[Congressional Bills 111th Congress]
[From the U.S. Government Publishing Office]
[H.R. 3500 Introduced in House (IH)]

111th CONGRESS
  1st Session
                                H. R. 3500

  To amend the Internal Revenue Code of 1986 to extend and modify the 
 benefits available in empowerment zones and other tax-incentive areas.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                             July 31, 2009

  Mr. Maffei introduced the following bill; which was referred to the 
                      Committee on Ways and Means

_______________________________________________________________________

                                 A BILL


 
  To amend the Internal Revenue Code of 1986 to extend and modify the 
 benefits available in empowerment zones and other tax-incentive areas.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

    (a) Short Title.--This Act may be cited as the ``Small and Medium 
Urban Regions Growth and Empowerment Act of 2009'' or the ``SURGE Act 
of 2009''.
    (b) Amendment of 1986 Code.--Except as otherwise expressly 
provided, whenever in this Act an amendment or repeal is expressed in 
terms of an amendment to, or repeal of, a section or other provision, 
the reference shall be considered to be made to a section or other 
provision of the Internal Revenue Code of 1986.

SEC. 2. FINDINGS.

    The Congress hereby finds the following:
            (1) Businesses in Empowerment Zones with less population 
        density are disadvantaged from reaching the 35 percent 
        employment rule, making them significantly less likely to be 
        eligible for tax-exempt facility bonds and section 179 
        expensing.
            (2) Businesses in Empowerment Zones with less population 
        density have a much smaller pool of eligible employees to 
        choose from in order to access the employee wage credits.
            (3) Increasing empowerment zone coverage area into 
        disadvantaged communities that are not currently covered by the 
        zone is difficult, bureaucratic and lengthy.
            (4) There are too many limitations placed on the type of 
        businesses that are eligible for the credit, making places such 
        as small biotech firms, spas, and family-owned and operated 
        businesses ineligible.
            (5) Workforce development and on-the-job training is needed 
        to allow companies to transition to newer technologies or begin 
        new hires for newly begun ventures.

SEC. 3. EXTENSION OF BENEFITS.

    (a) Empowerment Zones.--
            (1) Rounds i and ii designations.--Section 1391(d)(1) is 
        amended by striking ``December 31, 2009'' in subparagraph 
        (A)(i) and inserting ``December 31, 2019''.
            (2) Round iii designations.--Section 1391(h)(2) is amended 
        by striking ``December 31, 2009'' and inserting ``December 31, 
        2019''.
    (b) Rural Enterprise Communities.--Section 1391(d)(1)(A) is amended 
by striking ``or'' at the end of clause (i) and by striking clause (ii) 
and inserting the following new clauses:
                            ``(ii) in the case of an enterprise 
                        community not described in clause (iii), the 
                        close of the 10th calendar year beginning on or 
                        after such date of designation, or
                            ``(iii) in the case of an enterprise 
                        community designated in a rural area pursuant 
                        to section 766 of division A of the Omnibus 
                        Consolidated and Emergency Supplemental 
                        Appropriations Act, 1999, December 31, 2019,''.
    (c) Renewal Communities.--
            (1) Sections 1400E(b) and 1400I(g) are each amended by 
        striking ``December 31, 2009'' each place it appears and 
        inserting ``December 31, 2019''.
            (2) Sections 1400E(b)(3), 1400F(b), and 1400J(b) are each 
        amended by striking ``January 1, 2010'' each place it appears 
        and inserting ``January 1, 2020''.
            (3) Section 1400F(c)(2) amended by striking ``December 31, 
        2014'' and inserting ``December 31, 2024''.
            (4) Section 1400F(d) is amended by striking ``December 31, 
        2014'' and inserting ``December 31, 2024''.
            (5) Section 1400I(d)(2)(A) is amended by striking ``2010'' 
        and inserting ``2020''.
    (d) Treatment of Termination Dates Specified in Nominations.--
            (1) Paragraph (1) of section 1391(d) is amended by adding 
        at the end the following new flush sentence:
        ``The termination date referred to in subparagraph (B) shall be 
        treated as being no earlier than the termination date under 
        subparagraph (A) unless an earlier termination date is 
        designated under subparagraph (B) after the date of the 
        enactment of this sentence.''.
            (2) Paragraph (1) of section 1400E(b) of such Code is 
        amended by adding at the end the following new flush sentence:
        ``The termination date referred to in subparagraph (B) shall be 
        treated as being no earlier than the termination date under 
        subparagraph (A) unless an earlier termination date is 
        designated under subparagraph (B) after the date of the 
        enactment of this sentence''.

