Title: Protecting Taxpayers Act
Policy area: Taxation

Summary:
Protecting Taxpayers Act
This bill modifies the organizational structure, management practices, and enforcement procedures of the Internal Revenue Service (IRS).
The bill modifies policies regarding:

[Congressional Bills 115th Congress]
[From the U.S. Government Publishing Office]
[S. 3278 Introduced in Senate (IS)]

<DOC>






115th CONGRESS
  2d Session
                                S. 3278

   To amend the Internal Revenue Code of 1986 to provide additional 
                       protections to taxpayers.


_______________________________________________________________________


                   IN THE SENATE OF THE UNITED STATES

                             July 26, 2018

Mr. Portman (for himself and Mr. Cardin) introduced the following bill; 
     which was read twice and referred to the Committee on Finance

_______________________________________________________________________

                                 A BILL


 
   To amend the Internal Revenue Code of 1986 to provide additional 
                       protections to taxpayers.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE; TABLE OF CONTENTS.

    (a) Short Title.--This Act may be cited as the ``Protecting 
Taxpayers Act''.
    (b) Table of Contents.--The table of contents of this Act is as 
follows:

Sec. 1. Short title; table of contents.
Sec. 2. Amendment of Internal Revenue Code of 1986.
                    TITLE I--MANAGEMENT AND TRAINING

Sec. 101. Internal Revenue Service Management Board.
Sec. 102. Comprehensive training strategy.
Sec. 103. Streamlining centralized training program approval.
                     TITLE II--TAXPAYER PROTECTION

Sec. 201. Quarterly notices of delinquency.
Sec. 202. Regulation of tax return preparers.
Sec. 203. Misdirected tax refund deposits.
      TITLE III--SMALL BUSINESS TAX ADMINISTRATION AND COMPLIANCE

Sec. 301. Safe harbor for employer tip reporting.
Sec. 302. Information reporting of income from certain rentals of space 
                            in the beauty service industry.
Sec. 303. Release of Federal tax levies which cause business hardship.
Sec. 304. Extension of time for making S corporation elections.
Sec. 305. Quarterly reporting of estimated tax payments.
                 TITLE IV--RETIREMENT PLANS AND SAVINGS

Sec. 401. Expansion of employee plans compliance resolution system.
              TITLE V--ASSISTANCE FOR LOW-INCOME TAXPAYERS

Sec. 501. Establishment of income threshold for referral to private 
                            debt collection.
Sec. 502. Return preparation programs for applicable taxpayers.
Sec. 503. Low-income taxpayer clinics.
Sec. 504. Low-income exception for payments otherwise required in 
                            connection with a submission of an offer-
                            in-compromise.
                       TITLE VI--APPEALS PROCESS

Sec. 601. Right to independent conference.
Sec. 602. Access to case files.
Sec. 603. Ensuring taxpayer right to appeal.
Sec. 604. Limitation on designation of cases as not eligible for 
                            referral to Independent Office of Appeals.
Sec. 605. Procedures related to Secretarial authority to designate 
                            cases for litigation.
                        TITLE VII--MISCELLANEOUS

Sec. 701. Modification of authority to issue designated summons.
Sec. 702. Streamlined critical pay authority for information technology 
                            positions.
Sec. 703. Uniform standards for the use of electronic signatures for 
                            disclosure authorizations to, and other 
                            authorizations of, practitioners.
Sec. 704. Limitation on access of non-Internal Revenue Service 
                            employees to returns and return 
                            information.

SEC. 2. AMENDMENT OF INTERNAL REVENUE CODE OF 1986.

    Except as otherwise expressly provided, whenever in this Act an 
amendment 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 provision of the Internal Revenue Code of 
1986.

                    TITLE I--MANAGEMENT AND TRAINING

SEC. 101. INTERNAL REVENUE SERVICE MANAGEMENT BOARD.

    (a) In General.--Section 7802 is amended--
            (1) in the heading, by striking ``oversight board'' and 
        inserting ``management board'',
            (2) by striking ``Oversight Board'' each place it appears 
        and inserting ``Management Board'',
            (3) in subsection (b)--
                    (A) in paragraph (1)--
                            (i) in subparagraph (A), by striking 
                        ``six'' and inserting ``four'',
                            (ii) by striking subparagraph (B) and 
                        inserting the following:
                    ``(B) one non-voting member shall be the Deputy 
                Secretary of the Treasury.'',
                            (iii) in subparagraph (C), by inserting 
                        ``non-voting'' before ``member'', and
                            (iv) by adding at the end the following new 
                        subparagraph:
                    ``(E) one non-voting member shall be the Deputy 
                Inspector General for Tax Administration.'',
                    (B) in paragraph (4), by striking ``Five members'' 
                and inserting ``Three voting members'', and
                    (C) in paragraph (5), by striking subparagraph (B) 
                and inserting the following:
                    ``(B) Ex officio members.--An individual described 
                in subparagraph (B), (C), or (E) of paragraph (1) shall 
                be removed upon termination of service in the office 
                described in such subparagraph.'',
            (4) in subsection (c)(1)(B), by inserting ``and that all 
        employees of the Internal Revenue Service are familiar with and 
        act in accordance with the Taxpayer Bill of Rights'' before the 
        period, and
            (5) in subsection (d)--
                    (A) in paragraph (1)--
                            (i) in subparagraph (A), by striking 
                        ``and'' at the end,
                            (ii) by striking subparagraph (B) and 
                        inserting the following:
                    ``(B) long-range strategic plans, and'', and
                            (iii) by adding at the end the following:
                    ``(C) an annual performance report and plan.'',
                    (B) in paragraph (3)--
                            (i) in subparagraph (B)--
                                    (I) by striking ``selection, 
                                evaluation, and compensation'' and 
                                inserting ``selection and evaluation'', 
                                and
                                    (II) by striking ``and'' at the 
                                end,
                            (ii) by redesignating subparagraph (C) as 
                        subparagraph (D), and
                            (iii) by inserting after subparagraph (B) 
                        the following:
                    ``(C) review and approve the Commissioner's 
                compensation of Internal Revenue Service senior 
                executives described in subparagraph (B); and'',
                    (C) in paragraph (4)--
                            (i) in subparagraph (B), by striking 
                        ``and'' at the end,
                            (ii) by redesignating subparagraph (C) as 
                        subparagraph (D), and
                            (iii) by inserting after subparagraph (B) 
                        the following:
                    ``(C) review any changes made to such budget 
                request by the Office of Management and Budget prior to 
                submission of the President's annual budget request to 
                Congress; and'', and
                    (D) by inserting after paragraph (5) the following:
            ``(6) Audits.--To direct the Treasury Inspector General for 
        Tax Administration to perform an audit of any programs or 
        operations of the Internal Revenue Service.''.
    (b) Conforming Amendments.--
            (1) Section 4946(c)(7) is amended by striking ``Oversight 
        Board'' and inserting ``Management Board''.
            (2) Paragraph (6) of section 6103(h) is amended--
                    (A) in the heading, by striking ``Oversight board'' 
                and inserting ``Management board'', and
                    (B) by striking ``Oversight Board'' each place it 
                appears and inserting ``Management Board''.
            (3) Section 7803 is amended--
                    (A) in subsection (a)(4), by striking ``Oversight 
                Board'' and inserting ``Management Board'', and
                    (B) in subsection (c)--
                            (i) in paragraph (1)(B)(ii), by striking 
                        ``Oversight Board'' and inserting ``Management 
                        Board'', and
                            (ii) in paragraph (2)(B)(iii), by striking 
                        ``Oversight Board'' and inserting ``Management 
                        Board''.
    (c) Effective Date.--The amendments made by this section shall take 
effect on the date of the enactment of this Act.

