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Replaces and expands the provisions governing identifying numbers for tax return preparers: replaces subsection (a)(4) (furnishing identifying number of tax return preparer) to add supervised-preparer exception, suspension/revocation rules, and definitions (including "specified practitioner"), and inserts a new subsection (e) establishing an administrative program for preparer tax identification numbers with suitability, education, and state-program requirements, suspension/revocation authority, monetary penalties, reinstatement procedures, preliminary-suspension authority, and publication/disclosure requirements.
Redesignates existing subsection (c) as (d) and inserts a new subsection (c) requiring supervisors (persons described in new 6109(a)(4)(B)(ii)(III)) to include in returns the names and taxpayer identification numbers of preparers under their supervision, the employment status of each such preparer as of the return date, and any other information the Secretary determines appropriate.
Redesignates existing subsection (e) as (f) and inserts a new subsection (e) requiring publication on a public website of final determinations under subsection (c) or (d) within 30 days, including a statement of facts/circumstances and the reasons for the determination.
Adds a new paragraph (k)(16) authorizing the Secretary, under prescribed procedures, to disclose returns and return information (redacted to remove identifying information of persons other than the subject preparer/representative) to the extent necessary to publish determinations under new 6109(e)(7) and 31 U.S.C. 330(e); and makes a conforming amendment to include the new paragraph (16) in the cross-reference list in 6103(p)(3)(A).
Adds a new subsection (h) to section 7122 establishing a $250 penalty for a person who prepares an offer-in-compromise for compensation and fails to include a complying identifying number under new section 6109(a)(5), defines circumstances where an identifying number is noncompliant (e.g., assigned to another person, inactive/expired, withdrawn, suspended/revoked, or otherwise invalid), provides for inflation adjustments, exceptions for reasonable cause, and an annual cap on maximum penalties (e.g., $75,000) with its own inflation-adjustment rule.
Revises subsection (c) to increase the penalty for failure to furnish a complying identifying number and to define categories of non-compliance; redesignates existing subsection (h) as (i); inserts a new subsection (h) imposing a penalty on electronic return originators who fail to use an assigned electronic filing identification number and adds definitions for 'electronic return originator' and 'electronic filing identification number'; updates cross-references.
Modifies the definition of 'tax return preparer' to expand the scope of covered documents and to treat preparation of a substantial portion of a return, document purporting to be a return, or claim for refund as preparation; updates related subparagraph (B) clauses to include 'document purporting to be a return'.
Adds new section 7218 to chapter 75 (Part I of subchapter A) creating a criminal offense titled 'Willful misuse or misappropriation of identifying number' that penalizes a tax return preparer who willfully furnishes or fails to furnish preparer tax identification numbers in specified wrongful ways and defines 'preparer tax identification number' as the identifying number described in section 6109(a)(4)(A).
Revises subsection (e)(1) to change the statutory definition of 'return' by adding subparagraph (D) to cover any other document purporting to be a return, request, or report described in subparagraphs (A) through (C).
Referred to the House Committee on Ways and Means.
Introduced November 28, 2025 by James Varni Panetta · Last progress November 28, 2025
Referred to the House Committee on Ways and Means.
Introduced in House