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HR 2014119th CongressIntroduced
Reduction of Excess Business Holding Accrual Act
Introduced: Oct 28, 2025
Standard Summary
Comprehensive overview in 1-2 paragraphs
Amends the Internal Revenue Code to treat employee‑owned stock purchased under ESOPs as outstanding for private foundation excess business holdings tax purposes, clarifying the treatment and effective dates.
Key Points
- 1Certain ESOP‑purchased voting stock is treated as outstanding for foundation tax.
- 2Limits the treatment to prevent holdings exceeding 49 %.
- 3Effective for taxable years ending after enactment and purchases after 2019.
- 4Clarifies that the treatment does not apply to the first 10‑year period of the plan.
Impact Areas
Private foundationsEmployee‑owned companiesIRS and tax practitioners
Generated by openai/gpt-oss-20b:free on Nov 20, 2025