IB 

Union Calendar No. 616 

118TH CONGRESS 

2D SESSION H. R. 9495 

[Report No. 118–729] 

To amend the Internal Revenue Code of 1986 to postpone tax deadlines 

and reimburse paid late fees for United States nationals who are unlawfully or wrongfully detained or held hostage abroad, to terminate the 

tax-exempt status of terrorist supporting organizations, and for other 

purposes. 

IN THE HOUSE OF REPRESENTATIVES 

SEPTEMBER 9, 2024 

Ms. TENNEY (for herself, Mr. KUSTOFF, Mr. SCHNEIDER, and Ms. TITUS) introduced the following bill; which was referred to the Committee on Ways 

and Means 

NOVEMBER 8, 2024 

Additional sponsor: Ms. MALLIOTAKIS

NOVEMBER 8, 2024 

Reported with an amendment, committed to the Committee of the Whole 

House on the State of the Union, and ordered to be printed 

[Strike out all after the enacting clause and insert the part printed in italic] 

[For text of introduced bill, see copy of bill as introduced on September 9, 2024] 


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A BILL 

To amend the Internal Revenue Code of 1986 to postpone 

tax deadlines and reimburse paid late fees for United 

States nationals who are unlawfully or wrongfully detained or held hostage abroad, to terminate the taxexempt status of terrorist supporting organizations, and 

for other purposes. 


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1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Stop Terror-Financing 

5 and Tax Penalties on American Hostages Act’’. 

6 SEC. 2. POSTPONEMENT OF TAX DEADLINES FOR HOS7 TAGES AND INDIVIDUALS WRONGFULLY DE8 TAINED ABROAD. 

9 (a) IN GENERAL.—Chapter 77 of the Internal Revenue 

10 Code of 1986 is amended by inserting after section 7510 

11 the following new section: 

12 ‘‘SEC. 7511. TIME FOR PERFORMING CERTAIN ACTS POST13 PONED FOR HOSTAGES AND INDIVIDUALS 

14 WRONGFULLY DETAINED ABROAD. 

15 ‘‘(a) TIME TO BE DISREGARDED.— 

16 ‘‘(1) IN GENERAL.—The period during which an 

17 applicable individual was unlawfully or wrongfully 

18 detained abroad, or held hostage abroad, shall be dis19 regarded in determining, under the internal revenue 

20 laws, in respect of any tax liability of such indi21 vidual— 

22 ‘‘(A) whether any of the acts described in 

23 section 7508(a)(1) were performed within the 

24 time prescribed thereof (determined without re25 gard to extension under any other provision of 


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1 this subtitle for periods after the initial date (as 

2 determined by the Secretary) on which such in3 dividual was unlawfully or wrongfully detained 

4 abroad or held hostage abroad), 

5 ‘‘(B) the amount of any interest, penalty, 

6 additional amount, or addition to the tax for pe7 riods after such date, and 

8 ‘‘(C) the amount of any credit or refund. 

9 ‘‘(2) APPLICATION TO SPOUSE.—The provisions 

10 of paragraph (1) shall apply to the spouse of any in11 dividual entitled to the benefits of such paragraph. 

12 ‘‘(b) APPLICABLE INDIVIDUAL.— 

13 ‘‘(1) IN GENERAL.—For purposes of this section, 

14 the term ‘applicable individual’ means any indi15 vidual who is— 

16 ‘‘(A) a United States national unlawfully 

17 or wrongfully detained abroad, as determined 

18 under section 302 of the Robert Levinson Hos19 tage Recovery and Hostage-Taking Account20 ability Act (22 U.S.C. 1741), or 

21 ‘‘(B) a United States national taken hostage 

22 abroad, as determined pursuant to the findings 

23 of the Hostage Recovery Fusion Cell (as de24 scribed in section 304 of the Robert Levinson 


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1 Hostage Recovery and Hostage-Taking Account2 ability Act (22 U.S.C. 1741b)). 

3 ‘‘(2) INFORMATION PROVIDED TO TREASURY.— 

4 For purposes of identifying individuals described in 

5 paragraph (1), not later than January 1, 2025, and 

6 annually thereafter— 

7 ‘‘(A) the Secretary of State shall provide the 

8 Secretary with a list of the individuals described 

9 in paragraph (1)(A), as well as any other infor10 mation necessary to identify such individuals, 

11 and 

12 ‘‘(B) the Attorney General, acting through 

13 the Hostage Recovery Fusion Cell, shall provide 

14 the Secretary with a list of the individuals de15 scribed in paragraph (1)(B), as well as any 

16 other information necessary to identify such in17 dividuals. 

