II 

118TH CONGRESS 

2D SESSION S. 4057 

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, and for other purposes. 

IN THE SENATE OF THE UNITED STATES 

MARCH 22, 2024 

Mr. COONS (for himself, Mr. ROUNDS, Mr. WYDEN, Mr. TILLIS, Mr. CARDIN, 

and Mr. CASSIDY) introduced the following bill; which was read twice and 

referred to the Committee on Finance 

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, and for other purposes. 

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 Tax Penalties 

5 on American Hostages Act of 2024’’. 


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1 SEC. 2. POSTPONEMENT OF TAX DEADLINES FOR HOS2 TAGES AND INDIVIDUALS WRONGFULLY DE3 TAINED ABROAD. 

4 (a) IN GENERAL.—Chapter 77 of the Internal Rev5 enue Code of 1986 is amended by inserting after section 

6 7510 the following new section: 

7 ‘‘SEC. 7511. TIME FOR PERFORMING CERTAIN ACTS POST8 PONED FOR HOSTAGES AND INDIVIDUALS 

9 WRONGFULLY DETAINED ABROAD. 

10 ‘‘(a) TIME TO BE DISREGARDED.— 

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

12 an applicable individual was unlawfully or wrongfully 

13 detained abroad, or held hostage abroad, shall be 

14 disregarded in determining, under the internal rev15 enue laws, in respect of any tax liability of such indi16 vidual— 

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

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

19 time prescribed thereof (determined without re20 gard to extension under any other provision of 

21 this subtitle for periods after the initial date (as 

22 determined by the Secretary) on which such in23 dividual was unlawfully or wrongfully detained 

24 abroad or held hostage abroad), 


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

2 additional amount, or addition to the tax for 

3 periods after such date, and 

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

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

6 of paragraph (1) shall apply to the spouse of any in7 dividual entitled to the benefits of such paragraph. 

8 ‘‘(b) APPLICABLE INDIVIDUAL.— 

9 ‘‘(1) IN GENERAL.—For purposes of this sec10 tion, the term ‘applicable individual’ means any indi11 vidual who is— 

12 ‘‘(A) a United States national unlawfully 

13 or wrongfully detained abroad, as determined 

14 under section 302 of the Robert Levinson Hos15 tage Recovery and Hostage-Taking Account16 ability Act (22 U.S.C. 1741), or 

17 ‘‘(B) a United States national taken hos18 tage abroad, as determined pursuant to the 

19 findings of the Hostage Recovery Fusion Cell 

20 (as described in section 304 of the Robert 

21 Levinson Hostage Recovery and Hostage-Tak22 ing Accountability Act (22 U.S.C. 1741b)). 

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

24 For purposes of identifying individuals described in 


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

2 annually thereafter— 

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

4 the Secretary with a list of the individuals de5 scribed in paragraph (1)(A), as well as any 

6 other information necessary to identify such in7 dividuals, and 

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

9 the Hostage Recovery Fusion Cell, shall provide 

10 the Secretary with a list of the individuals de11 scribed in paragraph (1)(B), as well as any 

12 other information necessary to identify such in13 dividuals. 

14 ‘‘(c) REFUND AND ABATEMENT OF PENALTIES AND

15 FINES IMPOSED PRIOR TO IDENTIFICATION AS APPLICA16 BLE INDIVIDUAL.—In the case of any applicable indi17 vidual— 

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

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

20 liability for any taxable year ending during the pe21 riod described in subsection (a)(1) was assessed or 

22 collected, and 

23 ‘‘(2) who was, subsequent to such assessment 

24 or collection, determined to be an individual deVerDate Sep 11 2014 00:54 Apr 12, 2024 Jkt 049200 PO 00000 Frm 00004 Fmt 6652 Sfmt 6201 E:\BILLS\S4057.IS S4057

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1 scribed in subparagraph (A) or (B) of subsection 

2 (b)(1), 

3 the Secretary shall abate any such assessment and refund 

4 any amount collected to such applicable individual in the 

5 same manner as any refund of an overpayment of tax 

6 under section 6402.’’. 

