February 6, 2025
Mr. LaHood (for himself, Ms. DelBene, Mr. Feenstra, Mr. Schneider, Mr. Fitzpatrick, and Mr. Panetta) introduced the following bill; which was referred to the Committee on Ways and Means
To amend the Internal Revenue Code of 1986 to make improvements related to tax administration.
Section 1. Short title
This Act may be cited as the Tax Administration Simplification Act
.
Sec. 2. Application of mailbox rule to documents and payments electronically submitted to the Internal Revenue Service
(a) In general
Section 7502(c) of the Internal Revenue Code of 1986 is amended—
(1)
in the heading, by inserting and payment
after filing
,
(2)
in paragraph (2)—
(A)
in the heading, by striking ; electronic filing
, and
(B)
by striking and electronic filing
, and
(3)
by adding at the end the following:
(3) Electronic filing and payment
(A) In general
If any return, claim, statement, or other document required to be filed, or any payment required to be made, within a prescribed period or on or before a prescribed date under authority of any provision of the internal revenue laws is sent electronically by any person to the agency, officer, or office with which such return, claim, statement, or other document is required to be filed, or to which such payment is required to be made, the date on which such return, claim, statement, or other document, or payment, is sent electronically by such person shall be deemed to be the date of delivery or the date of payment, as the case may be, regardless of the date on which the applicable agency, officer, or office receives or reviews such return, claim, statement, document, or payment.
(B) Regulations
Not later than December 31, 2025, the Secretary shall issue such regulations or other guidance as the Secretary determines necessary to carry out the purposes of this paragraph.
(b) Effective date
The amendments made by this section shall apply to any document or payment sent after December 31, 2025.
Sec. 3. Extension of time for making S corporation elections
(a) In general
Section 1362(b) of the Internal Revenue Code of 1986 is amended to read as follows:
(b) When made
(1) In general
An election under subsection (a) may be made by a small business corporation for any taxable year not later than the due date for filing the return of the S corporation for such taxable year (including extensions).
(2) Certain elections treated as made for next taxable year
If—
(A)
an election under subsection (a) is made for any taxable year within the period described in paragraph (1), but
(B)
either—
(i)
on 1 or more days in such taxable year and before the day on which the election was made the corporation did not meet the requirements of subsection (b) of section 1361, or
(ii)
1 or more of the persons who held stock in the corporation during such taxable year and before the election was made did not consent to the election,
then such election shall be treated as made for the following taxable year.
(3) Authority to treat late elections, etc., as timely
If—
(A)
an election under subsection (a) is made for any taxable year after the date prescribed by this subsection for making such election for such taxable year or no such election is made for any taxable year, and
(B)
the Secretary determines that there was reasonable cause for the failure to timely make such election,
the Secretary may treat such an election as timely made for such taxable year.
(4) Election on timely filed returns
Except as otherwise provided by the Secretary, an election under subsection (a) for any taxable year may be made on a timely filed return of the S corporation for such taxable year.
(5) Secretarial authority
The Secretary may prescribe such regulations, rules, or other guidance as may be necessary or appropriate for purposes of applying this subsection.
(b) Coordination with certain other provisions
(1) Qualified subchapter S subsidiaries
Section 1361(b)(3)(B) of such Code is amended by adding at the end the following flush sentence:
Rules similar to the rules of section 1362(b) shall apply with respect to any election under clause (ii).
(2) Qualified subchapter S trusts
Section 1361(d)(2) of such Code is amended by striking subparagraph (D).
(c) Revocations
Section 1362(d)(1) of such Code is amended—
(1)
by striking subparagraph (D)
in subparagraph (C) and inserting subparagraphs (D) and (E)
, and
(2)
by adding at the end the following new subparagraph:
(E) Authority to treat late revocations as timely
If—
(i)
a revocation under subparagraph (A) is made for any taxable year after the date prescribed by this paragraph for making such revocation for such taxable year or no such revocation is made for any taxable year, and
(ii)
the Secretary determines that there was reasonable cause for the failure to timely make such revocation,
the Secretary may treat such a revocation as timely made for such taxable year.
(d) Effective date
(1) In general
Except as otherwise provided in this subsection, the amendments made by this section shall apply to elections for taxable years beginning after December 31, 2025.
(2) Revocations
The amendments made by subsection (c) shall apply to revocations made after the date of the enactment of this Act.
Sec. 4. Quarterly installments for estimated income tax payments by individual
(a) In general
The table contained in section 6654(c)(2) of the Internal Revenue Code of 1986 is amended—
(1)
by striking June 15
and inserting July 15
, and
(2)
by striking September 15
and inserting October 15
.
(b) Effective date
The amendments made by this section shall apply to installments due in taxable years beginning after December 31, 2025.