II 119THCONGRESS 1 STSESSION S. 684 To amend the Internal Revenue Code of 1986 to extend the period of time for making S corporation elections, and for other purposes. IN THE SENATE OF THE UNITED STATES FEBRUARY24, 2025 Mrs. B LACKBURN(for herself and Ms. CORTEZMASTO) introduced the following bill; which was read twice and referred to the Committee on Finance A BILL To amend the Internal Revenue Code of 1986 to extend the period of time for making S corporation elections, and for other purposes. 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 ‘‘Tax Administration 4 Simplification Act’’. 5 SEC. 2. EXTENSION OF TIME FOR MAKING S CORPORATION 6 ELECTIONS. 7 (a) I NGENERAL.— 8 VerDate Sep 11 2014 03:43 Mar 13, 2025 Jkt 059200 PO 00000 Frm 00001 Fmt 6652 Sfmt 6201 E:\BILLS\S684.IS S684 kjohnson on DSK7ZCZBW3PROD with $$_JOB 2 •S 684 IS (1) WHEN ELECTION MADE .—Section 1 1362(b)(1) of the Internal Revenue Code of 1986 is 2 amended to read as follows: 3 ‘‘(1) I N GENERAL.—An election under sub-4 section (a) may be made by a small business cor-5 poration for any taxable year not later than the due 6 date for filing the return of the S corporation for 7 such taxable year (including extensions).’’. 8 (2) C ONFORMING AMENDMENTS .— 9 (A) Section 1362(b)(2) of such Code is 10 amended— 11 (i) by striking ‘‘during such year and 12 on or before the 15th day of the 3d month 13 of such year’’ in subparagraph (A) and in-14 serting ‘‘within the period described in 15 paragraph (1)’’, and 16 (ii) by striking ‘‘ MADE DURING THE 17 FIRST 2 1 ⁄2MONTHS’’ in the heading there-18 of. 19 (B) Section 1362(b) of such Code is 20 amended by striking paragraphs (3) and (4) 21 and by redesignating paragraph (5) as para-22 graph (3). 23 VerDate Sep 11 2014 03:43 Mar 13, 2025 Jkt 059200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6201 E:\BILLS\S684.IS S684 kjohnson on DSK7ZCZBW3PROD with $$_JOB 3 •S 684 IS (C) Section 1362(b)(3) of such Code, as 1 redesignated by subparagraph (B), is amend-2 ed— 3 (i) by striking ‘‘(determined without 4 regard to paragraph (3))’’ in subparagraph 5 (A), and 6 (ii) by striking ‘‘(and paragraph (3) 7 shall not apply)’’. 8 (D) Section 1362(b) of such Code, as 9 amended by the preceding provisions of this 10 subsection, is amended by adding at the end the 11 following new paragraphs: 12 ‘‘(4) E LECTION ON TIMELY FILED RETURNS .— 13 Except as otherwise provided by the Secretary, an 14 election under subsection (a) for any taxable year 15 may be made on a timely filed return of the S cor-16 poration for such taxable year. 17 ‘‘(5) S ECRETARIAL AUTHORITY .—The Secretary 18 may prescribe such regulations, rules, or other guid-19 ance necessary to implement this subsection, includ-20 ing forms or other guidance for making the election 21 in the manner described by this subsection.’’. 22 (b) C OORDINATIONWITHCERTAINOTHERPROVI-23 SIONS.— 24 VerDate Sep 11 2014 03:43 Mar 13, 2025 Jkt 059200 PO 00000 Frm 00003 Fmt 6652 Sfmt 6201 E:\BILLS\S684.IS S684 kjohnson on DSK7ZCZBW3PROD with $$_JOB 4 •S 684 IS (1) QUALIFIED SUBCHAPTER S SUBSIDI -1 ARIES.—Section 1361(b)(3)(B) of the Internal Rev-2 enue Code of 1986 is amended by adding at the end 3 the following flush sentence: 4 ‘‘Rules similar to the rules of section 1362(b) 5 shall apply with respect to any election under 6 clause (ii).’’. 7 (2) Q UALIFIED SUBCHAPTER S TRUSTS .—Sec-8 tion 1361(d)(2) of such Code is amended by striking 9 subparagraph (D). 10 (c) R EVOCATIONS.—Section 1362(d)(1) of the Inter-11 nal Revenue Code of 1986 is amended— 12 (1) by striking ‘‘subparagraph (D)’’ in subpara-13 graph (C) and inserting ‘‘subparagraphs (D) and 14 (E)’’, and 15 (2) by adding at the end the following new sub-16 paragraph: 17 ‘‘(E) A UTHORITY TO TREAT LATE REVOCA -18 TIONS AS TIMELY.