(2) the aggregate amount of payments to the person as shown on such return.

The written statement required under the preceding sentence shall be furnished to the person on or before January 31 of the year following the calendar year for which the return under subsection (a)(1) was made. No statement shall be required to be furnished to any person under this subsection if the aggregate amount of payments to such person as shown on the return made under subsection (a)(1) is less than $10.

(d) Statements to be furnished by corporations to Secretary

Every corporation shall, when required by the Secretary—

(1) furnish to the Secretary a statement stating the name and address of each shareholder, and the number of shares owned by each shareholder;

(2) furnish to the Secretary a statement of such facts as will enable him to determine the portion of the earnings and profits of the corporation (including gains, profits, and income not taxed) accumulated during such periods as the Secretary may specify, which have been distributed or ordered to be distributed, respectively, to its shareholders during such taxable years as the Secretary may specify; and

(3) furnish to the Secretary a statement of its accumulated earnings and profits and the names and addresses of the individuals or shareholders who would be entitled to such accumulated earnings and profits if divided or distributed, and of the amounts that would be payable to each.

(Aug. 16, 1954, ch. 736, 68A Stat. 746; Oct. 16, 1962, Pub. L. 87-834, § 19(a), 76 Stat. 1053; Oct. 4. 1976, Pub. L. 94-455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834; Sept. 3, 1982, Pub. L. 97-248, title III, §§ 303(a), 308(a), 96 Stat. 587, 591; Oct. 19, 1982, Pub. L. 97-354, § 5(a)(40), 96 Stat. 1696.)

AMENDMENTS

1982-Subsecs. (a)(1), (c), (e). Pub. L. 97-248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, this section is amended as provided below. Section 102(a), (b) of Pub. L. 98-67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301-308) of title III of Pub. L. 97-248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 (this title) shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. The amendments to this section were as follows:

(1) Subsec. (a)(1) was amended by striking out "or" at the end of subpar. (A), by inserting "or" at the end of subpar. (B), by inserting after subpar. (B) the following new subpar. "(C) who is required to withhold tax under section 3451 on any payment of dividends,", by striking out the period at the end thereof, and by inserting the following at the end thereof ", and, in the case of a payment upon which tax is withheld, the amount of tax withheld."

(2) Subsec. (c) was amended by striking out "and" at the end of par. (1), by striking out the period at the end of par. (2) and inserting in lieu thereof ", and", by inserting after par. (2) the following par.

"(3) the amount of tax withheld under section 3451.", and by striking out "No statement" in the last sentence thereof and inserting in lieu thereof "Except in the case of a return required by reason of subparagraph (C) of subsection (a)(1), no statement".

(3) A new subsec. (e) was added at the end to read as follows:

"(e) Duplicate of subsection (c) statement may be requested to be filed with Secretary

"A duplicate of any statement made pursuant to subsection (c) which is required to set forth an amount withheld under section 3451 shall, when required by regulations prescribed by the Secretary, be filed with the Secretary."

Subsec. (b)(2). Pub. L. 97-354 redesignated cl. (A)(i) as subpar. (A) and cl. (A)(ii) as subpar. (B). Former subpar. (B), excluding from the term "dividends" any amount described in section 1373 (relating to undistributed taxable income of electing small business corporations), was struck out.

1976-Pub. L. 94-455 struck out "or his delegate" following "Secretary" wherever appearing.

1962-Pub. L. 87-834 substituted "Returns regarding payments of dividends and corporate earnings and profits" for "Returns regarding corporate dividends, earnings, and profits" in the section catchline, added subsecs. (a) to (c), designated existing provisions of section as subsec. (d), and substituted in par. (1) of subsec. (d) "furnish to the Secretary or his delegate a statement stating the name and address of each shareholder, and the number of shares owned by each shareholder" for "Make a return of its payments of dividends, stating the name and address of, the number of shares owned by, and the amount of dividends paid to, each shareholder."

EFFECTIVE DATE OF 1982 AmendmenT Amendment by Pub. L. 97-354 applicable to taxable years beginning after Dec. 31, 1982, see section 6(a) of Pub. L. 97-354, set out as an Effective Date note under section 1361 of this title.

