99–006 

112TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 1st Session 112–15 

SMALL BUSINESS PAPERWORK MANDATE ELIMINATION 

ACT OF 2011 

FEBRUARY 22, 2011.—Committed to the Committee of the Whole House on the State 

of the Union and ordered to be printed 

Mr. CAMP, from the Committee on Ways and Means, 

submitted the following 

R E P O R T 

[To accompany H.R. 4] 

[Including cost estimate of the Congressional Budget Office] 

The Committee on Ways and Means, to whom was referred the 

bill (H.R. 4) to repeal the expansion of information reporting requirements for payments of $600 or more to corporations, and for 

other purposes, having considered the same, report favorably thereon without amendment and recommend that the bill do pass. 

CONTENTS 

Page 

I. Summary and Background .............................................................................. 1 

II. Explanation of the Bill ..................................................................................... 2 

A. Repeal of Expansion of Information Reporting Requirements (sec. 

2 of the bill and sec. 6041 of the Code) ............................................ 2 

III. Votes of the Committee .................................................................................... 5 

IV. Budget Effects of the Bill ................................................................................. 5 

V. Other Matters To Be Discussed Under the Rules of the House ................... 8 

VI. Changes in Existing Law Made by the Bill, as Reported ............................. 11 

I. SUMMARY AND BACKGROUND

A. PURPOSE AND SUMMARY

The bill, H.R. 4 (the ‘‘Small Business Paperwork Mandate Elimination Act of 2011’’), as reported by the Committee on Ways and 

Means, provides that section 9006 of the Patient Protection and Affordable Care Act of 2010 (‘‘PPACA’’), Pub. L. No. 111–148 (March 

23, 2010), is repealed. As a result, section 6041 of the Internal Revenue Code is amended to no longer require reporting with respect 

to payments to corporations or with respect to gross proceeds for 


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1Secs. 6031 through 6060. 

property. Further, the additional regulatory authority granted to 

the Secretary is repealed. 

B. BACKGROUND AND NEED FOR LEGISLATION

Originally enacted in 2010 to help finance the cost of PPACA, the 

new provisions requiring expanded tax information reporting by 

businesses have generated considerable concern among taxpayers 

and policymakers alike. It is now widely acknowledged that, if allowed to go into effect, the expansion of these information reporting 

requirements will impose a substantial tax compliance burden on 

small businesses, forcing them to devote scarce resources to tax filing instead of to business expansion and job creation. Because the 

burdens on small businesses resulting from the imposition of these 

new requirements outweigh any potential improvement in tax compliance, the bill reflects a consensus that these new rules should 

be repealed. 

C. LEGISLATIVE HISTORY

Background 

H.R. 4 was introduced on January 12, 2011, and was referred to 

the Committee on Ways and Means. 

Committee action 

The Committee on Ways and Means marked up the bill on February 17, 2011, and ordered the bill favorably reported by voice 

vote. 

Committee hearings 

The Committee on Ways and Means held a full Committee hearing on January 20, 2011, on fundamental tax reform. This hearing 

focused on the economic and administrative burdens imposed by 

the current structure of the Federal income tax, including with respect to the burdens associated with the expanded Form 1099 reporting requirements imposed under section 9006 of PPACA. 

The Committee on Ways and Means held a full Committee hearing on January 26, 2011, on the health care law’s impact on jobs, 

employers, and the economy, including the impact of PPACA’s expanded Form 1099 reporting requirements. 

The Committee on Ways and Means held a full Committee hearing on February 15, 2011, on the President’s Fiscal Year 2012 

Budget with Secretary of the Treasury Timothy F. Geithner, including the President’s proposal relating to information reporting 

on payments to corporations and payments for property. 

II. EXPLANATION OF THE BILL

A. REPEAL OF EXPANSION OF INFORMATION REPORTING

REQUIREMENTS (SEC. 2 OF THE BILL AND SEC. 6041 OF THE CODE)

Present law 

A variety of information reporting requirements apply under 

present law.1 The primary provision governing information reporting by payors requires an information return by every person enVerDate Mar 15 2010 19:00 Feb 23, 2011 Jkt 099006 PO 00000 Frm 00002 Fmt 6659 Sfmt 6602 E:\HR\OC\HR015.XXX HR015

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2Sec. 6041(a). Information returns are generally submitted electronically on Forms 1096 and 

Forms 1099, although certain payments to beneficiaries or employees may require use of Forms 

W–3 and W–2, respectively. Treas. Reg. sec. 1.6041–1(a)(2). 3Sec. 6041(a) requires reporting of payments ‘‘other than payments to which section 

6042(a)(1), 6044(a)(1), 6047(c), 6049(a) or 6050N(a) applies and other than payments with respect to which a statement is required under authority of section 6042(a), 6044(a)(2) or 6045[.]’’ 

