. (B) Section 1375(b)(1)(A)(i) is amended by striking 25 percent and inserting 60 percent . (C) The heading for section 1375 is amended by striking 25 percent and inserting 60 percent . (D) The item relating to section 1375 in the table of sections for part III of subchapter S of chapter 1 is amended by striking 25 percent and inserting 60 percent . (3) Section 1042(c)(4)(A)(i) is amended by striking section 1362(d)(3)(C) and inserting section 1375(b)(3) . (4) Section 1362(f)(1)(B) is amended by striking paragraph (2) or (3) of subsection (d) and inserting subsection (d)(2) . (d) Effective Date The amendments made by this section shall apply to taxable years beginning after December 31, 2020. 3. Expansion of S corporation eligible shareholders to include IRAs (a) In General Section 1361(c)(2)(A)(vi) is amended to read as follows: (vi) A trust which constitutes an individual retirement account under section 408(a), including one designated as a Roth IRA under section 408A. . (b) Sale of Stock in IRA Relating to S Corporation Election Exempt From Prohibited Transaction Rules Section 4975(d)(16) is amended— (1) by striking subparagraphs (A) and (B) and by redesignating subparagraphs (C), (D), (E), and (F) as subparagraphs (A), (B), (C), and (D), respectively, and (2) by striking such bank or company in subparagraph (A) (as so redesignated) and inserting the issuer of such stock . (c) Effective Date The amendments made by this section shall take effect on January 1, 2021. 4. Treatment of S corporation built-in gain amount upon death of shareholder (a) In general Part II of subchapter S of chapter 1 is amended by adding at the end the following: 1369. Amortization of built-in gain amount upon death of shareholder (a) In general A person holding stock in an electing S corporation the basis of which is determined under section 1014(a) (hereafter in this section referred to as the shareholder ) shall be allowed a deduction with respect to the S corporation built-in gain amount. The amount of such deduction for any