[Congressional Bills 116th Congress]
[From the U.S. Government Publishing Office]
[S. 5031 Introduced in Senate (IS)]
<DOC>
116th CONGRESS
2d Session
S. 5031
To amend the Internal Revenue Code of 1986 to provide for a progressive
consumption tax and to reform the income tax, and for other purposes.
_______________________________________________________________________
IN THE SENATE OF THE UNITED STATES
December 16, 2020
Mr. Cardin introduced the following bill; which was read twice and
referred to the Committee on Finance
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to provide for a progressive
consumption tax and to reform the income tax, and for other purposes.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE, ETC.
(a) In General.--This Act may be cited as the ``Progressive
Consumption Tax Act of 2020''.
(b) Reference.--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.
(c) Table of Contents.--The table of contents of this Act is as
follows:
Sec. 1. Short title, etc.
TITLE I--PROGRESSIVE CONSUMPTION TAX
Sec. 101. Imposition of progressive consumption tax.
TITLE II--INDIVIDUAL AND CORPORATE TAX REFORM
Subtitle A--Individual Income Tax Reforms
Sec. 201. Individual income tax rate reductions and inflation
adjustments.
Sec. 202. Family allowance amounts; repeal of personal exemption
deduction.
Sec. 203. Repeal of limitations relating to itemized deductions.
Sec. 204. Restoration of certain deductions.
Sec. 205. Termination of separate treatment of capital gains.
Sec. 206. Repeals.
Sec. 207. Establishment of progressive tax rebate.
Sec. 208. Technical and conforming amendments.
Subtitle B--Corporate Tax Reforms
Sec. 211. Corporate income tax rate reduction.
TITLE III--REFUND OF EXCESS CONSUMPTION TAX REVENUE
Sec. 301. Refunds of excess consumption tax revenue.
TITLE I--PROGRESSIVE CONSUMPTION TAX
SEC. 101. IMPOSITION OF PROGRESSIVE CONSUMPTION TAX.
(a) In General.--Subtitle D is amended by inserting before chapter
31 the following new chapter:
``CHAPTER 30--PROGRESSIVE CONSUMPTION TAX
``subchapter a. imposition of tax
``subchapter b. taxable supply
``subchapter c. credit against tax
``subchapter d. administration
``subchapter e. definitions and special rules
``Subchapter A--Imposition of Tax
``Sec. 3901. Imposition of tax.
``Sec. 3902. Taxable amount.
``SEC. 3901. IMPOSITION OF TAX.
``(a) General Rule.--A tax is hereby imposed on every taxable
supply.
``(b) Amount of Tax.--
``(1) In general.--Except as provided in paragraph (2), the
amount of the tax shall be 10 percent of the taxable amount.
``(2) Special rate for exports.--The amount of the tax
shall be zero with respect to the provision of any supply which
is--
``(A) a supply of tangible personal property that
is exported from the United States within 90 days after
the provider gives an invoice for the supply, or
``(B) a supply, other than a supply of tangible
personal property--
``(i) which is provided to a recipient that
is not in the United States when the supply is
performed or otherwise done, and
``(ii) the use of which takes place outside
of the United States.
``SEC. 3902. TAXABLE AMOUNT.
``(a) Amount Charged Customer.--For purposes of this chapter, the
taxable amount for any taxable supply for which money is the only
consideration shall be the price charged by the provider--
``(1) including all invoiced charges for transportation,
and other items payable to the provider with respect to the
supply, but
``(2) excluding the tax imposed by section 3901 with
respect to the supply and excluding any State and local sales
and use taxes with respect to the supply.
``(b) Barter Transactions.--For purposes of this chapter, the
taxable amount for any taxable supply which includes consideration
other than money shall be the fair market value of the consideration
(including all invoiced charges for transportation and other items
payable to the provider) plus the amount of any money paid in
consideration.
``(c) Imports.--For purposes of this chapter, the taxable amount in
the case of any import shall be--
``(1) the customs value plus customs duties and any other
duties which may be imposed, or
``(2) if there is no such customs value, the fair market
value (determined as if the importer had sold the supply).
For purposes of this subsection, the customs value of any import shall
include all invoiced charges for transportation and other items payable
to the importer with respect to the supply.
``(d) Special Rule in the Case of Sales of Certain Used Consumer
Goods.--For purposes of this chapter, if--
``(1) a person acquires any tangible personal property in a
transaction which was not taxable under this chapter, and
``(2) such property had been used by an ultimate consumer
before such acquisition,
the taxable amount in the case of any sale of such property by such
person (determined without regard to this subsection) shall be reduced
by the amount paid for such property by such person.
``Subchapter B--Taxable Supply
``Sec. 3911. Taxable supply.
``Sec. 3912. Supplies made in connection with the United States.
``Sec. 3913. Exempt supply.
``SEC. 3911. TAXABLE SUPPLY.
``(a) In General.--For purposes of this chapter, the term `taxable
supply' means--
``(1) the importation of property into the United States,
and
``(2) any supply (other than an exempt supply)--
``(A) which is provided--
``(i) in the course of carrying on a trade
or business,
``(ii) in the case of an organization
exempt from tax under section 501(a), in
furtherance of the activities related to the
purpose or function constituting the basis of
its exemption under section 501, or
``(iii) in the case of a State, an Indian
tribal government, a possession of the United
States, or any political subdivision of any of
the foregoing, or the United States or the
District of Columbia, in carrying out any
activity that is not an essential governmental
function,
``(B) for which consideration is provided in
return, and
``(C) which is made in connection with the United
States.
``(b) Supply.--For purposes of this chapter--
``(1) In general.--The term `supply' means any supply
whatsoever, including--
``(A) the sale or provision (including through
renting, leasing, or licensing) of property,
``(B) the performance of services,
``(C) the grant, assignment, or surrender of real
property,
``(D) the creation, grant, transfer, assignment, or
surrender of any right,
``(E) financial supplies, and
``(F) an entry into, or release from, an obligation
or agreement to perform or refrain from performing an
act.
``(2) Special rule for services for employer.--An
employee's services for the employee's employer shall not be
treated as a supply.
``SEC. 3912. SUPPLIES MADE IN CONNECTION WITH THE UNITED STATES.
``(a) Tangible Property.--For purposes of this chapter--
``(1) In general.--The supply of tangible property is made
in connection with the United States if--
``(A) the property is delivered or made available
to the recipient in the United States, or
``(B) the property is assembled in or removed from
any location in the United States.
``(2) Real property.--The supply of real property is made
in connection with the United States if the real property is
located in the United States.
``(b) Services, Intangible Property, and Other Supplies.--For
purposes of this chapter, the supply of anything other than tangible
property or real property is made in connection with the United States
if--
``(1) the supply is used, performed, or otherwise done in
the United States, or
``(2) the supply is provided through a trade or business in
the United States.
``SEC. 3913. EXEMPT SUPPLY.
``(a) In General.--An exempt supply shall not be subject to tax
under this chapter.
``(b) Exempt Supply.--For purposes of this chapter--
``(1) In general.--The term `exempt supply' means--
``(A) the rental or leasing of residential real
property,
``(B) any sale of qualified residential real
property,
``(C) any financial supply,
``(D) any nonparticipating small supplier supply,
and
``(E) any taxable supply (or category of such
supplies) treated as an exempt supply under section
3932(b).
``(2) Qualified residential real property.--For purposes of
paragraph (1), the term `qualified residential real property'
means residential real property--
``(A) which--
``(i) has previously been sold as
residential real property, or
``(ii) has been continuously rented for 5
years or more, and
``(B) to which substantial renovations have not
been made after the date of the enactment of this
chapter.
``(3) Nonparticipating small supplier supply.--
``(A) In general.--For purposes of paragraph (1),
the term `nonparticipating small supplier supply' means
any supply provided by a supplier during--
``(i) any taxable period during which such
supplier was a nonparticipating small supplier,
or
``(ii) the four-week period beginning on
the first day after the close of the last
calendar quarter in which such supplier was a
nonparticipating small supplier.
``(B) Nonparticipating small supplier.--
``(i) In general.--For purposes of
subparagraph (A), the term `nonparticipating
small supplier' means any person for any
taxable period if--
``(I) such person has aggregate
taxable revenues of not more than
$100,000 for the four-calendar quarter
period ending immediately before the
taxable period, and
``(II) has not made an election
under clause (iii) for such taxable
period.
