,,ii #aaith ,,congress #b;d ,session ,s4 #dfci ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,may #ba1 #bjbf,mr4 ,grassley 7for himself and ,mr4 ,wyden7 introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to provide additional support to whistleblowers who report information about noncompliance with ,federal tax laws4 #a4 ,short title ,this ,act may be cited as the ,,irs ,whistleblower ,program ,improvement ,act4 #b4 ,standard and scope of review of whistleblower award determinations 7a7 ,in general ,paragraph 7#d7 of section #gfbc7;b7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by striking appealed to and inserting reviewed by2 and 7#b7 by adding at the end the following3 ,any review by the ,tax ,court under the preceding sentence shall be de novo and shall be based on the administrative record established at the time of the original determination and any additional newly discovered or previously unavailable evidence44 7b7 ,conforming amendment ,the heading of paragraph 7#d7 of section #gfbc7;b7 of the ,internal ,revenue ,code of #aihf is amended by striking ,appeal and inserting ,review4 7c7 ,effective date ,the amendments made by this section shall apply to petitions under section #gfbc7;b77#d7 of the ,internal ,revenue ,code of #aihf which are pending on1 or filed on or after1 the date of the enactment of this ,act4 #c4 ,exemption from sequestration 7a7 ,in general ,section #bee of the ,balanced ,budget and ,emergency ,deficit ,control ,act of #aihe 7#b ,u4,s4,c4 #ije7 is amended-- 7#a7 by redesignating subsection 7k7 as subsection 7l72 and 7#b7 by inserting after subsection 7j7 the following3 7k7 ,awards to whistleblowers ,an award authorized under section #gfbc of the ,internal ,revenue ,code of #aihf shall be exempt from reduction under any order issued under this part4 4 7b7 ,applicability ,the amendment made by this section shall apply to any sequestration order issued under the ,balanced ,budget and ,emergency ,deficit ,control ,act of #aihe 7#b ,u4,s4,c4 #ijj et seq47 after the date of enactment of this ,act4 #d4 ,whistleblower privacy protections 7a7 ,in general ,paragraph 7#f7 of section #gfbc7;b7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subparagraph3 7,d7 ,whistleblower anonymity before the ,tax ,court ,notwithstanding sections #gdeh and #gdfa1 a whistleblower shall proceed anonymously before the ,tax ,court for all proceedings under this section absent a finding by the ,tax ,court that a societal interest exists for disclosing the whistleblower's identity which exceeds the potential harm disclosure could cause to the whistleblower4 4 7b7 ,effective date ,the amendment made by this section shall apply to petitions filed with the ,tax ,court which are pending on1 or filed on or after1 the date of the enactment of this ,act4 #e4 ,modification of ,,irs whistleblower report 7a7 ,in general ,section #djf7;c7 of division ,a of the ,tax ,relief and ,health ,care ,act of #bjjf is amended by striking such use1 in paragraph 7#a7 and inserting such use 7which shall include a list and descriptions of the top tax avoidance schemes1 not to exceed #aj1 disclosed by whistleblowers during such year714 7b7 ,effective date ,the amendments made by this section shall apply to reports for fiscal years ending after the enactment of this ,act4 #f4 ,interest on whistleblower awards 7a7 ,in general ,section #gfbc7;b7 of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new paragraph3 7#g7 ,interest 7,a7 ,in general ,if the ,secretary has not provided notice to an individual described in paragraph 7#a7 of a preliminary award recommendation before the applicable date1 the amount of any award under this subsection shall include interest from such date at the overpayment rate under section #ffba7;a74 7,b7 ,exception ,no interest shall accrue under this paragraph after the date on which the ,secretary provides notice to the individual of a preliminary award recommendation4 7,c7 ,applicable date ,for purposes of this paragraph1 the applicable date is the date that is #ab months after the first date on which-- 7i7 all of the proceeds resulting from actions subject to the award recommendation have been collected1 and 7ii7 either-- 7,i7 the statutory period for filing a claim or suit for refund has expired1 or 7,,ii7 the taxpayers subject to the actions and the ,secretary have agreed with finality to the tax or other liabilities for the periods at issue1 and either the taxpayers have waived the right to file a claim or suit for refund or any claim or suit for refund has been resolved4 4 7b7 ,effective date 7#a7 ,in general ,the amendments made by this section shall take effect #ahj days after the date of the enactment of this ,act4 7#b7 ,special rule ,if1 as of the date described in paragraph 7#a7-- 7,a7 the ,secretary has not provided notice to the individual of a preliminary award recommendation as described in paragraph 7#g77;,a7 of section #gfbc7;b7 of the ,internal ,revenue ,code of #aihf1 as added by this ,act1 and 7,b7 the applicable date provided in paragraph 7#g77;,c7 of such section1 as so added1 has passed1 the applicable date for purposes of such paragraph 7#g77;,c7 is the date that is #ab months after the date described in paragraph 7#a74 #g4 ,correction regarding deductions for attorney's fees 7a7 ,in general ,section #fb7;a77#ba77;,a77i7 of the ,internal ,revenue ,code of #aihf is amended by striking #gfbc7;b7 and inserting #gfbc4 7b7 ,effective date ,the amendment made by this section shall apply to taxable years ending after the date of the enactment of this ,act4