under section 45S(a). . (B) The table of sections for subpart D of part IV of subchapter A of chapter 1 of such Code is amended by adding at the end the following new item: Sec. 45S. Contributions to scholarship granting organizations. . (c) Excise tax on failure of scholarship granting organizations To make distributions (1) In general Chapter 42 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subchapter: H Scholarship granting organizations Sec. 4968. Tax on failure to distribute receipts. 4968. Tax on failure to distribute receipts (a) Tax imposed There is hereby imposed a tax on the failure of an scholarship granting organization (as defined in section 25E(c)(2)) to make distributions in any taxable year in an amount equal to or in excess of the required distribution amount before the distribution deadline. (b) Amount of tax The tax imposed by subsection (a) shall be equal to 15 percent of the excess (if any) of— (1) the required distribution amount with respect to the taxable year, over (2) the amount of receipts of the scholarship granting organization for such taxable year which are distributed before the distribution deadline with respect to such receipts. (c) Definitions For purposes of this section— (1) Required distribution amount The required distribution amount with respect to a taxable year is an amount equal to 90 percent of the total receipts of the scholarship granting organization for such taxable year. (2) Distributions The term distribution includes amounts which are formally committed but not distributed. (3) Distribution deadline The distribution deadline with respect to receipts for a taxable year is the first day of the second taxable year following the taxable year in which such receipts are received by the scholarship granting organization. (d) Reasonable cause exception The tax imposed by subsection (a) shall not apply with respect to any failure to make required distributions before the distribution deadline which is not willful and is due to