``(ii) Taxable revenue.--For purposes of
this paragraph, the term `taxable revenue'
means revenue from supplies which are taxable
supplies, determined without regard to
paragraph (1)(D).
``(iii) Election.--Under regulations
prescribed by the Secretary, any person who
meets the requirements of clause (i)(I) may
make an election not to be treated as a
nonparticipating small supplier for any taxable
period.
``(C) Aggregation rules.--For purposes of
determining aggregate taxable revenues under
subparagraph (B)(i)(I), all members of the same
controlled group of corporations (within the meaning of
section 267(f)) and all persons under common control
(within the meaning of section 52(b) but determined by
treating an interest of more than 50 percent as a
controlling interest) shall be treated as 1 person.
``Subchapter C--Credit Against Tax
``Sec. 3916. Credit against tax.
``SEC. 3916. CREDIT AGAINST TAX.
``(a) General Rule.--There shall be allowed as a credit against the
aggregate amount of tax imposed by section 3901 with respect to all
taxable supplies made by the taxpayer during the taxable period an
amount equal to the aggregate amount of tax imposed by section 3901 on
creditable acquisitions of the taxpayer during such taxable period.
``(b) Creditable Acquisitions.--For purposes of this chapter, the
term `creditable acquisition' means the acquisition or receipt of any
supply which--
``(1) was subject to tax under section 3901 at the time it
was provided to the taxpayer,
``(2) was used by the taxpayer--
``(A) in the course of carrying on a trade or
business,
``(B) in the case of a taxpayer exempt from tax
under section 501(a), in furtherance of the activities
related to the purpose or function constituting the
basis of the exemption under section 501, or
``(C) in the case of a State, an Indian tribal
government, a possession of the United States, or any
political subdivision of any of the foregoing, or the
United States or the District of Columbia, in carrying
out any activity that is not an essential governmental
function, and
``(3) except as provided in subsection (c), was not used by
the taxpayer to make an exempt supply.
``(c) Certain Acquisitions Related to Financial Supplies.--
``(1) Acquisitions by qualified small financial
suppliers.--
``(A) In general.--Solely for purposes of
subsections (b)(3) and (d)(1), a financial supply which
is provided by a qualified small financial supplier
shall not be treated as an exempt supply.
``(B) Qualified small financial supplier.--
``(i) In general.--For purposes of this
paragraph, the term `qualified small financial
supplier' means any person for any month if,
for the 12-month period ending with the month
preceding such month, the amount of credits
which, but for this paragraph, would be
allowable to such person under subsection (a)
for taxable supplies which are used for the
purpose of making financial supplies does not
exceed the lesser of--
``(I) $150,000, or
``(II) 10 percent of the amount of
credits allowable to such person under
subsection (a) (determined without
regard to this paragraph) for all
taxable supplies during such 12-month
period.
``(ii) Aggregation rules.--For purposes of
determining the amount of credits for any
period under clause (i), all members of the
same controlled group of corporations (within
the meaning of section 267(f)) and all persons
under common control (within the meaning of
section 52(b) but determined by treating an
interest of more than 50 percent as a
controlling interest) shall be treated as 1
person.
``(2) Partially creditable acquisitions.--
``(A) In general.--In the case of any partially
creditable acquisition by a person other than a
qualified small financial supplier--
``(i) subsection (b) shall be applied
without regard to paragraph (3) thereof, and
``(ii) only 60 percent of the amount of tax
imposed by section 3901 shall be taken account
under subsection (a) in determining the amount
of the credit under this section.
``(B) Partially creditable acquisition.--For
purposes of this section--
``(i) In general.--The term `partially
creditable acquisition' means the acquisition
of any supply described in clause (ii) if such
acquisition is used to provide a financial
supply.
``(ii) Supplies described.--A supply is
described in this clause if such supply is a
supply of--
``(I) banking or cash management
services, including services related to
issuing, closing, operating, and
maintaining accounts, and the
processing of account information and
applications,
``(II) payment and fund transfer
services, including for the operation
of a payment system and processing
account transactions,
``(III) securities transaction
services for the provision,
acquisition, or disposal of an interest
in a security,
``(IV) loan and debt collection
services, including mortgage brokerage
services, services related to mortgage
insurance and loan protection
insurance, and loan application,
management, and processing services,
``(V) capital markets, financial
instruments, or fund management
services,
``(VI) insurance services,
including brokerage services, or
``(VII) such other services as the
Secretary may specify in regulations.
``(d) Exempt Supplies, etc.--
``(1) In general.--If acquisitions (other than partially
creditable acquisitions) are used partly for a use which is not
for an exempt supply and partly for an exempt supply, the
credit shall be allowable only with respect to the acquisitions
which are not used for an exempt supply.
``(2) Partially creditable acquisitions.--If partially
creditable acquisition is used partly to provide a supply
described in subsection (c)(2)(B)(ii) and partly for another
use, subsection (c)(2) shall apply only with respect to
acquisitions used to provide supplies described in subsection
(c)(2)(B)(ii).
``(e) Excess Credit Treated as Overpayment.--
``(1) In general.--If for any taxable period the amount of
the credit allowable by subsection (a) exceeds the aggregate
amount of the tax imposed by section 3901 for such period, such
excess shall be treated as an overpayment of the tax imposed by
section 3901.
``(2) Time when overpayment arises.--Any overpayment under
paragraph (1) for any taxable period shall be treated as
arising on the later of--
``(A) the due date for the return for such period,
or
``(B) the date on which the return is filed.
``Subchapter D--Administration
``Sec. 3921. Provider liable for tax.
``Sec. 3922. Tax invoices.
``Sec. 3923. Time for filing return and claiming credit; deposits of
tax.
``Sec. 3924. Treatment of related businesses, etc.
``Sec. 3925. Reports.
``Sec. 3926. Regulations.
``SEC. 3921. PROVIDER LIABLE FOR TAX.
``(a) In General.--Except as provided in subsection (b), the person
providing the supply shall be liable for the tax imposed by section
3901.
``(b) Special Rule for Imports.--The person receiving the supply
shall be liable for the tax imposed under section 3901--
``(1) in the case of any taxable supply described in
section 3911(a)(1), and
``(2) in the case of any taxable supply which is not a
supply of tangible property and which is--
``(A) performed or otherwise done outside the
United States,
``(B) used in the United States, and
``(C) acquired for use--
``(i) in carrying on a trade or business in
the United States,
``(ii) by an organization exempt from tax
under section 501(a), in furtherance of
activities related to the purpose or function
constituting the basis of its exemption under
section 501, or
``(iii) by a State, an Indian tribal
government, a possession of the United States,
or any political subdivision of any of the
foregoing, or the United States or the District
of Columbia, in carrying out any activity that
is not an essential governmental function.
``SEC. 3922. TAX INVOICES.
``(a) In General.--
``(1) Supplies made in connection with the united states.--
Except as otherwise provided in this subsection, any person
providing a taxable supply shall give the recipient a tax
invoice with respect to such supply.
``(2) Certain services performed outside the united
states.--In the case of any taxable supply described in section
3921(b)(2), paragraph (1) shall not apply and the person
receiving the taxable supply shall generate a tax invoice with
respect to such supply.
``(3) Imports.--In the case of any taxable supply described
in section 3911(a), the Secretary, in consultation with the
Commissioner of Customs and Border Protection, shall promulgate
regulations governing the provision of tax invoices.
``(b) Content of Invoice.--The tax invoice required by subsection
(a) with respect to any supply shall set forth--
``(1) the name and, in the case of an invoice under
subsection (a)(1), identification number of the provider,
``(2) the name of the recipient,
``(3) the date of the taxable supply,
``(4) the taxable amount with respect to the taxable
supply,
``(5) the amount of the tax imposed by section 3901, and
``(6) such other information as may be prescribed by
regulations.
``(c) No Credit Without Invoice.--
``(1) In general.--Except as provided in paragraph (2) or
(3), a taxpayer may claim a credit with respect to a creditable
acquisition only if the taxpayer--
``(A) has in the taxpayer's possession a tax
invoice which meets the requirements of this section,
and
``(B) is named as the recipient of the supply in
such invoice.
