAX
REFUND 
FRAUD.— 
‘‘(A) IN
GENERAL.—Under such proce-
dures and subject to such conditions as the Sec-
retary may prescribe, the Secretary may dis-
close specified return information to specified 
ISAC participants to the extent that the Sec-
retary determines such disclosure is in further-
ance of effective Federal tax administration re-
lating to the detection or prevention of identity 
theft tax refund fraud, validation of taxpayer 
identity, authentication of taxpayer returns, or 
detection or prevention of cybersecurity threats. 
‘‘(B) SPECIFIED ISAC PARTICIPANTS.—For 
purposes of this paragraph— 
‘‘(i) IN GENERAL.—The term ‘speci-
fied ISAC participant’ means— 
‘‘(I) any person designated by 
the Secretary as having primary re-
sponsibility for a function performed
with respect to the information shar-
ing and analysis center described in 
section 2003(a) of the Taxpayer First 
Act of 2018, and 
‘‘(II) any person subject to the 
requirements of section 7216 and 
which is a participant in such infor-
mation sharing and analysis center. 
‘‘(ii) INFORMATION SHARING AGREE-
MENT.—Such term shall not include any 
person unless such person has entered into 
a written agreement with the Secretary 
setting forth the terms and conditions for 
the disclosure of information to such per-
son under this paragraph, including re-
quirements regarding the protection and 
safeguarding of such information by such 
person. 
‘‘(C) SPECIFIED RETURN INFORMATION.— 
For purposes of this paragraph, the term ‘spec-
ified return information’ means— 
‘‘(i) in the case of a return which is 
in connection with a case of potential iden-
tity theft refund fraud—
‘‘(I) in the case of such return 
filed electronically, the internet pro-
tocol address, device identification, 
email domain name, speed of comple-
tion, method of authentication, refund 
method, and such other return infor-
mation related to the electronic filing 
characteristics of such return as the 
Secretary may identify for purposes of 
this subclause, and 
‘‘(II) in the case of such return 
prepared by a tax return preparer, 
identifying information with respect to 
such tax return preparer, including 
the preparer taxpayer identification 
number and electronic filer identifica-
tion number of such preparer, 
‘‘(ii) in the case of a return which is 
in connection with a case of a identity 
theft refund fraud which has been con-
firmed by the Secretary (pursuant to such 
procedures as the Secretary may provide), 
the information referred to in subclauses 
(I) and (II) of clause (i), the name and 
taxpayer identification number of the tax-
payer as it appears on the return, and any 
bank account and routing information pro-
vided for making a refund in connection 
with such return, and 
‘‘(iii) in the case of any cybersecurity 
threat to the Internal Revenue Service, in-
formation similar to the information de-
scribed in subclauses (I) and (II) of clause 
(i) with respect to such threat. 
‘‘(D) RESTRICTION ON USE OF DISCLOSED 
INFORMATION.— 
‘‘(i) DESIGNATED THIRD PARTIES.— 
Any return information received by a per-
son described in subparagraph (B)(i)(I) 
shall be used only for the purposes of and 
to the extent necessary in— 
‘‘(I) performing the function such 
person is designated to perform under 
such subparagraph, 
‘‘(II) facilitating disclosures au-
thorized under subparagraph (A) to 
persons described in subparagraph 
(B)(i)(II), and 
‘‘(III) facilitating disclosures au-
thorized under subsection (d) to par-
ticipants in such information sharing 
and analysis center. 
‘‘(ii) RETURN
PREPARERS.—Any re-
turn information received by a person de-
scribed in subparagraph (B)(i)(II) shall be 
treated for purposes of section 7216 as in-
formation furnished to such person for, or 
in connection with, the preparation of a re-
turn of the tax imposed under chapter 1. 
‘‘(E) 
DATA
PROTECTION
AND
SAFE-
GUARDS.—Return information disclosed under 
this paragraph shall be subject to such protec-
tions and safeguards as the Secretary may re-
quire in regulations or other guidance or in the 
written agreement referred to in subparagraph 
(B)(ii). Such written agreement shall include a 
requirement that any unauthorized access to in-
formation disclosed under this paragraph, and 
any breach of any system in which such infor-
mation is held, be reported to the Treasury In-
spector General for Tax Administration.’’. 
(2) APPLICATION OF CIVIL AND CRIMINAL PEN-
ALTIES.—
(A) Section 6103(a)(3), as amended by 
this Act, is amended by striking ‘‘or (13)’’ and 
inserting ‘‘(13), or (14)’’. 
(B) Section 7213(a)(2), as amended by 
this Act, is amended by striking ‘‘or (13)’’ and 
inserting ‘‘(13), or (14)’’. 
SEC. 2004. COMPLIANCE BY CONTRACTORS WITH CON-
FIDENTIALITY SAFEGUARDS. 
(a) IN GENERAL.—Section 6103(p) is amended by 
adding at the end the following new paragraph: 
‘‘(9) 
DISCLOSURE
TO
CONTRACTORS
AND 
OTHER AGENTS.—Notwithstanding any other provi-
sion of this section, no return or return information 
shall be disclosed to any contractor or other agent 
of a Federal, State, or local agency unless such 
agency, to the satisfaction of the Secretary— 
‘‘(A) has requirements in effect which re-
quire each such contractor or other agent which 
would have access to returns or return informa-
tion to provide safeguards (within the meaning 
of paragraph (4)) to protect the confidentiality 
of such returns or return information, 
‘‘(B) agrees to conduct an on-site review 
every 3 years (or a mid-point review in the case 
of contracts or agreements of less than 3 years
in duration) of each contractor or other agent 
to determine compliance with such require-
ments, 
‘‘(C) submits the findings of the most re-
cent review conducted under subparagraph (B) 
to the Secretary as part of the report required 
by paragraph (4)(E), and 
‘‘(D) certifies to the Secretary for the most 
recent annual period that such contractor or 
other agent is in compliance with all such re-
quirements. 
The certification required by subparagraph (D) shall 
include the name and address of each contractor or 
other agent, a description of the contract or agree-
ment with such contractor or other agent, and the 
duration of such contract or agreement. The require-
ments of this paragraph shall not apply to disclo-
sures pursuant to subsection (n) for purposes of 
Federal tax administration.’’. 
(b) 
CONFORMING
AMENDMENT.—Section 
6103(p)(8)(B) is amended by inserting ‘‘or paragraph 
(9)’’ after ‘‘subparagraph (A)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures made after Decem-
ber 31, 2022.
SEC. 2005. REPORT ON ELECTRONIC PAYMENTS. 
