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SECTION 1. SHORT TITLE.

This Act may be cited as the ''Civil Asset Forfeiture Reform Act''.

SEC. 2. LIMITATION OF CUSTOMS AND TAX EXEMPTION UNDER THE TORT CLAIMS
PROCEDURES.

Section 2680(c) of title 28, United States Code, is amended by
striking ''law-enforcement officer'' and inserting ''law enforcement
officer, except that this chapter and section 1346(b) shall apply to a
claim based on the negligent destruction, injury, or loss of goods or
merchandise (including real property) while in the possession of an
officer of customs or excise or any other law enforcement officer''.

SEC. 3. LONGER PERIOD FOR FILING CLAIMS IN CERTAIN IN REM PROCEEDINGS.

Rule C(6) of the Supplemental Rules for Certain Admiralty and
Maritime Claims to the Federal Rules of Civil Procedures (28 U.S.C.
App.) is amended by striking ''10 days'' and inserting ''60 days''.

SEC. 4. CLAIM AFTER SEIZURE.

Section 608 of the Tariff Act of 1930 (19 U.S.C. 1608) is amended
to read as follows:

''SEC. 608. SEIZURE; CLAIMS; REPRESENTATION.

''(a) In General.--
''(1) Filing of claim.--At any time within 60 days after
the date on which a notice of seizure is first published, a
person who claims a vessel, vehicle, aircraft, merchandise, or
baggage seized under a law described in section 605 may file
with the appropriate customs officer a claim stating the
person's interest in the property.
''(2) Condemnation.--On filing of a claim under paragraph
(1), the customs officer shall transmit the claim, with a
duplicate list and description of the articles seized, to the
United States attorney for the district in which the seizure
was made, who shall proceed to a condemnation of the
merchandise or other property in the manner prescribed by law.
''(b) Court-Appointed Counsel.--
''(1) In general.--If a person filing a claim under
subsection (a), or a claim regarding property seized under
another law that incorporates by reference the seizure,
forfeiture, and condemnation procedures of the customs laws, is
financially unable to obtain representation of counsel, the
court may appoint appropriate counsel to represent the person
with respect to the claim.
''(2) Compensation.--(A) The court shall set the
compensation for counsel appointed under paragraph (1) in an
amount that is equivalent to that provided for counsel
appointed under section 3006A of title 18, United States Code.
''(B) Compensation of counsel appointed under paragraph (1)
shall be paid from the Justice Assets Forfeiture Fund
established under section 524 of title 28, United States
Code.''.

SEC. 5. BURDEN OF PROOF IN FORFEITURE PROCEEDINGS.

Section 615 of the Tariff Act of 1930 (19 U.S.C. 1615) is amended
to read as follows:

''SEC. 615. BURDEN OF PROOF IN FORFEITURE PROCEEDINGS.

''(a) In General.--In a suit or action described in subsection (b),
the burden of proof is on the Government to establish by clear and
convincing evidence that the property is subject to forfeiture.
''(b) Suits and Actions Described.--A suit or action is described
in this subsection if it is--
''(1) a suit or action (other than a suit or action arising
under section 592) brought for the forfeiture of a vessel,
vehicle, aircraft, merchandise, or baggage seized under any law
relating to the collection of duties on imports or tonnage; or
''(2) a suit or action brought for the recovery of the
value of any vessel, vehicle, aircraft, merchandise, or
baggage, because of a violation of that law.''.

SEC. 6. RELEASE OF SEIZED PROPERTY FOR SUBSTANTIAL HARDSHIP.

