Taxpayer Notification and Privacy Act of 2025

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 2629 Introduced in Senate (IS)]

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119th CONGRESS
  1st Session
                                S. 2629

  To amend the Internal Revenue Code of 1986 to provide for specific 
     taxpayer notice when information is sought from third parties.


_______________________________________________________________________


                   IN THE SENATE OF THE UNITED STATES

                             July 31, 2025

  Mr. Barrasso (for himself and Mr. Warnock) introduced the following 
  bill; which was read twice and referred to the Committee on Finance

_______________________________________________________________________

                                 A BILL


 
  To amend the Internal Revenue Code of 1986 to provide for specific 
     taxpayer notice when information is sought from third parties.

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

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Taxpayer Notification and Privacy 
Act of 2025''.

SEC. 2. SPECIFICITY OF THIRD-PARTY CONTACT NOTICES.

    (a) In General.--Paragraph (1) of section 7602(c) of the Internal 
Revenue Code of 1986 is amended--
            (1) by striking ``and'' at the end of subparagraph (A),
            (2) by redesignating subparagraph (B) as subparagraph (C),
            (3) by inserting after subparagraph (A) the following new 
        subparagraph:
                    ``(B) in any case in which the information sought 
                to be obtained from such other persons could reasonably 
                be provided by the taxpayer, identifies each specific 
                item of information intended to be sought from such 
                persons, and'', and
            (4) by amending subparagraph (C), as redesignated by 
        paragraph (2), to read as follows:
                    ``(C) except as otherwise provided by the 
                Secretary, provides the taxpayer with reasonable 
                opportunity and a period of not less than 45 days (or 
                more, if the taxpayer requests additional time and 
                shows reasonable cause) to respond, including by 
                providing the information described in subparagraph 
                (B), before contact is made with such other persons.''.
    (b) Exception.--Section 7602(c)(3) of the Internal Revenue Code of 
1986 is amended--
            (1) by redesignating subparagraphs (A), (B), and (C) as 
        clauses (i), (ii), and (iii), respectively, and by moving such 
        clauses 2 ems to the right,
            (2) by striking ``Exceptions.--This subsection'' and 
        inserting ``Exceptions.--
                    ``(A) In general.--This subsection'', and
            (3) by adding at the end the following new subparagraph:
                    ``(B) Exception for information specificity.--If 
                the Secretary determines that the information sought 
                from a person other than the taxpayer is necessary 
                notwithstanding whether the taxpayer could 
                independently provide such information, subparagraph 
                (B) of paragraph (1) shall not apply.''.
    (c) Effective Date.--The amendments made by this section shall 
apply to notices provided under section 7602(c) of the Internal Revenue 
Code of 1986 after the date that is 12 months after the date of the 
enactment of this Act.
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