103 STAT. 2338 PUBLIC LAW 101-239—DEC. 19, 1989 "(1) control (as defined in section 304(c)(l)) of a corporation is acquired by any person (or group of persons) in a transaction (or series of related transactions), or "(2) there is a recapitalization of a corporation or other substantial change in the capital structure of a corporation, when required by the Secretary, such corporation shall make a return (at such time and in such manner as the Secretary may prescribe) setting forth the identity of the parties to the transaction, the fees involved, the changes in the capital structure involved, and such other information as the Secretary may require with respect to
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such transaction. "(d) CROSS REFERENCES.^ "For provisions relating to penalties for failure to file— .^ "(1) a return under subsection (b), see section 6652(c), or "(2) a return under subsection (c), see section 6652(1)." (2) PENALTY.— Section 6652 is amended by redesignating subsection (L) as subsection (m) and by inserting after subsection (k) the following new subsection: "(1) FAILURE TO FILE RETURN WITH RESPECT TO CERTAIN COR- PORATE TRANSACTIONS. — In the case of any failure to make a return required under section 6043(c) containing the information required by such section on the date prescribed therefor (determined with regard to any extension of time for filing), unless it is shown that such failure is due to reasonable cause, there shall be paid (on notice and demand by the Secretary and in the ssime manner as tax) by the person failing to file such return, an amount equal to $500 for each day during which such failure continues, but the total amount imposed under this subsection with respect to any return shall not exceed $100,000. " (3) CONFORMING AMENDMENTS.— (A) The subsection heading for subsection (a) of section »• 6043 is amended by striking CORPORATIONS" and inserting "C ORPORATE LIQUIDATING, ETC., TR ANSACTIONS". (B) The section heading for section 6043 is amended to read as follows: "SEC. 6043. LIQUIDATING; ETC., TRANSACTIONS." ' (C) The table of sections for subpart B of part III of subchapter A of chapter 61 is amended by striking the item relating to section 6043 and inserting the following: -I* "Sec. 6043. Liquidating; etc., transactions." 26 USC 6043 (4) EFFECTIVE DATE.— The amendments made by this subsec- ^°*®- tion shall £^ply to transactions after March 31, 1990. SEC. 7209. ESTIMATED TAX PAYMENTS REQUIRED FOR S CORPORATIONS. . .
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(a) IN GENERAL.—Subsection (g) of section 6655 (relating to failure by corporation to pay estimated income tax) is amended by adding at the end thereof the following new paragraph: " (4) APPLICATION OF SECTION TO CERTAIN TAXES IMPOSED ON S CORPORATIONS.— In the case of an S corporation, for purposes of this section— "(A) The following taxes shall be treated as imposed by section 11: "(i) The tax imposed by section 1374(a) (or the cor- responding provisions of prior law).
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