Whistleblower Program: IRS Needs to Improve Data Controls for Some Award Determinations (GAO-18-698)

GAO-18-698, Whistleblower Program: IRS Needs to Improve Data Controls for Some Award Determinations (Sep 2018, public version, 48 pp.): highlights (IRS collected $3.6 billion since 2007; FBAR penalties of about $10.7 million in 28 of 132 sampled claims; table of FBAR penalties and maximum potential awards by penalty type); background (15-30% awards, FY2017 $191 million collected, $34 million paid on 367 claims to 242 whistleblowers, average award over $140,000; Figure 1 process chart; Figure 2 collections and awards FY2012-2017 bar chart without printed values); 2014 regulation excluding Title 31/18 amounts, 2016 Tax Court ruling, 2017 appeal, 2018 statutory change and IRS response (hold, guidance dates, 2,096 claims closed meanwhile); FBAR penalty levels (not reward rules - out of scope); Table 1 FBAR outcomes for 92 matched claims; Table 2 penalties by type; Figure 3 potential average awards (no printed values); Table 3 and Appendix I Table 4 sample populations; estimate of at least 146 claims (1.4%) with FBAR allegations; FBAR Database controls (44 records with date errors - database quality, out of scope); attorney interviews (counts of firms - methodology); OVDP over $11 billion since 2009 and offshore wealth and tax-gap estimates (out of scope); IRS comment letter (scanned, partly redacted). Already in the data: $3.6 billion, FBAR totals (28 claims, $10,748,886; $10.7 million), FY2017 collections, award amount and whistleblowers, 1 event. Added: Table 2 and highlights table by penalty type, potential-award estimates, Tables 1 and 3, other figures (10,306 closed claims, 146 / 1.4%, 97%, <0.1%, 2,096, 367 claims, $140,000 average), 2 rules, 3 events. Table 4 repeats Table 3 (not duplicated). Checks: Tables 1-3 add up.