18 ‘‘(c) MODIFICATION OF TREASURY DATABASES AND IN19 FORMATION SYSTEMS.—The Secretary shall ensure that 

20 databases and information systems of the Department of the 

21 Treasury are updated as necessary to ensure that statute 

22 expiration dates, interest and penalty accrual, and collec23 tion activities are suspended consistent with the application 

24 of subsection (a). 


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1 ‘‘(d) REFUND AND ABATEMENT OF PENALTIES AND

2 FINES IMPOSED PRIOR TO IDENTIFICATION AS APPLICABLE

3 INDIVIDUAL.—In the case of any applicable individual— 

4 ‘‘(1) for whom any interest, penalty, additional 

5 amount, or addition to the tax in respect to any tax 

6 liability for any taxable year ending during the pe7 riod described in subsection (a)(1) was assessed or col8 lected, and 

9 ‘‘(2) who was, subsequent to such assessment or 

10 collection, determined to be an individual described in 

11 subparagraph (A) or (B) of subsection (b)(1), 

12 the Secretary shall abate any such assessment and refund 

13 any amount collected to such applicable individual in the 

14 same manner as any refund of an overpayment of tax under 

15 section 6402.’’. 

16 (b) CLERICAL AMENDMENT.—The table of sections for 

17 chapter 77 of the Internal Revenue Code of 1986 is amended 

18 by inserting after the item relating to section 7510 the fol19 lowing new item: 

‘‘Sec. 7511. Time for performing certain acts postponed for hostages and individuals wrongfully detained abroad.’’. 

20 (c) EFFECTIVE DATE.—The amendments made by this 

21 section shall apply to taxable years ending after the date 

22 of enactment of this Act. 


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1 SEC. 3. REFUND AND ABATEMENT OF PENALTIES AND 

2 FINES PAID BY ELIGIBLE INDIVIDUALS. 

3 (a) IN GENERAL.—Section 7511 of the Internal Rev4 enue Code of 1986, as added by section 2, is amended by 

5 adding at the end the following new subsection: 

6 ‘‘(e) REFUND AND ABATEMENT OF PENALTIES AND

7 FINES PAID BY ELIGIBLE INDIVIDUALS WITH RESPECT TO

8 PERIODS PRIOR TO DATE OF ENACTMENT OF THIS SEC9 TION.— 

10 ‘‘(1) IN GENERAL.— 

11 ‘‘(A) ESTABLISHMENT.—Not later than 

12 January 1, 2025, the Secretary (in consultation 

13 with the Secretary of State and the Attorney 

14 General) shall establish a program to allow any 

15 eligible individual (or the spouse or any depend16 ent (as defined in section 152) of such indi17 vidual) to apply for a refund or an abatement 

18 of any amount described in paragraph (2) (in19 cluding interest) to the extent such amount was 

20 attributable to the applicable period. 

21 ‘‘(B) IDENTIFICATION OF INDIVIDUALS.— 

22 Not later than January 1, 2025, the Secretary of 

23 State and the Attorney General, acting through 

24 the Hostage Recovery Fusion Cell (as described 

25 in section 304 of the Robert Levinson Hostage 


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1 Recovery and Hostage-Taking Accountability Act 

2 (22 U.S.C. 1741b)), shall— 

3 ‘‘(i) compile a list, based on such infor4 mation as is available, of individuals who 

5 were applicable individuals during the ap6 plicable period, and 

7 ‘‘(ii) provide the list described in 

8 clause (i) to the Secretary. 

9 ‘‘(C) NOTICE.—For purposes of carrying 

10 out the program described in subparagraph (A), 

11 the Secretary (in consultation with the Secretary 

12 of State and the Attorney General) shall, with 

13 respect to any individual identified under sub14 paragraph (B), provide notice to such indi15 vidual— 

16 ‘‘(i) in the case of an individual who 

17 has been released on or before the date of en18 actment of this subsection, not later than 90 

19 days after the date of enactment of this sub20 section, or 

21 ‘‘(ii) in the case of an individual who 

22 is released after the date of enactment of 

23 this subsection, not later than 90 days after 

24 the date on which such individual is re25 leased, 


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1 that such individual may be eligible for a refund 

2 or an abatement of any amount described in 

3 paragraph (2) pursuant to the program de4 scribed in subparagraph (A). 

