FINANCIAL
INSTITUTIONS.—Subparagraph (B) 
of section 861(a)(1) shall not apply. 
‘‘(2) SUBSTANTIAL UNITED STATES OWNER.— 
‘‘(A) IN GENERAL.—The term ‘substantial 
United States owner’ means— 
‘‘(i) with respect to any corporation, 
any specified United States person which 
owns, directly or indirectly, more than 10 
percent of the stock of such corporation 
(by vote or value), 
‘‘(ii) with respect to any partnership, 
any specified United States person which 
owns, directly or indirectly, more than 10 
percent of the profits interests or capital 
interests in such partnership, and 
‘‘(iii) in the case of a trust— 
‘‘(I) any specified United States 
person treated as an owner of any 
portion of such trust under subpart E 
of part I of subchapter J of chapter 
1, and 
‘‘(II) to the extent provided by 
the Secretary in regulations or other 
guidance, any specified United States 
person which holds, directly or indi-
rectly, more than 10 percent of the 
beneficial interests of such trust. 
‘‘(B) SPECIAL RULE FOR INVESTMENT VE-
HICLES.—In the case of any financial institu-
tion described in section 1471(d)(5)(C), clauses 
(i), (ii), and (iii) of subparagraph (A) shall be 
applied by substituting ‘0 percent’ for ‘10 per-
cent’. 
‘‘(3) SPECIFIED UNITED STATES PERSON.—Ex-
cept as otherwise provided by the Secretary, the 
term ‘specified United States person’ means any 
United States person other than— 
‘‘(A) any corporation the stock of which is 
regularly traded on an established securities 
market, 
‘‘(B) any corporation which is a member of 
the same expanded affiliated group (as defined 
in section 1471(e)(2) without regard to the last 
sentence thereof) as a corporation the stock of 
which is regularly traded on an established se-
curities market, 
‘‘(C) any organization exempt from tax-
ation under section 501(a) or an individual re-
tirement plan,
‘‘(D) the United States or any wholly 
owned agency or instrumentality thereof, 
‘‘(E) any State, the District of Columbia, 
any possession of the United States, any polit-
ical subdivision of any of the foregoing, or any 
wholly owned agency or instrumentality of any 
one or more of the foregoing, 
‘‘(F) any bank (as defined in section 581), 
‘‘(G) any real estate investment trust (as 
defined in section 856), 
‘‘(H) any regulated investment company 
(as defined in section 851), 
‘‘(I) any common trust fund (as defined in 
section 584(a)), and 
‘‘(J) any trust which— 
‘‘(i) is exempt from tax under section 
664(c), or 
‘‘(ii) 
is 
described 
in 
section 
4947(a)(1). 
‘‘(4) WITHHOLDING AGENT.—The term ‘with-
holding agent’ means all persons, in whatever capac-
ity acting, having the control, receipt, custody, dis-
posal, or payment of any withholdable payment.
‘‘(5) FOREIGN ENTITY.—The term ‘foreign en-
tity’ means any entity which is not a United States 
person. 
‘‘SEC. 1474. SPECIAL RULES. 
‘‘(a) LIABILITY FOR WITHHELD TAX.—Every person 
required to deduct and withhold any tax under this chap-
ter is hereby made liable for such tax and is hereby indem-
nified against the claims and demands of any person for 
the amount of any payments made in accordance with the 
provisions of this chapter. 
‘‘(b) CREDITS AND REFUNDS.— 
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), the determination of whether any tax de-
ducted and withheld under this chapter results in an 
overpayment by the beneficial owner of the payment 
to which such tax is attributable shall be made as 
if such tax had been deducted and withheld under 
subchapter A of chapter 3. 
‘‘(2) SPECIAL RULE WHERE FOREIGN FINAN-
CIAL INSTITUTION IS BENEFICIAL OWNER OF PAY-
MENT.— 
‘‘(A) IN GENERAL.—In the case of any tax 
properly deducted and withheld under section 
1471 from a specified financial institution pay-
ment—
‘‘(i) if the foreign financial institution 
referred to in subparagraph (B) with re-
spect to such payment is entitled to a re-
duced rate of tax with respect to such pay-
ment by reason of any treaty obligation of 
the United States— 
‘‘(I) the amount of any credit or 
refund with respect to such tax shall 
not exceed the amount of credit or re-
fund attributable to such reduction in 
rate, and 
‘‘(II) no interest shall be allowed 
or paid with respect to such credit or 
refund, and 
‘‘(ii) if such foreign financial institu-
tion is not so entitled, no credit or refund 
shall be allowed or paid with respect to 
such tax. 
