MODIFICATION OF STATUTE OF LIMITATIONS FOR SIGNIFICANT OMISSION OF INCOME IN CONNECTION WITH FOREIGN ASSETS.

SEC. 513. MODIFICATION OF STATUTE OF LIMITATIONS FOR SIGNIFICANT OMISSION OF INCOME IN CONNECTION WITH FOREIGN ASSETS.(a) Extension of Statute of Limitations.—(1) In general.—Paragraph (1) of section 6501(e) is amended by redesignating subparagraphs (A) and (B) as subparagraphs (B) and (C), respectively, and by inserting before subparagraph (B) (as so redesignated) the following new subparagraph:“(A) General rule.—If the taxpayer omits from gross income an amount properly includible therein and—“(i) such amount is in excess of 25 percent of the amount of gross income stated in the return, or“(ii) such amount—“(I) is attributable to one or more assets with respect to which information is required to be reported under section 6038D (or would be so required if such section were applied without regard to the dollar threshold specified in subsection (a) thereof and without regard to any exceptions provided pursuant to subsection (h)(1) thereof), and“(II) is in excess of $5,000,the tax may be assessed, or a proceeding in court for collection of such tax may be begun without assessment, at any time within 6 years after the return was filed.”.(2) Conforming amendments.—124 STAT. 112(A) Subparagraph (B) of section 6501(e)(1), as redesignated by paragraph (1), is amended by striking all that precedes clause (i) and inserting the following:“(B) Determination of gross income.—For purposes of subparagraph (A)—”.(B) Paragraph (2) of section 6229(c) is amended by striking “which is in excess of 25 percent of the amount of gross income stated in its return” and inserting “and such amount is described in clause (i) or (ii) of section 6501(e)(1)(A)”.(b) Additional Reports Subject to Extended Period.—Paragraph (8) of section 6501(c) is amended—(1) by inserting “pursuant to an election under section 1295(b) or” before “under section 6038”,(2) by inserting “1298(f),” before “6038”, and(3) by inserting “6038D,” after “6038B,”.(c) Clarifications Related to Failure To Disclose Foreign Transfers.—Paragraph (8) of section 6501(c) is amended by striking “event” and inserting “tax return, event,”.(d) Effective Date.—The amendments made by this section shall apply to—(1) returns filed after the date of the enactment of this Act; and(2) returns filed on or before such date if the period specified in section 6501 of the Internal Revenue Code of 1986 (determined without regard to such amendments) for assessment of such taxes has not expired as of such date.