SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Presidential Tax Fil-
ings and Audit Transparency Act of 2022’’. 
SEC. 2. EXAMINATION AND DISCLOSURE WITH RESPECT TO 
PRESIDENTIAL INCOME TAX RETURNS. 
(a) AUDIT.—Subchapter A of chapter 78 of the Inter-
nal Revenue Code of 1986 is amended by redesignating 
section 7613 as section 7614 and by inserting after section 
7612 the following new section: 
‘‘SEC. 7613. EXAMINATION WITH RESPECT TO PRESI-
DENTIAL INCOME TAX RETURNS. 
‘‘(a) IN GENERAL.—As rapidly as practicable after 
the filing of any Presidential income tax return, the Sec-
retary shall conduct an examination to ascertain the cor-
rectness of such return and enforce the requirements of 
this title with respect to the taxable year covered by such 
return. 
‘‘(b) REPORTS.— 
‘‘(1) INITIAL REPORT.—Not later than 90 days 
after the filing of a Presidential income tax return, 
the Secretary shall disclose and make publicly avail-
able an initial report regarding the examination with 
respect to such return. Such report shall include— 
‘‘(A) the name of the taxpayer,
‘‘(B) an identification of the subparagraph 
of subsection (c)(1) which describes such re-
turn, 
‘‘(C) the date that such return was filed, 
and 
‘‘(D) the date on which the examination 
with respect to such return commenced (or, if 
such examination has not commenced as of the 
date of such report, a detailed description of the 
reasons that such examination has not com-
menced). 
‘‘(2) PERIODIC REPORTS.—Not later than 180 
days after the disclosure of the report described in 
paragraph (1) with respect to any Presidential in-
come tax return and not later than 180 days after 
the most recent disclosure of a report described in 
this paragraph with respect to such return, the Sec-
retary shall disclose and make publicly available a 
periodic report regarding the examination with re-
spect to such return. Such report shall include— 
‘‘(A) the information described in subpara-
graphs (A) through (D) of paragraph (1), 
‘‘(B) a description of the status of the ex-
amination, including a description of the por-
tions of the examination which have been com-
pleted, which are in process, and which are an-
ticipated to take place, and 
‘‘(C) an estimate of the time frame for the 
completion of the examination, including an 
identification of factors which could alter such 
time frame, reasonable estimates of the likeli-
hood of such factors (taking into account the 
specific facts and circumstances of the examina-
tion), and the likely specific effects of such fac-
tors on such time frame. 
Notwithstanding the preceding sentence, a periodic 
report shall not be required under this paragraph 
with respect to any return after the date on which 
a final report is disclosed under paragraph (3) with 
respect to such return. 
‘‘(3) FINAL REPORT.—Not later than 90 days 
after the completion of the examination described in 
subsection (a) with respect to any Presidential in-
come tax return, the Secretary shall disclose and 
make publicly available a final report regarding such 
examination. Such report shall include— 
‘‘(A) the information described in subpara-
graphs (A) through (C) of paragraph (1), 
‘‘(B) the date on which the examination 
with respect to such return was completed,
‘‘(C) a list of the audit materials (as de-
fined in section 6103(q)(2)) with respect to 
such examination, and 
‘‘(D) a description (including the amount) 
of each proposed adjustment, adjustment, and 
controversy with respect to such examination 
together with a description of how such pro-
posed adjustment or controversy was resolved 
(or a statement that such proposed adjustment 
or controversy was not resolved, as the case 
may be). 
For purposes of this paragraph, an examination 
shall be treated as complete on the date that the 
Secretary provides the taxpayer with a notice of defi-
ciency, or any closing document referred to in sec-
tion 6103(q)(2)(A)(v), with respect to such examina-
tion. 