Not later than 2 years after the date of the enact-
ment of this Act, the Secretary of the Treasury (or the 
Secretary’s delegate), in coordination with the Bureau of 
Fiscal Service and the Internal Revenue Service, and in 
consultation with private sector financial institutions, shall 
submit a written report to Congress describing how the 
government can utilize new payment platforms to increase 
the number of tax refunds paid by electronic funds trans-
fer. Such report shall weigh the interests of reducing iden-
tity theft tax refund fraud, reducing the Federal Govern-
ment’s costs in delivering tax refunds, the costs and any 
associated fees charged to taxpayers (including monthly 
and point-of-service fees) to access their tax refunds, the 
impact on individuals who do not have access to financial 
accounts or institutions, and ensuring payments are made 
to accounts at a financial institution that complies with 
section 21 of the Federal Deposit Insurance Act, chapter 
2 of title I of Public Law 91–508, and subchapter II of 
chapter 53 of title 31, United States Code (commonly re-
ferred to collectively as the ‘‘Bank Secrecy Act’’) and the 
USA PATRIOT Act. Such report shall include any legisla-
tive recommendations necessary to accomplish these goals.
SEC. 2006. IDENTITY PROTECTION PERSONAL IDENTIFICA-
TION NUMBERS. 
(a) IN GENERAL.—Subject to subsection (b), the Sec-
retary of the Treasury or the Secretary’s delegate (here-
after referred to in this section as the ‘‘Secretary’’) shall 
establish a program to issue, upon the request of any indi-
vidual, a number which may be used in connection with 
such individual’s social security number (or other identi-
fying information with respect to such individual as deter-
mined by the Secretary) to assist the Secretary in 
verifying such individual’s identity. 
(b) REQUIREMENTS.— 
(1) ANNUAL
EXPANSION.—For each calendar 
year beginning after the date of the enactment of 
this Act, the Secretary shall provide numbers 
through the program described in subsection (a) to 
individuals residing in such States as the Secretary 
deems appropriate, provided that the total number 
of States served by such program during such year 
is greater than the total number of States served by 
such program during the preceding year. 
(2) NATIONWIDE
AVAILABILITY.—Not later 
than 5 years after the date of the enactment of this 
Act, the Secretary shall ensure that the program de-
scribed in subsection (a) is made available to any in-
dividual residing in the United States.
SEC. 2007. SINGLE POINT OF CONTACT FOR TAX-RELATED 
IDENTITY THEFT VICTIMS. 
(a) IN GENERAL.—The Secretary of the Treasury (or 
the Secretary’s delegate) shall establish and implement 
procedures to ensure that any taxpayer whose return has 
been delayed or otherwise adversely affected due to tax- 
related identity theft has a single point of contact at the 
Internal Revenue Service throughout the processing of the 
taxpayer’s case. The single point of contact shall track the 
taxpayer’s case to completion and coordinate with other 
Internal Revenue Service employees to resolve case issues 
as quickly as possible. 
(b) SINGLE POINT OF CONTACT.— 
(1) IN GENERAL.—For purposes of subsection 
(a), the single point of contact shall consist of a 
team or subset of specially trained employees who— 
(A) have the ability to work across func-
tions to resolve the issues involved in the tax-
payer’s case; and 
(B) shall be accountable for handling the 
case until its resolution. 
(2) TEAM OR SUBSET.—The employees included 
within the team or subset described in paragraph (1) 
may change as required to meet the needs of the In-
ternal Revenue Service, provided that procedures 
have been established to—
(A) ensure continuity of records and case 
history; and 
(B) notify the taxpayer when appropriate. 
SEC. 2008. NOTIFICATION OF SUSPECTED IDENTITY THEFT. 
(a) IN GENERAL.—Chapter 77 is amended by adding 
at the end the following new section: 
‘‘SEC. 
7529. 
NOTIFICATION 
OF 
SUSPECTED 
IDENTITY 
THEFT. 
‘‘(a) IN GENERAL.—If the Secretary determines that 
there has been or may have been an unauthorized use of 
the identity of any individual, the Secretary shall, without 
jeopardizing an investigation relating to tax administra-
tion— 
‘‘(1) as soon as practicable, notify the indi-
vidual of such determination and provide— 
‘‘(A) instructions on how to file a report 
with law enforcement regarding the unauthor-
ized use of the identity of the individual, 
‘‘(B) the identification of any forms nec-
essary for the individual to complete and submit 
to law enforcement to permit access to personal 
information of the individual during the inves-
tigation, 
‘‘(C) information regarding actions the in-
dividual may take in order to protect the indi-
vidual from harm relating to such unauthorized 
use, and 
‘‘(D) an offer of identity protection meas-
ures to be provided to the individual by the In-
ternal Revenue Service, such as the use of an 
identity protection personal identification num-
ber, and 
‘‘(2) at the time the information described in 
paragraph (1) is provided (or, if not available at 
such time, as soon as practicable thereafter), issue 
additional notifications to such individual (or such 
individual’s designee) regarding— 
‘‘(A) whether an investigation has been ini-
tiated in regards to such unauthorized use, 
‘‘(B) whether the investigation substan-
tiated an unauthorized use of the identity of the 
individual, and 
‘‘(C) whether— 
‘‘(i) any action has been taken against 
a person relating to such unauthorized use, 
or 
‘‘(ii) any referral has been made for 
criminal prosecution of such person and, to 
the extent such information is available,
whether such person has been criminally 
charged by indictment or information. 
‘‘(b) EMPLOYMENT-RELATED IDENTITY THEFT.— 
‘‘(1) IN GENERAL.—For purposes of this sec-
tion, the unauthorized use of the identity of an indi-
vidual includes the unauthorized use of the identity 
of the individual to obtain employment. 
‘‘(2) DETERMINATION
OF
EMPLOYMENT-RE-
LATED IDENTITY THEFT.—For purposes of this sec-
tion, in making a determination as to whether there 
has been or may have been an unauthorized use of 
the identity of an individual to obtain employment, 
the Secretary shall review any information— 
‘‘(A) obtained from a statement described 
in section 6051 or an information return relat-
ing to compensation for services rendered other 
than as an employee, or 
‘‘(B) provided to the Internal Revenue 
Service by the Social Security Administration 
regarding any statement described in section 
6051, 
which indicates that the social security account num-
ber provided on such statement or information re-
turn does not correspond with the name provided on 
such statement or information return or the name
on the tax return reporting the income which is in-
cluded on such statement or information return.’’. 
(b) ADDITIONAL MEASURES.— 
(1) EXAMINATION OF BOTH PAPER AND ELEC-
TRONIC
STATEMENTS
AND
RETURNS.—The Sec-
retary of the Treasury (or the Secretary’s delegate) 
shall examine the statements, information returns, 
and tax returns described in section 7529(b)(2) of 
the Internal Revenue Code of 1986 (as added by 
subsection (a)) for any evidence of employment-re-
lated identity theft, regardless of whether such state-
ments or returns are submitted electronically or on 
paper. 