``(2) Employees or other agents named in invoices.--To the
extent provided in regulations, the naming of an employee or
other agent of the recipient of the supply shall be treated as
the naming of the recipient.
``(3) Waiver of invoice requirement in certain cases.--To
the extent provided in regulations, paragraph (1) shall not
apply--
``(A) where the taxpayer can demonstrate that the
failure to receive or to have in the taxpayer's
possession a tax invoice was without fault on the
taxpayer's part, or
``(B) to a taxable supply (or category of supplies)
where--
``(i) the amount involved is de minimis, or
``(ii) the information required by
subsection (b) can be reliably established by
sampling or by another method and can be
adequately documented.
``(d) Time for Furnishing Invoice.--Any invoice required to be
furnished by subsection (a) with respect to any supply shall be
furnished not later than 15 business days after the tax point for such
supply.
``SEC. 3923. TIME FOR FILING RETURN AND CLAIMING CREDIT; DEPOSITS OF
TAX.
``(a) Filing Return.--Before the last day of the fourth week (third
week, in the case of any taxpayer to which subsection (c)(2) applies)
after the close of each taxable period, each person liable for tax
under this chapter shall file a return of the tax imposed by section
3901 on taxable supplies having a tax point within such taxable period.
``(b) Credit Allowed for Taxable Period in Which Recipient Receives
Invoice.--
``(1) In general.--Except as provided in paragraph (2), a
credit allowable by section 3916 with respect to a supply may
be allowed only for the first taxable period by the close of
which the taxpayer--
``(A) has paid or accrued amounts properly
allocable to the tax imposed by section 3901 with
respect to such supply, and
``(B) has a tax invoice (or equivalent) with
respect to such supply.
``(2) Use for later period.--Under regulations, a credit
allowable by section 3916 may be allowed for a period after the
period set forth in paragraph (1).
``(c) Taxable Period.--For purposes of this chapter--
``(1) In general.--Except as provided in paragraph (2), the
term `taxable period' means a calendar quarter.
``(2) Monthly period for certain taxpayers.--
``(A) In general.--In the case of a taxpayer who
makes taxable supplies for any month in excess of
$20,000,000, the term `taxable period' means a calendar
month.
``(B) Election of 1-month period.--If the taxpayer
so elects, the term `taxable period' means a calendar
month.
``(d) Tax Point.--For purposes of this chapter--
``(1) Chapter 1 rules with respect to provider govern.--
Except as provided in paragraph (2), the tax point for any
supply is the earlier of--
``(A) the time (or times) when any income from the
provision of the supply should be treated by the
provider as received or accrued (or any loss should be
taken into account by the seller) for purposes of
chapter 1, or
``(B) the time (or times) when the provider
receives payment for the sale.
``(2) Imports.--In the case of the importing of property,
the tax point is when the property is entered, or withdrawn
from warehouse, for consumption in the United States.
``(e) Monthly Deposits Required.--To the extent provided in
regulations, monthly deposits may be required of the estimated
liability for any taxable period for the tax imposed by section 3901.
``SEC. 3924. TREATMENT OF RELATED BUSINESSES, ETC.
``For purposes of this chapter, except as provided in sections
3913(b)(3)(C) and 3916(c)(1)(B)(ii) and in regulations established by
the Secretary, the taxpayer may elect--
``(1) to treat as 1 person 2 or more businesses which may
be treated under section 52(b) as 1 employer, and
``(2) to treat as separate persons separate divisions of
the same business.
``SEC. 3925. REPORTS.
``The Secretary shall submit to Congress semi-annual reports on the
implementation and administration of this chapter, including the amount
of revenue collected from the tax imposed under this chapter and
estimates of the revenue to be collected from such tax for future
period.
``SEC. 3926. REGULATIONS.
``The Secretary shall prescribe such regulations as may be
necessary to carry out the purposes of this chapter.
``Subchapter E--Definitions and Special Rules
``Sec. 3931. Definitions.
``Sec. 3932. Special rules.
``SEC. 3931. DEFINITIONS.
``For purposes of this chapter--
``(1) Business.--The term `business' includes--
``(A) a trade, and
``(B) an activity regularly carried on for profit.
``(2) Business day.--The term `business day' means any day
other than Saturday and Sunday and other than a legal holiday
(within the meaning of section 7503).
``(3) Employee.--The term `employee' has the meaning such
term has for purposes of chapter 24.
``(4) Financial supplies.--The term `financial supplies'
means the provision, acquisition, or disposal of any of the
following: a bank account, a debit or credit arrangement, a
mortgage, a superannuation fund, an annuity, insurance, a
financial guarantee, an indemnity, currency, securities, or
derivatives.
``(5) Person.--The term `person' includes any governmental
entity.
``(6) Provide; provider.--The term `provide', when used in
reference to taxable supplies (other than in section
3911(a)(2)), includes the importation of property and the term
`provider' includes the importer of property.
``(7) United states.--The term `United States', when used
in a geographical sense, includes a Commonwealth and any
possession of the United States.
``SEC. 3932. SPECIAL RULES.
``(a) Coordination With Subtitle A.--For purposes of subtitle A--
``(1) Treatment of credit.--Any credit allowable to a
taxpayer under section 3916 which is attributable to any supply
shall be treated as a reduction in the amount paid or incurred
by the taxpayer for such supply.
``(2) Amount of deduction for tax.--The amount allowable as
a deduction for the tax imposed by section 3901 shall be
determined without regard to any credit allowable under section
3916.
``(3) Computation of percentage depletion.--For purposes of
sections 613 and 613A--
``(A) gross income shall be reduced by the amount
of the tax imposed by section 3901, and
``(B) taxable income shall be determined without
regard to any deduction allowed for such tax.
``(b) Authority to Zero Rate De Minimis Supplies, etc.--The
Secretary may prescribe regulations treating as an exempt supply any
taxable supply (or category of such supplies) where--
``(1) the amount involved is de minimis, or
``(2) the revenue raised by taxing the supply is not
sufficient to justify the administrative and other costs
involved in the payment and collection of the tax.''.
(b) Clerical Amendment.--The table of chapters for subtitle D is
amended by inserting before the item relating to chapter 31 the
following:
``Chapter 30. Progressive Consumption Tax''.
(c) Effective Date.--The amendments made by this section shall
apply to supplies provided after December 31, 2021.
TITLE II--INDIVIDUAL AND CORPORATE TAX REFORM
Subtitle A--Individual Income Tax Reforms
SEC. 201. INDIVIDUAL INCOME TAX RATE REDUCTIONS AND INFLATION
ADJUSTMENTS.
(a) In General.--
(1) Married individuals filing joint returns and surviving
spouses.--Subsection (a) of section 1 is amended by striking
the table and inserting the following:
``If taxable income is: The tax is:
Not over $100,000..............
15 percent of taxable income.
Over $100,000 but not over
$500,000.
$15,000, plus 25 percent of the
excess over $100,000.
Over $500,000..................
$115,000, plus 28 percent of
the excess over
$500,000.''.
(2) Heads of households.--Subsection (b) of section 1 is
amended by striking the table and inserting the following:
``If taxable income is: The tax is:
Not over $50,000...............
15 percent of taxable income.
Over $50,000 but not over
$250,000.
$7,500, plus 25 percent of the
excess over $50,000.
Over $250,000..................
$57,500, plus 28 percent of the
excess over
$250,000.''.
(3) Unmarried individuals (other than surviving spouses and
heads of households).--Subsection (c) of section 1 is amended
by striking the table and inserting the following:
``If taxable income is: The tax is:
Not over $50,000...............
15 percent of taxable income.
Over $50,000 but not over
$250,000.
$7,500, plus 25 percent of the
excess over $250,000.
Over $250,000..................
$57,500, plus 28 percent of the
excess over
$250,000.''.
(4) Married individuals filing separate returns.--
Subsection (d) of section 1 is amended by striking the table
and inserting the following:
``If taxable income is: The tax is:
Not over $50,000...............
15 percent of taxable income.
Over $50,000 but not over
$250,000.
$7,500, plus 25 percent of the
excess over $250,000.
Over $250,000..................
$57,500, plus 28 percent of the
excess over
$250,000.''.
(5) Conforming amendments.--Section 1 is amended by
striking subsections (i) and (j).
