limitation on extension of statute of limitations for failure to notify secretary of certain foreign transfers

limitation on extension of statute of limitations for failure to notify secretary of certain foreign transfersSec. 218. (a) In General.—Paragraph (8) of section 6501(c) of the Internal Revenue Code of 1986 is amended—(1) by striking “In the case of any information” and inserting the following:“(A) In general.—In the case of any information”; and(2) by adding at the end the following:“(B) Application to failures due to reasonable cause.—If the failure to furnish the information referred to in subparagraph (A) is due to reasonable cause and not willful neglect, subparagraph (A) shall apply only to the item or items related to such failure.”.(b) Effective Date.—The amendments made by this section shall take effect as if included in section 513 of the Hiring Incentives to Restore Employment Act.