H.R. 6323

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 6323 Introduced in House (IH)]

<DOC>

119th CONGRESS
1st Session
H. R. 6323

To amend the Internal Revenue Code of 1986 to penalize improper 
compliance with certain taxpayer requirements, and for other purposes.

_______________________________________________________________________

IN THE HOUSE OF REPRESENTATIVES

November 28, 2025

Mr. Panetta (for himself and Mr. Steube) introduced the following bill; 
which was referred to the Committee on Ways and Means

_______________________________________________________________________

A BILL

To amend the Internal Revenue Code of 1986 to penalize improper 
compliance with certain taxpayer requirements, and for other purposes.

Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE; ETC.

(a) Short Title.--This Act may be cited as the ``Taxpayer 
Protection and Preparer Proficiency Act''.
(b) References to Internal Revenue Code.--Except as otherwise 
expressly provided, whenever in this Act an amendment is expressed in 
terms of an amendment to a section or other provision, the reference 
shall be considered to be made to a section or other provision of the 
Internal Revenue Code of 1986.
(c) References to Secretary.--For purposes of this Act, the term 
``Secretary'' means the Secretary of the Treasury or the Secretary's 
delegate.

SEC. 2. PENALTIES FOR TAX RETURN PREPARERS WHO IMPROPERLY ALTER 
RETURNS.

(a) In General.--Paragraph (1) of section 6696(e) is amended to 
read as follows:
``(1) Return.--The term `return' means--
``(A) any return of any tax imposed by this title,
``(B) any administrative adjustment request under 
section 6227,
``(C) any partnership adjustment tracking report 
under section 6226(b)(4)(A), and
``(D) any other document purporting to be a return, 
request, or report described in subparagraphs (A) 
through (C).''.
(b) Effective Date.--The amendment made by this section shall take 
effect on the date of enactment of this Act.

SEC. 3. PENALTIES FOR INVALID OR APPROPRIATED PREPARER IDENTIFICATION 
NUMBERS.