The payments thus excepted include most interest, royalties, and dividends. 4Treas. Reg. sec. 1.6041–3(p). 

5The Patient Protection and Affordable Care Act, Pub. L. No. 111–148, sec. 9006 (March 23, 

2010). 6Sec. 6041(d). Specifically, the recipient of the payment is required to provide a Form W–9 

to the payor, which enables the payee to provide the recipient of the payment with an annual 

statement showing the aggregate payments made and contact information for the payor. If a 

Form W–9 is not provided, the payor is required to ‘‘backup withhold’’ tax at a rate of 28 percent 

of the gross amount of the payment unless the payee has otherwise established that the income 

is exempt from backup withholding. The backup withholding tax may be credited by the payee 

against regular income tax liability, i.e., it is effectively an advance payment of tax, similar to 

the withholding of tax from wages. 7Sec. 6041(h); Small Business Jobs Act of 2010, Pub. L. No. 111–240, sec. 2101 (Sept. 27, 

2010). 8Treasury has not promulgated regulations defining these ‘‘minimal amounts of rental income’’ or ‘‘hardship’’ cases. 

gaged in a trade or business who makes payments to any one 

payee aggregating $600 or more in any taxable year in the course 

of that payor’s trade or business.2 Reportable payments include 

compensation for both goods and services, and may include gross 

proceeds. Certain enumerated types of payments that are subject 

to other specific reporting requirements are carved out of reporting 

under this general rule by regulation.3 Another carveout excepts 

payments to corporations from reporting requirements.4

For payments made after December 31, 2011, the class of payments subject to reporting was expanded in two ways.5 First, the 

regulatory carveout for payments to corporations was expressly 

overridden by the addition of section 6041(i). In addition, information reporting requirements were expanded to include gross proceeds paid in consideration for any type of property. The payor is 

required to provide the recipient of the payment with an annual 

statement showing the aggregate payments made and contact information for the payor.6 The regulations generally except from reporting payments to exempt organizations, governmental entities, 

international organizations, or retirement plans. 

Additionally, the requirement that businesses report certain payments is generally not applicable to payments by persons engaged 

in a passive investment activity. However, beginning in 2011, recipients of rental income from real estate generally are subject to 

the same information reporting requirements as taxpayers engaged 

in a trade or business.7 In particular, rental income recipients making payments of $600 or more to a service provider (such as a 

plumber, painter, or accountant) in the course of earning rental income are required to provide an information return (typically Form 

1099–MISC) to the IRS and to the service provider. Exceptions to 

this reporting requirement are made for (i) individuals who rent 

their principal residence on a temporary basis, including members 

of the military or employees of the intelligence community (as defined in section 121(d)(9)), (ii) individuals who receive only minimal 

amounts of rental income, as determined by the Secretary in accordance with regulations, and (iii) individuals for whom the requirements would cause hardship, as determined by the Secretary 

in accordance with regulations.8

Detailed rules are provided for the reporting of various types of 

investment income, including interest, dividends, and gross proVerDate Mar 15 2010 19:00 Feb 23, 2011 Jkt 099006 PO 00000 Frm 00003 Fmt 6659 Sfmt 6602 E:\HR\OC\HR015.XXX HR015

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9Secs. 6042 (dividends), 6045 (broker reporting) and 6049 (interest), as well as the Treasury 

regulations thereunder. 10See Treas. Reg. sec. 31.3406(h)–3. 11Sec. 6721. 12Sec. 6722. 13Sec. 6723. 

ceeds from brokered transactions (such as a sale of stock).9 In general, the requirement to file Form 1099 applies with respect to 

amounts paid to U.S. persons and is linked to the backup withholding rules of section 3406. Thus, a payor of interest, dividends 

or gross proceeds generally must request that a U.S. payee (other 

than certain exempt recipients) furnish a Form W–9 providing that 

person’s name and taxpayer identification number.10 That information is then used to complete the Form 1099. 