(b) Inflation Adjustments Applied Based on CPI.--Paragraph (3) of
section 1(f) is amended to read as follows:
``(3) Cost-of-living adjustment.--For purposes of this
subsection--
``(A) In general.--The cost-of-living adjustment
for any calendar year is the percentage (if any) by
which--
``(i) the CPI for the preceding calendar
year, exceeds
``(ii) the CPI for calendar year 2016,
multiplied by the amount determined under
subparagraph (B).
``(B) Amount determined.--The amount determined
under this subparagraph is the product of--
``(i) the amount obtained by dividing--
``(I) the C-CPI-U for calendar year
2016, by
``(II) the CPI for calendar year
2016, and
``(ii) the amount obtained by dividing--
``(I) the CPI for calendar year
2021, by
``(II) the C-CPI-U for calendar
year 2021.
``(C) Special rule for adjustments with a base
years after 2016.--
``(i) Base years after 2021.--For purposes
of any provision of this title which provides
for the substitution of a year after 2021 for
`2016' in subparagraph (A)(ii), such
subparagraph shall be applied without regard to
`, multiplied by the amount determined under
subparagraph (B)'.
``(ii) Base years after 2016 and before
2022.--For purposes of any provision of this
title which provides for the substitution of a
year after 2016 and before 2021 for `2016' in
subparagraph (A)(ii)--
``(I) subparagraph (A)(ii) shall be
applied by substituting `C-CPI-U' for
`CPI', and
``(II) the amount determined under
subparagraph (B) shall be the amount
obtained by dividing--
``(aa) the CPI for calendar
year 2021, by
``(bb) the C-CPI-U for
calendar year 2021.''.
(c) Conforming Amendments Related to Rate Changes.--
(1) In general.--Paragraph (3) of section 1(f) is amended
by inserting ``, except as provided in paragraph (7),'' after
``for any calendar year''.
(2) Updated cost-of-living adjustment for new rates.--
Section 1(f) is amended by striking paragraphs (8) and
inserting the following:
``(8) Cost-of-living adjustment for years after 2021.--
``(A) Calendar year 2022.--In prescribing the
tables under paragraph (1) which apply in lieu of the
tables contained in subsections (a), (b), (c), and (d)
with respect to taxable years beginning in calendar
year 2022, the Secretary shall make no adjustment to
the dollar amounts in any such table.
``(B) Later calendar years.--In prescribing tables
under paragraph (1) which apply in lieu of the tables
contained in subsections (a), (b), (c), and (d) with
respect to taxable years beginning after December 31,
2022, the cost-of-living adjustment used in making
adjustments to the dollar amounts in such tables shall
be determined under paragraph (3) by substituting
`2021' for `2016' in subparagraph (A)(ii) thereof.''.
(3) Other conforming amendments.--
(A) Paragraph (2) of section 1(f) is amended--
(i) by striking ``paragraph (8)'' in
subparagraph (A) and inserting ``paragraph
(7)(A)'', and
(ii) by striking ``by adjusting'' in
subparagraph (C) and inserting ``except as
provided in paragraph (7)(A), by adjusting''.
(B) The heading of subsection (f) of section 1 is
amended by striking ``Phaseout of Marriage Penalty in
15-Percent Bracket; Adjustments'' and inserting
``Adjustments''.
(d) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2021.
SEC. 202. FAMILY ALLOWANCE AMOUNTS; REPEAL OF PERSONAL EXEMPTION
DEDUCTION.
(a) Family Allowance Amount.--
(1) In general.--Section 63 is amended to read as follows:
``SEC. 63. TAXABLE INCOME DEFINED.
``(a) In General.--For purposes of this subtitle, the term `taxable
income' means adjusted gross income minus--
``(1) the deductions allowed by this chapter (other than
those taken into account in determining adjusted gross income),
and
``(2) the family allowance amount.
``(b) Family Allowance Amount.--For purposes of this subtitle--
``(1) In general.--The family allowance amount with respect
to a taxpayer shall be determined in accordance with the
following table:
The family
``If the taxpayer is: allowance
amount is:
Single or married filing separately............... $50,000
Married filing jointly or a surviving spouse...... $100,000
A head of a household............................. $75,000.
``(2) Definitions.--For purposes of this subsection--
``(A) the term `single or married filing
separately' means a taxpayer to whom subsection (c) or
(d) of section 1 applies,
``(B) the term `married filing jointly or a
surviving spouse' means a taxpayer to whom subsection
(a) of section 1 applies, and
``(C) the term `head of a household' means a
taxpayer to whom subsection (b) of section 1 applies.
``(3) Adjustment for inflation.--In the case of any taxable
year beginning after 2022, each of the dollar amounts in the
table under paragraph (1) shall be increased by an amount equal
to--
``(A) such dollar amount, multiplied by
``(B) the cost-of-living adjustment determined
under section 1(f)(3) for the calendar year in which
the taxable year begins, by substituting `2021' for
`2016' in subparagraph (A)(ii) thereof.
``(c) Cross References.--
``(1) For deductions of estates and trusts in lieu of the
family allowance amount, see section 642(b).
``(2) For calculation of family allowance relating to
nonresident aliens, see section 873(b)(3).
``(3) For determination of marital status, see section
7703.''.
(2) Application of family allowance to certain rules.--
(A) Source rules.--
(i) Section 861(b) is amended by striking
``the standard deduction'' and inserting ``the
family allowance''.
(ii) Section 862(b) is amended by striking
``the standard deduction'' and inserting ``the
family allowance''.
(B) Threshold for requirement to make return.--
(i) Section 6012(a)(1) is amended to read
as follows:
``(1)(A) Every individual--
``(i) having for the taxable year gross income
which equals or exceeds the family allowance amount
applicable to the individual under section 63, or
``(ii) in the case of individuals entitled to make
a joint return (but only if the individual and the
individual's spouse had the same household as their
home at the close of the taxable year), every
individual whose gross income, when combined with the
gross income of the individual's spouse, equals or
exceeds the family allowance amount applicable to
taxpayers who are married filing jointly under section
63.
``(B) Every individual not described in subparagraph (A)
who is taken into account as a dependent by another taxpayer
under section 7706 for purposes of any provision of this title,
but only if such individual's gross income, when combined with
the gross income of all individuals taken into account in
determining the family allowance amount under section 63(b) of
the taxpayer, equals or exceeds the family allowance amount
applicable to the taxpayer under such section.''.
(ii) Section 6012(a)(8) is amended by
striking ``is not less than the sum of the
exemption amount plus the basic standard
deduction under section 63(c)(2)(D)'' and
inserting ``equals or exceeds the family
allowance amount applicable to the estate under
section 1398(c)(3)''.
(iii) Section 6012 is amended by striking
subsection (f).
(C) Other rules.--
(i) Section 1398(c) is amended--
(I) by striking paragraph (3) and
inserting the following:
``(3) Family allowance amount.--The family allowance amount
under section 63(b) taken into account for the estate for the
taxable year shall be the same as for a taxpayer who is single
or married filing separately.'', and
(II) by striking ``Basic Standard
Deduction'' in the heading and
inserting ``Family Allowance Amount''.
(ii) Section 6014 is amended--
(I) by striking ``who dos not
itemize his deductions and who is not
described in section 6012(a)(1)(C)(i)''
in subsection (a) and inserting ``who
is not described in section
6012(a)(1)(B)'', and
(II) by striking subsection (b)(4)
and inserting the following:
``(4) to cases where the taxpayer claims deductions in
addition to the family allowance.''.
(b) Permanent Repeal of Deduction for Personal Exemptions.--
(1) In general.--Part V of subchapter B of chapter 1 is
hereby repealed.
(2) Definition of dependent retained.--
(A) In general.--Section 152, prior to the repeal
made by subsection (a), is hereby redesignated as
section 7706 and moved to the end of chapter 79.
(B) Identifying information required to treat
individual as dependent.--Section 7706, as redesignated
by subparagraph (A), is amended by adding at the end
the following new subsection:
``(g) Identifying Information Required.--No individual shall be
treated as a dependent of the taxpayer under this section for a taxable
year unless the taxpayer includes the TIN of such individual on the
return of tax for the taxable year.''.