7 (b) CLERICAL AMENDMENT.—The table of sections 

8 for chapter 77 of the Internal Revenue Code of 1986 is 

9 amended by inserting after the item relating to section 

10 7510 the following new item: 

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

11 (c) EFFECTIVE DATE.—The amendments made by 

12 this section shall apply to taxable years ending after the 

13 date of enactment of this Act. 

14 SEC. 3. REFUND AND ABATEMENT OF PENALTIES AND 

15 FINES PAID BY ELIGIBLE INDIVIDUALS. 

16 (a) IN GENERAL.—Section 7511 of the Internal Rev17 enue Code of 1986, as added by section 2, is amended 

18 by adding at the end the following new subsection: 

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

20 FINES PAID BY ELIGIBLE INDIVIDUALS.— 

21 ‘‘(1) IN GENERAL.— 

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

23 January 1, 2025, the Secretary (in consultation 

24 with the Secretary of State and the Attorney 


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1 General) shall establish a program to allow any 

2 eligible individual (or the spouse or any depend3 ent (as defined in section 152) of such indi4 vidual) to apply for a refund or an abatement 

5 of any amount described in paragraph (2) (in6 cluding interest) to the extent such amount was 

7 attributable to the applicable period. 

8 ‘‘(B) IDENTIFICATION OF INDIVIDUALS.— 

9 Not later than January 1, 2025, the Secretary 

10 of State and the Attorney General, acting 

11 through the Hostage Recovery Fusion Cell (as 

12 described in section 304 of the Robert Levinson 

13 Hostage Recovery and Hostage-Taking Ac14 countability Act (22 U.S.C. 1741b)), shall— 

15 ‘‘(i) compile a list, based on such in16 formation as is available, of individuals 

17 who were applicable individuals during the 

18 applicable period, and 

19 ‘‘(ii) provide the list described in 

20 clause (i) to the Secretary. 

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

22 out the program described in subparagraph (A), 

23 the Secretary (in consultation with the Sec24 retary of State and the Attorney General) shall, 

25 with respect to any individual identified under 


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1 subparagraph (B), provide notice to such indi2 vidual— 

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

4 has been released on or before the date of 

5 enactment of this subsection, not later 

6 than 90 days after the date of enactment 

7 of this subsection, or 

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

9 is released after the date of enactment of 

10 this subsection, not later than 90 days 

11 after the date on which such individual is 

12 released, 

13 that such individual may be eligible for a refund 

14 or an abatement of any amount described in 

15 paragraph (2) pursuant to the program de16 scribed in subparagraph (A). 

17 ‘‘(D) AUTHORIZATION.— 

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

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

20 subparagraph (A), the Secretary shall 

21 issue such refund to the eligible individual 

22 in the same manner as any refund of an 

23 overpayment of tax. 


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1 ‘‘(ii) EXTENSION OF LIMITATION ON

2 TIME FOR REFUND.—With respect to any 

3 refund under subparagraph (A)— 

4 ‘‘(I) the 3-year period of limita5 tion prescribed by section 6511(a) 

6 shall be extended until the end of the 

7 1-year period beginning on the date 

8 that the notice described in subpara9 graph (C) is provided to the eligible 

10 individual, and 

11 ‘‘(II) any limitation under section 

12 6511(b)(2) shall not apply. 

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

14 this subsection, the term ‘eligible individual’ means 

15 any applicable individual who, for any taxable year 

16 ending during the applicable period, paid or incurred 

17 any interest, penalty, additional amount, or addition 

18 to the tax in respect to any tax liability for such 

19 year of such individual based on a determination 

20 that an act described in section 7508(a)(1) which 

21 was not performed by the time prescribed therefor 

22 (without regard to any extensions). 

23 ‘‘(3) APPLICABLE PERIOD.—For purposes of 

24 this subsection, the term ‘applicable period’ means 

25 the period— 


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

2 ‘‘(B) ending on the date of enactment of 

3 this subsection.’’. 

4 (b) EFFECTIVE DATE.—The amendment made by 

5 this section shall apply to taxable years ending on or be6 fore the date of enactment of this Act. 

Æ 


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