EFTA01078150.pdf

taxanalystr DOCUMENT S RVICE Doc 20144426 (193 pgs) COMMITTEE ON 7\ WAYS AND MEANS CHAIRMAN DAVE CAM P Tax Reform Act of 2014 Discussion Draft Section-by-Section Summary Table of Contents Section I. Short Title; Etc 1 Title I — Tax Reform for Individuals 1 Subtitle A — Individual Income Tax Rate Reform I Secs. 1001-1003. Simplification of individual income tax rates; Deduction for adjusted net capital gain; Conforming amendments related to simplification of individual income tax rates 1 Subtitle B - Simplification of Tax Benefits for Families 3 Sec. 1101. Standard deduction 4 Sec. 1102. Increase and expansion of child tax credit. 5 Sec. 1103. Modification of earned income tax credit. 6 Sec. 1104. Repeal of deduction for personal exemptions. 7 Subtitle C — Simplification of Education Incentives 8 Sec. 1201. American opportunity tax credit. 8 Sec. 1202. Expansion of Pell Grant exclusion from gross income. 9 Sec. 1203. Repeal of exclusion of income from United States savings bonds used to pay higher education tuition and fees 10 Sec. 1204. Repeal of deduction for interest on education loans. 10 Sec. 1205. Repeal of deduction for qualified tuition and related expenses. 10 Sec. 1206. No new contributions to Coverdell education savings accounts 11 Sec. 1207. Repeal of exclusion for discharge of student loan indebtedness 11 Sec. 1208. Repeal of exclusion for qualified tuition reductions. 12 Sec. 1209. Repeal of exclusion for education assistance programs 12 Sec. 1210. Repeal of exception to 10-percent penalty for higher education expenses. 12 Subtitle D — Repeal of Certain Credits for Individuals 13 Sec. 1301. Repeal of dependent care credit. 13 Sec. 1302. Repeal of credit for adoption expenses 13 Sec. 1303. Repeal of credit for nonbusiness energy property 14 Sec. 1304. Repeal of credit for residential energy efficient property. 14 Sec. 1305. Repeal of credit for qualified electric vehicles 14 Sec. 1306. Repeal of alternative motor vehicle credit. 1 Sec. 1307. Repeal of alternative fuel vehicle refueling property credit 15 Sec. 1308. Repeal of credit for new qualified plug-in electric drive motor vehicles 15 Preparedby Ways andMeans Committee Majority Tax Staff EFTA01078150  tannalyStS . DOCUMENT S RVICE Doc 20144426 (193 pgs) Sec. 1309. Repeal of credit for health insurance costs of eligible individuals. 16 Sec. 1310. Repeal of first-time homebuyer credit. 16 Subtitle E — Deductions, Exclusions, and Certain Other Provisions 17 Sec. 1401. Exclusion of gain from sale of a principal residence. 17 Sec. 1402. Mortgage interest. 18 Sec. 1403. Charitable contributions. 19 Sec. 1404. Denial of deduction for expenses attributable to the trade or business of being an employee. 22 Sec. 1405. Repeal of deduction for taxes not paid or accrued in a trade or business. 23 Sec. 1406. Repeal of deduction for personal casualty losses 23 Sec. 1407. Limitation on wagering losses. 24 Sec. 1408. Repeal of deduction for tax preparation expenses. 24 Sec. 1409. Repeal of deduction for medical expenses 24 Sec. 1410. Repeal of disqualification of expenses for over-the-counter drugs under certain accounts and arrangements. 25 Sec. 1411. Repeal of deduction for alimony payments and corresponding inclusion in gross income. 25 Sec. 1412. Repeal of deduction for moving expenses. 26 Sec. 1413. Termination of deduction and exclusions for contributions to medical savings accounts. 26 Sec. 1414. Repeal of 2-percent floor on miscellaneous itemized deductions 27 Sec. 1415. Repeal of overall limitation on itemized deductions 27 Sec. 1416. Deduction for amortizable bond premium allowed in determining adjusted gross income. 28 Sec. 1417. Repeal of exclusion, etc., for employee achievement awards 28 Sec. 1418. Clarification of special rule for certain governmental plans. 29 Sec. 1419. Limitation on exclusion for employer-provided housing 29 Sec. 1420. Fringe benefits 30 Sec. 1421. Repeal of exclusion of net unrealized appreciation in employer securities. 30 Sec. 1422. Consistent basis reporting between estate and person acquiring property from decedent. 