,,ii #aagth ,,congress #ast ,session ,s4 #aheg ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,may #bf1 #bjba ,mr4 ,king 7for himself1 ,mr4 ,brown1 and ,mr4 ,kaine7 introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to provide appropriations for the ,internal ,revenue ,service to overhaul technology and strengthen enforcement1 and for other purposes4 #a4 ,short title ,this ,act may be cited as the ,stop ,corporations and ,high ,earners from ,avoiding ,taxes and ,enforce the ,rules ,strictly ,act or the ,stop ,,cheaters ,act4 #b4 ,policy of ,congress ,it is the policy of ,congress that-- 7#a7 tax compliance1 to raise revenue for national needs1 restore fairness1 and protect the integrity of the tax system1 high-income ,united ,states citizens and corporations should pay all of the taxes they owe1 7#b7 tax compliance1 as indicated by the fraction of taxes due that are reported and paid1 should be comparable among groups of taxpayers regardless of the legal entity1 7#c7 the ,internal ,revenue ,service should be given resources to increase audits and enforcement of tax compliance of high-income individuals to reduce the tax gap1 with an emphasis on the auditing and enforcement of tax compliance by individuals with gross income of not less than #a1jjj1jjj and of large corporations1 and to modernize its technology in order to better serve taxpayers and enforce the tax laws1 7#d7 pursuing non-filers is one of the most efficient enforcement strategies of the ,internal ,revenue ,service because issuing non-filer notices can be a cost-effective tool that requires little more than automated notices1 7#e7 priorities for actions and resources to improve compliance should be guided by the relative revenue loss from non-compliance1 7#f7 it should be the goal of the ,internal ,revenue ,service that1 by the tenth tax year after the effective date of this statute1 the net tax gap1 as measured by the fraction of taxes that are due that are not reported and paid1 should be reduced by at least one-third1 as compared with the fraction estimated in the most recent ,internal ,revenue ,service study prior to enactment of this statute1 and 7#g7 it should be the goal of the ,internal ,revenue ,service to provide quality1 timely1 and accurate assistance to all taxpayers interacting with the ,internal ,revenue ,service4 #c4 ,additional appropriations for the ,internal ,revenue ,service 7a7 ,enforcement 7#a7 ,in general ,in addition to other amounts1 there is appropriated the following amounts for necessary expenses to strengthen the enforcement capacity of the ,internal ,revenue ,service by increasing audits annually to meet the audit goals described in paragraph 7#b73 7,a7 ,for fiscal year #bjbb1 #a1fjj1jjj1jjj4 7,b7 ,for fiscal year #bjbc1 #c1bjj1jjj1jjj4 7,c7 ,for fiscal year #bjbd1 #d1jjj1jjj1jjj4 7,d7 ,for fiscal year #bjbe1 #f1djj1jjj1jjj4 7,e7 ,for fiscal year #bjbf1 #f1hjj1jjj1jjj4 7,f7 ,for fiscal year #bjbg1 #f1hjj1jjj1jjj4 7,g7 ,for fiscal year #bjbh1 #f1hjj1jjj1jjj4 7,h7 ,for fiscal year #bjbi1 #f1hjj1jjj1jjj4 7,i7 ,for fiscal year #bjcj1 #f1hjj1jjj1jjj4 7,j7 ,for fiscal year #bjca1 #f1hjj1jjj1jjj4 7#b7 ,goals ,the goals described in this subparagraph are to annually audit by #bjbe and each year thereafter-- 7,a7 in the case of the income tax returns of individuals-- 7i7 #bj percent of such returns reporting an adjusted gross income of not less than #a1jjj1jjj but less than #e1jjj1jjj2 7ii7 #cc percent of such returns reporting an adjusted gross income of not less than #e1jjj1jjj but less than #aj1jjj1jjj and 7iii7 #ej percent of such returns reporting an adjusted gross income of not less than #aj1jjj1jjj2 7,b7 #ie percent of the income tax returns of corporations reporting more than #bj1jjj1jjj1jjj in assets2 7,c7 #dj percent of the estate tax returns having a gross estate valued at more than #aj1jjj1jjj2 7,d7 #a4b percent of gift tax returns2 and 7,e7 #j4bb percent of employment tax returns filed by employers with respect to the taxes imposed under chapters #ba or #bb of the ,internal ,revenue ,code of #aihf4 7b7 ,taxpayer services ,in addition to other amounts1 there