The bill improves taxpayer notice and privacy by requiring advance notice and response time before third‑party contacts but does so at the cost of added IRS administrative burden, possible enforcement delays, and exceptions that could blunt those protections.
Most taxpayers will receive clearer written notice and at least 45 days to respond before the IRS contacts third parties, giving them an explicit chance to supply requested information and reducing unnecessary third‑party inquiries (preserving privacy and due‑process).
The rule's effective date is delayed 12 months, giving the IRS time to update procedures and reduce abrupt operational disruption.
Taxpayer protections could be undermined because exceptions allow the IRS to contact third parties for collection or whenever the Secretary determines the information is necessary, which could be applied broadly in practice.
Expanded procedural steps may slow enforcement and collection workflows, potentially delaying audits or information‑gathering that affect taxpayers.
The IRS will likely face higher administrative burden and costs to prepare more detailed notices and manage extended response periods, potentially requiring additional staff or resources.
Based on analysis of 2 sections of legislative text.
Requires IRS to specify items it will seek from third parties and give taxpayers at least 45 days to respond before contacting third parties, with narrow exceptions; effective in 12 months.
Requires the IRS to tell taxpayers exactly what information it plans to ask third parties for, and to give taxpayers at least 45 days to provide that information (or ask for more time) before the IRS contacts those third parties. The rule includes a narrow exception for collection of tax liability and for situations the IRS head judges necessary, and it does not take effect until 12 months after enactment.
Introduced December 5, 2025 by W. Greg Steube · Last progress April 28, 2026