Congress formally rebuilt the IRS whistleblower program through the Tax Relief and Health Care Act of 2006, signed by President George W. Bush on December 20, 2006. Section 7623(b) authorized rewards of 15% to 30% when insider information substantially contributed to collecting more than $2 million in tax, penalties, interest, or related sanctions. The program produced major recoveries: an IRS fiscal 2020 report said the office had paid more than $1.01 billion in awards while collecting $6.14 billion, including back taxes, interest, penalties, and criminal fines. In September 2012, former UBS banker Bradley Birkenfeld received $104 million after providing information concerning more than $5 billion in unpaid taxes.
The program’s enforcement value has been undermined by extreme delays. The IRS reported that Section 7623(b) claims took an average of nearly 11 years to process in 2020, compared with 10.3 years in 2019, potentially discouraging insiders from exposing complex tax-evasion schemes. In 2023, IRS agents Gary Shapley and Joseph Ziegler testified to Congress that the Justice Department restricted aspects of the Hunter Biden tax investigation and blocked leads they believed could have implicated President Joe Biden; those claims were publicly made whistleblower allegations, not established findings in the supplied source.