49–006 

114TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 1st Session 114–16 

PERMANENT S CORPORATION CHARITABLE 

CONTRIBUTION ACT OF 2015 

FEBRUARY 9, 2015.—Committed to the Committee of the Whole House on the State 

of the Union and ordered to be printed 

Mr. RYAN of Wisconsin, from the Committee on Ways and Means, 

submitted the following 

R E P O R T 

together with 

DISSENTING VIEWS 

[To accompany H.R. 630] 

[Including cost estimate of the Congressional Budget Office] 

The Committee on Ways and Means, to whom was referred the 

bill (H.R. 630) to amend the Internal Revenue Code of 1986 to 

make permanent certain rules regarding basis adjustments to stock 

of S corporations making charitable contributions of property, having considered the same, report favorably thereon with an amendment and recommend that the bill as amended do pass. 

CONTENTS 

Page 

I. SUMMARY AND BACKGROUND ............................................................... 2 

A. Purpose and Summary ..................................................................... 2 

B. Background and Need for Legislation ............................................. 2 

C. Legislative History ............................................................................ 2 

II. EXPLANATION OF THE BILL ................................................................... 3 

A. Permanent Rule Regarding Basis Adjustment to Stock of S 

Corporations Making Charitable Contributions of Property 

(sec. 1367 of the Code) ................................................................... 3 

III. VOTES OF THE COMMITTEE .................................................................... 4 

IV. BUDGET EFFECTS OF THE BILL ............................................................ 4 

A. Committee Estimate of Budgetary Effects ...................................... 4 

B. Statement Regarding New Budget Authority and Tax Expenditures Budget Authority .................................................................. 5 

C. Cost Estimate Prepared by the Congressional Budget Office ....... 5 

V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF 

THE HOUSE .............................................................................................. 6 


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A. Committee Oversight Findings and Recommendations ................. 6 

B. Statement of General Performance Goals and Objectives ............. 6 

C. Information Relating to Unfunded Mandates ................................ 6 

D. Applicability of House Rule XXI 5(b) .............................................. 7 

E. Tax Complexity Analysis .................................................................. 7 

F. Congressional Earmarks, Limited Tax Benefits, and Limited 

Tariff Benefits ................................................................................. 7 

G. Duplication of Federal Programs ..................................................... 7 

H. Disclosure of Directed Rule Makings .............................................. 7 

VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED 8 

VII. DISSENTING VIEWS ................................................................................... 9 

The amendment is as follows: 

Strike all after the enacting clause and insert the following: 

SECTION 1. SHORT TITLE. 

This Act may be cited as the ‘‘Permanent S Corporation Charitable Contribution 

Act of 2015’’. 

SEC. 2. PERMANENT RULE REGARDING BASIS ADJUSTMENT TO STOCK OF S CORPORATIONS 

MAKING CHARITABLE CONTRIBUTIONS OF PROPERTY. 

(a) IN GENERAL.—Section 1367(a)(2) of the Internal Revenue Code of 1986 is 

amended by striking the last sentence. 

(b) EFFECTIVE DATE.—The amendment made by this section shall apply to contributions made in taxable years beginning after December 31, 2014. 

I. SUMMARY AND BACKGROUND 

A. PURPOSE AND SUMMARY

H.R. 630, reported by the Committee on Ways and Means, provides that a shareholder’s basis in his S corporation stock is decreased by the adjusted basis of any charitable contributions made 

by the S corporation, rather than the fair market value. An identical, temporary provision expired for taxable years beginning after 

December 31, 2014. 

B. BACKGROUND AND NEED FOR LEGISLATION

While the Committee continues actively to pursue comprehensive 

tax reform as a critical means of promoting economic growth and 

job creation, the Committee also believes that it is important to 

provide small businesses permanent, immediate tax relief in order 

to help encourage economic growth and job creation. By providing 

small businesses with a permanent rule for adjusting the shareholders’ basis in stock of an S corporation making charitable contributions, H.R. 630 corrects a disparity between the treatment of 

charitable contributions made by S corporations and partnerships, 

which can result in a future tax liability for shareholders of an S 

corporation that donates appreciated property. H.R. 630 will level 

the playing field between S corporations and other types of businesses and provide S corporations with greater certainty so they 

can plan for charitable giving that is in the best interest of the 

company, its shareholders, and the charitable organizations receiving such donations. 