(3) Application of repeal to certain rules.--
(A) Determination of dependent.--Section 7706, as
redesignated by subparagraph (A), is amended--
(i) in subsection (d)--
(I) by striking ``the exemption
amount (as defined in section 151(d))''
in subparagraph (1)(B) and inserting
``$4,150'', and
(II) by adding at the end the
following new paragraph:
``(6) Inflation adjustment.--In the case of any taxable
year beginning in a calendar year beginning after 2018, the
$4,150 amount in paragraph (1)(B) shall be increased by an
amount equal to--
``(A) such dollar amount, multiplied by
``(B) the cost-of-living adjustment determined
under section 1(c)(2)(A) for the calendar year in which
such taxable year begins, determined by substituting
`calendar year 2017' for `calendar year 2016' in clause
(ii) thereof.'', and
(ii) in subsection (f)(6)(B)(i), by
striking ``the deduction under section 151(c)''
and inserting ``the family allowance amount
under section 63(b)''.
(B) Net operating loss.--Section 172(d)(3) is
amended to read as follows:
``(3) Family allowance amount.--Taxable income under
section 63 shall be determined without regard to paragraph (2)
of section 63(a), relating to the family allowance amount. No
deduction in lieu of such family allowance amount shall be
allowed.''.
(C) Short taxable years.--
(i) Section 443(c) is amended--
(I) by striking ``the exemptions
allowed as a deduction under section
151 (and any deduction in lieu thereof)
shall be reduced to amounts which bear
the same ratio to the full exemptions''
and inserting ``the family allowance
amount under section 63 (and any
deduction in lieu thereof) shall be
reduced to an amount which bears the
same ratio to the full family allowance
amount'', and
(II) by striking ``Deduction for
Personal Exemptions'' in the heading
and inserting ``Family Allowance
Amount''.
(ii) Section 441(f)(2)(B)(iii) is amended
by striking ``of the deductions for personal
exemptions as described in section 443(c)'' and
inserting ``of the family allowance amount''.
(D) Application to trusts and estates.--
(i) Section 642(b)(2)(C) is amended--
(I) by striking ``the exemption
amount under section 151(d)'' in clause
(i) and inserting ``the dollar amount
in effect under section
7706(d)(1)(B)'', and
(II) by striking clause (iii).
(ii) Section 642(b)(3) is amended--
(I) by striking ``the deductions
allowed under section 151 (relating to
deduction for personal exemption)'' and
inserting ``the family allowance
amount'', and
(II) by striking ``personal
exemption'' in the heading and
inserting ``family allowance amount''.
(E) Partnership computations.--Section 703(a) is
amended--
(i) by striking ``and'' at the end of
paragraph (1),
(ii) by striking subparagraph (A) of
paragraph (2) and by redesignating
subparagraphs (B), (C), (D), (E), and (F) of
such paragraph as subparagraphs (A), (B), (C),
(D), and (E),
(iii) by striking the period at the end of
paragraph (2)(F) and inserting ``, and'', and
(iv) by adding at the end the following new
paragraph:
``(3) taxable income under section 63 shall be determined
without regard to the family allowance amount.''.
(F) Nonresident aliens.--
(i) Section 873(b) is amended--
(I) by striking ``deductions'' in
the matter preceding paragraph (1), and
(II) by striking paragraph (3) and
inserting the following:
``(3) Family allowance amount.--The family allowance amount
under section 63(a)(2), except that the taxpayer shall be
treated for purposes of section 63(b) as single or married
filing separately unless the taxpayer is a resident of a
contiguous country or is a national of the United States.''.
(ii)(I) The heading of section 873 is
amended by striking ``deductions'' and
inserting ``deductions and allowances''.
(II) The item relating to section 873 in
the table of sections for subpart A of part II
of subchapter N of chapter 1 is amended to read
as follows:
``Sec. 873. Deductions and allowances.''.
(iii) Section 874(b) is amended by striking
``deduction for exemptions under section 151''
and inserting ``the family allowance amount
under section 63''.
(iv) Section 891 is amended by striking
``deductions allowable under section 151 and
under'' and inserting ``the family allowance
amount under section 63(a)(2) and the
deductions allowable under''.
(G) Foreign tax credit.--Section 904(b)(1) is
amended to read as follows:
``(1) Family allowance and deductions.--For purposes of
subsection (a), the taxable income in the case of an
individual, estate, or trust shall be computed without regard
to the family allowance amount under section 63(a)(2) or any
deduction in lieu of such amount under section 642(b)(3).''.
(H) Treatment of possessions.--
(i) Section 931(b)(1) is amended by
striking ``the deduction under section 151,
relating to personal exemptions'' and inserting
``the family allowance amount under section
63(c)''.
(ii) Section 933 is amended--
(I) by striking ``the deduction
under section 151, relating to personal
exemptions'' in paragraph (1) and
inserting ``the family allowance amount
under section 63(c)'', and
(II) by striking ``the deduction
for personal exemptions under section
151'' in paragraph (2) and inserting
``the family allowance amount under
section 63(c)''.
(I) Capital losses.--Section 1212(b)(2)(B)(ii) is
amended to read as follows:
``(ii) in the case of an estate or trust,
the deduction allowed for such year under
section 642(b).''.
(J) Net earnings from self-employment.--Section
1402(a) is amended by striking paragraph (7).
(K) Payroll withholding.--
(i) In general.--Paragraph (1) of section
3402(f) is amended by striking subparagraph (A)
and all that follows and inserting the
following:
``(A) the family allowance amount; and
``(B) any additional amounts to which the employee
elects to take into account under subsection (m), but
only if the employee's spouse does not have in effect a
withholding allowance certificate claiming such
allowance.''.
(ii) Family allowance exemption amount.--
Subsection (f) of section 3402 is amended--
(I) by redesignating paragraphs
(2), (3), (4), (5), (6), and (7) as
paragraphs (3), (4), (5), (6), (7), and
(8), respectively,
(II) by striking ``paragraph
(2)(C)'' in paragraph (3)(B)(iii) and
inserting ``paragraph (3)(C)'', and
(III) by inserting after paragraph
(1) the following new paragraph:
``(2) Family allowance exemption amount.--For purposes of
this section--
``(A) In general.--Except as provided in
subparagraphs (B) and (C), the term `family allowance
exemption amount' means the family allowance amount
with respect to the taxpayer under section 63(b) for
the taxable year in which the payroll period begins,
prorated to the payroll period.
``(B) Married employees.--If the employee is
married filing jointly and the employee's spouse is an
employee receiving wages, the employee and the
employee's spouse may divide the family allowance
amount determined under section 63(b) in the proportion
of their choice for purposes of this paragraph, but the
sum of the family allowance exemption amounts claimed
by the employee and the employee's spouse shall not
exceed such family allowance amount.
``(C) Employees with more than 1 employer.--In the
case of an employee that has withholding exemption
certificates in effect with respect to more than 1
employer, the employee may divide the family allowance
amount (or the employee's share of such amount after
the application of subparagraph (B), if applicable)
determined under section 63(b) among employers in the
proportion of the employee's choice for purposes of
this paragraph, but the sum of the family allowance
exemption amounts claimed by the employee with respect
to all employers shall not exceed such family allowance
amount (or the employee's share of such amount after
the application of subparagraph (B), if applicable).''.
(iii) Conforming amendments.--
(I) Paragraph (7) of section
3402(f), as redesignated by
subparagraph (B)(i) of this paragraph,
is amended by striking ``shall be
entitled to only one withholding
exemption'' and inserting ``shall be
treated as single or married filing
separately for purposes of determining
the family allowance exemption
amount''.
(II) Paragraph (8) of section
3402(f), as redesignated by
subparagraph (B)(i) of this paragraph,
is amended by inserting ``, except as
provided in paragraph (2)(C)'' after
``with respect to one employer''.
(III) Paragraph (3) of section
3402(m) is amended by striking
``deductions (including the additional
standard deduction under section
63(c)(3) for the aged and blind)'' and
inserting ``deductions''.
(IV) Paragraph (2) of section
3402(r) is amended striking ``the sum
of'' and all that follows and inserting
``the family allowance amount
determined under section 63(b) for a
taxpayer who is single or married
filing separately.''.
