Whistleblowers, Tax Justice & The Fight For Reform

Whistleblower legend Stephen Kohn joins Eric Green for a no-BS look inside the world of tax whistleblowing, billion-dollar recoveries, and why the IRS program is failing to live up to its potential.

From the UBS case that shook Swiss banking to the bipartisan bill that could finally fix the system, Stephen breaks down what’s working, what’s broken, and why whistleblowers remain America’s best weapon against large-scale tax cheats.

If you care about tax justice, enforcement, or the future of whistleblower law, this fast-moving conversation is essential listening.

Click here to Contact your Representative today to advocate for the inclusion of the reforms in the Taxpayer Assistance and Service Act.

Contact Steve Kohn at https://kkc.com/our-whistleblower-law-firm/our-whistleblower-lawyers/stephen-m-kohn/

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Whistleblowers, Tax Justice, and the Fight to Fix a Broken IRS Program

In a wide-ranging and candid conversation, Stephen Kohn joined Eric Green for a no-nonsense discussion about whistleblowers, billion-dollar tax recoveries, and why the IRS Whistleblower Program—despite its enormous potential—is failing the very people who make it work.

Kohn is widely regarded as one of the most influential whistleblower attorneys in the world. With nearly four decades of experience, he has helped shape modern whistleblower law, represented some of the most famous whistleblowers in history, and played a central role in drafting landmark legislation including Sarbanes-Oxley, Dodd-Frank, and anti-money-laundering whistleblower protections. Most famously, he represented Bradley Birkenfeld in the UBS case that exposed massive offshore tax evasion and resulted in the first-ever $100+ million whistleblower award.

Yet despite those successes, Kohn argues that the IRS Whistleblower Program has become “repeal by delay.”

The problem isn’t the lack of strong cases. According to Kohn, his firm routinely receives well-documented, credible submissions—often from insiders like CFOs—detailing tax fraud worth hundreds of millions or even billions of dollars. The problem is what happens next. IRS whistleblower cases often disappear into what Kohn calls a “black hole,” with minimal communication, extreme secrecy, and an average resolution time of more than eleven years.

That delay discourages whistleblowers and makes it increasingly difficult for attorneys to take cases on a contingency basis. In some instances, the IRS may choose not to pursue a case at all, with virtually no meaningful recourse for the whistleblower. Even when cases are successful, awards remain discretionary, there is no interest paid on delayed awards, and whistleblowers have limited ability to challenge denials.

This dysfunction stands in stark contrast to what whistleblower programs can achieve when they work properly. Kohn pointed to the UBS case as a prime example: one whistleblower triggered a cascade of enforcement actions that led to tens of billions of dollars in recovered revenue, the collapse of Swiss bank secrecy for U.S. taxpayers, and long-term compliance gains that continue to generate tax revenue today.

The data is clear. Whistleblower programs routinely deliver returns of 300-to-1 or more on government investment. They solve the hardest problem in white-collar enforcement—detection—and do so more effectively than traditional audits or investigations ever could.

So why the resistance?

Kohn described a deep cultural conflict within government agencies. On one side are investigators who recognize whistleblowers as invaluable partners. On the other is a long-standing anti-whistleblower mindset rooted in decades of viewing whistleblowers as adversaries rather than allies. That internal conflict has left the IRS program stalled.

The good news is that reform is on the table. A bipartisan bill—the Taxpayer Assistance and Service Act—would fix many of the program’s structural flaws. The proposed reforms would accelerate case processing, strengthen due-process protections, allow meaningful judicial review, and finally give whistleblowers a way to hold the IRS accountable for inaction.

Importantly, there is no organized opposition to the bill. The only obstacle is political attention.

That’s where tax professionals, practitioners, and concerned citizens come in. Kohn emphasized that targeted grassroots pressure works. Strategic action alerts have already succeeded in pushing major whistleblower reforms across the finish line in other areas.

If the IRS Whistleblower Program is going to live up to its promise—and if large-scale tax cheating is going to be meaningfully addressed—now is the moment to act.

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About Stephen Kohn

Stephen M. Kohn, with 38 years of experience, was peer-reviewed by the National Law Journal as one of the 50 top Plaintiff’s Lawyers in the United States, the only whistleblower rights lawyer to achieve this distinction. In 2024 and 2025, Forbes named Kohn as one of the top 200 attorneys in the United States.

A founding partner of Kohn, Kohn & Colapinto, LLP, Kohn specializes in whistleblower advocacy, helping to change that legal landscape worldwide. He won the first $100 million whistleblower award for a UBS Swiss Banker and set numerous precedents expanding the scope of whistleblower protections. He won landmark cases under the False Claims Act, Dodd-Frank, AML, FCPA, Commodity Exchange, and tax whistleblower laws, and currently represents the Danske Bank whistleblower who reported (and helped stop) the largest known money-laundering scandal ($230 billion). Kohn helped draft key transnational whistleblower laws, including Dodd-Frank, Sarbanes-Oxley, and the AML law.

In 1988, he helped found the National Whistleblower Center, where he currently serves, pro bono, as Chairman of the Board. He is the author of the first legal treatise on whistleblowing and is the world’s most published author on whistleblower protection. His eighth book on whistleblowing is “Rules for Whistleblowers: A Handbook for Doing What’s Right” (Lyons Press, 2023). https://kkc.com/our-whistleblower-law-firm/our-whistleblower-lawyers/stephen-m-kohn/