31 Subtitle F — Employment Tax Modifications 31 Sec. 1501. Modifications of deduction for Social Security taxes in computing net earnings from self-employment 31 Sec. 1502. Determination of net earnings from self-employment. 32 Sec. 1503. Repeal of exemption from FICA taxes for certain foreign workers. 33 Sec. 1504. Repeal of exemption from FICA taxes for certain students 34 Sec. 1505. Override of Treasury guidance providing that certain employer-provided supplemental unemployment benefits are not subject to employment taxes 34 Sec. 1506. Certified professional employer organizations. 35 Subtitle G — Pensions and Retirement 36 Part I — Individual Retirement Plans 36 Secs. 1601-1603. Elimination of income limits on contributions to Roth IRAs; No new contributions to traditional IRAs; Inflation adjustment for Roth IRA contributions. 36 Preparedby Ways andMeans Committee Majority Tax Staff ii EFTA01078151  taxanalystr DOCUMENT S RVICE Doc 20144426 (193 pgs) Sec. 1604. Repeal of special rule permitting recharacterization of Roth IRA contributions as traditional IRA contributions 37 Sec. 1605. Repeal of exception to 10-percent penalty for first home purchases. 37 Part 2 — Employer-Provided Plans 38 Secs. 1611-1612. Termination for new SEPs; Termination for new SIMPLE 401(k)s 38 Sec. 1613. Rules related to designated Roth contributions 39 Sec. 1614. Modifications of required distribution rules for pension plans. 40 Sec. 1615. Reduction in minimum age for allowable in-service distributions. 41 Sec. 1616. Modification of rules governing hardship distributions 42 Sec. 1617. Extended rollover period for the rollover of plan loan offset amounts in certain cases. 42 Sec. 1618. Coordination of contribution limitations for 403(b) plans and governmental 457(b) plans. 43 Sec. 1619. Application of 10-percent early distribution tax to governmental 457 plans 44 Secs. 1620-1624. Inflation adjustments for qualified plan benefit and contribution limitations; Inflation adjustments for qualified plan elective deferral limitations; Inflation adjustments for SIMPLE retirement accounts; Inflation adjustments for catch-up contributions for certain employer plans; Inflation adjustments for governmental and tax-exempt organization plans. 44 Subtitle H — Certain Provisions Related to Members of Indian Tribes 45 Secs. 1701-1703. Indian general welfare benefits; Tribal Advisory Committee; Other relief for Indian tribes 45 Title II — Alternative Minimum Tax Repeal 47 Sec. 2001. Repeal of alternative minimum tax. 47 Title III - Business Tax Reform 49 Subtitle A — Tax Rates 49 Sec. 3001. 25-percent corporate tax rate 49 Subtitle B — Reform of Business-related Exclusions and Deductions 50 Sec. 3101. Revision of treatment of contributions to capital. 50 Sec. 3102. Repeal of deduction for local lobbying expenses. 51 Sec. 3103. Expenditures for repairs in connection with casualty losses 51 Sec. 3104. Reform of accelerated cost recovery system 51 Sec. 3105. Repeal of amortization of pollution control facilities 53 Sec. 3106. Net operating loss deduction. 53 Sec. 3107. Circulation expenditures. 54 Sec. 3108. Amortization of research and experimental expenditures 54 Sec. 3109. Repeal of deductions for soil and water conservation expenditures and endangered species recovery expenditures 55 Sec. 3110. Amortization of certain advertising expenses. 56 Sec. 3111. Expensing certain depreciable business assets for small business 57 Sec. 3112. Repeal of election to expense certain refineries 58 Sec. 3113. Repeal of deduction for energy efficient commercial buildings. 58 Sec. 3114. Repeal of election to expense advanced mine safety equipment. 58 Preparedby Ways andMeans Committee Majority Tax Staff iii EFTA01078152  illiala l • DOCUMENT ISMI Doc 20144426 (193 pgs) Sec. 3115. Repeal of deduction for expenditures by farmers for fertilizer, etc. 59 Sec. 3116. Repeal of special treatment of certain qualified film and television productions 59 Sec. 3117. Repeal of special rules for recoveries of damages of antitrust violations, etc 59 Sec. 3118. Treatment of reforestation expenditures. 