SEC. 4. EXPANSION OF BUSINESSES ELIGIBLE FOR BENEFITS; EXPANSION OF 
              ELIGIBLE BUSINESS ACTIVITIES.

    (a) Expansion of Qualified Business Entities.--
            (1) In general.--Subsections (b) and (c) of section 1397C 
        are amended to read as follows:
    ``(b) Qualified Business Entity.--For purposes of this section, the 
term `qualified business entity' means, with respect to any taxable 
year, any corporation or partnership if for such year--
            ``(1) any trade or business of such entity is the active 
        conduct of a qualified business within an empowerment zone,
            ``(2) at least 35 percent of its employees are residents of 
        an empowerment zone,
            ``(3) less than 5 percent of the average of the aggregate 
        unadjusted bases of the property of such entity is attributable 
        to collectibles (as defined in section 408(m)(2)) other than 
        collectibles that are held primarily for sale to customers in 
        the ordinary course of such business, and
            ``(4) less than 5 percent of the average of the aggregate 
        unadjusted bases of the property of such entity is attributable 
        to nonqualified financial property.
    ``(c) Qualified Proprietorship.--For purposes of this section, the 
term `qualified proprietorship' means, with respect to any taxable 
year, any qualified business carried on by an individual as a 
proprietorship if for such year--
            ``(1) at least 35 percent of such employees are residents 
        of an empowerment zone,
            ``(2) less than 5 percent of the average of the aggregate 
        unadjusted bases of the property of such individual which is 
        used in such business is attributable to collectibles (as 
        defined in section 408(m)(2)) other than collectibles that are 
        held primarily for sale to customers in the ordinary course of 
        such business, and
            ``(3) less than 5 percent of the average of the aggregate 
        unadjusted bases of the property of such individual which is 
        used in such business is attributable to nonqualified financial 
        property.
For purposes of this subsection, the term `employee' includes the 
proprietor.''.
            (2) Conforming amendments.--
                    (A) Subsection (e) of section 1400 is amended by 
                striking ``subsections (b)(6) and (c)(5)'' and 
                inserting ``subsections (b)(2) and (c)(1)''.
                    (B) Paragraph (2) of section 1400B(c) is amended by 
                inserting ``(as in effect on the day before the date of 
                the enactment of the Small and Medium Urban Regions 
                Growth and Empowerment Act of 2009)'' after ``1397C''.
    (b) Modification of Employment Requirement for Businesses Located 
in Areas With Lower Population Density.--
            (1) Definition of qualified business entity.--Section 1397C 
        is amended by adding at the end the following new subsection:
    ``(g) Modification of Employment Requirement for Businesses Located 
in Areas With Lower Population Density.--
            ``(1) In general.--In the case of businesses located in a 
        lower-density empowerment zone, subsections (b)(2) and (c)(1) 
        shall be applied by treating employees as residents of the 
        empowerment zone if they are residents of a census tract--
                    ``(A) which is an area of pervasive poverty, 
                unemployment, and general distress (within the meaning 
                of section 1400E(c)(3)(A)), and
                    ``(B) any point on the boundary of which is within 
                50 miles of any point on the boundary of the 
                empowerment zone.
            ``(2) Lower-density empowerment zone.--For purposes of 
        paragraph (1), the term `lower density empowerment zone' means 
        any empowerment zone the average population of population 
        census tracts within such zone is less than 3,000.''.
            (2) Employment credit.--Paragraph (1) of section 1396(d) is 
        amended by adding at the end the following new flush sentence:
        ``In the case of businesses located in a lower-density 
        empowerment zone (as defined in section 1397C(g)(2)), 
        subparagraph (B) shall be applied by treating employees as 
        residents of the empowerment zone if they are residents of a 
        census tract which is an area of pervasive poverty, 
        unemployment, and general distress (within the meaning of 
        section 1400E(c)(3)(A)), and any point on the boundary of such 
        tract is within 50 miles of any point on the boundary of the 
        empowerment zone.''.
    (c) Expansion of Eligible Business Activities.--
            (1) Renting real or personal property permitted.--
                    (A) In general.--Subsection (d) of section 1397C is 
                amended by striking paragraphs (2) and (3).
                    (B) Recovery zone property.--Paragraph (2) of 
                section 1400U-3(c) is amended by striking subparagraph 
                (A).
                    (C) Conforming amendment.--Paragraph (3) of section 
                45D(d) is amended by striking ``; except that'' and all 
                that follows and inserting a period.
            (2) Developing or holding intangibles permitted.--
                    (A) In general.--Subsection (d) of section 1397C is 
                amended by striking paragraph (4).
                    (B) Conforming amendment.--Clause (iii) of section 
                1394(b)(3)(B) is amended by striking ``, (4),''.
            (3) Certain other businesses permitted.--
                    (A) Paragraph (5) of section 1397C(d) is amended--
                            (i) by striking ``any facility described in 
                        section 144(c)(6)(B)'' in subparagraph (A) and 
                        inserting ``any excluded facility'', and
                            (ii) by inserting before the last sentence 
                        the following new sentence: ``For purposes of 
                        subparagraph (A), the term `excluded facility' 
                        means any facility described in section 
                        144(c)(6)(B) other than any golf course, spa, 
                        or therapeutic massage facility.''.
                    (B) Paragraph (2) of section 1400U-3(c), as amended 
                by paragraph (1), is amended to read as follows:
            ``(2) Qualified business.--The term `qualified business' 
        means any trade or business other than any trade or business 
        consisting of the operation of any excluded facility (as 
        defined in section 1397C(d)(5)).''.
    (d) Empowerment Zone Employment Credit To Apply to Employees at 
Certain Additional Businesses and to Employees Who Are Family 
Members.--Subparagraph (D) of section 1396(d)(2) (defining qualified 
zone employee) is amended--
            (1) by striking subparagraph (A),
            (2) by redesignating subparagraphs (B), (C), (D), and (E) 
        as subparagraphs (A), (B), (C), and (D), respectively, and
            (3) by striking ``any facility described in section 
        144(c)(6)(B)'' in subparagraph (C), as so redesignated, and 
        inserting ``any excluded facility (as defined in section 
        1397C(d)(5))''.
    (e) Certain Businesses May Be Financed With Gulf Opportunity Zone 
Bonds.--
            (1) In general.--Subparagraph (E) of section 1400N(a)(2) is 
        amended by striking ``any property described in section 
        144(c)(6)(B)'' and inserting ``any excluded facility (as 
        defined in section 1397C(d)(5))''.
            (2) Effective date.--The amendment made by this subsection 
        shall apply to obligations issued after the date of the 
        enactment of this Act.

