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H.R.4351 / 108th Congress

Tax Shelter Promoter Liability Act of 2004

Referred to the House Committee on Ways and Means.

Official summary

Version 00 · Introduced in House · May 12, 2004

Tax Shelter Promoter Liability Act of 2004 - Amends the Internal Revenue Code to increase the penalties for: (1) promoting abusive tax shelters; (2) aiding and abetting the understatement of tax liability; (3) failing to provide required information on potentially abusive tax shelters or for filing false or incomplete information; and (4) failing to maintain a client list of tax shelter investors.

Revises the penalty for failure to report interests in foreign financial accounts to impose a penalty for simple violations (current law imposes a penalty only for willful violations). Allows an exemption from the penalty for reasonable cause, except for willful violations.

Adds a new penalty for failure to include potentially abusive tax shelter information with a tax return or statement. Revises requirements for disclosure of potentially abusive tax shelters and requirements for material advisers with respect to potentially abusive tax shelters to keep client lists.

Disallows tax deductions for the penalties added or increased by this Act.

Extends the limitation period for assessing tax due to underpayments of tax attributable to undisclosed tax shelters.

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Who introduced it

Rep. Emanuel, Rahm [D-IL-5] · D–IL

Committees

  • Ways and Means Committee
2 cosponsorship records, including any withdrawals

Actions

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  1. Referred to the House Committee on Ways and Means.

  2. Introduced in House

  3. Introduced in House

Bill text & related measures

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Related bills identified by Congress.gov

No related bills are listed in this snapshot. This does not establish whether the proposal has appeared in earlier Congresses.

Source last updated: Aug 18, 2025. Consult Congress.gov for the current record.

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Individual rights and government power

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