‘‘(B) SPECIFIED FINANCIAL INSTITUTION 
PAYMENT.—The term ‘specified financial insti-
tution payment’ means any payment if the ben-
eficial owner of such payment is a foreign fi-
nancial institution. 
‘‘(3) REQUIREMENT TO IDENTIFY SUBSTANTIAL 
UNITED STATES OWNERS.—No credit or refund shall
be allowed or paid with respect to any tax properly 
deducted and withheld under this chapter unless the 
beneficial owner of the payment provides the Sec-
retary such information as the Secretary may re-
quire to determine whether such beneficial owner is 
a United States owned foreign entity (as defined in 
section 1471(d)(3)) and the identity of any substan-
tial United States owners of such entity. 
‘‘(c) CONFIDENTIALITY OF INFORMATION.— 
‘‘(1) IN GENERAL.—For purposes of this chap-
ter, rules similar to the rules of section 3406(f) shall 
apply. 
‘‘(2) DISCLOSURE OF LIST OF PARTICIPATING 
FOREIGN
FINANCIAL
INSTITUTIONS
PERMITTED.— 
The identity of a foreign financial institution which 
meets the requirements of section 1471(b) shall not 
be treated as return information for purposes of sec-
tion 6103. 
‘‘(d) COORDINATION WITH OTHER WITHHOLDING 
PROVISIONS.—The Secretary shall provide for the coordi-
nation of this chapter with other withholding provisions 
under this title, including providing for the proper cred-
iting of amounts deducted and withheld under this chapter 
against amounts required to be deducted and withheld 
under such other provisions.
‘‘(e) TREATMENT OF WITHHOLDING UNDER AGREE-
MENTS.—Any tax deducted and withheld pursuant to an 
agreement described in section 1471(b) shall be treated 
for purposes of this title as a tax deducted and withheld 
by a withholding agent under section 1471(a). 
‘‘(f) REGULATIONS.—The Secretary shall prescribe 
such regulations or other guidance as may be necessary 
or appropriate to carry out the purposes of this chapter.’’. 
(b) SPECIAL RULE
FOR INTEREST
ON OVERPAY-
MENTS.—Subsection (e) of section 6611 is amended by 
adding at the end the following new paragraph: 
‘‘(4) CERTAIN WITHHOLDING TAXES.—In the 
case of any overpayment resulting from tax deducted 
and withheld under chapter 3 or 4, paragraphs (1), 
(2), and (3) shall be applied by substituting ‘180 
days’ for ‘45 days’ each place it appears.’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 6414 is amended by inserting ‘‘or 
4’’ after ‘‘chapter 3’’. 
(2) Paragraph (1) of section 6501(b) is amend-
ed by inserting ‘‘4,’’ after ‘‘chapter 3,’’. 
(3) Paragraph (2) of section 6501(b) is amend-
ed— 
(A) by inserting ‘‘4,’’ after ‘‘chapter 3,’’ in 
the text thereof, and
(B) by striking ‘‘TAXES AND TAX IMPOSED 
BY CHAPTER 3’’ in the heading thereof and in-
serting ‘‘AND WITHHOLDING TAXES’’. 
(4) Paragraph (3) of section 6513(b) is amend-
ed— 
(A) by inserting ‘‘or 4’’ after ‘‘chapter 3’’, 
and 
(B) by inserting ‘‘or 1474(b)’’ after ‘‘sec-
tion 1462’’. 
(5) Subsection (c) of section 6513 is amended 
by inserting ‘‘4,’’ after ‘‘chapter 3,’’. 
(6) Paragraph (1) of section 6724(d) is amend-
ed by inserting ‘‘under chapter 4 or’’ after ‘‘filed 
with the Secretary’’ in the last sentence thereof. 
(7) Paragraph (2) of section 6724(d) is amend-
ed by inserting ‘‘or 4’’ after ‘‘chapter 3’’. 
