PUBLIC LAW 109–135—DEC. 21, 2005
119 STAT. 2629
‘‘(B) provides a statement in accordance with section 6039G (if such a statement is otherwise required). ‘‘(2) LONG-TERM RESIDENTS.—A long-term resident (as defined in section 877(e)(2)) who would (but for this paragraph) be described in section 877(e)(1) shall be treated as a lawful permanent resident of the United States and as not described in section 877(e)(1) until such individual— ‘‘(A) gives notice of termination of residency (with the requisite intent to terminate residency) to the Secretary of Homeland Security, and ‘‘(B) provides a statement in accordance with section 6039G (if such a statement is otherwise required).’’. (w) AMENDMENT RELATED TO SECTION 811 OF THE ACT.—Subsection (c) of section 811 of the American Jobs Creation Act of 2004 is amended by inserting ‘‘and which were not filed before such date’’ before the period at the end. (x) AMENDMENTS RELATED TO SECTION 812 OF THE ACT.— (1) Subsection (b) of section 6662 is amended by adding at the end the following new sentence: ‘‘Except as provided in paragraph (1) or (2)(B) of section 6662A(e), this section shall not apply to the portion of any underpayment which is attributable to a reportable transaction understatement on which a penalty is imposed under section 6662A.’’. (2) Paragraph (2) of section 6662A(e) is amended to read as follows: ‘‘(2) COORDINATION WITH OTHER PENALTIES.— ‘‘(A) COORDINATION WITH FRAUD PENALTY.—This section shall not apply to any portion of an understatement on which a penalty is imposed under section 6663. WITH GROSS VALUATION ‘‘(B) COORDINATION MISSTATEMENT PENALTY.—This section shall not apply to any portion of an understatement on which a penalty is imposed under section 6662 if the rate of the penalty is determined under section 6662(h).’’. (3) Subsection (f) of section 812 of the American Jobs Creation Act of 2004 is amended to read as follows: ‘‘(f) EFFECTIVE DATES.— ‘‘(1) IN GENERAL.—Except as provided in paragraph (2), the amendments made by this section shall apply to taxable years ending after the date of the enactment of this Act. ‘‘(2) DISQUALIFIED OPINIONS.—Section 6664(d)(3)(B) of the Internal Revenue Code of 1986 (as added by subsection (c)) shall not apply to the opinion of a tax advisor if— ‘‘(A) the opinion was provided to the taxpayer before the date of the enactment of this Act, ‘‘(B) the opinion relates to one or more transactions all of which were entered into before such date, and ‘‘(C) the tax treatment of items relating to each such transaction was included on a return or statement filed by the taxpayer before such date.’’. (y) AMENDMENT RELATED TO SECTION 814 OF THE ACT.— Subparagraph (B) of section 6501(c)(10) is amended by striking ‘‘(as defined in section 6111)’’. (z) AMENDMENT RELATED TO SECTION 815 OF THE ACT.—Paragraph (1) of section 6112(b) is amended by inserting ‘‘(or was required to maintain a list under subsection (a) as in effect before
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26 USC 6707A note. 26 USC 6662.
26 USC 6662 note.
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