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plementing, or carrying out any reportable
transaction, and
‘‘(ii) who directly or indirectly derives
gross income in excess of the threshold
amount for such aid, assistance, or advice.
‘‘(B) THRESHOLD AMOUNT.—For purposes
of subparagraph (A), the threshold amount is—
‘‘(i) $50,000 in the case of a reportable
transaction substantially all of the tax bene-
fits from which are provided to natural per-
sons, and
‘‘(ii) $250,000 in any other case.
‘‘(2) REPORTABLE TRANSACTION.—The term ‘re-
portable transaction’ has the meaning given to such
term by section 6707A(c).
‘‘(c) REGULATIONS.—The Secretary may prescribe reg-
ulations which provide—
‘‘(1) that only 1 person shall be required to meet
the requirements of subsection (a) in cases in which
2 or more persons would otherwise be required to meet
such requirements,
‘‘(2) exemptions from the requirements of this
section, and
‘‘(3) such rules as may be necessary or appro-
priate to carry out the purposes of this section.’’.
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(b) CONFORMING AMENDMENTS.—
(1) The item relating to section 6111 in the table
of sections for subchapter B of chapter 61 is amended
to read as follows:
‘‘Sec. 6111. Disclosure of reportable transactions.’’.
(2)(A) So much of section 6112 as precedes sub-
section (c) thereof is amended to read as follows:
‘‘SEC. 6112. MATERIAL ADVISORS OF REPORTABLE TRANS-
ACTIONS MUST KEEP LISTS OF ADVISEES.
‘‘(a) IN GENERAL.—Each material advisor (as defined
in section 6111) with respect to any reportable transaction
(as defined in section 6707A(c)) shall maintain, in such
manner as the Secretary may by regulations prescribe, a
list—
‘‘(1) identifying each person with respect to
whom such advisor acted as such a material advisor
with respect to such transaction, and
‘‘(2) containing such other information as the
Secretary may by regulations require.
This section shall apply without regard to whether a mate-
rial advisor is required to file a return under section 6111
with respect to such transaction.’’.
(B) Section 6112 is amended by redesignating
subsection (c) as subsection (b).
(C) Section 6112(b), as redesignated by subpara-
graph (B), is amended—
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(i) by inserting ‘‘written’’ before ‘‘request’’
in paragraph (1)(A), and
(ii) by striking ‘‘shall prescribe’’ in para-
graph (2) and inserting ‘‘may prescribe’’.
(D) The item relating to section 6112 in the
table of sections for subchapter B of chapter 61 is
amended to read as follows:
‘‘Sec. 6112. Material advisors of reportable transactions must keep
lists of advisees.’’.
(3)(A) The heading for section 6708 is amended
to read as follows:
‘‘SEC. 6708. FAILURE TO MAINTAIN LISTS OF ADVISEES
WITH 
RESPECT 
TO 
REPORTABLE 
TRANS-
ACTIONS.’’.
(B) The item relating to section 6708 in the
table of sections for part I of subchapter B of chapter
68 is amended to read as follows:
‘‘Sec. 6708. Failure to maintain lists of advisees with respect to re-
portable transactions.’’.
(c) REQUIRED DISCLOSURE NOT SUBJECT TO CLAIM
OF
CONFIDENTIALITY.—Subparagraph (A) of section
6112(b)(1), as redesignated by subsection (b)(2)(B), is
amended by adding at the end the following new flush sen-
tence:
‘‘For purposes of this section, the identity of any per-
son on such list shall not be privileged.’’.
(d) EFFECTIVE DATE.—
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(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section shall
apply to transactions with respect to which material
aid, assistance, or advice referred to in section
6111(b)(1)(A)(i) of the Internal Revenue Code of 1986
(as added by this section) is provided after the date
of the enactment of this Act.
(2) NO CLAIM OF CONFIDENTIALITY AGAINST DIS-
CLOSURE.—The amendment made by subsection (c)
shall take effect as if included in the amendments
made by section 142 of the Deficit Reduction Act of
1984.
SEC. 606. MODIFICATIONS TO PENALTY FOR FAILURE TO
REGISTER TAX SHELTERS.
(a) IN GENERAL.—Section 6707 (relating to failure to
furnish information regarding tax shelters) is amended to
read as follows:
‘‘SEC. 6707. FAILURE TO FURNISH INFORMATION REGARD-
ING REPORTABLE TRANSACTIONS.