60 Sec. 3119. 20-year amortization of goodwill and certain other intangibles 60 Sec. 3120. Treatment of environmental remediation costs 61 Sec. 3121. Repeal of expensing of qualified disaster expenses. 61 Sec. 3122. Phaseout and repeal of deduction for income attributable to domestic production activities 62 Sec. 3123. Unification of deduction for organizational expenditures 62 Sec. 3124. Prevention of arbitrage of deductible interest expense and tax-exempt interest income 63 Sec. 3125. Prevention of transfer of certain losses from tax indifferent parties. 63 Sec. 3126. Entertainment, etc. expenses. 64 Sec. 3127. Repeal of limitation on corporate acquisition indebtedness 65 Sec. 3128. Denial of deductions and credits for expenditures in illegal businesses. 65 Sec. 3129. Limitation on deduction for FDIC premiums. 66 Sec. 3130. Repeal of percentage depletion. 66 Sec. 3131. Repeal of passive activity exception for working interests in oil and gas property 67 Sec. 3132. Repeal of special rules for gain or loss on timber, coal, or domestic iron ore 67 Sec. 3133. Repeal of like-kind exchanges. 68 Sec. 3134. Restriction on trade or business property treated as similar or related in service to involuntarily converted property in disaster areas. 69 Sec. 3135. Repeal of rollover of publicly traded securities gain into specialized small business investment companies. 69 Sec. 3136. Termination of special rules for gain from certain small business stock. 70 Sec. 3137. Certain self-created property not treated as a capital asset. 70 Sec. 3138. Repeal of special rule for sale or exchange of patents. 71 Sec. 3139. Depreciation recapture on gain from disposition of certain depreciable realty. 71 Sec. 3140. Common deduction conforming amendments. 72 Subtitle C — Reform of Business Credits 72 Sec. 3201. Repeal of credit for alcohol, etc., used as fuel. 72 Sec. 3202. Repeal of credit for biodiesel and renewable diesel used as fuel 72 Sec. 3203. Research credit modified and made permanent. 73 Sec. 3204. Low-income housing tax credit 75 Sec. 3205. Repeal of enhanced oil recovery credit. 77 Sec. 3206. Phaseout and repeal of credit for electricity produced from certain renewable resources. 78 Sec. 3207. Repeal of Indian employment credit. 78 Sec. 3208. Repeal of credit for portion of employer Social Security taxes paid with respect to employee cash tips 79 Sec. 3209. Repeal of credit for clinical testing expenses for certain drugs for rare diseases or conditions. 79 Sec. 3210. Repeal of credit for small employer pension plan startup costs 79 Preparedby Ways andMeans Committee Majority Tax Staff ry EFTA01078153  taxanalystr DOCUMENT S RVICE Doc 20144426 (193 pgs) Sec. 3211. Repeal of employer-provided child care credit. 80 Sec. 3212. Repeal of railroad track maintenance credit 80 Sec. 3213. Repeal of credit for production of low sulfur diesel fuel. 80 Sec. 3214. Repeal of credit for producing oil and gas from marginal wells 81 Sec. 3215. Repeal of credit for production from advanced nuclear power facilities. 81 Sec. 3216. Repeal of credit for producing fuel from a nonconventional source 81 Sec. 3217. Repeal of new energy efficient home credit. 81 Sec. 3218. Repeal of energy efficient appliance credit 82 Sec. 3219. Repeal of mine rescue team training credit 82 Sec. 3220. Repeal of agricultural chemicals security credit. 82 Sec. 3221. Repeal of credit for carbon dioxide sequestration 83 Sec. 3222. Repeal of credit for employee health insurance expenses of small employers 83 Sec. 3223. Repeal of rehabilitation credit. 84 Sec. 3224. Repeal of energy credit. 84 Sec. 3225. Repeal of qualifying advanced coal project credit. 85 Sec. 3226. Repeal of qualifying gasification project credit. 85 Sec. 3227. Repeal of qualifying advanced energy project credit 85 Sec. 3228. Repeal of qualifying therapeutic discovery project credit. 86 Sec. 3229. Repeal of work opportunity tax credit. 86 Sec. 3230. Repeal of deduction for certain unused business credits 86 Subtitle D — Accounting Methods 87 Sec. 3301. Limitation on use of cash method of accounting. 