It's not an additional tax break. In fact, it's proposed that this bill, which, generally speaking, introduces new tightening measures vis-à-vis foreign investment entities and non-resident trusts, applies not only from 2007 onward, which is what the bill says, but on an elective basis also applies back to 2003.
Why would somebody want to do that? Well, in large part, they don't want to re-file. What they would like to do is just have us put them back into the same position as they would have been in had they not filed their returns on the basis of the draft that was out there all these years. They would like us to recognize what would happen for them if it started as of 2007 but not force them to re-file income tax returns.