Section 614 of the Tariff Act of 1930 (19 U.S.C. 1614) is amended--
(1) by inserting ''(a) Release Upon Payment.--'' before
''If''; and
(2) by adding at the end the following new subsection:
''(b) Release of Seized Property for Substantial Hardship.--
''(1) Request for release.--(A) A claimant is entitled to
immediate release of seized property if continued possession by
the Government would cause the claimant substantial hardship.
''(B) A claimant seeking release of property under this
subsection shall--
''(i) request possession of the property from the
appropriate customs officer; and
''(ii) state in the request the basis for such
release.
''(2) Civil action.--(A) If, within 10 days after the date
on which a request is made under paragraph (1), the subject
property has not been released, the claimant may file a
complaint in any district court that would have jurisdiction
over forfeiture proceedings relating to the property.
''(B) A complaint under subparagraph (B) shall state--
''(i) the nature of the claim to the seized
property;
''(ii) the reason why the continued possession by
the United States Government pending the final
disposition of forfeiture proceedings will cause
substantial hardship to the claimant; and
''(iii) the steps that the claimant has taken to
secure release of the property from the appropriate
customs officer.
''(3) Return of property.--If a complaint is filed under
paragraph (2), the district court shall order that the property
be returned to the claimant, pending completion of proceedings
by the United States Government to obtain forfeiture of the
property, if the claimant shows that--
''(A) the claimant is likely to demonstrate a
possessory interest in the seized property; and
''(B) continued possession by the United States
Government of the seized property is likely to cause
substantial hardship to the claimant.
''(4) Conditions.--The court may place such conditions on
release of the property as the court finds are appropriate to
preserve the availability of the property or its equivalent for
forfeiture.
''(5) Time for decision.--The district court shall render a
decision on a complaint filed under paragraph (2) no later than
30 days after the date of the filing, unless such 30-day
limitation is extended by consent of the parties or by the
court for good cause shown.''.

SEC. 7. JUSTICE ASSETS FORFEITURE FUND.

Section 524(c) of title 28, United States Code, is amended--
(1) in paragraph (1)--
(A) in the matter preceding subparagraph (A) by
striking ''law enforcement'';
(B) by redesignating subparagraphs (H) and (I) as
subparagraphs (I) and (J), respectively; and
(C) by inserting after subparagraph (G) the
following new subparagraph:
''(H) payment of court-awarded compensation for
representation of claimants pursuant to section 608(b) of the
Tariff Act of 1930;''; and
(2) in paragraph (9)(A), by striking ''(H)'' and inserting
''(I)''.

SEC. 8. CLARIFICATION REGARDING FORFEITURES UNDER THE CONTROLLED
SUBSTANCES ACT.

Section 511(a)(7) of the Controlled Substances Act (21 U.S.C.
881(a)(7)) is amended by striking ''without the knowledge or consent of
that owner'' and inserting ''either without the knowledge of that owner
or without the consent of that owner''.

SEC. 9. APPLICABILITY.

The amendments made by this Act apply with respect to claims filed
under section 608 of the Tariff Act of 1930 and suits and actions filed
under section 615 of that Act on or after the date of enactment of this
Act.
Civil Asset Forfeiture Reform Act - Amends the Federal judicial code to exclude from the customs and tax exemption under tort claims procedures a claim based on the negligent destruction, injury, or loss of goods or merchandise (including real property) while in the possession of a customs or other law enforcement officer.
Extends the period for filing claims in certain in rem proceedings.
Amends the Tariff Act of 1930 to provide that: (1) in all suits or actions brought for the forfeiture of any vessel, vehicle, aircraft, merchandise, or baggage seized under the provisions of any law relating to the collection of duties on imports or tonnage, with exceptions, and for the recovery of the value of any forfeited property because of violation of any such law, the burden of proof is on the Government to establish by clear and convincing evidence that the property was subject to forfeiture; (2) any person claiming such property may at any time within 60 days from the date of the first publication of the notice of seizure file a claim with the appropriate customs officer, who shall transmit such claim to the U.S. attorney for the district in which seizure was made; and (3) if the person filing such claim (or a claim regarding seized property under any other provision of law that incorporates by reference the seizure, forfeiture, and condemnation procedures of the customs laws) is financially unable to obtain representation, the court may appoint counsel, subject to specified requirements.
Specifies that a claimant is entitled to immediate release of seized property if continued possession by the Government would cause the claimant substantial hardship. Sets forth procedures regarding the request for release, return of property, and time for decision by the court on a complaint for such return.
Makes sums in the Department of Justice Assets Forfeiture Fund available for the payment of court-awarded compensation for representation of claimants under the Tariff Act, with respect to seizure claims by individuals financially unable to obtain representation of counsel.

