II 

114TH CONGRESS 

1ST SESSION S. 663 

To repeal the violation of sovereign nations’ laws and privacy matters. 

IN THE SENATE OF THE UNITED STATES 

MARCH 4, 2015 

Mr. PAUL (for himself and Mr. WICKER) introduced the following bill; which 

was read twice and referred to the Committee on Finance 

A BILL 

To repeal the violation of sovereign nations’ laws and privacy 

matters. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. REPEAL OF WITHHOLDING AND REPORTING 

4 WITH RESPECT TO CERTAIN FOREIGN AC5 COUNTS. 

6 (a) IN GENERAL.—The Internal Revenue Code of 

7 1986 is amended by striking chapter 4. 

8 (b) CONFORMING AMENDMENTS FOR RULES FOR

9 ELECTRONICALLY FILED RETURNS.—Section 6011(e)(4) 

10 of such Code is amended— 

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1 (1) by striking ‘‘(as defined in section 

2 1471(d)(5))’’ and inserting ‘‘(as defined in section 

3 6038D(h)(3))’’, and 

4 (2) by striking ‘‘or 1474(a)’’. 

5 (c) CONFORMING AMENDMENT RELATED TO SUB6 STITUTE DIVIDENDS.—Section 871(l) of such Code is 

7 amended by striking ‘‘chapters 3 and 4’’ both places it 

8 appears and inserting ‘‘chapter 3’’. 

9 (d) OTHER CONFORMING AMENDMENTS.— 

10 (1) Section 6414 of such Code is amended by 

11 striking ‘‘or 4’’. 

12 (2) Paragraph (1) of section 6501(b) of such 

13 Code is amended by striking ‘‘4,’’. 

14 (3) Paragraph (2) of section 6501(b) of such 

15 Code is amended— 

16 (A) by striking ‘‘4,’’, and 

17 (B) by striking ‘‘AND WITHOLDING TAXES’’ 

18 in the heading and inserting ‘‘TAXES AND TAX

19 IMPOSED BY CHAPTER 3’’. 

20 (4) Paragraph (3) of section 6513(b) of such 

21 Code is amended— 

22 (A) by striking ‘‘or 4’’, and 

23 (B) by striking ‘‘or 1474(b)’’. 

24 (5) Section 6513(c) of such Code is amended by 

25 striking ‘‘4,’’. 

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1 (6) Section 6611(e)(4) of the Internal Revenue 

2 Code of 1986 is amended by striking ‘‘or 4’’. 

3 (7) Paragraph (1) of section 6724(d) of such 

4 Code is amended by striking ‘‘under chapter 4 or’’. 

5 (8) Paragraph (2) of section 6724(d) of such 

6 Code is amended by striking ‘‘or 4’’. 

7 (e) EFFECTIVE DATE.—The amendments made by 

8 this section shall apply to payments made after the date 

9 of the enactment of this Act. 

10 SEC. 2. REPEAL OF INFORMATION REPORTING WITH RE11 SPECT TO FOREIGN FINANCIAL ASSETS. 

12 (a) IN GENERAL.—Subpart A of part III of sub13 chapter A of chapter 61 of the Internal Revenue Code of 

14 1986 is amended by striking section 6038D. 

15 (b) REPEAL OF MODIFICATION OF STATUTE OF LIM16 ITATIONS FOR SIGNIFICANT OMISSION OF INCOME IN

17 CONNECTION WITH FOREIGN ASSETS.— 

18 (1) Paragraph (1) of section 6501(e) of the In19 ternal Revenue Code of 1986 is amended by striking 

20 subparagraph (A) and by redesignating subpara21 graphs (B) and (C) as subparagraphs (A) and (B), 

22 respectively. 

23 (2) Subparagraph (A) of section 6501(e) of 

24 such Code, as redesignated by paragraph (1), is 

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1 amended by striking all that precedes clause (i) and 

2 inserting the following: 

3 ‘‘(A) GENERAL RULE.—If the taxpayer 

4 omits from gross income an amount properly 

5 included therein which is in excess of 25 per6 cent of the amount of gross income stated in 

7 the return, the tax may be assessed, or a pro8 ceeding in court for the collection of such tax 

9 may be begun without assessment, at any time 

10 within 6 years after the return was filed. For 

11 purposes of this subparagraph—’’. 

