119th CONGRESS 1st Session |
To amend the Internal Revenue Code of 1986 to provide for specific taxpayer notice when information is sought from third parties.
December 5, 2025
Mr. Steube (for himself and Mr. Panetta) introduced the following bill; which was referred to the Committee on Ways and Means
To amend the Internal Revenue Code of 1986 to provide for specific taxpayer notice when information is sought from third parties.
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,
This Act may be cited as the “Taxpayer Notification and Privacy Act”.
SEC. 2. Specificity of third-party contact notices.
(a) In general.—Paragraph (1) of section 7602(c) of the Internal Revenue Code of 1986 is amended—
(1) by striking “and” at the end of subparagraph (A),
(2) by redesignating subparagraph (B) as subparagraph (C),
(3) by inserting after subparagraph (A) the following new subparagraph:
“(B) in any case in which the information sought to be obtained from such other persons has not been previously requested from the taxpayer and could reasonably be provided by the taxpayer, identifies each specific item of information intended to be sought from such persons, and”, and
(4) by amending subparagraph (C), as redesignated by paragraph (2), to read as follows:
“(C) except as otherwise provided by the Secretary, provides the taxpayer with reasonable opportunity and a period of not less than 45 days (or more, if the taxpayer requests additional time and shows reasonable cause) to respond, including by providing the information described in subparagraph (B), before contact is made with such other persons.”.
(b) Exception.—Section 7602(c)(3) of the Internal Revenue Code of 1986 is amended—
(1) by redesignating subparagraphs (A), (B), and (C) as clauses (i), (ii), and (iii), respectively, and by moving such clauses 2 ems to the right,
(2) by striking “Exceptions.—This subsection” and inserting “Exceptions.—
“(A) IN GENERAL.—This subsection”, and
(3) by adding at the end the following new subparagraph:
“(B) EXCEPTION FOR INFORMATION SPECIFICITY.—Subparagraph (B) of paragraph (1) (and so much of subparagraph (C) of paragraph (1) as relates to such subparagraph (B)) shall not apply to information sought from a person other than the taxpayer if—
“(i) such information is sought with respect to the collection of a tax liability, or
“(ii) the Secretary determines that such information is necessary notwithstanding whether the taxpayer could independently provide such information or whether such information has been previously requested from the taxpayer,”.
(c) Effective date.—The amendments made by this subsection shall apply to notices provided under section 7602(c) of the Internal Revenue Code of 1986 after the date that is 12 months after the date of the enactment of this Act.