SECTION 1. SHORT TITLE; TABLE OF CONTENTS.

(a) Short Title.--This Act may be cited as the ''Government Waste
Reduction Act of 2013''.
(b) Table of Contents.--The table of contents for this Act is as
follows:

Sec. 1. Short title; table of contents.
Sec. 2. Establishment of Board.
Sec. 3. Duties of the Board.
Sec. 4. Powers of the Board.
Sec. 5. Board personnel matters.
Sec. 6. Congressional consideration of Board recommendations.
Sec. 7. Termination of the Board.

SEC. 2. ESTABLISHMENT OF BOARD.

(a) Establishment.--There is established the Independent Government
Waste Reduction Board (hereafter in this Act referred to as the
''Board'').
(b) Membership.--
(1) In general.--
(A) Appointment.--The Board shall be composed of 15
members appointed by the President, by and with the
advice and consent of Congress.
(B) Qualifications.--The members of the Board shall
include individuals with national recognition for their
expertise in agencies, efficiency, waste reduction,
finance and economics, actuarial sciences, who provide
a mix of different professionals, broad geographic
representation, and a balance between urban and rural
representatives.
(C) Ethical disclosure.--The President shall
establish a system for public disclosure by members of
the Board of financial and other potential conflicts of
interest relating to such members. Members of the Board
shall be treated as officers in the executive branch
for purposes of applying title I of the Ethics in
Government Act of 1978 (Public Law 95-521).
(D) Conflicts of interest.--No individual may serve
as a member of the Board if that individual engages in
any other business, vocation, or employment.
(E) Consultation with congress.--In selecting
individuals for nominations for appointments to the
Board, the President shall consult with--
(i) the majority leader of the Senate
concerning the appointment of 3 members;
(ii) the Speaker of the House of
Representatives concerning the appointment of 3
members;
(iii) the minority leader of the Senate
concerning the appointment of 3 members; and
(iv) the minority leader of the House of
Representatives concerning the appointment of 3
members.
(2) Term of office.--Each member shall hold office for the
duration of the Board.
(3) Chairperson.--
(A) In general.--The Chairperson shall be appointed
by the President, by and with the advice and consent of
the Senate, from among the members of the Board.
(B) Duties.--The Chairperson shall be the principal
executive officer of the Board, and shall exercise all
of the executive and administrative functions of the
Board, including functions of the Board with respect
to--
(i) the appointment and supervision of
personnel employed by the Board;
(ii) the distribution of business among
personnel appointed and supervised by the
Chairperson and among administrative units of
the Board; and
(iii) the use and expenditure of funds.
(C) Governance.--In carrying out any of the
functions under subparagraph (B), the Chairperson shall
be governed by the general policies established by the
Board and by the decisions, findings, and
determinations the Board shall by law be authorized to
make.
(D) Requests for appropriations.--Requests or
estimates for regular, supplemental, or deficiency
appropriations on behalf of the Board may not be
submitted by the Chairperson without the prior approval
of a majority vote of the Board.
(4) Removal.--Any member may be removed by the President
for neglect of duty or malfeasance in office, but for no other
cause.
(c) Vacancies; Quorum; Seal; Vice Chairperson; Voting on Reports.--
(1) Vacancies.--No vacancy on the Board shall impair the
right of the remaining members to exercise all the powers of
the Board.
(2) Quorum.--A majority of the members of the Board shall
constitute a quorum for the transaction of business, but a
lesser number of members may hold hearings.
(3) Seal.--The Board shall have an official seal, of which
judicial notice shall be taken.
(4) Vice chairperson.--The Board shall elect a Vice
Chairperson to act in the absence or disability of the
Chairperson or in case of a vacancy in the office of the
Chairperson.
(5) Voting on proposals.--Any proposal of the Board must be
approved by the majority of members present.