(a) In General.--Section 6695 is amended--
(1) by striking subsection (c) and inserting the following:
``(c) Failure To Furnish Valid Identifying Number.--
``(1) In general.--
``(A) Penalty.--Any person who is a tax return 
preparer with respect to any return or claim for refund 
and who fails to furnish an identifying number which 
complies with section 6109(a)(4)(A) with respect to 
such return or claim shall pay a penalty of $250 for 
such failure.
``(B) Non-compliance.--For purposes of this 
paragraph, an identifying number shall be deemed to not 
comply with section 6109(a)(4)(A) if such identifying 
number--
``(i) is assigned to another person,
``(ii) does not exist,
``(iii) is inactive or expired,
``(iv) has been withdrawn,
``(v) is suspended or has been revoked, or
``(vi) is otherwise invalid for use by the 
tax return preparer.
``(2) Exception.--The penalty imposed under paragraph (1) 
shall not apply if it is shown that such failure is due to 
reasonable cause and not due to willful neglect.
``(3) Limitation.--The maximum penalty imposed under this 
subsection on any person with respect to documents filed during 
any calendar year shall not exceed $75,000.'',
(2) by redesignating subsection (h) as subsection (i),
(3) by inserting after subsection (g) the following new 
subsection:
``(h) Use of Invalid or Appropriated Electronic Filing 
Identification Number.--
``(1) In general.--Any person who is an electronic return 
originator with respect to any return or claim for refund who 
fails to use, with respect to such return or claim, an 
electronic filing identification number which is assigned to 
such person by the Secretary, shall pay a penalty of $250 for 
such failure, unless it is shown that such failure is due to 
reasonable cause and not due to willful neglect.
``(2) Definitions.--For purposes of this subsection--
``(A) Electronic return originator.--
``(i) In general.--The term `electronic 
return originator' means a person who 
originates the electronic submission of 1 or 
more returns or claims for refund on behalf of 
other taxpayers.
``(ii) Exceptions.--The term `electronic 
return originator' shall not include a person 
merely because such person originates an 
electronic submission described in clause (i)--
``(I) by furnishing mechanical 
assistance to a person described in 
such subclause,
``(II) at the direction of an 
employer (or of an officer or employee 
of the employer) by whom such person is 
regularly and continuously employed,
``(III) as a fiduciary, or
``(IV) in response to a 
determination that directly or 
indirectly affects the tax liability of 
a taxpayer.
``(B) Electronic filing identification number.--
``(i) In general.--The term `electronic 
filing identification number' means an 
identification number assigned by the Secretary 
to a person authorized to file returns in 
electronic format on behalf of other taxpayers.
``(ii) Suspension or revocation.--In the 
case of any electronic filing identification 
number which has been suspended or revoked by 
the Secretary, such number shall not be deemed 
valid for purposes of paragraph (1).'', and
(4) in subsection (i)(1), as redesignated by paragraph (2), 
by striking ``and (g)'' and inserting ``(g), and (h)''.
(b) Modification of Definition of Tax Return Preparer.--Section 
7701(a)(36) is amended--
(1) by striking subparagraph (A) and inserting the 
following:
``(A) In general.--The term `tax return preparer' 
means any person who prepares for compensation, or who 
employs one or more persons to prepare for 
compensation, any return of tax imposed by this title, 
any document purporting to be a return of tax imposed 
by this title, or any claim for refund of tax imposed 
by this title. For purposes of the preceding sentence, 
the preparation of a substantial portion of a return, 
document purporting to be a return, or claim for refund 
shall be treated as if it were the preparation of such 
return, document purporting to be a return, or claim 
for refund.'', and
(2) in subparagraph (B)--
(A) in clause (ii), by striking ``return or claim 
for refund'' and inserting ``return, document 
purporting to be a return, or claim for refund'', and
(B) in clause (iii), by striking ``return or claim 
for refund'' and inserting ``return, document 
purporting to be a return, or claim for refund''.
(c) Prevention of Inadvertent Errors Involving Identifying 
Numbers.--
(1) In general.--Not later than 18 months after the date of 
enactment of this Act, the Secretary shall establish a program 
to improve voluntary compliance with respect to requirements 
under subsections (c) and (h) of section 6695 of the Internal 
Revenue Code of 1986 (as amended by this section) and avoid the 
imposition of penalties under such subsections.
(2) Opportunity to correct.--For purposes of the program 
described in paragraph (1), the Secretary shall--
(A) prior to acceptance for processing, identify--
(i) any return or claim for refund which 
has been electronically submitted and does not 
include an identifying number which complies 
with section 6109(a)(4)(A) of the Internal 
Revenue Code of 1986, and
(ii) any return or claim for refund which 
has been electronically submitted and does not 
include an electronic filing identification 
number (as defined in section 6695(h)(2)(B) of 
such Code), and
(B) provide an opportunity for the person who 
submitted such return or claim for refund to avoid 
imposition of a penalty under subsection (c) or (h) of 
section 6695 of such Code, as applicable, if--
(i) such return or claim for refund is 
withdrawn, or
(ii) the correct identifying number or 
electronic filing identification number is 
provided.
(d) Criminal Penalty.--
(1) In general.--Part I of subchapter A of chapter 75 is 
amended by adding at the end the following new section:

``SEC. 7218. WILLFUL MISUSE OR MISAPPROPRIATION OF IDENTIFYING NUMBER.

``(a) In General.--Any tax return preparer who, with respect to any 
return, document purporting to be a return, or claim for refund--
``(1) willfully fails to furnish a valid preparer tax 
identification number with intent to evade or defeat the 
application of any requirement under any provision of this 
title which requires such preparer to obtain and furnish such 
number,
``(2) willfully furnishes a preparer tax identification 
number which--
``(A) does not exist,
``(B) is inactive or expired,
``(C) has been withdrawn,
``(D) is suspended or has been revoked, or
``(E) is otherwise invalid for use by such tax 
return preparer, or
``(3) willfully furnishes a preparer tax identification 
number which is assigned to another person,
shall, in addition to any other penalties provided by law, be guilty of 
a felony and, upon conviction thereof, shall be fined not more than 
$50,000 ($100,000 in the case of a corporation), or imprisoned not more 
than 2 years, or both, together with the costs of prosecution.
``(b) Preparer Tax Identification Number.--The term `preparer tax 
identification number' means an identifying number described in section 
6109(a)(4)(A).''.
(2) Clerical amendment.--The table of sections for part I 
of subchapter A of chapter 75 is amended by adding at the end 
the following new item:

``Sec. 7218. Willful misuse or misappropriation of identifying 
number.''.
(e) Effective Date.--The amendments made by this section shall 
apply to returns or claims for refund filed after the date which is 18 
months after the date of enactment of this Act.