12 (3) Paragraph (2) of section 6501(e) of such 

13 Code is amended by striking ‘‘and such amount is 

14 described in clause (i) or (ii) of section 

15 6501(e)(1)(A)’’ and inserting ‘‘which is in excess of 

16 25 percent of the amount of gross income stated in 

17 its return’’. 

18 (4) Paragraph (8) of section 6501(c) is amend19 ed— 

20 (A) by striking ‘‘pursuant to an election 

21 under section 1295(b) or’’, 

22 (B) by striking ‘‘1298(f)’’, and 

23 (C) by striking ‘‘6038D,’’. 

24 (c) CLERICAL AMENDMENT.—The table of sections 

25 for subpart A of part III of subchapter A of chapter 61 

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1 of such Code is amended by striking the item related to 

2 section 6038D. 

3 (d) EFFECTIVE DATE.— 

4 (1) IN GENERAL.—Except as provided in para5 graph (2), the amendments made by this section 

6 shall apply to taxable years ending after the date of 

7 the enactment of this Act. 

8 (2) RETURNS.—The amendments made by sub9 section (b) shall apply to returns filed after the date 

10 of the enactment of this Act. 

11 SEC. 3. REPEAL OF PENALTIES FOR UNDERPAYMENTS AT12 TRIBUTABLE TO UNDISCLOSED FOREIGN FI13 NANCIAL ASSETS. 

14 (a) IN GENERAL.—Section 6662 of the Internal Rev15 enue Code of 1986 is amended— 

16 (1) in subsection (b), by striking paragraph (7), 

17 and 

18 (2) by striking subsection (j). 

19 (b) EFFECTIVE DATE.—The amendments made by 

20 this section shall apply to taxable years ending after the 

21 date of the enactment of this Act. 

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1 SEC. 4. REPEAL OF REPORTING OF ACTIVITIES WITH RE2 SPECT TO PASSIVE FOREIGN INVESTMENT 

3 COMPANIES. 

4 (a) IN GENERAL.—Section 1298 of the Internal Rev5 enue Code of 1986 is amended by striking subsection (f) 

6 and by redesignating subsection (g) as subsection (f). 

7 (b) CONFORMING AMENDMENT.—Section 1291(e) of 

8 such Code is amended by striking ‘‘and (d)’’ and inserting 

9 ‘‘, (d), and (f)’’. 

10 (c) EFFECTIVE DATE.—The amendments made by 

11 this section shall take effect on the date of the enactment 

12 of this Act. 

13 SEC. 5. REPEAL OF REPORTING REQUIREMENT FOR 

14 UNITED STATES OWNERS OF FOREIGN 

15 TRUSTS. 

16 (a) IN GENERAL.—Paragraph (1) of section 6048(b) 

17 is amended by striking ‘‘shall submit such information as 

18 the Secretary may prescribe with respect to such trust for 

19 such year and’’. 

20 (b) EFFECTIVE DATE.—The amendments made by 

21 this section shall apply to taxable years ending after the 

22 date of the enactment of this Act. 

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1 SEC. 6. REPEAL OF MINIMUM PENALTY WITH RESPECT TO 

2 FAILURE TO REPORT ON CERTAIN FOREIGN 

3 TRUSTS. 

4 (a) IN GENERAL.—Section 6677(a) of the Internal 

5 Revenue Code of 1986 is amended— 

6 (1) by striking ‘‘the greater of $10,000 or’’, 

7 and 

8 (2) by striking the last sentence and inserting 

9 the following: ‘‘In no event shall the penalty under 

10 this subsection with respect to any failure exceed the 

11 gross reportable amount.’’. 

12 (b) EFFECTIVE DATE.—The amendments made by 

13 this section shall apply to notices and returns required to 

14 be filed after the date of the enactment of this Act. 

Æ 

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