Failure to comply with the information reporting requirements 

results in penalties, which may include a penalty for failure to file 

the information return,11 a penalty for failure to furnish payee 

statements,12 or failure to comply with other various reporting requirements.13

Reasons for change 

The Committee understands that there is a significant tax gap, 

or difference between the amount of tax owed by taxpayers and the 

amount voluntarily paid to the IRS, that must be addressed. The 

Committee also recognizes that information reporting requirements 

generally improve taxpayer compliance. However, the Committee is 

concerned that the expansion of the information reporting requirements imposes a substantial tax compliance burden on small businesses, including costs to acquire new software or pay for additional accounting services. The Committee believes this burden is 

disproportionate as compared with any resulting improvement in 

tax compliance and therefore believes that these requirements 

should be repealed in their entirety. The Committee will continue 

to explore other potential solutions to the tax gap problem. 

Explanation of provision 

Under the provision, the changes to section 6041 enacted under 

section 9006 of the Patient Protection and Affordable Care Act that 

provide rules for payments to corporations, provide additional regulatory authority and impose a reporting requirement with respect 

to gross proceeds from property, are repealed in their entirety. 

Effective date 

This provision is effective for payments made after December 31, 

2011. 


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III. VOTES OF THE COMMITTEE

In compliance with clause 3(b) of rule XIII of the Rules of the 

House of Representatives, the following statements are made concerning the vote of the Committee on Ways and Means in its consideration of H.R. 4, the ‘‘Small Business Paperwork Mandate 

Elimination Act of 2011.’’ 

MOTION TO REPORT RECOMMENDATIONS

H.R. 4 was ordered favorably reported by voice vote (with a 

quorum being present). 

IV. BUDGET EFFECTS OF THE BILL

A. COMMITTEE ESTIMATE OF BUDGETARY EFFECTS

In compliance with clause 3(d) of the rule XIII of the Rules of the 

House of Representatives, the following statement is made concerning the effects on the budget of the revenue provisions of the 

bill, H.R. 4 as reported. 

The bill, as reported, is estimated to have the following effects 

on budget receipts for fiscal years 2011–2021: 


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ESTIMATED REVENUE EFFECTS OF H.R. 4, ‘‘THE SMALL BUSINESS PAPERWORK MANDATE ELIMINATION ACT OF 2011,’’ AS REPORTED BY THE COMMITTEE ON WAYS 

AND MEANS—FISCAL YEARS 2011–2021 

[Millions of dollars] 

Provision Effective 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2011–16 2011–21 

1. Repeal 1099 information reporting requirements 

for certain payments of more than $600 .............. DOE ............ ¥263 ¥2,785 ¥1,995 ¥2,064 ¥2,135 ¥2,309 ¥2,413 ¥2,523 ¥2,636 ¥2,782 ¥9,242 ¥21,905 

Net total ............................................................. ............ ............ ¥263 ¥2,785 ¥1,995 ¥2,064 ¥2,135 ¥2,309 ¥2,413 ¥2,523 ¥2,636 ¥2,782 ¥9,242 ¥21,905 

Joint Committee on Taxation. Note: Details may not add to totals due to rounding. Legend for ‘‘Effective’’ column: DOE = date of enactment. 


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B. STATEMENT REGARDING NEW BUDGET AUTHORITY AND TAX

EXPENDITURES BUDGET AUTHORITY

In compliance with clause 3(c)(2) of rule XIII of the Rules of the 

House of Representatives, the Committee states that the bill involves no new or increased budget authority. 

C. COST ESTIMATE PREPARED BY THE CONGRESSIONAL BUDGET OFFICE

In compliance with clause 3(c)(3) of rule XIII of the Rules of the 

House of Representatives, requiring a cost estimate prepared by 

the CBO, the following statement by CBO is provided. 

U.S. CONGRESS, 

CONGRESSIONAL BUDGET OFFICE, 

Washington, DC, February 18, 2011. 

Hon. DAVE CAMP, 

Chairman, Committee on Ways and Means, 

House of Representatives, Washington, DC. 

DEAR MR. CHAIRMAN: The Congressional Budget Office has prepared the enclosed cost estimate for H.R. 4, the Small Business Paperwork Mandate Elimination Act of 2011. 