‘‘(4) EXTENSION OF DUE DATE REPORT.—If a 
request is made for an extension of the due date for 
filing any Presidential income tax return, the Sec-
retary shall, not later than 90 days after such re-
quest is granted or denied, disclose and make pub-
licly available an extension of due date report with 
respect to return. Such report shall include—
‘‘(A) the information described in subpara-
graphs (A) and (B) of paragraph (1), 
‘‘(B) a statement that an extension of the 
due date for the filing of such return has been 
requested, 
‘‘(C) the date that such request was re-
ceived, 
‘‘(D) a statement of whether such request 
has been granted or denied, and 
‘‘(E) the due date of such return (includ-
ing any extensions). 
‘‘(5) TREATMENT
OF
FAILURE
TO
FILE.—In 
the case of a failure to file a Presidential income tax 
return before the close of the 60-day period begin-
ning with the date prescribed for filing of such re-
turn— 
‘‘(A) the Secretary shall conduct the exam-
ination described in subsection (a) with respect 
to the taxable year covered by the return to 
which such failure relates, 
‘‘(B) reports made pursuant to this para-
graph shall include a statement that such re-
port is with respect to a return which the tax-
payer failed to file, and
‘‘(C) this section and section 6103(q) shall 
otherwise apply to such failure in the same 
manner as if a return were filed at the close of 
such period. 
The application of this paragraph with respect to 
any failure to file a Presidential income tax return 
shall not prevent the application of this section with 
respect to such return at such time as such return 
may be filed. 
‘‘(6) PUBLIC AVAILABILITY.—For purposes of 
this subsection, a document shall not be treated as 
having been made publicly available unless made 
available on the Internet. 
‘‘(c) PRESIDENTIAL INCOME TAX RETURN.—For 
purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘Presidential in-
come tax return’ means any relevant income tax re-
turn of— 
‘‘(A) a President, 
‘‘(B) an individual who is married (within 
the meaning of section 7703(a)) to a President 
for the taxable year to which such return re-
lates, 
‘‘(C) any corporation or partnership which 
is controlled by any individual described in sub-
paragraph (A) or (B) at any time during the 
taxable year to which such return relates, 
‘‘(D) the estate of any person described in 
(A) or (B) or any estate with respect to which 
any person described in subparagraph (A), (B), 
or (C) is an executor, or beneficiary at any time 
during the taxable year to which such return 
relates, and 
‘‘(E) any trust with respect to which any 
person described in subparagraph (A), (B), (C), 
or (D) is a grantor, fiduciary or beneficiary, or 
for which another trust described in this sub-
paragraph is a grantor or beneficiary, at any 
time during the taxable year to which such re-
turn relates. 
Such term shall include any schedule, attachment, or 
other document filed with such return. 
‘‘(2) RELEVANT
INCOME
TAX
RETURN.—The 
term ‘relevant income tax return’ means, with re-
spect to a President, any income tax return if— 
‘‘(A) any portion of the taxable year to 
which such return relates is during the period 
that such President is the President, 
‘‘(B) the due date for such return (includ-
ing any extensions) is during such period, or
‘‘(C) such return is filed during such pe-
riod. 
‘‘(3) CONTROL.—For purposes of paragraph 
(1)(C)— 
‘‘(A) IN GENERAL.—Except as otherwise 
provided in this paragraph, control shall be de-
termined under the rules of paragraphs (2) and 
(3) of section 6038(e) (determined without re-
gard to subparagraphs (A) and (B) of such 
paragraph (2) and without regard to subpara-
graph (C) of paragraph (3) thereof). 
‘‘(B) RESTRICTION ON FAMILY ATTRIBU-
TION.— 
‘‘(i) IN
GENERAL.—Except as pro-
vided in clause (ii), for purposes of apply-
ing subparagraph (A)— 
‘‘(I) section 318 shall applied 
without 
regard 
to 
subsection 
(a)(1)(A)(ii) thereof, and 
‘‘(II) section 267(c) shall applied 
by treating the family of an individual 
as including only such individual’s 
spouse (in lieu of the application of 
paragraph (4) thereof).
