Nonpartisan civic infrastructure
AllCiv·Legis1
·

S. 5477

BillFederalSenateIn Committee
A bill to amend the Internal Revenue Code of 1986 to provide for certain rules regarding determination of tax in the case of a receivership.
About This Bill
Committee
Latest Action · September 23, 2026
Read twice and referred to the Committee on Finance.
Introduced
September 23, 2026
Cosponsors (1)
1D 0R
View PDF ↗

Summary

Highlight any text to annotate
This bill amends federal tax law to establish rules for determining tax liability when a business or entity is placed in receivership by a court. The legislation allows federal courts overseeing receivership cases to determine the amount of unpaid federal taxes owed by the receivership estate, as long as those taxes haven't already been settled in a previous court or administrative proceeding. Receivers can request a tax determination by submitting a tax return and formal request to the IRS, and if the IRS doesn't examine the return or complete an examination within specified timeframes (60 and 180 days respectively), the receivership estate is discharged from that tax liability once the tax shown on the return is paid. The bill limits the IRS's ability to assert sovereign immunity in these cases and ensures that receivership courts can offset any claims the IRS makes against the estate with counterclaimns owed to the estate. For state receivership proceedings, the bill directs that federal tax questions be decided by federal district courts rather than state courts. The law applies to tax returns for which the assessment period is still open as of the bill's enactment and to all returns filed thereafter.

Take Action

Your position
Add a comment
to comment on this bill.
Annotate the text
Highlight any passage on the Summary or Full Text tab to attach a note. Annotations appear on the Annotations tab.