SEC. 102. COMPREHENSIVE TRAINING STRATEGY.

    Not later than 1 year after the date of the enactment of this Act, 
the Commissioner of Internal Revenue, in consultation with the National 
Taxpayer Advocate, shall submit to Congress a written report providing 
a comprehensive training strategy for employees of the Internal Revenue 
Service, including--
            (1) a plan to streamline current training processes, 
        including an assessment of the utility of further consolidating 
        internal training programs, technology, and funding,
            (2) a plan to develop annual training regarding taxpayer 
        rights, including the role of the Office of the Taxpayer 
        Advocate,
            (3) a plan to improve technology-based training, including 
        by developing or adopting state-of-the-art training delivery 
        methods,
            (4) proposals to focus employee training on early, fair, 
        and efficient resolution of taxpayer disputes and to ensure 
        consistency of skill development and employee evaluation 
        throughout the Internal Revenue Service,
            (5) recommendations for improvement of employee 
        recruitment, and
            (6) a thorough assessment of the funding necessary to 
        implement such strategy.

SEC. 103. STREAMLINING CENTRALIZED TRAINING PROGRAM APPROVAL.

    The Secretary of the Treasury, or the Secretary's delegate, shall 
modify the policy promulgated under Treasury Directive 12-70 to permit 
employee training events (as defined by the Secretary or the 
Secretary's delegate) for employees of the Internal Revenue Service, 
the cost to the Internal Revenue Service of which exceeds $249,999 (but 
does not exceed $500,000), to be approved by a Deputy Commissioner of 
Internal Revenue.

                     TITLE II--TAXPAYER PROTECTION

SEC. 201. QUARTERLY NOTICES OF DELINQUENCY.

    (a) In General.--Section 7524 is amended--
            (1) in the heading, by striking ``annual'' and inserting 
        ``quarterly'', and
            (2) by striking ``annually'' and inserting ``each calendar 
        quarter''.
    (b) Effective Date.--The amendments made by this section shall 
apply to any calendar quarter beginning after December 31, 2018.

SEC. 202. REGULATION OF TAX RETURN PREPARERS.