C. LEGISLATIVE HISTORY

Background 

H.R. 630 was introduced on January 30, 2015, and was referred 

to the Committee on Ways and Means. 


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1Sec. 1366(a)(1)(A). 

2Sec. 1367(a)(2)(B). See also the last sentence of section 1366(a)(1) referencing sec. 702(a)(4). 

Committee action 

The Committee on Ways and Means marked up H.R. 630, the 

Permanent S Corporation Charitable Contribution Act of 2015, on 

February 4, 2015, and ordered the bill, as amended, favorably reported (with a quorum being present). 

Committee hearings 

The need for permanent rules regarding basis adjustments to 

stock of S corporations making charitable contributions of property 

was discussed at no fewer than four hearings during the 112th and 

113th Congresses: 

• Full Committee hearing on Fundamental Tax Reform 

(January 20, 2011); 

• Full Committee hearing on the Treatment of Closely-Held 

Businesses in the Context of Tax Reform (March 7, 2012); 

• Full Committee hearing on the Small Business and PassThrough Entity Tax Reform Discussion Draft (May 15, 

2013); and 

• Full Committee hearing on the Benefits of Permanent Tax 

Policy for America’s Job Creators (April 8, 2014). 

II. EXPLANATION OF THE BILL 

A. PERMANENT RULE REGARDING BASIS ADJUSTMENT TO STOCK OF

S CORPORATIONS MAKING CHARITABLE CONTRIBUTIONS OF PROP- ERTY (SEC. 1367 OF THE CODE) 

PRESENT LAW

Under present law, if an S corporation makes a charitable contribution of money or other property, each shareholder takes into 

account the shareholder’s pro rata share of the contribution in determining its own income tax liability.1 A shareholder of an S corporation reduces the basis in the stock of the S corporation by the 

shareholder’s pro rata share of the S corporation’s charitable contributions.2

In the case of contributions made in taxable years beginning before January 1, 2015, the amount of a shareholder’s basis reduction 

in the stock of an S corporation on account of a charitable contribution made by the corporation is the shareholder’s pro rata share of 

the adjusted basis of the contributed property. For contributions 

made in taxable years beginning after December 31, 2014, the 

amount of the reduction is the shareholder’s pro rata share of the 

fair market value of the contributed property. 

REASONS FOR CHANGE

The Committee believes that the provision regarding basis adjustments to S corporation stock should be made permanent to prevent S corporation shareholders from losing the tax benefit of the 

deduction for charitable contributions of appreciated property when 

the shareholders sell their stock. Under the provision, S corporation shareholders will be treated in the same manner as other persons owning an interest in a business making charitable contribuVerDate Sep 11 2014 05:25 Feb 10, 2015 Jkt 049006 PO 00000 Frm 00003 Fmt 6659 Sfmt 6602 E:\HR\OC\HR016.XXX HR016

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tions, including partnerships and limited liability companies. The 

Committee also believes that this provision will encourage charitable giving. 

EXPLANATION OF PROVISION

The provision makes permanent the basis reduction rule applicable for contributions made in taxable years beginning before January 1, 2015. 

EFFECTIVE DATE

The provision applies to charitable contributions made in taxable 

years beginning after December 31, 2014. 

III. VOTES OF THE COMMITTEE 

In compliance with clause 3(b) of rule XIII of the Rules of the 

House of Representatives, the following statement is made concerning the vote of the Committee on Ways and Means in its consideration of H.R. 630, the Permanent S Corporation Charitable 

Contribution Act of 2015, on February 4, 2015. 

The bill, H.R. 630, was ordered favorably reported as amended 

by a roll call vote of 24 yeas to 14 nays (with a quorum being 

present). The vote was as follows: 

Representative Yea Nay Present Representative Yea Nay Present 

Mr. Ryan ............................... X ........... ............. Mr. Levin ............................. ........... X .............

Mr. Johnson .......................... X ........... ............. Mr. Rangel .......................... ........... X .............

Mr. Brady ............................. X ........... ............. Mr. McDermott .................... ........... X .............

Mr. Nunes ............................ X ........... ............. Mr. Lewis ............................. ........... X .............