‘‘(a) IN GENERAL.—If a person who is required to file
a return under section 6111(a) with respect to any report-
able transaction—
‘‘(1) fails to file such return on or before the date
prescribed therefor, or
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‘‘(2) files false or incomplete information with
the Secretary with respect to such transaction,
such person shall pay a penalty with respect to such return
in the amount determined under subsection (b).
‘‘(b) AMOUNT OF PENALTY.—
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), the penalty imposed under subsection (a)
with respect to any failure shall be $50,000.
‘‘(2) LISTED TRANSACTIONS.—The penalty im-
posed under subsection (a) with respect to any listed
transaction shall be an amount equal to the greater
of—
‘‘(A) $200,000, or
‘‘(B) 50 percent of the gross income derived
by such person with respect to aid, assistance, or
advice which is provided with respect to the list-
ed transaction before the date the return includ-
ing the transaction is filed under section 6111.
Subparagraph (B) shall be applied by substituting
‘75 percent’ for ‘50 percent’ in the case of an inten-
tional failure or act described in subsection (a).
‘‘(c) CERTAIN RULES TO APPLY.—The provisions of
section 6707A(d) shall apply to any penalty imposed under
this section.
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‘‘(d) REPORTABLE AND LISTED TRANSACTIONS.—The
terms ‘reportable transaction’ and ‘listed transaction’ have
the respective meanings given to such terms by section
6707A(c).’’.
(b) CLERICAL AMENDMENT.—The item relating to sec-
tion 6707 in the table of sections for part I of subchapter
B of chapter 68 is amended by striking ‘‘tax shelters’’ and
inserting ‘‘reportable transactions’’.
(c) EFFECTIVE DATE.—The amendments made by this
section shall apply to returns the due date for which is after
the date of the enactment of this Act.
SEC. 607. MODIFICATION OF PENALTY FOR FAILURE TO
MAINTAIN LISTS OF INVESTORS.
(a) IN GENERAL.—Subsection (a) of section 6708 is
amended to read as follows:
‘‘(a) IMPOSITION OF PENALTY.—
‘‘(1) IN GENERAL.—If any person who is re-
quired to maintain a list under section 6112(a) fails
to make such list available upon written request to
the 
Secretary 
in 
accordance 
with 
section
6112(b)(1)(A) within 20 business days after the date
of the Secretary’s request, such person shall pay a
penalty of $10,000 for each day of such failure after
such 20th day.
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‘‘(2) REASONABLE CAUSE EXCEPTION.—No pen-
alty shall be imposed by paragraph (1) with respect
to the failure on any day if such failure is due to rea-
sonable cause.’’.
(b) EFFECTIVE DATE.—The amendment made by this
section shall apply to requests made after the date of the
enactment of this Act.
SEC. 608. MODIFICATION OF ACTIONS TO ENJOIN CERTAIN
CONDUCT RELATED TO TAX SHELTERS AND
REPORTABLE TRANSACTIONS.
(a) IN GENERAL.—Section 7408 (relating to action to
enjoin promoters of abusive tax shelters, etc.) is amended
by redesignating subsection (c) as subsection (d) and by
striking subsections (a) and (b) and inserting the following
new subsections:
‘‘(a) AUTHORITY TO SEEK INJUNCTION.—A civil ac-
tion in the name of the United States to enjoin any person
from further engaging in specified conduct may be com-
menced at the request of the Secretary. Any action under
this section shall be brought in the district court of the
United States for the district in which such person resides,
has his principal place of business, or has engaged in speci-
fied conduct. The court may exercise its jurisdiction over
such action (as provided in section 7402(a)) separate and
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apart from any other action brought by the United States
against such person.
‘‘(b) ADJUDICATION
AND DECREE.—In any action
under subsection (a), if the court finds—
‘‘(1) that the person has engaged in any specified
conduct, and
‘‘(2) that injunctive relief is appropriate to pre-
vent recurrence of such conduct,
the court may enjoin such person from engaging in such
conduct or in any other activity subject to penalty under
this title.
‘‘(c) SPECIFIED CONDUCT.—For purposes of this sec-
tion, the term ‘specified conduct’ means any action, or fail-
ure to take action, subject to penalty under section 6700,
6701, 6707, or 6708.’’.
(b) CONFORMING AMENDMENTS.—
(1) The heading for section 7408 is amended to
read as follows:
‘‘SEC. 7408. ACTIONS TO ENJOIN SPECIFIED CONDUCT RE-
LATED TO TAX SHELTERS AND REPORTABLE
TRANSACTIONS.’’.