87 Sec. 3302. Rules for determining whether taxpayer has adopted a method of accounting 88 Sec. 3303. Certain special rules for taxable year of inclusion. 88 Sec. 3304. Installment sales. 89 Secs. 3305-3306. Repeal of special rule for prepaid subscription income; Repeal of special rule for prepaid dues income of certain membership organizations 90 Sec. 3307. Repeal of special rule for magazines, paperbacks, and records returned after close of the taxable year. 90 Sec. 3308. Modification of rules for long-term contracts 90 Sec. 3309. Nuclear decommissioning reserve funds. 91 Sec. 3310. Repeal of last-in, first-out method of inventory 92 Sec. 3311. Repeal of lower of cost or market method of inventory. 93 Sec. 3312. Modification of rules for capitalization and inclusion in inventory costs of certain expenses. 94 Sec. 3313. Modification of income forecast method. 94 Sec. 3314. Repeal of averaging for farm income 95 Sec. 3315. Treatment of patent or trademark infringement awards 95 Sec. 3316. Repeal of redundant rules with respect to carrying charges 96 Sec. 3317. Repeal of recurring item exception for spudding of oil or gas wells 96 Subtitle E — Financial Instruments 97 Part I — Derivatives and Hedges 97 Sec. 3401. Treatment of certain derivatives 97 Sec. 3402. Modification of certain rules related to hedges 98 Preparedby Ways andMeans Committee Majority Tax Staff V EFTA01078154  =Ma • DOCUMENT ISMI Doc 20144426 (193 pgs) Part 2 — Treatment of Debt Instruments 98 Sec. 3411. Current inclusion in income of market discount. 98 Sec. 3412. Treatment of certain exchanges of debt instruments 99 Sec. 3413. Coordination with rules for inclusion not later than for financial accounting purposes. 100 Sec. 3414. Rules regarding certain government debt 100 Part 3 — Certain Rules for Determining Gain and Loss 101 Sec. 3421. Cost basis of specified securities determined without regard to identification. 101 Sec. 3422. Wash sales by related parties. 101 Sec. 3423. Nonrecognition for derivative transactions by a corporation with respect to its stock. 102 Part 4 — Tax Favored Bonds 102 Secs. 3431-3432. Termination of private activity bonds; Termination of credit for interest on certain home mortgages. 102 Sec. 3433. Repeal of advance refunding bonds. 103 Sec. 3434. Repeal of tax credit bond rules 104 Subtitle F — Insurance Reforms 104 Sec. 3501. Exception to pro rata interest expense disallowance for corporate-owned life insurance restricted to 20-percent owners. 104 Sec. 3502. Net operating losses of life insurance companies 105 Sec. 3503. Repeal of small life insurance company deduction 105 Sec. 3504. Computation of life insurance tax reserves. 106 Sec. 3505. Adjustment for change in computing reserves. 106 Sec. 3506. Modification of rules for life insurance proration for purposes of determining the dividends received deduction. 107 Sec. 3507. Repeal of special rule for distributions to shareholders from pre-1984 policyholders surplus account 107 Sec. 3508. Modification of proration rules for property and casualty insurance companies. 108 Sec. 3509. Repeal of special treatment of Blue Cross and Blue Shield organizations, etc. 108 Sec. 3510. Modification of discounting rules for property and casualty insurance companies. 109 Sec. 3511. Repeal of special estimated tax payments 110 Sec. 3512. Capitalization of certain policy acquisition expenses. 110 Secs. 3513-3514. Tax reporting for life settlement transactions; Clarification of tax basis of life insurance contracts. 111 Sec. 3515. Exception to transfer for valuable consideration rules 112 Subtitle G — Pass-Thru and Certain Other Entities 112 Part 1 — S Corporations 112 Sec. 3601. Reduced recognition period for built-in gains made permanent. 113 Sec. 3602. Modifications to S corporation passive investment income rules 113 Sec. 3603. Expansion of qualifying beneficiaries of an electing small business trust 113 Preparedby Ways andMeans Committee Majority Tax Staff vi EFTA01078155  taxanalystr DOCUMENT S RVICE Doc 20144426 (193 pgs) Sec. 3604. Charitable contribution deduction for electing small business trusts 114 Sec. 3605. Permanent rule regarding basis adjustment to stock of S corporations making charitable contributions of property 114 Sec. 3606. Extension of time for making S corporation elections 115 Sec. 3607. Relocation of C corporation definition. 