Doubles the penalty for certain tax accuracy related underpayments.
Penalizes the promoter of tax avoidance strategies which have no economic substance in an amount equal to 100 percent of the gross income derived.
Modifies provisions concerning penalties for aiding and abetting understatement of tax liability, including adding provisions directed specifically at individuals who advise, represent, or procure certain tax shelters failing to meet legal requirements.
Revises provisions concerning the failure to maintain lists of investors in potentially abusive tax shelters to set the penalty for certain violations at 50 percent of gross proceeds.
Creates a new penalty, the penalty for failure to include tax shelter information with a return.
Requires the registration of certain tax shelters without corporate participants.
Revises provisions concerning the determination of the basis of corporations to state as a general rule that, with respect to property acquired by the issuance of stock or as paid-in surplus and transfers to corporations, if there would be (but for this paragraph) an importation of a net built-in loss, the basis of specified property acquired in such transaction shall be its fair market value immediately after such transaction.
Revises provisions concerning partnerships with respect to: (1) the treatment of contributed property with a built-in loss; (2) the adjustment of partnership property on the transfer of a partnership interest if there is a substantial built-in loss; and (3) the adjustment to the basis of undistributed partnership property if there is a substantial basis reduction.