Subtitle A—Exclusion for Energy
Conservation Subsidies Limited
to Subsidies With Respect to
Dwelling Units
SEC. 401. EXCLUSION FOR ENERGY CONSERVATION SUB-
SIDIES LIMITED TO SUBSIDIES WITH RE-
SPECT TO DWELLING UNITS.
(a) IN GENERAL.—Paragraph (1) of section 136(c)
(defining energy conservation measure) is amended by
striking ‘‘energy demand—’’ and all that follows and in-
serting ‘‘energy demand with respect to a dwelling unit.’’
(b) CONFORMING AMENDMENTS.—
(1) Subsection (a) of section 136 is amended to
read as follows:
‘‘(a) EXCLUSION.—Gross income shall not include the
value of any subsidy provided (directly or indirectly) by
a public utility to a customer for the purchase or installa-
tion of any energy conservation measure.’’
(2) Paragraph (2) of section 136(c) is amend-
ed—
(A) by striking subparagraph (A) and by
redesignating subparagraphs (B) and (C) as sub-
paragraphs (A) and (B), respectively, and
(B) by striking ‘‘AND SPECIAL RULES’’ in
the paragraph heading.
(c) EFFECTIVE DATE.—The amendments made by this
section shall apply to amounts received after December 31,
1996, unless received pursuant to a written binding con-
tract in effect on September 13, 1995, and at all times there-
after.
Subtitle B—Foreign Trust Tax
Compliance
SEC. 411. IMPROVED INFORMATION REPORTING ON FOR-
EIGN TRUSTS.
(a) IN GENERAL.—Section 6048 (relating to returns
as to certain foreign trusts) is amended to read as follows:
‘‘SEC. 6048. INFORMATION WITH RESPECT TO CERTAIN FOR-
EIGN TRUSTS.
‘‘(a) NOTICE OF CERTAIN EVENTS.—
‘‘(1) GENERAL RULE.—On or before the 90th day
(or such later day as the Secretary may prescribe)
after any reportable event, the responsible party shall
provide written notice of such event to the Secretary
in accordance with paragraph (2).
‘‘(2) CONTENTS OF NOTICE.—The notice required
by paragraph (1) shall contain such information as
the Secretary may prescribe, including—
‘‘(A) the amount of money or other property
(if any) transferred to the trust in connection
with the reportable event, and
‘‘(B) the identity of the trust and of each
trustee and beneficiary (or class of beneficiaries)
of the trust.
‘‘(3) REPORTABLE EVENT.—For purposes of this
subsection—
‘‘(A) IN
GENERAL.—The term ‘reportable
event’ means—
‘‘(i) the creation of any foreign trust
by a United States person,
‘‘(ii) the transfer of any money or
property (directly or indirectly) to a foreign
trust by a United States person, including
a transfer by reason of death, and
‘‘(iii) the death of a citizen or resident
of the United States if—
‘‘(I) the decedent was treated as
the owner of any portion of a foreign
trust under the rules of subpart E of
part I of subchapter J of chapter 1, or
‘‘(II) any portion of a foreign
trust was included in the gross estate
of the decedent.
‘‘(B) EXCEPTIONS.—
‘‘(i) FAIR
MARKET
VALUE
SALES.—
Subparagraph (A)(ii) shall not apply to
any transfer of property to a trust in ex-
change for consideration of at least the fair
market value of the transferred property.
For purposes of the preceding sentence, con-
sideration other than cash shall be taken
into account at its fair market value and
the rules of section 679(a)(3) shall apply.
‘‘(ii) DEFERRED
COMPENSATION
AND
CHARITABLE
TRUSTS.—Subparagraph (A)
shall not apply with respect to a trust
which is—
‘‘(I) described in section 402(b),
404(a)(4), or 404A, or
‘‘(II) determined by the Secretary
to be described in section 501(c)(3).
‘‘(4) RESPONSIBLE PARTY.—For purposes of this
subsection, the term ‘responsible party’ means—
‘‘(A) the grantor in the case of the creation
of an inter vivos trust,
‘‘(B) the transferor in the case of a report-
able event described in paragraph (3)(A)(ii)
other than a transfer by reason of death, and
‘‘(C) the executor of the decedent’s estate in
any other case.
