Short title

This Act may be cited as the

Stop Child Summer Hunger Act of 2014

Summer electronic benefits transfer for children program

Section 13(a) of the Richard B. Russell National School Lunch Act (42 U.S.C. 1761(a)) is amended by adding at the end the following:

(13)

Summer electronic benefits transfer for children program

(A)

Definitions

In this paragraph:(i)

Eligible household

The term eligible household means a household that includes 1 or more children who are eligible to receive free or reduced price lunches under this Act or free or reduced price breakfasts under the Child Nutrition Act of 1966 (42 U.S.C. 1771 et seq.).(ii)

Summer EBT card

The term summer EBT card means an electronic benefit transfer card that is issued to an eligible household under this paragraph and limited to food purchases.(B)

Program

The Secretary shall establish a program under which the Secretary shall provide to eligible households summer EBT cards for the purpose of providing access to food for children during summer months—(i)to reduce or eliminate the food insecurity and hunger of children; and(ii)to improve the nutritional status of children.(C)

Use

An eligible household may use a summer EBT card only to purchase food from retail food stores that have been approved for participation in the supplemental nutrition assistance program established under the Food and Nutrition Act of 2008 (7 U.S.C. 2011 et seq.), in accordance with section 7(b) of that Act (7 U.S.C. 2016(b)).(D)

Amount

Each summer EBT card issued shall be in an amount of—(i)for calendar year 2016, $150 in food assistance per child per summer; and(ii)for each subsequent calendar year, the amount specified in clause (i) as adjusted to reflect changes in reimbursement rates for school meals under this Act between calendar year 2016 and the most recent calendar year.(E)

Timing

Summer EBT cards shall be issued at the end of the regular school year.(F)

Funding

(i)

In general

On October 1, 2015, and on each October 1 thereafter, out of any funds in the Treasury not otherwise appropriated, the Secretary of the Treasury shall transfer to the Secretary such sums as are necessary to carry out this section, to remain available until expended.(ii)

Receipt and acceptance

The Secretary shall be entitled to receive, shall accept, and shall use to carry out this section the funds transferred under clause (i), without further appropriation. (G)

Regulations

(i)

In general

Not later than October 1, 2015, the Secretary shall issue regulations to carry out this paragraph.(ii)

Requirements

Regulations issued under this subparagraph shall require that—(I)children shall be eligible to participate and shall be enrolled into the program under this paragraph for a summer without further application if the children are enrolled to participate in the free or reduced price lunch program under this Act or the free or reduced price breakfast program under the Child Nutrition Act of 1966 (42 U.S.C. 1771 et seq.) during the school year immediately preceding the summer; and(II)local educational agencies shall distribute to the families of all children enrolled in schools participating in programs authorized under this Act and the Child Nutrition Act of 1966 (42 U.S.C. 1771 et seq.) and, to the maximum extent practicable, the families of all children enrolled in schools of the local educational agency information, as provided by the Secretary—(aa)regarding the program authorized under this paragraph, including eligibility rules and how children in eligible households that are not automatically enrolled under subclause (I) may apply for program benefits; and(bb)to assist households receiving summer EBT cards in making healthy food choices and maximizing resources.(iii)

Alternative timing

(I)

In general

In issuing regulations under this subparagraph, the Secretary shall allow alternative plans for the timing of issuance of the summer electronic benefit cards under subparagraph (D) in any part of a State in which the school year does not include a typical summer break, on the condition that the Secretary determines that no alternative plan increases or decreases Federal costs.(II)

Considerations

In developing regulations under subclause (I), the Secretary shall consider the ability of a State effectively to issue benefits under an alternative schedule.

Defer deduction of interest expense related to deferred income

(a)

In general

Section 163 of the Internal Revenue Code of 1986 (relating to deductions for interest expense) is amended by redesignating subsection (n) as subsection (o) and by inserting after subsection (m) the following new subsection:

(n)

Deferral of deduction for interest expense related to deferred income

(1)

General rule

The amount of foreign-related interest expense of any taxpayer allowed as a deduction under this chapter for any taxable year shall not exceed an amount equal to the applicable percentage of the sum of—(A)the taxpayer's foreign-related interest expense for the taxable year, plus(B)the taxpayer's deferred foreign-related interest expense.

