The bill gives taxpayers more notice, transparency, and protection from unnecessary third‑party inquiries, but it may slow IRS enforcement and raise administrative costs while leaving some legal uncertainty about exceptions.
Taxpayers will get at least 45 days (or longer for reasonable-cause extensions) to respond before the IRS contacts third parties, giving them time to gather and provide requested information.
Taxpayers will receive notices that identify each specific item the IRS intends to request when the taxpayer could reasonably provide it, improving transparency and helping taxpayers understand and respond to requests.
Taxpayers and third parties (e.g., family members, employers) will face fewer unnecessary third‑party inquiries, reducing privacy intrusions and the logistical burden on those third parties.
Taxpayers may experience slower IRS investigations and tax‑collection actions because of the mandatory minimum waiting period before the IRS can contact third parties.
The IRS will incur additional administrative burden and potential compliance costs (possibly requiring more staffing or resources), which could increase taxpayer‑funded costs or slow processing.
Narrow exceptions (for collection or where the Secretary determines necessity) could be broadly interpreted, creating uncertainty about when the protections apply.
Based on analysis of 2 sections of legislative text.
Requires IRS third‑party contact notices to list each specific item sought and gives taxpayers at least 45 days (longer for reasonable‑cause extensions) to respond before third‑party contact, with limited exceptions.
Introduced December 5, 2025 by W. Greg Steube · Last progress December 5, 2025
Amends the Internal Revenue Code to require that when the IRS plans to contact third parties for information that it has not already asked the taxpayer for and the taxpayer could reasonably provide, the IRS must tell the taxpayer exactly what items it intends to request and give the taxpayer at least 45 days (longer when a reasonable-cause extension applies) to respond or provide the information before contacting those third parties. Limited exceptions apply for collection of tax liabilities and when the Secretary determines the information is necessary despite prior requestability; the rule applies to notices issued more than 12 months after enactment.