SEC. __. UNDISCLOSED COVERED ASSETS; LIMITATIONS; HEIR AND TRANSFEREE LIABILITY.

Hidden assets do not age out. For any covered asset not adequately disclosed during life, no limitation period begins to run until adequate disclosure is made. If the asset is discovered at death or within two heir generations, the unpaid prepayment tax, estate tax, capital-gains-at-death tax, interest, additions to tax, and civil penalties remain collectible from the estate, from the asset, from substitute property, and from any heir or transferee who received property from that estate. A nonculpable heir's liability is capped at the value of property received from that same estate. A culpable heir, fiduciary, advisor, or nominee who participated in concealment is personally liable without that cap.

(a) No Limitation Period Until Adequate Disclosure.—
Notwithstanding any other provision of law, no period of limitation shall begin
to run with respect to any tax, interest, addition to tax, assessable penalty,
or civil penalty attributable to an undisclosed covered asset until the date on
which the Secretary receives an adequate disclosure of such asset.

(b) Adequate Disclosure.—
For purposes of this section, an adequate disclosure is a written disclosure,
made under penalties of perjury, that identifies the asset, beneficial owner,
legal title holder, location, acquisition date, estimated fair market value,
basis, encumbrances, related entities, nominees, trusts, custodians, and any
other information the Secretary reasonably requires to determine tax liability.

(c) Discovery After Death.—
If an undisclosed covered asset is discovered after the death of the covered
person, the Secretary may assess and collect the unpaid estate-prepayment tax,
estate tax, capital-gains-at-death tax, interest, additions to tax, penalties,
and enforcement costs attributable to such asset against—

    (1) the estate;
    (2) the executor, trustee, fiduciary, nominee, or controlled entity;
    (3) the asset itself;
    (4) substitute property or proceeds traceable to the asset; and
    (5) any heir, beneficiary, transferee, distributee, or successor who received
        property from the estate.

(d) Heir and Transferee Liability.—
A nonculpable heir, beneficiary, transferee, distributee, or successor shall be
liable under this section only to the extent of the fair market value, as of the
date received, of property received from the same estate, including substitute
property and traceable proceeds.

(e) Culpable Participant Liability.—
The limitation in subsection (d) shall not apply to any person who knowingly
concealed, transferred, encumbered, misvalued, laundered, destroyed records
concerning, or otherwise assisted in the nondisclosure of a covered asset. Such
person shall be personally liable for the amounts described in subsection (c),
together with any additional civil or criminal penalties provided by law.

(f) Post-Discovery Assessment Period.—
After actual discovery by the Secretary of an undisclosed covered asset, the
Secretary may assess liability under this section at any time within 6 years
after such discovery. The preceding sentence shall not limit assessment in any
case involving fraud, false statement, no return, nominee ownership, forged
records, concealed beneficial ownership, or willful attempt to evade tax.

(g) Collection Period.—
Amounts timely assessed under this section may be collected by levy, lien,
foreclosure, offset, or civil action within 20 years after assessment. If the
United States timely commences a civil action, the liability may be collected
until the judgment is satisfied or becomes unenforceable.

(h) Bona Fide Purchaser Protection.—
A purchaser for adequate and full consideration, without actual or constructive
notice of the nondisclosure, shall take free of liability under this section,
except that the lien and liability shall attach to the consideration, proceeds,
or substitute property received by the transferor.

(i) Reasonable Cause and Valuation Safe Harbor.—
No civil penalty shall be imposed under this section for a valuation error or
incomplete disclosure if the taxpayer establishes reasonable cause, substantial
compliance, and good-faith reliance on qualified appraisal or professional
advice, except where the asset itself, beneficial ownership, or controlling
interest was omitted.

(j) No Effect on Criminal Law.—
Nothing in this section limits prosecution for tax evasion, false statement,
conspiracy, obstruction, money laundering, or any other offense.

The Accord can and should have an effectively unlimited limitations rule for hidden wealth. The legally stronger version is: no clock starts until disclosure; the estate remains liable; the hidden asset remains liable; heirs are liable up to what they received from that estate; culpable heirs, fiduciaries, nominees, and advisors face full personal liability. That gives early disclosure real teeth while preserving due process, proportionality, and a clean public defense.