(8) The table of chapters of the Internal Rev-
enue Code of 1986 is amended by adding at the end 
the following new item: 
‘‘CHAPTER 4. TAXES TO ENFORCE REPORTING ON CERTAIN FOREIGN 
ACCOUNTS.’’. 
(d) EFFECTIVE DATE.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall apply to payments made after De-
cember 31, 2012.
(2) GRANDFATHERED
TREATMENT
OF
OUT-
STANDING
OBLIGATIONS.—The amendments made 
by this section shall not require any amount to be 
deducted or withheld from any payment under any 
obligation outstanding on the date which is 2 years 
after the date of the enactment of this Act. 
(3) 
INTEREST
ON
OVERPAYMENTS.—The 
amendment made by subsection (b) shall apply— 
(A) in the case of such amendment’s appli-
cation to paragraph (1) of section 6611(e) of 
the Internal Revenue Code of 1986, to returns 
the due date for which (determined without re-
gard to extensions) is after the date of the en-
actment of this Act, 
(B) in the case of such amendment’s appli-
cation to paragraph (2) of such section, to 
claims for credit or refund of any overpayment 
filed after the date of the enactment of this Act 
(regardless of the taxable period to which such 
refund relates), and 
(C) in the case of such amendment’s appli-
cation to paragraph (3) of such section, to re-
funds paid after the date of the enactment of 
this Act (regardless of the taxable period to 
which such refund relates).
SEC. 502. REPEAL OF CERTAIN FOREIGN EXCEPTIONS TO 
REGISTERED BOND REQUIREMENTS. 
(a) REPEAL OF EXCEPTION TO DENIAL OF DEDUC-
TION FOR INTEREST ON NON-REGISTERED BONDS.— 
(1) IN
GENERAL.—Paragraph (2) of section 
163(f) is amended by striking subparagraph (B) and 
by redesignating subparagraph (C) as subparagraph 
(B). 
(2) CONFORMING AMENDMENTS.— 
(A) Subparagraph (A) of section 163(f)(2) 
is amended by inserting ‘‘or’’ at the end of 
clause (ii), by striking ‘‘, or’’ at the end of 
clause (iii) and inserting a period, and by strik-
ing clause (iv). 
(B) 
Subparagraph 
(B) 
of 
section 
163(f)(2), as redesignated by paragraph (1), is 
amended— 
(i) by striking ‘‘, and subparagraph 
(B),’’ in the matter preceding clause (i), 
and 
(ii) by amending clause (i) to read as 
follows: 
‘‘(i) such obligation is of a type which 
the Secretary has determined by regula-
tions to be used frequently in avoiding 
Federal taxes, and’’.
(C) Sections 165(j)(2)(A) and 1287(b)(1) 
are each amended by striking ‘‘except that 
clause (iv) of subparagraph (A), and subpara-
graph (B), of such section shall not apply’’. 
(b) REPEAL OF TREATMENT AS PORTFOLIO DEBT.— 
(1) IN
GENERAL.—Paragraph (2) of section 
871(h) is amended to read as follows: 
‘‘(2) PORTFOLIO INTEREST.—For purposes of 
this subsection, the term ‘portfolio interest’ means 
any interest (including original issue discount) 
which— 
‘‘(A) would be subject to tax under sub-
section (a) but for this subsection, and 
‘‘(B) is paid on an obligation— 
‘‘(i) which is in registered form, and 
‘‘(ii) with respect to which— 
‘‘(I) the United States person 
who would otherwise be required to 
deduct and withhold tax from such in-
terest under section 1441(a) receives 
a statement (which meets the require-
ments of paragraph (5)) that the ben-
eficial owner of the obligation is not a 
United States person, or
‘‘(II) the Secretary has deter-
mined that such a statement is not re-
quired in order to carry out the pur-
poses of this subsection.’’. 
(2) CONFORMING AMENDMENTS.— 
(A) Section 871(h)(3)(A) is amended by 
striking ‘‘subparagraph (A) or (B) of’’. 
