Taxpayer First Act
PL 116-25 (H.R.3151), enacted 07/01/2019

[116th Congress Public Law 25]
[From the U.S. Government Publishing Office]



[[Page 133 STAT. 981]]

Public Law 116-25
116th Congress

                                 An Act


 
To amend the Internal Revenue Code of 1986 to modernize and improve the 
   Internal Revenue Service, and for other purposes. <<NOTE: July 1, 
                         2019 -  [H.R. 3151]>> 

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled, <<NOTE: Taxpayer First 
Act.>> 
SECTION 1. SHORT TITLE; ETC.

    (a) <<NOTE: 26 USC 1 note.>>  Short Title.--This Act may be cited as 
the ``Taxpayer First Act''.

    (b) Amendment of 1986 Code.--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.
    (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 
           structuring 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.

[[Page 133 STAT. 982]]

Sec. 1404. Rules for seizure and sale of perishable goods restricted to 
           only perishable 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 
           Committee 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 
           positions.

  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 return 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 
           Service who was involuntarily separated from service for 
           misconduct.
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.

[[Page 133 STAT. 983]]

                    TITLE I--PUTTING TAXPAYERS FIRST

                 Subtitle A--Independent Appeals Process

SEC. 1001. ESTABLISHMENT OF INTERNAL REVENUE SERVICE INDEPENDENT 
                          OFFICE OF APPEALS.

    (a) <<NOTE: 26 USC 7803.>>  In General.--Section 7803 is amended by 
adding 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 official 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 Appeals shall be 
                appointed by the Commissioner of Internal Revenue 
                without regard to the provisions of title 5, United 
                States Code, relating to appointments in the competitive 
                service or the Senior Executive Service.
                    ``(C) Qualifications.--An individual appointed under 
                subparagraph (B) shall have experience 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 
                      organizations.
            ``(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 Government 
                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 integrity 
                and efficiency of the Internal Revenue Service.
            ``(4) Right of appeal.--The resolution process 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) <<NOTE: Notice.>>  In general.--If any 
                taxpayer which is in receipt of a notice of deficiency 
                authorized under section 6212 requests referral to the 
                Internal Revenue Service Independent Office of Appeals 
                and such request is denied, the Commissioner of Internal 
                Revenue shall provide such taxpayer a written notice 
                which--
                          ``(i) provides a detailed description of the 
                      facts involved, the basis for the decision to deny 
                      the request,

[[Page 133 STAT. 984]]

                      and a detailed explanation of how the basis of 
                      such decision applies to such facts, and
                          ``(ii) describes the procedures prescribed 
                      under subparagraph (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 subparagraph (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 a denial of a request described in 
                subparagraph (A).
                    ``(D) Not applicable to frivolous positions.--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) <<NOTE: Deadline.>>  In general.--In any case 
                in which a conference with the Internal Revenue Service 
                Independent Office of Appeals has been scheduled upon 
                request of a specified taxpayer, the Chief of Appeals 
                shall ensure that such taxpayer 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 
                Service) not later than 10 days before the date of such 
                conference.
                    ``(B) <<NOTE: Applicability.>>  Taxpayer election to 
                expedite conference.--If the taxpayer so elects, 
                subparagraph (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 
                paragraph--
                          ``(i) <<NOTE: Definition.>>  In general.--The 
                      term `specified 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

[[Page 133 STAT. 985]]

                                    ``(II) in the case of any other 
                                taxpayer, a taxpayer whose gross 
                                receipts do not exceed $5 million for 
                                the taxable year to which the dispute 
                                relates.
                          ``(ii) <<NOTE: Applicability.>>  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 Appeals'' and inserting 
        ``Internal Revenue Service Independent Office of Appeals'':
                    (A) <<NOTE: 26 USC 6015.>>  Section 
                6015(c)(4)(B)(ii)(I).
                    (B) Section 6320(b)(1).
                    (C) Subsections (b)(1) and (d)(3) of section 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) <<NOTE: 26 USC 7803 note.>>  Other References.--Any reference in 
any provision of law, or regulation or other guidance, to the Internal 
Revenue Service Office of Appeals shall be treated as a reference to the 
Internal Revenue Service Independent Office of Appeals.

    (d) <<NOTE: Applicability.>>  Savings Provisions.--Rules similar to 
the rules of paragraphs (2) through (6) <<NOTE: 26 USC 7803 note.>>  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) <<NOTE: 26 USC 7803 note.>>  Effective Date.--
            (1) In general.--Except as otherwise provided in this 
        subsection, the amendments made by this section shall take 
        effect on the date of the enactment of this Act.
            (2) <<NOTE: Applicability. Time period.>>  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. <<NOTE: 26 USC 7804 note. Deadline.>>  COMPREHENSIVE 
                          CUSTOMER SERVICE STRATEGY.

    (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 
customer service strategy for the Internal Revenue Service. Such 
strategy shall include--
            (1) <<NOTE: Plan.>>  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

[[Page 133 STAT. 986]]

        private sector, including online services, telephone call back 
        services, and training of employees providing customer services;
            (2) <<NOTE: Assessment.>>  a thorough assessment of the 
        services that the Internal Revenue Service can co-locate with 
        other Federal services or offer as self-service options;
            (3) <<NOTE: Proposals. Time periods.>>  proposals to improve 
        Internal Revenue Service customer service in the short term (the 
        current and following fiscal year), medium term (approximately 3 
        to 5 fiscal years), and long term (approximately 10 fiscal 
        years);
            (4) <<NOTE: Plan.>>  a plan to update guidance and training 
        materials 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 quantitatively 
        measuring the progress of the Internal Revenue Service in 
        implementing such strategy.

    (b) <<NOTE: Deadline.>>  Updated Guidance and Training Materials.--
Not later than 2 years after the date of the enactment 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 updated 
guidance and training materials (including the Internal 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 OTHERWISE REQUIRED IN 
                          CONNECTION WITH A SUBMISSION OF AN 
                          OFFER-IN-COMPROMISE.

    (a) <<NOTE: 26 USC 7122.>>  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) <<NOTE: 26 USC 122 note.>>  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 REQUIREMENTS WITH 
                          RESPECT TO STRUCTURING 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 seizure requirements 
                with respect to structuring transactions.--
                          ``(i) Property derived from an illegal 
                      source.--Property may only be seized by the 
                      Internal Revenue Service pursuant to subparagraph 
                      (A) by reason of

[[Page 133 STAT. 987]]

                      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) <<NOTE: Deadline.>>  Notice.--Not later 
                      than 30 days after property is seized by the 
                      Internal Revenue Service pursuant to subparagraph 
                      (A), the Internal Revenue Service shall--
                                    ``(I) make a good faith effort to 
                                find all persons with an ownership 
                                interest 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 extension of the notice requirement under 
                      clause (ii) if the Internal Revenue Service can 
                      establish probable cause of an imminent threat to 
                      national security or personal safety necessitating 
                      such extension.
                          ``(iv) <<NOTE: Time period.>>  Post-seizure 
                      hearing.--If a person with an ownership interest 
                      in property seized pursuant to subparagraph (A) by 
                      the Internal Revenue Service requests a hearing by 
                      a court of competent jurisdiction 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 provide, but only 
                      on request of an interested party) that there is 
                      probable cause to believe 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 INTERNAL REVENUE 
                          SERVICE BASED ON STRUCTURING 
                          TRANSACTION.

    (a) In General.--Part III of subchapter B of chapter 1 is amended by 
inserting before section 140 the following new section:
``SEC. 139H. <<NOTE: 26 USC 139H.>>  INTEREST RECEIVED IN ACTION 
                          TO RECOVER PROPERTY SEIZED BY THE 
                          INTERNAL REVENUE 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.''.

[[Page 133 STAT. 988]]

    (b) Clerical Amendment.--The table of sections for part III of 
subchapter B of chapter 1 <<NOTE: 26 USC 101 prec.>>  is amended by 
inserting before the item relating to section 140 the following new 
item:

``Sec. 139H. Interest received in action to recover property seized by 
           the Internal Revenue Service based on structuring 
           transaction.''.

