date The amendment made by this section shall apply to reports the due date for which are after the enactment of this Act. 6. Interest on whistleblower awards (a) In general Section 7623(b) of the Internal Revenue Code of 1986 is amended by redesignating paragraphs (5) and (6) as paragraphs (6) and (7), respectively, and by inserting after paragraph (4) the following new paragraph: (5) Interest (A) In general If the Secretary has not provided notice to an individual described in paragraph (1) of a preliminary award recommendation before the applicable date, the amount of any award under this subsection shall include interest from such date at the overpayment rate under section 6621(a). (B) Exception No interest shall accrue under this paragraph after the date on which the Secretary provides notice to the individual of a preliminary award recommendation. (C) Applicable date For purposes of this paragraph, the applicable date is the date that is 12 months after the first date on which— (i) all of the proceeds resulting from actions subject to the award recommendation have been collected, and (ii) either— (I) the statutory period for filing a claim for refund has expired, or (II) the taxpayers subject to the actions and the Secretary have agreed with finality to the tax or other liabilities for the periods at issue, and either the taxpayers have waived the right to file a claim for refund or any claim for refund has been resolved. . (b) Effective date (1) In general The amendments made by this section shall take effect 180 days after the date of the enactment of this Act. (2) Special rule In the case of a claim for a whistleblower award under section 7623(b) of the Internal Revenue Code of 1986 with respect to which, as of the date described in paragraph (1)— (A) the Secretary of the Treasury has not provided notice to the individual of a preliminary award recommendation as described in paragraph (5)(A) of such section, as added by this Act, and (B) the applicable date provided in paragraph (5)(C) of such section,