‘‘(b) UNITED STATES GRANTOR OF FOREIGN TRUST.—
‘‘(1) IN GENERAL.—If, at any time during any
taxable year of a United States person, such person
is treated as the owner of any portion of a foreign
trust under the rules of subpart E of part I of sub-
chapter J of chapter 1, such person shall be respon-
sible to ensure that—
‘‘(A) such trust makes a return for such
year which sets forth a full and complete ac-
counting of all trust activities and operations for
the year, the name of the United States agent for
such trust, and such other information as the
Secretary may prescribe, and
‘‘(B) such trust furnishes such information
as the Secretary may prescribe to each United
States person (i) who is treated as the owner of
any portion of such trust or (ii) who receives
(directly or indirectly) any distribution from the
trust.
‘‘(2) TRUSTS
NOT
HAVING
UNITED
STATES
AGENT.—
‘‘(A) IN
GENERAL.—If the rules of this
paragraph apply to any foreign trust, the deter-
mination of amounts required to be taken into
account with respect to such trust by a United
States person under the rules of subpart E of
part I of subchapter J of chapter 1 shall be de-
termined by the Secretary.
‘‘(B) UNITED STATES AGENT REQUIRED.—
The rules of this paragraph shall apply to any
foreign trust to which paragraph (1) applies un-
less such trust agrees (in such manner, subject to
such conditions, and at such time as the Sec-
retary shall prescribe) to authorize a United
States person to act as such trust’s limited agent
solely for purposes of applying sections 7602,
7603, and 7604 with respect to—
‘‘(i) any request by the Secretary to ex-
amine records or produce testimony related
to the proper treatment of amounts required
to be taken into account under the rules re-
ferred to in subparagraph (A), or
‘‘(ii) any summons by the Secretary
for such records or testimony.
The appearance of persons or production of
records by reason of a United States person
being such an agent shall not subject such per-
sons or records to legal process for any purpose
other than determining the correct treatment
under this title of the amounts required to be
taken into account under the rules referred to in
subparagraph (A). A foreign trust which ap-
points an agent described in this subparagraph
shall not be considered to have an office or a per-
manent establishment in the United States, or to
be engaged in a trade or business in the United
States, solely because of the activities of such
agent pursuant to this subsection.
‘‘(C) OTHER RULES TO APPLY.—Rules simi-
lar to the rules of paragraphs (2) and (4) of sec-
tion 6038A(e) shall apply for purposes of this
paragraph.
‘‘(c) REPORTING BY UNITED STATES BENEFICIARIES
OF FOREIGN TRUSTS.—
‘‘(1) IN GENERAL.—If any United States person
receives (directly or indirectly) during any taxable
year of such person any distribution from a foreign
trust, such person shall make a return with respect
to such trust for such year which includes—
‘‘(A) the name of such trust,
‘‘(B) the aggregate amount of the distribu-
tions so received from such trust during such
taxable year, and
‘‘(C) such other information as the Sec-
retary may prescribe.
‘‘(2) INCLUSION
IN
INCOME
IF
RECORDS
NOT
PROVIDED.—
‘‘(A) IN GENERAL.—If adequate records are
not provided to the Secretary to determine the
proper treatment of any distribution from a for-
eign trust, such distribution shall be treated as
an accumulation distribution includible in the
gross income of the distributee under chapter 1.
To the extent provided in regulations, the preced-
ing sentence shall not apply if the foreign trust
elects to be subject to rules similar to the rules
of subsection (b)(2)(B).
‘‘(B) APPLICATION OF ACCUMULATION DIS-
TRIBUTION
RULES.—For purposes of applying
section 668 in a case to which subparagraph (A)
applies, the applicable number of years for pur-
poses of section 668(a) shall be 1⁄2 of the number
of years the trust has been in existence.
‘‘(d) SPECIAL RULES.—
‘‘(1) DETERMINATION
OF
WHETHER
UNITED
STATES PERSON MAKES TRANSFER OR RECEIVES DIS-
TRIBUTION.—For purposes of this section, in deter-
mining whether a United States person makes a
transfer to, or receives a distribution from, a foreign
trust, the fact that a portion of such trust is treated
as owned by another person under the rules of sub-
part E of part I of subchapter J of chapter 1 shall
be disregarded.