SEC. 3. DUTIES OF THE BOARD.

(a) Submission of Report.--Not later than one year after the date
of the enactment of this Act, the Board shall submit to Congress and
the President a report that advises specific implementation of the
recommendations from the March 2011 Government Accountability Office
report to Congress, entitled ''Opportunities to Reduce Potential
Duplication in Government Programs, Save Tax Dollars, and Enhance
Revenue'' (GAO-11-318SP) and the February 2012 Government
Accountability Office report to Congress, entitled ''Opportunities to
Reduce Duplication, Overlap and Fragmentation, Achieve Savings, and
Enhance Revenue'' (GAO-12-342SP) and shall include--
(1) a summary of the recommendations;
(2) an explanation of each recommendation contained in the
report and the reasons for including such recommendation;
(3) an opinion by the Government Accountability Office on
whether each recommendation is consistent with the intent of
such Government Accountability Office reports;
(4) a legislative proposal that implements the
recommendations; and
(5) other information determined appropriate by the Board.
(b) Recommendations Requirements.--
(1) Requirements.--Each recommendation in the report
submitted under subsection (a)--
(A) shall result in a decrease of overall
Government spending or an increase of Government
revenue; and
(B) shall not result in--
(i) any cut in benefits for veterans,
members of the Armed Forces, or their families;
or
(ii) any cut in benefits for seniors,
including--
(I) the elimination of guaranteed
health insurance benefits for seniors
or people with disabilities;
(II) the conversion of Medicare
into a voucher plan that provides
limited payments to seniors or people
with disabilities to purchase health
care in the private health insurance
market;
(III) cuts in Medicaid health
insurance benefits;
(IV) cuts in nursing home care; or
(V) privatization of Social
Security benefits.
(2) Consultation with other agencies.--The Board shall
consult regularly with the Government Accountability Office and
other agencies in making the recommendations required under
this section.

SEC. 4. POWERS OF THE BOARD.

(a) Hearings.--The Board may hold such hearings, sit and act at
such times and places, take such testimony, and receive such evidence
as the Board considers advisable to carry out this Act.
(b) Obtaining Official Data.--The Board may secure directly from
any department or agency information necessary to enable it to carry
out this section. Upon request of the Chairperson, the head of that
department or agency shall furnish that information to the Board on an
agreed upon schedule.
(c) Postal Services.--The Board may use the United States mails in
the same manner and under the same conditions as other agencies of the
Federal Government.
(d) Gifts.--The Board may accept, use, and dispose of gifts or
donations of services or property.
(e) Offices.--The Board shall maintain a principal office and such
field offices as it determines necessary, and may meet and exercise any
of its powers at any other place.

SEC. 5. BOARD PERSONNEL MATTERS.

(a) Compensation of Members and Chairperson.--Each member of the
Board, other than the Chairperson, shall be compensated at a rate equal
to the annual rate of basic pay prescribed for level III of the
Executive Schedule under section 5315 of title 5, United States Code.
The Chairperson shall be compensated at a rate equal to the daily
equivalent of the annual rate of basic pay prescribed for level II of
the Executive Schedule under section 5315 of title 5, United States
Code.
(b) Travel Expenses.--The members of the Board shall be allowed
travel expenses, including per diem in lieu of subsistence, at rates
authorized for employees of agencies under subchapter I of chapter 57
of title 5, United States Code, while away from their homes or regular
places of business in the performance of services for the Board.
(c) Staff.--
(1) In general.--The Chairperson may, without regard to the
civil service laws and regulations, appoint and terminate an
executive director and such other additional personnel as may
be necessary to enable the Board to perform its duties. The
employment of an executive director shall be subject to
confirmation by the Board.
(2) Compensation.--The Chairperson may fix the compensation
of the executive director and other personnel without regard to
chapter 51 and subchapter III of chapter 53 of title 5, United
States Code, relating to classification of positions and
General Schedule pay rates, except that the rate of pay for the
executive director and other personnel may not exceed the rate
payable for level V of the Executive Schedule under section
5316 of such title.
(d) Detail of Government Employees.--Any Federal Government
employee may be detailed to the Board without reimbursement, and such
detail shall be without interruption or loss of civil service status or
privilege.
(e) Procurement of Temporary and Intermittent Services.--The
Chairperson may procure temporary and intermittent services under
section 3109(b) of title 5, United States Code, at rates for
individuals which do not exceed the daily equivalent of the annual rate
of basic pay prescribed for level V of the Executive Schedule under
section 5316 of such title.

