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[House Report 113-497]
[From the U.S. Government Publishing Office]

113th Congress                                                   Report
                        HOUSE OF REPRESENTATIVES
 2d Session                                                     113-497

======================================================================

 
        PRIVATE FOUNDATION EXCISE TAX SIMPLIFICATION ACT OF 2014

                                _______
                                

 June 26, 2014.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

                                _______
                                

Mr. Camp, from the Committee on Ways and Means, submitted the following

                              R E P O R T

                             together with

                            DISSENTING VIEWS

                        [To accompany H.R. 4691]

      [Including cost estimate of the Congressional Budget Office]

    The Committee on Ways and Means, to whom was referred the 
bill (H.R. 4691) to amend the Internal Revenue Code of 1986 to 
modify the tax rate for excise tax on investment income of 
private foundations, 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.................................     3
 II. EXPLANATION OF THE BILL..........................................3
          A. Simplification of Excise Tax on Private Foundation 
              Investment Income (sec. 4940 of the Code)..........     3
III. VOTES OF THE COMMITTEE...........................................4
 IV. BUDGET EFFECTS OF THE BILL.......................................5
          A. Committee Estimate of Budgetary Effects.............     5
          B. Statement Regarding New Budget Authority and Tax 
              Expenditures Budget Authority......................     5
          C. Cost Estimate Prepared by the Congressional Budget 
              Office.............................................     6
          D. Macroeconomic Impact Analysis.......................     7
  V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE.......7
          A. Committee Oversight Findings and Recommendations....     7
          B. Statement of General Performance Goals and 
              Objectives.........................................     7
          C. Information Relating to Unfunded Mandates...........     7
          D. Applicability of House Rule XXI 5(b)................     7
          E. Tax Complexity Analysis.............................     8
          F. Congressional Earmarks, Limited Tax Benefits, and 
              Limited Tariff Benefits............................     8
          G. Duplication of Federal Programs.....................     8
          H. Disclosure of Directed Rule Makings.................     8
 VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED............8
VII. DISSENTING VIEWS................................................11

    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 ``Private Foundation Excise Tax 
Simplification Act of 2014''.

SEC. 2. MODIFICATION OF THE TAX RATE FOR THE EXCISE TAX ON INVESTMENT 
                    INCOME OF PRIVATE FOUNDATIONS.

  (a) In General.--Section 4940(a) of the Internal Revenue Code of 1986 
is amended by striking ``2 percent'' and inserting ``1 percent''.
  (b) Elimination of Reduced Tax Where Foundation Meets Certain 
Distribution Requirements.--Section 4940 of such Code is amended by 
striking subsection (e).
  (c) Effective Date.--The amendments made by this section shall apply 
to taxable years beginning after the date of the enactment of this Act.

                       I. SUMMARY AND BACKGROUND

                         A. Purpose and Summary

    Similar to a provision contained in the discussion draft of 
the ``Tax Reform Act of 2014'' released on February 26, 2014, 
the bill, H.R. 4691, reported by the Committee on Ways and 
Means, provides that the excise tax rate on the net investment 
income of private foundations is reduced to 1 percent. The bill 
repeals the alternative rules that reduce the current-law 
excise tax rate from 2 percent to 1 percent for a private 
foundation with qualifying distributions that exceed the 
average historical level of its charitable distributions.

                 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 permanent, immediate tax relief 
to encourage faster economic growth and job creation, while 
fostering charitable giving. By simplifying and reducing the 
private foundation excise tax on net investment income, H.R. 
4691 eliminates a source of confusion and frustration, 
especially for smaller foundations, which can have endowments 
that vary in size significantly from year to year. Private 
foundations, both large and small, recommended to the 
Committee's 2013 Tax Reform Working Group on Charitable/Exempt 
Organizations that the net investment tax be reduced to a flat 
1 percent to ease compliance. By adopting this recommendation 
to ease the administrative burden on all private foundations, 
H.R. 4691, which is similar to a provision contained in the 
February 26, 2014, discussion draft of the ``Tax Reform Act of 
2014,'' will encourage private foundations to provide more 
funding of charitable activities to benefit local communities 
across the nation.

                         C. Legislative History

Background

    H.R. 4691 was introduced on May 20, 2014, and was referred 
to the Committee on Ways and Means.

Committee action

    The Committee on Ways and Means marked up H.R. 4691, the 
Private Foundation Excise Tax Simplification Act of 2014, on 
May 29, 2014, and ordered the bill, as amended, favorably 
reported (with a quorum being present).

Committee hearings

    The need for permanent rules simplifying the excise tax on 
investment income of private foundations was discussed at a 
full Committee hearing on Tax Reform and Charitable 
Contributions (February 14, 2013).

