- Record: Senate Floor
- Section type: Amendments
- Chamber: Senate
- Date: June 23, 2026
- Congress: 119th Congress
- Why this source matters: This section came from the Senate floor portion of the record.
SA 5981. Mr. SCHIFF submitted an amendment intended to be proposed by him to the bill S. 4784, to authorize appropriations for fiscal year 2027 for military activities of the Department of Defense, for military construction, and for defense activities of the Department of Energy, to prescribe military personnel strengths for such fiscal year, and for other purposes; which was ordered to lie on the table; as follows:
At the end of subtitle G of title X, insert the following:
SEC. . RULES RELATED TO AGREEMENTS WITH THE PRESIDENT.
(a) Authority of DOJ.—Section 516 of title 28, United
States Code, is amended by adding at the end the following:
“The authority of the Attorney General and the Department of
Justice to conduct litigation pursuant to this section shall
not apply to any offer of compromise or settlement agreement
in the case of any return of tax of the President or any
member of the immediate family of the President which was
filed during the President's term in office.”.
(b) Finality of Closing Agreements With Respect to Internal
Revenue Taxes.—Section 7121 of the Internal Revenue Code of
1986 is amended by adding at the end the following new
subsection:
“(c) Special Rule.—Paragraphs (1) and (2) of subsection
(b) shall not apply to any agreement with the President or
related or affiliated individuals (including family or others
filing jointly) or parties (including trusts, parent, sister,
or related companies, affiliates, and subsidiaries) until the
date that is 1 year after the conclusion of the President's
term of office.”.
(c) Extension of Statute of Limitations.—Section 6501(c)
of the Internal Revenue Code of 1986 is amended by adding at
the end the following new paragraph:
“(13) Returns of the president subject to closing
agreements.—
“(A) In general.—In the case of any return of tax
described in subparagraph (B), the period for assessment, or
for bringing a proceeding in court for collection of such tax
, may be begun at any time before the later of—
“(i) the date that is 3 years after the conclusion of the
term in office as President of the individual described in
subparagraph (B)(i), or
“(ii) the date otherwise provided in this section.
“(B) Return of tax described.—A return of tax is
described in this subparagraph if such return—
“(i) is a return of tax of an individual—
“(I) who is or was President, or
“(II) who is a related or affiliated individual (including
family or others filing jointly) or party (including trusts,
parent, sister, or related companies, affiliates, and
subsidiaries) with respect to the individual described in
subclause (I), and
“(ii) is subject to an agreement described in section 7121
that was entered into during the period the individual
described in clause (i)(I) was President.”.
(d) Effective Date.—The amendments made by this section
shall apply with respect to any case or cause of action
arising on or after January 20, 2025.