On October 6, the National Whistleblower Center (NWC) and a coalition of whistleblower law firms filed an amicus brief supporting the United States in the Supreme Court case Bittner v. United States. The whistleblower advocates argue for a “per account” approach to sanctions by the Internal Revenue Service (IRS), a highly technical issue they say has large implications for the IRS Whistleblower Program.
Bittner v. United States will resolve a Circuit split on whether the failure to file an annual Report of Foreign Bank and Financial Accounts is a single violation under the Bank Secrecy Act regardless of the number of relevant accounts or whether each individual account that was not reported constitutes a unique violation.
The whistleblower advocates argue in the brief that a “per account” approach will lead to larger sanctions issued by the IRS, which would mean that more cases would qualify for whistleblower awards, in turn furthering the strength of the IRS Whistleblower Program.
“By ruling in favor of a ‘per-account’ enforcement regime, the Court will align the law with the Congressional intent to effectively track illegal tax activities with the support of whistleblower tips,” the brief states. “Whistleblowers have proven to be a boon for tax enforcement efforts and a ‘per-account’ approach will continue the success of the IRS Whistleblower Program, safeguarding billions of tax-dollars and deterring criminal activity.”
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