A bill to amend the Internal Revenue Code of 1986 to treat tax penalties as assessable in the same manner as taxes, to provide notice requirements for certain penalties, and for other purposes.
About This Bill
Committee
Latest Action · July 30, 2026
Read twice and referred to the Committee on Finance.
The Fairness in Foreign Filing Act modifies how the Internal Revenue Service handles certain tax penalties, primarily those related to foreign financial reporting requirements. The bill treats tax penalties more like regular taxes for assessment purposes and requires the IRS to provide taxpayers with advance written notice at least 60 days before assessing covered penalties, along with information about the penalty basis and the right to request an independent review. Taxpayers can request a review by the IRS Office of Appeals within the notice period, during which time the IRS cannot assess or collect the penalty. The covered penalties addressed in this bill relate to foreign trusts, controlled foreign corporations, foreign financial assets, and other international tax reporting obligations. The bill also repeals certain due date requirements for information returns relating to foreign trusts effective for tax years beginning after December 31, 2026, and includes an exception allowing the IRS to bypass these notice and review requirements when collection is considered in jeopardy.
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