(B) Paragraph (2) of section 881(c) is 
amended to read as follows: 
‘‘(2) PORTFOLIO INTEREST.—For purposes of 
this subsection, the term ‘portfolio interest’ means 
any interest (including original issue discount) 
which— 
‘‘(A) would be subject to tax under sub-
section (a) but for this subsection, and 
‘‘(B) is paid on an obligation— 
‘‘(i) which is in registered form, and 
‘‘(ii) with respect to which— 
‘‘(I) the person who would other-
wise be required to deduct and with-
hold tax from such interest under sec-
tion 1442(a) receives a statement 
which meets the requirements of sec-
tion 871(h)(5) that the beneficial
owner of the obligation is not a 
United States person, or 
‘‘(II) the Secretary has deter-
mined that such a statement is not re-
quired in order to carry out the pur-
poses of this subsection.’’. 
(c) 
DEMATERIALIZED
BOOK
ENTRY
SYSTEMS 
TREATED AS REGISTERED FORM.—Paragraph (3) of sec-
tion 163(f) is amended by inserting ‘‘, except that a dema-
terialized book entry system shall be treated as a book 
entry system described in such section’’ before the period 
at the end. 
(d) REPEAL OF EXCEPTION TO REQUIREMENT THAT 
TREASURY OBLIGATIONS BE IN REGISTERED FORM.— 
(1) IN
GENERAL.—Subsection (g) of section 
3121 of title 31, United States Code, is amended by 
striking paragraph (2) and by redesignating para-
graphs (3) and (4) as paragraphs (2) and (3), re-
spectively. 
(2) CONFORMING
AMENDMENTS.—Paragraph 
(1) of section 3121(g) of such title is amended— 
(A) by adding ‘‘or’’ at the end of subpara-
graph (A), 
(B) by striking ‘‘; or’’ at the end of sub-
paragraph (B) and inserting a period, and
(C) by striking subparagraph (C). 
(e) PRESERVATION OF EXCEPTION FOR EXCISE TAX 
PURPOSES.—Paragraph (1) of section 4701(b) is amend-
ed to read as follows: 
‘‘(1) REGISTRATION-REQUIRED OBLIGATION.— 
‘‘(A) IN
GENERAL.—The term ‘registra-
tion-required obligation’ has the same meaning 
as when used in section 163(f), except that 
such term shall not include any obligation 
which— 
‘‘(i) is required to be registered under 
section 149(a), or 
‘‘(ii) is described in subparagraph (B). 
‘‘(B) CERTAIN
OBLIGATIONS
NOT
IN-
CLUDED.—An obligation is described in this 
subparagraph if— 
‘‘(i) there are arrangements reason-
ably designed to ensure that such obliga-
tion will be sold (or resold in connection 
with the original issue) only to a person 
who is not a United States person, 
‘‘(ii) interest on such obligation is 
payable only outside the United States and 
its possessions, and
‘‘(iii) on the face of such obligation 
there is a statement that any United 
States person who holds such obligation 
will be subject to limitations under the 
United States income tax laws.’’. 
(f) EFFECTIVE DATE.—The amendments made by 
this section shall apply to obligations issued after the date 
which is 2 years after the date of the enactment of this 
Act. 
Subtitle B—Under Reporting With 
Respect to Foreign Assets 
SEC. 511. DISCLOSURE OF INFORMATION WITH RESPECT 
TO FOREIGN FINANCIAL ASSETS. 
(a) IN GENERAL.—Subpart A of part III of sub-
chapter A of chapter 61 is amended by inserting after sec-
tion 6038C the following new section: 
‘‘SEC. 6038D. INFORMATION WITH RESPECT TO FOREIGN FI-
NANCIAL ASSETS. 
‘‘(a) IN GENERAL.—Any individual who, during any 
taxable year, holds any interest in a specified foreign fi-
nancial asset shall attach to such person’s return of tax 
imposed by subtitle A for such taxable year the informa-
tion described in subsection (c) with respect to each such 
asset if the aggregate value of all such assets exceeds
$50,000 (or such higher dollar amount as the Secretary 
may prescribe). 
