This bill authorizes the Department of the Treasury to impose restrictions on foreign jurisdictions or financial institutions to counter money laundering and efforts to significantly impede U.S. tax enforcement.

Among other provisions, the bill

• expands reporting requirements for certain foreign investments and accounts held by U.S. persons,
• establishes a rebuttable presumption against the validity of transactions by institutions that do not comply with reporting requirements under the Foreign Account Tax Compliance Act,
• treats certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes,
• treats swap payments sent offshore as taxable U.S. source income,
• requires corporations to disclose certain financial information on a country-by-country basis,
• imposes penalties for failing to disclose offshore holdings,
• modifies the base erosion anti-abuse tax to lower the gross receipts applicability threshold from $500 million to $100 million,
• makes investment advisers and persons engaged in forming new business entities subject to new anti-money laundering requirements,
• requires reporting of U. S. beneficial owners of foreign-owned financial accounts, and
• imposes additional requirements for third party summonses used to obtain information in tax investigations that do not identify the person with respect to whose liability the summons is issued (i.e., John Doe summons).