MCG17B51 S.L.C.

AMENDMENT NO.llll Calendar No.lll

Purpose: To repeal the violation of sovereign nations laws
and privacy matters.

IN THE SENATE OF THE UNITED STATES115th Cong., 1st Sess.

H. R. 1

To provide for reconciliation pursuant to titles II and V

of the concurrent resolution on the budget for fiscal
year 2018.
Referred to the Committee on llllllllll and
ordered to be printed
Ordered to lie on the table and to be printed
AMENDMENT intended to be proposed by Mr. PAUL to the
amendment (No. lll) proposed by
llllllllll
Viz:
1 At the end of subtitle D of title I, add the following:
2 PART IVREPEAL OF FOREIGN ACCOUNT TAX

3 COMPLIANCE ACT

4 SEC. 14601. REPEAL OF WITHHOLDING AND REPORTING

5 WITH RESPECT TO CERTAIN FOREIGN AC-

6 COUNTS.

7 (a) IN GENERAL.Chapter 4 is repealed.

8 (b) CONFORMING AMENDMENTS FOR RULES FOR

9 ELECTRONICALLY FILED RETURNS.Section 6011(e)(4)

10 is amended
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1 (1) by inserting , as in effect on January 1,
2 2017 after (as defined in section 1471(d)(5),
3 and
4 (2) by striking or 1474(a).
5 (c) CONFORMING AMENDMENT RELATED TO SUB-
6 STITUTE DIVIDENDS.Section 871(m) is amended by
7 striking chapters 3 and 4 both places it appears and
8 inserting chapter 3.
9 (d) OTHER CONFORMING AMENDMENTS.
10 (1) Section 6414 s amended by striking or 4.
11 (2) Paragraph (1) of section 6501(b) is amend-
12 ed by striking 4,.
13 (3) Paragraph (2) of section 6501(b) is amend-
14 ed
15 (A) by striking 4,, and
16 (B) by striking AND WITHOLDING TAXES

17 in the heading and inserting TAXES AND TAX

18 IMPOSED BY CHAPTER 3.

19 (4) Paragraph (3) of section 6513(b) is amend-

20 ed
21 (A) by striking or 4, and
22 (B) by striking or 1474(b).
23 (5) Section 6513(c) is amended by striking
24 4,.
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1 (6) Section 6611(e)(4) is amended by striking
2 or 4.
3 (7) Paragraph (1) of section 6724(d) is amend-
4 ed by striking under chapter 4 or.
5 (8) Paragraph (2) of section 6724(d) is amend-
6 ed by striking or 4.
7 (e) EFFECTIVE DATE.The amendments made by
8 this section shall apply to payments made after the date
9 of the enactment of this Act.
10 SEC. 14602. REPEAL OF INFORMATION REPORTING WITH

11 RESPECT TO FOREIGN FINANCIAL ASSETS.

12 (a) IN GENERAL.Subpart A of part III of sub-

13 chapter A of chapter 61 is amended by striking section
14 6038D.
15 (b) REPEAL OF MODIFICATION OF STATUTE OF LIM-
16 ITATIONS FOR SIGNIFICANT OMISSION OF INCOME IN

17 CONNECTION WITH FOREIGN ASSETS.

18 (1) Paragraph (1) of section 6501(e) is amend-
19 ed by striking subparagraph (A) and by redesig-
20 nating subparagraphs (B) and (C) as subparagraphs
21 (A) and (B), respectively.
22 (2) Subparagraph (A) of section 6501(e), as re-
23 designated by paragraph (1), is amended by striking
24 all that precedes clause (i) and inserting the fol-
25 lowing:
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1 (A) GENERAL RULE.If the taxpayer
2 omits from gross income an amount properly
3 included therein which is in excess of 25 per-
4 cent of the amount of gross income stated in
5 the return, the tax may be assessed, or a pro-
6 ceeding in court for the collection of such tax
7 may be begun without assessment, at any time
8 within 6 years after the return was filed. For
9 purposes of this subparagraph.
10 (3) Paragraph (2) of section 6229(c) is amend-
11 ed by striking and such amount is described in
12 clause (i) or (ii) of section 6501(e)(1)(A) and in-
13 serting which is in excess of 25 percent of the
14 amount of gross income stated in its return.
15 (4) Paragraph (8) of section 6501(c) is amend-
16 ed
17 (A) by striking pursuant to an election
18 under section 1295(b) or,
19 (B) by striking 1298(f), and
20 (C) by striking 6038D,.
21 (c) CLERICAL AMENDMENT.The table of sections
22 for subpart A of part III of subchapter A of chapter 61
23 is amended by striking the item related to section 6038D.
24 (d) EFFECTIVE DATE.
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1 (1) IN GENERAL.Except as provided in para-
2 graph (2), the amendments made by this section
3 shall apply to taxable years ending after the date of
4 the enactment of this Act.
5 (2) RETURNS.The amendments made by sub-
6 section (b) shall apply to returns filed after the date
7 of the enactment of this Act.
8 SEC. 14603. REPEAL OF PENALTIES FOR UNDERPAYMENTS

9 ATTRIBUTABLE TO UNDISCLOSED FOREIGN

10 FINANCIAL ASSETS.

11 (a) IN GENERAL.Section 6662 is amended

12 (1) in subsection (b), by striking paragraph (7)
13 and redesignating paragraph (8) as paragraph (7),
14 and
15 (2) by striking subsection (j) and redesignating
16 subsection (k) as subsection (j).
17 (b) EFFECTIVE DATE.The amendments made by
18 this section shall apply to taxable years ending after the
19 date of the enactment of this Act.
20 SEC. 14604. REPEAL OF REPORTING OF ACTIVITIES WITH

21 RESPECT TO PASSIVE FOREIGN INVESTMENT

22 COMPANIES.

23 (a) IN GENERAL.Section 1298 is amended by strik-

24 ing subsection (f) and by redesignating subsection (g) as
25 subsection (f).
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1 (b) CONFORMING AMENDMENT.Section 1291(e) is
2 amended by striking and (d) and inserting , (d), and
3 (f).
4 (c) EFFECTIVE DATE.The amendments made by
5 this section shall take effect on the date of the enactment
6 of this Act.
7 SEC. 14605. REPEAL OF REPORTING REQUIREMENT FOR

8 UNITED STATES OWNERS OF FOREIGN

9 TRUSTS.

10 (a) IN GENERAL.Paragraph (1) of section 6048(b)

11 is amended by striking shall submit such information as
12 the Secretary may prescribe with respect to such trust for
13 such year and.
14 (b) EFFECTIVE DATE.The amendments made by
15 this section shall apply to taxable years ending after the
16 date of the enactment of this Act.
17 SEC. 14606. REPEAL OF MINIMUM PENALTY WITH RESPECT

18 TO FAILURE TO REPORT ON CERTAIN FOR-

19 EIGN TRUSTS.

20 (a) IN GENERAL.Section 6677(a) is amended

21 (1) by striking the greater of $10,000 or,
22 and
23 (2) by striking the last sentence and inserting
24 the following: In no event shall the penalty under
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1 this subsection with respect to any failure exceed the
2 gross reportable amount..
3 (b) EFFECTIVE DATE.The amendments made by
4 this section shall apply to notices and returns required to
5 be filed after the date of the enactment of this Act.