Page:United States Statutes at Large Volume 98 Part 1.djvu/728

 98 STAT. 680

PUBLIC LAW 98-369—JULY 18, 1984 "(1) rules for the aggregation of similar investments offered by the same person or persons for purposes of applying subsection (c)(4), "(2) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements, "(3) exemptions from the requirements of this section, and "(4) such rules as may be necessary or appropriate to carry out the purposes of this section in the case of foreign tax shelters." (b) PENALTIES.—Subchapter B of chapter 68 (relating to assessable penalties) is amended by adding at the end thereof the following new section:

26 USC 6707.

"SEC. 6707. FAILURE TO FURNISH INFORMATION REGARDING TAX SHELTERS. "(a) FAILURE TO REGISTER TAX SHELTER.— "(1) IMPOSITION OF PENALTY.—If a person who is required to

Ante, p. 677.

register a tax shelter under section 6111(a)— "(A) fails to register such tax shelter on or before the date described in section 6111(a)(1), or "(B) files false or incomplete information with the Secretary with respect to such registration, such person shall pay a penalty with respect to such registration in the amount determined under paragraph (2). No penalty shall be imposed under the preceding sentence with respect to any failure which is due to reasonable cause. "(2) AMOUNT OF PENALTY.—The penalty imposed under paragraph (1) with respect to any tax shelter shall be an amount equal to the greater of— "(A) $500, or "(B) the lesser of (i) 1 percent of the aggregate amount invested in such tax shelter, or (ii) $10,000. The $10,000 limitation in subparagraph (B) shall not apply where there is an intentional disregard of the requirements of section 6111(a). "(b) FAILURE TO FURNISH TAX SHELTER IDENTIFICATION NUMBER.— "(1) SELLERS, ETC.—Any person who fails to furnish the identi-

fication number of a tax shelter which such person is required to furnish under section 6111(b)(1) shall pay a penalty of $100 for each such failure. "(2) FAILURE TO INCLUDE NUMBER ON RETURN.—Any person who fails to include an identification number on a return on which such number is required to be included under section 6111(b)(2) shall pay a penalty of $50 for each such failure, unless such failure is due to reasonable cause." (c) CONFORMING AMENDMENTS.—

(1) The table of sections for subchapter B of chapter 61 is amended by striking out the item relating to section 6111 and inserting in lieu thereof the following new items: "Sec. 6111. Registration of tax shelters. "Sec. 6112. Cross references."

(2) The table of sections for subchapter B of chapter 68 is amended by adding at the end thereof the following new item: "Sec. 6707. Failure to furnish information regarding tax shelters." 26 USC 6111

note.

(d) EFFECTIVE D A T E. —

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