Page:United States Statutes at Large Volume 114 Part 5.djvu/674

 114 STAT. 2763A-634 PUBLIC LAW 106-554^APPENDIX G "(d) CROSS REFERENCES.— "For penalties for the unauthorized disclosure of tax convention information which is return or return information, see sections 7213, 7213A, and 7431.". (2) CLERICAL AMENDMENT. —The table of sections for subchapter B of chapter 61 is amended by inserting after the item relating to section 6104 the following new item: "Sec. 6105. Confidentiality of information arising under treaty obligations.". (c) EXCEPTION FROM PUBLIC INSPECTION AS WRITTEN DETER- MINATION. — (1) CLOSING AND SIMILAR AGREEMENTS.—Paragraph (1) of section 6110(b) is amended to read as follows: "(1) WRITTEN DETERMINATION. — "(A) IN GENERAL. —The term 'written determination' means a ruling, determination letter, technical advice memorandum, or Chief Counsel advice. "(B) EXCEPTIONS. —Such term shall not include any matter referred to in subparagraph (C) or (D) of section 6103(b)(2). ". (2) AGREEMENTS WITH FOREIGN GOVERNMENTS.— Paragraph (1) of section 6110(1) is amended by inserting "or 6105" after " 6104". (d) EFFECTIVE DATE. —The amendments made by this section shall take effect on the date of the enactment of this Act. SEC. 305. INCREASE IN THRESHOLD FOR JOINT COMMITTEE REPORTS ON REFUNDS AND CREDITS. (a) GENERAL RULE.— Subsections (a) and (b) of section 6405 are each amended by striking "$1,000,000" and inserting " $2,000,000". (b) EFFECTIVE DATE. —The amendment made by subsection (a) shall take effect on the date of the enactment of this Act, except that such amendment shall not apply with respect to any refund or credit with respect to a report that has been made before such date of the enactment under section 6405 of the Internal Revenue Code of 1986. SEC. 306. TREATMENT OF MISSING CHILDREN WITH RESPECT TO CER- TAIN TAX BENEFITS. (a) IN GENERAL. —Subsection (c) of section 151 (relating to additional exemption for dependents) is amended by adding at the end the following new paragraph: "(6) TREATMENT OF MISSING CHILDREN. — "(A) IN GENERAL.— Solely for the purposes referred to in subparagraph (B), a child of the taxpayer— "(i) who is presumed by law enforcement authorities to have been kidnapped by someone who is not a member of the family of such child or the taxpayer, and "(ii) who was (without regard to this paragraph) the dependent of the taxpayer for the portion of the taxable year before the date of the kidnapping, shall be treated as a dependent of the taxpayer for all taxable years ending during the period that the child is kidnapped. "(B) PURPOSES.— Subparagraph (A) shall apply solely for purposes of determining—

