Ventry, Dennis J., Whistleblowers and Qui Tam for Tax. Tax Lawyer, Forthcoming Available via SSRN.
“This Article examines the underexplored IRS whistleblower program, which Congress revamped in December 2006 by, among other things, significantly expanding the size of rewards paid to informants. Increased monetary incentives for exposing tax cheats align private citizens on the side of tax collection rather than tax avoidance, and add risk of detection and prosecution to the compliance calculus. This Article recommends that Congress broaden the whistleblower program still further to allow private citizens to bring qui tam lawsuits against tax cheats. Other federal and state whistleblower statutes, including the widely praised False Claims Act (FCA), already provide for qui tam actions against persons submitting false claims to the government. This Article proposes using the FCA as a model for the tax whistleblower statute, and extending qui tam to tax.”
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