—If— 19 ‘‘(i) a revocation under subparagraph 20 (A) is made for any taxable year after the 21 date prescribed by this paragraph for mak-22 ing such revocation for such taxable year 23 or no such revocation is made for any tax-24 able year, and 25 VerDate Sep 11 2014 03:43 Mar 13, 2025 Jkt 059200 PO 00000 Frm 00004 Fmt 6652 Sfmt 6201 E:\BILLS\S684.IS S684 kjohnson on DSK7ZCZBW3PROD with $$_JOB 5 •S 684 IS ‘‘(ii) the Secretary determines that 1 there was reasonable cause for the failure 2 to timely make such revocation, 3 the Secretary may treat such a revocation as 4 timely made for such taxable year.’’. 5 (d) E FFECTIVEDATE.— 6 (1) I N GENERAL.—Except as otherwise pro-7 vided in this subsection, the amendments made by 8 this section shall apply to elections for taxable years 9 beginning after the last day of the calendar year 10 which includes the date of the enactment of this Act. 11 (2) R EVOCATIONS.—The amendments made by 12 subsection (c) shall apply to revocations made after 13 the date of the enactment of this Act. 14 SEC. 3. QUARTERLY INSTALLMENTS FOR ESTIMATED IN-15 COME TAX PAYMENTS BY INDIVIDUALS. 16 (a) I NGENERAL.—The table contained in section 17 6654(c)(2) of the Internal Revenue Code of 1986 is 18 amended— 19 (1) by striking ‘‘June 15’’ and inserting ‘‘July 20 15’’, and 21 (2) by striking ‘‘September 15’’ and inserting 22 ‘‘October 15’’. 23 VerDate Sep 11 2014 03:43 Mar 13, 2025 Jkt 059200 PO 00000 Frm 00005 Fmt 6652 Sfmt 6201 E:\BILLS\S684.IS S684 kjohnson on DSK7ZCZBW3PROD with $$_JOB 6 •S 684 IS (b) EFFECTIVEDATE.—The amendments made by 1 this section shall apply to installments due in taxable years 2 beginning after the date of the enactment of this Act. 3 SEC. 4. EXTENSION OF MAILBOX RULE TO ELECTRONIC 4 SUBMISSIONS AND PAYMENTS. 5 (a) I NGENERAL.—Section 7502(c) of the Internal 6 Revenue Code of 1986 is amended— 7 (1) in the heading, by inserting ‘‘ ANDPAY-8 MENT’’ after ‘‘FILING’’, 9 (2) in paragraph (2)— 10 (A) in the heading, by striking ‘‘; ELEC-11 TRONIC FILING’’, and 12 (B) by striking ‘‘and electronic filing’’, and 13 (3) by adding at the end the following: 14 ‘‘(3) E LECTRONIC FILING AND PAYMENT .— 15 ‘‘(A) I N GENERAL.—In the case of any 16 document which the Secretary has permitted to 17 be filed by electronic means (or, in the case of 18 any payment, which the Secretary has per-19 mitted to be made by electronic means), if such 20 document or payment is— 21 ‘‘(i) transmitted by the permitted elec-22 tronic means to the agency, officer, or of-23 fice to which the document was required to 24 be filed (or payment was required to be 25 VerDate Sep 11 2014 03:43 Mar 13, 2025 Jkt 059200 PO 00000 Frm 00006 Fmt 6652 Sfmt 6201 E:\BILLS\S684.IS S684 kjohnson on DSK7ZCZBW3PROD with $$_JOB 7 •S 684 IS made) on or before the prescribed date (or 1 within the period required) with respect to 2 such document or payment, and 3 ‘‘(ii) received (or, in the case of a pay-4 ment, received and accounted for) after the 5 prescribed date or period required with re-6 spect to such document or payment, 7 the date that such document or payment was 8 transmitted (as described in clause (i)) shall be 9 deemed to be the date that such document was 10 filed or such payment was made. 11 ‘‘(B) R EGULATIONS.—Not later than the 12 date which is 1 year after the date of enact-13 ment of the Tax Administration Simplification 14 Act, the Secretary shall issue such regulations 15 or other guidance as the Secretary determines 16 necessary to carry out the purposes of this 17 paragraph.’’. 18 (b) E FFECTIVEDATE.—The amendments made by 19 subsection (a) shall apply to any document or payment 20 sent on or after the date which is 1 year after the date 21 of enactment of this Act. 22 Æ VerDate Sep 11 2014 03:43 Mar 13, 2025 Jkt 059200 PO 00000 Frm 00007 Fmt 6652 Sfmt 6301 E:\BILLS\S684.IS S684 kjohnson on DSK7ZCZBW3PROD with $$_JOB