Fairness in Foreign Filing Act

The Fairness in Foreign Filing Act changes how the IRS handles specific penalties related to foreign information reporting to give taxpayers more time to contest them. Under the new rules, the IRS must send a written notice explaining the proposed penalty at least 60 days before assessing it, allowing the taxpayer to request a review by the IRS Appeals Office and stopping collection until that review is complete. The bill also clarifies that certain existing penalties are treated as taxes for collection purposes while preserving other taxpayer rights to sue for refunds. Additionally, the legislation removes a requirement for foreign trusts to file certain information returns by a specific deadline, applying this change to tax years starting after December 31, 2026.