110 STAT. 1908 PUBLIC LAW 104-188—AUG. 20, 1996 "(2) subsection (a) shall be applied by substituting *5 percent' for '35 percent'. "(c) GROSS REPORTABLE AMOUNT. —For purposes of subsection (a), the term 'gross reportable amount' means— "(1) the gross value of the property involved in the event (determined as of the date of the event) in the case of a failure relating to section 6048(a), "(2) the gross value of the portion of the trust's assets at the close of the year treated as owned by the United States person in the case of a failure relating to section 6048(b)(1), and "(3) the gross amount of the distributions in the case of a failure relating to section 6048(c). "(d) REASONABLE CAUSE EXCEPTION. —NO penalty shall be imposed by this section on any failure which is shown to be due to reasonable cause and not due to willful neglect. The fact that a foreign jurisdiction would impose a civil or criminal penalty on the taxpayer (or any other person) for disclosing the required information is not reasonable cause. "(e) DEFICIENCY PROCEDURES NOT TO APPLY. —Subchapter B of chapter 63 (relating to deficiency procedures for income, estate, gift, and certain excise taxes) shall not apply in respect of the assessment or collection of any penalty imposed by subsection (a).". (c) CONFORMING AMENDMENTS. — (1) Paragraph (2) of section 6724(d) is amended by striking "or" at the end of subparagraph (S), by striking the period at the end of subparagraph (T) and inserting ", or", and by inserting after subparagraph (T) the following new subparagraph: "(U) section 6048(b)(1)(B) (relating to foreign trust reporting requirements).". (2) The table of sections for subpart B of part III of subchapter A of chapter 61 is amended by striking the item relating to section 6048 and inserting the following new item: "Sec. 6048. Information with respect to certain foreign trusts.". (3) The table of sections for part I of subchapter B of chapter 68 is amended by striking the item relating to section 6677 and inserting the following new item: "Sec. 6677. Failure to file information with respect to certain foreign trusts.". 26 USC 6048 (d) EFFECTIVE DATES. — note. (1) REPORTABLE EVENTS. —To the extent related to subsection (a) of section 6048 of the Internal Revenue Code of 1986, as amended by this section, the amendments made by this section shall apply to reportable events (as defined in such section 6048) occurring after the date of the enactment of this Act. (2) GRANTOR TRUST REPORTING.—To the extent related to subsection (b) of such section 6048, the amendments made by this section shall apply to taxable years of United States persons beginning after December 31, 1995. (3) REPORTING BY UNITED STATES BENEFICIARIES.— To the extent related to subsection (c) of such section 6048, the amendments made by this section shall apply to distributions received after the date of the enactment of this Act.