SEC. 5. MODIFICATIONS PERMITTING EXPANSION OF DESIGNATED AREAS.

    (a) Authority To Expand Boundaries of Zones and Communities.--
            (1) Empowerment zones and enterprise communities.--Section 
        1391 is amended by adding at the end the following new 
        subsection:
    ``(i) Authority To Expand Boundaries of Designated Areas.--
            ``(1) In general.--At the request of all governments which 
        nominated an area as an empowerment zone or enterprise 
        community, the appropriate Secretary may expand the area of 
        such zone or community to include 1 or more contiguous or 
        noncontiguous areas if such governments establish to the 
        satisfaction of the appropriate Secretary that such expansion 
        furthers the purposes of the designation of the initial area as 
        such a zone or community.
            ``(2) Rural areas.--With respect to any empowerment zone or 
        enterprise community located in a rural area, at the request of 
        the nominating local government, the appropriate Secretary 
        shall expand the area of such zone or community to include the 
        entire area of such nominating local government, but only if--
                    ``(A) either--
                            ``(i) the poverty rate and the unemployment 
                        rate for such entire area as determined by the 
                        2000 decennial census data was at least 110 
                        percent of such rate for the United States, or
                            ``(ii) during the period beginning with the 
                        1990 decennial census and ending with the 2000 
                        decennial census, such entire area has a net 
                        out migration of inhabitants of at least 10 
                        percent of the population of such area, and
                    ``(B) such entire area meets 1 or more of the 
                following criteria determined by the 2000 decennial 
                census data:
                            ``(i) Median household income is not more 
                        than 70 percent of such income for the United 
                        States.
                            ``(ii) Per capita income is not more than 
                        75 percent of such income for the United 
                        States.
                            ``(iii) The percentage of such area's 
                        population which is disabled is at least 130 
                        percent of such percentage for the United 
                        States.''.
            (2) Renewal communities.--Section 1400E is amended by 
        adding at the end the following new subsection:
    ``(h) Authority To Expand Boundaries of Designated Areas.--
            ``(1) In general.--At the request of all governments which 
        nominated an area as a renewal community, the Secretary of 
        Housing and Urban Development may expand the area of such 
        community to include 1 or more noncontiguous areas if such 
        governments establish to the satisfaction of such Secretary 
        that such expansion furthers the purposes of the designation of 
        the initial area as a renewal community.
            ``(2) Rural areas.--With respect to any renewal community 
        located in a rural area, at the request of the nominating local 
        government, the Secretary of Housing and Urban Development 
        shall expand the area of such community to include the entire 
        area of such nominating local government, but only if--
                    ``(A) either--
                            ``(i) the poverty rate and the unemployment 
                        rate for such entire area as determined by the 
                        2000 decennial census data was at least 110 
                        percent of such rate for the United States, or
                            ``(ii) during the period beginning with the 
                        1990 decennial census and ending with the 2000 
                        decennial census, such entire area has a net 
                        out migration of inhabitants of at least 10 
                        percent of the population of such area, and
                    ``(B) such entire area meets 1 or more of the 
                following criteria determined by the 2000 decennial 
                census data:
                            ``(i) Median household income is not more 
                        than 70 percent of such income for the United 
                        States.
                            ``(ii) Per capita income is not more than 
                        75 percent of such income for the United 
                        States.
                            ``(iii) The percentage of such area's 
                        population which is disabled is at least 130 
                        percent of such percentage for the United 
                        States.''.
            (3) Effective date.--The amendments made by this subsection 
        shall take effect on the date of the enactment of this Act.
    (b) Modification of Requirement for Expanding Designated Area Based 
on 2000 Census.--
            (1) In general.--Clause (ii) of section 1400E(g)(1)(A) is 
        amended to read as follows:
                            ``(ii) such tract has a poverty rate using 
                        2000 census data--
                                    ``(I) which is at least 20 percent, 
                                or
                                    ``(II) which exceeds the poverty 
                                rate for such tract using 1990 census 
                                data.''.
            (2) Effective date.--The amendment made by this subsection 
        shall take effect on the date of the enactment of this Act.
    (c) Repeal of Exclusion of Central Business District From 
Eligibility as Designated Area.--
            (1) In general.--Paragraph (3) of section 1392(a) is 
        amended by adding ``and'' at the end of subparagraph (B), by 
        striking ``, and'' at the end of subparagraph (C) and inserting 
        a period, and by striking subparagraph (D).
            (2) Effective date.--The amendments made by this subsection 
        shall take effect on the date of the enactment of this Act.

SEC. 6. EXPANDED USE OF TAX-EXEMPT BONDS.