EFFECTIVE DATE OF 1962 AMENDMENT Section 19(h) of Pub. L. 87-834 provided that: "(1) DIVIDENDS AND INTEREST.-The amendments made by this section [adding sections 6049 and 6678 of this title and amending sections 6041, 6042, 6044 and 6052 of this title] shall apply to payments of dividends and interest made on or after January 1, 1963.

“(2) PATRONAGE DIVIDENDS.-The amendments made by this section [adding sections 6049 and 6678 of this title and amending sections 6041, 6042, 6044 and 6052 of this title] shall apply to payments of amounts described in section 6044(b) of the Internal Revenue Code of 1954 made on or after January 1, 1963, with respect to patronage occurring on or after the first day of the first taxable year of the cooperative beginning on or after January 1, 1963."

CROSS REFERENCES

Failure to file income tax return, additions to tax for, see section 6652 of this title.

Wilful failure to supply information, punishment for, see section 7203 of this title.

SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 3402, 6041, 6652, 6678 of this title.

§ 6043. Returns regarding liquidation, dissolution, termination, or contraction

(a) Corporations

Every corporation shall—

(1) Within 30 days after the adoption by the corporation of a resolution or plan for the

dissolution of the corporation or for the liquidation of the whole or any part of its capital stock, make a return setting forth the terms of such resolution or plan and such other information as the Secretary shall by forms or regulations prescribe; and

(2) When required by the Secretary, make a return regarding its distributions in liquidation, stating the name and address of, the number and class of shares owned by, and the amount paid to, each shareholder, or, if the distribution is in property other than money, the fair market value (as of the date the distribution is made) of the property distributed to each shareholder.

(b) Exempt organizations

Every organization which for any of its last 5 taxable years preceding its liquidation, dissolution, termination, or substantial contraction was exempt from taxation under section 501(a) shall file such return and other information with respect to such liquidation, dissolution, termination, or substantial contraction as the Secretary shall by forms or regulations prescribe; except that

(1) no return shall be required under this subsection from churches, their integrated auxiliaries, conventions or associations of churches, or any organization which is not a private foundation (as defined in section 509(a)) and the gross receipts of which in each taxable year are normally not more than $5,000, and

(2) the Secretary may relieve any organization from such filing where he determines that such filing is not necessary to the efficient administration of the internal revenue laws or, with respect to an organization described in section 401(a), where the employer who established such organization files such a return.

(c) Cross reference

For provisions relating to penalties for failure to file a return required by subsection (b), see section 6652(d). (Aug. 16, 1954, ch. 736, 68A Stat. 746; Dec. 30, 1969, Pub. L. 91-172, title I, § 101(j)(35), 83 Stat. 529; Oct. 4, 1976, Pub. L. 94-455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834.)

AMENDMENTS

1976-Pub. L. 94-455 struck out “or his delegate" following "Secretary" wherever appearing.

1969-Pub. L. 91-172 inserted references to termination and contraction in the section catchline, designated existing provisions as subsec. (a), and added subsecs. (b) and (c).

EFFECTIVE DATE OF 1969 AMENDMENT Amendment by Pub. L. 91-172 applicable to taxable years beginning after Dec. 31, 1969, see section 101(k)(2)(B) of Pub. L. 91-172, set out as an Effective Date note under section 4940 of this title.

CROSS REFERENCES

Partial liquidation defined, see section 346 of this title.

SECTION REFERRED TO IN OTHER SECTIONS

This section is referred to in sections 6033, 6652 of this title.

§ 6044. Returns regarding payments of patronage dividends

(a) Requirement of reporting

(1) In general

Except as otherwise provided in this section, every cooperative to which part I of subchapter T of chapter 1 applies, which makes payments of amounts described in subsection (b) aggregating $10 or more to any person during any calendar year, shall make a return according to the forms of regulations prescribed by the Secretary, setting forth the aggregate amount of such payments and the name and address of the person to whom paid.

(2) Returns required by the Secretary

Every such cooperative which makes payments of amounts described in subsection (b) aggregating less than $10 to any person during any calendar year shall, when required by the Secretary, make a return setting forth the aggregate amount of such payments and the name and address of the person to whom paid.

