Amends the Internal Revenue Code to: (1) establish a six year limitation period on assessment and collection of tax for tax returns involving offshore secrecy jurisdictions (defined as foreign jurisdictions which unreasonably restrict information required to enforce U.S. tax laws and which have ineffective information exchange practices); (2) suspend the limitation period for assessment and collection of tax while a summons for tax records involving a foreign jurisdiction is pending; (3) extend the limitation period during any failure by a taxpayer to give notice of certain foreign transactions; and (4) extend the period for collection of tax after assessment in the case of a willful attempt to evade or defeat payment of tax to 10 years after such attempt.