After being passed by the House of Representatives, this year’s reconciliation bill (H.R. 1) moved to the Senate, which passed its own version of the legislation today, July 1.  The Senate bill would preserve without significant change many tax-related items from the House bill.  There are several provisions, however, where the Senate bill varies from the version the passed the House earlier.  The Senate-passed legislation will now head back to the House, where its fate is somewhat uncertain.

We previously covered several of the relevant tax provisions when House passed its version of the reconciliation bill.  This article is part of a series of articles examining how those provisions would change under the Senate’s legislation.

As discussed in our previous post, the House version of this bill addressed qualified transportation fringes provided under section 132(f) of the Internal Revenue Code. The House Bill would would treat expenses for such fringes, including public transit benefits, highway van pools, and qualified parking, paid by tax-exempt employers as unrelated business taxable income under section 512, resurrecting an unpopular provision of the Tax Cuts and Jobs Act that had been repealed retroactively in 2020. Likely fearing the outcry from tax exempt organizations and churches that led to the retroactive repeal of the provision following its prior enactment, the Senate version of the reconciliation bill does not include such a provision or propose any other amendments to section 512 of the Code.

Photo of Lydia Marik Lydia Marik

Lydia Marik is an associate in the firm’s New York office and is a member of both the Corporate and Employee Benefits and Executive Compensation Practice Groups. She maintains an active pro bono practice, including filing asylum and withholding of removal applications and…

Lydia Marik is an associate in the firm’s New York office and is a member of both the Corporate and Employee Benefits and Executive Compensation Practice Groups. She maintains an active pro bono practice, including filing asylum and withholding of removal applications and clemency petitions.

Photo of S. Michael Chittenden S. Michael Chittenden

Michael Chittenden practices in the areas of tax and employee benefits with a focus on the Foreign Account Tax Compliance Act (FATCA), information reporting (e.g., Forms 1095, 1096, 1098, 1099, W-2, 1042, and 1042-S) and withholding, payroll taxes, and fringe benefits. Michael advises…

Michael Chittenden practices in the areas of tax and employee benefits with a focus on the Foreign Account Tax Compliance Act (FATCA), information reporting (e.g., Forms 1095, 1096, 1098, 1099, W-2, 1042, and 1042-S) and withholding, payroll taxes, and fringe benefits. Michael advises companies on their obligations under FATCA and assists in the development of comprehensive FATCA and Chapter 3 (nonresident alien reporting and withholding) compliance programs.

Michael advises large employers on their employment tax obligations, including the special FICA and FUTA rules for nonqualified deferred compensation, the successor employer rules, the voluntary correction of employment tax mistakes, and the abatement of late deposit and information reporting penalties. In addition, he has also advised large insurance companies and employers on the Affordable Care Act reporting requirements in Sections 6055 and 6056, and advised clients on the application of section 6050W (Form 1099-K reporting), including its application to third-party payment networks.

Michael counsels clients on mobile workforce issues including state income tax withholding for mobile employees and expatriate and inpatriate taxation and reporting.

Michael is a frequent commentator on information withholding, payroll taxes, and fringe benefits and regularly gives presentations on the compliance burdens for companies.