    (a) In General.--Subsection (a) of section 330 of title 31, United 
States Code, is amended--
            (1) by striking paragraph (1) and inserting the following:
            ``(1) regulate--
                    ``(A) the practice of representatives of persons 
                before the Department of the Treasury; and
                    ``(B) the practice of tax return preparers; and'', 
                and
            (2) in paragraph (2)--
                    (A) by inserting ``or a tax return preparer to 
                prepare tax returns'' after ``practice'',
                    (B) by inserting ``or tax return preparer'' before 
                ``demonstrate'', and
                    (C) by inserting ``or in preparing their tax 
                returns, claims for refund, or documents in connection 
                with tax returns or claims for refund'' after ``cases'' 
                in subparagraph (D).
    (b) Authority To Sanction Regulated Tax Return Preparers.--
Subsection (c) of section 330 of title 31, United States Code, is 
amended--
            (1) by striking ``before the Department'',
            (2) by inserting ``or tax return preparer'' after 
        ``representative'' each place it appears, and
            (3) in paragraph (4), by striking ``misleads or threatens'' 
        and all that follows and inserting ``misleads or threatens--
                    ``(A) any person being represented or any 
                prospective person being represented; or
                    ``(B) any person or prospective person whose tax 
                return, claim for refund, or document in connection 
                with a tax return or claim for refund, is being or may 
                be prepared.''.
    (c) Minimum Competency Standards for Tax Return Preparers.--Section 
330 of title 31, United States Code, is amended by adding at the end 
the following new subsection:
    ``(f) Tax Return Preparers.--
            ``(1) In general.--Any tax return preparer shall 
        demonstrate minimum competency standards under this subsection 
        by--
                    ``(A) obtaining an identifying number for securing 
                proper identification of such preparer as described in 
                section 6109(a)(4) of the Internal Revenue Code of 
                1986;
                    ``(B) satisfying any examination and annual 
                continuing education requirements as prescribed by the 
                Secretary; and
                    ``(C) completing a background check administered by 
                the Secretary.
            ``(2) Exemption.--The Secretary shall exempt tax return 
        preparers who have been subject to comparable examination, 
        continuing education requirements, and background checks 
        administered by the Secretary or any comparable State licensing 
        program. Such exemption shall extend directly to individuals 
        who are supervised by such preparers and are not required to 
        secure an identification number under section 6109(a)(4).''.
    (d) Tax Return Preparer Defined.--Section 330 of title 31, United 
States Code, as amended by subsection (c), is amended by adding at the 
end the following new subsection:
    ``(g) Tax Return Preparer.--For purposes of this section--
            ``(1) In general.--The term `tax return preparer' has the 
        meaning given such term under section 7701(a)(36) of the 
        Internal Revenue Code of 1986.
            ``(2) Tax return.--The term `tax return' has the meaning 
        given to the term `return' under section 6696(e)(1) of the 
        Internal Revenue Code of 1986.
            ``(3) Claim for refund.--The term `claim for refund' has 
        the meaning given such term under section 6696(e)(2) of such 
        Code.''.
    (e) Amendments With Respect to Identifying Number.--
            (1) In general.--Section 6109(a) is amended by striking 
        paragraph (4) and inserting the following:
            ``(4) Furnishing identifying number of tax return 
        preparer.--
                    ``(A) In general.--Any return or claim for refund 
                prepared by a tax return preparer shall bear such 
                identifying number for securing proper identification 
                of such preparer, his employer, or both, as may be 
                prescribed. For purposes of this paragraph, the terms 
                `return' and `claim for refund' have the respective 
                meanings given to such terms by section 6696(e).
                    ``(B) Exception.--Subparagraph (A) shall not apply 
                to any tax return preparer who prepares a return or 
                claim for refund under the supervision and direction of 
                a tax return preparer who signs the return or claim for 
                refund and is a certified public accountant, an 
                attorney or enrolled agent.''.
            (2) Clarification of rescission authority.--Section 6109 is 
        amended by inserting after subsection (d) the following new 
        subsection:
    ``(e) Authority To Rescind Identifying Number of Tax Return 
Preparer.--
            ``(1) In general.--The Secretary may rescind an identifying 
        number issued under subsection (a)(4) if--
                    ``(A) after notice and opportunity for a hearing, 
                the preparer is shown to be incompetent or disreputable 
                (as such terms are used in subsection (c) of section 
                330 of title 31, United States Code), and
                    ``(B) rescinding the identifying number would 
                promote compliance with the requirements of this title 
                and effective tax administration.
            ``(2) Records.--If an identifying number is rescinded under 
        paragraph (1), the Secretary shall place in the file in the 
        Office of the Director of Professional Responsibility the 
        opinion of the Secretary with respect to the determination, 
        including--
                    ``(A) a statement of the facts and circumstances 
                relating to the determination, and
                    ``(B) the reasons for the rescission.''.
    (f) GAO Study and Report on the Exchange of Information Between the 
IRS and State Taxation Authorities.--
            (1) In general.--Not later than 18 months after the date of 
        the enactment of this Act, the Comptroller General shall 
        conduct a study and submit to Congress a report on the sharing 
        of information between the Secretary of the Treasury and State 
        authorities, as authorized under section 6103(d) of the 
        Internal Revenue Code of 1986, regarding identification numbers 
        issued to paid tax return preparers and return preparer minimum 
        standards.
            (2) Increased information sharing.--The study and report 
        described in paragraph (1) shall include an analysis of the 
        impact that increased information sharing between Federal and 
        State authorities would have on efforts to enforce minimum 
        standards on paid tax return preparers.

SEC. 203. 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 January 1, 
2019, 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 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 described in 
                paragraph (1); and
                    ``(B) recovery of the erroneously transferred 
                amounts; and
            ``(3) the refund to be delivered to the correct account of 
        the taxpayer.''.

      TITLE III--SMALL BUSINESS TAX ADMINISTRATION AND COMPLIANCE

SEC. 301. SAFE HARBOR FOR EMPLOYER TIP REPORTING.

    (a) In General.--Subsection (q) of section 3121 is amended--
            (1) by striking ``For purposes of this chapter'' and 
        inserting the following:
            ``(1) In general.--For purposes of this chapter'', and
            (2) by adding at the end the following:
            ``(2) Tip program safe harbor.--In the case of an employer 
        for which 1 or more employees receive tips in the course of 
        their employment which are considered remuneration for such 
        employment under paragraph (1), the Secretary shall not 
        initiate a tip examination (as that term is used in the model 
        Tip Reporting Alternative Commitment agreement promulgated by 
        the Internal Revenue Service) of the employer (except in 
        relation to a tip examination of 1 or more employees or former 
        employees of such employer) if such employer has demonstrated 
        that it has--
                    ``(A) established an educational program regarding 
                the applicable laws relating to the proper reporting of 
                tips received by employees for--
                            ``(i) new employees, which shall include 
                        both verbal explanations and written materials; 
                        and
                            ``(ii) existing employees, which shall be 
                        conducted quarterly;
                    ``(B) established procedures for employees who 
                receive tips to, in accordance with section 6053(a), 
                provide monthly reporting of their cash and charged 
                services and any related tips of $20 or greater;
                    ``(C) complied with any requirements applicable to 
                employers for purposes of filing returns and collection 
                and payment of taxes imposed with respect to tips 
                received by employees; and
                    ``(D) maintained employee records related to--
                            ``(i) contact information for such 
                        employees; and
                            ``(ii) gross receipts from any services 
                        subject to tipping and charge receipts for such 
                        services for a period of not less than 4 
                        calendar years after the calendar year to which 
                        such records relate.''.
    (b) Effective Date.--The amendments made by this section shall 
apply to tips received for services performed after December 31, 2018.

SEC. 302. INFORMATION REPORTING OF INCOME FROM CERTAIN RENTALS OF SPACE 
              IN THE BEAUTY SERVICE INDUSTRY.

    (a) In General.--Subpart B of part III of subchapter A of chapter 
61 is amended by inserting after section 6050Y the following new 
section:

``SEC. 6050Z. RETURNS WITH RESPECT TO INCOME FROM CERTAIN RENTALS OF 
              SPACE FOR BEAUTY SERVICES.