‘‘(2) DOMESTIC TRUSTS WITH FOREIGN ACTIVI-
TIES.—To the extent provided in regulations, a trust
which is a United States person shall be treated as
a foreign trust for purposes of this section and section
6677 if such trust has substantial activities, or holds
substantial property, outside the United States.
‘‘(3) TIME AND MANNER OF FILING INFORMA-
TION.—Any notice or return required under this sec-
tion shall be made at such time and in such manner
as the Secretary shall prescribe.
‘‘(4) 
MODIFICATION
OF
RETURN
REQUIRE-
MENTS.—The Secretary is authorized to suspend or
modify any requirement of this section if the Sec-
retary determines that the United States has no sig-
nificant tax interest in obtaining the required infor-
mation.’’.
(b) INCREASED PENALTIES.—Section 6677 (relating to
failure to file information returns with respect to certain
foreign trusts) is amended to read as follows:
‘‘SEC. 6677. FAILURE TO FILE INFORMATION WITH RESPECT
TO CERTAIN FOREIGN TRUSTS.
‘‘(a) CIVIL PENALTY.—In addition to any criminal
penalty provided by law, if any notice or return required
to be filed by section 6048—
‘‘(1) is not filed on or before the time provided
in such section, or
‘‘(2) does not include all the information re-
quired pursuant to such section or includes incorrect
information,
the person required to file such notice or return shall pay
a penalty equal to 35 percent of the gross reportable
amount. If any failure described in the preceding sentence
continues for more than 90 days after the day on which
the Secretary mails notice of such failure to the person re-
quired to pay such penalty, such person shall pay a penalty
(in addition to the amount determined under the preceding
sentence) of $10,000 for each 30-day period (or fraction
thereof) during which such failure continues after the expi-
ration of such 90-day period. In no event shall the penalty
under this subsection with respect to any failure exceed the
gross reportable amount.
‘‘(b) SPECIAL RULES FOR RETURNS UNDER SECTION
6048(b).—In the case of a return required under section
6048(b)—
‘‘(1) the United States person referred to in such
section shall be liable for the penalty imposed by sub-
section (a), and
‘‘(2) subsection (a) shall be applied by substitut-
ing ‘5 percent’ for ‘35 percent’.
‘‘(c) GROSS REPORTABLE AMOUNT.—For purposes of
subsection (a), the term ‘gross reportable amount’ means—
‘‘(1) the gross value of the property involved in
the event (determined as of the date of the event) in
the case of a failure relating to section 6048(a),
‘‘(2) the gross value of the portion of the trust’s
assets at the close of the year treated as owned by the
United States person in the case of a failure relating
to section 6048(b)(1), and
‘‘(3) the gross amount of the distributions in the
case of a failure relating to section 6048(c).
‘‘(d) 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.
‘‘(e) DEFICIENCY PROCEDURES NOT TO APPLY.—Sub-
chapter B of chapter 63 (relating to deficiency procedures
for income, estate, gift, and certain excise taxes) shall not
apply in respect of the assessment or collection of any pen-
alty imposed by subsection (a).’’.
(c) CONFORMING AMENDMENTS.—
(1) Paragraph (2) of section 6724(d) is amended
by striking ‘‘or’’ at the end of subparagraph (S), by
striking the period at the end of subparagraph (T)
and inserting ‘‘, or’’, and by inserting after subpara-
graph (T) the following new subparagraph:
‘‘(U) section 6048(b)(1)(B) (relating to for-
eign trust reporting requirements).’’.
(2) The table of sections for subpart B of part
III of subchapter A of chapter 61 is amended by strik-
ing the item relating to section 6048 and inserting
the following new item:
‘‘Sec. 6048. Information with respect to certain foreign trusts.’’.
(3) The table of sections for part I of subchapter
B of chapter 68 is amended by striking the item relat-
ing to section 6677 and inserting the following new
item:
‘‘Sec. 6677. Failure to file information with respect to certain for-
eign trusts.’’.
(d) EFFECTIVE DATES.—
(1) REPORTABLE EVENTS.—To the extent related
to subsection (a) of section 6048 of the Internal Reve-
nue Code of 1986, as amended by this section, the
amendments made by this section shall apply to re-
portable events (as defined in such section 6048) oc-
curring after the date of the enactment of this Act.
(2) GRANTOR TRUST REPORTING.—To the extent
related to subsection (b) of such section 6048, the
amendments made by this section shall apply to tax-
able years of United States persons beginning after
December 31, 1995.
