349(a) of the Immigration and Nationality Act (8
U.S.C. 1481(a)(1)–(4)),
‘‘(3) the issuance by the United States Depart-
ment of State of a certificate of loss of nationality to
the individual, or
‘‘(4) the cancellation by a court of the United
States of a naturalized citizen’s certificate of natu-
ralization.
‘‘(d) PENALTY.—Any individual failing to provide a
statement required under subsection (a) shall be subject to
a penalty for each year (of the 10-year period beginning
on the date of loss of United States citizenship) during any
portion of which such failure continues in an amount equal
to the greater of—
‘‘(1) 5 percent of the tax required to be paid
under section 877 for the taxable year ending during
such year, or
‘‘(2) $1,000,
unless it is shown that such failure is due to reasonable
cause and not to willful neglect.
‘‘(e) INFORMATION
TO
BE
PROVIDED
TO
SEC-
RETARY.—Notwithstanding any other provision of law—
‘‘(1) any Federal agency or court which collects
(or is required to collect) the statement under sub-
section (a) shall provide to the Secretary—
‘‘(A) a copy of any such statement, and
‘‘(B) the name (and any other identifying
information) of any individual refusing to com-
ply with the provisions of subsection (a),
‘‘(2) the Secretary of State shall provide to the
Secretary a copy of each certificate as to the loss of
American nationality under section 358 of the Immi-
gration and Nationality Act which is approved by the
Secretary of State, and
‘‘(3) the Federal agency primarily responsible for
administering the immigration laws shall provide to
the Secretary the name of each lawful permanent resi-
dent of the United States (within the meaning of sec-
tion 7701(b)(6)) whose status as such has been re-
voked or has been administratively or judicially de-
termined to have been abandoned.
Notwithstanding any other provision of law, not later than
30 days after the close of each calendar quarter, the Sec-
retary shall publish in the Federal Register the name of
each individual losing United States citizenship (within the
meaning of section 877(a)) with respect to whom the Sec-
retary receives information under the preceding sentence
during such quarter.
‘‘(f) REPORTING BY LONG-TERM LAWFUL PERMANENT
RESIDENTS WHO CEASE TO BE TAXED AS RESIDENTS.—
In lieu of applying the last sentence of subsection (a), any
individual who is required to provide a statement under
this section by reason of section 877(e)(1) shall provide such
statement with the return of tax imposed by chapter 1 for
the taxable year during which the event described in such
section occurs.
‘‘(g) EXEMPTION.—The Secretary may by regulations
exempt any class of individuals from the requirements of
this section if he determines that applying this section to
such individuals is not necessary to carry out the purposes
of this section.’’
(b) CLERICAL AMENDMENT.—The table of sections for
such subpart A is amended by inserting after the item relat-
ing to section 6039E the following new item:
‘‘Sec. 6039F. Information on individuals losing United States citi-
zenship.’’
(c) EFFECTIVE DATE.—The amendments made by this
section shall apply to—
(1) individuals losing United States citizenship
(within the meaning of section 877 of the Internal
Revenue Code of 1986) after the date of the enactment
of this Act, and
(2) long-term residents of the United States with
respect to whom an event described in subparagraph
(A) or (B) of section 877(e)(1) of such Code occurs
after such date.
SEC. 4. REPORT ON TAX COMPLIANCE BY UNITED STATES
CITIZENS AND RESIDENTS LIVING ABROAD.
Not later than 90 days after the date of the enactment
of this Act, the Secretary of the Treasury shall prepare and
submit to the Committee on Ways and Means of the House
of Representatives and the Committee on Finance of the
Senate a report—
(1) describing the compliance with subtitle A of
the Internal Revenue Code of 1986 by citizens and
lawful permanent residents of the United States
(within the meaning of section 7701(b)(6) of such
Code) residing outside the United States, and
(2) recommending measures to improve such
compliance (including improved coordination between
executive branch agencies).
HR 1812 RH——2