(2) IMPROVEMENT
OF
EFFECTIVE
RETURN 
PROCESSING PROGRAM WITH SOCIAL SECURITY AD-
MINISTRATION.—Section 232 of the Social Security 
Act (42 U.S.C. 432) is amended by inserting after 
the third sentence the following: ‘‘For purposes of 
carrying out the return processing program de-
scribed in the preceding sentence, the Commissioner 
of Social Security shall request, not less than annu-
ally, 
such 
information 
described 
in 
section 
7529(b)(2) of the Internal Revenue Code of 1986 as 
may be necessary to ensure the accuracy of the 
records maintained by the Commissioner of Social
Security related to the amounts of wages paid to, 
and the amounts of self-employment income derived 
by, individuals.’’. 
(3) UNDERREPORTING OF INCOME.—The Sec-
retary (or the Secretary’s delegate) shall establish 
procedures to ensure that income reported in con-
nection with the unauthorized use of a taxpayer’s 
identity is not taken into account in determining any 
penalty for underreporting of income by the victim 
of identity theft. 
(c) CLERICAL AMENDMENT.—The table of sections 
for chapter 77 is amended by adding at the end the fol-
lowing new item: 
‘‘Sec. 7529. Notification of suspected identity theft.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to determinations made after the 
date that is 6 months after the date of the enactment of 
this Act. 
SEC. 2009. GUIDELINES FOR STOLEN IDENTITY REFUND 
FRAUD CASES. 
(a) IN GENERAL.—Not later than 1 year after the 
date of the enactment of this Act, the Secretary (or the 
Secretary’s delegate), in consultation with the National 
Taxpayer Advocate, shall develop and implement publicly 
available guidelines for management of cases involving sto-
len identity refund fraud in a manner that reduces the
administrative burden on taxpayers who are victims of 
such fraud. 
(b) STANDARDS AND PROCEDURES TO BE CONSID-
ERED.—The guidelines described in subsection (a) may in-
clude— 
(1) standards for— 
(A) the average length of time in which a 
case involving stolen identity refund fraud 
should be resolved; 
(B) the maximum length of time, on aver-
age, a taxpayer who is a victim of stolen iden-
tity refund fraud and is entitled to a tax refund 
which has been stolen should have to wait to re-
ceive such refund; and 
(C) the maximum number of offices and 
employees within the Internal Revenue Service 
with whom a taxpayer who is a victim of stolen 
identity refund fraud should be required to 
interact in order to resolve a case; 
(2) standards for opening, assigning, reas-
signing, or closing a case involving stolen identity re-
fund fraud; and 
(3) procedures for implementing and accom-
plishing the standards described in paragraphs (1) 
and (2), and measures for evaluating such proce-
dures and determining whether such standards have 
been successfully implemented. 
SEC. 2010. INCREASED PENALTY FOR IMPROPER DISCLO-
SURE OR USE OF INFORMATION BY PRE-
PARERS OF RETURNS. 
(a) IN GENERAL.—Section 6713 is amended— 
(1) by redesignating subsections (b) and (c) as 
subsections (c) and (d), respectively; and 
(2) by inserting after subsection (a) the fol-
lowing new subsection: 
‘‘(b) ENHANCED PENALTY FOR IMPROPER USE OR 
DISCLOSURE RELATING TO IDENTITY THEFT.— 
‘‘(1) IN GENERAL.—In the case of a disclosure 
or use described in subsection (a) that is made in 
connection with a crime relating to the misappro-
priation of another person’s taxpayer identity (as de-
fined in section 6103(b)(6)), whether or not such 
crime involves any tax filing, subsection (a) shall be 
applied— 
‘‘(A) by substituting ‘$1,000’ for ‘$250’, 
and 
‘‘(B) 
by 
substituting 
‘$50,000’ 
for 
‘$10,000’. 
‘‘(2) SEPARATE APPLICATION OF TOTAL PEN-
ALTY
LIMITATION.—The limitation on the total
amount of the penalty under subsection (a) shall be 
applied separately with respect to disclosures or uses 
to which this subsection applies and to which it does 
not apply.’’. 
(b) CRIMINAL PENALTY.—Section 7216(a) is amend-
ed by striking ‘‘$1,000’’ and inserting ‘‘$1,000 ($100,000 
in the case of a disclosure or use to which section 6713(b) 
applies)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures or uses on or after 
the date of the enactment of this Act. 
Subtitle B—Development of 
Information Technology 
SEC. 2101. MANAGEMENT OF INTERNAL REVENUE SERVICE 
INFORMATION TECHNOLOGY. 
(a) DUTIES AND RESPONSIBILITIES OF INTERNAL 
REVENUE SERVICE CHIEF INFORMATION OFFICER.—Sec-
tion 7803, as amended by section 1001, is amended by 
adding at the end the following new subsection: 
‘‘(f) INTERNAL REVENUE SERVICE CHIEF INFORMA-
TION OFFICER.— 
‘‘(1) IN GENERAL.—There shall be in the Inter-
nal Revenue Service an Internal Revenue Service 
Chief Information Officer (hereafter referred to in 
this subsection as the ‘IRS CIO’) who shall be ap-
pointed by the Commissioner of the Internal Rev-
enue Service. 
‘‘(2) CENTRALIZED
RESPONSIBILITY
FOR
IN-
TERNAL
REVENUE
SERVICE
INFORMATION
TECH-
NOLOGY.—The Commissioner of the Internal Rev-
enue Service (and the Secretary) shall act through 
the IRS CIO with respect to all development, imple-
mentation, and maintenance of information tech-
nology for the Internal Revenue Service. Any ref-
erence in this subsection to the IRS CIO which di-
rects the IRS CIO to take any action, or to assume 
any responsibility, shall be treated as a reference to 
the Commissioner of the Internal Revenue Service 
acting through the IRS CIO. 
‘‘(3) GENERAL
DUTIES
AND
RESPONSIBIL-
ITIES.—The IRS CIO shall— 
‘‘(A) be responsible for the development, 
implementation, and maintenance of informa-
tion technology for the Internal Revenue Serv-
ice, 
‘‘(B) ensure that the information tech-
nology of the Internal Revenue Service is secure 
and integrated,
‘‘(C) maintain operational control of all in-
formation technology for the Internal Revenue 
Service, 
‘‘(D) be the principal advocate for the in-
formation technology needs of the Internal Rev-
enue Service, and 
‘‘(E) consult with the Chief Procurement 
Officer of the Internal Revenue Service to en-
sure that the information technology acquired 
for the Internal Revenue Service is consistent 
with— 
‘‘(i) the goals and requirements speci-
fied in subparagraphs (A) through (D), 
and 
‘‘(ii) the strategic plan developed 
under paragraph (4). 