115 Part 2 — Partnerships 116 Sec. 3611. Repeal of rules relating to guaranteed payments and liquidating distributions. 116 Sec. 3612-3614. Mandatory adjustments to basis of partnership property in case of transfer of partnership interests; Mandatory adjustments to basis of undistributed partnership property; Corresponding adjustments to basis of properties held by partnership where partnership basis adjusted. 117 Sec. 3615. Charitable contributions and foreign taxes taken into account in determining limitation on allowance of partner's share of loss 117 Sec. 3616. Revisions related to unrealized receivables and inventory items 118 Sec. 3617. Repeal of time limitation on taxing precontribution gain. 118 Sec. 3618. Partnership interests created by gift. 119 Sec. 3619. Repeal of technical termination 119 Sec. 3620. Publicly traded partnership exception restricted to mining and natural resources partnerships 119 Sec. 3621. Ordinary income treatment in the case of partnership interests held in connection with performance of services. 120 Sec. 3622. Partnership audits and adjustments. 122 Part 3 — REITs and RICs 123 Sec. 3631. Prevention of tax-free spinoffs involving REITs. 123 Sec. 3632. Extension of period for prevention of REIT election following revocation or termination 124 Sec. 3633. Certain short-life property not treated as real property for purposes of REIT provisions 124 Sec. 3634. Repeal of special rules for timber held by REITs. 124 Sec. 3635. Limitation on fixed percentage rent and interest exceptions for REIT income tests 125 Secs. 3636-3637. Repeal of preferential dividend rule for publicly offered REITs; Authority for alternative remedies to address certain REIT distribution failures. 126 Sec. 3638. Limitations on designation of dividends by REITs 126 Sec. 3639. Non-REIT earnings and profits required to be distributed by REIT in cash 127 Sec. 3640. Debt instruments of publicly offered REITs and mortgages treated as real estate assets. 127 Sec. 3641. Asset and income test clarification regarding ancillary personal property. 127 Sec. 3642. Hedging provisions. 128 Sec. 3643. Modification of REIT earnings and profits calculation to avoid duplicate taxation 128 Sec. 3644. Reduction in percentage limitation on assets of REIT which may be taxable REIT subsidiaries. 129 Sec. 3645. Treatment of certain services provided by taxable REIT subsidiaries 129 Preparedby Ways andMeans Committee Majority Tax Staff vn EFTA01078156  taxanalysts° DOCUMENT StRVICE Doc 20144426 (193 pgs) Sec. 3646. Study relating to taxable REIT subsidiaries 130 Sec. 3647. C corporation election to become, or transfer assets to, a RIC or REIT. 130 Sec. 3648. Interests in RICs and REITs not excluded from definition of United States real property interests 130 Sec. 3649. Dividends derived from RICs and REITs ineligible for deduction for United States source portion of dividends from certain foreign corporations. 131 Part 4 — Personal Holding Companies 132 Sec. 3661. Exclusion of dividends from controlled foreign corporations from the definition of personal holding company income for purposes of the personal holding company rules 132 Subtitle H — Taxation of Foreign Persons 132 Sec. 3701. Prevention of avoidance of tax through reinsurance with non-taxed affiliates. 132 Sec. 3702. Taxation of passenger cruise gross income of foreign corporations and nonresident alien individuals. 133 Sec. 3703. Restriction on insurance business exception to passive foreign investment company rules. 134 Sec. 3704. Modification of limitation on earnings stripping. 134 Sec. 3705. Limitation on treaty benefits for certain deductible payments 135 Subtitle I — Provisions Related to Compensation 135 Part I — Executive Compensation 135 Sec. 3801. Nonqualified deferred compensation. 