    ``(a) In General.--Any person who, in connection with its trade or 
business or rental activity, receives rental income from 2 or more 
individuals providing beauty services in excess of $600 each for a 
calendar year for the rental of space to provide such beauty services 
to third-party patrons, shall make a return with respect to each such 
individual, at such time and in such manner as the Secretary shall 
prescribe, which shall include--
            ``(1) the name, address, and TIN of such individual,
            ``(2) the total amount received from such individual during 
        such calendar year, including the date and amount of each 
        payment, and
            ``(3) such additional information as the Secretary may 
        require.
    ``(b) Statements To Be Furnished to Persons With Respect to Whom 
Information Is Required To Be Furnished.--
            ``(1) In general.--Every person required to make a return 
        under subsection (a) shall furnish to each individual whose 
        name is required to be set forth in such return a written 
        statement showing--
                    ``(A) the name, address, and phone number of the 
                information contact of the person required to make such 
                return, and
                    ``(B) the aggregate amount of payments to the 
                person required to be shown on such return.
            ``(2) Furnishing of information.--The written statement 
        required under paragraph (1) shall be furnished to the 
        individual on or before January 31 of the year following the 
        calendar year for which the return under subsection (a) was 
        made.
    ``(c) Regulations and Guidance.--The Secretary may prescribe such 
regulations and other guidance as may be appropriate or necessary to 
carry out the purposes of this section, including rules to prevent 
duplicative reporting of transactions.
    ``(d) Beauty Service.--For purposes of this section, the term 
`beauty service' means--
            ``(1) barbering and hair care,
            ``(2) nail care,
            ``(3) esthetics, and
            ``(4) body and spa treatments.''.
    (b) Conforming Amendments.--
            (1) Section 6724(d)(1)(B) is amended by striking ``or'' at 
        the end of clause (xxv), by striking ``and'' at the end of 
        clause (xxvi) and inserting ``or'', and by inserting after 
        clause (xxvi) the following new clause:
                            ``(xvii) section 6050X(a) (relating to 
                        information reporting with respect to rentals 
                        of space for beauty services), and''.
            (2) Paragraph (2) of section 6724(d) is amended--
                    (A) by striking ``or'' at the end of subparagraph 
                (II),
                    (B) by striking the period at the end of the first 
                subparagraph (JJ) and inserting a comma,
                    (C) by redesignating the second subparagraph (JJ) 
                as subparagraph (KK),
                    (D) in subparagraph (KK), as redesignated by 
                subparagraph (C), by striking the period at the end and 
                inserting ``, or'', and
                    (E) by inserting after subparagraph (KK) the 
                following new subparagraph:
                    ``(LL) section 6050Z(b)(1) (relating to statements 
                to providers of beauty services).''.
            (3) The table of sections for subpart B of part III of 
        subchapter A of chapter 61 is amended by adding after the item 
        relating to section 6050Y the following new item:

``Sec. 6050Z. Returns with respect to income from certain rentals of 
                            space for beauty services.''.
    (c) Effective Date.--The amendments made by this section shall 
apply to calendar years after 2018.

SEC. 303. RELEASE OF FEDERAL TAX LEVIES WHICH CAUSE BUSINESS HARDSHIP.

    (a) In General.--Subparagraph (D) of section 6343(a)(1) is amended 
by inserting ``or any trade or business of the taxpayer'' before ``, 
or''.
    (b) Criteria for Determining Business Hardship.--Subsection (a) of 
section 6343 is amended by adding at the end the following new 
paragraph:
            ``(4) Criteria for determining business hardship.--For 
        purposes of making a determination under paragraph (1)(D), with 
        respect to a trade or business of the taxpayer, the Secretary 
        shall take into consideration--
                    ``(A) the economic viability of such trade or 
                business,
                    ``(B) the nature and extent of the hardship, 
                including the extent to which the taxpayer exercised 
                ordinary business care and prudence, and
                    ``(C) any hardships which would be caused to other 
                individuals or businesses if such trade or business 
                were liquidated.''.
    (c) Effective Date.--The amendments made by this section shall take 
effect on the date of the enactment of this Act.

SEC. 304. EXTENSION OF TIME FOR MAKING S CORPORATION ELECTIONS.

    (a) In General.--Subsection (b) of section 1362 is amended to read 
as follows:
    ``(b) When Made.--
            ``(1) In general.--An election under subsection (a) may be 
        made by a small business corporation for any taxable year not 
        later than the due date for filing the return of the S 
        corporation for such taxable year (including extensions).
            ``(2) Certain elections treated as made for next taxable 
        year.--If--
                    ``(A) an election under subsection (a) is made for 
                any taxable year within the period described in 
                paragraph (1), but
                    ``(B) either--
                            ``(i) on 1 or more days in such taxable 
                        year and before the day on which the election 
                        was made the corporation did not meet the 
                        requirements of subsection (b) of section 1361, 
                        or
                            ``(ii) 1 or more of the persons who held 
                        stock in the corporation during such taxable 
                        year and before the election was made did not 
                        consent to the election,
                then such election shall be treated as made for the 
                following taxable year.
            ``(3) Authority to treat late elections, etc., as timely.--
        If--
                    ``(A) an election under subsection (a) is made for 
                any taxable year after the date prescribed by this 
                subsection for making such election for such taxable 
                year or no such election is made for any taxable year, 
                and
                    ``(B) the Secretary determines that there was 
                reasonable cause for the failure to timely make such 
                election,
        the Secretary may treat such an election as timely made for 
        such taxable year.
            ``(4) Election on timely filed returns.--Except as 
        otherwise provided by the Secretary, an election under 
        subsection (a) for any taxable year may be made on a timely 
        filed return of the S corporation for such taxable year.
            ``(5) Secretarial authority.--The Secretary may prescribe 
        such regulations, rules, or other guidance as may be necessary 
        or appropriate for purposes of applying this subsection.''.
    (b) Coordination With Certain Other Provisions.--
            (1) Qualified subchapter s subsidiaries.--Section 
        1361(b)(3)(B) is amended by adding at the end the following 
        flush sentence:
                ``Rules similar to the rules of section 1362(b) shall 
                apply with respect to any election under clause 
                (ii).''.
            (2) Qualified subchapter s trusts.--Section 1361(d)(2) is 
        amended by striking subparagraph (D).
    (c) Revocations.--Paragraph (1) of section 1362(d) is amended--
            (1) by striking ``subparagraph (D)'' in subparagraph (C) 
        and inserting ``subparagraphs (D) and (E)'', and
            (2) by adding at the end the following new subparagraph:
                    ``(E) Authority to treat late revocations as 
                timely.--If--
                            ``(i) a revocation under subparagraph (A) 
                        is made for any taxable year after the date 
                        prescribed by this paragraph for making such 
                        revocation for such taxable year or no such 
                        revocation is made for any taxable year, and
                            ``(ii) the Secretary determines that there 
                        was reasonable cause for the failure to timely 
                        make such revocation,
                the Secretary may treat such a revocation as timely 
                made for such taxable year.''.
    (d) Effective Date.--
            (1) In general.--Except as otherwise provided in this 
        subsection, the amendments made by this section shall apply to 
        elections for taxable years beginning after December 31, 2018.
            (2) Revocations.--The amendments made by subsection (c) 
        shall apply to revocations after December 31, 2018.