‘‘(4) STRATEGIC PLAN.— 
‘‘(A) IN
GENERAL.—The IRS CIO shall 
develop and implement a multiyear strategic 
plan for the information technology needs of the 
Internal Revenue Service. Such plan shall— 
‘‘(i) include performance measure-
ments of such technology and of the imple-
mentation of such plan,
‘‘(ii) include a plan for an integrated 
enterprise architecture of the information 
technology of the Internal Revenue Service, 
‘‘(iii) include and take into account 
the resources needed to accomplish such 
plan, 
‘‘(iv) take into account planned major 
acquisitions of information technology by 
the Internal Revenue Service, including 
Customer Account Data Engine 2 and the 
Enterprise Case Management System, and 
‘‘(v) align with the needs and stra-
tegic plan of the Internal Revenue Service. 
‘‘(B) PLAN
UPDATES.—The IRS CIO 
shall, not less frequently than annually, review 
and update the strategic plan under subpara-
graph (A) (including the plan for an integrated 
enterprise architecture described in subpara-
graph (A)(ii)) to take into account the develop-
ment of new information technology and the 
needs of the Internal Revenue Service. 
‘‘(5) SCOPE OF AUTHORITY.— 
‘‘(A) INFORMATION
TECHNOLOGY.—For 
purposes of this subsection, the term ‘informa-
tion technology’ has the meaning given such
term by section 11101 of title 40, United States 
Code. 
‘‘(B) INTERNAL REVENUE SERVICE.—Any 
reference in this subsection to the Internal Rev-
enue Service includes a reference to all compo-
nents of the Internal Revenue Service, includ-
ing— 
‘‘(i) the Office of the Taxpayer Advo-
cate, 
‘‘(ii) the Criminal Investigation Divi-
sion of the Internal Revenue Service, and 
‘‘(iii) except as otherwise provided by 
the Secretary with respect to information 
technology related to matters described in 
subsection (b)(3)(B), the Office of the 
Chief Counsel.’’. 
(b) INDEPENDENT VERIFICATION AND VALIDATION 
OF THE CUSTOMER ACCOUNT DATA ENGINE 2 AND EN-
TERPRISE CASE MANAGEMENT SYSTEM.— 
(1) IN GENERAL.—The Commissioner of the In-
ternal Revenue Service shall enter into a contract 
with an independent reviewer to verify and validate 
the implementation plans (including the performance 
milestones and cost estimates included in such 
plans) developed for the Customer Account Data
Engine 2 and the Enterprise Case Management Sys-
tem. 
(2) DEADLINE FOR COMPLETION.—Such con-
tract shall require that such verification and valida-
tion be completed not later than the date which is 
1 year after the date of the enactment of this Act. 
(3) APPLICATION TO PHASES OF CADE 2.— 
(A) IN GENERAL.—Paragraphs (1) and (2) 
shall not apply to phase 1 of the Customer Ac-
count Data Engine 2 and shall apply separately 
to each other phase. 
(B) 
DEADLINE
FOR
COMPLETING 
PLANS.—Not later than 1 year after the date of 
the enactment of this Act, the Commissioner of 
the Internal Revenue Service shall complete the 
development of plans for all phases of the Cus-
tomer Account Data Engine 2. 
(C) DEADLINE
FOR
COMPLETION
OF 
VERIFICATION AND VALIDATION OF PLANS.—In 
the case of any phase after phase 2 of the Cus-
tomer Account Data Engine 2, paragraph (2) 
shall be applied by substituting ‘‘the date on 
which the plan for such phase was completed’’ 
for ‘‘the date of the enactment of this Act’’.
(c) COORDINATION OF IRS CIO AND CHIEF PRO-
CUREMENT OFFICER OF THE INTERNAL REVENUE SERV-
ICE.— 
(1) IN GENERAL.—The Chief Procurement Offi-
cer of the Internal Revenue Service shall— 
(A) identify all significant IRS information 
technology acquisitions and provide written no-
tification to the Internal Revenue Service Chief 
Information Officer (hereafter referred to in 
this subsection as the ‘‘IRS CIO’’) of each such 
acquisition in advance of such acquisition, and 
(B) regularly consult with the IRS CIO re-
garding acquisitions of information technology 
for the Internal Revenue Service, including 
meeting with the IRS CIO regarding such ac-
quisitions upon request. 
(2) SIGNIFICANT
IRS
INFORMATION
TECH-
NOLOGY ACQUISITIONS.—For purposes of this sub-
section, the term ‘‘significant IRS information tech-
nology acquisitions’’ means— 
(A) any acquisition of information tech-
nology for the Internal Revenue Service in ex-
cess of $1,000,000; and 
(B) such other acquisitions of information 
technology for the Internal Revenue Service (or
categories of such acquisitions) as the IRS CIO, 
in consultation with the Chief Procurement Of-
ficer of the Internal Revenue Service, may iden-
tify. 
(3) SCOPE.—Terms used in this subsection 
which are also used in section 7803(f) of the Inter-
nal Revenue Code of 1986 (as amended by sub-
section (a)) shall have the same meaning as when 
used in such section. 
SEC. 2102. INTERNET PLATFORM FOR FORM 1099 FILINGS. 
(a) IN GENERAL.—Not later than January 1, 2023, 
the Secretary of the Treasury or the Secretary’s delegate 
(hereafter referred to in this section as the ‘‘Secretary’’) 
shall make available an Internet website or other elec-
tronic media, with a user interface and functionality simi-
lar to the Business Services Online Suite of Services pro-
vided by the Social Security Administration, that will pro-
vide access to resources and guidance provided by the In-
ternal Revenue Service and will allow persons to— 
(1) prepare and file Forms 1099; 
(2) prepare Forms 1099 for distribution to re-
cipients other than the Internal Revenue Service; 
and 
(3) maintain a record of completed and sub-
mitted Forms 1099.
(b) ELECTRONIC SERVICES TREATED AS SUPPLE-
MENTAL; APPLICATION OF SECURITY STANDARDS.—The 
Secretary shall ensure that the services described in sub-
section (a)— 
(1) are a supplement to, and not a replacement 
for, other services provided by the Internal Revenue 
Service to taxpayers; and 
(2) comply with applicable security standards 
and guidelines. 
SEC. 2103. STREAMLINED CRITICAL PAY AUTHORITY FOR 
INFORMATION TECHNOLOGY POSITIONS. 
(a) IN GENERAL.—Subchapter A of chapter 80 is 
amended by adding at the end the following new section: 
‘‘SEC. 7812. STREAMLINED CRITICAL PAY AUTHORITY FOR 
INFORMATION TECHNOLOGY POSITIONS. 