5 ‘‘(D) AUTHORIZATION.— 

6 ‘‘(i) IN GENERAL.—Subject to clause 

7 (ii), in the case of any refund described in 

8 subparagraph (A), the Secretary shall issue 

9 such refund to the eligible individual in the 

10 same manner as any refund of an overpay11 ment of tax. 

12 ‘‘(ii) EXTENSION OF LIMITATION ON

13 TIME FOR REFUND.—With respect to any 

14 refund under subparagraph (A)— 

15 ‘‘(I) the 3-year period of limita16 tion prescribed by section 6511(a) shall 

17 be extended until the end of the 1-year 

18 period beginning on the date that the 

19 notice described in subparagraph (C) 

20 is provided to the eligible individual, 

21 and 

22 ‘‘(II) any limitation under section 

23 6511(b)(2) shall not apply. 

24 ‘‘(2) ELIGIBLE INDIVIDUAL.—For purposes of 

25 this subsection, the term ‘eligible individual’ means 


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1 any applicable individual who, for any taxable year 

2 ending during the applicable period, paid or incurred 

3 any interest, penalty, additional amount, or addition 

4 to the tax in respect to any tax liability for such year 

5 of such individual based on a determination that an 

6 act described in section 7508(a)(1) which was not 

7 performed by the time prescribed therefor (without re8 gard to any extensions). 

9 ‘‘(3) APPLICABLE PERIOD.—For purposes of this 

10 subsection, the term ‘applicable period’ means the pe11 riod— 

12 ‘‘(A) beginning on January 1, 2021, and 

13 ‘‘(B) ending on the date of enactment of this 

14 subsection.’’. 

15 (b) EFFECTIVE DATE.—The amendment made by this 

16 section shall apply to taxable years ending on or before the 

17 date of enactment of this Act. 

18 SEC. 4. TERMINATION OF TAX-EXEMPT STATUS OF TER19 RORIST SUPPORTING ORGANIZATIONS. 

20 (a) IN GENERAL.—Section 501(p) of the Internal Rev21 enue Code of 1986 is amended by adding at the end the 

22 following new paragraph: 

23 ‘‘(8) APPLICATION TO TERRORIST SUPPORTING

24 ORGANIZATIONS.— 


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1 ‘‘(A) IN GENERAL.—For purposes of this 

2 subsection, in the case of any terrorist sup3 porting organization— 

4 ‘‘(i) such organization (and the des5 ignation of such organization under sub6 paragraph (B)) shall be treated as described 

7 in paragraph (2), and 

8 ‘‘(ii) the period of suspension described 

9 in paragraph (3) with respect to such orga10 nization shall be treated as beginning on the 

11 date that the Secretary designates such or12 ganization under subparagraph (B) and 

13 ending on the date that the Secretary re14 scinds such designation under subparagraph 

15 (D). 

16 ‘‘(B) TERRORIST SUPPORTING ORGANIZA17 TION.—For purposes of this paragraph, the term 

18 ‘terrorist supporting organization’ means any 

19 organization which is designated by the Sec20 retary as having provided, during the 3-year pe21 riod ending on the date of such designation, ma22 terial support or resources (within the meaning 

23 of section 2339B of title 18, United States Code) 

24 to an organization described in paragraph (2) 

25 (determined after the application of this paraVerDate Sep 11 2014 21:56 Nov 08, 2024 Jkt 059200 PO 00000 Frm 00011 Fmt 6652 Sfmt 6203 E:\BILLS\H9495.RH H9495

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1 graph to such organization) in excess of a de 

2 minimis amount. 

3 ‘‘(C) DESIGNATION PROCEDURE.— 

4 ‘‘(i) NOTICE REQUIREMENT.—Prior to 

5 designating any organization as a terrorist 

6 supporting organization under subpara7 graph (B), the Secretary shall mail to the 

8 most recent mailing address provided by 

9 such organization on the organization’s an10 nual return or notice under section 6033 (or 

11 subsequent form indicating a change of ad12 dress) a written notice which includes— 

13 ‘‘(I) a statement that the Sec14 retary will designate such organization 

15 as a terrorist supporting organization 

16 unless the organization satisfies the re17 quirements of subclause (I) or (II) of 

18 clause (ii), 

19 ‘‘(II) the name of the organization 

20 or organizations with respect to which 

21 the Secretary has determined such or22 ganization provided material support 

23 or sources as described in subpara24 graph (B), and 


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1 ‘‘(III) a description of such mate2 rial support or resources to the extent 

3 consistent with national security and 

4 law enforcement interests. 