    (a) Enterprise Facility Bond Limit for Small Cities To Be the Same 
as for Larger Cities.--Subparagraph (B) of section 1394(f)(2) is 
amended by adding ``and'' at the end of clause (i), by striking clause 
(iii), and by amending clause (ii) to read as follows:
                            ``(ii) $230,000,000 if such zone is in an 
                        urban area.''.
    (b) Zone Employment Requirement Need Not Be Met After Testing 
Period Under Zone Facility Bond Rules.--
            (1) In general.--Clause (iii) of section 1394(b)(3)(B) is 
        amended by striking ``if at least 35 percent of the employees 
        of such business for such year are residents of an empowerment 
        zone or an enterprise community''.
            (2) Conforming amendment.--Subsection (a) of section 1400A 
        is amended by striking ``and section 1394(b)(3)(B)(iii) shall 
        be applied without regard to the employee residency 
        requirement''.
    (c) Zone Facility Bonds for Small Businesses May Be Guaranteed.--
            (1) In general.--Subsection (d) of section 1394 is amended 
        to read as follows:
    ``(d) Special Rules.--
            ``(1) Acquisition of land and existing property 
        permitted.--The requirements of sections 147(c)(1)(A) and 
        147(d) shall not apply to any bond described in subsection (a).
            ``(2) Bonds for small business may be guaranteed.--Section 
        149(b) shall not apply to any bond issued as part of an issue 
        95 percent or more of the net proceeds (as defined in section 
        150(a)(3)) of which are to be used to provide any enterprise 
        zone facility the principal user of which is a small employer 
        (as defined in section 221(c)(4)).''.
            (2) Qualified gulf opportunity zone bonds.--Paragraph (5) 
        of section 1400N(a) is amended by adding at the end the 
        following new subparagraph:
                    ``(H) Section 149(b) shall not apply to any 
                qualified Gulf Opportunity Zone Bond issued as part of 
                an issue 95 percent or more of the net proceeds (as 
                defined in section 150(a)(3)) of such issue are to be 
                used for qualified project costs for nonresidential 
                real property (including fixed improvements associated 
                with such property) the principal user of which is a 
                small employer (as defined in section 221(c)(4)).''.
            (3) Recovery zone facility bonds.--Subsection (d) of 
        section 1400U-3 is amended by adding at the end the following 
        new sentence: ``Section 149(b) shall not apply to any recovery 
        zone facility bond issued as part of an issue 95 percent or 
        more of the net proceeds (as defined in section 150(a)(3)) of 
        such issue are to be used for recovery zone property the 
        principal user of which is a small employer (as defined in 
        section 221(c)(4)).''
    (d) Effective Date.--The amendments made by this section shall 
apply to obligations issued after the date of the enactment of this 
Act.

SEC. 7. OTHER MODIFICATIONS.

    (a) Nonrecognition of Gain To Apply to Real Property and 
Intangibles.--Paragraph (2) of section 1397B(b) is amended to read as 
follows:
            ``(2) Gain taxed as ordinary income not eligible for 
        rollover.--This section shall not apply to any gain which is 
        treated as ordinary income for purposes of this subtitle.''.
    (b) Election of Financing Arrangement in Lieu of Tax Benefits.--
            (1) In general.--Section 1396 is amended by adding at the 
        end the following new subsection:
    ``(e) Election of Financing Arrangement in Lieu of Tax Benefits.--
            ``(1) In general.--At the election of any significant 
        empowerment zone business, for the payment period of the debt 
        obligation designated in such election (or as an amendment to 
        such election) by such business--
                    ``(A) such business--
                            ``(i) shall not be allowed an empowerment 
                        zone employment credit described in subsection 
                        (a), and
                            ``(ii) shall not be allowed any deduction 
                        for depreciation under section 168 with respect 
                        to qualified zone property that provides a cost 
                        recovery benefit described in paragraph (2), 
                        and
                    ``(B) the Secretary shall make the payments 
                described in paragraph (2) to a trustee designated by 
                the electing business to accept such payments on behalf 
                of such holders).
            ``(2) Payments.--
                    ``(A) In general.--At the beginning of each year of 
                the payment period, the Secretary shall pay (out of any 
                money in the Treasury not otherwise appropriated) to 
                the trustee designated by such business an amount equal 
                to--
                            ``(i) the empowerment zone employment 
                        credit computed for such year under this 
                        section as if the election was not made under 
                        this subsection, and
                            ``(ii) except as provided in paragraph 
                        (4)(A), the amount equal to the cost recovery 
                        benefit divided by the number of years in the 