    (c) <<NOTE: 26 USC 139H note.>>  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) <<NOTE: 26 USC 6015.>>  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 follows:

    ``(f) Equitable Relief.--
            ``(1) In general.--Under procedures prescribed by the 
        Secretary, if--
                    ``(A) taking into account all the facts and 
                circumstances, it is inequitable to hold the individual 
                liable for any unpaid tax or any deficiency (or any 
                portion of either), and
                    ``(B) relief is not available to such individual 
                under subsection (b) or (c),
        the Secretary may relieve such individual of such liability.
            ``(2) Limitation.--A request for equitable relief 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 applicable period 
                of limitation under section 6502, or
                    ``(B) has been paid, provided that such request is 
                made during the period in which the individual could 
                submit a timely claim for refund or credit of such 
                payment.''.

    (b) <<NOTE: 26 USC 6015 note.>>  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 pertains 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 
paragraph.''.

[[Page 133 STAT. 989]]

    (b) <<NOTE: Applicability. Time period. 26 USC 7609.>>  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 COMPLIANCE 
                          PERSONNEL PROGRAM.

    (a) Certain Tax Receivables Not Eligible for Collection Under Tax 
Collection Contracts.--Section 6306(d)(3) <<NOTE: 26 USC 6306.>>  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 information is available, which does 
                not exceed 200 percent of the applicable poverty level 
                (as determined by the Secretary),''.

    (b) Determination of Inactive Tax Receivables Eligible for 
Collection Under Tax Collection 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 Agreements Offered Under Tax 
Collection Contracts.--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 amended--
                    (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 technology costs treated 
        as program costs.--Section 6307(d)(2)(B) is amended by striking 
        ``telecommunications'' 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 Revenue Service 
                or other government agencies for the cost of 
                administering the qualified tax collection program under 
                section 6306.''.

    (e) <<NOTE: Applicability. 26 USC 6306 note.>>  Effective Dates.--
            (1) In general.--Except as otherwise provided 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.

[[Page 133 STAT. 990]]

            (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 subsection (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) <<NOTE: 26 USC 7602.>>  In General.--Section 7602(c)(1) is 
amended to read as follows:
            ``(1) <<NOTE: Time period.>>  General notice.--An officer or 
        employee of the Internal Revenue Service may not contact 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 intended to be made 
                during such period, and
                    ``(B) <<NOTE: Deadline.>>  except as otherwise 
                provided by the Secretary, is provided to the taxpayer 
                not later than 45 days before the beginning of such 
                period.
        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 therein 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) <<NOTE: Applicability. Time period. 26 USC 7602 note.>>  
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 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) 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 Internal Revenue Service and the 
                      Chief Counsel which--
                                    ``(I) states facts clearly 
                                establishing that the Secretary has made 
                                reasonable requests for the information 
                                that is the subject of the summons, and
                                    ``(II) is attached to such 
                                summons,''.

[[Page 133 STAT. 991]]

    (c) Establishment That Reasonable Requests for Information Were 
Made.--Subsection (j) of section 6503 <<NOTE: 26 USC 6503.>>  is amended 
by adding at the end the following new paragraph:
            ``(4) Establishment that reasonable requests 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) <<NOTE: Applicability. Time period. 26 USC 6503 note.>>  
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 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) <<NOTE: 26 USC 7602 note.>>  Effective Date.--The amendment made 
by this section--
            (1) shall take effect on the date of the enactment of this 
        Act; and
            (2) <<NOTE: Applicability.>>  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 ADVOCATE.

    (a) Taxpayer Advocate Directives.--
            (1) In general.--Section 7803(c) is amended by adding at the 
        end the following new paragraph:
            ``(5) <<NOTE: Deadlines.>>  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 Internal Revenue--
                    ``(A) the Commissioner or a Deputy Commissioner 
                shall modify, rescind, or ensure compliance 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 Commissioner, 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

[[Page 133 STAT. 992]]

                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 congress regarding 
        directives.--Section 7803(c)(2)(B)(ii) <<NOTE: 26 USC 7803.>>  
        is amended by redesignating subclauses (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 specified under 
                                paragraph (5);''.

    (b) National Taxpayer Advocate Annual Reports 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 inserting ``the 10''.
            (2) Coordination with treasury inspector general for tax 
        administration.--Section 7803(c)(2) is amended by adding at the 
        end the following new subparagraph:
                    ``(E) Coordination with treasury inspector general 
                for tax administration.--Before beginning any research 
                or study, the National Taxpayer Advocate shall 
                coordinate with the Treasury Inspector General for Tax 
                Administration to ensure that the National Taxpayer 
                Advocate does not duplicate any action 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 amended by adding 
                at the end the following new subsection:

    ``(d) Statistical Support for National Taxpayer Advocate.--Upon 
request of the National Taxpayer Advocate, the Secretary shall, to the 
extent practicable, provide the National Taxpayer Advocate with 
statistical support in connection with the preparation by the National 
Taxpayer Advocate of the annual report described in section 
7803(c)(2)(B)(ii). Such statistical support shall include statistical 
studies, compilations, and the review of 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 subclause:
                                    ``(XII) with respect to any 
                                statistical information included in such 
                                report, include a statement of whether 
                                such statistical information was 
                                reviewed 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

[[Page 133 STAT. 993]]

                respect to statistical information 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 <<NOTE: 26 USC 7803.>>  by striking ``, or, if the Secretary 
of the Treasury so determines, at a rate fixed under section 9503 of 
such title''.

    (d) <<NOTE: 26 USC 6108 note.>>  Effective Date.--
            (1) In general.--Except as otherwise provided in this 
        subsection, the amendments made by this section shall take 
        effect on the date of the enactment of this Act.
            (2) <<NOTE: Applicability.>>  Salary of national taxpayer 
        advocate.--The amendment made by subsection (c) shall apply to 
        compensation paid to individuals appointed as the National 
        Taxpayer Advocate after March 31, 2019.
SEC. <<NOTE: 26 USC 7801 note.>>  1302. MODERNIZATION OF INTERNAL 
                          REVENUE SERVICE ORGANIZATIONAL 
                          STRUCTURE.

    (a) <<NOTE: Deadline. Plan.>>  In General.--Not later than September 
30, 2020, the Secretary of the Treasury (or the Secretary's delegate) 
shall submit to Congress a comprehensive written plan to redesign the 
organization of the Internal Revenue Service. Such plan shall--
            (1) ensure the successful implementation of the priorities 
        specified by Congress in this Act;
            (2) prioritize taxpayer services to ensure that all 
        taxpayers easily and readily receive the assistance that they 
        need;
            (3) streamline the structure of the agency including 
        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 Internal Revenue Service; 
        and
            (5) address whether the Criminal Investigation Division of 
        the Internal Revenue Service should report directly to the 
        Commissioner of Internal Revenue.

    (b) Repeal of Restriction on Organizational Structure of Internal 
Revenue Service.--Paragraph (3) <<NOTE: Termination date.>>  of section 
1001(a) of the Internal Revenue Service 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 APPLICABLE TAXPAYERS.

    (a) In General.--Chapter 77 is amended by inserting after section 
7526 the following new section:
``SEC. <<NOTE: 26 USC 7526A.>>  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

[[Page 133 STAT. 994]]

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) <<NOTE: Procedures. Time period.>>  In general.--The 
        Secretary shall establish procedures for, and shall conduct not 
        less frequently than once every

[[Page 133 STAT. 995]]

        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) <<NOTE: Determination.>>  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

[[Page 133 STAT. 996]]

                                    ``(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 
        three 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 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 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) Referrals to low-income taxpayer clinics.--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.''.

[[Page 133 STAT. 997]]

    (b) Clerical Amendment.--The table of sections for chapter 77 
is <<NOTE: 26 USC 7501 prec.>> amended by inserting after the item 
relating 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.--Notwithstanding 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 qualified low-
                income taxpayer clinics receiving funding under this 
                section, and
                    ``(B) provide information regarding the location of, 
                and contact information for, such clinics.''.

