I
119THCONGRESS
1
STSESSION H. R. 2014
To amend the Internal Revenue Code of 1986 for purposes of the tax
on private foundation excess business holdings to treat as outstanding
any employee-owned stock purchased by a business enterprise pursuant
to certain employee stock ownership retirement plans.
IN THE HOUSE OF REPRESENTATIVES
MARCH10, 2025
Mr. S
TEUBEintroduced the following bill; which was referred to the
Committee on Ways and Means
A BILL
To amend the Internal Revenue Code of 1986 for purposes
of the tax on private foundation excess business holdings
to treat as outstanding any employee-owned stock pur-
chased by a business enterprise pursuant to certain em-
ployee stock ownership retirement plans.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Reduction of Excess 4
Business Holding Accrual Act’’. 5
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SEC. 2. CERTAIN PURCHASES OF EMPLOYEE-OWNED STOCK 1
DISREGARDED FOR PURPOSES OF FOUNDA-2
TION TAX ON EXCESS BUSINESS HOLDINGS. 3
(a) I
NGENERAL.—Section 4943(c)(4)(A) of the In-4
ternal Revenue Code of 1986 is amended by adding at the 5
end the following new clauses: 6
‘‘(v) For purposes of clause (i), subpara-7
graph (D), and paragraph (2), any voting stock 8
which— 9
‘‘(I) is not readily tradable on an es-10
tablished securities market, 11
‘‘(II) is purchased by the business en-12
terprise on or after January 1, 2020, from 13
an employee stock ownership plan (as de-14
fined in section 4975(e)(7)) in which em-15
ployees of such business enterprise partici-16
pate, in connection with a distribution 17
from such plan, and 18
‘‘(III) is held by the business enter-19
prise as treasury stock, cancelled, or re-20
tired, 21
shall be treated as outstanding voting stock, but 22
only to the extent so treating such stock would 23
not result in permitted holdings exceeding 49 24
percent (determined without regard to this 25
clause). The preceding sentence shall not apply 26
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with respect to the purchase of stock from a 1
plan during the 10-year period beginning on the 2
date the plan is established. 3
‘‘(vi) Section 4943(c)(4)(A)(ii) shall not 4
apply with respect to any decrease in the per-5
centage of holdings in a business enterprise by 6
reason of the application of clause (v).’’. 7
(b) E
FFECTIVEDATE.—The amendments made by 8
this section shall apply to taxable years ending after the 9
date of the enactment of this Act and to purchases by 10
a business enterprise of voting stock in taxable years be-11
ginning after December 31, 2019. 12
Æ
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