are appropriated the following amounts to provide taxpayer services1 including pre-filing assistance and education1 filing and account services1 taxpayer advocacy services1 and services related to the reporting required under section #fjej,z of the ,internal ,revenue ,code of #aihf 7as added by section #d73 7#a7 ,for fiscal year #bjbb1 #hjj1jjj1jjj4 7#b7 ,for fiscal year #bjbc1 #hjj1jjj1jjj4 7#c7 ,for fiscal year #bjbd1 #hjj1jjj1jjj4 7#d7 ,for fiscal year #bjbe1 #b1jjj1jjj1jjj4 7#e7 ,for fiscal year #bjbf1 #b1jjj1jjj1jjj4 7#f7 ,for fiscal year #bjbg1 #b1jjj1jjj1jjj4 7#g7 ,for fiscal year #bjbh1 #b1jjj1jjj1jjj4 7#h7 ,for fiscal year #bjbi1 #b1jjj1jjj1jjj4 7#i7 ,for fiscal year #bjcj1 #b1jjj1jjj1jjj4 7#aj7 ,for fiscal year #bjca1 #b1jjj1jjj1jjj4 7c7 ,operations support ,there are appropriated the following additional amounts for the ,department of the ,treasury--,internal ,revenue ,service--,operations ,support account to overhaul outdated technology of the ,internal ,revenue ,service and improve the capacity of the ,internal ,revenue ,service to detect fraud related to income from a trade or business3 7#a7 ,for fiscal year #bjbb1 #hjj1jjj1jjj4 7#b7 ,for fiscal year #bjbc1 #hjj1jjj1jjj4 7#c7 ,for fiscal year #bjbd1 #hjj1jjj1jjj4 7#d7 ,for fiscal year #bjbe1 #hjj1jjj1jjj4 7#e7 ,for fiscal year #bjbf1 #hjj1jjj1jjj4 7#f7 ,for fiscal year #bjbg1 #hjj1jjj1jjj4 7#g7 ,for fiscal year #bjbh1 #hjj1jjj1jjj4 7#h7 ,for fiscal year #bjbi1 #hjj1jjj1jjj4 7#i7 ,for fiscal year #bjcj1 #hjj1jjj1jjj4 7#aj7 ,for fiscal year #bjca1 #hjj1jjj1jjj4 7d7 ,availability ,each additional amount appropriated by this section shall remain available until expended4 #d4 ,returns relating to certain business transactions 7a7 ,in general ,subpart ,b of part ,,iii of subchapter ,a of chapter #fa of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new section3 #fjej,z4 ,returns relating to certain transactions 7a7 ,requirement of reporting ,any covered financial service provider shall make the information return described in subsection 7b7 at such time as the ,secretary may by regulations prescribe4 7b7 ,return ,a return is described in this subsection if such return-- 7#a7 is in such form as the ,secretary may prescribe1 and 7#b7 contains1 with respect to each account maintained by the covered financial service provider-- 7,a7 the name1 address1 and ,,tin of the person on whose behalf the account is maintained1 7,b7 a summary report of total deposits received and total withdrawals made in such account1 and 7,c7 such other information as the ,secretary may require4 7c7 ,statement ,to be furnished to taxpayers with respect to whom information is required 7#a7 ,in general ,every covered financial service provider that is required to make a return under subsection 7a7 shall furnish to each person whose identity is required to be set forth in such return a written statement showing-- 7,a7 the name1 address1 and phone number of the information contact of the covered financial service provider required to make such a return1 and 7,b7 the information required to be shown on such return with respect to such person4 7#b7 ,furnishing of information ,the written statement required under paragraph 7#a7 shall be furnished to the person on or before ,january #ca of the year following the calendar year for which the return under subsection 7a7 is required to be made4 7d7 ,covered financial service provider ,for purposes of this section1 the term covered financial service provider means any financial service provider 7as determined under regulations provided by the ,secretary7 which maintains an account on behalf of another person4 7e7 ,regulations and guidance ,the ,secretary may prescribe such regulations and other guidance as may be appropriate or necessary to carry out the purposes of this section4 4 7b7 ,penalties 7#a7 ,returns ,section #fgbd7;d77#a77;,b7 of the ,internal ,revenue ,code of #aihf is amended by striking or at the end of clause 7xxv71 by striking and at the end of clause 7xxvi71 and by inserting after clause 7xxvi7 the following new clause3 7xxvii7 section #fjej,z 7relating to information with