the sum of— (A) 25 percent of the taxpayer’s net unrealized gain (as defined in section 1481) for such taxable year, (B) the aggregate credits allowed under section 25F for such taxable year and all prior taxable years, and (C) the aggregate reductions determined under section 1481(h)(6) for such taxable year and all prior taxable years. . (d) Penalties for failure to report (1) Returns Section 6724(d)(1)(D) of the Internal Revenue Code of 1986 is amended by inserting 1481(i)(1) or before 6055 . (2) Statements Section 6724(d)(2) of such Code is amended— (A) in subparagraph (II), by striking or at the end, (B) in the first subparagraph (JJ), by striking the period at the end and inserting a comma, (C) in the second subparagraph (JJ)— (i) by redesignating such subparagraph as subparagraph (KK), and (ii) by striking the period at the end and inserting , or , and (D) by adding at the end the following new subparagraph: (LL) section 1481(i)(2) (relating to statements relating to minimum tax on certain wealthy taxpayers). . (e) Conforming amendments (1) Section 6211(b)(4)(A) of the Internal Revenue Code of 1986 is amended by inserting 36C, after 36B, . (2) Paragraph (2) of section 1324(b) of title 31, United States Code, is amended by inserting 36C, after 36B, . (3) The table of chapters for subtitle A of the Internal Revenue Code of 1986 is amended by inserting after the item relating to chapter 4 the following new item: Chapter 5. Minimum tax on certain wealthy taxpayers. . (4) The table of sections for subpart A of part IV of subchapter A of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after the item relating to section 25E the following new item: Sec. 25F. Minimum tax on certain wealthy taxpayers credited against recognized gains. . (5) The table of sections for subpart C of part IV of subchapter A of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting after the item relating to section 36B the following new item: Sec. 36C. Credit for excess minimum tax on certain