SEC. 6. CONGRESSIONAL CONSIDERATION OF BOARD RECOMMENDATIONS.

(a) Introduction.--
(1) In general.--On the day on which the report is
submitted by the Board to the Congress under section 3(a), the
legislative proposal (described in section 3(a)(4)) contained
in the report shall be introduced (by request) in the Senate by
the majority leader of the Senate or by Members of the Senate
designated by the majority leader of the Senate and shall be
introduced (by request) in the House by the majority leader of
the House or by Members of the House designated by the majority
leader of the House.
(2) Not in session.--If either House is not in session on
the day on which such legislative proposal is submitted, the
legislative proposal shall be introduced in that House, as
provided in subparagraph (A), on the first day thereafter on
which that House is in session.
(3) Any member.--If the legislative proposal is not
introduced in either House within 5 days on which that House is
in session after the day on which the legislative proposal is
submitted, then any Member of that House may introduce the
legislative proposal.
(4) Referral.--The legislation introduced under this
subsection in the House of Representatives shall be referred to
the Committee on Oversight and Government Reform of the House
of Representatives. The legislation introduced under this
subsection in the Senate shall be referred to the Committee on
Homeland Security and Governmental Affairs of the Senate.
(b) Discharge.--If the committee to which a legislative proposal
described in subsection (a) is referred has not reported the bill
containing such proposal by the end of the 20-day period beginning on
the date on which the Board submits the report to Congress under
section 3(a), such committee shall be, at the end of such period,
discharged from further consideration of such bill, and such bill shall
be placed on the appropriate calendar of the House involved.
(c) Expedited Consideration.--
(1) Consideration.--On or after the third day after the
date on which the committee to which such a bill is referred
has reported, or has been discharged (under subsection (b))
from further consideration of, such a bill, it is in order
(even though a previous motion to the same effect has been
disagreed to) for any Member of the respective House to move to
proceed to the consideration of the bill. A member may make the
motion only on the day after the calendar day on which the
Member announces to the House concerned the Member's intention
to make the motion, except that, in the case of the House of
Representatives, the motion may be made without such prior
announcement if the motion is made by direction of the
committee to which the bill was referred. The motion is highly
privileged in the House of Representatives and is privileged in
the Senate and is not debatable. The motion is not subject to
amendment, or to a motion to postpone, or to a motion to
proceed to the consideration of other business. A motion to
reconsider the vote by which the motion is agreed to or
disagreed to shall not be in order. If a motion to proceed to
the consideration of the bill is agreed to, the respective
House shall immediately proceed to consideration of the bill
without intervening motion, order, or other business, and the
bill shall remain the unfinished business of the respective
House until disposed of.
(2) Debate.--Debate on the bill, and on all debatable
motions and appeals in connection therewith, shall be limited
to not more than 2 hours, which shall be divided equally
between those favoring and those opposing the bill. An
amendment to the bill is not in order. A motion further to
limit debate is in order and not debatable. A motion to
postpone, or a motion to proceed to the consideration of other
business, or a motion to recommit the bill is not in order. A
motion to reconsider the vote by which the bill is agreed to or
disagreed to is not in order.
(3) Vote on final passage.--Immediately following the
conclusion of the debate on the bill and a single quorum call
at the conclusion of the debate if requested in accordance with
the rules of the appropriate House, the vote on final passage
of the bill shall occur.
(4) Appeals.--Appeals from the decisions of the Chair
relating to the application of the rules of the Senate or the
House of Representatives, as the case may be, to the procedure
relating to the bill shall be decided without debate.
(d) Consideration by Other House.--
(1) Before passage.--If, before the passage by one House of
a bill of that House described in subsection (b), that House
receives from the other House a bill described in subsection
(b), then the following procedures shall apply--
(A) the bill of the other House shall not be
referred to a committee and may not be considered in
the House receiving it except in the case of final
passage as provided in subparagraph (B)(ii); and
(B) with respect to a bill described in subsection
(b) of the House receiving the bill (i) the procedure
in that House shall be the same as if no bill had been
received from the other House; but (ii) the vote on
final passage shall be on the bill of the other House.
(2) After passage.--Upon disposition of the bill received
from the other House, it shall no longer be in order to
consider the bill that originated in the receiving House.
(e) Rules of the Senate and House.--This section is enacted by
Congress--
(1) as an exercise of the rulemaking power of the Senate
and House of Representatives, respectively, and as such it is
deemed a part of the rules of each House, respectively, but
applicable only with respect to the procedure to be followed in
that House in the case of a bill described in subsection (b),
and it supersedes other rules only to the extent that it is
inconsistent with such rules; and
(2) with full recognition of the constitutional right of
either House to change the rules (so far as relating to the
procedure of that House) at any time, in the same manner, and
to the same extent as in the case of any other rule of that
House.
(f) Calendar Day Defined.--In this section, the term ''calendar
day'' means a calendar day other than one on which either House is not
in session because of an adjournment of more than three days to a date
certain.

