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Makes broad changes to how the IRS enforces tax law, how taxpayers resolve disputes, and how IRS personnel are supervised and disciplined. It limits what the IRS Independent Office of Appeals may decide on appeal, restricts seizure of a taxpayer’s principal residence except after a written Treasury determination, expands taxpayer options for mediation/arbitration and conferences with Appeals, creates a new limited deduction for certain audit-related costs, changes offers-in-compromise and levy rules for businesses, raises civil damages and criminal/administrative penalties for unauthorized disclosures or misconduct, and increases oversight and reporting by TIGTA and other accountability provisions. Many changes take effect on enactment; some tax provisions apply to taxable years beginning after enactment and certain inflation adjustments begin after 2025.
Read twice and referred to the Committee on Finance.
Introduced April 9, 2025 by John Cornyn · Last progress April 9, 2025