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Rule 7: Get a Reward! Tax Cheats and the IRS Qui Tam
“The IRS’ serious efforts to combat offshore tax evasion, which had long been a problem, began in 2008 with our efforts to address specific situations brought to our attention in part by whistleblowers.”
John Koskinen, Commissioner, IRS
- Internal Revenue Manual Section on Whistleblower Program
- 26 USC § 7623
- Read the 2019 amendment of 26 USC § 7623, related to compensatory damages and sharing of information.
- Read the 2018 amendment of 26 USC § 7623, related to taxation of awards.
- Final IRS Whistleblower Rules (August 12, 2014)
- Whistleblower 14106-10W v. Commissioner of the IRS, 137 Tax Court No. 15 (December 8, 2011) (decision of the Tax Court permitting
whistleblower to remain confidential in Tax Court proceedings). - Whistleblower 13412-12W v. Commissioner, T.C. Memo. 2014-93 (May 20, 2014) (setting forth procedures for requesting anonymity in tax court proceedings).
- Whistleblower 21276-13W v. Commissioner, 147 Tax Court No. 4 (August 3, 2016) (broad interpretation of “related action” rule permitting whistleblowers to obtain rewards based on tax-related criminal proceedings).
- Whistleblower 21276-13W v. Commissioner, 144 Tax Court No. 15 (June 2, 2015) (whistleblower can qualify for a reward if initially
provides information to other government agencies instead of the IRS Whistleblower Office). - Whistleblower 11099-13W v. Commissioner, 147 Tax Court No. 3 (July 28, 2016) (Whistleblowers can conduct discovery in tax court as to why the IRS denied a reward).
- Cooper v. Commissioner, 2010 Tax Court LEXIS 20, 135 T.C. No 4 (July 8,2010)
- Tax Court Decision Protecting Confidentiality
- Swiss Bank Program Sees Final Resolutions
- IRS Whistleblower Office Releases Information on Claim Process
- Tax Court Ruling: Landmark Victory for Whistleblowers
- UBS Whistleblower Chronicles the Demise of Swiss Banking Secrecy
- Inspector General Recommends Improvements for IRS Whistleblower Program
- 13.769 Billion Reasons to Thank Whistleblowers on Tax Day
- Brad Birkenfield receives $104 million IRS whistleblower award
- Tax Court Delivers Victory For Tax Whistleblowers
- Illegal Swiss Banking Collapses
- The Legality of the IRS’ Proposed Whistleblower Rule: Flunking The Loving Test
- IRS Commissioner Koskinen’s Remarks at US CIB and OECD International Tax Conference (June 2014)
- Form 211, IRS Application for Award for Original Information (form used to file as an IRS Whistleblower)
- Taxpayer First Act Of 2019: Report of the Committee on Ways and Means: House of Representatives on H.R. 1957
- DOJ Swiss Bank Program
- GAO report, IRS Whistleblower Program: Billions Collected but Timeliness and Communication Concerns May Discourage Whistleblowers (October 2015)
- GAO report on Offshore Tax Evasion, IRS Has Collected Billions of Dollars, but May be Missing Continued Evasion (March 2013) (Part 1 and Part 2).
- Whistleblower Office Annual Report (2018)
- Whistleblower Office Annual Report (2017)
- Whistleblower Office Annual Report (2016)
- Whistleblower Office Annual Report (2015)
- Whistleblower Office Annual Report (2014)
- Whistleblower Office Annual Report (2013).
- Whistleblower Office Annual Report (2012).
- Whistleblower Office Annual Report (2011).
- Whistleblower Office Annual Report (2010).
- Whistleblower Office Annual Report (2009).
- Whistleblower Office Annual Report (2008).
- Whistleblower Office Annual Report (Initial Report after the Office’s first 12 months).
- Who Blows the Whistle on Corporate Fraud? Chicago Booth School Study, Alexander Dyck, Adair Morse, Luigi Zingales (September 2009)
- IRS Whistleblower Office At-a-Glance
- IRS Page on Whistleblower Informant Awards
- IRS Notice 2008-4, 2008-1
- Karie Davis-Nozemack, et al., “Lost Opportunities: The Underuse of Tax Whistleblowers,” 67 Administrative Law Review 321 (2015).
- Commissioner Koskinen’s Remarks at US CIB and OECD Int Tax Conf June 2014
- Not Just Whistling Dixie: The Case For Tax Whistleblowers in the States (Dennis J. Ventry Jr, Villanova, Vol. 59, Issue 3)
- Bill as introduced (September 19, 2006).
- Senate Amendment and Consideration (Dec 7, 2006).
- The House of Representatives Committee on Rules, Report including Amendment to the Senate Amendment (December 7, 2006).
- The House of Rules Committee Amendment to the Senate Amendment is agreed to in the House of Representatives (December 8, 2006).
- Failed Amendment to the House Amendment of the Senate Amendment (December 8, 2006).
- The Senate agrees to the House of Representatives’ Amendment to the Senate Amendment (December 8, 2006).
- Internal Revenue Manual, Part 25.2.2 (updated June 18, 2010).
- 26 C.F.R. § 301