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‘‘(4) CERTIFIED PROFESSIONAL EMPLOYER OR-
GANIZATIONS.—The fee charged under the program 
in connection with the certification by the Secretary 
of a professional employer organization under sec-
tion 7705 shall be an annual fee not to exceed 
$1,000 per year.’’. 
(g) EFFECTIVE DATES.— 
(1) IN GENERAL.—The amendments made by 
this section shall apply with respect to wages for 
services performed on or after January 1 of the first 
calendar year beginning more than 12 months after 
the date of the enactment of this Act. 
(2) CERTIFICATION PROGRAM.—The Secretary 
of the Treasury shall establish the certification pro-
gram described in section 7705(b) of the Internal 
Revenue Code of 1986, as added by subsection (b), 
not later than 6 months before the effective date de-
termined under paragraph (1). 
(h) NO INFERENCE.—Nothing contained in this sec-
tion or the amendments made by this section shall be con-
strued to create any inference with respect to the deter-
mination of who is an employee or employer— 
(1) for Federal tax purposes (other than the 
purposes set forth in the amendments made by this 
section), or 
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(2) for purposes of any other provision of law. 
SEC. 207. EXCLUSION OF DIVIDENDS FROM CONTROLLED 
FOREIGN CORPORATIONS FROM THE DEFINI-
TION OF PERSONAL HOLDING COMPANY IN-
COME FOR PURPOSES OF THE PERSONAL 
HOLDING COMPANY RULES. 
(a) IN GENERAL.—Section 543(a)(1) is amended— 
(1) by redesignating subparagraphs (C) and 
(D) as subparagraphs (D) and (E), respectively, and 
(2) by inserting after subparagraph (B) the fol-
lowing: 
‘‘(C) dividends received by a United States 
shareholder (as defined in section 951(b)) from 
a controlled foreign corporation (as defined in 
section 957(a)),’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this Act shall apply to taxable years ending on or after 
the date of the enactment of this Act. 
SEC. 208. INFLATION ADJUSTMENT FOR CERTAIN CIVIL 
PENALTIES UNDER THE INTERNAL REVENUE 
CODE OF 1986. 
(a) FAILURE TO FILE TAX RETURN OR PAY TAX.— 
Section 6651 is amended by adding at the end the fol-
lowing new subsection: 
‘‘(i) ADJUSTMENT FOR INFLATION.— 
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‘‘(1) IN GENERAL.—In the case of any return 
required to be filed in a calendar year beginning 
after 2014, the $135 dollar amount under subsection 
(a) shall be increased by such dollar amount multi-
plied by the cost-of-living adjustment determined 
under section 1(f)(3) determined by substituting 
‘calendar year 2013’ for ‘calendar year 1992’ in sub-
paragraph (B) thereof. 
‘‘(2) ROUNDING.—If any amount adjusted 
under paragraph (1) is not a multiple of $5, such 
amount shall be rounded to the next lowest multiple 
of $5.’’. 
(b) FAILURE TO FILE CERTAIN INFORMATION RE-
TURNS, REGISTRATION STATEMENTS, ETC.— 
(1) IN GENERAL.—Section 6652(c) is amended 
by adding at the end the following new paragraph: 
‘‘(6) ADJUSTMENT FOR INFLATION.— 
‘‘(A) IN
GENERAL.—In the case of any 
failure relating to a return required to be filed 
in a calendar year beginning after 2014, each 
of the dollar amounts under paragraphs (1), 
(2), and (3) shall be increased by such dollar 
amount multiplied by the cost-of-living adjust-
ment determined under section 1(f)(3) deter-
mined by substituting ‘calendar year 2013’ for 
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‘calendar year 1992’ in subparagraph (B) 
thereof. 
‘‘(B) ROUNDING.—If any amount adjusted 
under subparagraph (A)— 
‘‘(i) is not less than $5,000 and is not 
a multiple of $500, such amount shall be 
rounded to the next lowest multiple of 
$500, and 
‘‘(ii) is not described in clause (i) and 
is not a multiple of $5, such amount shall 
be rounded to the next lowest multiple of 
$5.’’. 
(2) CONFORMING AMENDMENTS.— 
(A) 
The 
last 
sentence 
of 
section 
6652(c)(1)(A) is amended by striking ‘‘the first 
sentence of this subparagraph shall be applied 
by substituting ‘$100’ for ‘$20’ and’’ and in-
serting ‘‘in applying the first sentence of this 
subparagraph, the amount of the penalty for 
each day during which a failure continues shall 
be $100 in lieu of the amount otherwise speci-
fied, and’’. 
(B) Section 6652(c)(2)(C)(ii) is amended 
by striking ‘‘the first sentence of paragraph 
(1)(A)’’ and all that follows and inserting ‘‘in 
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applying the first sentence of paragraph (1)(A), 
the amount of the penalty for each day during 
which a failure continues shall be $100 in lieu 
of the amount otherwise specified, and in lieu of 
applying the second sentence of paragraph 
(1)(A), the maximum penalty under paragraph 
(1)(A) shall not exceed $50,000, and’’. 
(c) OTHER ASSESSABLE PENALTIES WITH RESPECT 
TO THE PREPARATION OF TAX RETURNS FOR OTHER 
PERSONS.—Section 6695 is amended by adding at the end 
the following new subsection: 
‘‘(h) ADJUSTMENT FOR INFLATION.— 
‘‘(1) IN GENERAL.—In the case of any failure 
relating to a return or claim for refund filed in a 
calendar year beginning after 2014, each of the dol-
lar amounts under subsections (a), (b), (c), (d), (e), 
(f), and (g) shall be increased by such dollar amount 
multiplied by the cost-of-living adjustment deter-
mined under section 1(f)(3) determined by sub-
stituting ‘calendar year 2013’ for ‘calendar year 
1992’ in subparagraph (B) thereof. 
‘‘(2) ROUNDING.—If any amount adjusted 
under subparagraph (A)— 
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‘‘(A) is not less than $5,000 and is not a 
multiple of $500, such amount shall be rounded 
to the next lowest multiple of $500, and 
‘‘(B) is not described in clause (i) and is 
not a multiple of $5, such amount shall be 
rounded to the next lowest multiple of $5.’’. 
(d) FAILURE TO FILE PARTNERSHIP RETURN.—Sec-
tion 6698 is amended by adding at the end the following 
new subsection: 
‘‘(e) ADJUSTMENT FOR INFLATION.— 
‘‘(1) IN GENERAL.—In the case of any return 
required to be filed in a calendar year beginning 
after 2014, the $195 dollar amount under subsection 
(b)(1) shall be increased by such dollar amount mul-
tiplied by the cost-of-living adjustment determined 
under section 1(f)(3) determined by substituting 
‘calendar year 2013’ for ‘calendar year 1992’ in sub-
paragraph (B) thereof. 
‘‘(2) ROUNDING.—If any amount adjusted 
under paragraph (1) is not a multiple of $5, such 
amount shall be rounded to the next lowest multiple 
of $5.’’. 
(e) FAILURE TO FILE S CORPORATION RETURN.— 
Section 6699 is amended by adding at the end the fol-
lowing new subsection: 
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