SEC. 4. PENALTIES FOR IMPROPER TAX PREPARATION OR MISAPPROPRIATION OF 
REFUNDS.

(a) Other Assessable Penalties With Respect to the Preparation of 
Tax Returns for Other Persons.--Section 6695, as amended by the 
preceding provisions of this Act, is amended--
(1) in subsection (a)--
(A) by striking ``$50'' and inserting ``$250'', and
(B) by striking ``$25,000'' and inserting 
``$50,000'',
(2) in subsection (b)--
(A) by striking ``$50'' and inserting ``$250'', and
(B) by striking ``$25,000'' and inserting 
``$75,000'',
(3) in subsection (d)--
(A) by striking ``$50'' and inserting ``$250'', and
(B) by striking ``$25,000'' and inserting 
``$50,000'',
(4) in subsection (e)--
(A) by striking ``$50'' and inserting ``$250'', and
(B) by striking ``$25,000'' and inserting 
``$75,000'',
(5) in subsection (g), by striking ``$500'' and inserting 
``$1,000'', and
(6) in subsection (i)(1)--
(A) by striking ``2014'' and inserting ``2024'', 
and
(B) by striking ``calendar year 2013'' and 
inserting ``calendar year 2023''.
(b) Misappropriation of Electronic Funds Transfer.--
(1) In general.--Subsection (f) of section 6695 is amended 
to read as follows:
``(f) Negotiation of Check; Misappropriation.--
``(1) In general.--Any person who is a tax return preparer 
who--
``(A) endorses or otherwise negotiates (directly or 
through an agent) any check made in respect of the 
taxes imposed by this title which is issued to a 
taxpayer (other than the tax return preparer), or
``(B) misappropriates any refund (or advance 
payment with respect to a refundable credit), or any 
portion thereof, issued to any taxpayer through an 
electronic funds transfer,
shall pay a penalty in an amount determined under paragraph 
(2).
``(2) Penalty.--The amount of the penalty determined under 
this paragraph shall, with respect to each check or transfer 
described in paragraph (1), be equal to the greater of--
``(A) $1,000, or
``(B) the full amount of such check or transfer.
``(3) Exception.--Paragraph (1)(A) shall not apply with 
respect to the deposit by a bank (within the meaning of section 
581) of the full amount of the check in the taxpayer's account 
in such bank for the benefit of the taxpayer.''.
(2) Conforming amendment.--Section 6695(i)(1) is amended by 
striking ``(f),'' and inserting ``(f)(2)(A),''.

SEC. 5. AUTHORITY TO DENY, REVOKE, OR SUSPEND PREPARER TAX 
IDENTIFICATION NUMBERS.

