The IRS HMRC whistleblower partnership just turned every banker, bookkeeper and disgruntled business partner on both sides of the Atlantic into a potential paid informant. Washington and London want tips on hidden foreign accounts, and they’ll pay up to 30% of what they collect.
WASHINGTON, D.C., United States – 12 October 2026
On October 7 the IRS published news release IR-2026-120, spotlighting how its Whistleblower Office helped HM Revenue & Customs launch the UK’s Strengthened Reward Scheme. The first example of reportable conduct in the release? Undeclared foreign bank accounts and unfiled FBARs.
That landed eight days before the October 15 extended FBAR deadline. I don’t think the timing’s an accident.
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What did the IRS and HMRC announce?
The IRS said on October 7, 2026, in release IR-2026-120, that its Whistleblower Office helped HMRC stand up the UK’s Strengthened Reward Scheme, which launched in November 2025. Both agencies now urge insiders with specific, credible information on cross-border tax evasion to report it, and either one can pay an award when a tip produces collected tax.
The official IRS release is blunt about what it wants. Its list of target conduct reads like a checklist of classic offshore mistakes:
- Undeclared foreign bank accounts and failure to file an FBAR
- Assets hidden through foreign trusts, foundations, financial instruments or anonymous entities in tax havens
- Money laundering
- Transfer pricing manipulation and cross-border profit shifting by wealthy individuals and multinationals
IRS Chief Executive Officer Frank J. Bisignano said the collaboration “will help deter large-scale, cross-border tax evasion.” HMRC Chief Executive JP Marks praised “the important role that informants play.” Notice the second bullet. Properly reported offshore trusts are perfectly legal, but an unreported one is exactly the kind of file an informant can now sell to two governments at once.
It also lands amid growing pressure on FATCA enforcement, after a Treasury watchdog criticised how little the IRS does with the foreign bank data it already receives. Paying insiders is cheaper than auditing.
How much can an IRS HMRC whistleblower earn?
An IRS HMRC whistleblower can earn 15% to 30% under either program. The IRS pays that share of proceeds in cases where the amount in dispute exceeds $2 million, while HMRC pays 15% to 30% of tax collected, excluding penalties and interest, once a tip recovers at least £1.5 million. Neither program publishes a cap.
The US program isn’t theoretical. In release IR-2026-84 from July, the IRS said whistleblower tips have helped recover more than $8 billion since 2007, with over $1.4 billion paid out in awards. Read that number twice.
| Feature | IRS Whistleblower Program (US) | HMRC Strengthened Reward Scheme (UK) |
|---|---|---|
| Award range | 15% to 30% of proceeds collected | 15% to 30% of tax collected (excl. penalties and interest) |
| Minimum case size | Over $2 million in dispute | At least £1.5 million collected |
| Published cap | None | None |
| Launched | Award rules since 2006, Whistleblower Office since 2007 | November 2025 |
| Citizenship or residency needed? | No | No |
Who actually files these tips? In our experience, it’s rarely a stranger. It’s the bookkeeper who quit, the partner who got squeezed out of a deal, or the spouse in a messy divorce. Those people know where the accounts are, and now they’ve got a seven-figure reason to talk.
Who does the IRS HMRC whistleblower push target?
The IRS HMRC whistleblower push targets wealthy individuals and large businesses that use offshore accounts, shell companies, foreign trusts and foundations to hide income. US citizens abroad with unreported accounts, UK residents with undeclared offshore income, and anyone splitting transfers across several jurisdictions sit squarely in its sights.
Americans carry the heaviest load here. The US taxes its citizens on worldwide income wherever they live, so a US passport holder in Lisbon or Dubai still owes FBAR and FATCA reporting on foreign accounts. That’s why more Americans with real offshore lives are weighing whether to renounce US citizenship once they’ve secured a second nationality, and why second passport strategies have moved from fringe to mainstream planning.
The UK side bites differently. Since Britain abolished the non-dom tax break in April 2025, long-term residents face UK tax on worldwide income, and offshore income that used to sit outside the net is now fair game for an informant.
What should offshore account holders do before October 15?
File any missing FBAR through FinCEN’s BSA E-Filing System by October 15, the automatic extension date, if your foreign accounts topped $10,000 in aggregate at any point last year. Then audit every trust, company and account you control for proper reporting. A compliant structure gives an informant nothing to sell.
The IRS FBAR guidance is clear that the report goes to FinCEN separately from your tax return, and the extension to October 15 is automatic. No request needed.
This is where people get burned. We still see clients who assumed a dormant account holding $12,000 didn’t count. It does, because the $10,000 test is the combined value of all your foreign accounts. Under 31 U.S.C. 5321, FBAR penalties for non-willful failures start from a $10,000 base adjusted for inflation, while willful failures can cost the greater of $100,000 (also inflation-adjusted) or 50% of the account balance. The Supreme Court’s 2023 Bittner ruling limited non-willful penalties to one per report, which helps. Willful cases get no such mercy.
Being offshore is perfectly legal. Being unreported is the problem, and that’s the only thing these programs pay informants to expose.
IRS HMRC Whistleblower FAQ
What is the IRS HMRC whistleblower partnership?
How much is the HMRC whistleblower reward?
Can a non-American receive an IRS whistleblower award?
When is the FBAR deadline in 2026?
Does the IRS HMRC whistleblower program make offshore accounts illegal?
Bottom line: two of the world’s biggest tax authorities just put a price on your secrets. If your offshore setup is clean, this changes nothing. If it isn’t, October 15 is the cheapest day you’ll get to fix it.
Sources and References
- Internal Revenue Service, IR-2026-120: IRS highlights partnership with UK tax authority’s new whistleblower program
- HM Revenue & Customs, Reporting serious tax avoidance or evasion
- Internal Revenue Service, IR-2026-84: IRS recognizes National Whistleblower Day with $8 billion recovered since 2007
- Internal Revenue Service, Report of Foreign Bank and Financial Accounts (FBAR)
- Legal Information Institute, Cornell Law School, 31 U.S. Code 5321: Civil penalties
- Bloomberg Tax, The US and UK Are Aggressively Pursuing Tax Whistleblower Cases