‘‘In the case of any position which is critical to the 
functionality of the information technology operations of 
the Internal Revenue Service— 
‘‘(1) section 9503 of title 5, United States 
Code, shall be applied— 
‘‘(A) by substituting ‘during the period be-
ginning on the date of the enactment of section 
7812 of the Internal Revenue Code of 1986, 
and ending on September 30, 2023’ for ‘Before 
September 30, 2013 in subsection (a)’,
Subtitle C—Modernization of Con-
sent-Based Income Verification 
System 
SEC. 2201. DISCLOSURE OF TAXPAYER INFORMATION FOR 
THIRD-PARTY INCOME VERIFICATION. 
(a) IN GENERAL.—Not later than 1 year after the 
close of the 2-year period described in subsection (d)(1), 
the Secretary of the Treasury or the Secretary’s delegate 
(hereafter referred to in this section as the ‘‘Secretary’’) 
shall implement a program to ensure that any qualified 
disclosure— 
(1) is fully automated and accomplished 
through the Internet; and 
(2) is accomplished in as close to real-time as 
is practicable. 
(b) QUALIFIED DISCLOSURE.—For purposes of this 
section, the term ‘‘qualified disclosure’’ means a disclosure 
under section 6103(c) of the Internal Revenue Code of 
1986 of returns or return information by the Secretary 
to a person seeking to verify the income or creditworthi-
ness of a taxpayer who is a borrower in the process of 
a loan application. 
(c) APPLICATION OF SECURITY STANDARDS.—The 
Secretary shall ensure that the program described in sub-
section (a) complies with applicable security standards and 
guidelines. 
(d) USER FEE.— 
(1) IN GENERAL.—During the 2-year period be-
ginning on the first day of the 6th calendar month 
beginning after the date of the enactment of this 
Act, the Secretary shall assess and collect a fee for 
qualified disclosures (in addition to any other fee as-
sessed and collected for such disclosures) at such 
rates as the Secretary determines are sufficient to 
cover the costs related to implementing the program 
described in subsection (a), including the costs of 
any necessary infrastructure or technology. 
(2) DEPOSIT OF COLLECTIONS.—Amounts re-
ceived from fees assessed and collected under para-
graph (1) shall be deposited in, and credited to, an 
account solely for the purpose of carrying out the 
activities described in subsection (a). Such amounts 
shall be available to carry out such activities without 
need of further appropriation and without fiscal year 
limitation.
SEC. 2202. LIMIT REDISCLOSURES AND USES OF CONSENT- 
BASED DISCLOSURES OF TAX RETURN INFOR-
MATION. 
(a) IN GENERAL.—Section 6103(c) is amended by 
adding at the end the following: ‘‘Persons designated by 
the taxpayer under this subsection to receive return infor-
mation shall not use the information for any purpose other 
than the express purpose for which consent was granted 
and shall not disclose return information to any other per-
son without the express permission of, or request by, the 
taxpayer.’’. 
(b) 
APPLICATION
OF
PENALTIES.—Section 
6103(a)(3) is amended by inserting ‘‘subsection (c),’’ after 
‘‘return information under’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures made after the date 
of the enactment of this Act. 
Subtitle D—Expanded Use of 
Electronic Systems 
SEC. 2301. ELECTRONIC FILING OF RETURNS. 
(a) IN GENERAL.—Section 6011(e)(2)(A) is amended 
by striking ‘‘250’’ and inserting ‘‘the applicable number 
of’’. 
(b) APPLICABLE
NUMBER.—Section 6011(e) is 
amended by striking paragraph (5) and inserting the fol-
lowing new paragraphs:
‘‘(5) APPLICABLE NUMBER.— 
‘‘(A) IN GENERAL.—For purposes of para-
graph (2)(A), the applicable number shall be— 
‘‘(i) except as provided in subpara-
graph (B), in the case of calendar years 
before 2020, 250, 
‘‘(ii) in the case of calendar year 
2020, 100, and 
‘‘(iii) in the case of calendar years 
after 2020, 10. 
‘‘(B) SPECIAL RULE FOR PARTNERSHIPS 
FOR 2018 AND 2019.—In the case of a partner-
ship, for any calendar year before 2020, the ap-
plicable number shall be— 
‘‘(i) in the case of calendar year 2018, 
200, and 
‘‘(ii) in the case of calendar year 
2019, 150. 
‘‘(6) PARTNERSHIPS
REQUIRED
TO
FILE
ON 
MAGNETIC
MEDIA.—Notwithstanding 
paragraph 
(2)(A), the Secretary shall require partnerships hav-
ing more than 100 partners to file returns on mag-
netic media.’’.
(c) RETURNS FILED
BY
A TAX RETURN PRE-
PARER.—Section 6011(e)(3) is amended by adding at the 
end the following new subparagraph: 
‘‘(D) EXCEPTION
FOR
CERTAIN
PRE-
PARERS LOCATED IN AREAS WITHOUT INTER-
NET ACCESS.—The Secretary may waive the re-
quirement of subparagraph (A) if the Secretary 
determines, on the basis of an application by 
the tax return preparer, that the preparer can-
not meet such requirement by reason of being 
located in a geographic area which does not 
have access to internet service (other than dial- 
up or satellite service).’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 2302. UNIFORM STANDARDS FOR THE USE OF ELEC-
TRONIC SIGNATURES FOR DISCLOSURE AU-
THORIZATIONS TO, AND OTHER AUTHORIZA-
TIONS OF, PRACTITIONERS. 
Section 6061(b)(3) is amended to read as follows: 
‘‘(3) PUBLISHED GUIDANCE.— 
‘‘(A) IN
GENERAL.—The Secretary shall 
publish guidance as appropriate to define and 
implement any waiver of the signature require-
ments or any method adopted under paragraph 
(1). 
‘‘(B) ELECTRONIC SIGNATURES FOR DIS-
CLOSURE AUTHORIZATIONS TO, AND OTHER AU-
THORIZATIONS OF, PRACTITIONERS.—Not later 
than 6 months after the date of the enactment 
of this subparagraph, the Secretary shall pub-
lish guidance to establish uniform standards 
and procedures for the acceptance of taxpayers’ 
signatures appearing in electronic form with re-
spect to any request for disclosure of a tax-
payer’s return or return information under sec-
tion 6103(c) to a practitioner or any power of 
attorney granted by a taxpayer to a practi-
tioner. 
‘‘(C) PRACTITIONER.—For purposes of 
subparagraph (B), the term ‘practitioner’ 
means any individual in good standing who is 
regulated under section 330 of title 31, United 
States Code.’’. 
SEC. 2303. PAYMENT OF TAXES BY DEBIT AND CREDIT 
CARDS. 