    (b) <<NOTE: 26 USC 7526 note.>>  Effective Date.--The amendment made 
by this section shall take effect on the date of the enactment of this 
Act.
SEC. 1403. <<NOTE: 26 USC 7801 note.>>  NOTICE FROM IRS REGARDING 
                          CLOSURE OF TAXPAYER ASSISTANCE CENTERS.

    Not <<NOTE: Deadline.>>  later than 90 days before the date that a 
proposed closure of a Taxpayer Assistance Center would take effect, the 
Secretary of the Treasury (or the Secretary's delegate) shall--
            (1) <<NOTE: Public information.>>  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) <<NOTE: Reports.>>  submit to Congress a written report 
        that includes--
                    (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 Secretary 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 striking ``or become 
greatly reduced in price or value by keeping, or that such property 
cannot be kept without great expense''.
    (b) <<NOTE: 26 USC 6336 note.>>  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

[[Page 133 STAT. 998]]

                described in paragraph (1) or (2) of section 7623(a), 
                return information related to the investigation of any 
                taxpayer with respect to whom the individual has 
                provided 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 determination of tax liability 
                for tax, or the amount to be collected with respect to 
                the enforcement of any other provision of this title.
                    ``(B) <<NOTE: Deadlines.>>  Updates on whistleblower 
                investigations.--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 individual has provided 
                      information has made a payment of tax with respect 
                      to tax liability to which such information 
                      relates, a notice 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 action 
                                related to such information, and
                                    ``(II) in the case of a 
                                determination 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 Federal tax administration. 
                Information described in clauses (i), (ii), and (iii) 
                may be disclosed to a designee of the individual 
                providing such information in accordance with guidance 
                provided by the Secretary.''.
            (2) Conforming amendments.--
                    (A) Confidentiality of information.--Section 
                6103(a)(3) is amended <<NOTE: 26 USC 6103.>>  by 
                striking ``subsection (k)(10)'' and inserting 
                ``paragraph (10) or (13) of subsection (k)''.
                    (B) Penalty for unauthorized disclosure.--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 
                paragraph shall not apply to any disclosure to an 
                individual 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 Retaliation Cases.--
            ``(1) Anti-retaliation whistleblower protection for 
        employees.--No employer, or any officer, employee, contractor, 
        subcontractor, or agent of such employer, may discharge,

[[Page 133 STAT. 999]]

        demote, suspend, threaten, harass, or in any other manner 
        discriminate against an employee in the terms and conditions of 
        employment (including through an act in the ordinary course of 
        such employee's duties) in reprisal for any lawful act done by 
        the employee--
                    ``(A) to provide information, cause information to 
                be provided, or otherwise assist in an investigation 
                regarding underpayment of tax or any conduct which the 
                employee reasonably believes constitutes a violation of 
                the internal revenue laws or any provision of Federal 
                law relating to tax fraud, when the information or 
                assistance is provided to the Internal Revenue Service, 
                the Secretary of the Treasury, the Treasury Inspector 
                General for Tax Administration, the Comptroller General 
                of the United States, the Department of Justice, the 
                United States Congress, a person with supervisory 
                authority over the employee, or any other person working 
                for the employer who has the authority to investigate, 
                discover, or terminate misconduct, or
                    ``(B) to testify, participate in, or otherwise 
                assist in any administrative or judicial action taken by 
                the Internal Revenue Service relating to an alleged 
                underpayment of tax or any violation of the internal 
                revenue laws or any provision 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 violation of paragraph 
                (1) may seek relief under paragraph (3) by--
                          ``(i) filing a complaint with the Secretary of 
                      Labor, or
                          ``(ii) <<NOTE: Time period.>>  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 
                      appropriate 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 action 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 applying such section--
                                    ``(I) `behavior described in 
                                paragraph (1)' shall be substituted for 
                                `behavior described in paragraphs (1) 
                                through (4) of subsection (a)' each 
                                place it appears in paragraph (2)(B) 
                                thereof, and

[[Page 133 STAT. 1000]]

                                    ``(II) `a violation of paragraph 
                                (1)' shall be substituted for `a 
                                violation of subsection (a)' each place 
                                it appears.
                          ``(iv) <<NOTE: Deadline.>>  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 action 
                      brought under subparagraph (A)(ii) shall be 
                      entitled to trial by jury.
            ``(3) Remedies.--
                    ``(A) In general.--An employee prevailing 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 include--
                          ``(i) reinstatement with the same seniority 
                      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 reprisal, including 
                      litigation costs, expert witness fees, and 
                      reasonable attorney fees.
            ``(4) Rights retained by employee.--Nothing 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 provisions waiving rights 
        and remedies or requiring arbitration of disputes.--
                    ``(A) Waiver of rights and remedies.--The rights and 
                remedies provided for in this subsection may not be 
                waived by any agreement, policy form, or condition of 
                employment, including by a predispute arbitration 
                agreement.
                    ``(B) Predispute arbitration agreements.--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) <<NOTE: 26 USC 6103 note.>>  In general.--The amendments 
        made by subsection (a) shall apply to disclosures made after the 
        date of the enactment of this Act.
            (2) <<NOTE: 26 USC 7623 note.>>  Civil protection.--The 
        amendment made by subsection (b) shall take effect on the date 
        of the enactment of this Act.
SEC. 1406. <<NOTE: 26 USC 7801 note.>>  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 Revenue 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 protect 
        themselves from identity theft and tax scams.

[[Page 133 STAT. 1001]]

SEC. 1407. MISDIRECTED TAX REFUND DEPOSITS.

    Section 6402 <<NOTE: 26 USC 6402.>>  is amended by adding at the end 
the following new subsection:

    ``(n) <<NOTE: Deadline. Regulations. Procedures.>>  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) <<NOTE: Coordination.>>  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 transferred; 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. <<NOTE: 26 USC 7529 note.>>  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 refund fraud.
SEC. 2002. RECOMMENDATIONS OF ELECTRONIC TAX ADMINISTRATION 
                          ADVISORY COMMITTEE REGARDING IDENTITY 
                          THEFT REFUND FRAUD.

    The Secretary of the Treasury shall ensure that the advisory group 
convened by the Secretary pursuant to section 2001(b)(2) of the Internal 
Revenue Service Restructuring and Reform Act of 1998 (commonly known as 
the Electronic Tax Administration Advisory Committee) studies (including 
by providing organized public forums) and makes recommendations to the 
Secretary regarding methods to prevent identity theft and refund fraud.
SEC. 2003. INFORMATION SHARING AND ANALYSIS CENTER.

    (a) <<NOTE: 26 USC 7529 note.>>  In General.--The Secretary of the 
Treasury (or the Secretary's delegate) may participate in an information 
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) <<NOTE: 26 USC 7529 note.>>  Development of Performance 
Metrics.--The Secretary of the Treasury (or the Secretary's delegate) 
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 amended 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 prevention of identity theft tax refund 
        fraud.--

[[Page 133 STAT. 1002]]

                    ``(A) In general.--Under such procedures and subject 
                to such conditions as the Secretary may prescribe, the 
                Secretary may disclose specified return information to 
                specified ISAC participants to the extent that the 
                Secretary determines such disclosure is in furtherance 
                of effective Federal tax administration relating 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) <<NOTE: Definition.>>  Specified isac 
                participants.--For purposes of this paragraph--
                          ``(i) In general.--The term `specified ISAC 
                      participant' means--
                                    ``(I) any person designated by the 
                                Secretary as having primary 
                                responsibility for a function performed 
                                with respect to the information sharing 
                                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 information 
                                sharing and analysis center.
                          ``(ii) Information sharing agreement.--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 person under this paragraph, including 
                      requirements regarding the protection and 
                      safeguarding of such information by such person.
                    ``(C) <<NOTE: Definition.>>  Specified return 
                information.--For purposes of this paragraph, the term 
                `specified return information' means--
                          ``(i) in the case of a return which is in 
                      connection with a case of potential identity theft 
                      refund fraud--
                                    ``(I) in the case of such return 
                                filed electronically, the internet 
                                protocol address, device identification, 
                                email domain name, speed of completion, 
                                method of authentication, refund method, 
                                and such other return information 
                                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 identification 
                                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 confirmed 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 taxpayer 
                      as it appears on the return, and any bank account 
                      and routing information provided for making a 
                      refund in connection with such return, and