(3) REPORTING
BY
UNITED
STATES
BENE-
FICIARIES.—To the extent related to subsection (c) of
such section 6048, the amendments made by this sec-
tion shall apply to distributions received after the
date of the enactment of this Act.
SEC. 412. COMPARABLE PENALTIES FOR FAILURE TO FILE
RETURN RELATING TO TRANSFERS TO FOR-
EIGN ENTITIES.
(a) IN GENERAL.—Section 1494 is amended by adding
at the end the following new subsection:
‘‘(c) PENALTY.—In the case of any failure to file a re-
turn required by the Secretary with respect to any transfer
described in section 1491, the person required to file such
return shall be liable for the penalties provided in section
6677 in the same manner as if such failure were a failure
to file a notice under section 6048(a).’’.
(b) EFFECTIVE DATE.—The amendment made by sub-
section (a) shall apply to transfers after the date of the en-
actment of this Act.
SEC. 413. MODIFICATIONS OF RULES RELATING TO FOR-
EIGN TRUSTS HAVING ONE OR MORE UNITED
STATES BENEFICIARIES.
(a) TREATMENT OF TRUST OBLIGATIONS, ETC.—
(1) Paragraph (2) of section 679(a) is amended
by striking subparagraph (B) and inserting the fol-
lowing:
‘‘(B) 
TRANSFERS
AT
FAIR
MARKET
VALUE.—To any transfer of property to a trust
in exchange for consideration of at least the fair
market value of the transferred property. For
purposes of the preceding sentence, consideration
other than cash shall be taken into account at its
fair market value.’’.
(2) Subsection (a) of section 679 (relating to for-
eign trusts having one or more United States bene-
ficiaries) is amended by adding at the end the follow-
ing new paragraph:
‘‘(3) CERTAIN OBLIGATIONS NOT TAKEN INTO AC-
COUNT UNDER FAIR MARKET VALUE EXCEPTION.—
‘‘(A) IN GENERAL.—In determining whether
paragraph (2)(B) applies to any transfer by a
person described in clause (ii) or (iii) of sub-
paragraph (C), there shall not be taken into ac-
count—
‘‘(i) except as provided in regulations,
any obligation of a person described in sub-
paragraph (C), and
‘‘(ii) to the extent provided in regula-
tions, any obligation which is guaranteed
by a person described in subparagraph (C).
‘‘(B) TREATMENT OF PRINCIPAL PAYMENTS
ON
OBLIGATION.—Principal payments by the
trust on any obligation referred to in subpara-
graph (A) shall be taken into account on and
after the date of the payment in determining the
portion of the trust attributable to the property
transferred.
‘‘(C) PERSONS
DESCRIBED.—The persons
described in this subparagraph are—
‘‘(i) the trust,
‘‘(ii) any grantor or beneficiary of the
trust, and
‘‘(iii) any person who is related (with-
in the meaning of section 643(i)(2)(B)) to
any grantor or beneficiary of the trust.’’.
(b) EXEMPTION
OF
TRANSFERS
TO
CHARITABLE
TRUSTS.—Subsection (a) of section 679 is amended by
striking ‘‘section 404(a)(4) or 404A’’ and inserting ‘‘section
6048(a)(3)(B)(ii)’’.
(c) OTHER MODIFICATIONS.—Subsection (a) of section
679 is amended by adding at the end the following new
paragraphs:
‘‘(4) SPECIAL RULES APPLICABLE TO FOREIGN
GRANTOR WHO LATER BECOMES A UNITED STATES
PERSON.—
‘‘(A) IN GENERAL.—If a nonresident alien
individual has a residency starting date within
5 years after directly or indirectly transferring
property to a foreign trust, this section and sec-
tion 6048 shall be applied as if such individual
transferred to such trust on the residency start-
ing date an amount equal to the portion of such
trust attributable to the property transferred by
such individual to such trust in such transfer.
‘‘(B) TREATMENT
OF
UNDISTRIBUTED
IN-
COME.—For purposes of this section, undistrib-
uted net income for periods before such individ-
ual’s residency starting date shall be taken into
account in determining the portion of the trust
which is attributable to property transferred by
such individual to such trust but shall not other-
wise be taken into account.
