Bill · S. 5477· Senate(119-S-5477)
Federal Receivership Fairness Act
- Introduced
- 9/23/2026
- Last activity
- 9/23/2026 — Read twice and referred to the Committee on Finance.
- Sponsored by
- Todd Young
- Cosponsors
- - 0 - 1
- Introduced
- In Committee
What this bill would do
This bill is called the Federal Receivership Fairness Act. It amends the Internal Revenue Code of 1986 to set new rules for how federal taxes are determined during a receivership. The bill gives courts handling receivership proceedings the power to figure out the amount or legality of federal taxes, fines, and penalties. It creates a process for receivers to request a tax determination and receive a discharge from tax liability under certain conditions. The legislation also waives sovereign immunity for the Secretary in these specific matters and grants jurisdiction to Federal courts for federal tax determinations in State or District of Columbia receivership proceedings. Finally, it explicitly excludes bankruptcy trustees and estate executors from the definition of a receiver under these new rules.
Yes
Does this protect the right to fair treatment by the courts?+5
The bill provides receivers and individuals in receivership with a structured court process to resolve federal tax disputes and obtain timely discharges from liability.
Does this make what the government does easier for the public to see?+4
The legislation establishes clear, formalized processes and timelines for courts and the Secretary to determine tax liabilities during receiverships.
Does this give the federal government more power?+3
The bill grants jurisdiction to United States District Courts to adjudicate federal tax determinations in State or District of Columbia receivership proceedings.
The opposite
No question was scored the opposite.
Who it would affect, and how
Potential Positive Impacts for People
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Section 6874(a) allows the court appointing a receiver in a receivership proceeding to determine the amount or legality of any Federal tax, fine, penalty, or addition to tax. This could benefit individuals involved in a receivership by providing a clear, centralized court process to resolve tax disputes rather than dealing with separate administrative tribunals.
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Section 6874(c)(2) allows a receiver to request a determination of unpaid tax liability by submitting a tax return and request. Under this section, the receivership estate, receiver, and successors are discharged from tax liability upon payment if the Secretary fails to notify the receiver of an examination within 60 days or complete it within 180 days. This protects individuals and estates from endless waiting and lingering tax threats by forcing the government to act in a timely manner.
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Section 6874(f)(1) waives sovereign immunity as to the Secretary for matters covered in the bill. This is a positive step for accountability because it allows courts to issue orders, processes, or judgments against the Secretary, ensuring regular people can hold government officials properly responsible during these legal proceedings.
Potential Negative Impacts for People
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Section 6874(b)(1) states that the court shall not determine the amount or legality of any Federal tax or penalty if it was already contested and adjudicated by a judicial or administrative tribunal before the receivership started. This could be a burden for individuals who want a fresh review of a past tax dispute within their receivership proceedings, as they are blocked from re-arguing those specific settled issues.
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Section 6874(g) requires that in any receivership proceeding in a State or District of Columbia court, the determination of any Federal tax must be adjudicated by the United States District Court for that district rather than the local court. This could place a burden on people by forcing them to navigate an extra federal court process instead of handling all parts of their receivership locally.
Groups and Interests Ranking
Every group the model scored this bill for, from -10 to +10. Hover a score for the reason it gave.
- Governance And Ideology
- Improves Due Process+5Improves Government Transparency+4Increases Federal Power+3
- 9/23/2026
- 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.
Mark WarnerDemocrat · Virginia