Section 6311(d)(2) is amended by adding at the end 
the following: ‘‘The preceding sentence shall not apply to 
the extent that the Secretary ensures that any such fee
or other consideration is fully recouped by the Secretary 
in the form of fees paid to the Secretary by persons paying 
taxes imposed under subtitle A with credit, debit, or 
charge cards pursuant to such contract. Notwithstanding 
the preceding sentence, the Secretary shall seek to mini-
mize the amount of any fee or other consideration that 
the Secretary pays under any such contract.’’. 
SEC. 2304. REQUIREMENT THAT ELECTRONICALLY PRE-
PARED PAPER RETURNS INCLUDE SCAN-
NABLE CODE. 
(a) IN GENERAL.—Subsection (e) of section 6011, as 
amended by this Act, is amended by adding at the end 
the following new paragraph: 
‘‘(7) SPECIAL RULE FOR RETURNS PREPARED 
ELECTRONICALLY AND SUBMITTED ON PAPER.—The 
Secretary shall require that any return of tax which 
is prepared electronically, but is printed and filed on 
paper, bear a code which can, when scanned, convert 
such return to electronic format.’’. 
(b) CONFORMING AMENDMENT.—Paragraph (1) of 
section 6011(e) is amended by striking ‘‘paragraph (3)’’ 
and inserting ‘‘paragraphs (3) and (7)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to returns of tax the due date for
which (determined without regard to extensions) is after 
December 31, 2020. 
SEC. 2305. AUTHENTICATION OF USERS OF ELECTRONIC 
SERVICES ACCOUNTS. 
Beginning 180 days after the date of the enactment 
of this Act, the Secretary of the Treasury (or the Sec-
retary’s delegate) shall verify the identity of any individual 
opening an e-Services account with the Internal Revenue 
Service before such individual is able to use the e-Services 
tools. 
Subtitle E—Other Provisions 
SEC. 2401. REPEAL OF PROVISION REGARDING CERTAIN 
TAX COMPLIANCE PROCEDURES AND RE-
PORTS. 
Section 2004 of the Internal Revenue Service Re-
structuring and Reform Act of 1998 (26 U.S.C. 6012 
note) is repealed. 
SEC. 2402. COMPREHENSIVE TRAINING STRATEGY. 
Not later than 1 year after the date of the enactment 
of this Act, the Commissioner of Internal Revenue shall 
submit to Congress a written report providing a com-
prehensive training strategy for employees of the Internal 
Revenue Service, including— 
(1) a plan to streamline current training proc-
esses, including an assessment of the utility of fur-
ther consolidating internal training programs, tech-
nology, and funding; 
(2) a plan to develop annual training regarding 
taxpayer rights, including the role of the Office of 
the Taxpayer Advocate, for employees that interface 
with taxpayers and their managers; 
(3) a plan to improve technology-based training; 
(4) proposals to— 
(A) focus employee training on early, fair, 
and efficient resolution of taxpayer disputes for 
employees that interface with taxpayers and 
their managers; and 
(B) ensure consistency of skill development 
and employee evaluation throughout the Inter-
nal Revenue Service; and 
(5) a thorough assessment of the funding nec-
essary to implement such strategy. 
TITLE III—MISCELLANEOUS 
PROVISIONS 
Subtitle A—Reform of Laws Gov-
erning Internal Revenue Serv-
ice Employees 
SEC. 3001. ELECTRONIC RECORD RETENTION. 
(a) RETENTION OF RECORDS.—
(1) IN GENERAL.—Email records of the Inter-
nal Revenue Service shall be retained in an appro-
priate electronic system that supports records man-
agement and litigation requirements, including the 
capability to identify, retrieve, and retain the 
records, in accordance with the requirements de-
scribed in paragraph (2). 
(2) REQUIREMENTS.— 
(A) PRIOR TO CERTIFICATION.—The Com-
missioner of Internal Revenue and the Chief 
Counsel for the Internal Revenue Service shall 
retain all email records generated on or after 
the date of the enactment of this Act and be-
fore the date on which the Treasury Inspector 
General for Tax Administration makes the cer-
tification under subsection (c)(1). 
(B) PRINCIPAL OFFICERS AND SPECIFIED 
EMPLOYEES.—Not later than December 31, 
2019, the Commissioner of Internal Revenue 
and the Chief Counsel for the Internal Revenue 
Service shall maintain email records of all prin-
cipal officers and specified employees of the In-
ternal Revenue Service for a period of not less 
than 15 years beginning on the date such 
record was generated.
(b) TRANSMISSION OF RECORDS TO THE NATIONAL 
ARCHIVES.—Not later than 15 years after the date on 
which an email record of a principal officer or specified 
employee of the Internal Revenue Service is generated, the 
Commissioner of Internal Revenue and the Chief Counsel 
for the Internal Revenue Service shall transfer such email 
record to the Archivist of the United States. 
(c) COMPLIANCE.— 
(1) CERTIFICATION.—On the date that the 
Treasury Inspector General for Tax Administration 
determines that the Internal Revenue Service has a 
program in place that complies with the require-
ments of subsections (a)(2)(B) and (b), the Treas-
ury Inspector General for Tax Administration shall 
certify to the Committee on Ways and Means of the 
House of Representatives and the Committee on Fi-
nance of the Senate that the Internal Revenue Serv-
ice is in compliance with such requirements. 
(2) REPORTS.— 
(A) INTERIM REPORT.—Not later than De-
cember 31, 2019, the Treasury Inspector Gen-
eral for Tax Administration shall submit a re-
port to the Committee on Ways and Means of 
the House of Representatives and the Com-
mittee on Finance of the Senate on the steps
being taken by the Commissioner of Internal 
Revenue and the Chief Counsel for the Internal 
Revenue Service to comply with the require-
ments of subsections (a)(2)(B) and (b). 
(B) FINAL REPORT.—Not later than April 
1, 2020, the Treasury Inspector General for 
Tax Administration shall submit a report to the 
Committee on Ways and Means of the House of 
Representatives and the Committee on Finance 
of the Senate describing whether the Internal 
Revenue Service is in compliance with the re-
quirements of subsections (a)(2)(B) and (b). 
(d) DEFINITIONS.—For purposes of this section— 
(1) PRINCIPAL OFFICER.—The term ‘‘principal 
officer’’ means, with respect to the Internal Revenue 
Service— 
(A) any employee whose position is listed 
under the Internal Revenue Service in the most 
recent version of the United States Government 
Manual published by the Office of the Federal 
Register; 
(B) any employee who is a senior staff 
member reporting directly to the Commissioner 
of Internal Revenue or the Chief Counsel for 
the Internal Revenue Service; and
(C) any associate counsel, deputy counsel, 
or division head in the Office of the Chief 
Counsel for the Internal Revenue Service. 
