(ii) either— 
(I) owns, directly or indirectly, at 
least $1,000,000 of assets in the 
United States, or 
(II) has, for the most recent cal-
endar year, at least $1,000,000 of in-
come from sources within the United 
States, 
(B) is an entity that— 
(i) is organized in, or a tax resident 
of, a foreign country (including any sub-
division 
thereof) 
to 
which 
section 
901(j)(2)(C) of such Code applies, 
(ii) is not a controlled foreign corpora-
tion (as defined in section 957 of such 
Code), and 
(iii) has provided or sold goods or 
services to a government (including any in-
strumentality thereof) to which section 
901(j)(2)(C) of such Code applies, 
(C) is an executive, board member, or offi-
cer of an entity described in subparagraph (B), 
or 
(D) is a person that is related to any other 
person to which this section applies. 
VerDate Sep 11 2014 
19:31 Jun 15, 2022
Jkt 029200
PO 00000
Frm 00011
Fmt 6652
Sfmt 6201
E:\BILLS\H7901.IH
H7901
pamtmann on DSKBC07HB2PROD with BILLS
(3) SPECIAL RULES FOR CONTROLLED ENTI-
TIES.—Under regulations provided by the Sec-
retary— 
(A) IN
GENERAL.—The Secretary may 
treat a person controlled (within the meaning of 
section 954(d)(3) of the Internal Revenue Code 
of 1986) by a person described in paragraph 
(1) as a person to whom this section applies 
without regard to whether such controlled per-
son has been identified by the Secretary under 
paragraph (1)(C). 
(B) NOTIFICATION.— 
(i) IN GENERAL.—The Secretary may 
require any person treated as a person to 
whom this section applies by reason of sub-
paragraph (A) to provide notice to the Sec-
retary and to each withholding agent of 
such person that this section applies to 
such person. 
(ii) PENALTIES.—For purposes of ap-
plying part II of subchapter B of chapter 
68 of the Internal Revenue Code of 
1986— 
(I) any notice required to be pro-
vided to the Secretary under clause (i) 
VerDate Sep 11 2014 
19:31 Jun 15, 2022
Jkt 029200
PO 00000
Frm 00012
Fmt 6652
Sfmt 6201
E:\BILLS\H7901.IH
H7901
pamtmann on DSKBC07HB2PROD with BILLS
shall be treated as an information re-
turn described in section 6724(d)(1) 
of such Code, and 
(II) any notice required to be 
provided to a withholding agent under 
clause (i) shall be treated as a payee 
statement 
described 
in 
section 
6724(d)(2) of such Code. 
(c) PERIOD FOR WHICH THIS SECTION APPLIES.— 
For purposes of this section— 
(1) IN GENERAL.—This section applies to any 
person described in subsection (b) during the pe-
riod— 
(A) except as provided in paragraph (2), 
beginning on the date that is 30 days after the 
later of— 
(i) the date of the enactment of this 
Act, or 
(ii) the date such person is first de-
scribed in subsection (b), and 
(B) ending on the date such person is no 
longer described in subsection (b). 
(2) SPECIAL
RULES
FOR
PORTFOLIO
INTER-
EST.— 
VerDate Sep 11 2014 
19:31 Jun 15, 2022
Jkt 029200
PO 00000
Frm 00013
Fmt 6652
Sfmt 6201
E:\BILLS\H7901.IH
H7901
pamtmann on DSKBC07HB2PROD with BILLS
(A) IN GENERAL.—For purposes of apply-
ing subsection (a)(4), except as provided in sub-
paragraph (B), the period described in para-
graph (1) shall begin on the later of— 
(i) the date that is 180 days (60 days 
in the case of obligations issued on or after 
the date of the enactment of this Act) 
after the date of enactment of this Act, or 
(ii) 60 days after the date such person 
first becomes described in subsection (b). 
(B) 
SIGNIFICANT
MODIFICATIONS.—If, 
after the date of the enactment of this Act, 
there is a significant modification of an obliga-
tion issued before the date of the enactment of 
this Act, then, for purposes of applying sub-
section (a)(4), the period described in para-
graph (1) shall begin on the later of— 
(i) the earlier of— 
(I) the day that is 60 days after 
the date of such significant modifica-
tion, or 
(II) the day that is 180 days 
after the date of the enactment of this 
Act, or 
VerDate Sep 11 2014 
19:31 Jun 15, 2022
Jkt 029200
PO 00000
Frm 00014
Fmt 6652
Sfmt 6201
E:\BILLS\H7901.IH
H7901
pamtmann on DSKBC07HB2PROD with BILLS
(ii) the date that is 60 days after the 
date such person first becomes described in 
subsection (b). 
(d) DEFINITIONS.—For purposes of this section— 
(1) SECRETARY.—The term ‘‘Secretary’’ means 
the Secretary of the Treasury. 
(2) RELATED.—A person (hereinafter in this 
paragraph referred to as the ‘‘related person’’) is re-
lated to any person if— 
(A) the related person bears a relationship 
to such person which is— 
(i) specified in section 267(b) or 
707(b)(1) of the Internal Revenue Code of 
1986, or 
(ii) specified in the regulations pre-
scribed under subsection (f), or 
(B) the related person and such person are 
engaged in trades or businesses under common 
control (within the meaning of subsections (a) 
and (b) of section 52 of such Code, determined 
after the application of the rules of section 
2(c)(2)(B)(i)). 
(e) REPORTS.—Not later than 1 year after the date 
of the enactment of this Act, and annually thereafter, the 
Secretary shall submit to Congress a report detailing the 
VerDate Sep 11 2014 
19:31 Jun 15, 2022
Jkt 029200
PO 00000
Frm 00015
Fmt 6652
Sfmt 6201
E:\BILLS\H7901.IH
H7901
pamtmann on DSKBC07HB2PROD with BILLS