(V) Section 6040(4) is amended by
striking ``section 3402(f)(2), (3),
(4), and (5)'' and inserting
``paragraphs (3), (4), (5), and (6) of
section 3402(f)''.
(L) Joint returns.--Section 6013(b)(3)(A) is
amended by striking ``has the meaning given to such
term'' and all that follows and inserting ``means the
family allowance amount applicable to a taxpayer who is
single or married filing separately under section
63(b).''.
(M) Amounts subject to levy.--
(i) Section 6334(d)(2)(A) is amended to
read as follows:
``(A) 50 percent of the family allowance amount
determined under section 63(b) with respect to the
taxpayer for the taxable year in which such levy
occurs, divided by''.
(ii) Section 6334(d) is amended by striking
paragraph (4).
(c) Other Conforming Amendments.--
(1) Section 1(f)(7) is amended--
(A) by striking ``section 63(c)(4), section
68(b)(2) or section 151(d)(4)'' in subparagraph (A) and
inserting ``subsection (g)(4)(B), section 63(b)(3),
section 68(b)(2), or section 7706(d)(6)'', and
(B) by striking ``sections 63(c)(4) and section
151(d)(4)(A)'' in subparagraph (B) and inserting
``sections 63(b)(3) and 7706(d)(6)''.
(2) Section 1(g)(4) is amended--
(A) by striking subparagraph (A)(ii)(I) and
inserting the following:
``(I) $500, plus'', and
(B) by redesignating subparagraphs (B) and (C) as
subparagraphs (C) and (D), respectively, and inserting
after subparagraph (A) the following new subparagraph:
``(B) Adjustment for inflation.--In the case of any
taxable year beginning in a calendar year after 1988,
the $500 amount in subparagraph (A)(ii)(I) shall be
increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment
determined under subsection (f)(3) for the
calendar year in which the taxable year begins,
by substituting `1987' for `2016' in
subparagraph (A)(ii) thereof.''.
(3) Section 1(g)(5)(A) is amended by striking ``section
152(e)'' and inserting ``section 7706(e)''.
(4) Section 2(a)(1)(B) is amended--
(A) by striking ``section 152'' and inserting
``section 7706'', and
(B) by striking ``with respect to whom the taxpayer
is entitled to a deduction for the taxable year under
section 151'' and inserting ``whose TIN is included on
the taxpayer's return of tax for the taxable year''.
(5) Section 2(b)(1)(A)(i) is amended--
(A) in the matter preceding subclause (I)--
(i) by striking ``section 152(c)'' and
inserting ``section 7706(c)'', and
(ii) by striking ``section 152(e)'' and
inserting ``section 7706(e)'', and
(B) in subclause (II), by striking ``section
152(b)(2) or 152(b)(3)'' and inserting ``section
7706(b)(2) or 7706(b)(3)''.
(6) Section 2(b)(1)(A)(ii) is amended by striking ``if the
taxpayer is entitled to a deduction for the taxable year for
such person under section 151'' and inserting ``if the taxpayer
included such person's TIN on the return of tax for the taxable
year''.
(7) Section 2(b)(1)(B) is amended by striking ``if the
taxpayer is entitled to a deduction for the taxable year for
such father or mother under section 151'' and inserting ``if
such father or mother is a dependent of the taxpayer and the
taxpayer included such father or mother's TIN on the return of
tax for the taxable year''.
(8) Section 2(b)(3)(B) is amended--
(A) by striking ``section 152(d)(2)'' in clause (i)
and inserting ``section 7706(d)(2)'', and
(B) by striking ``section 152(d)'' in clause (ii)
and inserting ``section 7706(d)''.
(9) Section 36B(b)(2)(A) is amended by striking ``section
152'' and inserting ``section 7706''.
(10) Section 36B(b)(3)(B) is amended by striking ``unless a
deduction is allowed under section 151 for the taxable year
with respect to a dependent'' in the flush matter at the end
and inserting ``unless the taxpayer has a dependent for the
taxable year (and the taxpayer included such dependent's TIN on
the return of tax for the taxable year)''.
(11) Section 36B(c)(1)(D) is amended by striking ``with
respect to whom a deduction under section 151 is allowable to
another taxpayer'' and inserting ``who is a dependent of
another taxpayer''.
(12) Section 36B(d)(1) is amended by striking ``equal to
the number of individuals for whom the taxpayer is allowed a
deduction under section 151 (relating to allowance of deduction
for personal exemptions) for the taxable year'' and inserting
``the sum of 1 (2 in the case of a joint return) plus the
number of individuals who are dependents of the taxpayer for
the taxable year''.
(13) Section 36B(e)(1) is amended by striking ``1 or more
individuals for whom a taxpayer is allowed a deduction under
section 151 (relating to allowance of deduction for personal
exemptions) for the taxable year (including the taxpayer or his
spouse)'' and inserting ``1 or more of the taxpayer, the
taxpayer's spouse, or any dependent of the taxpayer''.
(14) Section 42(i)(3)(D)(ii)(I) is amended by striking
``section 152'' and inserting ``section 7706''.
(15) Section 45R(e)(1)(A)(iv) is amended--
(A) by striking ``section 152(d)(2)'' and inserting
``section 7706(d)(2)'', and
(B) by striking ``section 152(d)(2)(H)'' and
inserting ``section 7706(d)(2)(H)''.
(16) Section 51(i)(1) is amended--
(A) by striking ``section 152(d)(2)'' in
subparagraphs (A) and (B) and inserting ``section
7706(d)(2)'', and
(B) by striking ``section 152(d)(2)(H)'' in
subparagraph (C) and inserting ``section
7706(d)(2)(H)''.
(17) Section 72(t)(2)(D)(i)(III) is amended by striking
``section 152'' and inserting ``section 7706''.
(18) Section 72(t)(7)(A)(iii) is amended by striking
``section 152(f)(1)'' and inserting ``section 7706(f)(1)''.
(19) Section 105(b) is amended--
(A) by striking ``as defined in section 152'' and
inserting ``as defined in section 7706'',
(B) by striking ``section 152(f)(1)'' and inserting
``section 7706(f)(1)'', and
(C) by striking ``section 152(e)'' and inserting
``section 7706(e)''.
(20) Section 105(c)(1) is amended by striking ``section
152'' and inserting ``section 7706''.
(21) Section 125(e)(1)(D) is amended by striking ``section
152'' and inserting ``section 7706''.
(22) Section 129(c)(1) is amended to read as follows:
``(1) who is a dependent of such employee or of such
employee's spouse, or''.
(23) Section 129(c)(2) is amended by striking ``section
152(f)(1)'' and inserting ``section 7706(f)(1)''.
(24) Section 132(h)(2)(B) is amended--
(A) by striking ``section 152(f)(1)'' and inserting
``section 7706(f)(1)'', and
(B) by striking ``section 152(e)'' and inserting
``section 7706(e)''.
(25) Section 139D(c)(5) is amended by striking ``section
152'' and inserting ``section 7706''.
(26) Section 139E(c)(2) is amended by striking ``section
152'' and inserting ``section 7706''.
(27) Section 162(l)(1)(D) is amended by striking ``section
152(f)(1)'' and inserting ``section 7706(f)(1)''.
(28) Section 170(g)(1) is amended by striking ``section
152'' and inserting ``section 7706''.
(29) Section 170(g)(3) is amended by striking ``section
152(d)(2)'' and inserting ``section 7706(d)(2)''.
(30) Section 213(a) is amended by striking ``section 152''
and inserting ``section 7706''.
(31) Section 213(d)(5) is amended by striking ``section
152(e)'' and inserting ``section 7706(e)''.
(32) Section 213(d)(11) is amended by striking ``section
152(d)(2)'' in the matter following subparagraph (B) and
inserting ``section 7706(d)(2)''.
(33) Section 220(b)(6) is amended by striking ``with
respect to whom a deduction under section 151 is allowable to''
and inserting ``who is a dependent of''.
(34) Section 220(d)(2)(A) is amended by striking ``section
152'' and inserting ``section 7706''.
(35) Section 223(b)(6) is amended by striking ``with
respect to whom a deduction under section 151 is allowable to''
and inserting ``who is a dependent of''.
(36) Section 223(d)(2)(A) is amended by striking ``section
152'' and inserting ``section 7706''.