(2) SPECIFIED EMPLOYEE.—The term ‘‘speci-
fied employee’’ means, with respect to the Internal 
Revenue Service, any employee who— 
(A) holds a Senior Executive Service posi-
tion (as defined in section 3132 of title 5, 
United States Code) in the Internal Revenue 
Service or the Office of Chief Counsel for the 
Internal Revenue Service; and 
(B) is not a principal officer of the Inter-
nal Revenue Service. 
SEC. 3002. PROHIBITION ON REHIRING ANY EMPLOYEE OF 
THE INTERNAL REVENUE SERVICE WHO WAS 
INVOLUNTARILY SEPARATED FROM SERVICE 
FOR MISCONDUCT. 
(a) IN GENERAL.—Section 7804 is amended by add-
ing at the end the following new subsection: 
‘‘(d) PROHIBITION ON REHIRING EMPLOYEES INVOL-
UNTARILY SEPARATED.—The Commissioner may not hire 
any individual previously employed by the Commissioner 
who was removed for misconduct under this subchapter 
or chapter 43 or chapter 75 of title 5, United States Code, 
or whose employment was terminated under section 1203
of the Internal Revenue Service Restructuring and Reform 
Act of 1998 (26 U.S.C. 7804 note).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
subsection (a) shall apply with respect to the hiring of em-
ployees after the date of the enactment of this Act. 
SEC. 3003. NOTIFICATION OF UNAUTHORIZED INSPECTION 
OR DISCLOSURE OF RETURNS AND RETURN 
INFORMATION. 
(a) IN GENERAL.—Subsection (e) of section 7431 is 
amended by adding at the end the following new sen-
tences: ‘‘The Secretary shall also notify such taxpayer if 
the Internal Revenue Service or a Federal or State agency 
(upon notice to the Secretary by such Federal or State 
agency) proposes an administrative determination as to 
disciplinary or adverse action against an employee arising 
from the employee’s unauthorized inspection or disclosure 
of the taxpayer’s return or return information. The notice 
described in this subsection shall include the date of the 
unauthorized inspection or disclosure and the rights of the 
taxpayer under such administrative determination.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to determinations proposed after 
the date which is 180 days after the date of the enactment 
of this Act.
Subtitle B—Provisions Relating to 
Exempt Organizations 
SEC. 3101. MANDATORY E-FILING BY EXEMPT ORGANIZA-
TIONS. 
(a) IN GENERAL.—Section 6033 is amended by re-
designating subsection (n) as subsection (o) and by insert-
ing after subsection (m) the following new subsection: 
‘‘(n) MANDATORY ELECTRONIC FILING.—Any orga-
nization required to file a return under this section shall 
file such return in electronic form.’’. 
(b) CONFORMING AMENDMENT.—Paragraph (7) of 
section 527(j) is amended by striking ‘‘if the organization 
has’’ and all that follows through ‘‘such calendar year’’. 
(c) INSPECTION OF ELECTRONICALLY FILED AN-
NUAL RETURNS.—Subsection (b) of section 6104 is 
amended by adding at the end the following: ‘‘Any annual 
return required to be filed electronically under section 
6033(n) shall be made available by the Secretary to the 
public as soon as practicable in a machine readable for-
mat.’’. 
(d) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section 
shall apply to taxable years beginning after the date 
of the enactment of this Act.
(2) TRANSITIONAL RELIEF.— 
(A) SMALL ORGANIZATIONS.— 
(i) IN GENERAL.—In the case of any 
small organizations, or any other organiza-
tions for which the Secretary of the Treas-
ury or the Secretary’s delegate (hereafter 
referred to in this paragraph as the ‘‘Sec-
retary’’) determines the application of the 
amendments made by this section would 
cause undue burden without a delay, the 
Secretary may delay the application of 
such amendments, but such delay shall not 
apply to any taxable year beginning on or 
after the date 2 years after of the enact-
ment of this Act. 
(ii) SMALL ORGANIZATION.—For pur-
poses of clause (i), the term ‘‘small organi-
zation’’ means any organization— 
(I) the gross receipts of which for 
the 
taxable 
year 
are 
less 
than 
$200,000; and 
(II) the aggregate gross assets of 
which at the end of the taxable year 
are less than $500,000.
100 
(B) ORGANIZATIONS
FILING
FORM 990– 
T.—In the case of any organization described 
in section 511(a)(2) of the Internal Revenue 
Code of 1986 which is subject to the tax im-
posed by section 511(a)(1) of such Code on its 
unrelated business taxable income, or any orga-
nization required to file a return under section 
6033 of such Code and include information 
under subsection (e) thereof, the Secretary may 
delay the application of the amendments made 
by this section, but such delay shall not apply 
to any taxable year beginning on or after the 
date 2 years after of the enactment of this Act. 
SEC. 3102. NOTICE REQUIRED BEFORE REVOCATION OF 
TAX EXEMPT STATUS FOR FAILURE TO FILE 
RETURN. 
(a) IN GENERAL.—Section 6033(j)(1) is amended by 
striking ‘‘If an organization’’ and inserting the following: 
‘‘(A) NOTICE.— 
‘‘(i) IN GENERAL.—After an organiza-
tion described in subsection (a)(1) or (i) 
fails to file the annual return or notice re-
quired under either subsection for 2 con-
secutive years, the Secretary shall notify 
the organization—
101 
‘‘(I) that the Internal Revenue 
Service has no record of such a return 
or notice from such organization for 2 
consecutive years, and 
‘‘(II) about the revocation that 
will occur under subparagraph (B) if 
the organization fails to file such a re-
turn or notice by the due date for the 
next such return or notice required to 
be filed. 
The notification under the preceding sen-
tence shall include information about how 
to comply with the filing requirements 
under subsection (a)(1) and (i). 
‘‘(B) REVOCATION.—If an organization’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to failures to file returns or notices 
for 2 consecutive years if the return or notice for the sec-
ond year is required to be filed after December 31, 2018. 
Subtitle C—Tax Court 
SEC. 3301. DISQUALIFICATION OF JUDGE OR MAGISTRATE 
JUDGE OF THE TAX COURT. 
(a) IN GENERAL.—Part II of subchapter C of chap-
ter 76 is amended by adding at the end the following new 
section:
102 
‘‘SEC. 7467. DISQUALIFICATION OF JUDGE OR MAGISTRATE 
JUDGE OF THE TAX COURT. 
‘‘Section 455 of title 28, United States Code, shall 
apply to judges and magistrate judges of the Tax Court 
and to proceedings of the Tax Court.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for such part is amended by adding at the end the fol-
lowing new item: 
‘‘Sec. 7467. Disqualification of judge or magistrate judge of the Tax Court.’’. 
