Page 220

PUBLIC LAW 103-66—AUG. 10, 1993 107 STAT. 531 (f) OTHER LAW APPLICABLE.—^All provisions of law, including penalties, applicable with respect to tne taxes imposed by section 4091 of sucn Code shall, insoiar as applicable and not inconsistent with the provisions of this section, apply with respect to the floor stock taxes imposed by subsection (a) to the same extent as if such taxes were imposed by such section 4091. PART V—COMPLIANCE PROVISIONS SEC. 13251. MODIFICATIONS TO SUBSTANTIAL UNDERSTATEMENT PENALTY. (a) REASONABLE BASIS REQUIRED.—Clause (ii) of section 6662(dX2XB) (relating to reduction for imderstatement due to posi- tion of taxpayer or msclosed item) is amended to read as follows: 26 use 6662. **(ii) any item if— "(I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and "(II) there is a reasonable basis for the tax treatment of such item by the taxpayer." (b) EFFECTIVE DATE.—^The amendment made by this section 26 use 6662 shall apply to returns the due dates for which (determined without "°^^ regard to extensions) are after December 31,1993. SEC. 13252. RETURNS RELATING TO THE CANCELLATION OF INDEBT- EDNESS BY CERTAIN FINANCIAL ENTITIES. (a) IN GENERAL.—Subpart B of part III of subchapter A of chapter 61 (relating to information concerning transactions with other persons) is amended by adding at the end thereof the following new section: '^EC. 6050P. RETURNS RELATING TO THE CANCELLATION OF INDEBT- EDNESS BY CERTAIN FINANCIAL ENTITIES. "(a) IN GENERAL.—^Any applicable financial entity which dis- charges (in whole or in part) the indebtedness of any person during any calendar year shall make a return (at such time and in such form as the Secretary may by regulations prescribe) setting forth— "(1) the name, address, and TIN of each person whose indebtedness was discharged during such calendar year, "(2) the date of the discharge and the amount of the indebt- edness discharged, and "(3) such other information as the Secretary may prescribe, "(b) EXCEPTION.—Subsection (a) shall not apply to any discharge ofless than $600. "(c) DEFINITIGNS AND SPECIAL RULES.—For purposes of this section— "(1) APPLICABLE FINANCIAL ENTITY.—The term 'applicable financial entity* means— "(A) any financial institution described in section 581 or 591(a) and any credit union, "(B) the Federal Deposit Insurance Corporation, the Resolution Trust Corporation, the National Credit Union Administration, and any other Federal executive agency (as defined in section 6050M), and any successor or subunit of any of the foregoing, and (C) any other corporation which is a direct or indirect subsidiary of an entity referred to in subparagraph (A) but only if, by virtue of being affiliated with such entity.