(a) In General.--Section 6109 is amended--
(1) in subsection (a), by striking paragraph (4) and 
inserting the following:
``(4) Furnishing identifying number of tax return 
preparer.--
``(A) In general.--Any return or claim for refund 
which is prepared by a tax return preparer shall bear 
such identifying number for securing proper 
identification of such preparer, their employer, or 
both, as may be prescribed.
``(B) Exception for supervised preparer.--
Subparagraph (A) shall not apply with respect to any 
tax return preparer who prepares any return or claim 
for refund if such preparer is--
``(i) employed by a specified practitioner, 
and
``(ii) under the supervision and direction 
of a tax return preparer who--
``(I) includes their identifying 
number (as described in subparagraph 
(A)) on such return or claim,
``(II) signs such return or claim, 
and
``(III) is a specified 
practitioner.
``(C) Suspension or revocation.--In the case of any 
identifying number which has been suspended or revoked 
by the Secretary under subsection (e), such number 
shall not be deemed valid for purposes of subparagraph 
(A).
``(D) Definitions.--For purposes of this section--
``(i) Specified practitioner.--The term 
`specified practitioner' means a certified 
public accountant, attorney, or enrolled 
agent--
``(I) who is in good standing and 
authorized to represent persons before 
the Department of the Treasury under 
section 330 of title 31, United States 
Code, and
``(II) whose professional license 
or certification has not been revoked.
``(ii) Return; claim for refund.--The terms 
`return' and `claim for refund' have the 
respective meanings given to such terms by 
section 6696(e).'', and
(2) by inserting after subsection (d) the following:
``(e) Identifying Number of Tax Return Preparer.--
``(1) In general.--The Secretary shall maintain a program 
for administration of preparer tax identification numbers 
required under subsection (a)(4), which shall include 
restrictions on the issuance of such numbers to any individual 
other than an individual who--
``(A) meets the suitability requirements of 
paragraph (2) and the education requirements of 
paragraph (3),
``(B) meets the state program requirements of 
paragraph (4), or
``(C) is a specified practitioner.
``(2) Demonstration of suitability.--
``(A) In general.--An individual meets the 
suitability requirements of this paragraph if such 
individual has demonstrated to the Secretary the 
individual's suitability to be a tax return preparer 
by--
``(i) providing such information as the 
Secretary determines necessary, and
``(ii) undergoing a background check, 
including a review by the Secretary regarding 
compliance with personal tax obligations.
``(B) Conduct demonstrating lack of suitability.--
For purposes of subparagraph (A), an individual shall 
be deemed to have failed to demonstrate their 
suitability to be a tax return preparer if--
``(i) any license or registration issued to 
such individual by a State to prepare tax 
returns has been suspended or revoked by such 
State, or
``(ii) the Secretary determines that such 
individual is described in clauses (ii) through 
(vi) of paragraph (5)(A).
``(C) Regulations and guidance.--The Secretary 
shall issue such regulations or other guidance as the 
Secretary determines necessary to carry out the 
purposes of this paragraph.
``(D) Prohibition on examinations.--For purposes of 
subparagraph (A), except as provided in paragraph 
(3)(C)(iii), the Secretary may not require an 
examination as a prerequisite for the assignment or 
renewal of a preparer tax identification number.
``(E) Grandfathering of prior background checks.--
For purposes of subparagraph (A)(ii), in the case of an 
individual who has undergone a background check prior 
to the date of enactment of this subsection, the 
Secretary may deem such individual to have satisfied 
the requirement under such subparagraph.
``(3) Educational programs.--
``(A) In general.--An individual meets the 
education requirements of this paragraph if such 
individual completes a specified number of hours of 
educational programs on ethics, professional 
responsibility, and tax law (including recently enacted 
legislation) as may be required by the Secretary prior 
to the assignment or renewal of a preparer tax 
identification number.
``(B) Additional educational requirements for 
renewal.--The Secretary may require any individual 
seeking the renewal of a preparer tax identification 
number to complete educational programs in addition to 
those required under subparagraph (A). Any educational 
programs required under this subparagraph shall be 
based on--
``(i) a review of returns which include the 
preparer tax identification number of such 
preparer, and
``(ii) any errors identified by the 
Secretary as part of the review described in 
clause (i).
``(C) Other requirements.--For purposes of this 
paragraph, the Secretary--
``(i) may not require a tax return preparer 
to annually complete more than 18 hours of 
educational programs,
