PUBLIC LAW 105-34—AUG. 5, 1997 111 STAT. 981 The Secretary may provide simplified filing procedures for foreign partnerships to which this section applies.". (b) SANCTION FOR FAILURE BY FOREIGN PARTNERSHIP TO COM- PLY WITH SECTION 6031 To INCLUDE DENIAL OF DEDUCTIONS.— Subsection (f) of section 6231 is amended— (1) by striking "LOSSES AND" in the heading and inserting "DEDUCTIONS, LOSSES, AND", and (2) by striking "loss or" each place it appears and inserting "deduction, loss, or". (c) EFFECTIVE DATE. —The amendments made by this section 26 USC 6031 shall apply to taxable years beginning after the date of the enact- note. ment of this Act. SEC. 1142. CONTROLLED FOREIGN PARTNERSHIPS SUBJECT TO INFORMATION REPORTING COMPARABLE TO INFORMA- TION REPORTING FOR CONTROLLED FOREIGN COR- PORATIONS. (a) IN GENERAL.— So much of section 6038 (relating to information with respect to certain foreign corporations) as precedes paragraph (2) of subsection (a) is amended to read as follows: "SEC. 6038. INFORMATION REPORTING WITH RESPECT TO CERTAIN FOREIGN CORPORATIONS AND PARTNERSHIPS. "(a) REQUIREMENT.— "(1) IN GENERAL.— Every United States person shall furnish, with respect to any foreign business entity which such person controls, such information as the Secretary may prescribe relating to— "(A) the name, the principal place of business, and the nature of business of such entity, and the country under whose laws such entity is incorporated (or organized in the case of a partnership); "(B) in the case of a foreign corporation, its post-1986 undistributed earnings (as defined in section 902(c)); "(C) a balance sheet for such entity listing assets, liabilities, and capital; "(D) transactions between such entity and— "(i) such person, "(ii) any corporation or partnership which such person controls, and "(iii) any United States person owning, at the time the transaction takes place— "(I) in the case of a foreign corporation, 10 percent or more of the value of any class of stock outstanding of such corporation, and "(II) in the case of a foreign partnership, at least a 10-percent interest in such partnership; and "(E)(i) in the case of a foreign corporation, a description of the various classes of stock outstanding, and a list showing the name and address of, and number of shares held by, each United States person who is a shareholder of record owning at any time during the annual accounting period 5 percent or more in value of any class of stock outstanding of such foreign corporation, and "(ii) information comparable to the information described in clause (i) in the case of a foreign partnership.
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