(b) Amounts subject to reporting

(1) General rule

Except as otherwise provided in this section, the amounts subject to reporting under subsection (a) are

(A) the amount of any patronage dividend (as defined in section 1388(a)) which is paid in money, qualified written notices of allocation (as defined in section 1388(c)), or other property (except nonqualified written notices of allocation as defined in section 1388(d)),

(B) any amount described in section 1382(c)(2)(A) (relating to certain nonpatronage distributions) which is paid in money, qualified written notices of allocation, or other property (except nonqualified written notices of allocation) by an organization exempt from tax under section 521 (relating to exemption of farmers' cooperatives from tax),

(C) any amount described in section 1382(b)(2) (relating to redemption of nonqualified written notices of allocation) and, in the case of an organization described in section 1381(a)(1), any amount described in section 1382(c)(2)(B) (relating to redemption of nonqualified written notices of allocation paid with respect to earnings derived from sources other than patronage), and

(D) the amount of any per-unit retain allocation (as defined in section 1388(f)) which is paid in qualified per-unit retain certificates (as defined in section 1388(h)), and

(E) any amount described in section 1382(b)(4) (relating to redemption of nonqualified per-unit retain certificates). (2) Exceptions

The provisions of subsection (a) shall not apply, to the extent provided in regulations prescribed by the Secretary, to any payment

(A) by a foreign corporation, or

(B) to a foreign corporation, a nonresident alien, or a partnership not engaged in trade or business in the United States and composed in whole or in part of nonresident aliens.

(c) Exemption for certain consumer cooperatives

A cooperative which the Secretary determines is primarily engaged in selling at retail goods or services of a type that are generally for personal, living, or family use shall, upon application to the Secretary, be granted exemption from the reporting requirements imposed by subsection (a). Application for exemption under this subsection shall be made in accordance with regulations prescribed by the Secretary.

(d) Determination of amount paid

For purposes of this section, in determining the amount of any payment

(1) property (other than a qualified written notice of allocation or a qualified per-unit retain certificate) shall be taken into account at its fair market value, and

(2) a qualified written notice of allocation or a qualified per-unit retain certificate shall be taken into account at its stated dollar amount.

(e) Statements to be furnished to persons with respect to whom information is furnished

Every cooperative making a return under subsection (a)(1) shall furnish to each person whose name is set forth in such return a written statement showing

(1) the name and address of the cooperative making such return, and

(2) the aggregate amount of payments to the person as shown on such return. The written statement required under the preceding sentence shall be furnished to the person on or before January 31 of the year following the calendar year for which the return under subsection (a)(1) was made. No statement shall be required to be furnished to any person under this subsection if the aggregate amount of payments to such person as shown on the return made under subsection (a)(1) is less than $10.

(Aug. 16, 1954, ch. 736, 68A Stat. 746; Oct. 16, 1962, Pub. L. 87-834, § 19(b), 76 Stat. 1054; Nov. 13, 1966, Pub. L. 89-809, title II, § 211(d), 80 Stat. 1584; Oct. 4, 1976, Pub. L. 94-455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834; Sept. 3, 1982, Pub. L. 97-248, title III, §§ 304, 308(a), 96 Stat. 587, 591.)

AMENDMENTS

1982-Subsecs. (a)(1), (b)(1), (e), (f). Pub. L. 97-248 provided that, applicable to payments of interest, dividends, and patronage dividends paid or credited after June 30, 1983, this section is amended as provided below. Section 102(a), (b) of Pub. L. 98-67, title I, Aug. 5, 1983, 97 Stat. 369, repealed subtitle A (§§ 301-308) of Pub. L. 97-248 as of the close of June 30, 1983, and provided that the Internal Revenue Code of 1954 (this title) shall be applied and administered (subject to certain exceptions) as if such subtitle A (and the amendments made by such subtitle A) had not been enacted. The amendments to this section were as follows:

(a) Subsec. (a)(1) was amended to read as follows: "(1) In general

"Except as otherwise provided in this section, every cooperative to which part I of subchapter T of chapter 1 applies which

"(A) makes payments of amounts described in subsection (b) aggregating $10 or more to any person during any calendar year, or

"(B) is required to withhold any tax under section 3451,

shall make a return according to the forms or regulations prescribed by the Secretary, setting forth the aggregate amount of such payments, the name and address of the person to whom paid, and the amount of tax withheld."

(b) Subsec. (b)(1) was amended by striking out "under subsection (a)", and by inserting "under paragraph (1)(A) or (2) of subsection (a)”.