(37) Section 401(h) is amended by striking ``section
152(f)(1)'' in the last sentence and inserting ``section
7706(f)(1)''.
(38) Section 402(l)(4)(D) is amended by striking ``section
152'' and inserting ``section 7706''.
(39) Section 409A(a)(2)(B)(ii)(I) is amended by striking
``section 152(a)'' and inserting ``section 7706(a)''.
(40) Section 501(c)(9) is amended by striking ``section
152(f)(1)'' and inserting ``section 7706(f)(1)''.
(41) Section 529(e)(2)(B) is amended by striking ``section
152(d)(2)'' and inserting ``section 7706(d)(2)''.
(42) Section 529A(e)(4) is amended--
(A) by striking ``section 152(d)(2)(B)'' and
inserting ``section 7706(d)(2)(B)'', and
(B) by striking ``section 152(f)(1)(B)'' and
inserting ``section 7706(f)(1)(B)''.
(43) Section 643(a)(2) is amended--
(A) by striking ``(relating to deduction for
personal exemptions)'' and inserting ``(relating to
basic deduction)'', and
(B) by striking ``Deduction for personal
exemption'' in the heading thereof and inserting
``Basic deduction''.
(44) Section 1361(c)(1)(C) is amended by striking ``section
152(f)(1)(C)'' and inserting ``section 7706(f)(1)(C)''.
(45) Section 2032A(c)(7)(D) is amended by striking
``section 152(f)(2)'' and inserting ``section 7706(f)(2)''.
(46) Section 5000A(b)(3)(A) is amended by striking
``section 152'' and inserting ``section 7706''.
(47) Section 5000A(c)(4)(A) is amended by striking ``the
number of individuals for whom the taxpayer is allowed a
deduction under section 151 (relating to allowance of deduction
for personal exemptions) for the taxable year'' and inserting
``the sum of 1 (2 in the case of a joint return) plus the
number of the taxpayer's dependents for the taxable year''.
(48) Section 6103(l)(21)(A)(iii) is amended by striking
``for whom a deduction is allowed under section 151'' and
inserting ``who is taken into account as a dependent under
section 7706 for purposes of any provision of this title''.
(49) Section 6213(g)(2)(H) is amended by striking ``section
21 (relating to expenses for household and dependent care
services necessary for gainful employment) or section 151
(relating to allowance of deductions for personal exemptions)''
and inserting ``subsection (a)(1)(B), (b)(1)(A)(ii), or
(b)(1)(B) of section 2 or section 36B(b)(3)(B)''.
(50) Section 7702B(f)(2)(C)(iii) is amended by striking
``section 152(d)(2)'' and inserting ``section 7706(d)(2)''.
(51) Section 7703(a) is amended by striking ``part V of
subchapter B of chapter 1 and''.
(52) Section 7703(b)(1) is amended by striking ``section
152(f)(1))'' and all that follows and inserting ``section
7706(f)(1)) who is a dependent of such individual for the
taxable year (or would be but for section 7706(e)),''.
(53) Section 7706(a), as redesignated by this section, is
amended by striking ``this subtitle'' and inserting ``subtitle
A''.
(54) Section 7706(e)(3), as redesignated by this section,
is amended by inserting ``(as in effect before its repeal)''
after ``section 151''.
(55) The table of parts for subchapter B of chapter 1 is
amended by striking the item relating to part V.
(56) The table of sections for chapter 79 is amended by
adding at the end the following new item:
``Sec. 7706. Dependent defined.''.
(d) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2021.
SEC. 203. REPEAL OF LIMITATIONS RELATING TO ITEMIZED DEDUCTIONS.
(a) In General.--Sections 67 and 68 are repealed.
(b) Conforming Amendments.--
(1) Section 162(o) is amended by striking paragraph (2) and
redesignating paragraph (3) as paragraph (2).
(2) Section 164(b)(5)(H)(ii) is amended--
(A) by striking the comma at the end of subclause
(I) and inserting ``, and'',
(B) by striking ``, and'' at the end of subclause
(II) and inserting a period, and
(C) by striking subclause (III).
(3) Section 302(b)(5) is amended by inserting ``, as in
effect on December 31, 2021'' after ``67(c)(2)(B)''.
(4) Section 562(c) is amended by inserting ``, as in effect
on December 31, 2021'' after ``67(c)(2)(B)''.
(5) Section 642(b)(2)(C)(i)(II) is amended by inserting ``,
and as in effect on December 31, 2021'' after ``642(b)''.
(6) Section 6654(d)(1)(C)(iii) is amended by inserting ``,
as in effect on December 31, 2021'' before the period.
(c) Effective Date.--The repeal and the amendments made by this
section shall apply to taxable years beginning after December 31, 2021.
SEC. 204. RESTORATION OF CERTAIN DEDUCTIONS.
(a) Deduction for Qualified Residence Interest.--Section 163(h)(3)
is amended by striking subparagraph (F).
(b) Deduction for State and Local Taxes.--Section 164(b) is amended
by striking paragraph (6).
(c) Deduction for Personal Casualty Losses.--Section 165(h) is
amended by striking paragraph (5).
(d) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2021.
SEC. 205. TERMINATION OF SEPARATE TREATMENT OF CAPITAL GAINS.
Subsection (h) of section 1 is amended by adding at the end the
following new paragraph:
``(12) Termination.--This subsection shall not apply to any
taxable year beginning after December 31, 2021.''.
SEC. 206. REPEALS.
(a) In General.--The following provisions of the Internal Revenue
Code of 1986 are repealed:
(1) Subpart A of part IV of subchapter A of chapter 1
(relating to nonrefundable personal credits).
(2) Subpart B of part IV of subchapter A of chapter 1
(relating to other credits), other than section 27 (relating to
taxes of foreign countries and possessions of the United
States; possession tax credit).
(3) Sections 34, 35, and 36.
(4) Part VI of subchapter A of chapter 1 (relating to
alternative minimum tax).
(5) Section 199A (relating to deduction for qualified
business income).
(6) Section 217 (relating to moving expenses).
(7) Section 221 (relating to interest on education loans).
(8) Section 222 (relating to qualified tuition and related
expenses).
(9) Chapter 2A (relating to unearned income medicare
contribution).
(b) Effective Date.--The repeals made by subsection (a) shall take
effect for taxable years beginning after December 31, 2021.
SEC. 207. ESTABLISHMENT OF PROGRESSIVE TAX REBATE.
(a) In General.--Section 32 is amended to read as follows:
``SEC. 32. PROGRESSIVE TAX REBATE.
``(a) Allowance of Credit.--In the case of an eligible taxpayer,
there shall be allowed as a credit against the tax imposed by this
subtitle for the taxable year an amount equal to the sum of--
``(1) the earned income amount (as determined under
subsection (b)),
``(2) the child benefit amount (as determined under
subsection (c)), plus
``(3) the additional child benefit amount (as determined
under subsection (d)).
``(b) Earned Income Amount.--
``(1) Single workers.--In the case of an eligible taxpayer
(other than a head of a household as defined in section 2(b))
who is not filing a joint return for the taxable year under
section 6013, the earned income amount shall be equal to--
``(A) in the case of a taxpayer whose earned income
for the taxable year does not exceed $6,100, 25.1
percent of such earned income,
``(B) in the case of a taxpayer whose earned income
for the taxable year exceeds $6,100 but does not exceed
$9,000, $1,530 plus 17.1 percent of such earned income
in excess of $6,100,
``(C) in the case of a taxpayer whose earned income
(or, if greater, adjusted gross income) for the taxable
year exceeds $9,000, but does not exceed $49,494,
$2,025 minus 5 percent of such earned income or
adjusted gross income in excess of $9,000, or
``(D) in the case of a taxpayer whose earned income
(or, if greater, adjusted gross income) for the taxable
year exceeds $49,494, $0.
``(2) Head of household.--In the case of an eligible
taxpayer who is a head of a household (as defined in section
2(b)), the earned income amount shall be equal to--
``(A) in the case of a taxpayer whose earned income
for the taxable year does not exceed $9,150, 25.1
percent of such earned income,
``(B) in the case of a taxpayer whose earned income
for the taxable year exceeds $9,150 but does not exceed
$13,500, $2,294 plus 17.1 percent of such earned income
in excess of $9,150,
``(C) in the case of a taxpayer whose earned income
(or, if greater, adjusted gross income) for the taxable
year exceeds $13,500, but does not exceed $74,241,
$3,037 minus 5 percent of such earned income or
adjusted gross income in excess of $13,500, or
``(D) in the case of a taxpayer whose earned income
(or, if greater, adjusted gross income) for the taxable
year exceeds $74,241, $0.