[[Page 133 STAT. 1003]]

                          ``(iii) in the case of any cybersecurity 
                      threat to the Internal Revenue Service, 
                      information similar to the information described 
                      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 person 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 
                                authorized under subparagraph (A) to 
                                persons described in subparagraph 
                                (B)(i)(II), and
                                    ``(III) facilitating disclosures 
                                authorized under subsection (d) to 
                                participants in such information sharing 
                                and analysis center.
                          ``(ii) Return preparers.--Any return 
                      information received by a person described in 
                      subparagraph (B)(i)(II) shall be treated for 
                      purposes of section 7216 as information furnished 
                      to such person for, or in connection with, the 
                      preparation of a return of the tax imposed under 
                      chapter 1.
                    ``(E) Data protection and safeguards.--Return 
                information disclosed under this paragraph shall be 
                subject to such protections and safeguards as the 
                Secretary may require 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 information 
                disclosed under this paragraph, and any breach of any 
                system in which such information is held, be reported to 
                the Treasury Inspector General for Tax 
                Administration.''.
            (2) Application of civil and criminal penalties.--
                    (A) <<NOTE: 26 USC 6103.>>  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 CONFIDENTIALITY 
                          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 provision 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 require each 
                such contractor or other agent which would have access 
                to returns or return information to provide safeguards 
                (within the meaning of paragraph (4)) to protect the 
                confidentiality of such returns or return information,

[[Page 133 STAT. 1004]]

                    ``(B) <<NOTE: Review. Time period.>>  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 requirements,
                    ``(C) submits the findings of the most recent review 
                conducted under subparagraph (B) to the Secretary as 
                part of the report required by paragraph (4)(E), and
                    ``(D) <<NOTE: Certification.>>  certifies to the 
                Secretary for the most recent annual period that such 
                contractor or other agent is in compliance with all such 
                requirements.
        The certification required by subparagraph (D) shall include the 
        name and address of each contractor or other agent, a 
        description of the contract or agreement with such contractor or 
        other agent, and the duration of such contract or agreement. The 
        requirements of this paragraph shall not apply to disclosures 
        pursuant to subsection (n) for purposes of Federal tax 
        administration.''.

    (b) <<NOTE: 26 USC 6103.>>  Conforming Amendment.--Section 
6103(p)(8)(B) is amended by inserting ``or paragraph (9)'' after 
``subparagraph (A)''.

    (c) <<NOTE: 26 USC 6103 note.>>  Effective Date.--The amendments 
made by this section shall apply to disclosures made after December 31, 
2022.
SEC. 2005. <<NOTE: 26 USC 6109 note.>>  IDENTITY PROTECTION 
                          PERSONAL IDENTIFICATION NUMBERS.

    (a) In General.--Subject to subsection (b), the Secretary of the 
Treasury or the Secretary's delegate (hereafter referred to in this 
section as the ``Secretary'') shall establish a program to issue, upon 
the request of any individual, a number which may be used in connection 
with such individual's social security number (or other identifying 
information with respect to such individual as determined by the 
Secretary) to assist the Secretary in verifying such individual's 
identity.
    (b) Requirements.--
            (1) Annual expansion.--For each calendar year beginning 
        after the date of the enactment of this Act, the Secretary shall 
        provide numbers through the program described in subsection (a) 
        to individuals residing in such States as the Secretary deems 
        appropriate, provided that the total number of States served by 
        such program during such year is greater than the total number 
        of States served by such program during the preceding year.
            (2) <<NOTE: Deadline.>>  Nationwide availability.--Not later 
        than 5 years after the date of the enactment of this Act, the 
        Secretary shall ensure that the program described in subsection 
        (a) is made available to any individual residing in the United 
        States.
SEC. 2006. <<NOTE: 26 USC 7529 note.>>  SINGLE POINT OF CONTACT 
                          FOR TAX-RELATED IDENTITY THEFT VICTIMS.

    (a) <<NOTE: Procedures.>>  In General.--The Secretary of the 
Treasury (or the Secretary's delegate) shall establish and implement 
procedures to ensure that any taxpayer whose return has been delayed or 
otherwise adversely affected due to tax-related identity theft has a 
single point of contact at the Internal Revenue Service throughout the 
processing of the taxpayer's case. <<NOTE: Coordination.>>  The single 
point of contact shall track the taxpayer's case to completion and 
coordinate with other Internal Revenue Service employees to resolve case 
issues as quickly as possible.

[[Page 133 STAT. 1005]]

    (b) Single Point of Contact.--
            (1) In general.--For purposes of subsection (a), the single 
        point of contact shall consist of a team or subset of specially 
        trained employees who--
                    (A) have the ability to work across functions to 
                resolve the issues involved in the taxpayer's case; and
                    (B) shall be accountable for handling the case until 
                its resolution.
            (2) <<NOTE: Procedures.>>  Team or subset.--The employees 
        included within the team or subset described in paragraph (1) 
        may change as required to meet the needs of the Internal Revenue 
        Service, provided that procedures have been established to--
                    (A) ensure continuity of records and case history; 
                and
                    (B) <<NOTE: Notification.>>  notify the taxpayer 
                when appropriate.
SEC. 2007. NOTIFICATION OF SUSPECTED IDENTITY THEFT.

    (a) In General.--Chapter 77 is amended by adding at the end the 
following new section:
``SEC. 7529. <<NOTE: 26 USC 7529.>>  NOTIFICATION OF SUSPECTED 
                          IDENTITY THEFT.

    ``(a) <<NOTE: Determination.>>  In General.--If the Secretary 
determines that there has been or may have been an unauthorized use of 
the identity of any individual, the Secretary shall, without 
jeopardizing an investigation relating to tax administration--
            ``(1) as soon as practicable--
                    ``(A) notify the individual of such determination,
                    ``(B) provide instructions on how to file a report 
                with law enforcement regarding the unauthorized use,
                    ``(C) identify any steps to be taken by the 
                individual to permit law enforcement to access personal 
                information of the individual during the investigation,
                    ``(D) provide information regarding actions the 
                individual may take in order to protect the individual 
                from harm relating to the unauthorized use, and
                    ``(E) offer identity protection measures to the 
                individual, such as the use of an identity protection 
                personal identification number, and
            ``(2) at the time the information described in paragraph (1) 
        is provided (or, if not available at such time, as soon as 
        practicable thereafter), issue additional notifications to such 
        individual (or such individual's designee) regarding--
                    ``(A) whether an investigation has been initiated in 
                regards to such unauthorized use,
                    ``(B) whether the investigation substantiated an 
                unauthorized use of the identity of the individual, and
                    ``(C) whether--
                          ``(i) any action has been taken against a 
                      person relating to such unauthorized use, or
                          ``(ii) any referral has been made for criminal 
                      prosecution of such person and, to the extent such 
                      information is available, whether such person has 
                      been criminally charged by indictment or 
                      information.

    ``(b) Employment-Related Identity Theft.--
            ``(1) In general.--For purposes of this section, the 
        unauthorized use of the identity of an individual includes the 
        unauthorized use of the identity of the individual to obtain 
        employment.

[[Page 133 STAT. 1006]]

            ``(2) Determination of employment-related identity theft.--
        For purposes <<NOTE: Review.>>  of this section, in making a 
        determination as to whether there has been or may have been an 
        unauthorized use of the identity of an individual to obtain 
        employment, the Secretary shall review any information--
                    ``(A) obtained from a statement described in section 
                6051 or an information return relating to compensation 
                for services rendered other than as an employee, or
                    ``(B) provided to the Internal Revenue Service by 
                the Social Security Administration regarding any 
                statement described in section 6051,
        which indicates that the social security account number provided 
        on such statement or information return does not correspond with 
        the name provided on such statement or information return or the 
        name on the tax return reporting the income which is included on 
        such statement or information return.''.