For purposes of this paragraph, the applicable percentage is the percentage equal to the current inclusion ratio.

(2)

Treatment of deferred deductions

If, for any taxable year, the amount of the limitation determined under paragraph (1) exceeds the taxpayer's foreign-related interest expense for the taxable year, there shall be allowed as a deduction for the taxable year an amount equal to the lesser of—(A)such excess, or (B)the taxpayer's deferred foreign-related interest expense. (3)

Definitions and special rule

For purposes of this subsection— (A)

Foreign-related interest expense

The term foreign-related interest expense means, with respect to any taxpayer for any taxable year, the amount which bears the same ratio to the amount of interest expense for such taxable year allocated and apportioned under sections 861, 864(e), and 864(f) to income from sources outside the United States as—(i)the value of all stock held by the taxpayer in all section 902 corporations with respect to which the taxpayer meets the ownership requirements of subsection (a) or (b) of section 902, bears to(ii)the value of all assets of the taxpayer which generate gross income from sources outside the United States. (B)

Deferred foreign-related interest expense

The term deferred foreign-related interest expense means the excess, if any, of the aggregate foreign-related interest expense for all prior taxable years beginning after December 31, 2014, over the aggregate amount allowed as a deduction under paragraphs (1) and (2) for all such prior taxable years. (C)

Value of assets

Except as otherwise provided by the Secretary, for purposes of subparagraph (A)(ii), the value of any asset shall be the amount with respect to such asset determined for purposes of allocating and apportioning interest expense under sections 861, 864(e), and 864(f). (D)

Current inclusion ratio

The term current inclusion ratio means, with respect to any domestic corporation which meets the ownership requirements of subsection (a) or (b) of section 902 with respect to one or more section 902 corporations for any taxable year, the ratio (expressed as a percentage) of— (i)the sum of all dividends received by the domestic corporation from all such section 902 corporations during the taxable year plus amounts includible in gross income under section 951(a) from all such section 902 corporations, in each case computed without regard to section 78, divided by (ii)the aggregate amount of post-1986 undistributed earnings. (E)

Aggregate amount of post-1986 undistributed earnings

The term aggregate amount of post-1986 undistributed earnings means, with respect to any domestic corporation which meets the ownership requirements of subsection (a) or (b) of section 902 with respect to one or more section 902 corporations, the domestic corporation’s pro rata share of the post-1986 undistributed earnings (as defined in section 902(c)(1)) of all such section 902 corporations. (F)

Foreign currency conversion

For purposes of determining the current inclusion ratio, and except as otherwise provided by the Secretary, the aggregate amount of post-1986 undistributed earnings for the taxable year shall be determined by translating each section 902 corporation’s post-1986 undistributed earnings into dollars using the average exchange rate for such year.(G)

Section 902 corporation

The term section 902 corporation has the meaning given to such term by section 909(d)(5).(4)

Treatment of affiliated groups

The current inclusion ratio of each member of an affiliated group (as defined in section 864(e)(5)(A)) shall be determined as if all members of such group were a single corporation. (5)

Application to separate categories of income

This subsection shall be applied separately with respect to the categories of income specified in section 904(d)(1). (6)

Regulations

The Secretary may prescribe such regulations or other guidance as is necessary or appropriate to carry out the purposes of this subsection, including regulations or other guidance providing— (A)for the proper application of this subsection with respect to changes in ownership of a section 902 corporation, (B)that certain corporations that otherwise would not be members of the affiliated group will be treated as members of the affiliated group for purposes of this subsection, (C)for the proper application of this subsection with respect to the taxpayer’s share of a deficit in earnings and profits of a section 902 corporation, (D)for appropriate adjustments to the determination of the value of stock in any section 902 corporation for purposes of this subsection or to the foreign-related interest expense to account for income that is subject to tax under section 882(a)(1), and (E)for the proper application of this subsection with respect to interest expense that is directly allocable to income with respect to certain assets.

(b)

Effective date

The amendments made by this section shall apply to taxable years beginning after December 31, 2014.