SEC. 305. QUARTERLY REPORTING OF ESTIMATED TAX PAYMENTS.

    (a) In General.--The table contained in paragraph (2) of section 
6654(c) is amended--
            (1) by striking ``June 15'' and inserting ``July 15'', and
            (2) by striking ``September 15'' and inserting ``October 
        15''.
    (b) Effective Date.--The amendments made by this section shall 
apply to installments due in taxable years beginning after December 31, 
2018.

                 TITLE IV--RETIREMENT PLANS AND SAVINGS

SEC. 401. EXPANSION OF EMPLOYEE PLANS COMPLIANCE RESOLUTION SYSTEM.

    (a) In General.--Except as otherwise provided in regulations 
prescribed by the Secretary of the Treasury or the Secretary's delegate 
(referred to in this section as the ``Secretary''), any inadvertent 
failure to comply with the rules applicable under section 401(a), 
403(a), 403(b), 408(p), or 408(k) of the Internal Revenue Code of 1986 
may be self-corrected under the Employee Plans Compliance Resolution 
System (as described in Revenue Procedure 2016-51 or any successor 
guidance), except to the extent that such failure was identified by 
Secretary prior to any actions that demonstrate a commitment to 
implement a self-correction.
    (b) Loan Error.--The Secretary of Labor shall treat any loan error 
corrected pursuant to subsection (a) as meeting the requirements of the 
Voluntary Fiduciary Correction Program of the Department of Labor.
    (c) EPCRS for IRAs.--The Secretary shall expand the Employee Plans 
Compliance Resolution System to allow custodians of individual 
retirement plans to address inadvertent errors for which the owner of 
an individual retirement plan was not at fault, including (but not 
limited to)--
            (1) waivers of the excise tax that would otherwise apply 
        under section 4974 of the Internal Revenue Code of 1986;
            (2) under the self-correction component of the Employee 
        Plans Compliance Resolution System, waivers of the 60-day 
        deadline for a rollover where the deadline is missed for 
        reasons beyond the reasonable control of the account owner; and
            (3) rules permitting a nonspouse beneficiary to return 
        distributions to an inherited individual retirement plan 
        described in section 408(d)(3)(C) of the Internal Revenue Code 
        of 1986 in a case where, due to an inadvertent error by a 
        service provider, the beneficiary had reason to believe that 
        the distribution could be rolled over without inclusion in 
        income of any part of the distributed amount.
    (d) Required Minimum Distribution Corrections.--The Secretary shall 
expand the Employee Plans Compliance Resolution System to allow plans 
to which such system applies and custodians of individual retirement 
plans to self-correct, without an excise tax, any inadvertent errors 
pursuant to which a distribution is made no more than 180 days after it 
was required to be made.
    (e) Additional Safe Harbors.--The Secretary shall expand the 
Employee Plans Compliance Resolution System (as described in Revenue 
Procedure 2016-51 or any successor guidance) to provide additional safe 
harbor means of correcting inadvertent failures described in subsection 
(a), including safe harbor means of calculating the earnings that must 
be restored to a plan in cases where plan assets have been depleted by 
reason of an inadvertent failure.

              TITLE V--ASSISTANCE FOR LOW-INCOME TAXPAYERS

SEC. 501. ESTABLISHMENT OF INCOME THRESHOLD FOR REFERRAL TO PRIVATE 
              DEBT COLLECTION.

    (a) In General.--Section 6306(d)(3) is amended by striking ``or'' 
at the end of subparagraph (C), by adding ``or'' at the end of 
subparagraph (D), and by inserting after subparagraph (D) the following 
new subparagraph:
                    ``(E) in the case of a tax receivable which is 
                identified by the Secretary (or the Secretary's 
                delegate) during the period beginning on the date which 
                is 180 days after the date of the enactment of this Act 
                and ending on December 31, 2019, a taxpayer who is an 
                individual with adjusted gross income, as determined 
                for the most recent taxable year for which such 
                information is available, which does not exceed 250 
                percent of the applicable poverty level (as determined 
                by the Secretary),''.
    (b) Effective Date.--The amendments made by this section shall 
apply to tax receivables identified by the Secretary of the Treasury 
(or the Secretary's delegate) after the date which is 180 days after 
the date of the enactment of this Act.

SEC. 502. RETURN PREPARATION PROGRAMS FOR APPLICABLE TAXPAYERS.

    (a) In General.--Chapter 77 is amended by inserting after section 
7526 the following new section:

``SEC. 7526A. RETURN PREPARATION PROGRAMS FOR APPLICABLE TAXPAYERS.