(2) The table of sections for subchapter A of
chapter 67 is amended by striking the item relating
to section 7408 and inserting the following new item:
‘‘Sec. 7408. Actions to enjoin specified conduct related to tax shelters and re-
portable transactions.’’.
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(c) EFFECTIVE DATE.—The amendments made by this
section shall take effect on the day after the date of the en-
actment of this Act.
SEC. 609. UNDERSTATEMENT OF TAXPAYER’S LIABILITY BY
INCOME TAX RETURN PREPARER.
(a) STANDARDS CONFORMED TO TAXPAYER STAND-
ARDS.—Section 6694(a) (relating to understatements due to
unrealistic positions) is amended—
(1) by striking ‘‘realistic possibility of being sus-
tained on its merits’’ in paragraph (1) and inserting
‘‘reasonable belief that the tax treatment in such posi-
tion was more likely than not the proper treatment’’,
(2) by striking ‘‘or was frivolous’’ in paragraph
(3) and inserting ‘‘or there was no reasonable basis
for the tax treatment of such position’’, and
(3) by striking ‘‘UNREALISTIC’’ in the heading
and inserting ‘‘IMPROPER’’.
(b) 
AMOUNT
OF
PENALTY.—Section 
6694 
is
amended—
(1) by striking ‘‘$250’’ in subsection (a) and in-
serting ‘‘$1,000’’, and
(2) by striking ‘‘$1,000’’ in subsection (b) and
inserting ‘‘$5,000’’.
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(c) EFFECTIVE DATE.—The amendments made by this
section shall apply to documents prepared after the date
of the enactment of this Act.
SEC. 610. REGULATION OF INDIVIDUALS PRACTICING BE-
FORE THE DEPARTMENT OF TREASURY.
(a) CENSURE; IMPOSITION OF PENALTY.—
(1) IN
GENERAL.—Section 330(b) of title 31,
United States Code, is amended—
(A) by inserting ‘‘, or censure,’’ after ‘‘De-
partment’’, and
(B) by adding at the end the following new
flush sentence:
‘‘The Secretary may impose a monetary penalty on any
representative described in the preceding sentence. If the
representative was acting on behalf of an employer or any
firm or other entity in connection with the conduct giving
rise to such penalty, the Secretary may impose a monetary
penalty on such employer, firm, or entity if it knew, or
reasonably should have known, of such conduct. Such pen-
alty shall not exceed the gross income derived (or to be de-
rived) from the conduct giving rise to the penalty and may
be in addition to, or in lieu of, any suspension, disbarment,
or censure of the representative.’’.
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(2) EFFECTIVE DATE.—The amendments made
by this subsection shall apply to actions taken after
the date of the enactment of this Act.
(b) TAX SHELTER OPINIONS, ETC.—Section 330 of
such title 31 is amended by adding at the end the following
new subsection:
‘‘(d) Nothing in this section or in any other provision
of law shall be construed to limit the authority of the Sec-
retary of the Treasury to impose standards applicable to
the rendering of written advice with respect to any entity,
transaction plan or arrangement, or other plan or arrange-
ment, which is of a type which the Secretary determines
as having a potential for tax avoidance or evasion.’’.
SEC. 611. PENALTY ON PROMOTERS OF TAX SHELTERS.
(a) PENALTY ON PROMOTING ABUSIVE TAX SHEL-
TERS.—Section 6700(a) is amended by adding at the end
the following new sentence: ‘‘Notwithstanding the first sen-
tence, if an activity with respect to which a penalty im-
posed under this subsection involves a statement described
in paragraph (2)(A), the amount of the penalty shall be
equal to 50 percent of the gross income derived (or to be
derived) from such activity by the person on which the pen-
alty is imposed.’’.
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(b) EFFECTIVE DATE.—The amendment made by this
section shall apply to activities after the date of the enact-
ment of this Act.
SEC. 612. STATUTE OF LIMITATIONS FOR TAXABLE YEARS
FOR 
WHICH 
REQUIRED 
LISTED 
TRANS-
ACTIONS NOT REPORTED.