SEC. 3302. OPINIONS AND JUDGMENTS. 
(a) IN GENERAL.—Section 7459 is amended by strik-
ing all that precedes subsection (c) and inserting the fol-
lowing: 
‘‘SEC. 7459. OPINIONS AND JUDGMENTS. 
‘‘(a) REQUIREMENT.—An opinion upon any pro-
ceeding instituted before the Tax Court and a judgment 
thereon shall be made as quickly as practicable. The judg-
ment shall be made by a judge in accordance with the 
opinion of the Tax Court, and such judgment so made 
shall, when entered, be the judgment of the Tax Court. 
‘‘(b) INCLUSION OF FINDINGS OF FACT IN OPIN-
ION.—It shall be the duty of the Tax Court and of each 
division to include in its opinion or memorandum opinion 
upon any proceeding, its findings of fact. The Tax Court 
shall issue in writing all of its findings of fact, opinions, 
and memorandum opinions. Subject to such conditions as
103 
the Tax Court may by rule provide, the requirements of 
this subsection and of section 7460 are met if findings 
of fact or opinion are stated orally and recorded in the 
transcript of the proceedings.’’. 
(b) REFERENCES.—Section 7459 is amended by re-
designating subsection (g) as subsection (h) and by insert-
ing after subsection (f) the following new subsection: 
‘‘(g) REFERENCES.—Any reference in this title to a 
decision or report of the Tax Court shall be treated as 
a reference to a judgment or opinion of the Tax Court, 
respectively.’’. 
(c) CONFORMING AMENDMENT.—The item relating 
to section 7459 in the table of sections for part II of sub-
chapter C of chapter 76 is amended to read as follows: 
‘‘Sec. 7459. Opinions and judgments.’’. 
(d) CONTINUING EFFECT OF LEGAL DOCUMENTS.— 
All orders, decisions, reports, rules, permits, agreements, 
grants, contracts, certificates, licenses, registrations, privi-
leges, and other administrative actions, in connection with 
the Tax Court, which are in effect at the time this section 
takes effect, or were final before the effective date of this 
section and are to become effective on or after the effective 
date of this section, shall continue in effect according to 
their terms until modified, terminated, superseded, set 
aside, or revoked in accordance with law by the Tax Court.
104 
SEC. 3303. TITLE OF SPECIAL TRIAL JUDGE CHANGED TO 
MAGISTRATE JUDGE OF THE TAX COURT. 
(a) IN GENERAL.—Section 7443A is amended— 
(1) by striking ‘‘special trial judges’’ in sub-
sections (a) and (e) and inserting ‘‘magistrate 
judges of the Tax Court’’; 
(2) by striking ‘‘special trial judges of the 
court’’ in subsection (b) and inserting ‘‘magistrate 
judges of the Tax Court’’; and 
(3) by striking ‘‘special trial judge’’ in sub-
sections (c) and (d) and inserting ‘‘magistrate judge 
of the Tax Court’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The heading of section 7443A is amended 
by striking ‘‘SPECIAL TRIAL JUDGES’’ and insert-
ing 
‘‘MAGISTRATE
JUDGES
OF
THE
TAX 
COURT’’. 
(2) The heading of section 7443A(b) is amend-
ed by striking ‘‘SPECIAL TRIAL JUDGES’’ and insert-
ing ‘‘MAGISTRATE JUDGES OF THE TAX COURT’’. 
(3) The item relating to section 7443A in the 
table of sections for part I of subchapter C of chap-
ter 76 is amended to read as follows: 
‘‘Sec. 7443A. Magistrate judges of the Tax Court.’’.
105 
(4) The heading of section 7448 is amended by 
striking ‘‘SPECIAL TRIAL JUDGES’’ and inserting 
‘‘MAGISTRATE JUDGES OF THE TAX COURT’’. 
(5) Section 7448 is amended— 
(A) by striking ‘‘special trial judge’s’’ each 
place it appears in subsections (a)(6), (c)(1), 
(d), and (m)(1) and inserting ‘‘magistrate judge 
of the Tax Court’s’’; and 
(B) by striking ‘‘special trial judge’’ each 
place it appears other than in subsection (n) 
and inserting ‘‘magistrate judge of the Tax 
Court’’. 
(6) Section 7448(n) is amended— 
(A) by striking ‘‘special trial judge which 
are allowable’’ and inserting ‘‘magistrate judge 
of the Tax Court which are allowable’’; and 
(B) by striking ‘‘special trial judge of the 
Tax Court’’ both places it appears and inserting 
‘‘magistrate judge of the Tax Court’’. 
(7) The heading of section 7448(b)(2) is 
amended by striking ‘‘SPECIAL TRIAL JUDGES’’ and 
inserting ‘‘MAGISTRATE
JUDGES
OF
THE
TAX 
COURT’’.
106 
(8) The item relating to section 7448 in the 
table of sections for part I of subchapter C of chap-
ter 76 is amended to read as follows: 
‘‘Sec. 7448. Annuities to surviving spouses and dependent children of judges 
and magistrate judges of the Tax Court.’’. 
(9) Section 7456(a) is amended— 
(A) by striking ‘‘special trial judge’’ each 
place it appears and inserting ‘‘magistrate 
judge’’; and 
(B) by striking ‘‘(or by the clerk’’ and in-
serting ‘‘of the Tax Court (or by the clerk’’. 
(10) Section 7466(a) is amended by striking 
‘‘special trial judge’’ and inserting ‘‘magistrate 
judge’’. 
(11) Section 7470A is amended by striking 
‘‘special trial judges’’ both places it appears in sub-
sections (a) and (b) and inserting ‘‘magistrate 
judges’’. 
(12) Section 7471(a)(2)(A) is amended by 
striking ‘‘special trial judges’’ and inserting ‘‘mag-
istrate judges’’. 
(13) Section 7471(c) is amended— 
(A) by striking ‘‘SPECIAL TRIAL JUDGES’’ 
in the heading and inserting ‘‘MAGISTRATE 
JUDGES OF THE TAX COURT’’; and
107 
(B) by striking ‘‘special trial judges’’ and 
inserting ‘‘magistrate judges’’. 
SEC. 3304. REPEAL OF DEADWOOD RELATED TO BOARD OF 
TAX APPEALS. 
(a) Section 7459, as amended by this Act, is amended 
by striking subsection (f) and by redesignating subsections 
(g) and (h) as subsections (f) and (g), respectively. 
(b) Section 7447(a)(3) is amended to read as follows: 
‘‘(3) In any determination of length of service 
as judge or as a judge of the Tax Court of the 
United States there shall be included all periods 
(whether or not consecutive) during which an indi-
vidual served as judge.’’. 
Passed the House of Representatives December 20, 
2018. 
Attest: 
Clerk.