0425 Publ 6074 (PDF)

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/p6074.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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An Integrated Approach to Advance the Whistleblower Program

Transformed Whistleblower Program ����������������������������������������������� 02 IRS Whistleblower Office Guiding Principles ����������������������������������� 03 Framework of Strategic Priorities ���������������������������������������������������� 04 Key Themes ������������������������������������������������������������������������������������������ 04 Critical Steps & Benefits �������������������������������������������������������������������� 05 Achievements and Efforts Underway ������������������������������������������������ 06 Strategic Priorities, Initiatives, and Priority Efforts ����������������������� 08

Strategic Priority 1 – Enhance the claim submission process to

Strategic Priority 4 - Keep whistleblowers informed of the

Strategic Priority 6 - Ensure that our workforce is supported

i IRS WHISTLEBLOWER OFFICE OPERATING PLAN

Plan Development and Overview

As the Director of the IRS Whistleblower Office, I am pleased to share our first-ever multi-year Operating Plan for the IRS Whistleblower Program. This document outlines our guiding principles, strategic priorities, recent achievements, and the efforts currently underway to drive progress. The Whistleblower Office is responsible for administering claims for award filed by whistleblowers that identify taxpayers who may not be fully compliant with tax laws or other laws the IRS is authorized to administer, enforce, or investigate.

Our Operating Plan is an integrated approach to advance the IRS Whistleblower Program and incorporates extensive feedback received from whistleblowers, whistleblower practitioners, IRS leaders and employees, oversight bodies, and other program stakeholders. The plan considers and integrates fundamental concepts around risk management, data management, metrics, information systems, claim processes, training, communication, stakeholder relationships, employee needs, and whistleblower laws and regulations. It includes both short-term operational planning and longer-term planning for the future of the program.

The Value of an Effective IRS Whistleblower Program

Our nation’s tax system is built on the principle of voluntary compliance. When this principle is observed, taxpayers file tax returns and pay their taxes timely and accurately. Voluntary compliance is aided by the knowledge that non-compliance with tax laws will be addressed through examinations, collection activities, criminal investigations, and other tax compliance work. The IRS uses increasingly sophisticated data analytics and other methods to detect non-compliance with tax laws, but we can’t find it all by ourselves. We need help from whistleblowers – people with firsthand knowledge of non-compliance who are willing to share what they know with us so we can investigate it when warranted.

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The IRS Whistleblower Office’s mission and vision statements guide the direction and future of the Whistleblower Program. As the first part of enhancing the Whistleblower Program, we prepared new mission and vision statements to ensure our responsibilities and goals are clear and concise.

America’s first whistleblower law was passed by the

Continental Congress on July 30, 1778. The first law

related to whistleblowers on tax violations was

enacted in March 1867. Congress mandated the

creation of the IRS Whistleblower Office in Section

406 of the Tax Relief and Health Care Act of 2006 to administer the IRS Whistleblower Program. The Whistleblower Office analyzes

information submitted by whistleblowers,

monitors the contribution made by

whistleblowers, and makes deter minations on whistleblower

claims for award.

To effectively promote voluntary compliance and reduce the tax gap by providing excellent service to whistleblowers, taxpayers, and other stakeholders.

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Mission and Core Strategy We will align our actions with the mission, vision, and strategic goals of the IRS and the Whistleblower Office. We are committed to continuous improvement of the IRS Whistleblower Program. We will promote a culture that supports whistleblowers, and we will work to raise awareness of the Whistleblower Program. We will prioritize effective communication, internal controls, and risk management.

Law and Regulations We recognize that whistleblower laws and regulations are the foundation of our program. We will emphasize and adhere to the statutory obligations and agency policies to maintain the confidentiality of both whistleblower information and taxpayer information. We will collaborate regularly and effectively with the Office of Chief Counsel on legal matters and explore the potential for updating whistleblower-related regulations and for suggesting changes to whistleblower-related laws. We will remain fully compliant with annual withholding tax return filing requirements.

The IRS Whistleblower Office’s guiding principles serve as the foundation for the success of the IRS Whistleblower Program. They define elements of our mission, vision, and ongoing/ continuous priorities.

Whistleblower Program Stakeholders We recognize and value the numerous stakeholders of the IRS Whistleblower Program. We will partner with stakeholders to strengthen collaboration and to seek frequent input and feedback. We are committed to providing excellent service to whistleblowers, whistleblower practitioners, taxpayers, IRS compliance functions, and all other stakeholders. We’ll consider other governmental whistleblower program practices in our efforts to continuously improve the program.

Data, Systems, and Processes We will emphasize the importance of capturing relevant data accurately and protecting it. We will continually improve data analytics capabilities and enhance internal measures and metrics dashboards to drive informed decisions and improved performance. We will support a robust risk management process and evaluate risk management strategies. We will ensure compliance with our internal controls and quality assurance processes. We will identify new opportunities to pay award claims sooner.