Mr. Tiberi ............................. X ........... ............. Mr. Neal .............................. ........... X .............

Mr. Reichert ......................... X ........... ............. Mr. Becerra ......................... ........... X .............

Mr. Boustany ........................ X ........... ............. Mr. Doggett ......................... ........... X .............

Mr. Roskam .......................... X ........... ............. Mr. Thompson ..................... ........... X .............

Mr. Price .............................. X ........... ............. Mr. Larson ........................... ........... X .............

Mr. Buchanan ...................... X ........... ............. Mr. Blumenauer .................. ........... ............. .............

Mr. Smith (NE) ..................... X ........... ............. Mr. Kind .............................. ........... X .............

Mr. Schock ........................... X ........... ............. Mr. Pascrell ......................... ........... X .............

Ms. Jenkins .......................... X ........... ............. Mr. Crowley ......................... ........... X .............

Mr. Paulsen .......................... X ........... ............. Mr. Davis ............................. ........... X .............

Mr. Marchant ....................... X ........... ............. Ms. Sanchez ........................ ........... X .............

Ms. Black ............................. X ........... .............

Mr. Reed .............................. X ........... .............

Mr. Young ............................ X ........... .............

Mr. Kelly ............................... X ........... .............

Mr. Renacci .......................... X ........... .............

Mr. Meehan .......................... X ........... .............

Ms. Noem ............................. X ........... .............

Mr. Holding .......................... X ........... .............

Mr. Smith (MO) .................... X ........... .............

IV. BUDGET EFFECTS OF THE BILL 

A. COMMITTEE ESTIMATE OF BUDGETARY EFFECTS

In compliance with clause 3(d) of rule XIII of the Rules of the 

House of Representatives, the following statement is made concerning the effects on the budget of the bill, H.R. 630, as reported. 

The bill, as reported, is estimated to have the following effect on 

Federal budget receipts for fiscal years 2015–2025: 


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FISCAL YEARS 

[Millions of dollars] 

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2015–20 2015–25 

¥23 ¥49 ¥53 ¥55 ¥57 ¥59 ¥61 ¥64 ¥68 ¥71 ¥75 ¥296 ¥635 

NOTE: Details do not add to totals due to rounding. 

Pursuant to clause 8 of rule XIII of the Rules of the House of 

Representatives, the following statement is made by the Joint Committee on Taxation with respect to the provisions of the bill amending the Internal Revenue Code of 1986: the gross budgetary effect 

(before incorporating macroeconomic effects) in any fiscal year is 

less than 0.25 percent of the current projected gross domestic product of the United States for that fiscal year; therefore, the bill is 

not ‘‘major legislation’’ for purposes of requiring that the estimate 

include the budgetary effects of changes in economic output, employment, capital stock and other macroeconomic variables. 

B. STATEMENT REGARDING NEW BUDGET AUTHORITY AND TAX

EXPENDITURES BUDGET AUTHORITY

In compliance with clause 3(c)(2) of rule XIII of the Rules of the 

House of Representatives, the Committee states that the bill involves no new or increased budget authority. The Committee states 

further that the bill involves no new or increased tax expenditures. 

C. COST ESTIMATE PREPARED BY THE CONGRESSIONAL BUDGET

OFFICE

In compliance with clause 3(c)(3) of rule XIII of the Rules of the 

House of Representatives, requiring a cost estimate prepared by 

the CBO, the following statement by CBO is provided. 

U.S. CONGRESS, 

CONGRESSIONAL BUDGET OFFICE, 

Washington, DC, February 5, 2015. 

Hon. PAUL RYAN, 

Chairman, Committee on Ways and Means, 

House of Representatives, Washington, DC. 

DEAR MR. CHAIRMAN: The Congressional Budget Office has prepared the enclosed cost estimate for H.R. 630, the Permanent S 

Corporation Charitable Contribution Act of 2015. 

If you wish further details on this estimate, we will be pleased 

to provide them. The CBO staff contact is Nate Frentz. 

Sincerely, 

DOUGLAS W. ELMENDORF. 

Enclosure. 

