[Congressional Record Volume 171, Number 112 (Saturday, June 28, 2025)]
[Senate]
[Pages S3997-S3998]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
SA 2499. Mr. ROUNDS submitted an amendment intended to be proposed by
him to the bill H.R. 1, to provide for reconciliation pursuant to title
II of H. Con. Res. 14; which was ordered to lie on the table; as
follows:
At the appropriate place, insert the following:
SEC. ___01. POSTPONEMENT OF TAX DEADLINES FOR HOSTAGES AND
INDIVIDUALS WRONGFULLY DETAINED ABROAD.
(a) In General.--Chapter 77 of the Internal Revenue Code of
1986 is amended by inserting after section 7510 the following
new section:
``SEC. 7511. TIME FOR PERFORMING CERTAIN ACTS POSTPONED FOR
HOSTAGES AND INDIVIDUALS WRONGFULLY DETAINED
ABROAD.
``(a) Time To Be Disregarded.--
``(1) In general.--The period during which an applicable
individual was unlawfully or wrongfully detained abroad, or
held hostage abroad, shall be disregarded in determining,
under the internal revenue laws, in respect of any tax
liability of such individual--
``(A) whether any of the acts described in section
7508(a)(1) were performed within the time prescribed thereof
(determined without regard to extension under any other
provision of this subtitle for periods after the initial date
(as determined by the Secretary) on which such individual was
unlawfully or wrongfully detained abroad or held hostage
abroad),
``(B) the amount of any interest, penalty, additional
amount, or addition to the tax for periods after such date,
and
``(C) the amount of any credit or refund.
``(2) Application to spouse.--The provisions of paragraph
(1) shall apply to the spouse of any individual entitled to
the benefits of such paragraph.
``(3) Special rule for overpayments.--The rules of section
7508(b) shall apply for purposes of this section.
``(b) Applicable Individual.--
``(1) In general.--For purposes of this section, the term
`applicable individual' means any individual who is--
``(A) a United States national unlawfully or wrongfully
detained abroad, as determined under section 302 of the
Robert Levinson Hostage Recovery and Hostage-Taking
Accountability Act (22 U.S.C. 1741), or
``(B) a United States national taken hostage abroad, as
determined pursuant to the findings of the Hostage Recovery
Fusion Cell (as described in section 304 of the Robert
Levinson Hostage Recovery and Hostage-Taking Accountability
Act (22 U.S.C. 1741b)).
``(2) Information provided to treasury.--For purposes of
identifying individuals described in paragraph (1), not later
than January 1, 2026, and annually thereafter--
``(A) the Secretary of State shall provide the Secretary
with a list of the individuals described in paragraph (1)(A),
as well as any other information necessary to identify such
individuals, and
``(B) the Attorney General, acting through the Hostage
Recovery Fusion Cell, shall provide the Secretary with a list
of the individuals described in paragraph (1)(B), as well as
any other information necessary to identify such individuals.
``(c) Modification of Treasury Databases and Information
Systems.--The Secretary shall update, as necessary, any
database or information system of the Department of the
Treasury in order to ensure that the provisions of subsection
(a) are applied with respect to each applicable individual.
``(d) Refund and Abatement of Penalties and Fines Imposed
Prior to Identification as Applicable Individual.--In the
case of any applicable individual--
``(1) for whom any interest, penalty, additional amount, or
addition to the tax in respect to any tax liability for any
taxable year ending during the period described in subsection
(a)(1) was assessed or collected, and
``(2) who was, subsequent to such assessment or collection,
determined to be an individual described in subparagraph (A)
or (B) of subsection (b)(1),
the Secretary shall abate any such assessment and refund any
amount collected to such applicable individual in the same
manner as any refund of an overpayment of tax under section
6402.''.
(b) Clerical Amendment.--The table of sections for chapter
77 of the Internal Revenue Code of 1986 is amended by
inserting after the item relating to section 7510 the
following new item:
``Sec. 7511. Time for performing certain acts postponed for hostages
and individuals wrongfully detained abroad.''.
(c) Effective Date.--The amendments made by this section
shall apply to taxable years ending after the date of
enactment of this Act.
SEC. ___02. REFUND AND ABATEMENT OF PENALTIES AND FINES PAID
BY ELIGIBLE INDIVIDUALS.
(a) In General.--Section 7511 of the Internal Revenue Code
of 1986, as added by section ___01, is amended by adding at
the end the following new subsection:
[[Page S3998]]
``(d) Refund and Abatement of Penalties and Fines Paid by
Eligible Individuals.--
``(1) In general.--
``(A) Establishment.--Not later than January 1, 2026, the
Secretary shall establish a program to allow any eligible
individual (or the spouse or any dependent (as defined in
section 152) of such individual) to apply for a refund or an
abatement of any amount described in paragraph (2) (including
interest) to the extent such amount was attributable to the
applicable period.
``(B) Identification of individuals.--Not later than
January 1, 2026, the Secretary of State and the Attorney
General, acting through the Hostage Recovery Fusion Cell (as
described in section 304 of the Robert Levinson Hostage
Recovery and Hostage-Taking Accountability Act (22 U.S.C.
1741b)), shall--
``(i) compile a list, based on such information as is
available, of individuals who were applicable individuals
during the applicable period, and
``(ii) provide the list described in clause (i) to the
Secretary.
``(C) Notice.--For purposes of carrying out the program
described in subparagraph (A), the Secretary (in consultation
with the Secretary of State and the Attorney General) shall,
with respect to any individual identified under subparagraph
(B), provide notice to such individual--
``(i) in the case of an individual who has been released on
or before the date of enactment of this subsection, not later
than 90 days after the date of enactment of this subsection,
or
``(ii) in the case of an individual who is released after
the date of enactment of this subsection, not later than 90
days after the date on which such individual is released,
that such individual may be eligible for a refund or an
abatement of any amount described in paragraph (2) pursuant
to the program described in subparagraph (A).
``(D) Authorization.--
``(i) In general.--Subject to clause (ii), in the case of
any refund described in subparagraph (A), the Secretary shall
issue such refund to the eligible individual in the same
manner as any refund of an overpayment of tax.
``(ii) Extension of limitation on time for refund.--With
respect to any refund under subparagraph (A)--
``(I) the 3-year period of limitation prescribed by section
6511(a) shall be extended until the end of the 1-year period
beginning on the date that the notice described in
subparagraph (C) is provided to the eligible individual, and
``(II) any limitation under section 6511(b)(2) shall not
apply.
``(2) Eligible individual.--For purposes of this
subsection, the term `eligible individual' means any
applicable individual who, for any taxable year ending during
the applicable period, paid or incurred any interest,
penalty, additional amount, or addition to the tax in respect
to any tax liability for such year of such individual based
on a determination that an act described in section
7508(a)(1) which was not performed by the time prescribed
therefor (without regard to any extensions).
``(3) Applicable period.--For purposes of this subsection,
the term `applicable period' means the period--
``(A) beginning on January 1, 2021, and
``(B) ending on the date of enactment of this
subsection.''.
(b) Effective Date.--The amendment made by this section
shall apply to taxable years ending on or before the date of
enactment of this Act.
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