``(ii) shall require that any educational 
program include written materials which satisfy 
such standards as are established by the 
Secretary,
``(iii) may require that any educational 
program include a method to ensure that the tax 
return preparer attended the program and 
sufficiently understood the material presented, 
and
``(iv) may not direct any educational 
program to be completed through a specific 
provider.
``(D) Notice of failure to timely complete 
requirements.--The Secretary shall provide any tax 
return preparer who fails to complete the requirements 
of this paragraph notice of such failure and a period 
in which to cure such failure.
``(E) Publication of approved courses.--The 
Secretary shall publish, on the public website of the 
Internal Revenue Service--
``(i) a list of educational programs which 
have been determined by the Secretary to 
satisfy the requirement under clause (ii) of 
subparagraph (C) (and, if applicable, the 
requirement under clause (iii) of such 
subparagraph), including the providers of such 
programs, and
``(ii) any such requirements as the 
Secretary deems necessary to impose with 
respect to any additional programs required 
under subparagraph (B).
``(4) Exemption.--
``(A) In general.--Subject to subparagraph (B), any 
individual meets the state program requirements of this 
paragraph if such individual maintains a valid State 
license or registration issued by a State licensing 
program or State registration program (including State 
tax education councils) which includes examination, 
education, and background check requirements that are 
determined by the Secretary (on the basis of such 
information as is provided by the taxpayer or State 
program) to be comparable to the suitability 
requirements described in paragraph (2) and the 
education requirements described in paragraph (3).
``(B) Grandfathering of certain programs.--For 
purposes of subparagraph (A), with respect to 
determining whether a State licensing program or State 
registration program (including State tax education 
councils) includes examination, education, and 
background check requirements which are comparable to 
the suitability requirements described in paragraph (2) 
and the education requirements described in paragraph 
(3), such determination shall be made by the Secretary 
without regard to whether such requirements were 
included in such program at the time that such 
individual was licensed or registered under such 
program, provided that such requirements are, as of the 
date that such individual requested assignment or 
renewal of a preparer tax identification number under 
this subsection, presently included in such program.
``(5) Authority to revoke or suspend preparer tax 
identification number.--
``(A) In general.--The Secretary may suspend or 
revoke a preparer tax identification number if, after 
notice and opportunity for a hearing, the Secretary 
makes a determination that the tax return preparer--
``(i) has not met--
``(I) the suitability requirements 
of paragraph (2) and the education 
requirements of paragraph (3), or
``(II) the State program 
requirements of paragraph (4),
``(ii) is incompetent, as demonstrated by a 
repeated pattern of errors in returns that were 
prepared by such preparer or individuals who 
were supervised by such preparer (as described 
in subsection (a)(4)(B)) which affected the 
determination of tax liability in such returns,
``(iii) is disreputable, as demonstrated 
by--
``(I) giving false or misleading 
information under paragraph (2)(A)(i),
``(II) failure to comply with 
personal tax obligations,
``(III) revocation or suspension of 
any license or registration issued by a 
State for the preparation of tax 
returns,
``(IV) conviction of any criminal 
offense--
``(aa) involving dishonesty 
or breach of trust, or
``(bb) which is punishable 
under this title,
``(V) a final determination of 
liability for a penalty pursuant to 
section 6694, 6695(h), 6700, 6701, or 
6702, or
``(VI) any conduct similar to the 
conduct described in subclauses (I) 
through (V),
``(iv) in the case of a person subject to 
regulation under section 330 of title 31, 
United States Code, or regulations prescribed 
thereunder, has violated the requirements under 
such section or such regulations,
``(v) with intent to defraud, willfully and 
knowingly misleads or threatens--
``(I) the person whose return or 
claim for refund is being prepared, or
``(II) a prospective person seeking 
for a return or claim for refund to be 
prepared, or
``(vi) has engaged in conduct (as 
identified in regulations or guidance issued by 
the Secretary) which is similar to the conduct 
described in clauses (i) through (v) and that 
the denial, suspension, or revocation of such 
number would promote compliance with the 
requirements of this title and effective tax 
administration.
``(B) Monetary penalty.--
``(i) In general.--In addition to, or in 
lieu of, any suspension or revocation of a 
preparer tax identification number under 