If you wish further details on this estimate, we will be pleased 

to provide them. The staff contacts are Kalyani Parthasarathy 

(CBO) and Pamela Moomau (JCT). 

Sincerely, 

DOUGLAS W. ELMENDORF. 

Enclosure. 

H.R. 4—Small Business Paperwork Mandate Elimination Act of 

2011 

H.R. 4 would repeal certain scheduled expansions in information 

reporting requirements. The staff of the Joint Committee on Taxation (JCT) estimates that enacting the legislation would increase 

federal budget deficits by $21.9 billion over the 2011–2021 period, 

reflecting reductions in revenues. 

The legislation would repeal an expansion currently scheduled to 

take effect in 2012 of information that businesses must report to 

the recipients of certain payments, as well as to the Internal Revenue Service, on form 1099. Beginning in 2012, certain payments 

not previously subject to 1099 reporting requirements, including 

those made to corporations and those made for property, will become subject to the reporting requirements. The repeal of this expansion would reduce revenues by an estimated $21.9 billion over 

the 2011–2021 period, as shown in the following table. Because enacting H.R. 4 would affect revenues, pay-as-you-go procedures 

apply. (All effects are on-budget.) 


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By fiscal year, in millions of dollars— 

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2011–2016 2011–2021 

Estimated Revenue Effect ......................................................... 0 ¥263 ¥2,785 ¥1,995 ¥2,064 ¥2,135 ¥2,309 ¥2,413 ¥2,523 ¥2,636 ¥2,782 ¥9,242 ¥21,905 


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JCT has determined that the bill contains no intergovernmental 

or private-sector mandates as defined in the Unfunded Mandates 

Reform Act. 

The CBO staff contact for this estimate is Kalyani 

Parthasarathy. The estimate was approved by Frank Sammartino. 

D. MACROECONOMIC IMPACT ANALYSIS

In compliance with clause 3(h)(2) of rule XIII of the Rules of the 

House of Representatives, the following statement is made by the 

Joint Committee on Taxation with respect to the provisions of the 

bill amending the Internal Revenue Code of 1986: The effects of the 

bill on economic activity are so small as to be incalculable within 

the context of a model of the aggregate economy. 

V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE

HOUSE

A. COMMITTEE OVERSIGHT FINDINGS AND RECOMMENDATIONS

With respect to clause 3(c)(1) of rule XIII of the Rules of the 

House of Representatives (relating to oversight findings), the Committee advises that it was a result of the Committee’s oversight review concerning the tax compliance burden on taxpayers that the 

Committee concluded that it is appropriate to report the bill favorably to the House of Representatives with the recommendation that 

the bill do pass. 

B. STATEMENT OF GENERAL PERFORMANCE GOALS AND OBJECTIVES

With respect to clause 3(c)(4) of rule XIII of the Rules of the 

House of Representatives, the Committee advises that the bill contains no measure that authorizes funding, so no statement of general performance goals and objectives for which any measure authorizes funding is required. 

C. INFORMATION RELATING TO UNFUNDED MANDATES

This information is provided in accordance with section 423 of 

the Unfunded Mandates Reform Act of 1995 (P.L. 104–4). 

The Committee has determined that the bill does not contain 

Federal mandates on the private sector. The Committee has determined that the bill does not impose a Federal intergovernmental 

mandate on State, local, or tribal governments. 

D. APPLICABILITY OF HOUSE RULE XXI 5(b)

Rule XXI 5(b) of the Rules of the House of Representatives provides, in part, that ‘‘A bill or joint resolution, amendment, or conference report carrying a Federal income tax rate increase may not 

be considered as passed or agreed to unless so determined by a 

vote of not less than three-fifths of the Members voting, a quorum 

being present.’’ The Committee has carefully reviewed the provisions of the bill, and states that the provisions of the bill do not 

involve any Federal income tax rate increases within the meaning 

of the rule. 


