IRS Reports on U.S.–UK Tax Whistleblower Cooperation as National Award Rules Remain in Place
The Internal Revenue Service reported on October 7, 2026, that it had worked with HM Revenue & Customs on the development of the United Kingdom’s tax whistleblower program. In announcement IR-2026-120, the IRS said its Whistleblower Office had shared experience with the British agency. The announcement identified cross-border tax evasion as an area of cooperation, including information about concealed offshore assets and failures to report foreign accounts. It also stated that citizenship or residence in either country is not, by itself, required to receive an award. The release describes cooperation between existing national programs; it does not announce a single application process covering both countries. Applicants remain subject to the requirements of the agency handling their information and award claim.
The UK program predates the October announcement
The British scheme began at the Autumn Budget on November 26, 2025. A subsequent government response published by the UK Parliament described its intended focus as serious noncompliance involving large corporations, wealthy individuals, offshore arrangements and avoidance schemes. That chronology separates the underlying program’s introduction from the new U.S. announcement about cooperation. The parliamentary response connects potential rewards to information that directly produces a tax recovery. It does not describe payment simply for identifying a suspicious transaction or supplying a person’s name. The program is therefore presented as a mechanism for obtaining actionable information about substantial tax cases, with eligibility assessed under HMRC’s published scheme rather than under the U.S. award statute.
HMRC’s current guidance says information leading to the collection of at least £1.5 million in tax may qualify for a reward of between 15% and 30% of the tax recovered. Penalties and interest are excluded from that calculation. Payment is discretionary, and anonymous reports do not qualify for a reward, although HMRC accepts them. The exclusions also cover certain government personnel, information already known to the agency, and people who planned and initiated the relevant conduct. HMRC tells informants not to investigate further or encourage criminal activity to obtain additional information. It also states that investigations can take years. These conditions appear in the scheme guidance and are not new conditions introduced by the October IRS announcement.
How the U.S. award framework operates
The U.S. Whistleblower Office administers claims concerning violations of tax laws and other laws the IRS is authorized to administer, enforce or investigate. Its responsibilities include evaluating award claims, determining awards and arranging payment to eligible individuals. The agency’s program history dates the modern office and statutory framework to legislation enacted in December 2006. It also identifies later changes in 2018 concerning the definition of collected proceeds and changes in 2019 concerning notifications and employee protections. These developments form the domestic framework within which the current international cooperation occurs. The office’s general description gives a usual award range of 15% to 30% of qualifying collected proceeds attributable to the information, subject to the governing provisions.
Section 7623(b) contains a statutory award framework for qualifying cases where proceeds in dispute exceed $2 million. When the subject is an individual taxpayer, that person’s gross income must also exceed $200,000 for at least one relevant tax year. The income threshold concerns the reported taxpayer, not the whistleblower. The statute permits representation by counsel and requires information to be submitted under penalty of perjury. Its language connects an award to “proceeds collected as a result of the action.” That phrase refers to an actual recovery rather than the amount alleged in a report. The law also contains provisions for reduced awards based principally on specified public disclosures and for reducing or denying awards where the claimant planned and initiated the underlying conduct.
Submitting information and evaluating a claim
The IRS currently directs award applicants to Form 211, Application for Award for Original Information. Its submission page requests identification of the reported person or business, a description of the alleged noncompliance, supporting documents, and an explanation of how and when the applicant learned of the matter. It also requests the applicant’s contact details and present or former relationship to the reported taxpayer. The IRS provides an online submission route and cautions that sending the same claim through multiple channels can delay processing. Additional information about an existing claim can be associated with its assigned claim number. The page separately lists eligibility exclusions, including certain government employees and contractors whose information came from their official work.
The agency’s published explanation of its review process describes separate roles for the Whistleblower Office and the operating divisions that conduct tax examinations or investigations. In a July 2022 account of that structure, the IRS explained that potentially actionable information may be referred to divisions responsible for criminal investigations, large businesses, smaller businesses or tax-exempt entities. Those divisions assess the information and whether enforcement work is warranted. The August 2026 claim-process publication likewise describes referral for further development when the office concludes that a claim merits additional consideration. Receipt of a submission is consequently one stage in a longer administrative process. A claim number records the submission; it does not establish that the reported allegations have been proved or that an award has been approved.
The IRS’s operating manual also describes a review for legal and evidentiary restrictions before information reaches investigators. This includes material potentially protected by attorney-client privilege, work-product protections or other applicable privileges. Agency counsel participates in resolving privilege questions. The manual instructs staff not to continue using material determined to be privileged and describes controls intended to prevent problematic information from reaching the enforcement team. It separately addresses information obtained unlawfully and constitutional concerns that can arise if the government directs an informant’s activities. Under those instructions, the IRS acts as a passive recipient of whistleblower information. The review therefore considers how material was acquired and whether it can be used, as well as what the material appears to establish.
Confidentiality and the time needed for payment
IRS field-collection instructions dated September 25, 2026, require employees to protect both a whistleblower’s identity and information revealing that a whistleblower exists. Access inside the agency is restricted to personnel who need the information for their official duties. The instructions call for a separate electronic whistleblower file rather than placing the material in the ordinary collection file. They also prohibit routine references to the whistleblower in general collection records. These are internal information-handling controls, not a guarantee that identity can never become relevant in a legal proceeding. The agency’s public commitment remains protection to the fullest extent permitted by law. Restrictions on taxpayer information also limit what the agency can communicate back to an informant.