SEC. 7. TERMINATION OF THE BOARD.

The Board shall terminate 120 days after the date on which the
Board submits the report under section 3(a).
Government Waste Reduction Act of 2013 - Establishes the Independent Government Waste Reduction Board, the membership of which shall include individuals with national recognition for expertise in agencies, waste reduction, finance and economics, and actuarial sciences. Requires the Board to submit to Congress and the President a report that advises specific implementation of the recommendations from the March 2011 Government Accountability Office (GAO) report "Opportunities to Reduce Potential Duplication in Government Programs, Save Tax Dollars, and Enhance Revenue" and the February 2012 GAO report "Opportunities to Reduce Duplication, Overlap and Fragmentation, Achieve Savings, and Enhance Revenue." Sets forth procedures for congressional consideration of the Board's recommendations.

SECTION 1. SHORT TITLE.

This Act may be cited as the ''Close the SILO/LILO Loophole Act of
2009''.

SEC. 2. EXCISE TAX ON CERTAIN PROCEEDS RECEIVED ON SILO AND LILO
TRANSACTIONS.

(a) In General.--Subchapter F of chapter 42 of subtitle D of the
Internal Revenue Code of 1986 is amended by adding at the end the
following new section:

''SEC. 4965A. EXCISE TAX ON CERTAIN PROCEEDS RECEIVED ON SILO AND LILO
TRANSACTIONS.

