Overview

Title

To amend the Internal Revenue Code of 1986 to clarify the tax-exempt controlled entity rules with respect to certain stock of government-sponsored enterprises.

ELI5 AI

S. 4933 is changing some rules about tax-free organizations holding stocks in special companies like Fannie Mae. It says the United States government and its agencies don't count as tax-free in this case, and this change starts from 2008.

Summary AI

S. 4933 aims to amend the Internal Revenue Code of 1986 to clarify rules about tax-exempt entities holding stock in government-sponsored enterprises, like the Federal Home Loan Mortgage Corporation and the Federal National Mortgage Association. The bill specifies that the term "tax-exempt entity" does not include the United States or its agencies. This clarification is set to apply to taxable years ending after July 30, 2008. The bill is titled the “Preserving Rural Housing Investments Act.”

Published

2024-08-01
Congress: 118
Session: 2
Chamber: SENATE
Status: Introduced in Senate
Date: 2024-08-01
Package ID: BILLS-118s4933is

Bill Statistics

Size

Sections:
2
Words:
302
Pages:
2
Sentences:
7

Language

Nouns: 104
Verbs: 25
Adjectives: 13
Adverbs: 1
Numbers: 11
Entities: 28

Complexity

Average Token Length:
4.25
Average Sentence Length:
43.14
Token Entropy:
4.61
Readability (ARI):
23.47

AnalysisAI

General Summary of the Bill

The bill, introduced as S. 4933, is titled the “Preserving Rural Housing Investments Act.” Its primary goal is to amend the Internal Revenue Code of 1986. Specifically, it seeks to clarify the rules related to tax-exempt controlled entities concerning certain stocks held in government-sponsored enterprises (GSEs), notably the Federal Home Loan Mortgage Corporation (Freddie Mac) and the Federal National Mortgage Association (Fannie Mae). The amendment excludes the United States and any of its agencies from being defined as a “tax-exempt entity” in regards to these stocks. This legislative change is made retroactive to taxable years ending after July 30, 2008.

Summary of Significant Issues

Several issues arise from this bill. Firstly, the retroactive application of the amendment to a period as far back as July 2008 may disrupt financial planning and reporting for entities that have not anticipated this legislative change. Additionally, the technical jargon used, particularly in the sections amending the Internal Revenue Code, could obscure understanding for individuals without specialized knowledge in finance or tax law, thus limiting broader debate and public accountability.

The bill's title, “Preserving Rural Housing Investments Act,” seems disconnected from the specific content, which centers around tax code amendments rather than explicit initiatives for rural housing. This discrepancy might lead to misunderstandings regarding the bill’s intended impact or scope.

Furthermore, the rationale behind excluding the United States or its agencies from being considered as tax-exempt entities in this specific context is not clearly explained within the bill. This lack of transparency might provoke concerns about fairness and the motives behind this legislative decision.

Potential Impact on the Public

Broadly, this bill might affect various stakeholders in both positive and negative ways. For the general public, clarifying tax-exempt rules for GSEs could enhance transparency and perhaps stabilize certain financial operations involving Freddie Mac and Fannie Mae. However, the retroactive nature of this bill's application might create complexity and uncertainty for entities that have been operating under different assumptions.

For professionals and businesses involved in finance and tax, the bill’s technical language and retroactive clause could necessitate significant adjustments in accounting practices and tax reporting, potentially increasing administrative burdens and costs.

Impact on Specific Stakeholders

Financial Institutions and Enterprises: Entities that interact with Freddie Mac and Fannie Mae might find the new clarity beneficial for strategic planning and taxation purposes. However, those who did not anticipate these changes due to the retroactive application could face unwelcome adjustments to previously completed tax filings.

Tax Professionals and Lawyers: Specialists in tax law may need to invest additional efforts to comprehend the full implications of these changes for their clients. The technical complexity of the bill emphasizes the necessity for expert advice and potentially increases the demand for professional services.

Rural Housing Advocates: Although the bill's title suggests an emphasis on rural housing, its provisions do not directly address housing investments or innovations. This misalignment may frustrate stakeholders expecting direct actions to promote rural housing development.

Overall, while the bill aims to bring clarity and stabilization within the realm of government-sponsored enterprises' taxation, its technical language, retroactive nature, and vague titling may also give rise to confusion and unintended financial impacts.

Issues

  • The amendment made to Section 168(h)(6)(F)(iii)(I) of the Internal Revenue Code of 1986 retroactively applies to taxable years ending after July 30, 2008, which may create complications for financial planning and reporting for entities that were unaware of this change. (Section 2)

  • The bill explicitly excludes the United States or any of its agencies from being considered as a 'tax-exempt entity' concerning certain stocks of government-sponsored enterprises, but lacks a clear explanation, which may raise transparency and fairness concerns. (Section 2)

  • The highly technical nature of the language used in Section 2 presents a barrier to understanding for those without specialized knowledge in tax law or finance, potentially limiting public debate and accountability. (Section 2)

  • The title 'Preserving Rural Housing Investments Act' does not reflect the specific content or objectives of the bill, potentially leading to misunderstandings about its impact or scope. (Section 1)

Sections

Sections are presented as they are annotated in the original legislative text. Any missing headers, numbers, or non-consecutive order is due to the original text.

1. Short title Read Opens in new tab

Summary AI

The first section of the bill provides its short title, stating that it may be referred to as the “Preserving Rural Housing Investments Act.”

2. Clarification of tax-exempt controlled entity rules with respect to certain stock of government-sponsored enterprises Read Opens in new tab

Summary AI

The section clarifies the tax-exempt rules related to certain government-supported financial entities by stating that the term "tax-exempt entity" does not include the United States or any of its agencies when it comes to the Federal Home Loan Mortgage Corporation and the Federal National Mortgage Association. This change applies to taxable years ending after July 30, 2008.