H.R. 1075 — Tax Administration Simplification Act

This section establishes the short title of the Act as the “Tax Administration Simplification Act.”

This section revises the Internal Revenue Service’s mailbox rule under section 7502 of the Internal Revenue Code of 1986 to apply to electronically submitted returns, claims, statements, other documents, and payments. As background, section 7502 generally treats timely mailing as timely filing or payment for certain paper submissions. The amendment adds a new rule providing that, if a required document or payment is sent electronically to the appropriate IRS office by the applicable deadline, the date of electronic transmission is deemed the date of delivery or payment, regardless of when the IRS receives or reviews it. It also directs the Secretary of the Treasury to issue implementing regulations or other guidance by December 31, 2025. The changes apply to any document or payment sent after December 31, 2025.

This section revises the rules for making and revoking S corporation elections under section 1362 of the Internal Revenue Code of 1986. It allows a small business corporation to make an S corporation election by the due date for filing the S corporation return for the taxable year, including extensions, and authorizes the Secretary of the Treasury to treat a late election as timely if there was reasonable cause for the failure to file on time. It also provides that, if an election is made on time but the corporation did not meet the S corporation eligibility requirements on one or more days before the election or one or more shareholders did not consent before the election, the election is treated as made for the following taxable year. In addition, it permits an election to be made on a timely filed return unless the Secretary provides otherwise and authorizes Treasury to issue regulations or other guidance to implement these rules. The section also makes conforming changes for qualified subchapter S subsidiaries and qualified subchapter S trusts. It applies rules similar to the late-election rules to certain qualified subchapter S subsidiary elections and strikes a provision governing qualified subchapter S trusts. For revocations, it authorizes the Secretary to treat a late S corporation revocation as timely if there was reasonable cause for the failure to revoke on time. The amendments generally apply to elections for taxable years beginning after December 31, 2025, and the revocation changes apply to revocations made after the date of enactment.

This section delays two quarterly estimated income tax payment deadlines for individuals under section 6654(c)(2) of the Internal Revenue Code of 1986 by moving the June 15 installment to July 15 and the September 15 installment to October 15. The changes apply to installments due in taxable years beginning after December 31, 2025.