H.R. 2014 (119th)Bill Overview

Reduction of Excess Business Holding Accrual Act

Taxation|Taxation
Cosponsors
Support
Republican
Introduced
Mar 10, 2025
Discussions
Bill Text
Current stageCommittee

Referred to the House Committee on Ways and Means.

Introduced
Committee
Floor
President
Law
Congressional Activities
01 · The brief
Plain-English summaryWhat this bill actually does

Amends Internal Revenue Code section 4943 to change how certain repurchases of employee-owned stock affect private foundations' excess business holdings calculations. Stock purchased by a company from an employee stock ownership plan, and held as treasury stock, cancelled, or retired, can be treated as outstanding for purposes of foundation ownership percentages, subject to limits and a 10-year exclusion.

Why people may split

Progressives worry about benefits to wealthy foundations and donors.

Watch point

Relative to its intended legislative type, this bill is a narrowly focused substantive amendment to the Internal Revenue Code that clearly defines the legal mechanism and integrates with existing statutory provisions, while offering limited implementation guidance, fiscal acknowledgment, and oversight provisions.

Amends Internal Revenue Code section 4943 to change how certain repurchases of employee-owned stock affect private foundations' excess business holdings calculations.

Stock purchased by a company from an employee stock ownership plan, and held as treasury stock, cancelled, or retired, can be treated as outstanding for purposes of foundation ownership percentages, subject to limits and a 10-year exclusion.

The change applies to purchases after December 31, 2019 and taxable years ending after enactment.

Passage55/100

A narrow, low‑salience tax technical fix with guardrails; passage plausible if adopted in committee or attached to broader tax legislation.

CredibilityAligned

Relative to its intended legislative type, this bill is a narrowly focused substantive amendment to the Internal Revenue Code that clearly defines the legal mechanism and integrates with existing statutory provisions, while offering limited implementation guidance, fiscal acknowledgment, and oversight provisions.

Contention55/100

Progressives worry about benefits to wealthy foundations and donors.

02 · What it does

Who stands to gain, and who may push back.

Likely benefits vs burdens50% / 50%
EmployersFederal agencies

These are examples from the analysis, not a ranked list of the most-affected groups.

Likely helped
  • EmployersReduces the chance private foundations incur excess-holding excise taxes after employer ESOP repurchases.
  • Potential benefitFacilitates ESOP distributions and share repurchases for retiring employees without triggering foundation penalties.
  • EmployersEncourages use of ESOPs and employer buybacks as succession tools, potentially preserving business continuity and jobs.
Likely burdened
  • Federal agenciesMay reduce federal revenue from excess business holdings excise taxes by narrowing taxable events.
  • Potential burdenCould allow foundations to retain greater effective ownership, undermining statutory limits on foundation business cont…
  • Potential burdenCreates opportunities for strategic timing or structuring of repurchases to avoid excess-holdings tax exposure.
03 · Why people split

Why the argument around this bill splits.

Progressives worry about benefits to wealthy foundations and donors.
Progressive35%

A mainstream progressive would view this as a narrow technical tax change that eases a compliance burden for foundations and companies.

They would be wary that it could let wealthy donors and corporations avoid excess holdings rules, even while acknowledging support for employee ownership plans.

Likely resistant
Centrist65%

A pragmatic centrist would see this mainly as a technical fix to an unintended interaction between ESOP distributions and foundation rules.

They would support clarity but seek assurances about fiscal effects and anti-abuse safeguards.

Split reaction
Conservative85%

A mainstream conservative would likely view this as a reasonable, limited relief that supports employee ownership, reduces needless tax complexity, and protects businesses from unintended penalties.

They would favor the pro-business, pro-ESOP effect.

Leans supportive
04 · Can it pass?

The path through Congress.

Introduced

Reached or meaningfully advanced

Committee

Reached or meaningfully advanced

Floor

Still ahead

President

Still ahead

Law

Still ahead

Passage likelihood55/100

A narrow, low‑salience tax technical fix with guardrails; passage plausible if adopted in committee or attached to broader tax legislation.

Scope and complexity
24%
Scopenarrow
24%
Complexitylow
Why this could stall
  • No official revenue/cost estimate included
  • Level of support on Ways and Means unknown
05 · Recent votes

Recent votes on the bill.

No vote history yet

The bill has not accumulated any surfaced votes yet.

06 · Go deeper

Go deeper than the headline read.

Included on this page

Progressives worry about benefits to wealthy foundations and donors.

A narrow, low‑salience tax technical fix with guardrails; passage plausible if adopted in committee or attached to broader tax legislation.

Unlocked analysis

Relative to its intended legislative type, this bill is a narrowly focused substantive amendment to the Internal Revenue Code that clearly defines the legal mechanism and integrates with existing statutory provisions, w…

Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.

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