    (b) Additional Measures.--
            (1) <<NOTE: 26 USC 7529 note.>>  Examination of both paper 
        and electronic statements and returns.--The Secretary of the 
        Treasury (or the Secretary's delegate) shall examine the 
        statements, information returns, and tax returns described in 
        section 7529(b)(2) of the Internal Revenue Code of 1986 (as 
        added by subsection (a)) for any evidence of employment-related 
        identity theft, regardless of whether such statements or returns 
        are submitted electronically or on paper.
            (2) Improvement of effective return processing program with 
        social security administration.--Section 232 of the Social 
        Security Act (42 U.S.C. 432) is amended by inserting after the 
        third sentence the following: ``For purposes of carrying out the 
        return processing program described in the preceding sentence, 
        the Commissioner of Social Security shall request, not less than 
        annually, such information described in section 7529(b)(2) of 
        the Internal Revenue Code of 1986 as may be necessary to ensure 
        the accuracy of the records maintained by the Commissioner of 
        Social Security related to the amounts of wages paid to, and the 
        amounts of self-employment income derived by, individuals.''.
            (3) <<NOTE: Procedures. 26 USC 7529 note.>>  Underreporting 
        of income.--The Secretary of the Treasury (or the Secretary's 
        delegate) shall establish procedures to ensure that income 
        reported in connection with the unauthorized use of a taxpayer's 
        identity is not taken into account in determining any penalty 
        for underreporting of income by the victim of identity theft.

    (c) Clerical Amendment.--The table of sections for chapter 77 
is <<NOTE: 26 USC 7501 prec.>> amended by adding at the end the 
following new item:

``Sec. 7529. Notification of suspected identity theft.''.

    (d) <<NOTE: Applicability. Determinations. Time period. 26 USC 
7529 note. 26 USC 
7529 note. Deadline. Consultation. Public information.>>  Effective 
Date.--The amendments made by this section shall apply to determinations 
made after the date that is 6 months after the date of the enactment of 
this Act.
SEC. 2008. GUIDELINES FOR STOLEN IDENTITY REFUND FRAUD CASES.

    (a) In General.--Not later than 1 year after the date of the 
enactment of this Act, the Secretary of the Treasury (or the Secretary's 
delegate), in consultation with the National Taxpayer Advocate, shall 
develop and implement publicly available guidelines for management of 
cases involving stolen identity refund fraud

[[Page 133 STAT. 1007]]

in a manner that reduces the administrative burden on taxpayers who are 
victims of such fraud.
    (b) Standards and Procedures To Be Considered.--The guidelines 
described in subsection (a) may include--
            (1) standards for--
                    (A) the average length of time in which a case 
                involving stolen identity refund fraud should be 
                resolved;
                    (B) the maximum length of time, on average, a 
                taxpayer who is a victim of stolen identity refund fraud 
                and is entitled to a tax refund which has been stolen 
                should have to wait to receive such refund; and
                    (C) the maximum number of offices and employees 
                within the Internal Revenue Service with whom a taxpayer 
                who is a victim of stolen identity refund fraud should 
                be required to interact in order to resolve a case;
            (2) standards for opening, assigning, reassigning, or 
        closing a case involving stolen identity refund fraud; and
            (3) procedures for implementing and accomplishing the 
        standards described in paragraphs (1) and (2), and measures for 
        evaluating such procedures and determining whether such 
        standards have been successfully implemented.
SEC. 2009. INCREASED PENALTY FOR IMPROPER DISCLOSURE OR USE OF 
                          INFORMATION BY PREPARERS OF RETURNS.

    (a) <<NOTE: 26 USC 6713.>>  In General.--Section 6713 is amended--
            (1) by redesignating subsections (b) and (c) as subsections 
        (c) and (d), respectively; and
            (2) by inserting after subsection (a) the following new 
        subsection:

    ``(b) Enhanced Penalty for Improper Use or Disclosure Relating to 
Identity Theft.--
            ``(1) In general.--In the case of a disclosure or use 
        described in subsection (a) that is made in connection with a 
        crime relating to the misappropriation of another person's 
        taxpayer identity (as defined in section 6103(b)(6)), whether or 
        not such crime involves any tax filing, subsection (a) shall be 
        applied--
                    ``(A) by substituting `$1,000' for `$250', and
                    ``(B) by substituting `$50,000' for `$10,000'.
            ``(2) Separate application of total penalty limitation.--The 
        limitation on the total amount of the penalty under subsection 
        (a) shall be applied separately with respect to disclosures or 
        uses to which this subsection applies and to which it does not 
        apply.''.

    (b) Criminal Penalty.--Section 7216(a) is amended by striking 
``$1,000'' and inserting ``$1,000 ($100,000 in the case of a disclosure 
or use to which section 6713(b) applies)''.
    (c) <<NOTE: 26 USC 6713 note.>>  Effective Date.--The amendments 
made by this section shall apply to disclosures or uses on or after the 
date of the enactment of this Act.

[[Page 133 STAT. 1008]]

            Subtitle B--Development of Information Technology

SEC. 2101. MANAGEMENT OF INTERNAL REVENUE SERVICE INFORMATION 
                          TECHNOLOGY.

    (a) Duties and Responsibilities of Internal Revenue Service Chief 
Information Officer.--Section 7803, as amended by section 
1001, <<NOTE: 26 USC 7803.>>  is amended by adding at the end the 
following new subsection:

    ``(f) Internal Revenue Service Chief Information Officer.--
            ``(1) <<NOTE: Appointment.>>  In general.--There shall be in 
        the Internal Revenue Service an Internal Revenue Service Chief 
        Information Officer (hereafter referred to in this subsection as 
        the `IRS CIO') who shall be appointed by the Commissioner of 
        Internal Revenue.
            ``(2) Centralized responsibility for internal revenue 
        service information technology.--The Commissioner of Internal 
        Revenue (and the Secretary) shall act through the IRS CIO with 
        respect to all development, implementation, and maintenance of 
        information technology for the Internal Revenue Service. Any 
        reference in this subsection to the IRS CIO which directs the 
        IRS CIO to take any action, or to assume any responsibility, 
        shall be treated as a reference to the Commissioner of Internal 
        Revenue acting through the IRS CIO.
            ``(3) General duties and responsibilities.--The IRS CIO 
        shall--
                    ``(A) be responsible for the development, 
                implementation, and maintenance of information 
                technology for the Internal Revenue Service,
                    ``(B) ensure that the information technology of the 
                Internal Revenue Service is secure and integrated,
                    ``(C) maintain operational control of all 
                information technology for the Internal Revenue Service,
                    ``(D) be the principal advocate for the information 
                technology needs of the Internal Revenue Service, and
                    ``(E) <<NOTE: Consultation.>>  consult with the 
                Chief Procurement Officer of the Internal Revenue 
                Service to ensure that the information technology 
                acquired for the Internal Revenue Service is consistent 
                with--
                          ``(i) the goals and requirements specified in 
                      subparagraphs (A) through (D), and
                          ``(ii) the strategic plan developed under 
                      paragraph (4).
            ``(4) Strategic plan.--
                    ``(A) In general.--The IRS CIO shall develop and 
                implement a multiyear strategic plan for the information 
                technology needs of the Internal Revenue Service. Such 
                plan shall--
                          ``(i) include performance measurements of such 
                      technology and of the implementation of such plan,
                          ``(ii) include a plan for an integrated 
                      enterprise architecture of the information 
                      technology of the Internal Revenue Service,
                          ``(iii) include and take into account the 
                      resources needed to accomplish such plan,

[[Page 133 STAT. 1009]]