IRS Employees IRS Whistleblower Office employees and the many other employees who support the program are the key to our success. Their dedication, expertise, and collaborative efforts make them essential to accomplishing our mission and goals. We will recognize employees for outstanding contributions to the program. We will ensure they are supported with the right tools, training, coaching, and networking. We will engage with employees to seek their input for improvement and feedback on proposed changes.

Knowledge Management We will foster a culture of knowledge sharing across the organization by leveraging broad insights and expertise through training, online resources, networking, and cross-function collaboration. We will update and maintain the Internal Revenue Manual and procedure guides to ensure information is current and consistent. We will ensure Whistleblower Program information on IRS.gov is helpful and accurate.

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The IRS Whistleblower Office Operating Plan is framed around six strategic priorities:

Award whistleblowers fairly and as soon as possible.

Within these six strategic priorities, we have selected 38 initiatives to focus our efforts on. Some of the initiatives will require discrete, specific activities to complete while other initiatives are broad. Our intention is to ensure the plan identifies areas of significant importance while allowing flexibility to address other concerns that may have multiple aspects.

Ensuring that we have the right resources supported with effective tools, technology, and training.

Identifying improvements to claim management systems, claim filing, initial claim analysis, claim determinations, and claim status processes.

Capturing better data, improving analytics, and ensuring both whistleblower and taxpayer information is effectively protected.

Increasing collaboration with IRS compliance functions, with the Office of Chief Counsel, with whistleblower practitioners, and with other stakeholders to continuously improve the program.

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We’ve already made significant progress toward realizing goals of the plan, and remain committed to investing in our employees, enhancing data and systems, and improving processes to better serve our stakeholders. We haven’t waited to finalize our plan before taking robust action to make progress on our goals.

Recent achievements and significant efforts underway by the Whistleblower Office include:

X In September 2024, the Whistleblower Office implemented a new

organizational structure. Organizational changes included transferring-in the Initial Claim Evaluation team from the Small Business/ Self-Employed Division (SB/SE) and expanding from two to three Whistleblower Office functions.

X During Fiscal Year (FY) 2024, we hired 36 additional employees (a

75% increase) with a focus on whistleblower claim processing, notifications to whistleblowers, and data analytics.

X In March 2024, we updated and improved the Form 211 (Application

for Award for Original Information). Improvements include reorganizing the form with a more logical flow, the addition of expandable data fields, an updated list of alleged violations issues to select from, a new option for multiple whistleblowers to file jointly, and we updated the form’s instructions including the addition of QR codes for quick access to Whistleblower Program information.

X In FY 2024, we revised the Internal Revenue Manual (IRM) and

whistleblower procedure guides. A key IRM update was to provide clarifications around factors for disaggregations (a process that allows for earlier award payments by separating certain completed actions). We also updated the IRM to provide guidance on Freedom of Information Act (FOIA) requests to strengthen controls over and protection of whistleblower records. We continue reviewing policy and procedures for opportunities to improve program effectiveness and claim processing efficiencies.

X We have continued efforts to disaggregate claims to pay awards

sooner and we took steps in FY 2024 to improve Taxpayer First Act whistleblower notices and letters.

X We are developing an online digital intake portal for whistleblower

claims to make it easier to submit information and request an award. We are working with other IRS functions and contractors to build and implement the system.

X We added more locations across the U.S. to offer whistleblowers

additional options for the Administrative Claim File Review process.

X We are developing a new approach for the initial analysis of

whistleblower claims to help ensure high-value submissions are better identified and prioritized.

X We are working with contractors and other IRS functions to design

and implement a new whistleblower claim inventory management system that will improve program efficiencies and data analytics.

X We developed new internal measures and metrics reporting as part

of our effort to enhance program performance.

X We established a process to ensure the Annual Report to Congress

is submitted for clearance by December 31st each year.

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X In March 2024, we updated and improved the Form 11369 (Confi dential Evaluation Report on Claim for Award). The updates improve our ability to evaluate the contributions made by whistleblowers in actions taken by the IRS.

X We increased outreach and collaboration across IRS programs and

business units, with the Office of Chief Counsel, other governmental whistleblower programs, the external whistleblower practitioner community, and with others.

X We continue to invest in our talented and dedicated employees

through technical training, leadership training, employee developmental opportunities, and improved tools.

X We made updates to program information on IRS.gov to improve

content and are continuing these efforts.

X Using new data analytics techniques with our existing whistleblower

claim management system, we have identified claims for additional review to determine if the claim can be moved to the next processing step and closer to determination and award payment, when appropriate.

