S. 5441
TAS Act
Sponsor: Mike Crapo · 0 cosponsors
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Text of the bill
I Tax Administration and Customer Service
II American Citizens Abroad
III Judicial Review
IV Office of the Taxpayer Advocate
V Tax Return Preparers
VI Appeals
VII Whistleblowers
(a) In general. Section 7623(b) is amended by adding at the end the following new paragraph:
(7) Interest
(A) In general. If the Secretary has not provided notice to an individual described in paragraph (1) of a preliminary award recommendation before the applicable date, the amount of any award under this subsection shall include interest from such date at the overpayment rate under section 6621(a).
(B) Exception. No interest shall accrue under this paragraph after the date on which the Secretary provides notice to the individual of a preliminary award recommendation.
(C) Applicable date. For purposes of this paragraph, the applicable date is the date that is 12 months after the first date on which—
(i) all of the proceeds resulting from actions subject to the award recommendation have been collected, and
(ii) either—
(I) the statutory period for filing a claim or suit for refund has expired, or
(II) the taxpayers subject to the actions and the Secretary have agreed with finality to the tax or other liabilities for the periods at issue, and either the taxpayers have waived the right to file a claim or suit for refund or any claim or suit for refund has been resolved.
(b) Effective date
(1) In general. The amendments made by this section shall take effect 180 days after the date of the enactment of this Act.
(2) Special rule. If, as of the date described in paragraph (1)— the applicable date for purposes of such paragraph (7)(C) is the date that is 12 months after the date described in paragraph (1).
(A) the Secretary has not provided notice to the individual of a preliminary award recommendation as described in paragraph (7)(A) of section 7623(b) of the Internal Revenue Code of 1986, as added by this Act, and
(B) the applicable date provided in paragraph (7)(C) of such section, as so added, has passed,
VIII Hostages
IX Small Businesses
X Miscellaneous