                          ``(iv) take into account planned major 
                      acquisitions of information technology by the 
                      Internal Revenue Service, and
                          ``(v) align with the needs and strategic plan 
                      of the Internal Revenue Service.
                    ``(B) <<NOTE: Time period. Review.>>  Plan 
                updates.--The IRS CIO shall, not less frequently than 
                annually, review and update the strategic plan under 
                subparagraph (A) (including the plan for an integrated 
                enterprise architecture described in subparagraph 
                (A)(ii)) to take into account the development of new 
                information technology and the needs of the Internal 
                Revenue Service.
            ``(5) Scope of authority.--
                    ``(A) <<NOTE: Definition.>>  Information 
                technology.--For purposes of this subsection, the term 
                `information technology' has the meaning given such term 
                by section 11101 of title 40, United States Code.
                    ``(B) Internal revenue service.--Any reference in 
                this subsection to the Internal Revenue Service includes 
                a reference to all components of the Internal Revenue 
                Service, including--
                          ``(i) the Office of the Taxpayer Advocate,
                          ``(ii) the Criminal Investigation Division of 
                      the Internal Revenue Service, and
                          ``(iii) except as otherwise provided by the 
                      Secretary with respect to information technology 
                      related to matters described in subsection 
                      (b)(3)(B), the Office of the Chief Counsel.''.

    (b) Independent Verification and Validation of the Customer Account 
Data Engine 2 and Enterprise Case Management System.--
            (1) <<NOTE: Contracts.>>  In general.--The Commissioner of 
        Internal Revenue shall enter into a contract with an independent 
        reviewer to verify and validate the implementation plans 
        (including the performance milestones and cost estimates 
        included in such plans) developed for the Customer Account Data 
        Engine 2 and the Enterprise Case Management System.
            (2) Deadline for completion.--Such contract shall require 
        that such verification and validation be completed not later 
        than the date which is 1 year after the date of the enactment of 
        this Act.
            (3) Application to phases of cade 2.--
                    (A) In general.--Paragraphs (1) and (2) shall not 
                apply to phase 1 of the Customer Account Data Engine 2 
                and shall apply separately to each other phase.
                    (B) Deadline for completing plans.--Not later than 1 
                year after the date of the enactment of this Act, the 
                Commissioner of Internal Revenue shall complete the 
                development of plans for all phases of the Customer 
                Account Data Engine 2.
                    (C) Deadline for completion of verification and 
                validation of plans.--In the case of any phase after 
                phase 2 of the Customer Account Data Engine 2, paragraph 
                (2) shall be applied by substituting ``the date on which 
                the plan for such phase was completed'' for ``the date 
                of the enactment of this Act''.

[[Page 133 STAT. 1010]]

    (c) <<NOTE: 26 USC 7803 note.>>  Coordination of IRS CIO and Chief 
Procurement Officer of the Internal Revenue Service.--
            (1) In general.--The Chief Procurement Officer of the 
        Internal Revenue Service shall--
                    (A) <<NOTE: Notification.>>  identify all 
                significant IRS information technology acquisitions and 
                provide written notification to the Internal Revenue 
                Service Chief Information Officer (hereafter referred to 
                in this subsection as the ``IRS CIO'') of each such 
                acquisition in advance of such acquisition, and
                    (B) <<NOTE: Consultation.>>  regularly consult with 
                the IRS CIO regarding acquisitions of information 
                technology for the Internal Revenue Service, including 
                meeting with the IRS CIO regarding such acquisitions 
                upon request.
            (2) Significant irs information technology acquisitions.--
        For purposes <<NOTE: Definition.>>  of this subsection, the term 
        ``significant IRS information technology acquisitions'' means--
                    (A) any acquisition of information technology for 
                the Internal Revenue Service in excess of $1 million; 
                and
                    (B) such other acquisitions of information 
                technology for the Internal Revenue Service (or 
                categories of such acquisitions) as the IRS CIO, in 
                consultation with the Chief Procurement Officer of the 
                Internal Revenue Service, may identify.
            (3) Scope.--Terms used in this subsection which are also 
        used in section 7803(f) of the Internal Revenue Code of 1986 (as 
        added by subsection (a)) shall have the same meaning as when 
        used in such section.
SEC. 2102. <<NOTE: 26 USC 6011 note. Deadline.>>  INTERNET 
                          PLATFORM FOR FORM 1099 FILINGS.

    (a) In General.--Not later than January 1, 2023, the Secretary of 
the Treasury or the Secretary's delegate (hereafter referred to in this 
section as the ``Secretary'') shall make available an internet website 
or other electronic media, with a user interface and functionality 
similar to the Business Services Online Suite of Services provided by 
the Social Security Administration, that provides access to resources 
and guidance provided by the Internal Revenue Service and allows persons 
to--
            (1) prepare and file Forms 1099;
            (2) prepare Forms 1099 for distribution to recipients other 
        than the Internal Revenue Service; and
            (3) maintain a record of completed, filed, and distributed 
        Forms 1099.

    (b) Electronic Services Treated as Supplemental; Application of 
Security Standards.--The Secretary shall ensure that the services 
described in subsection (a)--
            (1) are a supplement to, and not a replacement for, other 
        services provided by the Internal Revenue Service to taxpayers; 
        and
            (2) <<NOTE: Compliance.>>  comply with applicable security 
        standards and guidelines.
SEC. 2103. STREAMLINED CRITICAL PAY AUTHORITY FOR INFORMATION 
                          TECHNOLOGY POSITIONS.

    (a) In General.--Subchapter A of chapter 80 is amended by adding at 
the end the following new section:

[[Page 133 STAT. 1011]]

``SEC. 7812. <<NOTE: Applicability. 26 USC 7812.>>  STREAMLINED 
                          CRITICAL PAY AUTHORITY FOR INFORMATION 
                          TECHNOLOGY POSITIONS.

    ``In the case of any position which is critical to the functionality 
of the information technology operations of the Internal Revenue 
Service--
            ``(1) section 9503 of title 5, United States Code, shall be 
        applied--
                    ``(A) by substituting `during the period beginning 
                on the date of the enactment of section 7812 of the 
                Internal Revenue Code of 1986, and ending on September 
                30, 2025' for `Before September 30, 2013 in subsection 
                (a)',
                    ``(B) without regard to subparagraph (B) of 
                subsection (a)(1), and
                    ``(C) by substituting `the date of the enactment of 
                the Taxpayer First Act' for `June 1, 1998' in subsection 
                (a)(6),
            ``(2) section 9504 of such title 5 shall be applied by 
        substituting `During the period beginning on the date of the 
        enactment of section 7812 of the Internal Revenue Code of 1986, 
        and ending on September 30, 2025' for `Before September 30, 
        2013' each place it appears in subsections (a) and (b), and
            ``(3) section 9505 of such title shall be applied--
                    ``(A) by substituting `During the period beginning 
                on the date of the enactment of section 7812 of the 
                Internal Revenue Code of 1986, and ending on September 
                30, 2025' for `Before September 30, 2013' in subsection 
                (a), and
                    ``(B) by substituting `the information technology 
                operations' for `significant functions' in subsection 
                (a).''.

    (b) Clerical Amendment.--The table of sections for subchapter A of 
chapter 80 is <<NOTE: 26 USC 7801 prec.>> amended by adding at the end 
the following new item:

``Sec. 7812. Streamlined critical pay authority for information 
           technology positions.''.

  Subtitle C--Modernization of Consent-Based Income Verification System

SEC. 2201. <<NOTE: 26 USC 6103 note.>>  DISCLOSURE OF TAXPAYER 
                          INFORMATION FOR THIRD-PARTY INCOME 
                          VERIFICATION.

    (a) <<NOTE: Deadline.>>  In General.--Not later than 1 year after 
the close of the 2-year period described in subsection (d)(1), the 
Secretary of the Treasury or the Secretary's delegate (hereafter 
referred to in this section as the ``Secretary'') shall implement a 
program to ensure that any qualified disclosure--
            (1) is fully automated and accomplished through the 
        internet; and
            (2) is accomplished in as close to real-time as is 
        practicable.