    ``(a) Establishment of Volunteer Income Tax Assistance Matching 
Grant Program.--The Secretary shall establish a Community Volunteer 
Income Tax Assistance Matching Grant Program under which the Secretary 
may, subject to the availability of appropriated funds, make grants to 
provide matching funds for the development, 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 preparation programs 
        may use grants received under this section for--
                    ``(A) ordinary and necessary costs associated with 
                program operation in accordance with cost principles 
                under the applicable Office of Management and Budget 
                circular, including--
                            ``(i) wages or salaries of persons 
                        coordinating the activities of the program,
                            ``(ii) developing training materials, 
                        conducting training, and performing quality 
                        reviews of the returns prepared under the 
                        program,
                            ``(iii) equipment purchases, and
                            ``(iv) vehicle-related expenses associated 
                        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 establishment 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 program,
                    ``(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 containing such information as the 
        Secretary may reasonably require.
            ``(2) Priority.--In awarding grants under this section, the 
        Secretary shall give priority to applications 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 determining matching 
        grants under this section, the Secretary shall only take into 
        account amounts provided by the qualified return preparation 
        program for expenses described in subsection (b).
    ``(d) Program Adherence.--
            ``(1) In general.--The Secretary shall establish procedures 
        for, and shall conduct not less frequently than once every 5 
        calendar years during which a qualified return preparation 
        program is operating 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 adherence 
                        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 provides sufficient 
        documentation of corrective measures established to address any 
        such deficiencies determined.
    ``(e) Definitions.--For purposes of this section--
            ``(1) Qualified return preparation program.--The term 
        `qualified return preparation program' means any program--
                    ``(A) which provides assistance to individuals, not 
                less than 90 percent of whom are applicable taxpayers, 
                in preparing and filing Federal 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 cooperative 
                        agreements, and
                            ``(iv) agrees to provide documentation to 
                        substantiate any matching funds provided 
                        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 enactment 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 section 
                        501(c) and exempt from tax under section 
                        501(a),
                            ``(iii) a local government agency, 
                        including--
                                    ``(I) a county or municipal 
                                government agency, and
                                    ``(II) an Indian tribe, as defined 
                                in section 4(13) of the Native American 
                                Housing Assistance and Self-
                                Determination Act of 1996 (25 U.S.C. 
                                4103(13)), including any tribally 
                                designated housing entity (as defined 
                                in section 4(22) of such Act (25 U.S.C. 
                                4103(22))), tribal subsidiary, 
                                subdivision, or other wholly owned 
                                tribal entity,
                            ``(iv) a local, State, regional, or 
                        national coalition (with one lead organization 
                        which meets the eligibility requirements of 
                        clause (i), (ii), or (iii) acting as the 
                        applicant organization), or
                            ``(v) in the case of applicable taxpayers 
                        and members of underserved populations with 
                        respect to which no organizations described in 
                        the preceding clauses are available--
                                    ``(I) a State government agency, or
                                    ``(II) an office providing 
                                Cooperative Extension services (as 
                                established at the land-grant colleges 
                                and universities under the Smith-Lever 
                                Act of May 8, 1914).
            ``(3) Applicable taxpayers.--The term `applicable taxpayer' 
        means a taxpayer whose income for the taxable year does not 
        exceed an amount equal to the completed phaseout amount under 
        section 32(b) for a married couple filing a joint return with 3 
        or more qualifying children, as determined in a revenue 
        procedure or other published guidance.
            ``(4) Underserved population.--The term `underserved 
        population' includes populations of persons 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 Secretary is authorized to 
        award a multi-year grant not to exceed 3 years.
            ``(2) Aggregate limitation.--Unless otherwise provided by 
        specific appropriation, the Secretary 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 promote tax 
        preparation through qualified return preparation programs 
        through the use of mass communications and other means.
            ``(2) Provision of information regarding qualified return 
        preparation programs.--The Secretary may provide taxpayers 
        information regarding qualified return preparation programs 
        receiving grants under this section.
            ``(3) VITA grantee referral.--Qualified return 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 taxpayer clinics 
                receiving funding under section 7526, and
                    ``(B) provide information regarding the location 
                of, and contact information for, such clinics.''.
    (b) Clerical Amendment.--The table of sections for chapter 77 is 
amended by inserting after the item relating to section 7526 the 
following new item:

``Sec. 7526A. Return preparation programs for applicable taxpayers.''.

SEC. 503. LOW-INCOME TAXPAYER CLINICS.

    (a) Promotion of Clinics.--Section 7526 is amended by adding at the 
end the following new subsection:
    ``(d) Promotion of Clinics.--The Secretary is authorized to promote 
the benefits of and encourage the use of qualified low-income taxpayer 
clinics through the use of mass communications, referrals, and other 
means.''.
    (b) IRS Referrals to Clinics.--Subsection (c) of section 7526 is 
amended by adding at the end the following new paragraph:
            ``(6) IRS referrals.--Notwithstanding any other provision 
        of law, the Secretary may refer taxpayers to specific qualified 
        low-income taxpayer clinics receiving funding under this 
        section.''.
    (c) Effective Date.--The amendments made by this section shall take 
effect on the date of the enactment of this Act.

SEC. 504. LOW-INCOME EXCEPTION FOR PAYMENTS OTHERWISE 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 taxpayers.--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 
        individual with adjusted gross income, as determined for the 
        most recent taxable year for which such information is 
        available, which does not exceed 250 percent of the applicable 
        poverty level (as determined 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.

                       TITLE VI--APPEALS PROCESS

SEC. 601. RIGHT TO INDEPENDENT CONFERENCE.

    (a) In General.--Section 1001 of the Internal Revenue Service 
Restructuring and Reform Act of 1998 is amended by redesignating 
subsection (c) as subsection (d) and by inserting after subsection (b) 
the following new subsection:
    ``(c) Right to Independent Conference.--Under the organization plan 
of the Internal Revenue Service, a taxpayer shall have the right to a 
conference with the Internal Revenue Service Office of Appeals which 
does not include personnel from the Office of Chief Counsel for the 
Internal Revenue Service or the compliance functions of the Internal 
Revenue Service unless the taxpayer specifically consents to the 
participation of such personnel.''.
    (b) Effective Date.--This section shall apply to conferences 
occurring after the date of the enactment of this Act.

SEC. 602. ACCESS TO CASE FILES.

    (a) In General.--In the case of any specified taxpayer with respect 
to which a conference with the Internal Revenue Service Office of 
Appeals has been scheduled, the taxpayer shall be 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 Service) not later than 10 days before the date of 
such conference.
    (b) Taxpayer Election To Expedite Conference.--If the taxpayer so 
elects, subsection (a) shall be applied by substituting ``the date of 
such conference'' for ``10 days before the date of such conference''.
    (c) Specified Taxpayer.--For purposes of this section:
            (1) In general.--The term ``specified taxpayer'' means--
                    (A) in the case of any taxpayer who is a natural 
                person, a taxpayer whose adjusted gross income does not 
                exceed $400,000, and
                    (B) in the case of any other taxpayer, a taxpayer 
                whose gross receipts do not exceed $5,000,000.
            (2) Aggregation rule.--Rules similar to the rules of 
        section 448(c)(2) of the Internal Revenue Code of 1986 shall 
        apply for purposes of paragraph (1)(B).
    (d) Effective Date.--This section shall apply to conferences 
occurring after the date which is 1 year after the date of the 
enactment of this Act.

SEC. 603. ENSURING TAXPAYER RIGHT TO APPEAL.

