IRS releases Whistleblower Office operating plan

Editor: Michael J. Mondelli, J.D.

The IRS Whistleblower Program plays a critical role in identifying tax noncompliance. Since its inception in 2007, it has led to the collection of over $7 billion in unpaid taxes and awarded more than $1.3 billion to whistleblowers. The Whistleblower Office is building on this success by addressing operational challenges and incorporating feedback from stakeholders, including whistleblowers, legal practitioners, and IRS personnel.

In April 2025, the Whistleblower Office unveiled its first–ever multiyear operating plan, marking a significant step toward enhancing the effectiveness and transparency of its Whistleblower Program. The plan’s purpose and vision are to improve the IRS’s ability to act on credible whistleblower information, ensure fair and timely awards to whistleblowers, enhance communication and transparency, and strengthen internal processes and workforce capabilities. The Service has emphasized that the plan is flexible, allowing for adjustments based on stakeholder feedback and evolving enforcement needs.

This plan is structured around six comprehensive strategic priorities that will improve how the IRS handles whistleblower claims, rewards informants, and integrates their contributions into broader tax enforcement efforts. In addition, there are 38 initiatives of focus within these six strategic priorities. These initiatives will be a mix of short–term actions (such as updating forms and guidance) and long–term reforms (such as building new digital infrastructure and analytics tools).

The six core strategic priorities are:

• Enhancing the claim submission process;
• Using high-value whistleblower information effectively;
• Awarding whistleblowers fairly and promptly;
• Improving communication with whistleblowers about the status of their claims and the basis for IRS decisions on claims;
• Safeguarding sensitive whistleblower and taxpayer information; and
• Supporting the IRS workforce.

A discussion of each of these priorities follows.

Enhancing the claim submission process

To meet the evolving needs of this strategic priority, Form 211, Application for Award for Original Information, has been revised to enable digital processing of the form in the future. The office also aims to establish a digital intake portal for claims, allowing online submissions. To that end, it has updated IRS policy to remove the Form 211 “wet ink” signature requirement. The aim is to improve processes for receiving, analyzing, and classifying claims. In addition, staffing resources will be adjusted where needed to improve processing efficiencies.

Using high-value whistleblower information effectively

The Whistleblower Office has implemented a new organizational structure creating a triage system by a new team that will focus on improving the initial analysis of claims. This could help it to prioritize high–impact claims. It also seeks to improve coordination between the Whistleblower Office and IRS enforcement divisions and to leverage data analytics, which it says could help reduce the backlog of existing cases.

Awarding whistleblowers fairly and promptly

The Whistleblower Office has updated the Internal Revenue Manual (IRM) to provide clarification factors for allowing earlier award payments once certain completed actions are separated (“disaggregated”) from pending ones. The office continuously reviews its “risk appetite” as it moves toward an approach that carefully analyzes the level of risk and potential benefits. In addition, it will streamline the award determination process to reduce delays and increase transparency in how award percentages are calculated. The office has developed new internal measures and metrics reporting to improve its performance on claims.

Improving communication with whistleblowers

The Whistleblower Office continuously invests in improvements to whistleblower services and the notice process under provisions of the Taxpayer First Act, P.L. 116–25. It will continue to work with the IRS Office of Chief Counsel to establish regular status updates for claimants and their representatives and consider possible regulatory changes to allow clearer explanations for claim denials.

Safeguarding sensitive whistleblower and taxpayer information

Safeguarding whistleblower and taxpayer information is a high priority for the IRS, the Whistleblower Office states. The Service revised the IRM and added guidance for request procedures under the Freedom of Information Act, P.L. 89–487, to strengthen controls over and protection of whistleblower records. It has enhanced cybersecurity protocols to protect whistleblowers’ identities, implemented stricter access controls for sensitive case files, and trained staff on confidentiality and data–protection best practices.

Supporting the IRS workforce

The Whistleblower Office strives to hire, develop, and retain dedicated, knowledgeable, and experienced staff who are committed to providing excellent service to all program stakeholders. It reviews employee and management standard position descriptions to ensure those align with responsibilities and roles. Additionally, the Whistleblower Office is expanding training programs for staff who handle whistleblower claims and fostering a culture of collaboration across IRS programs and business units.

Toward a more effective Whistleblower Program

With an improved Whistleblower Program, the IRS is likely to identify more underreported income, offshore accounts, and fraudulent deductions. Taxpayers, especially those with complex returns, may face greater scrutiny and a higher risk of audit if they are noncompliant. The Whistleblower Office operating plan can encourage more employees, accountants, or business partners to report tax fraud. This will lead to more detailed and credible tips being submitted. More effectively using the information provided will help close the tax gap (the difference between taxes owed and taxes paid) and ensure that everyone pays their fair share. In essence, honest taxpayers will benefit from an improved Whistleblower Program, where tax cheats are held accountable and enforcement is more consistent.

Increasing transparency and predictability in the program will improve public trust in the tax system and help tax professionals better advise clients on compliance risks. As a result, taxpayers may feel more confident that the system is working fairly and that enforcement is based on clear, consistent rules.

Editor

Michael J. Mondelli, J.D., is a director in the Tax Advisory Group, with SingerLewak LLP in Irvine, Calif.

For additional information about these items, contact Mondelli at mmondelli@singerlewak.com.

Contributors are members of or associated with SingerLewak LLP.