    (b) Qualified Disclosure.--For purposes <<NOTE: Definition.>>  of 
this section, the term ``qualified disclosure'' means a disclosure under 
section 6103(c) of the Internal Revenue Code of 1986 of returns or 
return information by the Secretary to a person seeking to verify the 
income or creditworthiness of a taxpayer who is a borrower in the 
process of a loan application.

    (c) <<NOTE: Compliance.>>  Application of Security Standards.--The 
Secretary shall ensure that the program described in subsection (a) 
complies with applicable security standards and guidelines.

[[Page 133 STAT. 1012]]

    (d) User Fee.--
            (1) <<NOTE: Time period.>>  In general.--During the 2-year 
        period beginning on the first day of the sixth calendar month 
        beginning after the date of the enactment of this Act, the 
        Secretary shall assess and collect a fee for qualified 
        disclosures (in addition to any other fee assessed and collected 
        for such disclosures) at such rates as the Secretary determines 
        are sufficient to cover the costs related to implementing the 
        program described in subsection (a), including the costs of any 
        necessary infrastructure or technology.
            (2) Deposit of collections.--Amounts received from fees 
        assessed and collected under paragraph (1) shall be deposited 
        in, and credited to, an account solely for the purpose of 
        carrying out the activities described in subsection (a). Such 
        amounts shall be available to carry out such activities without 
        need of further appropriation and without fiscal year 
        limitation.
SEC. 2202. LIMIT REDISCLOSURES AND USES OF CONSENT-BASED 
                          DISCLOSURES OF TAX RETURN INFORMATION.

    (a) <<NOTE: 26 USC 6103.>>  In General.--Section 6103(c) is amended 
by adding at the end the following: ``Persons designated by the taxpayer 
under this subsection to receive return information shall not use the 
information for any purpose other than the express purpose for which 
consent was granted and shall not disclose return information to any 
other person without the express permission of, or request by, the 
taxpayer.''.

    (b) Application of Penalties.--Section 6103(a)(3) is amended by 
inserting ``subsection (c),'' after ``return information under''.
    (c) <<NOTE: Applicability. Time period. 26 USC 6103 note.>>  
Effective Date.--The amendments made by this section shall apply to 
disclosures made after the date which is 180 days after the date of the 
enactment of this Act.

             Subtitle D--Expanded Use of Electronic Systems

SEC. 2301. ELECTRONIC FILING OF RETURNS.

    (a) In General.--Section 6011(e)(2)(A) is amended by striking 
``250'' and inserting ``the applicable number of''.
    (b) Applicable Number.--Section 6011(e) is amended by striking 
paragraph (5) and inserting the following new paragraphs:
            ``(5) Applicable number.--
                    ``(A) In general.--For purposes of paragraph (2)(A), 
                the applicable number shall be--
                          ``(i) except as provided in subparagraph (B), 
                      in the case of calendar years before 2021, 250,
                          ``(ii) in the case of calendar year 2021, 100, 
                      and
                          ``(iii) in the case of calendar years after 
                      2021, 10.
                    ``(B) Special rule for partnerships for 2018, 2019, 
                2020, and 2021.--In the case of a partnership, for any 
                calendar year before 2022, the applicable number shall 
                be--
                          ``(i) in the case of calendar year 2018, 200,
                          ``(ii) in the case of calendar year 2019, 150,
                          ``(iii) in the case of calendar year 2020, 
                      100, and
                          ``(iv) in the case of calendar year 2021, 50.
            ``(6) Partnerships required to file on magnetic media.--
        Notwithstanding paragraph (2)(A), the Secretary shall

[[Page 133 STAT. 1013]]

        require partnerships having more than 100 partners to file 
        returns on magnetic media.''.

    (c) Returns Filed by a Tax Return Preparer.--Section 6011(e)(3) is 
amended <<NOTE: 26 USC 6011.>>  by adding at the end the following new 
subparagraph:
                    ``(D) Exception for certain preparers located in 
                areas without internet access.--The 
                Secretary <<NOTE: Waiver authority. Determination.>>  
                may waive the requirement of subparagraph (A) if the 
                Secretary determines, on the basis of an application by 
                the tax return preparer, that the preparer cannot meet 
                such requirement by reason of being located in a 
                geographic area which does not have access to internet 
                service (other than dial-up or satellite service).''.

    (d) Conforming Amendment.--Section 6724(c) is amended by striking 
``250 information returns (more than 100 information returns in the case 
of a partnership having more than 100 partners)'' and inserting ``the 
applicable number (determined under section 6011(e)(5) with respect to 
the calendar year to which such returns relate) of information 
returns''.
    (e) <<NOTE: 26 USC 6011 note.>>  Effective Date.--The amendments 
made by this section shall take effect on the date of the enactment of 
this Act.
SEC. 2302. UNIFORM STANDARDS FOR THE USE OF ELECTRONIC SIGNATURES 
                          FOR DISCLOSURE AUTHORIZATIONS TO, AND 
                          OTHER AUTHORIZATIONS OF, PRACTITIONERS.

    Section 6061(b)(3) is amended to read as follows:
            ``(3) Published guidance.--
                    ``(A) In general.--The Secretary shall publish 
                guidance as appropriate to define and implement any 
                waiver of the signature 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 <<NOTE: Deadline. Procedures.>>  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 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) <<NOTE: Definition.>>  Practitioner.--For 
                purposes of subparagraph (B), the term `practitioner' 
                means any individual in good standing who is regulated 
                under section 330 of title 31, United States Code.''.
SEC. 2303. PAYMENT OF TAXES BY DEBIT AND CREDIT CARDS.

    Section 6311(d)(2) is amended by adding at the end the following: 
``The preceding sentence shall not apply to the extent that the 
Secretary ensures that any such fee or other consideration is fully 
recouped by the Secretary in the form of fees paid to the Secretary by 
persons paying taxes imposed under subtitle A with credit, debit, or 
charge cards pursuant to such contract. Notwithstanding the preceding 
sentence, the Secretary shall seek to minimize the amount of any fee or 
other consideration that the Secretary pays under any such contract.''.

[[Page 133 STAT. 1014]]

SEC. 2304. <<NOTE: 26 USC 6011 note.>>  AUTHENTICATION OF USERS OF 
                          ELECTRONIC SERVICES ACCOUNTS.

    Beginning 180 days <<NOTE: Effective date. Time period.>>  after the 
date of the enactment of this Act, the Secretary of the Treasury (or the 
Secretary's delegate) shall verify the identity of any individual 
opening an e-Services account with the Internal Revenue Service before 
such individual is able to use the e-Services tools.

                      Subtitle E--Other Provisions

SEC. 2401. REPEAL OF PROVISION REGARDING CERTAIN TAX COMPLIANCE 
                          PROCEDURES AND REPORTS.

    Section 2004 of the Internal Revenue Service Restructuring and 
Reform Act of 1998 (26 U.S.C. 6012 note) is repealed.
SEC. 2402. COMPREHENSIVE TRAINING STRATEGY.

    Not <<NOTE: Deadline. Reports. Plans.>>  later than 1 year after the 
date of the enactment of this Act, the Commissioner of Internal Revenue 
shall submit to Congress a written report providing a comprehensive 
training strategy for employees of the Internal Revenue Service, 
including--
            (1) <<NOTE: Assessment.>>  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, for employees that interface with taxpayers and the 
        direct managers of such employees;
            (3) a plan to improve technology-based training;
            (4) <<NOTE: Proposals.>>  proposals to--
                    (A) focus employee training on early, fair, and 
                efficient resolution of taxpayer disputes for employees 
                that interface with taxpayers and the direct managers of 
                such employees; and
                    (B) ensure consistency of skill development and 
                employee evaluation throughout the Internal Revenue 
                Service; and
            (5) <<NOTE: Assessment.>>  a thorough assessment of the 
        funding necessary to implement such 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 SERVICE WHO WAS INVOLUNTARILY 
                          SEPARATED FROM SERVICE FOR MISCONDUCT.