‘‘(ii) EXCEPTION FOR RECENT TRANS-
FER TO FAMILY MEMBERS.—For purposes 
of determining whether any corporation or 
partnership is controlled by a President 
under paragraph (1)(C) for any taxable 
year, clause (i) shall not apply if such cor-
poration or partnership was controlled by 
such President (after application of clause 
(i)) at any time during the 4 immediately 
preceding taxable years. 
‘‘(d) APPLICATION
TO AMENDED RETURNS.—For 
purposes of this section and section 6103(q), any amend-
ment or supplement to a return of tax shall be treated 
as a separate return of tax and the determination of when 
such amendment or supplement is filed, and whether such 
amendment or supplement is a relevant income tax return, 
shall be made without regard to the underlying return.’’. 
(b) DISCLOSURE.—Section 6103 of such Code is 
amended by redesignating subsection (q) as subsection (r) 
and by inserting after subsection (p) the following new 
subsection: 
‘‘(q) DISCLOSURE WITH RESPECT TO PRESIDENTIAL 
INCOME TAX RETURNS.—
‘‘(1) IN
GENERAL.—The Secretary shall dis-
close and make publicly available (within the mean-
ing of section 7613(b))— 
‘‘(A) each Presidential income tax return 
(as defined in section 7613(c)), 
‘‘(B) each report described in section 
7613(b), and 
‘‘(C) any audit materials with respect a re-
turn described in subparagraph (A). 
‘‘(2) AUDIT MATERIALS.—The term ‘audit ma-
terials’ means, with respect to any return: 
‘‘(A) Any of the following which are pro-
vided by the Secretary to the taxpayer (or any 
designee of the taxpayer): 
‘‘(i) Any written communication which 
identifies such return as being subject to 
examination. 
‘‘(ii) 
Any 
written 
communication 
which proposes the adjustment of any item 
on such return, any report by an examiner 
related to such proposed adjustment, and 
any supervisory approval of any penalty 
proposed as part of such adjustment. 
‘‘(iii) Any memorandum or report of 
the Internal Revenue Service Independent
Office of Appeals with respect to such re-
turn, and any denial of any request de-
scribed in subparagraph (B). 
‘‘(iv) Any notice of deficiency with re-
spect to such return. 
‘‘(v) Any closing documents with re-
spect to the examination of such return, 
including any closing agreement or no 
change letter. 
‘‘(B) Any request for referral to the Inter-
nal Revenue Service Independent Office of Ap-
peals of any controversy with respect to such 
return. 
‘‘(C) Any petition filed with the Tax Court 
for a redetermination of any deficiency referred 
to in subparagraph (A)(iv). 
‘‘(3) EXCEPTION FOR CERTAIN IDENTITY IN-
FORMATION.—The information disclosed and made 
publicly available under paragraph (1) shall not in-
clude any identification number of any person (in-
cluding any social security number), any financial 
account number, the name of any individual who has 
not attained age 18 (as of the close of the taxable 
year to which the return relates), the name of any 
employee of the Department of the Treasury, or any
address (other than the city and State in which such 
address is located). 
‘‘(4) TIMING OF DISCLOSURES.—Any informa-
tion required to be disclosed under paragraph (1) 
shall be disclosed and made publicly available not 
later than— 
‘‘(A) in the case of any income tax return 
referred to in paragraph (1)(A), 90 days after 
the date that such return is filed, 
‘‘(B) in the case of any report referred to 
in paragraph (1)(B), the deadline specified in 
section 7613(b) for disclosing such report, and 
‘‘(C) in the case of the audit materials re-
ferred to in paragraph (1)(C), 90 days after the 
completion of the examination (within the 
meaning of section 7613(b)(3)) with respect to 
the return to which such audit materials re-
late.’’. 
(c) CLERICAL AMENDMENT.—Subchapter A of chap-
ter 78 of such Code is amended by redesignating the item 
relating to section 7613 as an item relating to section 
7614 and by inserting after the item relating to section 
7612 the following new item: 
‘‘Sec. 7613. Examination with respect to Presidential income tax returns.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this subsection shall apply to returns, amendments, and