                      II. EXPLANATION OF THE BILL

A. Simplification of Excise Tax on Private Foundation Investment Income 
                        (Sec. 4940 of the Code)

                              PRESENT LAW

    Under section 4940(a), a private foundation (other than an 
exempt operating foundation) that is exempt from tax under 
section 501(a) for a taxable year is subject to a two-percent 
excise tax on its net investment income. Net investment income 
generally includes interest, dividends, rents, royalties (and 
income from similar sources), and capital gain net income, and 
is reduced by expenses incurred to earn this income. The two-
percent rate of tax is reduced to one-percent in any year in 
which a foundation exceeds the average historical level of its 
charitable distributions. Specifically, the excise tax rate is 
reduced if the foundation's qualifying distributions 
(generally, amounts paid to accomplish exempt purposes)\1\ 
equal or exceed the sum of (1) the amount of the foundation's 
assets for the taxable year multiplied by the average 
percentage of the foundation's qualifying distributions over 
the five taxable years immediately preceding the taxable year 
in question, and (2) one percent of the net investment income 
of the foundation for the taxable year.\2\ In addition, the 
foundation cannot have been subject to tax in any of the five 
preceding years for failure to meet minimum qualifying 
distribution requirements in section 4942.
---------------------------------------------------------------------------
    \1\Sec. 4942(g).
    \2\Sec. 4940(e).
---------------------------------------------------------------------------
    Private foundations that are not exempt from tax under 
section 501(a), such as certain charitable trusts, are subject 
to an excise tax under section 4940(b). The tax is equal to the 
excess of the sum of the excise tax that would have been 
imposed under section 4940(a) if the foundation were tax exempt 
and the amount of the tax on unrelated business income that 
would have been imposed if the foundation were tax exempt, over 
the income tax imposed on the foundation under subtitle A of 
the Code.
    Private foundations are required to make a minimum amount 
of qualifying distributions each year to avoid tax under 
section 4942. The minimum amount of qualifying distributions a 
foundation has to make to avoid tax under section 4942 is 
reduced by the amount of section 4940 excise taxes paid.\3\
---------------------------------------------------------------------------
    \3\Sec. 4942(d)(2).
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    Under the present-law, two-tier private foundation excise 
tax rate structure, a foundation must carefully manage the 
timing and amount of its grant making to minimize its excise 
tax burden. Compliance can be costly and consume resources that 
otherwise would have been used for grant making or other 
charitable activity.
    In addition, to qualify for the lower, one-percent tax rate 
in a year, a foundation must ensure that its distributions for 
the year exceed a historical, average level of distributions. 
This structure creates an incentive for foundations to limit 
distributions in any one year, because a significant increase 
in distributions will raise the foundation's average level of 
distributions, making it more difficult to qualify for the 
reduced rate in future years. As a result, a foundation that 
might have been inclined to distribute an unusually large 
amount in a time of public need, such as during the response to 
a natural disaster, has a disincentive to do so.
    For these reasons, the Committee believes it is appropriate 
to replace the present-law, two-tier private foundation excise 
tax rate structure with a simplified structure that uses a 
single tax rate of one percent.

                        EXPLANATION OF PROVISION

    The provision replaces the two rates of excise tax on tax-
exempt private foundations with a single rate of tax of one 
percent. Thus, under the provision, a tax-exempt private 
foundation generally is subject to an excise tax of one percent 
on its net investment income. A taxable private foundation is 
subject to an excise tax equal to the excess (if any) of the 
sum of the one-percent net investment income excise tax and the 
amount of the tax on unrelated business income (both calculated 
as if the foundation were tax-exempt), over the income tax 
imposed on the foundation. The provision repeals the special 
reduced excise tax rate for private foundations that exceed 
their historical level of qualifying distributions.

                             EFFECTIVE DATE

    The provision is effective for taxable years beginning 
after the date of enactment.

                      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. 4691, the Private Foundation Excise Tax 
Simplification Act of 2014, on May 29, 2014.
    The bill, H.R. 4691, was ordered favorably reported as 
amended by a rollcall vote of 23 yeas to 10 nays (with a quorum 
being present). The vote was as follows:

