S.Amdt. 1623

SA 1623. Mr. PAUL (for himself and Mr. Wicker) submitted an amendment
intended to be proposed to amendment SA 1618 proposed by Mr. Hatch (for
himself and Ms. Murkowski) and intended to be proposed to the bill H.R.
1, to provide for reconciliation pursuant to titles II and V of the
concurrent resolution on the budget for fiscal year 2018; which was
ordered to lie on the table; as follows:

At the end of subtitle D of title I, add the following:

PART IV--REPEAL OF FOREIGN ACCOUNT TAX COMPLIANCE ACT

SEC. 14601. REPEAL OF WITHHOLDING AND REPORTING WITH RESPECT
TO CERTAIN FOREIGN ACCOUNTS.

(a) In General.--Chapter 4 is repealed.
(b) Conforming Amendments for Rules for Electronically
Filed Returns.--Section 6011(e)(4) is amended--
(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 Substitute Dividends.--
Section 871(m) is amended by striking ``chapters 3 and 4''
both places it appears and inserting ``chapter 3''.
(d) Other Conforming Amendments.--
(1) Section 6414 s amended by striking ``or 4''.
(2) Paragraph (1) of section 6501(b) is amended by striking
``4,''.
(3) Paragraph (2) of section 6501(b) 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) is amended--
(A) by striking ``or 4'', and
(B) by striking ``or 1474(b)''.
(5) Section 6513(c) is amended by striking ``4,''.
(6) Section 6611(e)(4) is amended by striking ``or 4''.
(7) Paragraph (1) of section 6724(d) is amended by striking
``under chapter 4 or''.
(8) Paragraph (2) of section 6724(d) 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. 14602. REPEAL OF INFORMATION REPORTING WITH RESPECT TO
FOREIGN FINANCIAL ASSETS.

(a) In General.--Subpart A of part III of subchapter A of
chapter 61 is amended by striking section 6038D.
(b) Repeal of Modification of Statute of Limitations for
Significant Omission of Income in Connection With Foreign
Assets.--
(1) Paragraph (1) of section 6501(e) is amended by striking
subparagraph (A) and by redesignating subparagraphs (B) and
(C) as subparagraphs (A) and (B), respectively.
(2) Subparagraph (A) of section 6501(e), as redesignated by
paragraph (1), is 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 percent of the amount of gross income stated in the
return, the tax may be assessed, or a proceeding 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--''.

[[Page S7469]]

(3) Paragraph (2) of section 6229(c) 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 amended--
(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 is amended by
striking the item related to section 6038D.
(d) Effective Date.--
(1) In general.--Except as provided in paragraph (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 subsection (b) shall
apply to returns filed after the date of the enactment of
this Act.

SEC. 14603. REPEAL OF PENALTIES FOR UNDERPAYMENTS
ATTRIBUTABLE TO UNDISCLOSED FOREIGN FINANCIAL
ASSETS.

(a) In General.--Section 6662 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.

SEC. 14604. REPEAL OF REPORTING OF ACTIVITIES WITH RESPECT TO
PASSIVE FOREIGN INVESTMENT COMPANIES.

(a) In General.--Section 1298 is amended by striking
subsection (f) and by redesignating subsection (g) as
subsection (f).

(b) Conforming Amendment.--Section 1291(e) 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. 14605. 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.

SEC. 14606. REPEAL OF MINIMUM PENALTY WITH RESPECT TO FAILURE
TO REPORT ON CERTAIN FOREIGN TRUSTS.

(a) In General.--Section 6677(a) is amended--
(1) by striking ``the greater of $10,000 or'', and
(2) by striking the last sentence and inserting the
following: ``In no event shall the penalty under this
subsection with respect to any failure exceed the gross
reportable amount.''.
(b) Effective Date.--The amendments made by this section
shall apply to notices and returns required to be filed after
the date of the enactment of this Act.
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