Sec. 1. Short title; etc

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This Act may be cited as the or Cut Unjustified Tax Loopholes Act . CUT Loopholes Act Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986. The table of contents of this Act is as follows: Sec. 1. Short title; etc. TITLE I—Ending offshore tax abuses Subtitle A—Deterring the use of tax havens for tax evasion Sec. 101.

Authorizing special measures against foreign jurisdictions, financial institutions, and others that significantly impede United States tax enforcement. Sec. 102. Strengthening the Foreign Account Tax Compliance Act (FATCA). Sec. 103. Treatment of foreign corporations managed and controlled in the United States as domestic corporations. Sec. 104. Reporting United States beneficial owners of foreign owned financial accounts. Sec. 105. Swap payments made from the United States to persons offshore.

Subtitle B—Other measures To combat tax haven and tax shelter abuses Sec. 111. Country-by-country reporting. Sec. 112. Penalty for failing to disclose offshore holdings. Sec. 113. Deadline for anti-money laundering rule for investment advisers. Sec. 114. Anti-money laundering requirements for formation agents. Sec. 115. Strengthening John Doe summons proceedings. Sec. 116. Improving enforcement of foreign financial account reporting. Subtitle C—Ending offshore tax avoidance Sec. 121.

Allocation of expenses and taxes on basis of repatriation of foreign income. Sec. 122. Excess income from transfers of intangibles to low-taxed affiliates treated as subpart F income. Sec. 123. Limitations on income shifting through intangible property transfers. Sec. 124. Limitation on earnings stripping by expatriated entities. Sec. 125. Repeal of check-the-box rules for certain foreign entities and CFC look-thru rules. Sec. 126. Prohibition on offshore loan abuse. TITLE II—Strengthening tax enforcement Subtitle A—Combating tax shelter promotion Sec. 201.

Penalty for promoting abusive tax shelters. Sec. 202. Penalty for aiding and abetting the understatement of tax liability. Sec. 203. Prohibited fee arrangement. Sec. 204. Preventing tax shelter activities by financial institutions. Sec. 205. Information sharing for enforcement purposes. Sec. 206. Disclosure of information to Congress. Sec. 207. Tax opinion standards for tax practitioners. Subtitle B—Simplify tax lien procedure Sec. 211. Short title. Sec. 212. Findings and purpose.

Sec. 213. National tax lien filing system. TITLE III—Ending excessive corporate tax deductions for stock options Sec. 301. Consistent treatment of stock options by corporations. Sec. 302. Application of executive pay deduction limit. TITLE IV—Closing the derivatives blended rate loophole Sec. 401. Short title. Sec. 402. Modifications to treatment of section 1256 contracts. Sec. 403. Modifications to treatment of dealers in securities and commodities. TITLE V—Ending the tar sands oil spill loophole Sec. 501.

Short title. Sec. 502. Requirements for contribution to the Oil Spill Liability Trust Fund. Sec. 503. Extension of Oil Spill Liability Trust Fund financing rate. Sec. 504. Technical amendment. TITLE VI—Ending the carried interest loophole Sec. 601. Short title; etc. Sec. 602. Partnership interests transferred in connection with performance of services. Sec. 603. Special rules for partners providing investment management services to partnerships.