To amend the Internal Revenue Code of 1986 to clarify the confidentiality of certain documents relating to closing agreements and agreements with foreign governments.

Amends provisions of the Internal Revenue Code concerning the confidentiality of return information to include within the definition of return information: (1) any closing agreement and any background file document related to such agreement; and (2) any agreement relating to a named taxpayer entered into by the Secretary of the Treasury with the competent authority of a foreign government pursuant to specified conventions and agreements.