X We worked closely with Chief Counsel attorneys and submitted

a request to be included in the 2024-2025 Treasury Department Priority Guidance Plan (PGP). The request was accepted, and a project to update the regulations under Internal Revenue Code (IRC) Section 7623 is included in the PGP published in October 2024.

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For each of the Whistleblower Office’s six strategic priorities, we have identified key initiatives. This section provides information on the initiatives and target priority efforts for 2025 through 2027.

ENHANCE THE CLAIM SUBMISSION PROCESS TO PROMOTE GREATER STRATEGIC PRIORITY 1 EFFICIENCY

The Whistleblower Office will adjust staffing and resources to effectively carry out its mission and meet evolving needs. We have significantly increased our engagement with IRS compliance functions, and the IRS’s new Chief Tax Compliance Officer (CTCO) organizational structure further re-enforces those efforts. We will work closely with IRS compliance functions to align efforts on priority compliance issues. The Whistleblower Office is evaluating current whistleblower claim intake, analysis, and classification processes and is working on improvements that will help ensure high-value submissions are identified and prioritized. We will improve claim processing efficiencies, expand digitalization, and move away from a paper-based system toward a new digital records approach. We are working on making it easier for whistleblowers to file a claim by developing a digital intake portal. In FY 2024, we made key revisions to the Form 211 (Application for Award for Original Information) to provide future digital processing, and we updated IRS policy to remove the Form 211 “wet-ink” signature requirement. We will work to increase program awareness that the IRS Whistleblower Program covers both non-compliance with tax laws as well as other laws the IRS is authorized to administer, enforce, or investigate.

1.1 Adjust staffing resources where needed

1.2 Create an online digital intake portal for the Form 211 (Application for Award for Original Information)

1.3 Improve intake, analysis, and classification processes

1.4 Expand digitalization

1.5 Efficiently deal with repeat filers of speculative claims

1.6 Improve content and functionality on the Whistleblower Office’s IRS.gov page

2025 Priority Efforts 2026 – 2027 Priority Efforts

1.7 Create focused, issuespecific outreach

1.8 Review award payment thresholds

1.9 Explore opportunities to expand whistleblower claim processing in languages other than English

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STRATEGIC PRIORITY 2 USE HIGH-VALUE WHISTLEBLOWER INFORMATION EFFECTIVELY

The Whistleblower Office is fully supporting IRS transformation efforts. We will continue close coordination with business units across the IRS, and collaboration efforts with whistleblower practitioners and other whistleblower programs. The Whistleblower Office will work to align claim priorities with the IRS’s portfolio of strategic enforcement priorities. In FY 2024, we revised the Form 211 to allow for improved identification of claim factors, added an option for multiple whistleblowers to submit a claim jointly, and improved the form’s instructions. We continue efforts to increase data capture and improve analytics by procuring a replacement for our whistleblower claim inventory management system.

In September 2024, the Whistleblower Office implemented a new organizational structure. Organizational changes included transferring-in the Initial Claim Evaluation team from the Small Business/Self-Employed Division (SB/SE), expansion from two to three Whistleblower Office functions, the addition of additional claim administration teams, and a new team that will focus on initial claim analysis.

The Whistleblower Office will continue its efforts to collaborate regularly with Chief Counsel attorneys throughout the IRS, including attorneys who support field compliance efforts and litigation, Procedure and Administration attorneys, and General Legal Services attorneys. We will continue our efforts to work closely with whistleblowers, when appropriate, using the authority provided by IRC Sections 6103(n) and 6103(k)(13)(A). We will continue our collaboration with other whistleblower programs to share and consider information on best practices.

2025 Priority Efforts 2026 – 2027 Priority Efforts

2.1 Improve initial analysis effectiveness

2.2 Improve the whistleblower claim management system

2.3 Ensure skill sets are aligned to program needs

2.4 Increase efforts to work more closely with whistleblowers using the most appropriate approach

2.5 Collaborate on and consider efficiencies around other types of IRS information submissions

2.6 Re-emphasize debriefings of whistleblowers

2.7 Consider best practices of other whistleblower programs

2.8 Watch for opportunities to identify tax compliance topics where strengthened information and service delivery could benefit taxpayers

2.9 Evaluate taint review procedures and risk assessments associated with whistleblower information

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STRATEGIC PRIORITY 3 AWARD WHISTLEBLOWERS FAIRLY AND AS SOON AS POSSIBLE

The Whistleblower Office will continue evaluating whistleblower claim processes, policies, procedures, and published products to help ensure whistleblower claims are fairly considered and awarded as soon as the law and resources permit. We will continue reviewing the Whistleblower Office “risk appetite” to move toward an approach that carefully analyzes the level of risk, available risk mitigations, and potential benefits/gains. In FY 2024, we revised the Form 11369 to improve data capture for the evaluation of how whistleblower information was used. On October 3, 2024, the Treasury Department released the 2024-2025 Priority Guidance Plan. Included in the plan is a project related to the regulations under IRC Section 7623 regarding awards to whistleblowers. The Whistleblower Office will work closely with Chief Counsel attorneys on this effort.