Publication 5251, revised in August 2026, explains that payment depends on completion of the relevant tax and award processes. A referral for examination does not guarantee that an examination will begin, and a notification that the taxpayer has made a payment does not guarantee an award. The publication explains that further resolution of tax matters may take years. It also describes written requests for information about a claim’s status or stage, subject to confidentiality restrictions. Such requests identify the relevant claim number and are handled separately from the eventual award determination. The publication limits routine status responses to one request per claim number per calendar year. A status update is therefore a procedural communication rather than a decision that money is payable.
The award manual describes an additional administrative stage when an award is recommended under section 7623(b). The claimant receives a summary explaining the recommended amount and the factors used in the calculation. The process allows comments, and a confidentiality agreement can provide access to a more detailed report and a supervised review of supporting records. The manual specifies response periods and describes how the office considers submissions before issuing its determination. It also explains that payment awaits the required finality of the tax matter and resolution or waiver of the applicable award appeal rights. The existence of a preliminary calculation consequently does not mean that a check has already been authorized for immediate release.
Treasury’s award regulations describe factors used to assess the whistleblower’s contribution. They include the usefulness of information in identifying an issue or transaction, its effect on the development of the case, and the assistance provided to the agency. The regulations also allow consideration of negative factors. The framework does not automatically assign the highest percentage to every qualifying claim, and the calculation is tied to the facts in the administrative record. The 2014 final-rule explanation describes an approach that starts with the statutory minimum for the ordinary section 7623(b) calculation and considers factors supporting a different percentage. This regulatory history explains how the published range is administered; the October 2026 announcement does not publish a replacement award formula.
Employee protections follow a separate process
The Department of Labor administers protections for employees who engage in activity covered by the Taxpayer First Act. OSHA’s public explanation identifies protected conduct that includes supplying information about reasonably suspected tax violations to specified government recipients or to supervisors and other authorized employer personnel. Participation in relevant IRS administrative or judicial proceedings is also covered. Retaliatory acts can include dismissal, demotion, threats, reduced hours, denial of benefits or other adverse employment action. OSHA explains that a retaliation complaint ordinarily must be filed within 180 days after the alleged retaliatory action. That complaint concerns employment conduct. It is separate from an IRS Form 211 application seeking a percentage of money recovered in a tax case.
OSHA’s September 2024 investigator guidance describes the initial allegations evaluated in a retaliation case: protected activity, the employer’s knowledge or suspicion of that activity, an adverse action, and circumstances linking the two. The guidance uses a contributing-factor standard and also describes the employer’s opportunity to show, by clear and convincing evidence, that it would have taken the same action without the protected conduct. It recognizes limited circumstances in which equitable tolling may affect filing time. The investigation examines the employment facts and the parties’ evidence; it does not simply adopt the tax allegation as established. These requirements apply to the retaliation proceeding independently of whether the IRS ultimately collects tax or makes a whistleblower award.
The governing statute, 26 U.S.C. §7623(d), authorizes relief intended to “make the employee whole.” Its remedies include reinstatement, double back pay, restoration of lost benefits with interest, and specified costs and damages. The statute also provides a route to federal district court if the Department of Labor has not issued a final decision within 180 days after the complaint was filed, provided the delay is not attributable to the claimant’s bad faith. That later 180-day period concerns agency processing after filing. It is distinct from the time allowed to initiate a retaliation complaint. These provisions are part of the existing U.S. employee-protection framework and were not created by the announcement about cooperation with HMRC.
Foreign accounts and the published program record
Foreign-account reporting is among the subjects mentioned in the IRS announcement. The agency’s FBAR guidance generally requires a U.S. person with a financial interest in, or specified authority over, foreign financial accounts to report them when their combined value exceeds $10,000 at any time during the calendar year, subject to exceptions. The report is filed with FinCEN rather than as part of the federal income tax return. Whether an account generated taxable income does not by itself determine whether it must be reported. These account-reporting rules supply background to the references to offshore information; the existence of a foreign account alone does not establish that its holder violated a reporting obligation.
FATCA operates through a separate statutory reporting framework. The IRS explains that foreign financial institutions and certain other foreign entities generally report specified information concerning U.S. account holders or face withholding on covered payments. U.S. persons may also have separate foreign-asset reporting requirements depending on the applicable values and circumstances. The IRS maintains distinct guidance comparing Form 8938 with FBAR. Neither a whistleblower submission nor an announcement about cooperation between tax agencies substitutes for those reporting rules. The relevant facts include the account holder, the assets, the institution and the reporting provision at issue. The October release discusses information about suspected violations; it does not treat all international financial activity as tax evasion.
Previously published figures illustrate the U.S. program’s operations without measuring the results of this new announcement. In its fiscal-year 2024 report, covering October 1, 2023, through September 30, 2024, the IRS reported $123.5 million in awards associated with $474.7 million in collected proceeds. It recorded 105 awards and 5,660 submissions during that fiscal year. The report also distinguished processing after all payment requirements were met from the full time between filing and payment. Those figures concern a defined historical reporting period; they are not a forecast of an individual claimant’s recovery or evidence of amounts collected through the U.S.–UK cooperation announced in October 2026. The current public materials continue to identify separate national reporting channels.
Legal Disclaimer. Originally published: 10/11/2026. This article provides general information only and is not legal advice for any particular matter. Laws, policies, procedures, fees and agency practices may change; their application depends on the facts and jurisdiction. Consult a qualified attorney about your circumstances before acting on this information. Reading this article or contacting Blumsack & Canzano does not, by itself, create an attorney-client relationship. Past results do not guarantee future outcomes. This material may be considered attorney advertising in some jurisdictions.
