SECTION 1. SHORT TITLE; ETC. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Taxpayer First Act’’. 
(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. 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. Identity protection personal identification numbers. 
Sec. 2006. Single point of contact for tax-related identity theft victims. 
Sec. 2007. Notification of suspected identity theft. 
Sec. 2008. Guidelines for stolen identity refund fraud cases. 
Sec. 2009. 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. 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. Prohibition on rehiring any employee of the Internal Revenue Serv-
ice who was involuntarily separated from service for mis-
conduct. 
Sec. 3002. 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—Revenue Provision 
Sec. 3201. Increase in penalty for failure to file. 
TITLE IV—BUDGETARY EFFECTS 
Sec. 4001. Determination of budgetary effects. 
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 Internal Revenue and shall be 
entitled to compensation at the same rate as 
the highest rate of basic pay established 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 
Internal Revenue without regard to the provi-
sions of title 5, United States Code, relating to 
appointments in the competitive service 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 Internal Revenue 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 Internal Revenue shall submit a 
written report to Congress on an annual basis 
which includes the number of requests described 
in subparagraph (A) which were denied and the 
reasons (described by category) that such re-
quests were denied. 
‘‘(C) PROCEDURES FOR PROTESTING DE-
NIAL OF REQUEST.—The Commissioner of In-
ternal Revenue shall prescribe procedures for 
protesting to the Commissioner of Internal Rev-
enue a denial of a request described in subpara-
graph (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, 
to the extent practicable, 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 million for the 
taxable year to which the dispute re-
lates.
‘‘(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 (or the Secretary’s delegate) 
shall submit to Congress a written comprehensive cus-
tomer service strategy for the Internal 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. 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 
that is 45 days 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, 2020.
(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 
which is 45 days 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 In-
ternal Revenue— 
‘‘(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 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.—Upon request of the National Tax-
payer Advocate, the Secretary shall, to the extent prac-
ticable, provide the National Taxpayer Advocate with sta-
tistical support in connection with the preparation by the
National Taxpayer Advocate of the annual report de-
scribed in section 7803(c)(2)(B)(ii). Such statistical sup-
port shall include statistical studies, compilations, and the 
review of information 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 striking ‘‘and’’ at the end of 
subclause (XI), by redesignating subclause 
(XII) as subclause (XIII), and by inserting 
after subclause (XI) the following new sub-
clause: 
‘‘(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; and’’. 
(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 
March 31, 2019. 
SEC. 1302. MODERNIZATION OF INTERNAL REVENUE SERV-
ICE ORGANIZATIONAL STRUCTURE. 
(a) IN GENERAL.—Not later than September 30, 
2020, the Secretary of the Treasury (or the Secretary’s 
delegate) shall submit to Congress a comprehensive writ-
ten plan to redesign the organization of the Internal Rev-
enue 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 of Internal Rev-
enue. 
(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 plan 
described in subsection (a) is submitted to Congress.
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 million 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) REFERRALS
TO
LOW-INCOME
TAXPAYER 
CLINICS.—Qualified return preparation programs re-
ceiving 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) 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 is amended by strik-
ing ‘‘or become greatly reduced in price or value by keep-
ing, 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 the Treasury, the 
Treasury Inspector General for Tax Adminis-
tration, the Comptroller General of the United 
States, the Department of Justice, the United 
States Congress, a person with supervisory au-
thority over the employee, or any other person 
working for the employer who has the authority 
to investigate, discover, or terminate mis-
conduct, 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, the Secretary 
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 not transferred to the account of the 
taxpayer; 
‘‘(2) coordination with financial institutions for 
the purpose of— 
‘‘(A) identifying the accounts to which 
transfers described in paragraph (1) were 
made; and
‘‘(B) recovery of the amounts so trans-
ferred; 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, 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-