subparagraph (A), the Secretary may impose a 
penalty in any amount not exceeding--
``(I) in the case of any 
determination made by the Secretary 
with respect to a tax return preparer 
which is described in subparagraph (A) 
(with the exception of clause (v) of 
such subparagraph), $1,000 with respect 
to each such determination, and
``(II) in the case of any 
determination made by the Secretary 
with respect to a tax return preparer 
which is described in subparagraph 
(A)(v), $5,000 with respect to each 
such determination.
``(ii) Reduction.--Any penalty imposed 
under clause (i) shall be reduced by the amount 
of any penalty imposed under section 6694, 
6695, 6700, 6701, or 6702 with regard to the 
same conduct.
``(iii) Adjustment for inflation.--
``(I) In general.--In the case of 
any penalty imposed during any calendar 
year beginning after 2025, the $1,000 
amount in clause (i)(I) and the $5,000 
amount in clause (i)(II) shall each be 
increased by an amount equal to--
``(aa) such dollar amount, 
multiplied by
``(bb) the cost-of-living 
adjustment determined under 
section 1(f)(3) for the 
calendar year, determined by 
substituting `calendar year 
2024' for `calendar year 2016' 
in subparagraph (A)(ii) 
thereof.
``(II) Rounding.--If any amount 
determined under subclause (I) is not a 
multiple of $100, such amount shall be 
rounded to the nearest multiple of 
$100.
``(C) Reinstatement.--The Secretary shall, through 
regulations or other guidance, establish procedures to 
allow any tax return preparer whose preparer tax 
identification number has been suspended or revoked 
pursuant to subparagraph (A) to have such number 
reissued (or, in the case of a suspension, for such 
suspension to be terminated), provided that such 
preparer demonstrates, to the satisfaction of the 
Secretary, that--
``(i) the conduct described in such 
paragraph which was the basis for such 
suspension or revocation has been sufficiently 
addressed or resolved (such as through 
completion of educational programs described in 
paragraph (3) or reinstatement of a license 
issued by a State for the preparation of tax 
returns), and
``(ii) effective tax administration would 
be promoted by terminating the suspension of 
such number or reissuing such number to such 
preparer.
``(D) Preliminary suspension.--
``(i) In general.--After notice and 
opportunity to respond, the Secretary may 
suspend the preparer tax identification number 
of a tax return preparer for a period of not 
greater than 180 days if the Secretary 
determines that--
``(I) such tax return preparer has 
engaged in any conduct described in 
clauses (i) through (vi) of 
subparagraph (A), and
``(II) such suspension is necessary 
to prevent serious economic harm to 
taxpayers or serious impairment of 
effective tax administration, such as 
to prevent the filing of fraudulent 
returns or claims for refund.
``(ii) Limitation.--For purposes of clause 
(i), if the preparer tax identification number 
of a tax return preparer has been suspended 
pursuant to such clause 2 times during any 5-
year period, the Secretary may not issue an 
additional suspension pursuant to such clause 
with respect to such preparer during such 
period unless such suspension is subsequent to 
a determination by the Secretary to suspend or 
revoke the preparer tax identification number 
of such preparer pursuant to subparagraph (A).
``(E) Regulations.--Not later than 24 months after 
the date of enactment of this subsection, the Secretary 
shall issue such regulations or other guidance as the 
Secretary determines necessary to carry out the 
purposes of this paragraph, including--
``(i) guidelines that identify the 
particular penalty applicable to any conduct 
described in subparagraph (A), and
``(ii) the manner of notice and opportunity 
to respond for purposes of subparagraph (D).
``(6) Appeal.--In the case of any tax return preparer for 
whom the Secretary has made a determination--
``(A) that such preparer has not met the 
requirements of paragraphs (2) and (3) or of paragraph 
(4) and that issuance of a preparer tax identification 
number should be denied,
``(B) under paragraph (5)(A) that the preparer tax 
identification number for such preparer should be 
suspended or revoked, or
``(C) that a penalty should be imposed pursuant to 
paragraph (5)(B),
such preparer shall be provided with an opportunity to appeal 
such determination to the Internal Revenue Service Independent 
Office of Appeals pursuant to procedures (as established by the 
Secretary through regulations or other guidance) which are 
similar to the procedures provided under section 330 of title 
31, United States Code, or regulations prescribed thereunder.
``(7) Disclosure of final determinations.--
``(A) In general.--In the case of any final 
determination with respect to the extended suspension, 
revocation, reissuance, or termination of an extended 
suspension of a preparer tax identification number 
under this subsection, not later than 30 days following 
