118 STAT. 1572 PUBLIC LAW 108–357—OCT. 22, 2004 paid to any foreign country in respect of any gift which is taxable under this section solely by reason of this para graph.’’. (2) TRANSFERS OF CERTAIN STOCK.—Subsection (a) of section 2501 is amended by adding at the end the following new para graph: ‘‘(5) TRANSFERS OF CERTAIN STOCK.— ‘‘(A) IN GENERAL.—In the case of a transfer of stock in a foreign corporation described in subparagraph (B) by a donor to whom section 877(b) applies for the taxable year which includes the date of the transfer— ‘‘(i) section 2511(a) shall be applied without regard to whether such stock is situated within the United States, and ‘‘(ii) the value of such stock for purposes of this chapter shall be its U.S. asset value determined under subparagraph (C). ‘‘(B) FOREIGN CORPORATION DESCRIBED.—A foreign cor poration is described in this subparagraph with respect to a donor if— ‘‘(i) the donor owned (within the meaning of section 958(a)) at the time of such transfer 10 percent or more of the total combined voting power of all classes of stock entitled to vote of the foreign corporation, and ‘‘(ii) such donor owned (within the meaning of sec tion 958(a)), or is considered to have owned (by applying the ownership rules of section 958(b)), at the time of such transfer, more than 50 percent of— ‘‘(I) the total combined voting power of all classes of stock entitled to vote of such corporation, or ‘‘(II) the total value of the stock of such cor poration. ‘‘(C) U.S. ASSET VALUE.—For purposes of subparagraph (A), the U.S. asset value of stock shall be the amount which bears the same ratio to the fair market value of such stock at the time of transfer as— ‘‘(i) the fair market value (at such time) of the assets owned by such foreign corporation and situated in the United States, bears to ‘‘(ii) the total fair market value (at such time) of all assets owned by such foreign corporation.’’. (e) ENHANCED INFORMATION REPORTING FROM INDIVIDUALS LOSING UNITED STATES CITIZENSHIP.— (1) IN GENERAL.—Subsection (a) of section 6039G is amended to read as follows: ‘‘(a) IN GENERAL.—Notwithstanding any other provision of law, any individual to whom section 877(b) applies for any taxable year shall provide a statement for such taxable year which includes the information described in subsection (b).’’. (2) INFORMATION TO BE PROVIDED.—Subsection (b) of section 6039G is amended to read as follows: ‘‘(b) INFORMATION TO BE PROVIDED.—Information required under subsection (a) shall include— ‘‘(1) the taxpayer’s TIN, Applicability.
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