Individual retirement plan statute of limitations for excise tax on excess contributions and certain accumulations

Section 6501(l) of the Internal Revenue Code of 1986 is amended by adding at the end the following new paragraph: (4) Individual retirement plans (A) In general For purposes of any tax imposed by section 4973 or 4974 in connection with an individual retirement plan, the return referred to in this section shall be the income tax return filed by the person on whom the tax under such section is imposed for the year in which the act (or failure to act) giving rise to the liability for such tax occurred. (B) Rule in case of individuals not required to file return In the case of a person who is not required to file an income tax return for such year— (i) the return referred to in this section shall be the income tax return that such person would have been required to file but for the fact that such person was not required to file such return, and (ii) the 3-year period referred to in subsection (a) with respect to the return shall be deemed to begin on the date by which the return would have been required to be filed (excluding any extension thereof)..