39–006 

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 


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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 


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1Sec. 4942(g). 

2Sec. 4940(e). 

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. 

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 


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3Sec. 4942(d)(2). 

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

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. 


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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. Sa ́ nchez ......................... ........... 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. 


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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. 


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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-AsYou-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 


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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 omitVerDate Mar 15 2010 05:22 Jun 28, 2014 Jkt 039006 PO 00000 Frm 00008 Fmt 6659 Sfmt 6602 E:\HR\OC\HR497.XXX HR497

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ted 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 ø2 percent¿ 1 percent of the net investment 

income of such foundation for the taxable year. 

* * * * * * * 

ø(e) REDUCTION IN TAX WHERE PRIVATE FOUNDATION MEETS

CERTAIN DISTRIBUTION REQUIREMENTS.— 

ø(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’’. 

ø(2) REQUIREMENTS.—A private foundation meets the requirements of this paragraph for any taxable year if— 

ø(A) the amount of the qualifying distributions made by 

the private foundation during such taxable year equals or 

exceeds the sum of— 

ø(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 

ø(ii) 1 percent of the net investment income of such 

foundation for such taxable year, and 

ø(B) such private foundation was not liable for tax under 

section 4942 with respect to any year in the base period. 

ø(3) AVERAGE PERCENTAGE PAYOUT FOR BASE PERIOD.—For 

purposes of this subsection— 

ø(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. 

ø(B) PERCENTAGE PAYOUT.—The term ‘‘percentage payout’’ means, with respect to any taxable year, the percentage determined by dividing— 

ø(i) the amount of the qualifying distributions made 

by the private foundation during the taxable year, by 

ø(ii) the assets of the private foundation for the taxable year. 

ø(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. 

ø(4) BASE PERIOD.—For purposes of this subsection— 

ø(A) IN GENERAL.—The term ‘‘base period’’ means, with 

respect to any taxable year, the 5 taxable years preceding 

such taxable year. 


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ø(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. 

ø(5) OTHER DEFINITIONS.—For purposes of this subsection— 

ø(A) QUALIFYING DISTRIBUTION.—The term ‘‘qualifying 

distribution’’ has the meaning given such term by section 

4942(g). 

ø(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). 

ø(6) TREATMENT OF SUCCESSOR ORGANIZATIONS, ETC.—In the 

case of— 

ø(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 

ø(B) a merger, reorganization, or division of a private 

foundation, this subsection shall be applied under regulations prescribed by the Secretary.¿ 


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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. 

Æ 


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