----------------------------------------------------------------------------------------------------------------
         Representative             Yea       Nay     Present     Representative      Yea       Nay     Present
----------------------------------------------------------------------------------------------------------------
Mr. Camp.......................        X   ........  .........  Mr. Levin........  ........        X   .........
Mr. Johnson....................        X   ........  .........  Mr. Rangel.......  ........  ........  .........
Mr. Brady......................        X   ........  .........  Mr. McDermott....  ........        X   .........
Mr. Ryan.......................        X   ........  .........  Mr. Lewis........  ........  ........  .........
Mr. Nunes......................        X   ........  .........  Mr. Neal.........  ........  ........  .........
Mr. Tiberi.....................        X   ........  .........  Mr. Becerra......  ........        X   .........
Mr. Reichert...................        X   ........  .........  Mr. Doggett......  ........        X   .........
Mr. Boustany...................        X   ........  .........  Mr. Thompson.....  ........        X   .........
Mr. Roskam.....................        X   ........  .........  Mr. Larson.......  ........        X   .........
Mr. Gerlach....................        X   ........  .........  Mr. Blumenauer...  ........  ........  .........
Mr. Price......................        X   ........  .........  Mr. Kind.........  ........        X   .........
Mr. Buchanan...................        X   ........  .........  Mr. Pascrell.....  ........  ........  .........
Mr. Smith......................        X   ........  .........  Mr. Crowley......  ........  ........  .........
Mr. Schock.....................        X   ........  .........  Ms. Schwartz.....  ........        X   .........
Ms. Jenkins....................        X   ........  .........  Mr. Davis........  ........        X   .........
Mr. Paulsen....................        X   ........  .........  Ms. Sanchez......  ........        X   .........
Mr. Marchant...................        X   ........  .........
Ms. Black......................        X   ........  .........
Mr. Reed.......................        X   ........  .........
Mr. Young......................        X   ........  .........
Mr. Kelly......................        X   ........  .........
Mr. Griffin....................        X   ........  .........
Mr. Renacci....................        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. 4691, as 
reported.
    The bill, as reported, is estimated to have the following 
effect on Federal budget receipts for fiscal years 2014-2024:

----------------------------------------------------------------------------------------------------------------
                                    Fiscal years, in millions of dollars----
-----------------------------------------------------------------------------------------------------------------
 2014     2015     2016     2017     2018     2019     2020     2021     2022    2023    2024   2014-19  2014-24
----------------------------------------------------------------------------------------------------------------
    --     -118     -166     -174     -182     -190     -198     -207     -215    -224    -233     -831  -1,909
----------------------------------------------------------------------------------------------------------------
Note: Details do not add to totals due to rounding.

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 further states that the revenue-reducing tax 
provision does not provide an increase or decrease in 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, June 5, 2014.
Hon. Dave Camp,
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. 4691, the Private 
Foundation Excise Tax Simplification Act of 2014.
    If you wish further details on this estimate, we will be 
pleased to provide them. The CBO staff contact is Logan 
Timmerhoff.
            Sincerely,
                                              Douglas W. Elmendorf.
    Enclosure.

H.R. 4691--Private Foundation Excise Tax Simplification Act of 2014

    H.R. 4691 would amend the Internal Revenue Code to 
restructure the excise tax on net investment income of private 
foundations from a dual-rate system (tax rates of 1 percent and 
2 percent) to a single-rate system with a rate of 1 percent. 
Under current law, the calculation of the amount of excise tax 
differs depending on whether the foundation is exempt from 
income taxes or not, but in both cases a foundation faces a 
general excise tax rate of 2 percent on its net investment 
income. The rate of tax is reduced to 1 percent when a 
foundation has made charitable distributions in a year that 
exceed an amount based largely on its historical rate of 
distributions relative to its assets.
    The staff of the Joint Committee on Taxation (JCT) 
estimates that enacting H.R. 4691 would reduce revenues, thus 
increasing federal budget deficits, by about $1.9 billion over 
the 2014-2024 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. 4691 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 Logan 
Timmerhoff. The estimate was approved by David Weiner, 
Assistant Director for Tax Analysis.

            CBO ESTIMATE OF PAY-AS-YOU-GO EFFECTS FOR H.R. 4691, AS ORDERED REPORTED BY THE HOUSE COMMITTEE ON WAYS AND MEANS ON MAY 29, 2014
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                    By fiscal year, in millions of dollars--
                                                      --------------------------------------------------------------------------------------------------
                                                        2014   2015   2016   2017   2018   2019   2020   2021   2022   2023   2024  2014-2019  2014-2024
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                               NET INCREASE IN THE DEFICIT

Statutory Pay-As-You-Go Effects......................      0    118    166    174    182    190    198    207    215    224    233       831     1,909
--------------------------------------------------------------------------------------------------------------------------------------------------------
Source: Staff of the Joint Committee on Taxation.
Note: Components may not sum to totals because of rounding.

                    D. Macroeconomic Impact Analysis

    In compliance with clause 3(h)(2) 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 effects of the bill on economic activity are so small 
as to be incalculable within the context of a model of the 
aggregate economy.

     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. 4691 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.

