A bill to amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Read twice and referred to the Committee on Finance.

S.765 through Congress

S.765 keeps its number as it moves between the House and Senate.

SenateApr 1, 2009IntroducedOfficial record

Major milestones in the imported record. See all actions.

No House action is available in our imported record yet.

Separate related House measures (1)

These are different measures identified as related by Congress.gov. Their text and outcomes may differ; they are not the House stage of S.765.

Related House bill: H.R.2143 To amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Congressional Research Service

Official summary

Version 00 · Introduced in Senate · Apr 1, 2009

Amends the Internal Revenue Code to: (1) allow a waiver of the penalty for failure to disclose reportable transactions (i.e., transactions which have a potential for tax avoidance or evasion) if such failure is due to reasonable cause and not due to willful neglect; (2) revise the amount of the penalty for such failure; and (3) limit the imposition of such penalty to the taxpayer (currently, any person).

Reaffirms the authority of the Commissioner of Internal Revenue to rescind all or any portion of the penalty for failure to furnish information regarding reportable transactions.

Read the summary on Congress.gov

PlainBill analysis is coming later. This page presents official source data. We have not yet published a PlainBill explanation for this bill.

People & committees

Who introduced it

Sen. Nelson, Ben [D-NE] · D–NE

Committees

Finance Committee

10 cosponsorship records, including any withdrawals

Legislative record

Actions

A procedural vote is different from passage. Passage in one chamber does not establish enactment. Explore the glossary.

Apr 1, 2009
Read twice and referred to the Committee on Finance.
Apr 1, 2009
Introduced in Senate

Primary sources

Bill text & related measures

Text links open the official source. We currently store references to these documents.

Introduced in Senate · Apr 1, 2009 Formatted Text PDF Formatted XML

Related bills identified by Congress.gov

HR 2143 · To amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Source last updated: Dec 5, 2025. Consult Congress.gov for the current record.

AI Conversation Starters

Explore the bill from different angles

Choose a perspective, copy a prompt, and paste it into your preferred AI. Each prompt includes the bill version and available official source links, and asks for counterarguments as well as supporting evidence.

Neutral evidence review

Objective

Analyze S.765 as objectively as possible. Explain its main provisions, who would be affected, possible benefits and harms, implementation, exceptions, and uncertainties. Present the strongest arguments for and against it, and identify evidence needed to assess its public impact.

View full prompt & sources

Discuss S.765, 111th Congress: A bill to amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Official record: https://www.congress.gov/bill/111th-congress/senate-bill/765

Text version to examine: Introduced in Senate · 2009-04-01.

Official full text: https://www.congress.gov/111/bills/s765/BILLS-111s765is.htm

Imported record last updated by the source: 2025-12-05T20:28:54Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Analyze S.765 as objectively as possible. Explain its main provisions, who would be affected, possible benefits and harms, implementation, exceptions, and uncertainties. Present the strongest arguments for and against it, and identify evidence needed to assess its public impact.

Fairness and public impact

Progressive lens

Examine S.765 through a progressive lens, focusing on fairness, access, economic inequality, and effects on vulnerable communities. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and distinguish stated goals from demonstrated outcomes.

View full prompt & sources

Discuss S.765, 111th Congress: A bill to amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Official record: https://www.congress.gov/bill/111th-congress/senate-bill/765

Text version to examine: Introduced in Senate · 2009-04-01.

Official full text: https://www.congress.gov/111/bills/s765/BILLS-111s765is.htm

Imported record last updated by the source: 2025-12-05T20:28:54Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Examine S.765 through a progressive lens, focusing on fairness, access, economic inequality, and effects on vulnerable communities. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and distinguish stated goals from demonstrated outcomes.

Institutions and government scope

Conservative lens

Examine S.765 through a conservative lens, focusing on fiscal responsibility, institutional stability, federalism, and the scope of government. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and any provisions that challenge this perspective.

View full prompt & sources

Discuss S.765, 111th Congress: A bill to amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Official record: https://www.congress.gov/bill/111th-congress/senate-bill/765

Text version to examine: Introduced in Senate · 2009-04-01.

Official full text: https://www.congress.gov/111/bills/s765/BILLS-111s765is.htm

Imported record last updated by the source: 2025-12-05T20:28:54Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Examine S.765 through a conservative lens, focusing on fiscal responsibility, institutional stability, federalism, and the scope of government. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and any provisions that challenge this perspective.

Individual rights and government power

Liberty lens

Examine S.765 through a civil-liberties and limited-government lens. Consider individual rights, privacy, voluntary choice, accountability, and government power. Explain tradeoffs, possible safeguards, and the strongest counterarguments without assuming the proposal is beneficial or harmful.

View full prompt & sources

Discuss S.765, 111th Congress: A bill to amend the Internal Revenue Code of 1986 to allow the Secretary of the Treasury to not impose a penalty for failure to disclose reportable transactions when there is reasonable cause for such failure, to modify such penalty, and for other purposes.

Official record: https://www.congress.gov/bill/111th-congress/senate-bill/765

Text version to examine: Introduced in Senate · 2009-04-01.

Official full text: https://www.congress.gov/111/bills/s765/BILLS-111s765is.htm

Imported record last updated by the source: 2025-12-05T20:28:54Z. Verify current status and distinguish any later version from the version above.

Read the official text before answering. If you cannot access it, say so and ask me to provide it; do not assume a link means you have read the document. Distinguish proposals from enacted law, cite sources, and separate facts, interpretation, and uncertain predictions. Include counterarguments even when using a particular perspective.

Examine S.765 through a civil-liberties and limited-government lens. Consider individual rights, privacy, voluntary choice, accountability, and government power. Explain tradeoffs, possible safeguards, and the strongest counterarguments without assuming the proposal is beneficial or harmful.