(a) IN GENERAL.—Section 6501(c) (relating to excep-
tions) is amended by adding at the end the following new
paragraph:
‘‘(10) LISTED
TRANSACTIONS.—If a taxpayer
fails to include on any return or statement for any
taxable year any information with respect to a listed
transaction (as defined in section 6707A(c)(2)) which
is required under section 6011 to be included with
such return or statement, the time for assessment of
any tax imposed by this title with respect to such
transaction shall not expire before the date which is
1 year after the earlier of—
‘‘(A) the date on which the Secretary is fur-
nished the information so required; or
‘‘(B) the date that a material advisor (as
defined in section 6111) meets the requirements
of section 6112 with respect to a request by the
Secretary under section 6112(b) relating to such
transaction with respect to such taxpayer.’’.
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SEC. 614. AUTHORIZATION OF APPROPRIATIONS FOR TAX
LAW ENFORCEMENT.
There is authorized to be appropriated $300,000,000
for each fiscal year beginning after September 30, 2003, for
the purpose of carrying out tax law enforcement to combat
tax avoidance transactions and other tax shelters, including
the use of offshore financial accounts to conceal taxable in-
come.
PART II—OTHER CORPORATE GOVERNANCE
PROVISIONS
SEC. 621. AFFIRMATION OF CONSOLIDATED RETURN REGU-
LATION AUTHORITY.
(a) IN GENERAL.—Section 1502 (relating to consoli-
dated return regulations) is amended by adding at the end
the following new sentence: ‘‘In prescribing such regula-
tions, the Secretary may prescribe rules applicable to cor-
porations filing consolidated returns under section 1501
that are different from other provisions of this title that
would apply if such corporations filed separate returns.’’.
(b) RESULT
NOT
OVERTURNED.—Notwithstanding
subsection (a), the Internal Revenue Code of 1986 shall be
construed by treating Treasury regulation § 1.1502–
20(c)(1)(iii) (as in effect on January 1, 2001) as being in-
applicable to the type of factual situation in 255 F.3d 1357
(Fed. Cir. 2001).
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(c) EFFECTIVE DATE.—The provisions of this section
shall apply to taxable years beginning before, on, or after
the date of the enactment of this Act.
SEC. 622. DECLARATION BY CHIEF EXECUTIVE OFFICER RE-
LATING TO FEDERAL ANNUAL INCOME TAX
RETURN OF A CORPORATION.
(a) IN GENERAL.—The Federal annual tax return of
a corporation with respect to income shall also include a
declaration signed by the chief executive officer of such cor-
poration (or other such officer of the corporation as the Sec-
retary of the Treasury may designate if the corporation does
not have a chief executive officer), under penalties of per-
jury, that the corporation has in place processes and proce-
dures to ensure that such return complies with the Internal
Revenue Code of 1986 and that the chief executive officer
was provided reasonable assurance of the accuracy of all
material aspects of such return. The preceding sentence
shall not apply to any return of a regulated investment
company (within the meaning of section 851 of such Code).
(b) EFFECTIVE DATE.—This section shall apply to the
Federal annual tax return of a corporation with respect to
income for taxable years ending after the date of the enact-
ment of this Act.
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SEC. 623. DENIAL OF DEDUCTION FOR CERTAIN FINES, PEN-
ALTIES, AND OTHER AMOUNTS.
(a) IN GENERAL.—Subsection (f) of section 162 (relat-
ing to trade or business expenses) is amended to read as
follows:
‘‘(f) FINES, PENALTIES, AND OTHER AMOUNTS.—
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), no deduction otherwise allowable shall be
allowed under this chapter for any amount paid or
incurred (whether by suit, agreement, or otherwise)
to, or at the direction of, a government or entity de-
scribed in paragraph (4) in relation to the violation
of any law or the investigation or inquiry by such
government or entity into the potential violation of
any law.
‘‘(2) EXCEPTION
FOR
AMOUNTS
CONSTITUTING
RESTITUTION.—Paragraph (1) shall not apply to any
amount which the taxpayer establishes constitutes res-
titution (including remediation of property) for dam-
age or harm caused by or which may be caused by
the violation of any law or the potential violation of
any law. This paragraph shall not apply to any
amount paid or incurred as reimbursement to the
government or entity for the costs of any investigation
or litigation.
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‘‘(3) EXCEPTION
FOR
AMOUNTS
PAID
OR
IN-
CURRED
AS
THE
RESULT
OF
CERTAIN
COURT
OR-
DERS.—Paragraph (1) shall not apply to any
amount paid or incurred by order of a court in a suit
in which no government or entity described in para-
graph (4) is a party.
