Taxpayer Notification and Privacy Act of 2025

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

(3) , 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.

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.—

This subsection

(2) , and

(3) by adding at the end the following new subparagraph:

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.

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.