‘‘(b) SPECIFIED FOREIGN FINANCIAL ASSETS.—For 
purposes of this section, the term ‘specified foreign finan-
cial asset’ means— 
‘‘(1) any financial account (as defined in section 
1471(d)(2)) maintained by a foreign financial insti-
tution (as defined in section 1471(d)(4)), and 
‘‘(2) any of the following assets which are not 
held in an account maintained by a financial institu-
tion (as defined in section 1471(d)(5))— 
‘‘(A) any stock or security issued by a per-
son other than a United States person, 
‘‘(B) any financial instrument or contract 
held for investment that has an issuer or 
counterparty which is other than a United 
States person, and 
‘‘(C) any interest in a foreign entity (as 
defined in section 1473). 
‘‘(c) REQUIRED INFORMATION.—The information de-
scribed in this subsection with respect to any asset is: 
‘‘(1) In the case of any account, the name and 
address of the financial institution in which such ac-
count is maintained and the number of such ac-
count.
‘‘(2) In the case of any stock or security, the 
name and address of the issuer and such informa-
tion as is necessary to identify the class or issue of 
which such stock or security is a part. 
‘‘(3) In the case of any other instrument, con-
tract, or interest— 
‘‘(A) such information as is necessary to 
identify such instrument, contract, or interest, 
and 
‘‘(B) the names and addresses of all 
issuers and counterparties with respect to such 
instrument, contract, or interest. 
‘‘(4) The maximum value of the asset during 
the taxable year. 
‘‘(d) PENALTY FOR FAILURE TO DISCLOSE.— 
‘‘(1) IN GENERAL.—If any individual fails to 
furnish the information described in subsection (c) 
with respect to any taxable year at the time and in 
the manner described in subsection (a), such person 
shall pay a penalty of $10,000. 
‘‘(2) INCREASE IN PENALTY WHERE FAILURE 
CONTINUES
AFTER
NOTIFICATION.—If any failure 
described in paragraph (1) continues for more than 
90 days after the day on which the Secretary mails 
notice of such failure to the individual, such indi-
vidual shall pay a penalty (in addition to the pen-
alties under paragraph (1)) of $10,000 for each 30- 
day period (or fraction thereof) during which such 
failure continues after the expiration of such 90-day 
period. The penalty imposed under this paragraph 
with respect to any failure shall not exceed $50,000. 
‘‘(e) PRESUMPTION THAT VALUE
OF SPECIFIED 
FOREIGN
FINANCIAL
ASSETS
EXCEEDS
DOLLAR 
THRESHOLD.—If— 
‘‘(1) the Secretary determines that an indi-
vidual has an interest in one or more specified for-
eign financial assets, and 
‘‘(2) such individual does not provide sufficient 
information to demonstrate the aggregate value of 
such assets, 
then the aggregate value of such assets shall be treated 
as being in excess of $50,000 (or such higher dollar 
amount as the Secretary prescribes for purposes of sub-
section (a)) for purposes of assessing the penalties im-
posed under this section. 
‘‘(f) APPLICATION TO CERTAIN ENTITIES.—To the 
extent provided by the Secretary in regulations or other 
guidance, the provisions of this section shall apply to any 
domestic entity which is formed or availed of for purposes 
of holding, directly or indirectly, specified foreign financial
assets, in the same manner as if such entity were an indi-
vidual. 
‘‘(g) REASONABLE CAUSE EXCEPTION.—No penalty 
shall be imposed by this section on any failure which is 
shown to be due to reasonable cause and not due to willful 
neglect. The fact that a foreign jurisdiction would impose 
a civil or criminal penalty on the taxpayer (or any other 
person) for disclosing the required information is not rea-
sonable cause. 
‘‘(h) REGULATIONS.—The Secretary shall prescribe 
such regulations or other guidance as may be necessary 
or appropriate to carry out the purposes of this section, 
including regulations or other guidance which provide ap-
propriate exceptions from the application of this section 
in the case of— 
‘‘(1) classes of assets identified by the Sec-
retary, including any assets with respect to which 
the Secretary determines that disclosure under this 
section would be duplicative of other disclosures, 
‘‘(2) nonresident aliens, and 
‘‘(3) bona fide residents of any possession of 
the United States.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for subpart A of part III of subchapter A of chapter 61
is amended by inserting after the item relating to section 
6038C the following new item: 
‘‘Sec. 6038D. Information with respect to foreign financial assets.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 
512. 
PENALTIES 
FOR 
UNDERPAYMENTS 
ATTRIB-
UTABLE TO UNDISCLOSED FOREIGN FINAN-
CIAL ASSETS. 