135 Sec. 3802. Modification of limitation on excessive employee remuneration. 136 Sec. 3803. Excise tax on excess tax-exempt organization executive compensation. 137 Sec. 3804. Denial of deduction as research expenditure for stock transferred pursuant to an incentive stock option. 138 Part 2 — Worker Classification 138 Sec. 3811. Determination of worker classification 138 Subtitle J — Zones and Short-Term Regional Benefits 139 Sec. 3821. Repeal of provisions relating to Empowerment Zones and Enterprise Communities 139 Sec. 3822. Repeal of DC Zone provisions. 140 Sec. 3823. Repeal of provisions relating to renewal communities 140 Sec. 3824. Repeal of various short-term regional benefits. 141 Title IV — Participation Exemption System for the Taxation of Foreign Income 142 Subtitle A — Establishment of Exemption System 142 Sec. 4001. Deduction for dividends received by domestic corporations from certain foreign corporations 142 Sec. 4002. Limitation on losses with respect to specified 10-percent owned foreign corporations. 142 Sec. 4003. Treatment of deferred foreign income upon transition to participation exemption system of taxation. 143 Sec. 4004. Look-thru rule for related controlled foreign corporations made permanent 144 Preparedby Ways andMeans Committee Majority Tax Staff viii EFTA01078157  taxanalystr DOCUMENT S RVICE Doc 20144426 (193 pgs) Subtitle B — Modifications Related to Foreign Tax Credit System 145 Sec. 4101. Repeal of section 902 indirect foreign tax credits; determination of section 960 credit on current year basis 145 Sec. 4102. Foreign tax credit limitation applied by allocating only directly allocable deductions to foreign source income. 145 Sec. 4103. Passive category income expanded to include other mobile income. 146 Sec. 4104. Source of income from sales of inventory determined solely on basis of production activities 146 Subtitle C — Rules Related to Passive and Mobile Income 147 Part I — Modification of Subpart F Provisions 147 Sec. 4201. Subpart F income to only include low-taxed foreign income. 147 Sec. 4202. Foreign base company sales income. 147 Sec. 4203. Inflation adjustment of de minimis exception for foreign base company income 148 Sec. 4204. Active finance exception extended with limitation for low-taxed foreign income 148 Sec. 4205. Repeal of inclusion based on withdrawal of previously excluded subpart F income from qualified investment. 149 Part 2 — Prevention of Base Erosion 149 Sec. 4211. Foreign intangible income subject to taxation at reduced rate; intangible income treated as subpart F income 149 Sec. 4212. Denial of deduction for interest expense of United States shareholders which are members of worldwide affiliated groups with excess domestic indebtedness 151 Title V — Tax Exempt Entities 152 Subtitle A — Unrelated Business Income Tax 152 Sec. 5001. Clarification of unrelated business income tax treatment of entities treated as exempt from taxation under section 501(a) 152 Sec. 5002. Name and logo royalties treated as unrelated business taxable income 153 Sec. 5003. Unrelated business taxable income separately computed for each trade or business activity 153 Sec. 5004. Exclusion of research income limited to publicly available research. 154 Sec. 5005. Parity of charitable contribution limitation between trusts and corporations 154 Sec. 5006. Increased specific deduction. 154 Sec. 5007. Repeal of exclusion of gain or loss from disposition of distressed property 155 Sec. 5008. Qualified sponsorship payments. 155 Subtitle B — Penalties 156 Sec. 5101. Increase in information return penalties 156 Sec. 5102. Manager-level accuracy-related penalty on underpayment of unrelated business income tax. 157 Subtitle C — Excise Taxes 158 Sec. 5201. Modification of intermediate sanctions 158 Sec. 5202. Modification of taxes on self-dealing. 