    (a) <<NOTE: 26 USC 7804.>>  In General.--Section 7804 is amended by 
adding at the end the following new subsection:

    ``(d) Prohibition on Rehiring Employees Involuntarily Separated.--
The Commissioner may not hire any individual previously employed by the 
Commissioner who was removed for misconduct under this subchapter or 
chapter 43 or chapter 75 of

[[Page 133 STAT. 1015]]

title 5, United States Code, or whose employment was terminated under 
section 1203 of the Internal Revenue Service Restructuring and Reform 
Act of 1998 (26 U.S.C. 7804 note).''.
    (b) <<NOTE: 26 USC 7804 note.>>  Effective Date.--The amendment made 
by subsection (a) shall apply with respect to the hiring of employees 
after the date of the enactment of this Act.
SEC. 3002. <<NOTE: Determinations.>>  NOTIFICATION OF UNAUTHORIZED 
                          INSPECTION OR DISCLOSURE OF RETURNS AND 
                          RETURN INFORMATION.

    (a) <<NOTE: 26 USC 7431.>>  In General.--Subsection (e) of section 
7431 is amended by adding at the end the following new sentences: ``The 
Secretary shall also notify such taxpayer if the Internal Revenue 
Service or a Federal or State agency (upon notice to the Secretary by 
such Federal or State agency) proposes an administrative determination 
as to disciplinary or adverse action against an employee arising from 
the employee's unauthorized inspection or disclosure of the taxpayer's 
return or return information. The notice described in this subsection 
shall include the date of the unauthorized inspection or disclosure and 
the rights of the taxpayer under such administrative determination.''.

    (b) <<NOTE: Applicability. Time period. 26 USC 7431 note.>>  
Effective Date.--The amendment made by this section shall apply to 
determinations proposed after the date which is 180 days after the date 
of the enactment of this Act.

         Subtitle B--Provisions Relating to Exempt Organizations

SEC. 3101. MANDATORY E-FILING BY EXEMPT ORGANIZATIONS.

    (a) In General.--Section 6033 is amended by redesignating subsection 
(n) as subsection (o) and by inserting after subsection (m) the 
following new subsection:
    ``(n) Mandatory Electronic Filing.--Any organization required to 
file a return under this section shall file such return in electronic 
form.''.
    (b) Other Reports and Returns.--
            (1) Political organizations.--Section 527(j)(7) is amended 
        by striking ``if the organization has'' and all that follows 
        through ``such calendar year''.
            (2) Unrelated business income tax returns.--Section 6011 is 
        amended by redesignating subsection (h) as subsection (i) and by 
        inserting after subsection (g) the following new subsection:

    ``(h) Mandatory E-Filing of Unrelated Business Income Tax Return.--
Any organization required to file an annual return under this section 
which relates to any tax imposed by section 511 shall file such return 
in electronic form.''.
    (c) Inspection of Electronically Filed Annual Returns.--Section 
6104(b) is amended by adding at the end the following: ``Any annual 
return required to be filed electronically under section 6033(n) shall 
be made available by the Secretary to the public as soon as practicable 
in a machine readable format.''.
    (d) <<NOTE: 26 USC 527 note.>>  Effective Date.--
            (1) In general.--Except as provided in paragraph (2), the 
        amendments made by this section shall apply to taxable years 
        beginning after the date of the enactment of this Act.
            (2) Transitional relief.--

[[Page 133 STAT. 1016]]

                    (A) Small organizations.--
                          (i) <<NOTE: Determination. Time period.>>  In 
                      general.--In the case of any small organizations, 
                      or any other organizations for which the Secretary 
                      of the Treasury or the Secretary's delegate 
                      (hereafter referred to in this paragraph as the 
                      ``Secretary'') determines the application of the 
                      amendments made by this section would cause undue 
                      burden without a delay, the Secretary may delay 
                      the application of such amendments, but such delay 
                      shall not apply to any taxable year beginning on 
                      or after the date that is 2 years after the 
                      enactment of this Act.
                          (ii) <<NOTE: Definition.>>  Small 
                      organization.--For purposes of clause (i), the 
                      term ``small organization'' means any 
                      organization--
                                    (I) the gross receipts of which for 
                                the taxable year are less than $200,000; 
                                and
                                    (II) the aggregate gross assets of 
                                which at the end of the taxable year are 
                                less than $500,000.
                    (B) <<NOTE: Time period.>>  Organizations filing 
                form 990-t.--In the case of any organization described 
                in section 511(a)(2) of the Internal Revenue Code of 
                1986 which is subject to the tax imposed by section 
                511(a)(1) of such Code on its unrelated business taxable 
                income, or any organization required to file a return 
                under section 6033 of such Code and include information 
                under subsection (e) thereof, the Secretary may delay 
                the application of the amendments made by this section, 
                but such delay shall not apply to any taxable year 
                beginning on or after the date that is 2 years after the 
                enactment of this Act.
SEC. 3102. NOTICE REQUIRED BEFORE REVOCATION OF TAX-EXEMPT STATUS 
                          FOR FAILURE TO FILE RETURN.

    (a) <<NOTE: 26 USC 6033.>>  In General.--Section 6033(j)(1) is 
amended by striking ``If an organization'' and inserting the following:
                    ``(A) <<NOTE: Time period.>>  Notice.--If an 
                organization described in subsection (a)(1) or (i) fails 
                to file the annual return or notice required under 
                either subsection for 2 consecutive years, the Secretary 
                shall notify the organization--
                          ``(i) that the Internal Revenue Service has no 
                      record of such a return or notice from such 
                      organization for 2 consecutive years, and
                          ``(ii) about the revocation that will occur 
                      under subparagraph (B) if the organization fails 
                      to file such a return or notice by the due date 
                      for the next such return or notice required to be 
                      filed.
                The notification under the preceding sentence shall 
                include information about how to comply with the filing 
                requirements under subsections (a)(1) and (i).
                    ``(B) Revocation.--If an organization''.

    (b) <<NOTE: Applicability. Time period. 26 USC 6033 note.>>  
Effective Date.--The amendment made by this section shall apply to 
failures to file returns or notices for 2 consecutive years if the 
return or notice for the second year is required to be filed after 
December 31, 2019.

[[Page 133 STAT. 1017]]

                      Subtitle C--Revenue Provision

SEC. 3201. INCREASE IN PENALTY FOR FAILURE TO FILE.

    (a) In General.--The second sentence of subsection (a) of section 
6651 <<NOTE: 26 USC 6651.>>  is amended by striking ``$205'' and 
inserting ``$330''.

    (b) Inflation Adjustment.--Section 6651(j)(1) is amended--
            (1) by striking ``2014'' and inserting ``2020'',
            (2) by striking ``$205'' and inserting ``$330'', and
            (3) by striking ``2013'' and inserting ``2019''.

    (c) <<NOTE: 26 USC 6651 note.>>  Effective Date.--The amendments 
made by this section shall apply to returns required to be filed after 
December 31, 2019.

                       TITLE IV--BUDGETARY EFFECTS

SEC. 4001. DETERMINATION OF BUDGETARY EFFECTS.

    The budgetary effects of this Act, for the purpose of complying with 
the Statutory Pay-As-You-Go Act of 2010, shall be determined by 
reference to the latest statement titled ``Budgetary Effects of PAYGO 
Legislation'' for this Act, submitted for printing in the Congressional 
Record by the Chairman of the House Budget Committee, provided that such 
statement has been submitted prior to the vote on passage.

    Approved July 1, 2019.

LEGISLATIVE HISTORY--H.R. 3151:
---------------------------------------------------------------------------

CONGRESSIONAL RECORD, Vol. 165 (2019):
            June 10, considered and passed House.
            June 13, considered and passed Senate.
DAILY COMPILATION OF PRESIDENTIAL DOCUMENTS (2019):
            July 1, Presidential statement.

                                  <all>