DESCRIPTION OF THE CHAIRMAN'S AMENDMENT IN THE NATURE OF A SUBSTITUTE TO H.R. 7959, THE “IRS WHISTLEBLOWER PROGRAM IMPROVEMENT ACT”
JOINT COMMITTEE ON TAXATION
March 24, 2026
JCX-14-26
The Chairman's amendment in the nature of a substitute strikes the language of the bill and replaces it with similar language with the following changes.
In section 3 of H.R. 7959, a new paragraph D for IRC Code section 7623(b)(4) provides that a whistleblower in a Tax Court proceeding “shall proceed anonymously” absent a finding of societal interests that outweigh potential harm to the whistleblower. The amendment changes “shall proceed” to “may elect to proceed[.]”
In addition, the provisions of section 3 are now effective for petitions under section 7623(b)(4) which are pending on, or filed on or after, the date of enactment of this Act.
The amendment in the nature of a substitute is estimated not to change Federal revenues relative to the estimated revenue effects of H.R. 7959. For the revenue estimate of H.R. 7959, see Joint Committee on Taxation, Estimated Revenue Effects of H.R. 7959, the “IRS Whistleblower Program Improvement Act” (JCX-9-26), March 23, 2026.
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