The IRS pays awards from proceeds collected and as such, award payments can only be made once the taxpayer has exhausted all appeal rights, and the taxpayer no longer can file a claim for refund or otherwise seek to recover the proceeds from the government. Although the time it takes from when the Whistleblower Office receives a Form 211 claim submission to paying an award is mostly related to investigations, taxpayer appeals and litigation, and collection efforts, we will continue efforts to act expeditiously on processes that we control. In FY 2024, we updated the IRM to provide clarifications around factors for disaggregations. We will continue to apply these IRM provisions to make disaggregated award payments when appropriate. In addition to disaggregations, we will explore other potential opportunities to pay awards sooner. We will use new data analytic approaches to identify any backlogs where claims could be moved to the next claim processing stage. Where backlogs are identified, we will create a plan to address and eliminate such backlogs. We will be prepared to implement legislative or judicial changes, including, for example, if a provision is enacted that provides for the potential payment of interest on awards. We will continue to explore opportunities to more efficiently determine and pay awards for cases with multiple whistleblower award claims.

2025 Priority Efforts 2026 – 2027 Priority Efforts

3.1 Be prepared to implement legislative or judicial changes

3.2 Review procedures for identifying the final determination of tax

3.3 Identify opportunities to more efficiently determine awards for cases with multiple whistleblowers

3.4 Review procedures for reconsideration requests

3.5 Update program Delegation Orders

3.6 Consider opportunities to obtain input on whistleblower contributions earlier

3.7 Better define policies and procedures for claim cases with complex tax attributes

3.8 Review procedures to improve efficiencies with Tax Court remands

3.9 Explore the potential need for additional flexibilities to pay awards under the discretionary provisions of IRC Section 7623(a)

3.10 Explore opportunities to emphasize collection efforts on cases involving proceeds attributable to a whistleblower

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KEEP WHISTLEBLOWERS INFORMED OF THE STATUS OF THEIR CLAIMS AND STRATEGIC PRIORITY 4 THE BASIS FOR IRS DECISIONS ON CLAIMS

The Whistleblower Office will continue to invest in services for whistleblowers and representatives through improved communications and information contained in notices and will continue efforts to improve whistleblower “referred for audit”, “collection”, and “status and stage” TFA notification processes. In FY 2024, we established a 90-day target timeframe to respond to written status and stage claim requests. We will work with the Office of Chief Counsel to improve the administrative claim review process and standardize procedures for redactions of taxpayer information.

STRATEGIC PRIORITY 5 SAFEGUARD WHISTLEBLOWER AND TAXPAYER INFORMATION

Safeguarding whistleblower and taxpayer information is an utmost priority for the IRS. The Whistleblower Office will continue emphasizing the importance of confidentiality, security, and privacy of both whistleblower information and taxpayer information. In FY 2024, we revised the Internal Revenue Manual and added guidance for Freedom of Information Act (FOIA) request procedures to strengthen controls over and protection of whistleblower records. In FY 2024, we added content and information on the revised Form 211 and the Whistleblower Office’s IRS.gov page to raise awareness on potential restrictions for whistleblowers who are considered taxpayer representatives. We will also continue our efforts to reduce the risk of inadvertent improper disclosure of whistleblower information.

2025 Priority Efforts 2026 – 2027 Priority Efforts

5.1 Enhance the protection of whistleblower and taxpayer information

5.2 Strengthen processes related to privileged information

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ENSURE THAT OUR WORKFORCE IS SUPPORTED WITH EFFECTIVE TOOLS, STRATEGIC PRIORITY 6 TECHNOLOGY, TRAINING, AND OTHER RESOURCES

The Whistleblower Office is fortunate to have dedicated, knowledgeable, and experienced staff who are committed to providing excellent service to all program stakeholders. We will drive change by continuously assessing and monitoring employees’ feedback. We will work to attract, develop, and retain exceptional talent, and ensure our workforce has the tools and training necessary to serve whistleblowers, representatives, compliance staff, and other program stakeholders. We will update position descriptions as needed to ensure they accurately reflect critical job expectations and responsibilities.

2025 Priority Efforts 2026 – 2027 Priority Efforts

6.1 Review employee and management standard position descriptions (PDs) to ensure those align with responsibilities and roles

6.2 Develop and utilize a strategic management model that incorporates strategy, data, systems, & processes, the Whistleblower Office team, knowledge management, stakeholders, and laws & regulations

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Publication 6074 (4-2025) Catalog Number 95607T Department of Treasury Internal Revenue Service www.irs.gov