respect to certain transactions71 4 7#b7 ,statements ,section #fgbd7;d77#b7 of such ,code is amended-- 7,a7 by striking or at the end of subparagraph 7,,ii71 7,b7 by striking the period at the end of the first subparagraph 7,,jj7 7relating to section #fjce7 and inserting a comma1 7,c7 by redesignating the second subparagraph 7,,jj7 7relating to section #fjej,y7 as subparagraph 7,,kk71 7,d7 by striking the period at the end of subparagraph 7,,kk7 7as redesignated by subparagraph 7,c77 and inserting 1 or1 and 7,e7 by inserting after subparagraph 7,,kk7 7as so redesignated7 the following new subparagraph3 7,,ll7 section #fjej,z 7relating to information with respect to certain transactions74 4 7c7 ,clerical amendment ,the table of sections for subpart ,b of part ,,iii of subchapter ,a of chapter #fa of such ,code is amended by adding at the end the following new item3 ,sec4 #fjej,z4 ,returns relating to certain transactions4 4 7d7 ,effective date ,the amendments made by this section shall apply to calendar years beginning after ,december #ca1 #bjba4 #e4 ,reports to ,congress ,not later than #a year after the date of the enactment of this ,act and every #b years thereafter1 the ,commissioner of the ,internal ,revenue ,service1 after consultation with the ,comptroller ,general1 shall submit to ,congress a report containing-- 7#a7 a comprehensive description of-- 7,a7 a plan to-- 7i7 shift more of the auditing and enforcement assets of the ,internal ,revenue ,service toward high-income tax filers1 and 7ii7 recruit and retain auditors with the skills essential to audit high-income individuals1 and 7,b7 the progress made in implementing such plan1 7#b7 an estimate of revenue loss from offshore tax evasion1 and 7#c7 information with respect to revenue loss due to such tax evasion1 organized by groups of taxpayers arranged by the true income level of such taxpayers1 as determined by the ,secretary4 #f4 ,,irs ,enforcement penalties increased for certain taxpayers 7a7 ,in general ,subsection 7a7 of section #fffb of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7a7 ,imposition of penalty 7#a7 ,in general ,if this section applies to any portion of an underpayment of tax required to be shown on a return1 there shall be added to the tax an amount equal to the applicable percentage of the portion of the underpayment to which this section applies4 7#b7 ,applicable percentage ,for purposes of paragraph 7#a71 the term applicable percentage means-- 7,a7 in the case of a taxpayer with a taxable income of less than #b million1 #bj percent1 7,b7 in the case of a taxpayer with a taxable income greater than #b million but less than #e million1 #cj percent1 and 7,c7 in the case of a taxpayer with a taxable income greater than #e million1 #dj percent4 4 7b7 ,conforming amendments 7#a7 ,gross valuation misstatements ,section #fffb7;h77#a7 of such ,code is amended by striking with respect to such portion by substituting and all that follows and inserting with respect to such portion-- 7,a7 by substituting #dj percent for #bj percent in paragraph 7#b77;,a7 thereof1 and 7,b7 by substituting #dj percent for #cj percent in paragraph 7#b77;,b7 thereof4 4 7#b7 ,nondisclosed noneconomic substance transactions ,section #fffb7;i77#a7 of such ,code is amended by striking with respect to such portion by substituting and all that follows and inserting with respect to such portion-- 7,a7 by substituting #dj percent for #bj percent in paragraph 7#b77;,a7 thereof1 and 7,b7 by substituting #dj percent for #cj percent in paragraph 7#b77;,b7 thereof4 4 7#c7 ,undisclosed foreign financial asset understatements ,section #fffb7;j77#c7 of such ,code is amended by striking with respect to such portion by substituting and all that follows and inserting with respect to such portion-- 7,a7 by substituting #dj percent for #bj percent in paragraph 7#b77;,a7 thereof1 and 7,b7 by substituting #dj percent for #cj percent in paragraph 7#b77;,b7 thereof4 4 7c7 ,effective date ,the amendment made by this section shall apply to returns on the due date which 7determined without regard to extensions7 is after ,december #ca1 #bjbb4