''(a) Imposition of Tax.--In the case of any person other than a
SILO/LILO lessee that receives any ineligible amount as a party to any
SILO transaction or any LILO transaction, such person shall pay a tax
for the taxable year in which such ineligible amounts are received.
''(b) Amount of Tax.--The amount of the tax imposed under
subsection (a) with respect to any person shall be an amount equal to
the aggregate ineligible amounts received by such person in the taxable
year.
''(c) Definitions.--For purposes of this section--
''(1) Ineligible amount.--The term 'ineligible amount'
means, with respect to any SILO transaction or LILO
transaction, the excess of--
''(A) the aggregate proceeds received by the
taxpayer attributable to or arising from any remedial
action relating to such transaction, or any consensual
termination or rescission of any such transaction
(including the value of any property received and any
additional amounts purporting to indemnify or reimburse
the taxpayer for taxes assessable on any amounts
received), over
''(B) the aggregate proceeds described in
subparagraph (A) that are received from third parties
(other than the SILO/LILO lessee) pursuant to a payment
arrangement (including a defeasance escrow arrangement)
entered into at the time of such transaction in which
the SILO/LILO lessee's payment obligations were
economically defeased in whole or in part.
''(2) SILO transaction.--The term 'SILO transaction' means
a purported sale-leaseback arrangement which is identified as a
listed transaction in Notice 2005-13.
''(3) LILO transaction.--The term 'LILO transaction' means
a transaction which is a 'lease-in/lease-out' transaction
described in Revenue Rulings 99-14 and 2002-69 and identified
as a listed transaction in Notice 2000-15, or which is
substantially similar to such a transaction.
''(4) SILO/LILO lessee.--The term 'SILO/LILO lessee' means
any lessee in a SILO transaction or a LILO transaction that
is--
''(A) a tax-exempt entity (within the meaning of
section 168(h)(2)) or any other cooperative, nonprofit,
limited dividend, or mutual association, or
''(B) any other person that does not derive a
substantial economic benefit from the tax
characterization of such transaction.
''(d) Certain Transfers Disregarded.--If any person who is subject
to the tax under subsection (a) is a party to any transaction that
results in the transfer of such person's rights with respect to a SILO
transaction or a LILO transaction to any other person who would, but
for this subsection, not be subject to the full amount of the tax under
subsection (a) with respect to such SILO transaction or LILO
transaction, then such transfer shall be disregarded for purposes of
this section and the taxpayer shall continue to be treated as the
recipient of any ineligible amount.
''(e) Regulatory Authority.--The Secretary is authorized to
promulgate regulations consistent with the purposes of this section,
including regulations to prevent the avoidance of such purposes.
''(f) Coordination With Other Taxes and Penalties.--The tax imposed
by this section is in addition to any other tax, addition to tax, or
penalty imposed under this title.''.
(b) Clerical Amendment.--The table of sections for subchapter F of
chapter 42 of subtitle D of the Internal Revenue Code of 1986 is
amended by adding at the end the following new item:

''Sec. 4965A. Excise tax on certain proceeds received on SILO and LILO
transactions.''.
(c) Effective Date.--The amendments made by this section shall
apply to amounts received after the date of the introduction of this
Act, in taxable years ending after such date.

SEC. 3. DENIAL OF DEDUCTION FOR COSTS OF CERTAIN ACTIONS RELATING TO
SILO AND LILO TRANSACTIONS.

(a) In General.--Part IX of subchapter B of chapter 1 of the
Internal Revenue Code of 1986 is amended by inserting after section
269B the following new section:

''SEC. 269C. COSTS OF CERTAIN ACTIONS RELATING TO SILO AND LILO
TRANSACTIONS.

''(a) General Rule.--If any party to a SILO transaction or a LILO
transaction (other than a SILO/LILO lessee) brings a remedial action
seeking to recover any ineligible amount with respect to such
transaction, in computing taxable income no deduction shall be allowed
for any attorney fees or other costs attributable to such action.
''(b) Definitions.--For purposes of this section, the terms 'SILO
transaction', 'LILO transaction', 'SILO/LILO lessee', and 'ineligible
amount' have the meanings given such terms by section 4965A(c).''.
(b) Clerical Amendment.--The table of sections for part IX of
subchapter B of chapter 1 of the Internal Revenue Code of 1986 is
amended by inserting after the item relating to section 269B the
following new item:

''Sec. 269C. Costs of certain actions relating to SILO and LILO
transactions.''.
(c) Effective Date.--The amendments made by this section shall
apply to costs incurred after the date of the introduction of this Act.
Close the SILO/LILO Loophole Act of 2009 - Amends the Internal Revenue Code to: (1) impose a 100% excise tax on any income or benefits received from a SILO (sale-in/lease-out) or LILO (lease-in/lease-out) transaction involving a financial institution and a public entity; and (2) deny a tax deduction for attorney fees or other costs incurred by a party to a SILO or LILO transaction seeking to enforce the terms of such transaction.