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Imposes a civil penalty for a "reportable transaction understatement."
Requires each "material advisor" with respect to a reportable transaction to file a report about such transaction with the Secretary of the Treasury. Modifies or imposes penalties dealing with maintaining lists of investors, frivolous tax submissions, interests in foreign financial accounts, and promoting tax shelters.
Establishes rules concerning the tax treatment of expatriated entities and their foreign parents.
Imposes an excise tax on the stock compensation of specified insiders in expatriated corporations.
Repeals the CFC (controlled foreign corporations) rules on foreign base company sales and services income.
Sets forth provisions concerning foreign tax credit, including: (1) modifying interest expense allocation rules; (2) recharacterizing overall domestic loss; and (3) extending the period in which excess foreign taxes may be carried.
Applies uniform capitalization rules to foreign persons.
Provides for exemptions for certain dividends of regulated investment companies.
Repeals the withholding tax on dividends from certain foreign corporations.
Increases the dollar limitation for expensing under Section 179.
Repeals: (1) the exclusion for extraterritorial income; and (2) the FSC (foreign sales corporation) transitional rules.
Extends Internal Revenue Service user fees and customs user fees.
Includes in gross income funded deferred compensation of corporate insiders.
Extends transfers of excess pension assets to retiree health accounts.
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No CBO cost estimate has been published for this bill.