Think it is really interesting reading, also since it looks like facts and not roumours 
TITLE I – Deterring the Use of Offshore Secrecy Jurisdictions for Tax Evasion
Establish presumptions for entities and transactions in Offshore Secrecy Jurisdictions. (§101)
Establishes rebuttable evidentiary presumptions in tax and securities legal proceedings for non publicly-traded entities located in Offshore Secrecy Jurisdictions. The presumptions are as follows:
Control – In a tax proceeding, if a U.S. person (other than a publicly-traded corporation) directly or indirectly formed, transferred assets to, was a beneficiary of, had a beneficial interest in, or received assets from an Offshore Secrecy Jurisdiction entity (other than a publicly-traded corporation), it will be presumed that the person exercised control over the entity.
Transfers of income – In a tax proceeding, any amount or thing of value –
a) transferred to a U.S. person (other than a publicly-traded corporation) directly or indirectly from an account or entity in an Offshore Secrecy Jurisdiction, or
b) transferred from such a U.S. person directly or indirectly to an account or entity in an Offshore Secrecy Jurisdiction, will be presumed to represent previously unreported income to the U.S. person in the year of transfer.
Beneficial ownership – In a proceeding to enforce securities law, if a U.S. person (other than a publicly-traded corporation) formed, transferred assets to, was a beneficiary of, had a beneficiary interest in, or received assets from an Offshore Secrecy Jurisdiction entity (other than a publicly-traded corporation), it will be presumed that the person beneficially owned and exercised control over such entity, regardless of the nominal ownership.
TITLE I – Deterring the Use of Offshore Secrecy Jurisdictions for Tax Evasion
Establish presumptions for entities and transactions in Offshore Secrecy Jurisdictions. (§101)
Establishes rebuttable evidentiary presumptions in tax and securities legal proceedings for non publicly-traded entities located in Offshore Secrecy Jurisdictions. The presumptions are as follows:
Control – In a tax proceeding, if a U.S. person (other than a publicly-traded corporation) directly or indirectly formed, transferred assets to, was a beneficiary of, had a beneficial interest in, or received assets from an Offshore Secrecy Jurisdiction entity (other than a publicly-traded corporation), it will be presumed that the person exercised control over the entity.
Transfers of income – In a tax proceeding, any amount or thing of value –
a) transferred to a U.S. person (other than a publicly-traded corporation) directly or indirectly from an account or entity in an Offshore Secrecy Jurisdiction, or
b) transferred from such a U.S. person directly or indirectly to an account or entity in an Offshore Secrecy Jurisdiction, will be presumed to represent previously unreported income to the U.S. person in the year of transfer.
Beneficial ownership – In a proceeding to enforce securities law, if a U.S. person (other than a publicly-traded corporation) formed, transferred assets to, was a beneficiary of, had a beneficiary interest in, or received assets from an Offshore Secrecy Jurisdiction entity (other than a publicly-traded corporation), it will be presumed that the person beneficially owned and exercised control over such entity, regardless of the nominal ownership.