‘‘(4) CERTAIN NONGOVERNMENTAL REGULATORY
ENTITIES.—An entity is described in this paragraph
if it is—
‘‘(A) a nongovernmental entity which exer-
cises self-regulatory powers (including imposing
sanctions) in connection with a qualified board
or exchange (as defined in section 1256(g)(7)), or
‘‘(B) to the extent provided in regulations,
a nongovernmental entity which exercises self-
regulatory powers (including imposing sanc-
tions) as part of performing an essential govern-
mental function.
‘‘(5) EXCEPTION FOR TAXES DUE.—Paragraph
(1) shall not apply to any amount paid or incurred
as taxes due.’’.
(b) EFFECTIVE DATE.—The amendment made by this
section shall apply to amounts paid or incurred after April
27, 2003, except that such amendment shall not apply to
amounts paid or incurred under any binding order or
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agreement entered into on or before April 27, 2003. Such
exception shall not apply to an order or agreement requir-
ing court approval unless the approval was obtained on or
before April 27, 2003.
SEC. 624. DISALLOWANCE OF DEDUCTION FOR PUNITIVE
DAMAGES.
(a) DISALLOWANCE OF DEDUCTION.—
(1) IN
GENERAL.—Section 162(g) (relating to
treble damage payments under the antitrust laws) is
amended by adding at the end the following new
paragraph:
‘‘(2) PUNITIVE DAMAGES.—No deduction shall be
allowed under this chapter for any amount paid or
incurred for punitive damages in connection with
any judgment in, or settlement of, any action. This
paragraph shall not apply to punitive damages de-
scribed in section 104(c).’’.
(2) CONFORMING AMENDMENTS.—
(A) Section 162(g) is amended—
(i) by striking ‘‘If’’ and inserting:
‘‘(1) TREBLE DAMAGES.—If’’, and
(ii) by redesignating paragraphs (1)
and (2) as subparagraphs (A) and (B), re-
spectively.
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(B) The heading for section 162(g) is
amended by inserting ‘‘OR PUNITIVE DAMAGES’’
after ‘‘LAWS’’.
(b) INCLUSION IN INCOME OF PUNITIVE DAMAGES
PAID BY INSURER OR OTHERWISE.—
(1) IN GENERAL.—Part II of subchapter B of
chapter 1 (relating to items specifically included in
gross income) is amended by adding at the end the
following new section:
‘‘SEC. 91. PUNITIVE DAMAGES COMPENSATED BY INSUR-
ANCE OR OTHERWISE.
‘‘Gross income shall include any amount paid to or
on behalf of a taxpayer as insurance or otherwise by reason
of the taxpayer’s liability (or agreement) to pay punitive
damages.’’.
(2) REPORTING REQUIREMENTS.—Section 6041
(relating to information at source) is amended by
adding at the end the following new subsection:
‘‘(f) SECTION TO APPLY TO PUNITIVE DAMAGES COM-
PENSATION.—This section shall apply to payments by a
person to or on behalf of another person as insurance or
otherwise by reason of the other person’s liability (or agree-
ment) to pay punitive damages.’’.
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(3) CONFORMING AMENDMENT.—The table of sec-
tions for part II of subchapter B of chapter 1 is
amended by adding at the end the following new item:
‘‘Sec. 91. Punitive damages compensated by insurance or otherwise.’’.
(c) EFFECTIVE DATE.—The amendments made by this
section shall apply to damages paid or incurred on or after
the date of the enactment of this Act.
SEC. 625. INCREASE IN CRIMINAL MONETARY PENALTY FOR
INDIVIDUALS TO THE AMOUNT OF THE TAX
AT ISSUE.
(a) IN GENERAL.—Section 7206 (relating to fraud and
false statements) is amended—
(1) by striking ‘‘Any person who—’’ and insert-
ing ‘‘(a) IN GENERAL.—Any person who—’’, and
(2) by adding at the end the following new sub-
section:
‘‘(b) INCREASE IN MONETARY LIMITATION FOR UN-
DERPAYMENT OR OVERPAYMENT OF TAX DUE TO FRAUD.—
If any portion of any underpayment (as defined in section
6664(a)) or overpayment (as defined in section 6203(a)) of
tax required to be shown on a return is attributable to
fraudulent action described in subsection (a), the applicable
dollar amount under subsection (a) shall in no event be less
than an amount equal to such portion. A rule similar to
the rule under section 6663(b) shall apply for purposes of
determining the portion so attributable.’’.