such determination, the Secretary shall publish such 
determination on the public website of the Internal 
Revenue Service, which shall include--
``(i) a statement of the facts and 
circumstances relating to such determination, 
and
``(ii) the reasons for the determination.
``(B) Extended suspension.--For purposes of 
subparagraph (A), the term `extended suspension' means 
a suspension issued by the Secretary pursuant to 
paragraph (5)(A) for a period of greater than 180 days.
``(8) Preparer tax identification number.--For purposes of 
this subsection, the term `preparer tax identification number' 
means an identifying number described in subsection 
(a)(4)(A).''.
(b) Information Returns of Tax Return Preparers.--Section 6060 is 
amended--
(1) by redesignating subsection (c) as subsection (d), and
(2) by inserting after subsection (b) the following:
``(c) Additional Information From Supervisors.--In the case of a 
person required to make a return under subsection (a) who is described 
in section 6109(a)(4)(B)(ii)(III), such person shall include in such 
return--
``(1) the name and taxpayer identification number of any 
tax return preparer under their supervision and direction who, 
pursuant to subparagraph (B) of section 6109(a)(4), is exempted 
from the requirement under subparagraph (A) of such section,
``(2) with respect to each tax return preparer described in 
paragraph (1), whether such preparer is employed by such person 
as of the date on which such return is made, and
``(3) such other information as the Secretary determines 
appropriate.''.
(c) Determinations Regarding Practice Before the Department.--
Section 330 of title 31, United States Code, is amended--
(1) by redesignating subsection (e) as subsection (f); and
(2) by inserting after subsection (d) the following:
``(e) Disclosure of Final Determinations.--In the case of any final 
determination under subsection (c) or (d), not later than 30 days 
following such determination, the Secretary shall publish such 
determination on a public website, which shall include--
``(1) a statement of the facts and circumstances relating 
to such determination, and
``(2) the reasons for the determination.''.
(d) Disclosure Relating to Misconduct by Practitioners and Tax 
Return Preparers.--
(1) In general.--Section 6103(k) is amended by adding at 
the end the following new paragraph:
``(16) Disclosure relating to misconduct by practitioners 
and tax return preparers.--Under such procedures as the 
Secretary may prescribe, the Secretary may disclose returns and 
return information to the extent the Secretary determines it is 
necessary to publish determinations pursuant to section 
6109(e)(7) and section 330(e) of title 31, United States Code, 
provided that such disclosure is redacted to remove--
``(A) any name, address, or other identifying 
information with respect to any persons other than the 
representative or tax return preparer who is the 
subject of such determination, and
``(B) such other information as the Secretary 
determines appropriate to protect the privacy of such 
persons.''.
(2) Conforming amendment.--Section 6103(p)(3)(A) is amended 
by striking ``or (9)'' and inserting ``(9), or (16)''.
(e) Requirement To Include Identifying Number for Paid Preparer of 
Offer-in-Compromise.--
(1) In general.--Section 6109(a) is amended by inserting 
after paragraph (4) the following new paragraph:
``(5) Furnishing identifying number for offer-in-
compromise.--Any offer-in-compromise (as described in section 
7122) which has been prepared by any person for compensation 
shall include such identifying number as may be prescribed for 
securing proper identification of such person.''.
(2) Penalty.--Section 7122 is amended by adding at the end 
the following new subsection:
``(h) Failure To Furnish Identifying Number.--
``(1) In general.--
``(A) Penalty.--Any person who prepares an offer-
in-compromise for compensation and who fails to include 
an identifying number which complies with section 
6109(a)(5) with respect to such offer-in-compromise 
shall pay a penalty of $250 for such failure.
``(B) Non-compliance.--For purposes of this 
paragraph, an identifying number shall be deemed to not 
comply with section 6109(a)(5) if such identifying 
number--
``(i) is assigned to another person,
``(ii) does not exist,
``(iii) is inactive or expired,
``(iv) has been withdrawn,
``(v) is suspended or has been revoked, or
``(vi) is otherwise invalid for use by the 
preparer.
``(C) Adjustment for inflation.--
``(i) In general.--In the case of any 
documents filed during any calendar year 
beginning after 2025, the $250 amount in 
subparagraph (A) shall be increased by an 
amount equal to--
``(I) such dollar amount, 
multiplied by
``(II) the cost-of-living 
adjustment determined under section 
1(f)(3) for the calendar year, 
determined by substituting `calendar 
year 2024' for `calendar year 2016' in 
subparagraph (A)(ii) thereof.
``(ii) Rounding.--If any amount determined 
under clause (i) is not a multiple of $10, such 
amount shall be rounded to the nearest multiple 
