Fairness in Foreign Filing Act

This bill changes how the IRS handles certain tax penalties. It would treat penalties under the federal tax code as assessable in the same way as taxes, except for penalties that are collected through a civil or criminal court action. Before assessing certain penalties tied to foreign reporting, the IRS would have to mail the taxpayer a written notice at least 60 days ahead (120 days for taxpayers outside the United States). The taxpayer could then ask the IRS Independent Office of Appeals to review the penalty, and the penalty could not be collected until the review ends. The bill also repeals certain due date rules for information returns about foreign trusts, starting with tax years beginning after December 31, 2026.

Full text and official record on Congress.gov

Sponsors

• Sheldon Whitehouse Democrat sponsor
• 1 cosponsors