Bill · S. 5173· Senate(119-S-5173)
Fairness in Foreign Filing Act
- Introduced
- 7/30/2026
- Last activity
- 7/30/2026 — Read twice and referred to the Committee on Finance.
- Sponsored by
- Sheldon Whitehouse
- Cosponsors
- - 0 - 1
- Introduced
- In Committee
What this bill would do
This bill is cited as the Fairness in Foreign Filing Act. It amends the Internal Revenue Code of 1986 to treat certain tax penalties as assessable in the same manner as taxes. It requires the government to provide written notice to taxpayers before assessing certain covered penalties. It also grants taxpayers the right to request a review of these proposed penalties by the Internal Revenue Service Independent Office of Appeals. Finally, the bill repeals specific due date requirements for certain information returns relating to foreign trusts.
Who it would affect, and how
Potential Positive Impacts for People
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Preliminary Notice and Right of Review: Under Section 2(b), which adds Section 6752(a) and Section 6752(b) to the Internal Revenue Code, taxpayers must receive a written notice by mail at least 60 days (or 120 days if outside the United States) before a covered penalty can be assessed. This provision gives individuals the chance to understand the basis for the penalty and request a review by the Internal Revenue Service Independent Office of Appeals.
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Suspension of Assessment and Collection: Under Section 2(b), which adds Section 6752(c), covered penalties cannot be assessed, demanded, or collected while the taxpayer is waiting for the review period to expire or while a review by the Independent Office of Appeals is ongoing. This protects individuals from immediate collection actions and gives them fair time to address the issue.
Potential Negative Impacts for People
- Tax Penalties Treated as Taxes: Under Section 2(a), which amends Section 6671(a) of the Internal Revenue Code, any penalties provided by the title will generally be treated and assessable in the same manner as taxes. This could place a heavier administrative and financial burden on individuals who face these penalties.
- 7/30/2026
- Read twice and referred to the Committee on Finance.
- 1 Cosponsor added.
- Introduced in Senate
One bill Congress.gov lists as related to this one — companions in the other chamber, earlier versions, and bills this one absorbed or was folded into.
Bill CassidyRepublican · Louisiana