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14Government Accountability Office, IRS Could Do More to Promote Compliance by Third 

Parties with Miscellaneous Income Reporting Requirements, GAO–09–238 (January 2009). 15See e.g., ‘‘Tax Year 2001 Individual Income Tax Underreporting Gap,’’ <http://www.irs.gov/ 

pub/irs-utl/taxlgaplupdatel070212.pdf> at 2, finding that information reporting is the priE. TAX COMPLEXITY ANALYSIS

Section 4022(b) of the Internal Revenue Service Reform and Restructuring Act of 1998 (the ‘‘IRS Reform Act’’) requires the staff 

of the Joint Committee on Taxation (in consultation with the Internal Revenue Service and the Treasury Department) to provide a 

tax complexity analysis. The complexity analysis is required for all 

legislation reported by the Senate Committee on Finance, the 

House Committee on Ways and Means, or any committee of conference if the legislation includes a provision that directly or indirectly amends the Internal Revenue Code and has widespread applicability to individuals or small businesses. The staff of the Joint 

Committee on Taxation has identified only one such provision, 

which is discussed below. Pursuant to clause 3(h)(1) of rule XIII of 

the Rules of the House of Representatives, a summary description 

of that provision is provided, along with an estimate of the number 

and type of affected taxpayers, and a discussion regarding the relevant complexity and administrative issues. 

Following the analysis of the staff of the Joint Committee on 

Taxation are the comments of the IRS and Treasury. 

REPEAL OF EXPANDED INFORMATION REPORTING FOR PAYMENTS WITH

RESPECT TO PROPERTY OR PAYMENTS MADE TO CORPORATIONS

Summary description of provision 

Under the provision, section 6041 is amended to delete references 

to gross proceeds from property, a requirement that payments to 

corporations be reported, and a grant of additional regulatory authority. Accordingly, the changes to section 6041 enacted under section 9006 of the Patient Protection and Affordable Care Act are repealed in their entirety. 

As a result of the repeal, taxpayers are not required to file an 

information return for all payments aggregating $600 or more in 

a calendar year to any single corporation payee (except a tax-exempt corporation). Second, the payments to be reported do not include gross proceeds paid in consideration for property. 

Number of affected taxpayers 

It is estimated that the provision will affect more than 10 percent of individual or small business tax returns. 

Discussion 

According to the Government Accountability Office, only eight 

percent of approximately 50 million small businesses with less 

than $10 million in assets filed miscellaneous information return 

Form 1099–MISC.14 If greater reporting from small businesses 

were available, it is possible that the IRS could more readily identify areas of underreported income of the payees. In general, the 

more payments to which information reporting and/or withholding 

applies, the greater the improvement in compliance.15 However, 


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mary differentiator in compliance rates. See also, Joseph Bankman, ‘‘Eight Truths About Collecting Taxes from the Cash Economy,’’ 117 Tax Notes 506, 511 (2007). 16See, Senate Finance Committee, ‘‘America’s Healthy Future Act of 2009,’’ S. Rep. 111–89 

(October 19, 2009), pp. 365–366. 17See e.g., Government Accountability Office, Costs and Uses of Third-Party Information Returns, November 2007, GAO–08–266, available at <http://www/gao.gov/new.items/d08266.pdf>, 

wherein the GAO, based on its case studies, found the compliance costs associated with filing 

information returns to be ‘‘relatively low.’’ 

since the reporting requirements were expanded, numerous critics 

have pointed to disproportionate additional administrative burden 

on those required to comply with the reporting obligations. Thus, 

requiring information reporting for all payments aggregating $600 

or more in a calendar year to a corporation and for payments for 

property may outweigh the enhanced taxpayer compliance. 

At the time the expanded provisions were under consideration, a 

complexity analysis 16 suggested that the widespread use of computer technology to process and store business information should 

minimize the burden associated with generating and transmitting 

the information necessary to comply with the provision, regardless 

of the extent to which the taxpayer is currently subject to information reporting. Although the additional burden of expanded reporting would have depended on the extent to which taxpayers subject 

to the provision already had adequate procedures and systems in 

place to comply with existing information reporting requirements,17

uncertainty about the scope of the expansion, and the lack of administrative guidance to date has made it difficult for taxpayers to 

determine what steps would be necessary to comply with the expanded reporting. Repeal of the additional information reporting 

requirements avoids the need for small businesses to develop new 

bookkeeping systems necessary in time for implementation of the 

expanded reporting in 2012. In addition, it relieves the IRS of the 

need to develop new forms and outreach programs to educate the 

public about the changes in reporting obligations. 

Comments from IRS and Treasury 

No guidance would be required. 

