(1) by inserting ‘‘, as in effect on January 1, 
2017’’ after ‘‘(as defined in section 1471(d)(5)’’; 
and 
(2) by striking ‘‘or 1474(a)’’. 
(c) CONFORMING AMENDMENT RELATED TO SUB-
STITUTE DIVIDENDS.—Section 871(m) of such Code is 
amended by striking ‘‘chapters 3 and 4’’ both places it 
appears and inserting ‘‘chapter 3’’. 
(d) OTHER CONFORMING AMENDMENTS.— 
(1) Section 6414 of such Code is amended by 
striking ‘‘or 4’’. 
(2) Paragraph (1) of section 6501(b) of such 
Code is amended by striking ‘‘4,’’. 
(3) Paragraph (2) of section 6501(b) of such 
Code is amended— 
(A) by striking ‘‘4,’’; and 
(B) by striking ‘‘AND WITHOLDING TAXES’’ 
in the heading and inserting ‘‘TAXES AND TAX 
IMPOSED BY CHAPTER 3’’. 
(4) Paragraph (3) of section 6513(b) of such 
Code is amended— 
(A) by striking ‘‘or 4’’; and 
(B) by striking ‘‘or 1474(b)’’. 
(5) Section 6513(c) of such Code is amended by 
striking ‘‘4,’’. 
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(6) Section 6611(e)(4) of the Internal Revenue 
Code of 1986 is amended by striking ‘‘or 4’’. 
(7) Paragraph (1) of section 6724(d) of such 
Code is amended by striking ‘‘under chapter 4 or’’. 
(8) Paragraph (2) of section 6724(d) of such 
Code is amended by striking ‘‘or 4’’. 
(e) EFFECTIVE DATE.—The amendments made by 
this section shall apply to payments made after the date 
of the enactment of this Act. 
SEC. 2. REPEAL OF INFORMATION REPORTING WITH RE-
SPECT TO FOREIGN FINANCIAL ASSETS. 
(a) IN GENERAL.—Subpart A of part III of sub-
chapter A of chapter 61 of the Internal Revenue Code of 
1986 is amended by striking section 6038D. 
(b) REPEAL OF MODIFICATION OF STATUTE OF LIM-
ITATIONS
FOR SIGNIFICANT OMISSION
OF INCOME
IN 
CONNECTION WITH FOREIGN ASSETS.— 
(1) Paragraph (1) of section 6501(e) of the In-
ternal Revenue Code of 1986 is amended by striking 
subparagraph (A) and by redesignating subpara-
graphs (B) and (C) as subparagraphs (A) and (B), 
respectively. 
(2) Subparagraph (A) of section 6501(e) of 
such Code, as redesignated by paragraph (1), is 
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amended by striking all that precedes clause (i) and 
inserting the following: 
‘‘(A) GENERAL
RULE.—If the taxpayer 
omits from gross income an amount properly 
included therein which is in excess of 25 per-
cent of the amount of gross income stated in 
the return, the tax may be assessed, or a pro-
ceeding in court for the collection of such tax 
may be begun without assessment, at any time 
within 6 years after the return was filed. For 
purposes of this subparagraph—’’. 
(3) Paragraph (2) of section 6229(c) of such 
Code is amended by striking ‘‘and such amount is 
described 
in 
clause 
(i) 
or 
(ii) 
of 
section 
6501(e)(1)(A)’’ and inserting ‘‘which is in excess of 
25 percent of the amount of gross income stated in 
its return’’. 
(4) Paragraph (8) of section 6501(c) is amend-
ed— 
(A) by striking ‘‘pursuant to an election 
under section 1295(b) or’’; 
(B) by striking ‘‘1298(f)’’; and 
(C) by striking ‘‘6038D,’’. 
(c) CLERICAL AMENDMENT.—The table of sections 
for subpart A of part III of subchapter A of chapter 61 
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of such Code is amended by striking the item related to 
section 6038D. 
(d) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section 
shall apply to taxable years ending after the date of 
the enactment of this Act. 
(2) RETURNS.—The amendments made by sub-
section (b) shall apply to returns filed after the date 
of the enactment of this Act. 
SEC. 3. REPEAL OF PENALTIES FOR UNDERPAYMENTS AT-
TRIBUTABLE TO UNDISCLOSED FOREIGN FI-
NANCIAL ASSETS. 
(a) IN GENERAL.—Section 6662 of the Internal Rev-
enue Code of 1986 is amended— 
(1) in subsection (b), by striking paragraph (7) 
and redesignating paragraph (8) as paragraph (7); 
and 
(2) by striking subsection (j) and redesignating 
subsection (k) as subsection (j). 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years ending after the 
date of the enactment of this Act. 
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SEC. 4. REPEAL OF REPORTING OF ACTIVITIES WITH RE-
SPECT TO PASSIVE FOREIGN INVESTMENT 
COMPANIES. 
(a) IN GENERAL.—Section 1298 of the Internal Rev-
enue Code of 1986 is amended by striking subsection (f) 
and by redesignating subsection (g) as subsection (f). 
(b) CONFORMING AMENDMENT.—Section 1291(e) of 
such Code is amended by striking ‘‘and (d)’’ and inserting 
‘‘, (d), and (f)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 5. REPEAL OF REPORTING REQUIREMENT FOR 
UNITED 
STATES 
OWNERS 
OF 
FOREIGN 
TRUSTS. 
(a) IN GENERAL.—Paragraph (1) of section 6048(b) 
is amended by striking ‘‘shall submit such information as 
the Secretary may prescribe with respect to such trust for 
such year and’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years ending after the 
date of the enactment of this Act. 
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