‘‘(B) REQUIREMENTS.—A request meets 
the requirements of this subparagraph if it sets 
forth— 
‘‘(i) the nature of the investigation, 
examination, or proceeding, 
‘‘(ii) the statutory authority under 
which such investigation, examination, or 
proceeding is being conducted, 
‘‘(iii) the name or names of the finan-
cial institution, issuer, or public accounting 
firm to which such return information re-
lates, 
‘‘(iv) the taxable period or periods to 
which such return information relates, and 
‘‘(v) the specific reason or reasons 
why such disclosure is, or may be, relevant 
to such investigation, examination or pro-
ceeding. 
‘‘(C) FINANCIAL
INSTITUTION.—For the 
purposes of this paragraph, the term ‘financial 
institution’ means a depository institution, for-
eign bank, insured institution, industrial loan 
company, broker, dealer, investment company, 
investment advisor, or other entity subject to 
regulation or oversight by the United States Se-
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curities and Exchange Commission or an appro-
priate Federal banking agency.’’. 
(b) FINANCIAL AND ACCOUNTING FRAUD INVESTIGA-
TIONS.—Section 6103(i) is amended by adding at the end 
the following new paragraph: 
‘‘(9) DISCLOSURE OF RETURNS AND RETURN 
INFORMATION
FOR
USE
IN
FINANCIAL
AND
AC-
COUNTING FRAUD INVESTIGATIONS.— 
‘‘(A) WRITTEN
REQUEST.—Upon receipt 
by the Secretary of a written request which 
meets the requirements of subparagraph (B) 
from the head of the United States Securities 
and Exchange Commission or the Public Com-
pany Accounting Oversight Board, a return or 
return information shall be disclosed to such re-
questor’s officers and employees who are per-
sonally and directly engaged in an investigation, 
examination, or proceeding by such requester to 
evaluate the accuracy of a financial statement 
or report, or to determine whether to require a 
restatement, penalize, or deter conduct by an 
issuer, investment company, or public account-
ing firm, or associated person, in connection 
with a potential or actual violation of auditing 
standards or prohibitions against false or mis-
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leading statements or omissions in financial 
statements or reports. Such disclosure shall be 
solely for use by such officers and employees in 
such investigation, examination, or proceeding. 
‘‘(B) REQUIREMENTS.—A request meets 
the requirements of this subparagraph if it sets 
forth— 
‘‘(i) the nature of the investigation, 
examination, or proceeding, 
‘‘(ii) the statutory authority under 
which such investigation, examination, or 
proceeding is being conducted, 
‘‘(iii) the name or names of the issuer, 
investment company, or public accounting 
firm to which such return information re-
lates, 
‘‘(iv) the taxable period or periods to 
which such return information relates, and 
‘‘(v) the specific reason or reasons 
why such disclosure is, or may be, relevant 
to such investigation, examination or pro-
ceeding.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures and to information 
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and document requests made after the date of the enact-
ment of this Act. 
SEC. 306. DISCLOSURE OF INFORMATION TO CONGRESS. 
(a) DISCLOSURE BY TAX RETURN PREPARER.— 
(1) IN GENERAL.—Subparagraph (B) of section 
7216(b)(1) is amended to read as follows: 
‘‘(B) pursuant to any one of the following 
documents, if clearly identified: 
‘‘(i) The order of any Federal, State, 
or local court of record. 
‘‘(ii) A subpoena issued by a Federal 
or State grand jury. 
‘‘(iii) An administrative order, sum-
mons, or subpoena which is issued in the 
performance of its duties by— 
‘‘(I) any Federal agency, includ-
ing Congress or any committee or 
subcommittee thereof, or 
‘‘(II) any State agency, body, or 
commission charged under the laws of 
the State or a political subdivision of 
the State with the licensing, registra-
tion, or regulation of tax return pre-
parers.’’. 
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(2) EFFECTIVE DATE.—The amendment made 
by this subsection shall apply to disclosures made 
after the date of the enactment of this Act pursuant 
to any document in effect on or after such date. 
(b) DISCLOSURE BY SECRETARY.—Paragraph (2) of 
section 6104(a) is amended to read as follows: 
‘‘(2) INSPECTION BY CONGRESS.— 
‘‘(A) IN
GENERAL.—Upon receipt of a 
written request from a committee or sub-
committee of Congress, copies of documents re-
lated to a determination by the Secretary to 
grant, deny, revoke, or restore an organization’s 
exemption from taxation under section 501 
shall be provided to such committee or sub-
committee, including any application, notice of 
status, or supporting information provided by 
such organization to the Internal Revenue Serv-
ice; any letter, analysis, or other document pro-
duced by or for the Internal Revenue Service 
evaluating, determining, explaining, or relating 
to the tax exempt status of such organization 
(other than returns, unless such returns are 
available to the public under this section or sec-
tion 6103 or 6110); and any communication be-
tween the Internal Revenue Service and any 
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other party relating to the tax exempt status of 
such organization. 
‘‘(B) ADDITIONAL INFORMATION.—Section 
6103(f) shall apply with respect to— 
‘‘(i) the application for exemption of 
any organization described in subsection 
(c) or (d) of section 501 which is exempt 
from taxation under section 501(a) for any 
taxable year and any application referred 
to in subparagraph (B) of subsection 
(a)(1) of this section, and 
‘‘(ii) any other papers which are in 
the possession of the Secretary and which 
relate to such application, 
as if such papers constituted returns.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures and to information 
and document requests made after the date of the enact-
ment of this Act. 
SEC. 307. TAX OPINION STANDARDS FOR TAX PRACTI-
TIONERS. 
Section 330(d) of title 31, United States Code, is 
amended to read as follows: 
‘‘(d) The Secretary of the Treasury shall impose 
standards applicable to the rendering of written advice 
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with respect to any listed transaction or any entity, plan, 
arrangement, or other transaction which has a potential 
for tax avoidance or evasion. Such standards shall ad-
dress, but not be limited to, the following issues: 
‘‘(1) Independence of the practitioner issuing 
such written advice from persons promoting, mar-
keting, or recommending the subject of the advice. 
‘‘(2) Collaboration among practitioners, or be-
tween a practitioner and other party, which could re-
sult in such collaborating parties having a joint fi-
nancial interest in the subject of the advice. 
‘‘(3) Avoidance of conflicts of interest which 
would impair auditor independence. 
‘‘(4) For written advice issued by a firm, stand-
ards for reviewing the advice and ensuring the con-
sensus support of the firm for positions taken. 
‘‘(5) Reliance on reasonable factual representa-
tions by the taxpayer and other parties. 
‘‘(6) Appropriateness of the fees charged by the 
practitioner for the written advice. 
‘‘(7) Preventing practitioners and firms from 
aiding or abetting the understatement of tax liability 
by clients. 
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‘‘(8) Banning the promotion of potentially abu-
sive or illegal tax shelters.’’. 
Æ 
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