(c) Subsec. (e) was amended by striking out "and" at the end of par. (1), by striking out the period at the end of par. (2) and inserting ", and" in lieu thereof, by inserting after par. (2) the following par. "(3) the amount of tax withheld under section 3451.", and by striking out "No statement" in the last sentence thereof and inserting in lieu thereof "Except in the case of a return required by reason of subparagraph (B) of subsection (a)(1), no statement".

(d) A new subsec. (f) was added at the end to read as follows:

"(f) Duplicate of subsection (e) statement may be required to be filed with Secretary

"A duplicate of any statement made pursuant to subsection (e) which is required to set forth an amount withheld under section 3451 shall, when required by regulations prescribed by the Secretary, be filed with the Secretary."

1976-Pub. L. 94-455 struck out "or his delegate" following "Secretary" wherever appearing.

1966-Subsec. (b)(1). Pub. L. 89-809, § 211(d)(1), added subpars. (D) and (E).

Subsec. (d). Pub. L. 89-809, § 211(d)(2), inserted references to qualified per-unit retain certificates.

1962-Pub. L. 87-834 substituted "Returns regarding payments of patronage dividends" for "Returns regarding patronage dividends" in section catchline.

Subsec. (a). Pub. L. 87-834 amended subsection generally to read as above set forth. Prior to such amendment, subsection read as follows:

"(a) PAYMENTS OF $100 OR MORE.-Any Corporation allocating amounts as patronage dividends, rebates, or refunds (whether in cash, merchandise, capital stock, revolving fund certificates, retain certificates, certificates of indebtedness, letters of advice, or in some other manner that discloses to each patron the amount of such dividend, refund, or rebate) shall make a return showing

"(1) The name and address of each patron to whom it has made such allocations amounting to $100 or more during the calendar year; and

"(2) The amount of such allocations to each patron."

Subsec. (b). Pub. L. 87-834 amended subsection generally to read as above set forth. Prior to such amendment, subsection read as follows:

"(b) PAYMENTS REGARDLESS OF AMOUNT.-If required by the Secretary or his delegate, any such corporation shall make a return of all patronage dividends, rebates, or refunds made during the calendar year to its patrons."

Subsec. (c). Pub. L. 87-834 amended subsection generally to read as above set forth. Prior to such amendment, subsection read as follows:

"(c) EXCEPTIONS.-This section shall not apply in the case of any corporation (including any cooperative or nonprofit corporation engaged in rural electrification) described in section 501(c)(12) or (15) which is exempt

from tax under section 501(a), or in the case of any corporation subject to a tax imposed by subchapter L of chapter 1.”

Subsecs. (d), (e). Pub. L. 87-834 added subsecs. (d) and (e).

EFFECTIVE DATE OF 1966 AmendmeNT

Amendment by section 211 of Pub. L. 89-809 applicable with respect to calendar years after 1966, see section 211(e)(2) of Pub. L. 89-809, set out as a note under section 1382 of this title.

EFFECTIVE DATE OF 1962 AmendmenNT Amendment by Pub. L. 87-834 applicable to payments of dividends and interest made on or after Jan. 1, 1963, and to payments of amounts described in subsection (b) of this section made on or after Jan. 1, 1963, with respect to patronage occurring on or after the first day of the first taxable year of the cooperative beginning on or after Jan. 1, 1963, see section 19(h) of Pub. L. 87-834, set out as a note under section 6042 of this title.

CROSS REFERENCES

Failure to file income tax return, additions to tax for, see section 6652 of this title.

SECTION REFERRED TO IN OTHER SECTIONS

This section is referred to in sections 3402, 6041, 6652, 6678 of this title.

§ 6045. Returns of brokers

(a) General rule

Every person doing business as a broker shall, when required by the Secretary, make a return, in accordance with such regulations as the Secretary may prescribe, showing the name and address of each customer, with such details regarding gross proceeds and such other information as the Secretary may by forms or regulations require with respect to such business. (b) Statements to be furnished to customers

Every person making a return under subsection (a) shall furnish to each customer whose name is set forth in such return a written statement showing

(1) the name and address of the person making such return, and

(2) the information shown on such return with respect to such customer.

The written statement required under the preceding sentence shall be furnished to the customer on or before January 31 of the year following the calendar year for which the return under subsection (a) was made.