H.R. 630—Permanent S Corporation Charitable Contribution Act of 

2015 

H.R. 630 would amend the Internal Revenue Code to make permanent a rule that expired at the end of 2014 that defines how a 

shareholder in an S corporation adjusts the basis of that S corporation stock to account for that corporation’s contributions of property 

to charity. This legislation would permanently provide that a 

shareholder reduces S corporation stock basis by an amount equal 


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to the shareholder’s pro rata share of the adjusted basis of the contributed property, instead of the pro rata share of the fair market 

value of the contributed property. 

The staff of the Joint Committee on Taxation (JCT) estimates 

that enacting H.R. 630 would reduce revenues, thus increasing federal deficits, by $635 million over the 2015–2025 period. 

The Statutory Pay-As-You-Go Act of 2010 establishes budget-reporting and enforcement procedures for legislation affecting direct 

spending and revenues. Enacting H.R. 630 would result in revenue 

losses in each year beginning in 2015. The estimated increases in 

the deficit are shown in the following table. 

JCT has determined that the bill contains no intergovernmental 

or private-sector mandates as defined in the Unfunded Mandates 

Reform Act. 

The CBO staff contact for this estimate is Nathaniel Frentz. The 

estimate was approved by David Weiner, Assistant Director for Tax 

Analysis. 

CBO ESTIMATE OF PAY-AS-YOU-GO EFFECTS FOR H.R. 630, AS ORDERED REPORTED BY THE 

HOUSE COMMITTEE ON WAYS AND MEANS ON FEBRUARY 4, 2015 

By fiscal year, in millions of dollars— 

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2015– 

2020 

2015– 

2025 

NET INCREASE IN THE DEFICIT 

Statutory Pay-As-You-Go Impact .... 23 49 53 55 57 59 61 64 68 71 75 296 635 

Source: Staff of the Joint Committee on Taxation. 

V. OTHER MATTERS TO BE DISCUSSED UNDER THE 

RULES OF THE HOUSE 

A. COMMITTEE OVERSIGHT FINDINGS AND RECOMMENDATIONS

With respect to clause 3(c)(1) of rule XIII of the Rules of the 

House of Representatives (relating to oversight findings), the Committee advises that it was as a result of the Committee’s review of 

the provisions of H.R. 630 that the Committee concluded that it is 

appropriate to report the bill, as amended, favorably to the House 

of Representatives with the recommendation that the bill do pass. 

B. STATEMENT OF GENERAL PERFORMANCE GOALS AND OBJECTIVES

With respect to clause 3(c)(4) of rule XIII of the Rules of the 

House of Representatives, the Committee advises that the bill contains no measure that authorizes funding, so no statement of general performance goals and objectives for which any measure authorizes funding is required. 

C. INFORMATION RELATING TO UNFUNDED MANDATES

This information is provided in accordance with section 423 of 

the Unfunded Mandates Reform Act of 1995 (Pub. L. No. 104–4). 

The Committee has determined that the bill does not contain 

Federal mandates on the private sector. The Committee has determined that the bill does not impose a Federal intergovernmental 

mandate on State, local, or tribal governments. 


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D. APPLICABILITY OF HOUSE RULE XXI 5(b) 

Rule XXI 5(b) of the Rules of the House of Representatives provides, in part, that ‘‘A bill or joint resolution, amendment, or conference report carrying a Federal income tax rate increase may not 

be considered as passed or agreed to unless so determined by a 

vote of not less than three-fifths of the Members voting, a quorum 

being present.’’ The Committee has carefully reviewed the bill, and 

states that the bill does not involve any Federal income tax rate 

increases within the meaning of the rule. 

E. TAX COMPLEXITY ANALYSIS

Section 4022(b) of the Internal Revenue Service Restructuring 

and Reform Act of 1998 (the ‘‘IRS Reform Act’’) requires the staff 

of the Joint Committee on Taxation (in consultation with the Internal Revenue Service and the Treasury Department) to provide a 

tax complexity analysis. The complexity analysis is required for all 

legislation reported by the Senate Committee on Finance, the 

House Committee on Ways and Means, or any committee of conference if the legislation includes a provision that directly or indirectly amends the Internal Revenue Code and has widespread applicability to individuals or small businesses. 