                        payment period described in subparagraph (C).
                    ``(B) Cost recovery benefit.--For purposes of 
                subparagraph (A), the cost recovery benefit shall be an 
                amount equal to 25 percent of--
                            ``(i) the cost of any tangible property 
                        which is qualified zone property (including 
                        improvements to such tangible property) 
                        incurred by the significant empowerment zone 
                        business before the end of the first 5 full 
                        calendar years beginning after the date the 
                        election is made under this subsection, and
                            ``(ii) any such cost for which a binding 
                        contract for financing the acquisition of such 
                        tangible property (including improvements to 
                        such tangible property) has been made by such 
                        business and which under the terms of the 
                        financing is to be incurred within the first 5 
                        full calendar years beginning after the date of 
                        the election made under this subsection.
                    ``(C) Payment period.--The payment period is the 
                period of 15 calendar years beginning with the earlier 
                of--
                            ``(i) the calendar year specified by the 
                        significant empowerment zone business as the 
                        1st year of the payment period without regard 
                        to the date the property is placed in service, 
                        or
                            ``(ii) the 5th calendar year beginning 
                        after the date that the election under this 
                        subsection is made.
            ``(3) Significant empowerment zone business.--For purposes 
        of this subsection, the term `significant empowerment zone 
        business' means any trade or business operating in an 
        empowerment zone if--
                    ``(A) such business is nominated by the chief 
                executive or the legislative body of the State or a 
                local government in which the zone property is located, 
                and
                    ``(B) the Secretary of Housing and Urban 
                Development determines that--
                            ``(i) it is a facility for qualified 
                        research as defined in section 41(d) which is 
                        reasonably anticipated to make at least 
                        $50,000,000 of capital expenditures within the 
                        first 3 years of the payment period, or
                            ``(ii) with respect to any other business, 
                        it is reasonably anticipated that such business 
                        will increase employment in such zone by the 
                        end of the first 3 years of the payment period 
                        by at least the lesser of--
                                    ``(I) 1,000 full-time employees or 
                                equivalents, or
                                    ``(II) 10 percent of the number of 
                                full-time employees estimated to have 
                                been employed in such zone on the date 
                                of its designation.
            ``(4) Special rules.--
                    ``(A) Adjustment to cost recovery benefit.--In the 
                event that the significant empowerment zone business 
                does not incur a cost within the period described in 
                paragraph (2)(B) and for which a cost recovery benefit 
                payment is made under this subsection, the Secretary 
                shall reduce future recovery benefit payments to 
                recover 110 percent of the overpayments in equal 
                installments over the remaining payment period. In the 
                event that a cost described in paragraph (2)(B)(i) is 
                incurred, or a contract described in paragraph 
                (2)(B)(ii) is entered into, after the beginning of the 
                payment period, the Secretary shall increase future 
                recover benefit payments to recover 100 percent of the 
                cost recovery benefit associated with such costs or 
                contracts in equal installments over the remaining 
                payment period.
                    ``(B) Basis adjustment.--For purposes of this 
                subtitle, if a cost recovery payment is made under this 
                subsection with respect to any property, the basis of 
                such property shall be reduced by the amount of such 
                payment.
            ``(5) Treatment of payments.--Any payment made under this 
        subsection shall not be treated as a Federal Government 
        guarantee for purposes of section 149(b).''.
            (2) Conforming amendment.--Section 1016(a) is amended by 
        striking ``and'' at the end of paragraph (36), by striking the 
        period at the end of paragraph (37) and inserting ``, and'', 
        and by adding at the end the following new paragraph:
            ``(38) to the extent provided in section 1396(e)(4)(B).''.