(a) IN GENERAL.—Section 6662 is amended— 
(1) in subsection (b), by inserting after para-
graph (5) the following new paragraph: 
‘‘(6) Any undisclosed foreign financial asset un-
derstatement.’’, and 
(2) by adding at the end the following new sub-
section: 
‘‘(i) UNDISCLOSED FOREIGN FINANCIAL ASSET UN-
DERSTATEMENT.— 
‘‘(1) IN GENERAL.—For purposes of this sec-
tion, the term ‘undisclosed foreign financial asset 
understatement’ means, for any taxable year, the 
portion of the understatement for such taxable year 
which is attributable to any transaction involving an 
undisclosed foreign financial asset. 
‘‘(2) 
UNDISCLOSED
FOREIGN
FINANCIAL 
ASSET.—For purposes of this subsection, the term
‘undisclosed foreign financial asset’ means, with re-
spect to any taxable year, any asset with respect to 
which information was required to be provided under 
section 6038, 6038B, 6038D, 6046A, or 6048 for 
such taxable year but was not provided by the tax-
payer as required under the provisions of those sec-
tions. 
‘‘(3) INCREASE IN PENALTY FOR UNDISCLOSED 
FOREIGN FINANCIAL ASSET UNDERSTATEMENTS.— 
In the case of any portion of an underpayment 
which is attributable to any undisclosed foreign fi-
nancial asset understatement, subsection (a) shall be 
applied with respect to such portion by substituting 
‘40 percent’ for ‘20 percent’.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 513. MODIFICATION OF STATUTE OF LIMITATIONS 
FOR SIGNIFICANT OMISSION OF INCOME IN 
CONNECTION WITH FOREIGN ASSETS. 
(a) EXTENSION OF STATUTE OF LIMITATIONS.— 
(1) IN
GENERAL.—Paragraph (1) of section 
6501(e) is amended by redesignating subparagraphs 
(A) and (B) as subparagraphs (B) and (C), respec-
tively, and by inserting before subparagraph (B) (as 
so redesignated) the following new subparagraph: 
‘‘(A) GENERAL
RULE.—If the taxpayer 
omits from gross income an amount properly 
includible therein and— 
‘‘(i) such amount is in excess of 25 
percent of the amount of gross income 
stated in the return, or 
‘‘(ii) such amount— 
‘‘(I) is attributable to one or 
more assets with respect to which in-
formation is required to be reported 
under section 6038D (or would be so 
required if such section were applied 
without regard to the dollar threshold 
specified in subsection (a) thereof and 
without regard to any exceptions pro-
vided pursuant to subsection (h)(1) 
thereof), and 
‘‘(II) is in excess of $5,000, 
the tax may be assessed, or a proceeding in 
court for collection of such tax may be begun 
without assessment, at any time within 6 years 
after the return was filed.’’. 
(2) CONFORMING AMENDMENTS.—
(A) 
Subparagraph 
(B) 
of 
section 
6501(e)(1), as redesignated by paragraph (1), 
is amended by striking all that precedes clause 
(i) and inserting the following: 
‘‘(B) DETERMINATION
OF
GROSS
IN-
COME.—For purposes of subparagraph (A)—’’. 
(B) Paragraph (2) of section 6229(c) is 
amended by striking ‘‘which is in excess of 25 
percent of the amount of gross income stated in 
its return’’ and inserting ‘‘and such amount is 
described in clause (i) or (ii) of section 
6501(e)(1)(A)’’. 
(b) ADDITIONAL REPORTS SUBJECT TO EXTENDED 
PERIOD.—Paragraph (8) of section 6501(c) is amended— 
(1) by inserting ‘‘pursuant to an election under 
section 1295(b) or’’ before ‘‘under section 6038’’, 
(2) by inserting ‘‘1298(f),’’ before ‘‘6038’’, and 
(3) by inserting ‘‘6038D,’’ after ‘‘6038B,’’. 
(c) CLARIFICATIONS RELATED TO FAILURE TO DIS-
CLOSE FOREIGN TRANSFERS.—Paragraph (8) of section 
6501(c) is amended by striking ‘‘event’’ and inserting ‘‘tax 
return, event,’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to—