With the recent focus in the media on abuse of the tax laws and the continuing Internal Revenue Service crackdown on tax shelters, pressure is building in Congress to provide the IRS with some additional tools to address abusive tax shelters, post-Enron corporate governance, and expatriation issues. The Senate included a fairly significant package of provisions covering each of these areas in the international tax reform legislation that it passed on May 11, 2004.

The House, which has been struggling to find an international tax reform bill that can attract sufficient votes for passage, now appears to be moving toward a consensus bill using the Senate bill as a guide. The draft House proposal also includes a number of provisions related to tax shelters, expatriation and corporate governance, although it is generally viewed as more restrained than the Senate version.

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