The relevant forms and instructions would not need to be modified (Forms 1099, 1098, 3921, 3922, 5498, and W–2G), and the instructions for certain other information returns and publications 

would not need to be revised to reflect the elimination of the exception for payments to corporations and the exception for payments 

other than for services. 

The IRS would not need to modify existing tax systems to reflect 

this provision. 

F. CONGRESSIONAL EARMARKS, LIMITED TAX BENEFITS, AND LIMITED

TARIFF BENEFITS

With respect to clause 9 of rule XXI of the Rules of the House 

of Representatives, the Committee has carefully reviewed the provisions of the bill, and states that the provisions of the bill do not 

contain any congressional earmarks, limited tax benefits, or limited 

tariff benefits within the meaning of the rule. 


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VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

In compliance with clause 3(e) of rule XIII of the Rules of the 

House of Representatives, changes in existing law made by the bill, 

as reported, are shown as follows (existing law proposed to be omitted is enclosed in black brackets and existing law in which no 

change is proposed is shown in roman): 

PATIENT PROTECTION AND AFFORDABLE CARE ACT 

* * * * * * * 

TITLE IX—REVENUE PROVISIONS 

SUBTITLE A—REVENUE OFFSET PROVISIONS

* * * * * * * 

øSEC. 9006. EXPANSION OF INFORMATION REPORTING REQUIREMENTS. 

ø(a) IN GENERAL.—Section 6041 of the Internal Revenue Code of 

1986 is amended by adding at the end the following new subsections: 

ø‘‘(h) APPLICATION TO CORPORATIONS.—Notwithstanding any regulation prescribed by the Secretary before the date of the enactment of this subsection, for purposes of this section the term ‘person’ includes any corporation that is not an organization exempt 

from tax under section 501(a). 

ø‘‘(i) REGULATIONS.—The Secretary may prescribe such regulations and other guidance as may be appropriate or necessary to 

carry out the purposes of this section, including rules to prevent 

duplicative reporting of transactions.’’. 

ø(b) PAYMENTS FOR PROPERTY AND OTHER GROSS PROCEEDS.— 

Subsection (a) of section 6041 of the Internal Revenue Code of 1986 

is amended— 

ø(1) by inserting ‘‘amounts in consideration for property,’’ 

after ‘‘wages,’’, 

ø(2) by inserting ‘‘gross proceeds,’’ after ‘‘emoluments, or 

other’’, and 

ø(3) by inserting ‘‘gross proceeds,’’ after ‘‘setting forth the 

amount of such’’. 

ø(c) EFFECTIVE DATE.—The amendments made by this section 

shall apply to payments made after December 31, 2011.¿ 

* * * * * * * 

SECTION 6041 OF THE INTERNAL REVENUE CODE OF 1986 

SEC. 6041. INFORMATION AT SOURCE. 

(a) PAYMENTS OF $600 OR MORE.—All persons engaged in a trade 

or business and making payment in the course of such trade or 

business to another person, of rent, salaries, wages, øamounts in 

consideration for property,¿ premiums, annuities, compensations, 

remunerations, emoluments, or other øgross proceeds,¿ fixed or determinable gains, profits, and income (other than payments to 

which section 6042(a)(1), 6044(a)(1), 6047(e), 6049(a), or 6050N(a) 


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applies, and other than payments with respect to which a statement is required under the authority of section 6042(a)(2), 

6044(a)(2), or 6045), or $600 or more in any taxable year, or, in the 

case of such payments made by the United States, the officers or 

employees of the United States having information as to such payments and required to make returns in regard thereto by the regulations hereinafter provided for, shall render a true and accurate 

return to the Secretary, under such regulations and in such form 

and manner and to such extent as may be prescribed by the Secretary, setting forth the amount of such øgross proceeds,¿ gains, 

profits, and income, and the name and address of the recipient of 

such payment. 

* * * * * * * 

ø(i) APPLICATION TO CORPORATIONS.—Notwithstanding any regulation prescribed by the Secretary before the date of the enactment 

of this subsection, for purposes of this section the term ‘‘person’’ includes any corporation that is not an organization exempt from tax 

under section 501(a). 

ø(j) REGULATIONS.—The Secretary may prescribe such regulations and other guidance as may be appropriate or necessary to 

carry out the purposes of this section, including rules to prevent 

duplicative reporting of transactions.¿ 

Æ 


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