‘‘(C) RESIDENCY
STARTING
DATE.—For
purposes of this paragraph, an individual’s resi-
dency starting date is the residency starting date
determined under section 7701(b)(2)(A).
‘‘(5) OUTBOUND TRUST MIGRATIONS.—If—
‘‘(A) an individual who is a citizen or resi-
dent of the United States transferred property to
a trust which was not a foreign trust, and
‘‘(B) such trust becomes a foreign trust
while such individual is alive,
then this section and section 6048 shall be applied as
if such individual transferred to such trust on the
date such trust becomes a foreign trust an amount
equal to the portion of such trust attributable to the
property previously transferred by such individual to
such trust. A rule similar to the rule of paragraph
(4)(B) shall apply for purposes of this paragraph.’’.
(d) MODIFICATIONS RELATING TO WHETHER TRUST
HAS UNITED STATES BENEFICIARIES.—Subsection (c) of
section 679 is amended by adding at the end the following
new paragraph:
‘‘(3) CERTAIN
UNITED
STATES
BENEFICIARIES
DISREGARDED.—A beneficiary shall not be treated as
a United States person in applying this section with
respect to any transfer of property to foreign trust if
such beneficiary first became a United States person
more than 5 years after the date of such transfer.’’.
(e) TECHNICAL AMENDMENT.—Subparagraph (A) of
section 679(c)(2) is amended to read as follows:
‘‘(A) in the case of a foreign corporation,
such corporation is a controlled foreign corpora-
tion (as defined in section 957(a)),’’.
(f) REGULATIONS.—Section 679 is amended by adding
at the end the following new subsection:
‘‘(d) REGULATIONS.—The Secretary shall prescribe
such regulations as may be necessary or appropriate to
carry out the purposes of this section.’’.
(g) EFFECTIVE DATE.—The amendments made by this
section shall apply to transfers of property after February
6, 1995.
SEC. 414. FOREIGN PERSONS NOT TO BE TREATED AS OWN-
ERS UNDER GRANTOR TRUST RULES.
(a) GENERAL RULE.—
(1) Subsection (f) of section 672 (relating to spe-
cial rule where grantor is foreign person) is amended
to read as follows:
‘‘(f) SUBPART NOT TO RESULT IN FOREIGN OWNER-
SHIP.—
‘‘(1) IN GENERAL.—Notwithstanding any other
provision of this subpart, this subpart shall apply
only to the extent such application results in an
amount (if any) being currently taken into account
(directly or through 1 or more entities) under this
chapter in computing the income of a citizen or resi-
dent of the United States or a domestic corporation.
‘‘(2) EXCEPTIONS.—
‘‘(A) CERTAIN
REVOCABLE
AND
IRREV-
OCABLE
TRUSTS.—Paragraph (1) shall not
apply to any portion of a trust if—
‘‘(i) the power to revest absolutely in
the grantor title to the trust property to
which such portion is attributable is exer-
cisable solely by the grantor without the ap-
proval or consent of any other person or
with the consent of a related or subordinate
party who is subservient to the grantor, or
‘‘(ii) the only amounts distributable
from such portion (whether income or cor-
pus) during the lifetime of the grantor are
amounts distributable to the grantor or the
spouse of the grantor.
‘‘(B) COMPENSATORY
TRUSTS.—Except as
provided in regulations, paragraph (1) shall not
apply to any portion of a trust distributions
from which are taxable as compensation for serv-
ices rendered.
‘‘(3) SPECIAL RULES.—Except as otherwise pro-
vided in regulations prescribed by the Secretary—
‘‘(A) a controlled foreign corporation (as de-
fined in section 957) shall be treated as a domes-
tic corporation for purposes of paragraph (1),
and
‘‘(B) paragraph (1) shall not apply for pur-
poses of applying section 1296.
‘‘(4) 
RECHARACTERIZATION
OF
PURPORTED
GIFTS.—In the case of any transfer directly or indi-
rectly from a partnership or foreign corporation
which the transferee treats as a gift or bequest, the
Secretary may recharacterize such transfer in such
circumstances as the Secretary determines to be ap-
propriate to prevent the avoidance of the purposes of
this subsection.