SEC. 8. GRANTS FOR AWARENESS OF ZONE BENEFITS AND TECHNICAL ASSISTANCE 
              TO SMALL BUSINESS.

    (a) In General.--Chapter 77 is amended by adding at the end the 
following new section:

``SEC. 7529. GRANTS FOR AWARENESS OF ZONE BENEFITS AND TECHNICAL 
              ASSISTANCE TO SMALL BUSINESS.

    ``(a) In General.--The Secretary may make grants to State or local 
governments, or nonprofit organizations, for the purpose of making 
businesses aware of the benefits available under--
            ``(1) subchapter U of chapter 1 (relating to designation 
        and treatment of empowerment zones, enterprise communities, and 
        rural development investment areas),
            ``(2) subchapter W of chapter 1 (relating to District of 
        Columbia enterprise zone),
            ``(3) subchapter X of chapter 1 (relating to renewal 
        communities), and
            ``(4) subchapter Y of chapter 1 (relating to short-term 
        regional benefits).
    ``(b) Technical Assistance Grants.--The Secretary may make grants 
to provide technical assistance to small businesses eligible for any 
benefits referred to in subsection (a).''.
    (b) Clerical Amendment.--The table of sections for such chapter is 
amended by adding at the end the following new item:

``Sec. 7529. Grants for awareness of zone benefits and technical 
                            assistance to small business.''.
    (c) Effective Date.--The amendments made by this section shall take 
effect on the date of the enactment of this Act.

SEC. 9. EFFECTIVE DATE.

    Except as otherwise provided in this Act, the amendments made by 
this Act shall apply to taxable years beginning after the date of the 
enactment of this Act.
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