123STA T . 2 9 9 6PUBLIC LA W 111 – 92 —NOV .6 , 2 0 09 amil i t a ryb a se reali gn ment o r c los u re ’ ’an d inserting ‘ ‘t h e A merican R eco v ery and Reinvestment T a x Act o f20 0 9) ’’ , and ( 2) in sub p aragraph (2) by stri k ing ‘‘clause ( 1 ) of’’ . (b) EF F ECTIV E DA TE. — The amendments made by this act shall apply to payments made after F ebruary 1 7 , 2009. SEC.15 . D E LAYIN A P PLICA T I O NO FW O R LDWIDE ALLOCATION OF INTEREST. (a) ING ENE R A L .— P aragraphs ( 5 )(D) and ( 6 ) of section 8 6 4 (f) of the Internal Revenue C ode of 1986 are each amended by striking ‘‘December 3 1, 2010’’ and inserting ‘‘December 31, 2017’’. (b) C O NFOR M IN G AMEN D MENT.— S ection 864(f) of the Internal Revenue Code of 1986 is amended by striking paragraph (7). (c) EFFECTIVE DATE S .—The amendments made by this section shall apply to taxable years beginning after December 31, 2010. SEC. 1 6 . INCREASE IN PENALTY FOR FAIL U RE TO FILE A PARTNERS H IP OR S CORPORATION RETURN. (a) IN GENERAL.—Sections 6698(b)(1) and 6699(b)(1) of the Internal Revenue Code of 1986 are each amended by striking ‘‘ $ 89’’ and inserting ‘‘$195’’. (b) EFFECTIVE DATE.—The amendments made by this section shall apply to returns for taxable years beginning after December 31, 2009. SEC. 1 7 . CERTAIN TA X RETURN PREPARERS RE Q UIRED TO FILE RETURNS ELECTRONICALLY. (a) IN GENERAL.—Subsection (e) of section 6011 of the Internal Revenue Code of 1986 is amended by adding at the end the follo w ing new paragraph
‘‘(3) S P ECIAL R U LE FOR TA X RETURN PREPARERS.— ‘‘(A) IN GENERAL.—The Secretary shall re q uire than any individual income tax return prepared by a tax return preparer be filed on magnetic media if— ‘‘(i) such return is filed by such tax return pre - parer, and ‘‘(ii) such tax return preparer is a specified tax return preparer for the calendar year during which such return is filed. ‘‘( B ) SPECIFIED TAX RETURN PREPARER.—For purposes of this paragraph, the term ‘specified tax return preparer’ means, with respect to any calendar year, any tax return preparer unless such preparer reasonably expects to file 10 or fewer individual income tax returns during such calendar year. ‘‘(C) INDIVIDUAL INCOME TAX RETURN.—For purposes of this paragraph, the term ‘individual income tax return’ means any return of the tax imposed by subtitle A on individuals, estates, or trusts.’’. (b) CONFORMING AMENDMENT.—Paragraph (1) of section 6011(e) of the Internal Revenue Code of 1986 is amended by striking ‘‘The Secretary may not’’ and inserting ‘‘Except as provided in paragraph (3), the Secretary may not’’. (c) EFFECTIVE DATE.—The amendments made by this section shall apply to returns filed after December 31, 2010. 26USC 6 01 1 note. 26 USC 6011. 26 USC 66 98 note. 26 USC 6698 , 6699. 26 USC 86 4 note. 26 USC 864. 26USC1 3 2 note.