159 Preparedby Ways andMeans Committee Majority Tax Staff rx EFTA01078158  taxanalystr DOCUMENT S RVICE Doc 20144426 (193 pgs) Sec. 5203. Excise tax on failure to distribute within 5 years contribution to donor advised fund 160 Sec. 5204. Simplification of excise tax on private foundation investment income 161 Sec. 5205. Repeal of exception for private operating foundation failure to distribute income 161 Sec. 5206. Excise tax based on investment income of private colleges and universities 162 Subtitle D — Requirements for Organizations Exempt from Tax 162 Sec. 5301. Repeal of tax-exempt status for professional sports leagues 162 Sec. 5302. Repeal of exemption from tax for certain insurance companies and co-op health insurance issuers. 163 Sec. 5303. In-State requirement for workmen's compensation insurance organizations 163 Sec. 5304. Repeal of Type II and Type III supporting organizations. 164 Title VI —Tax Administration and Compliance 165 Subtitle A — IRS Investigation-Related Reforms 165 Sec. 6001. Organizations required to notify Secretary of intent to operate as 501(c)(4) 165 Sec. 6002. Declaratory judgments for 501(c)(4) organizations. 166 Sec. 6003. Restriction on donation reporting for certain 501(c)(4) organizations. 167 Sec. 6004. Mandatory electronic filing for annual returns of exempt organizations 167 Sec. 6005. Duty to ensure that IRS employees are familiar with and act in accord with certain taxpayer rights 168 Sec. 6006. Termination of employment of IRS employees for taking official actions for political purposes. 168 Sec. 6007. Release of information regarding the status of certain investigations. 169 Sec. 6008. Review of IRS examination selection procedures 169 Sec. 6009. IRS employees prohibited from using personal email accounts for official business 170 Sec. 6010. Moratorium on IRS conferences. 170 Sec. 6011. Applicable standard for determinations of whether an organization is operated exclusively for the promotion of social welfare 170 Subtitle B — Taxpayer Protection and Service Reforms 171 Sec. 6101. Extension of IRS authority to require truncated Social Security numbers on Form W-2 171 Sec. 6102. Free electronic filing. 172 Sec. 6103. Pre-populated returns prohibited 172 Sec. 6104. Form 1040SR for seniors 173 Sec. 6105. Increased refund and credit threshold for Joint Committee on Taxation review of C corporation return 174 Subtitle C — Tax Return Due Date Simplification 174 Secs. 6201-6203. Due dates for returns of partnerships, S corporations, and C corporations; Modification of due dates by regulation; Corporations permitted statutory automatic 6-month extension of income tax returns. 174 Subtitle D — Compliance Reforms 175 Sec. 6301. Penalty for failure to file. 175 Preparedby Ways andMeans Committee Majority Tax Staff EFTA01078159  =Ma • DOCUMENT ISMI Doc 20144426 (193 pgs) Sec. 6302. Penalty for failure to file correct information returns and provide payee statements 175 Sec. 6303. Clarification of 6-year statute of limitations in case of overstatement of basis. 176 Sec. 6304. Reform of rules related to qualified tax collection contracts. 176 Sec. 6305. 100 percent continuous levy on payments to Medicare providers and suppliers 177 Sec. 6306. Treatment of refundable credits for purposes of certain penalties. 178 Title VII — Excise Taxes 179 Sec. 7001. Repeal of medical device excise tax. 179 Sec. 7002. Modifications relating to oil spill liability trust fund. 179 Sec. 7003. Modification relating to inland waterways trust fund financing rate. 179 Sec. 7004. Excise tax on systemically important financial institutions. 180 Sec. 7005. Clarification of orphan drug exception to annual fee on branded prescription pharmaceutical manufacturers and importers 181 Title VIII — Deadwood and Technical Provisions 182 Subtitle A — Repeal of Deadwood 182 Secs. 8001-8084. Repeal of Deadwood. 182 Subtitle B — Conforming Amendments Related to Multiple Sections 182 Sec. 8101. Conforming amendments related to multiple sections 182 Preparedby Ways andMeans Committee Majority Tax Staff Xi EFTA01078160  tannalyStS . DOCUMENT S RVICE Doc 20144426 (193 pgs) Tax Reform Act of 2014 Discussion Draft Section-by-Section Summary Section 1. Short Title; Etc. This section provides: (1) a short title for the discussion draft, the "Tax Reform Act of 2014";