    (a) In General.--Subsection (a) of section 6212 is amended--
            (1) by striking ``In General.--If the Secretary'' and 
        inserting ``In General.--
            ``(1) Authorization.--If--
                    ``(A) the Secretary'',
            (2) by striking ``44, he is authorized'' and inserting 
        ``44, and
                    ``(B) the requirements of paragraph (2) have been 
                met with respect to such deficiency,
        the Secretary is authorized'', and
            (3) by adding at the end the following new paragraph:
            ``(2) Opportunity for administrative review in the office 
        of appeals.--
                    ``(A) In general.--The requirements of this 
                paragraph are met with respect to a deficiency if, 
                prior to the issuance of the notice of deficiency under 
                paragraph (1)--
                            ``(i) the taxpayer has been issued a letter 
                        of proposed deficiency that explains the basis 
                        for the determination of deficiency and allows 
                        the taxpayer an opportunity for administrative 
                        review in the Internal Revenue Service Office 
                        of Appeals, and
                            ``(ii) either--
                                    ``(I) the time provided in such 
                                letter for contacting the Office of 
                                Appeals has expired and the taxpayer 
                                has not so contacted such Office, or
                                    ``(II) the Office of Appeals has 
                                issued a decision with respect to such 
                                deficiency.
                    ``(B) Frivolous tax positions.--The Secretary is 
                authorized to issue regulations limiting the 
                application of subparagraph (A) in cases involving 
                solely the failure or refusal to comply with the tax 
                laws because of moral, religious, political, 
                constitutional, conscientious, or similar grounds, or 
                for other positions listed as frivolous under section 
                6702(c).
                    ``(C) Cases designated for litigation.--
                Subparagraph (A) shall not apply in the case of issues 
                designated for litigation in accordance with section 
                7124.''.
    (b) Opportunity for Appeal if Fewer Than 60 Days Remain on Statute 
of Limitations.--Section 6212 is amended by adding at the end the 
following new subsection:
    ``(e) Opportunity for Appeal if Fewer Than 60 Days Remain on 
Statute of Limitations.--In the case of any issues relating to a 
potential deficiency with respect to which 60 days or fewer remain in 
the period applicable under section 6501, if the taxpayer agrees to the 
extension of such period by 12 months, the Secretary shall issue a 
letter of proposed deficiency described in subsection (a)(2)(A)(i) 
allowing the taxpayer an opportunity for administrative review of such 
issues in the Internal Revenue Service Office of Appeals before a 
notice of deficiency is issued under this section. Rules similar to the 
rules of subsection (a)(2)(B) shall apply for purposes of this 
subsection.''.
    (c) Effective Date.--The amendments made by this section shall 
apply to notices of deficiency issued after the date of the enactment 
of this Act.

SEC. 604. 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 notice of 
deficiency authorized under section 6212 of the Internal Revenue Code 
of 1986 requests referral to the Internal Revenue Service Office of 
Appeals and such request is denied, the Commissioner of Internal 
Revenue shall provide such taxpayer a written notice which--
            (1) provides a detailed description of the facts involved, 
        the basis for the decision to deny the request, and a detailed 
        explanation of how the basis of such decision applies to such 
        facts, and
            (2) describes the procedures proscribed under subsection 
        (c) for protesting the decision to deny the request.
    (b) Report to Congress.--The Commissioner of Internal Revenue shall 
submit a written report to Congress on an annual basis which includes 
the number of requests described in subsection (a) which were denied 
and the reasons (described by category) that such requests were denied.
    (c) Procedures for Protesting Denial of Request.--The Commissioner 
of Internal Revenue shall prescribe procedures for protesting to the 
Commissioner of Internal Revenue (personally and not through any 
delegate) a denial of a request described in subsection (a).
    (d) Not Applicable to Frivolous Positions.--This section shall not 
apply to a request for referral to the Internal Revenue Service Office 
of Appeals which is denied on the basis that the issue involved is a 
frivolous position (within the meaning of section 6702(c) of the 
Internal Revenue Code of 1986).

SEC. 605. PROCEDURES RELATED TO SECRETARIAL AUTHORITY TO DESIGNATE 
              CASES FOR LITIGATION.

    (a) In General.--Chapter 74 is amended by redesignating section 
7124 as section 7125 and by inserting after section 7123 the following 
new section:

``SEC. 7124. PROCEDURES RELATED TO SECRETARIAL AUTHORITY TO DESIGNATE 
              CASES FOR LITIGATION.

    ``(a) In General.--For any matter which the Commissioner of 
Internal Revenue and the Chief Counsel for the Internal Revenue Service 
have determined shall be designated for litigation, such determination 
shall be--
            ``(1) based on a joint written recommendation by the 
        Commissioner of the relevant operating division of the Internal 
        Revenue Service and the Division Counsel for such operating 
        division, which shall include an explanation as to why the 
        designation is preferable to other means of resolving the 
        matter, and
            ``(2) made in consultation with the Associate Chief Counsel 
        with relevant subject matter jurisdiction over such matter.
    ``(b) Notification Prior to Recommendation.--Prior to submission of 
a recommendation described in subsection (a)(1), the Division Counsel 
for the relevant operating division of the Internal Revenue Service 
shall provide written notification to the taxpayer regarding the 
recommendation, including--
            ``(1) a description of the issues recommended for 
        designation and the reasons for such recommendation, and
            ``(2) notification that the taxpayer's views may be 
        presented in writing or in person to the Division Counsel and 
        the Commissioner of the relevant operating division--
                    ``(A) within 60 days of such notification, or
                    ``(B) prior to such other date as the taxpayer and 
                the Division Counsel may agree.
    ``(c) Notification After Recommendation.--Not later than 30 days 
after submission of a recommendation described in subsection (a)(1), 
the Division Counsel for the relevant operating division of the 
Internal Revenue Service shall provide written notification to the 
taxpayer regarding submission of the recommendation, including 
notification that the taxpayer's views may be presented in writing or 
in person to the Commissioner of Internal Revenue and the Chief Counsel 
for the Internal Revenue Service--
            ``(1) within 60 days of such notification, or
            ``(2) prior to such other date as the taxpayer, the 
        Commissioner of Internal Revenue, and the Chief Counsel for the 
        Internal Revenue Service may agree.
    ``(d) Notice of Approval of Designation.--For any matter which the 
Commissioner of Internal Revenue and the Chief Counsel for the Internal 
Revenue Service have determined shall be designated for litigation--
            ``(1) the Division Counsel for the relevant operating 
        division of the Internal Revenue Service shall provide written 
        notification to the taxpayer regarding such determination, and
            ``(2) the jurisdiction of the Internal Revenue Service 
        Office of Appeals over such matter shall be limited solely to 
        any issues not included in such designation.
    ``(e) Rescinding of Designation.--The Chief Counsel for the 
Internal Revenue Service may rescind any designation of a matter for 
litigation if the Chief Counsel determines that continuation of such 
litigation does not serve the purpose for which such designation was 
originally made.''.
    (b) Clerical Amendment.--The table of sections for chapter 74 is 
amended by striking the item relating to section 7124 and inserting the 
following new items:

``Sec. 7124. Procedures related to Secretarial authority to designate 
                            cases for litigation.
``Sec. 7125. Cross references.''.
    (c) Effective Date.--The amendments made by this section shall 
apply to the designation of issues for litigation occurring after the 
date of the enactment of this Act.