(c) Definitions

For purposes of this section(1) Broker

The term "broker" includes

(A) a dealer,

(B) a barter exchange, and

(C) any other person who (for a consideration) regularly acts as a middleman with respect to property or services.

(2) Customer

The term "customer" means any person for whom the broker has transacted any busi

ness.

(3) Barter exchange

The term "barter exchange" means any organization of members providing property or services who jointly contract to trade or barter such property or services.

(Aug. 16, 1954, ch. 736, 68A Stat. 747; Oct. 4, 1976, Pub. L. 94-455, title XIX, § 1906(b)(13)(A), 90 Stat. 1834; Sept. 3, 1982, Pub. L. 97-248, title III, § 311(a)(1), 96 Stat. 600.)

AMENDMENTS

1982-Pub. L. 97-248 designated existing provisions as subsec. (a), and in subsec. (a) as so designated, substituted "the name and address of each customer, with such details regarding gross proceeds" for "the names of customers for whom such person has transacted any business, with such details regarding the profits and losses" after "may prescribe, showing" and "such business" for "each customer as will enable the Secretary to determine the amount of such profits and losses" after "with respect to", and added subsecs. (b) and (c).

1976-Pub. L. 94-455 struck out "or his delegate" following "Secretary" wherever appearing.

EFFECTIVE DATE OF 1982 Amendment

Section 311(c)(1) of Pub. L. 97-248 provided that: "The amendments made by subsection (a) [amending sections 6045 and 6678 of this title] shall take effect on the date of the enactment of this Act [Sept. 3, 1982], except that

"(A) regulations relating to reporting by commodities and securities brokers shall be issued under section 6045 of the Internal Revenue Code of 1954 (as amended by this Act) within 6 months after the date of the enactment of this Act [Sept. 3, 1982], and

"(B) such regulations shall not apply to transactions occurring before January 1, 1983."

CROSS REFERENCES

Failure to file income tax return, additions to tax for, see section 6652 of this title. Willful failure to supply information, punishment for, see section 7203 of this title.

SECTION REFERRED TO IN OTHER SECTIONS This section is referred to in sections 3402, 6041, 6049, 6652, 6678, 7609 of this title.

§ 6046. Returns as to organization or reorganization of foreign corporations and as to acquisitions of their stock

(a) Requirement of return

A return complying with the requirements of subsection (b) shall be made by

(1) each United States citizen or resident who is on January 1, 1963, an officer or director of a foreign corporation, 5 percent or more in value of the stock of which is owned by a United States person (as defined in section 7701(a)(30)), or who becomes such an officer or director at any time after such date, (2) each United States person who on January 1, 1963, owns 5 percent or more in value of the stock of a foreign corporation, or who, at any time after such date

(A) acquires stock which, when added to any stock owned on January 1, 1963, has a value equal to 5 percent or more of the value of the stock of a foreign corporation, or

(B) acquires an additional 5 percent or more in value of the stock of a foreign corporation, and

(3) each person who at any time after January 1, 1963, becomes a United States person while owning 5 percent or more in value of the stock of a foreign corporation.

(b) Form and contents of returns

The returns required by subsection (a) shall be in such form and shall set forth, in respect of the foreign corporation, such information as the Secretary prescribes by forms or regulations as necessary for carrying out the provisions of the income tax laws, except that in the case of persons described only in subsection (a)(1) the information required shall be limited to the names and addresses of persons described in subsection (a)(2).

(c) Ownership of stock

For purposes of subsection (a), stock owned directly or indirectly by a person (including, in the case of an individual, stock owned by members of his family) shall be taken into account. For purposes of the preceding sentence, the family of an individual shall be considered as including only his brothers and sisters (whether by the whole or half blood), spouse, ancestors, and lineal descendants.

(d) Time for filing

Any return required by subsection (a) shall be filed on or before the 90th day after the day on which, under any provision of subsection (a), the United States citizen, resident, or person becomes liable to file such return (or on or before such later day as the Secretary may by forms or regulations prescribe). (e) Limitation

No information shall be required to be furnished under this section with respect to any foreign corporation unless such information was required to be furnished under regulations which have been in effect for at least 90 days before the date on which the United States citizen, resident, or person becomes liable to file a return required under subsection (a).