of $10.
``(2) Exception.--The penalty imposed under paragraph (1) 
shall not apply if it is shown that such failure is due to 
reasonable cause and not due to willful neglect.
``(3) Limitation.--
``(A) In general.--The maximum penalty imposed 
under this subsection on any person with respect to 
documents filed during any calendar year shall not 
exceed $75,000.
``(B) Adjustment for inflation.--
``(i) In general.--In the case of any 
penalty imposed during any calendar year 
beginning after 2025, the $75,000 amount in 
subparagraph (A) shall be increased by an 
amount equal to--
``(I) such dollar amount, 
multiplied by
``(II) the cost-of-living 
adjustment determined under section 
1(f)(3) for the calendar year, 
determined by substituting `calendar 
year 2024' for `calendar year 2016' in 
subparagraph (A)(ii) thereof.
``(ii) Rounding.--If any amount determined 
under clause (i) is not a multiple of $1,000, 
such amount shall be rounded to the nearest 
multiple of $1,000.
``(4) Other applicable rules.--Rules similar to the rules 
of section 6696 shall apply for purposes of this subsection.''.
(f) GAO Study and Report on the Exchange of Information Between the 
IRS and State Taxation Authorities.--
(1) In general.--Not later than 18 months after the date of 
the enactment of this Act, the Comptroller General of the 
United States shall conduct a study and submit to Congress a 
report on the sharing of information between the Secretary and 
State authorities, as authorized under subsections (d) and 
(k)(5) of section 6103 of the Internal Revenue Code of 1986, 
regarding identification numbers issued to paid tax return 
preparers and return preparer minimum standards.
(2) Increased information sharing.--The study and report 
described in paragraph (1) shall include an analysis of the 
impact that increased information sharing between Federal and 
State authorities would have on efforts to enforce minimum 
standards on paid tax return preparers.
(g) Publication of Common Errors and Penalties.--Not later than 36 
months after the date of the enactment of this Act and annually 
thereafter, the Commissioner of the Internal Revenue shall publish on 
the public website of the Internal Revenue Service--
(1) the 10 most frequent errors found on tax returns which 
were prepared by tax return preparers (as defined in section 
7701(a)(36) of the Internal Revenue Code of 1986) during the 
preceding calendar year, and
(2) with respect to the preceding calendar year, the top 10 
reasons that tax return preparers were--
(A) subject to penalties imposed under the Internal 
Revenue Code of 1986, or
(B) otherwise disciplined under section 6109 of 
such Code or section 330 of title 31, United States 
Code.
(h) Rule of Construction.--Nothing in this section (or amendment 
made by this section) shall be construed to require the Secretary to 
eliminate or terminate any existing program or authority--
(1) which, pursuant to section 330 of title 31, United 
States Code, permits a tax return preparer to represent a 
taxpayer before the Department of the Treasury in cases in 
which such preparer prepared and signed the return of tax, or
(2) for publication of a public database on the website of 
the Internal Revenue Service of tax return preparers who have 
satisfied the requirements for issuance of a preparer tax 
identification number (as defined in section 6109(e)(8) of the 
Internal Revenue Code of 1986).
(i) Effective Date.--
(1) In general.--The amendments made by this section shall 
take effect on the date which is 180 days after the date of 
enactment of this Act.
(2) Transition rules for educational requirements for tax 
return preparers.--
(A) Annual filing season program.--In the case of 
any tax return preparer who, as of the date of 
enactment of this Act, has received a record of 
completion with respect to the Annual Filing Season 
Program established by the Internal Revenue Service, 
such tax return preparer shall be deemed to have 
satisfied the education requirements of section 
6109(e)(3) of the Internal Revenue Code of 1986 (as 
added by this section) for the calendar year for which 
such record of completion applies.
(B) Approved courses.--In the case of any entity 
which, as of the date of enactment of this Act, is 
approved to provide continuing education for purposes 
of the Annual Filing Season Program established by the 
Internal Revenue Service, such entity shall be deemed 
to satisfy the applicable requirements under section 
6109(e)(3) of the Internal Revenue Code of 1986 until 
the date on which the Secretary has--
(i) issued such regulations or other 
guidance as the Secretary determines necessary 
for purposes of establishing standards for 
educational programs under such section, and
(ii) pursuant to subparagraph (E) of such 
section, published a list of educational 
programs which have been determined by the 
Secretary to satisfy the applicable 
requirements under such section.
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