‘‘(5) SPECIAL RULE WHERE GRANTOR IS FOR-
EIGN PERSON.—If—
‘‘(A) but for this subsection, a foreign per-
son would be treated as the owner of any portion
of a trust, and
‘‘(B) such trust has a beneficiary who is a
United States person,
such beneficiary shall be treated as the grantor of
such portion to the extent such beneficiary or any
member of such beneficiary’s family (within the
meaning of section 267(c)(4)) has made (directly or
indirectly) transfers of property (other than in a sale
for full and adequate consideration) to such foreign
person. For purposes of the preceding sentence, any
gift shall not be taken into account to the extent such
gift would be excluded from taxable gifts under section
2503(b).
‘‘(6) REGULATIONS.—The Secretary shall pre-
scribe such regulations as may be necessary or appro-
priate to carry out the purposes of this subsection, in-
cluding regulations providing that paragraph (1)
shall not apply in appropriate cases.’’.
(2) The last sentence of subsection (c) of section
672 of such Code is amended by inserting ‘‘subsection
(f) and’’ before ‘‘sections 674’’.
(b) CREDIT FOR CERTAIN TAXES.—
(1) Paragraph (2) of section 665(d) is amended
by adding at the end the following new sentence:
‘‘Under rules or regulations prescribed by the Sec-
retary, in the case of any foreign trust of which the
settlor or another person would be treated as owner
of any portion of the trust under subpart E but for
section 672(f), the term ‘taxes imposed on the trust’
includes the allocable amount of any income, war
profits, and excess profits taxes imposed by any for-
eign country or possession of the United States on the
settlor or such other person in respect of trust in-
come.’’.
(2) Paragraph (5) of section 901(b) is amended
by adding at the end the following new sentence:
‘‘Under rules or regulations prescribed by the Sec-
retary, in the case of any foreign trust of which the
settlor or another person would be treated as owner
of any portion of the trust under subpart E but for
section 672(f), the allocable amount of any income,
war profits, and excess profits taxes imposed by any
foreign country or possession of the United States on
the settlor or such other person in respect of trust in-
come.’’.
(c) DISTRIBUTIONS
BY CERTAIN FOREIGN TRUSTS
THROUGH NOMINEES.—
(1) Section 643 is amended by adding at the end
the following new subsection:
‘‘(h) DISTRIBUTIONS BY CERTAIN FOREIGN TRUSTS
THROUGH NOMINEES.—For purposes of this part, any
amount paid to a United States person which is derived
directly or indirectly from a foreign trust of which the
payor is not the grantor shall be deemed in the year of pay-
ment to have been directly paid by the foreign trust to such
United States person.’’.
(2) Section 665 is amended by striking sub-
section (c).
(d) EFFECTIVE DATE.—
(1) IN GENERAL.—Except as provided by para-
graph (2), the amendments made by this section shall
take effect on the date of the enactment of this Act.
(2) EXCEPTION
FOR
CERTAIN
TRUSTS.—The
amendments made by this section shall not apply to
any trust—
(A) which is treated as owned by the grant-
or under section 676 or 677 (other than sub-
section (a)(3) thereof) of the Internal Revenue
Code of 1986, and
(B) which is in existence on September 19,
1995.
The preceding sentence shall not apply to the portion
of any such trust attributable to any transfer to such
trust after September 19, 1995.
(e) TRANSITIONAL RULE.—If—
(1) by reason of the amendments made by this
section, any person other than a United States person
ceases to be treated as the owner of a portion of a do-
mestic trust, and
(2) before January 1, 1997, such trust becomes
a foreign trust, or the assets of such trust are trans-
ferred to a foreign trust,
no tax shall be imposed by section 1491 of the Internal Rev-
enue Code of 1986 by reason of such trust becoming a for-
eign trust or the assets of such trust being transferred to
a foreign trust.
SEC. 415. INFORMATION REPORTING REGARDING FOREIGN
GIFTS.
(a) IN GENERAL.—Subpart A of part III of subchapter
A of chapter 61 is amended by inserting after section 6039E
the following new section:
‘‘SEC. 6039F. NOTICE OF LARGE GIFTS RECEIVED FROM
FOREIGN PERSONS.
‘‘(a) IN GENERAL.—If the value of the aggregate for-
eign gifts received by a United States person (other than
an organization described in section 501(c) and exempt
from tax under section 501(a)) during any taxable year ex-
ceeds $10,000, such United States person shall furnish (at
such time and in such manner as the Secretary shall pre-