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(b) INCREASE IN PENALTIES.—
(1) ATTEMPT TO EVADE OR DEFEAT TAX.—Sec-
tion 7201 is amended—
(A) by striking ‘‘$100,000’’ and inserting
‘‘$250,000’’,
(B) by striking ‘‘$500,000’’ and inserting
‘‘$1,000,000’’, and
(C) by striking ‘‘5 years’’ and inserting ‘‘10
years’’.
(2) WILLFUL FAILURE TO FILE RETURN, SUPPLY
INFORMATION, 
OR
PAY
TAX.—Section 
7203 
is
amended—
(A) in the first sentence—
(i) by striking ‘‘misdemeanor’’ and in-
serting ‘‘felony’’, and
(ii) by striking ‘‘1 year’’ and inserting
‘‘10 years’’, and
(B) by striking the third sentence.
(3) FRAUD
AND
FALSE
STATEMENTS.—Section
7206(a) (as redesignated by subsection (a)) is
amended—
(A) by striking ‘‘$100,000’’ and inserting
‘‘$250,000’’,
(B) by striking ‘‘$500,000’’ and inserting
‘‘$1,000,000’’, and
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(C) by striking ‘‘3 years’’ and inserting ‘‘5
years’’.
(c) EFFECTIVE DATE.—The amendments made by this
section shall apply to underpayments and overpayments at-
tributable to actions occurring after the date of the enact-
ment of this Act.
SEC. 626. DOUBLING OF CERTAIN PENALTIES, FINES, AND
INTEREST ON UNDERPAYMENTS RELATED TO
CERTAIN OFFSHORE FINANCIAL ARRANGE-
MENTS.
(a) GENERAL RULE.—If—
(1) a taxpayer eligible to participate in—
(A) the Department of the Treasury’s Off-
shore Voluntary Compliance Initiative, or
(B) the Department of the Treasury’s vol-
untary disclosure initiative which applies to the
taxpayer by reason of the taxpayer’s under-
reporting of United States income tax liability
through financial arrangements which rely on
the use of offshore arrangements which were the
subject of the initiative described in subpara-
graph (A), and
(2) any interest or applicable penalty is imposed
with respect to any arrangement to which any initia-
tive described in paragraph (1) applied or to any un-
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derpayment of Federal income tax attributable to
items arising in connection with any arrangement
described in paragraph (1),
then, notwithstanding any other provision of law, the
amount of such interest or penalty shall be equal to twice
that determined without regard to this section.
(b) DEFINITIONS AND RULES.—For purposes of this
section—
(1) APPLICABLE PENALTY.—The term ‘‘applica-
ble penalty’’ means any penalty, addition to tax, or
fine imposed under chapter 68 of the Internal Rev-
enue Code of 1986.
(2) VOLUNTARY OFFSHORE COMPLIANCE INITIA-
TIVE.—The term ‘‘Voluntary Offshore Compliance
Initiative’’ means the program established by the De-
partment of the Treasury in January of 2003 under
which any taxpayer was eligible to voluntarily dis-
close previously undisclosed income on assets placed
in offshore accounts and accessed through credit card
and other financial arrangements.
(3) PARTICIPATION.—A taxpayer shall be treated
as having participated in the Voluntary Offshore
Compliance Initiative if the taxpayer submitted the
request in a timely manner and all information re-
quested by the Secretary of the Treasury or his dele-
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gate within a reasonable period of time following the
request.
(c) EFFECTIVE DATE.—The provisions of this section
shall apply to interest, penalties, additions to tax, and fines
with respect to any taxable year if as of the date of the
enactment of this Act, the assessment of any tax, penalty,
or interest with respect to such taxable year is not prevented
by the operation of any law or rule of law.
PART III—EXTENSION OF IRS USER FEES
SEC. 631. EXTENSION OF IRS USER FEES.
(a) IN GENERAL.—Section 7528(c) (relating to termi-
nation) is amended by striking ‘‘December 31, 2004’’ and
inserting ‘‘September 30, 2013’’.
(b) EFFECTIVE DATE.—The amendment made by this
section shall apply to requests after the date of the enact-
ment of this Act.
PART IV—OTHER REVENUE PROVISIONS
SEC. 641. REPORTING OF TAXABLE MERGERS AND ACQUISI-
TIONS.
(a) IN GENERAL.—Subpart B of part III of subchapter
A of chapter 61 is amended by inserting after section 6043
the following new section:
‘‘SEC. 6043A. TAXABLE MERGERS AND ACQUISITIONS.
‘‘(a) IN GENERAL.—The acquiring corporation in any
taxable acquisition shall make a return (according to the