                        TITLE VII--MISCELLANEOUS

SEC. 701. MODIFICATION OF AUTHORITY TO ISSUE DESIGNATED SUMMONS.

    (a) In General.--Paragraph (1) of section 6503(j) is amended by 
striking ``coordinated examination program'' and inserting 
``coordinated industry case program''.
    (b) Designated 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 Large Business and 
                        International Division Commissioner and the 
                        Division Counsel of the Office of Chief Counsel 
                        (or their successors)--
                                    ``(I) which clearly establishes 
                                that the taxpayer did not reasonably 
                                cooperate with reasonable requests by 
                                the Secretary for witnesses, documents, 
                                meetings, and interviews, and
                                    ``(II) which is attached to such 
                                summons,''.
    (c) Burden of Proof.--Subsection (j) of section 6503 is amended by 
adding at the end the following new paragraph:
            ``(4) Burden of proof.--In any court proceeding described 
        in paragraph (3), the Secretary shall bear the burden of 
        proving that the corporation described in paragraph (1) did not 
        reasonably cooperate with reasonable requests by the Secretary 
        for witnesses, documents, meetings, and interviews.''.
    (d) Effective Date.--The amendments made by this section shall 
apply to summonses issued after the date of the enactment of this Act.

SEC. 702. STREAMLINED CRITICAL PAY AUTHORITY FOR INFORMATION TECHNOLOGY 
              POSITIONS.

    (a) Authority.--Section 9503(a) of title 5, United States Code, is 
amended--
            (1) in the matter preceding paragraph (1), by striking 
        ``the Secretary of the Treasury'' and all that follows through 
        ``establish'' and inserting ``the Secretary of the Treasury 
        may, during the period beginning on October 1, 2018, and ending 
        on September 30, 2023, establish'', and
            (2) in paragraph (1)(B), by striking ``the Internal Revenue 
        Service's successful accomplishment of an important mission'' 
        and inserting ``the functionality of the information technology 
        operations of the Internal Revenue Service''.
    (b) Recruitment, Retention, Relocation Incentives, and Relocation 
Expenses.--Section 9504 of title 5, United States Code, is amended--
            (1) in subsection (a)--
                    (A) by striking ``Before September 30, 2013'' and 
                inserting ``During the period beginning on October 1, 
                2018, and ending on September 30, 2023'', and
                    (B) by inserting ``for employees holding positions 
                described in section 9503(a)(1)'' after ``incentives'', 
                and
            (2) in subsection (b)--
                    (A) by striking ``Before September 30, 2013'' and 
                inserting ``During the period beginning on October 1, 
                2018, and ending on September 30, 2023'',
                    (B) by striking ``employees transferred or 
                reemployed'' and inserting ``employees holding 
                positions described in section 9503(a)(1) who are 
                transferred or reemployed during such period'', and
                    (C) by striking ``section 9502 or 9503 after June 
                1, 1998'' and inserting ``section 9503 during such 
                period''.
    (c) Performance Awards for Senior Executives.--Section 9505(a) of 
title 5, United States Code, is amended--
            (1) by striking ``Before September 30, 2013'' and inserting 
        ``During the period beginning on October 1, 2018, and ending on 
        September 30, 2023'', and
            (2) by striking ``significant functions'' and inserting 
        ``the information technology operations''.
    (d) Effective Date.--The amendments made by this section shall 
apply to payments made on or after the date of the enactment of this 
Act.

SEC. 703. UNIFORM STANDARDS FOR THE USE OF ELECTRONIC SIGNATURES FOR 
              DISCLOSURE AUTHORIZATIONS TO, AND OTHER AUTHORIZATIONS 
              OF, PRACTITIONERS.

    Paragraph (3) of section 6061(b) 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 requirements or any method 
                adopted under paragraph (1).
                    ``(B) Electronic signatures for disclosure 
                authorizations to, and other authorizations of, 
                practitioners.--Not later than 6 months after the date 
                of the enactment of this subparagraph, the Secretary 
                shall publish guidance to establish uniform standards 
                and procedures for the acceptance of taxpayers' 
                signatures appearing in commercially provided 
                electronic form with respect to any request for 
                disclosure of a taxpayer's return or return information 
                under section 6103(c) to a practitioner or any power of 
                attorney granted by a taxpayer to a practitioner.
                    ``(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. 704. LIMITATION ON ACCESS OF NON-INTERNAL REVENUE SERVICE 
              EMPLOYEES TO RETURNS AND RETURN INFORMATION.

    (a) In General.--Section 7602 is amended by adding at the end the 
following new subsection:
    ``(f) Limitation on Access of Persons Other Than Internal Revenue 
Service Officers and Employees.--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 person requires such 
information for the sole purpose of providing expert evaluation and 
assistance to the Internal Revenue Service. No person other than an 
officer or employee 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 pursuant to this section.''.
    (b) Effective Date.--
            (1) In general.--Except as provided in paragraph (2), the 
        amendment made by this section shall take effect on the date of 
        the enactment of this Act.
            (2) Application to contracts in effect.--The amendment made 
        by this section shall apply to any contract in effect under 
        section 6103(n) of the Internal Revenue Code of 1986, pursuant 
        to temporary Treasury Regulation section 301.7602-1T proposed 
        in Internal Revenue Bulletin 2014-28, Treasury Regulation 
        section 301.7602-1(b)(3), or any similar or successor 
        regulation, that is in effect on the date of the enactment of 
        this Act.
                                 <all>