(f) Cross reference

For provisions relating to penalties for violations of this section, sections 6679 and 7203.

(Aug. 16, 1954, ch. 736, 68A Stat. 747; Sept. 14, 1960, Pub. L. 86-780, § 7(a), 74 Stat. 1016; Oct. 16, 1962, Pub. L. 87-834, § 20(b), 76 Stat. 1061; Oct. 4, 1976, Pub. L. 94-455, title XIX, § 1906(a)(4), (b)(13)(A), 90 Stat. 1824, 1834; Sept. 3, 1982, Pub. L. 97-248, title III, § 341(a), 96 Stat. 635.)

AMENDMENTS

1982-Subsec. (d). Pub. L. 97-248 added "(or on or before such later day as the Secretary may by forms or regulations prescribe)" at the end.

1976-Subsec. (b). Pub. L. 94-455, § 1906(b)(13)(A), struck out "or his delegate" following "Secretary".

Subsec. (e). Pub. L. 94-455, § 1906(a)(4), struck out provisions relating to the requirement for information to be furnished in the case of liability to file a return under subsec. (a) of this section arising on or after Jan. 1, 1963, and before June 1, 1963, under regulations in effect on or before June 1, 1963.

1962-Pub. L. 87-834 substituted "organization or reorganization of foreign corporations and as to acquisitions of their stock" for "creation or organization, or reorganization, of foreign corporations" in section catchline.

Subsec. (a). Pub. L. 87-834 amended subsection generally to read as above set forth. Prior to such amendment, subsection read as follows:

"(a) GENERAL RULE.-On or before the 90th day after the creation or organization, or reorganization, of any foreign corporation

"(1) Each United States citizen or resident who was an officer or director of the corporation at any time within 60 days after the creation or organization, or reorganization thereof, and

"(2) Each United States shareholder of the corporation by or for whom, at any time within 60 days after the creation or organization or reorganization of the corporation, 5 percent or more in value of the stock of the corporation outstanding was owned directly or indirectly (including, in the case of an individual, stock owned by members of his family), shall make a return in compliance with the provisions of subsection (b)."

Subsec. (b). Pub. L. 87-834 inserted the exception providing that in the case of persons described only in subsec. (a)(1) the information required shall be limited to the names and addresses of persons described in subsec. (a)(2).

Subsec. (c). Pub. L. 87-834 substituted provisions requiring, for purposes of subsec. (a), stock owned directly or indirectly by a person (including, in the case of an individual, stock owned by members of his family) to be taken into account for provisions which defined "United States shareholder".

Subsec. (d). Pub. L. 87-834 added subsec. (d) and redesignated former subsec. (d) as (f).

Subsec. (e). Pub. L. 87-834 added subsec. (e). Subsec. (f). Pub. L. 87-834 redesignated former subsec. (d) as (f) and inserted a reference to section 6679 of this title.

1960-Catchline amended by Pub. L. 86-780 which substituted "Returns as to creation or organization, or reorganization, of foreign corporations" for "Returns as to formation or reorganization of foreign corporations".

Subsec. (a). Pub. L. 86-780 substituted requirement that returns relating to the creation, organization, or reorganization of foreign corporations be made by every citizen or resident of the United States who was an officer or director of the corporation at any time within 60 days after its creation, organization, or reorganization, and by every United States shareholder of the corporation owning at least 5 percent of its outstanding stock at any time within such 60 days for requirement that every attorney, accountant, fiduciary, bank, trust company, financial institution, or other person, who advises as to the formation or reorganization of a foreign corporation, file a return in accordance with regulations prescribed by the Secretary of the Treasury or his delegate.

Subsec. (b). Pub. L. 86-780 reenacted the substance of subsec. (b), eliminating the phrase "to the full extent of the information within the possession or knowledge or under the control of the person required to make the return" preceding "such information".

Subsec. (c). Pub. L. 86-780 added the provisions defining United States shareholder and members of family and eliminated provision relating to the making of a return by an attorney-at-law with respect to privileged communications.

EFFECTIVE Date of 1982 Amendment Section 341(c) of Pub. L. 97-248 provided that: "The amendments made by this section [amending sections 6046 and 6048 of this title] shall apply to returns filed after the date of the enactment of this Act [Sept. 3, 1982]."