5 ‘‘(ii) OPPORTUNITY TO CURE.—In the 

6 case of any notice provided to an organiza7 tion under clause (i), the Secretary shall, at 

8 the close of the 90-day period beginning on 

9 the date that such notice was sent, designate 

10 such organization as a terrorist supporting 

11 organization under subparagraph (B) if 

12 (and only if) such organization has not 

13 (during such period)— 

14 ‘‘(I) demonstrated to the satisfac15 tion of the Secretary that such organi16 zation did not provide the material 

17 support or resources referred to in sub18 paragraph (B), or 

19 ‘‘(II) made reasonable efforts to 

20 have such support or resources re21 turned to such organization and cer22 tified in writing to the Secretary that 

23 such organization will not provide any 

24 further support or resources to organi25 zations described in paragraph (2). 


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1 A certification under subclause (II) shall 

2 not be treated as valid if the organization 

3 making such certification has provided any 

4 other such certification during the preceding 

5 5 years. 

6 ‘‘(D) RESCISSION.—The Secretary shall re7 scind a designation under subparagraph (B) if 

8 (and only if)— 

9 ‘‘(i) the Secretary determines that such 

10 designation was erroneous, 

11 ‘‘(ii) after the Secretary receives a 

12 written certification from an organization 

13 that such organization did not receive the 

14 notice described in subparagraph (C)(i)— 

15 ‘‘(I) the Secretary determines that 

16 it is reasonable to believe that such or17 ganization did not receive such notice, 

18 and 

19 ‘‘(II) such organization satisfies 

20 the requirements of subclause (I) or 

21 (II) of subparagraph (C)(ii) (deter22 mined after taking into account the 

23 last sentence thereof), or 

24 ‘‘(iii) the Secretary determines, with 

25 respect to all organizations to which the 


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1 material support or resources referred to in 

2 subparagraph (B) were provided, the peri3 ods of suspension under paragraph (3) have 

4 ended. 

5 A certification described in the matter preceding 

6 subclause (I) of clause (II) shall not be treated 

7 as valid if the organization making such certifi8 cation has provided any other such certification 

9 during the preceding 5 years. 

10 ‘‘(E) ADMINISTRATIVE REVIEW BY INTER11 NAL REVENUE SERVICE INDEPENDENT OFFICE OF

12 APPEALS.—In the case of the designation of an 

13 organization by the Secretary as a terrorist sup14 porting organization under subparagraph (B), a 

15 dispute regarding such designation shall be sub16 ject to resolution by the Internal Revenue Service 

17 Independent Office of Appeals under section 

18 7803(e) in the same manner as if such designa19 tion were made by the Internal Revenue Service 

20 and paragraph (5) of this subsection did not 

21 apply. 

22 ‘‘(F) JURISDICTION OF UNITED STATES

23 COURTS.—Notwithstanding paragraph (5), the 

24 United States district courts shall have exclusive 

25 jurisdiction to review a final determination with 


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1 respect to an organization’s designation as a ter2 rorist supporting organization under subpara3 graph (B). In the case of any such determination 

4 which was based on classified information (as 

5 defined in section 1(a) of the Classified Informa6 tion Procedures Act), such information may be 

7 submitted to the reviewing court ex parte and in 

8 camera. For purposes of this subparagraph, a 

9 determination with respect to an organization’s 

10 designation as a terrorist supporting organiza11 tion shall not fail to be treated as a final deter12 mination merely because such organization fails 

13 to utilize the dispute resolution process of the In14 ternal Revenue Service Independent Office of Ap15 peals provided under subparagraph (E).’’. 

16 (b) EFFECTIVE DATE.—The amendment made by this 

17 section shall apply to designations made after the date of 

18 the enactment of this Act in taxable years ending after such 

19 date. 


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Union Calendar No. 616 

118TH CONGRESS 

2D SESSION H. R. 9495 

[Report No. 118–729] 

A BILL 

To amend the Internal Revenue Code of 1986 to 

purposes. terrorist supporting organizations, and for other abroad, to terminate the tax-exempt status of fully or wrongfully detained or held hostage fees for United States nationals who are unlawpostpone tax deadlines and reimburse paid late 

NOVEMBER 8, 2024 

Reported with an amendment, committed to the Comand ordered to be printed mittee of the Whole House on the State of the Union, 


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