Pursuant to clause 3(h)(1) of rule XIII of the Rules of the House 

of Representatives, the staff of the Joint Committee on Taxation 

has determined that a complexity analysis is not required under 

section 4022(b) of the IRS Reform Act because the bill contains no 

provisions that amend the Code and that have ‘‘widespread applicability’’ to individuals or small businesses, within the meaning of 

the rule. 

F. CONGRESSIONAL EARMARKS, LIMITED TAX BENEFITS, AND

LIMITED TARIFF BENEFITS

With respect to clause 9 of rule XXI of the Rules of the House 

of Representatives, the Committee has carefully reviewed the provisions of the bill, and states that the provisions of the bill do not 

contain any congressional earmarks, limited tax benefits, or limited 

tariff benefits within the meaning of the rule. 

G. DUPLICATION OF FEDERAL PROGRAMS

In compliance with Sec. 3(g)(2) of H. Res. 5 (114th Congress), the 

Committee states that no provision of the bill establishes or reauthorizes: (1) a program of the Federal Government known to be 

duplicative of another Federal program, (2) a program included in 

any report from the Government Accountability Office to Congress 

pursuant to section 21 of Public Law 111–139, or (3) a program related to a program identified in the most recent Catalog of Federal 

Domestic Assistance, published pursuant to the Federal Program 

Information Act (Public Law 95–220, as amended by Public Law 

98–169). 

H. DISCLOSURE OF DIRECTED RULE MAKINGS

In compliance with Sec. 3(i) of H. Res. 5 (114th Congress), the 

following statement is made concerning directed rule makings: The 


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Committee estimates that the bill requires no directed rule makings within the meaning of such section. 

VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS 

REPORTED 

In compliance with clause 3(e) of rule XIII of the Rules of the 

House of Representatives, changes in existing law made by the bill, 

as reported, are shown as follows (existing law proposed to be omitted is enclosed in black brackets, new matter is printed in italic, 

existing law in which no change is proposed is shown in roman): 

INTERNAL REVENUE CODE OF 1986 

* * * * * * * 

Subtitle A—Income Taxes 

* * * * * * * 

CHAPTER 1—NORMAL TAXES AND SURTAXES 

* * * * * * * 

Subchapter S—Tax Treatment of S Corporations 

and Their Shareholders 

* * * * * * * 

PART II—TAX TREATMENT OF SHAREHOLDERS 

* * * * * * * 

SEC. 1367. ADJUSTMENTS TO BASIS OF STOCK OF SHAREHOLDERS, 

ETC. 

(a) GENERAL RULE.— (1) INCREASES IN BASIS.—The basis of each shareholder’s 

stock in an S corporation shall be increased for any period by 

the sum of the following items determined with respect to that 

shareholder for such period: 

(A) the items of income described in subparagraph (A) of 

section 1366(a)(1), 

(B) any nonseparately computed income determined 

under subparagraph (B) of section 1366(a)(1), and 

(C) the excess of the deductions for depletion over the 

basis of the property subject to depletion. 

(2) DECREASES IN BASIS.—The basis of each shareholder’s 

stock in an S corporation shall be decreased for any period (but 

not below zero) by the sum of the following items determined 

with respect to the shareholder for such period: 

(A) distributions by the corporation which were not includible in the income of the shareholder by reason of section 1368, 

(B) the items of loss and deduction described in subparagraph (A) of section 1366(a)(1), 


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(C) any nonseparately computed loss determined under 

subparagraph (B) of section 1366(a)(1), 

(D) any expense of the corporation not deductible in computing its taxable income and not properly chargeable to 

capital account, and 

(E) the amount of the shareholder’s deduction for depletion for any oil and gas property held by the S corporation 

to the extent such deduction does not exceed the proportionate share of the adjusted basis of such property allocated to such shareholder under section 613A(c)(11)(B). 

The decrease under subparagraph (B) by reason of a charitable 

contribution (as defined in section 170(c)) of property shall be 

the amount equal to the shareholder’s pro rata share of the adjusted basis of such property. øThe preceding sentence shall 

not apply to contributions made in taxable years beginning 

after December 31, 2014.¿ 

(b) SPECIAL RULES.— 

(1) INCOME ITEMS.—An amount which is required to be included in the gross income of a shareholder and shown on his 

return shall be taken into account under subparagraph (A) or 

(B) of subsection (a)(1) only to the extent such amount is included in the shareholder’s gross income on his return, increased or decreased by any adjustment of such amount in a 

redetermination of the shareholder’s tax liability. 

