Integrates Foreign Bank and Financial Account (FBAR) reporting with the annual federal income tax return, treating them as timely filed if the main tax return is on time. It explicitly grants the Tax Court jurisdiction to review and redetermine whether these disallowance periods were properly imposed. It explicitly grants the Tax Court jurisdiction to review and redetermine whether these disallowance periods were properly imposed. TITLE VII—WHISTLEBLOWERSDe Novo Tax Court Review: Clarifies that Tax Court reviews of whistleblower award determinations must be de novo, utilizing the original administrative record and newly discovered or previously unavailable evidence. Whistleblowers shall proceed anonymously before the Tax Court unless the court determines a heightened societal interest outweighs potential harm to the whistleblower.