                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(j)(2) of H. Res. 5 (113th 
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(k) of H. Res. 5 (113th Congress), 
the following statement is made concerning directed rule 
makings: The 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 
shown in roman):

           SECTION 4940 OF THE INTERNAL REVENUE CODE OF 1986

SEC. 4940. EXCISE TAX BASED ON INVESTMENT INCOME.

  (a) Tax-Exempt Foundations.--There is hereby imposed on each 
private foundation which is exempt from taxation under section 
501(a) for the taxable year, with respect to the carrying on 
its activities, a tax equal to [2 percent] 1 percent of the net 
investment income of such foundation for the taxable year.

           *       *       *       *       *       *       *

  [(e) Reduction in Tax Where Private Foundation Meets Certain 
Distribution Requirements.--
          [(1) In general.--In the case of any private 
        foundation which meets the requirements of paragraph 
        (2) for any taxable year, subsection (a) shall be 
        applied with respect to such taxable year by 
        substituting ``1 percent'' for ``2 percent''.
          [(2) Requirements.--A private foundation meets the 
        requirements of this paragraph for any taxable year 
        if--
                  [(A) the amount of the qualifying 
                distributions made by the private foundation 
                during such taxable year equals or exceeds the 
                sum of--
                          [(i) an amount equal to the assets of 
                        such foundation for such taxable year 
                        multiplied by the average percentage 
                        payout for the base period, plus
                          [(ii) 1 percent of the net investment 
                        income of such foundation for such 
                        taxable year, and
                  [(B) such private foundation was not liable 
                for tax under section 4942 with respect to any 
                year in the base period.
          [(3) Average percentage payout for base period.--For 
        purposes of this subsection--
                  [(A) In general.--The average percentage 
                payout for the base period is the average of 
                the percentage payouts for taxable years in the 
                base period.
                  [(B) Percentage payout.--The term 
                ``percentage payout'' means, with respect to 
                any taxable year, the percentage determined by 
                dividing--
                          [(i) the amount of the qualifying 
                        distributions made by the private 
                        foundation during the taxable year, by
                          [(ii) the assets of the private 
                        foundation for the taxable year.
                  [(C) Special rule where tax reduced under 
                this subsection.--For purposes of this 
                paragraph, if the amount of the tax imposed by 
                this section for any taxable year in the base 
                period is reduced by reason of this subsection, 
                the amount of the qualifying distributions made 
                by the private foundation during such year 
                shall be reduced by the amount of such 
                reduction in tax.
          [(4) Base period.--For purposes of this subsection--
                  [(A) In general.--The term ``base period'' 
                means, with respect to any taxable year, the 5 
                taxable years preceding such taxable year.
                  [(B) New private foundations, etc.--If an 
                organization has not been a private foundation 
                throughout the base period referred to in 
                subparagraph (A), the base period shall consist 
                of the taxable years during which such 
                foundation has been in existence.
          [(5) Other definitions.--For purposes of this 
        subsection--
                  [(A) Qualifying distribution.--The term 
                ``qualifying distribution'' has the meaning 
                given such term by section 4942(g).
                  [(B) Assets.--The assets of a private 
                foundation for any taxable year shall be 
                treated as equal to the excess determined under 
                section 4942(e)(1).
          [(6) Treatment of successor organizations, etc.--In 
        the case of--
                  [(A) a private foundation which is a 
                successor to another private foundation, this 
                subsection shall be applied with respect to 
                such successor by taking into account the 
                experience of such other foundation, and
                  [(B) a merger, reorganization, or division of 
                a private foundation, this subsection shall be 
                applied under regulations prescribed by the 
                Secretary.]

                         VII. DISSENTING VIEWS

    The six bills approved by the Republicans at the markup 
would add $304 billion to the deficit. Combined with the $310 
billion that the six bills approved by Republicans on the 
Committee in April added to the deficit, Republicans have added 
$614 billion to the deficit in two short months--and there does 
not appear to be an end in sight. 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.
    To put the combined cost ($614 billion) into context, it is 
25 percent more than the entire projected federal deficit this 
year and $86 billion more than total non-defense domestic 
discretionary spending (e.g., medical research, education, 
veterans' pensions and health care, transportation, etc.) will 
be in 2014. It is almost seven times what we spend annually on 
education, job training, and social services. It is ten times 
more than we spend on veterans. And, it is eleven times more 
than we spend on medical research and public health.
    Public charities and private foundations serve an important 
role in our society. We all support the good works of the 
charitable community and strive to provide charities with the 
resources they need to carry out their charitable mission. The 
markup was not to debate the good works of charities across 
this country, or the merits of H.R. 4691 which provides a 
single rate of tax on private foundations' investment income.
    The consideration of this tax bill should be part of 
comprehensive tax reform. It should not take priority over 
other reforms for the charitable sector.
                                                   Sander M. Levin.

                                  
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