(2) ADJUSTMENTS IN BASIS OF INDEBTEDNESS.— (A) REDUCTION OF BASIS.—If for any taxable year the 

amounts specified in subparagraphs (B), (C), (D), and (E) 

of subsection (a)(2) exceed the amount which reduces the 

shareholder’s basis to zero, such excess shall be applied to 

reduce (but not below zero) the shareholder’s basis in any 

indebtedness of the S corporation to the shareholder. 

(B) RESTORATION OF BASIS.—If for any taxable year beginning after December 31, 1982, there is a reduction 

under subparagraph (A) in the shareholder’s basis in the 

indebtedness of an S corporation to a shareholder, any net 

increase (after the application of paragraphs (1) and (2) of 

subsection (a)) for any subsequent taxable year shall be 

applied to restore such reduction in basis before any of it 

may be used to increase the shareholder’s basis in the 

stock of the S corporation. 

(3) COORDINATION WITH SECTIONS 165(G) AND 166(D).—This 

section and section 1366 shall be applied before the application 

of sections 165(g) and 166(d) to any taxable year of the shareholder or the corporation in which the security or debt becomes 

worthless. 

(4) ADJUSTMENTS IN CASE OF INHERITED STOCK.— 

(A) IN GENERAL.—If any person acquires stock in an S 

corporation by reason of the death of a decedent or by bequest, devise, or inheritance, section 691 shall be applied 

with respect to any item of income of the S corporation in 

the same manner as if the decedent had held directly his 

pro rata share of such item. 

(B) ADJUSTMENTS TO BASIS.—The basis determined 

under section 1014 of any stock in an S corporation shall 

be reduced by the portion of the value of the stock which 


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is attributable to items constituting income in respect of 

the decedent. 

* * * * * * * 


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VII. DISSENTING VIEWS 

The seven bills approved by the Republicans at the markup 

would add more than $93 billion to the deficit—and if history is our 

guide, this is merely the start of the approach the Republicans embraced last Congress. In the 113th Congress, Ways and Means 

Committee Republicans approved $825 billion worth of deficit-financed, permanent tax cuts. The bills marked up by the Committee 

set us down a partisan path, when we should be embracing bipartisanship and working in a responsible, bipartisan manner on tax reform. 

Even though some of these bills were introduced individually 

with some bipartisan support, the opposition to these bills was 

based on the position that these tax provisions should not be made 

permanent by adding to the deficit without any revenue offset. Our 

nation’s small businesses play a vital role in the economy. They are 

the backbone of our communities, creating jobs, economic growth, 

and harnessing the American entrepreneurial spirit—this is undeniable. But the approach that the Committee Republicans are taking with respect to this and other important legislation undermines 

that bipartisan support that the provisions enjoy. The American 

people expect a tax code that maintains and supports our shared 

priorities, and each time the Committee considers these bills in a 

piecemeal approach, it is taking a step in the wrong direction and 

away from comprehensive tax reform. 

We all support the small businesses in our communities and 

across the nation. The markup was not to debate the economic 

growth driven by small businesses, the role of small businesses donations in our country’s charitable giving, or the merits of H.R. 

630, which would make permanent the certain rules regarding 

basis adjustments to the stock of S corporations making charitable 

contributions of property. 

Finally, we also oppose the manner in which Republicans were 

proceeding—selecting seven provisions to make permanent at a 

cost of nearly $100 billion without any offset from the approximately 60 tax provisions that expired at the end of last year. This 

approach is both fiscally irresponsible and contrary to the goals of 

bipartisan, comprehensive tax reform. 


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Expired provisions must be dealt with in a comprehensive manner. The Republicans did not take up other tax extenders that also 

are important to Democratic Committee Members. Left to an uncertain fate are provisions like the Work Opportunity Tax Credit, 

the New Markets Tax Credit, and the renewable energy tax credits, 

as well as the long-term status of the Earned Income Tax Credit, 

the Child Tax Credit, and the American Opportunity Tax Credit. 

SANDER M. LEVIN. 

Æ 


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