On 7 October 2026, the Internal Revenue Service published a short news release that most people with money abroad will never read. Its subject was not a new law, a new form or a new deadline. It was a partnership between two whistleblower offices. In IR-2026-120, the IRS said it had helped Britain's tax authority set up its own programme for paying informants, and both agencies invited people with information about hidden wealth to come forward.
"The collaboration between the U.S. and the UK's whistleblower program will help deter large-scale, cross-border tax evasion," said Frank J. Bisignano, the IRS chief executive. HMRC's chief executive, JP Marks, said he was "pleased to join the IRS in recognizing the important role that informants play in helping protect the integrity of our tax systems."
It would be easy to file this under public relations. That would be a mistake. The release describes one more piece of a system that has been assembled step by step, and it changes the economics of secrecy in a way that automatic information exchange never could.
What Britain now pays
HMRC's programme is called the Strengthened Reward Scheme. According to the IRS it launched in November 2025, and HMRC's guidance, published on 26 November 2025, is plain about the money. If information leads HMRC to collect at least £1.5 million in tax, the informant can receive between 15% and 30% of the tax collected, excluding penalties and interest. HMRC says cases of that size normally involve large companies, wealthy individuals, or offshore or avoidance schemes.
There are conditions. Rewards are discretionary and not guaranteed. Anonymous reports are accepted but not paid. The taxpayer and anyone who planned and started the arrangement cannot claim. Neither can civil servants who learned of it at work, nor anyone whose information HMRC already had. And HMRC warns that investigations can take years, so payment may come long after the report.
What America has paid for longer
The American model is older and the numbers are similar. The IRS Whistleblower Office says awards are generally 15% to 30% of the proceeds collected and attributable to the whistleblower's information. Before a 2006 reform, the maximum was 15%. Since a 2018 amendment, the mandatory award regime under section 7623(b) applies where the proceeds in dispute exceed $2 million.
The October release adds two points that matter for anyone living across borders. The first is a list of what either agency wants to hear about: undeclared foreign bank accounts and failures to file the FBAR, "hidden assets routed through foreign trusts, foundation structures, financial instruments, or anonymous holding entities in tax havens", money laundering and transfer pricing manipulation. The second is a sentence that removes any comfortable assumption about who might talk: "Whistleblowers do not need to be citizens or residents of the U.S. or UK to receive an award."
From institutional secrecy to human secrecy
For most of the twentieth century, financial secrecy offshore rested on institutions. A bank in a discreet jurisdiction would not tell a foreign tax office anything, and the law of its home country forbade it to. That model ended in stages: FATCA for Americans, then the OECD's Common Reporting Standard for nearly everyone else, now being extended to crypto platforms and tightened for banks. The Brief has traced that process in the global transparency endgame and, for one major centre, in what the amended CRS will tell your home tax office about a Singapore account.
Automatic exchange has a limit, though. It reports what institutions hold in the name of identifiable people. It is much weaker against arrangements designed so that no institution's records point to the real owner: nominee structures, layered entities, assets held through a chain that ends somewhere the reporting does not reach. That residue of secrecy no longer lives in any bank's legal duty of confidentiality. It lives in the memories of the people who built and run the structure.
The IRS release names them without euphemism: "The accountants, bankers, or executives who blow the whistle and provide specific, credible intelligence, allow tax authorities to identify bad actors and ensure they fulfill their tax obligations." That is the shift. Institutional secrecy was abolished by treaty. Human secrecy is now being priced.
Every secret becomes an option held by someone else
Consider what a reward scheme does to the people around a hidden arrangement. A bookkeeper, a former finance director, a business partner who left on bad terms, a junior employee at a corporate services provider: each of them holds information. Before reward schemes, that information had moral value and legal risk, and little else. Now it has a cash value, set by statute or guidance at a percentage of the tax it helps recover.
Three features of that value make it worse for the person with something to hide.
It scales with the size of the secret. A reward of 15% to 30% of the tax collected means the larger the hidden liability, the larger the payout. The arrangements most worth hiding are, by construction, the ones most worth reporting.
It does not expire quickly. HMRC says plainly that investigations take years and rewards come late. An informant does not need to act in the year of the wrong. A dispute ten years later, a redundancy, a sale of the business, an ugly exit from a partnership: any of these can be the moment someone decides the information is worth more to a tax authority than to their loyalty.
It multiplies with the number of people who know. Every structure requires someone to set it up, someone to keep the books, someone to sign. Each of them is, in effect, holding an option that the owner of the structure cannot buy back. HMRC excludes the taxpayer, the person who planned and started the arrangement, and anyone legally bound to disclose or withhold the information, but its exclusions do not cover everyone who merely worked on a structure.
None of this requires a single new reporting rule. It works by changing the incentives of people who already know.
Why governments like this tool
From a treasury's point of view, a reward scheme has an unusual property: it pays for itself. HMRC's reward is a share of the tax collected, and the IRS award is a share of the proceeds collected. If nothing is recovered, nothing is paid. A government can therefore offer large sums without a budget line, and the larger the hidden liability, the more it gains even after the reward.
It is also a tool that crosses borders cheaply. Automatic exchange needed treaties, legislation in dozens of countries and years of systems work. A reward scheme needs a reporting form and a willingness to pay, and the October release shows the agencies sharing their experience of running one. The release says the IRS Whistleblower Office's expertise helped the British scheme "quickly get established". Other tax authorities that want the same result know where to ask.
What it does not mean
It is worth being precise about the limits, because the schemes are often misdescribed.
They are aimed at large cases. HMRC's threshold is £1.5 million of tax collected; the American mandatory regime starts above $2 million in dispute. A forgotten savings account abroad is not what either office is building its programme around, even if the FBAR is on the list of reportable conduct. For the ordinary internationally mobile family, the relevant deadlines and forms are the familiar ones, such as the October deadline for Americans abroad.
They pay only on results. HMRC's rewards are discretionary and not guaranteed, and even the American mandatory regime pays only out of proceeds actually collected on the strength of the information. Both agencies ask for information that is specific and credible. A grudge is not evidence.
And they do not change what is legal. A structure that is properly reported, in a jurisdiction that exchanges information, has nothing in it an informant could sell. The schemes raise the price only of what is hidden.
The robust structure is the one that survives being described
The practical lesson follows directly. For anyone with assets in several countries, the useful test for a structure is no longer "can a tax authority find this?" Automatic exchange has largely answered that. The test is now "would this survive being described, accurately and in detail, by the least loyal person who knows about it?"
A structure that passes that test has a few recognisable features. It sits in jurisdictions that cooperate, which is one reason the Brief has argued that boring jurisdictions win. It is reported where it should be, by its owner, before anyone else reports it. And it is documented well enough that its owner, not a former employee, controls the story; the Brief's case for the paper trail makes the same point about residence.
A structure that fails it is not only a legal risk. It is a standing liability whose size the owner does not control, held in part by people whose interests may diverge from the owner's at any moment, now with two of the world's largest tax authorities offering to pay them for it and cooperating with each other in doing so.
For a long time, international wealth planning treated secrecy as a feature that could be bought. The October release is a reminder that it can now be sold, and not by the person who paid for it.
Work with Sebastian
If you hold assets across several countries and want a structure that is built to be reported rather than hidden, and that would stand up to any description of it, that is the kind of cross-border planning Sebastian works on with internationally mobile clients. Book a consultation.