``(3) Married filing jointly.--In the case of an eligible
taxpayer filing a joint return under section 6013, the earned
income amount shall be determined pursuant to paragraph (1),
except that the dollar amounts in effect under such paragraph
shall be multiplied by 2.
``(c) Child Benefit Amount.--
``(1) In general.--In the case of an eligible taxpayer with
a qualifying child, the child benefit amount shall be equal to
15 percent of the earned income of such taxpayer for the
taxable year.
``(2) Limitations.--
``(A) Limitation based on number of children.--The
child benefit amount determined under paragraph (1)
shall not exceed an amount equal to the product of--
``(i) the number of qualifying children of
the taxpayer, multiplied by
``(ii) $1,590.
``(B) Reduction based on earnings or adjusted gross
income.--The child benefit amount determined under this
subsection (as determined after application of
subparagraph (A)) shall be reduced (but not below zero)
by an amount equal to 5 percent of the earned income
(or, if greater, the adjusted gross income) of the
taxpayer for the taxable year in excess of $75,000
($110,000 in the case of a joint return).
``(d) Additional Child Benefit Amount.--
``(1) In general.--In the case of an eligible taxpayer with
a qualifying child, the additional child benefit amount shall
be equal to--
``(A) in the case of a taxpayer whose earned income
for the taxable year does not exceed $20,000, the
applicable percentage of such earned income,
``(B) in the case of a taxpayer whose earned income
exceeds $20,000 but does not exceed $25,000, the
applicable percentage of $20,000,
``(C) in the case of a taxpayer whose earned income
(or, if greater, adjusted gross income) exceeds $25,000
but does not exceed the applicable amount, an amount
equal to--
``(i) the applicable percentage of $20,000,
minus
``(ii) 15 percent of such earned income or
adjusted gross income in excess of $25,000, or
``(D) in the case of a taxpayer whose earned income
(or, if greater, adjusted gross income) exceeds the
applicable amount, $0.
``(2) Applicable percentage.--For purposes of paragraph
(1), the applicable percentage is--
``(A) in the case of a taxpayer with 1 qualifying
child, 11 percent,
``(B) in the case of a taxpayer with 2 qualifying
children, 17 percent, and
``(C) in the case of a taxpayer with 3 or more
qualifying children, 19 percent.
``(3) Applicable amount.--For purposes of paragraph (1),
the applicable amount is--
``(A) in the case of a taxpayer with 1 qualifying
child, $39,667,
``(B) in the case of a taxpayer with 2 qualifying
children, $47,667, and
``(C) in the case of a taxpayer with 3 or more
qualifying children, $50,333.
``(e) Eligible Taxpayer.--
``(1) In general.--The term `eligible taxpayer' means an
individual--
``(A) whose principal place of abode is in the
United States for more than one-half of such taxable
year, and
``(B) is not a dependent (as defined under section
152) to another taxpayer for any taxable year beginning
in the same calendar year as such taxable year.
``(2) Qualifying child ineligible.--If an individual is the
qualifying child of a taxpayer for any taxable year of such
taxpayer beginning in a calendar year, such individual shall
not be treated as an eligible taxpayer for any taxable year of
such individual beginning in such calendar year.
``(3) Exception for taxpayer claiming benefits under
section 911.--The term `eligible taxpayer' does not include any
taxpayer who claims the benefits of section 911 for the taxable
year.
``(4) Limitation on eligibility of nonresident aliens.--The
term `eligible taxpayer' shall not include any individual who
is a nonresident alien individual for any portion of the
taxable year unless such individual is treated for such taxable
year as a resident of the United States for purposes of this
chapter by reason of an election under subsection (g) or (h) of
section 6013.
``(5) Identification number requirement.--No credit shall
be allowed under this section to an eligible taxpayer who does
not include on the return of tax for the taxable year--
``(A) such individual's taxpayer identification
number, and
``(B) if the individual is married (within the
meaning of section 7703), the taxpayer identification
number of such individual's spouse.
``(6) Taxpayers who do not include tin, etc., of any
qualifying child.--No credit shall be allowed under this
section to any eligible taxpayer who has one or more qualifying
children if no qualifying child of such taxpayer is taken into
account under subsection (c) or (d) by reason of subsection
(f)(4).
``(7) Treatment of military personnel stationed outside of
the united states.--For purposes of paragraph (1)(A) and
subsection (f)(3), the principal place of abode of a member of
the Armed Forces of the United States shall be treated as in
the United States during any period during which such member is
stationed outside the United States while serving on extended
active duty with the Armed Forces of the United States. For
purposes of the preceding sentence, the term `extended active
duty' means any period of active duty pursuant to a call or
order to such duty for a period in excess of 90 days or for an
indefinite period.
``(8) Joint return.--
``(A) Married individuals.--In the case of an
individual who is married (within the meaning of
section 7703), this section shall apply only if a joint
return is filed for the taxable year under section
6013.
``(B) Other.--In the case of taxpayer filing a
joint return under section 6013, such taxpayer shall
not be treated as an eligible taxpayer for purposes of
this section unless either the taxpayer or the
taxpayer's spouse satisfies each of the requirements
under this subsection.
``(f) Qualifying Child.--
``(1) In general.--The term `qualifying child' means a
qualifying child of the taxpayer (as defined in section 152(c),
determined without regard to paragraph (1)(D) thereof and
section 152(e)).
``(2) Married individual.--The term `qualifying child'
shall not include an individual who is married as of the close
of the eligible taxpayer's taxable year unless the individual
qualifies as a dependent (as defined under section 152) of the
taxpayer for such taxable year.
``(3) Place of abode.--For purposes of paragraph (1), the
requirements of section 152(c)(1)(B) shall be met only if the
principal place of abode is in the United States.
``(4) Identification requirements.--
``(A) In general.--A qualifying child shall not be
taken into account under subsection (c) or (d) unless
the taxpayer includes the name, age, and TIN of the
qualifying child on the return of tax for the taxable
year.
``(B) Other methods.--The Secretary may prescribe
other methods for providing the information described
in subparagraph (A).
``(g) Earned Income.--
``(1) In general.--The term `earned income' means--
``(A) wages, salaries, tips, and other employee
compensation, but only if such amounts are includible
in gross income for the taxable year, plus
``(B) the amount of the taxpayer's net earnings
from self-employment for the taxable year (within the
meaning of section 1402(a)), but such net earnings
shall be determined with regard to the deduction
allowed to the taxpayer by section 164(f).
``(2) Special rules.--For purposes of paragraph (1)--
``(A) no amount received as a pension or annuity
shall be taken into account,
``(B) no amount to which section 871(a) applies
(relating to income of nonresident alien individuals
not connected with United States business) shall be
taken into account,
``(C) no amount received for services provided by
an individual while the individual is an inmate at a
penal institution shall be taken into account,
``(D) no amount described in paragraph (1) received
for service performed in work activities as defined in
paragraph (4) or (7) of section 407(d) of the Social
Security Act to which the taxpayer is assigned under
any State program under part A of title IV of such Act
shall be taken into account, but only to the extent
such amount is subsidized under such State program, and
``(E) a taxpayer may elect to treat amounts
excluded from gross income by reason of section 112 as
earned income.
``(h) Taxable Year Must Be Full Taxable Year.--Except in the case
of a taxable year closed by reason of the death of the eligible
taxpayer, no credit shall be allowable under this section in the case
of a taxable year covering a period of less than 12 months.
``(i) Coordination With Certain Means-Tested Programs.--For
purposes of--
``(1) the United States Housing Act of 1937,
``(2) title V of the Housing Act of 1949,
``(3) section 101 of the Housing and Urban Development Act
of 1965,
``(4) sections 221(d)(3), 235, and 236 of the National
Housing Act, and
``(5) the Food and Nutrition Act of 2008,
any refund made to a taxpayer by reason of this section shall not be
treated as income (and shall not be taken into account in determining
resources for the month of its receipt and the following month).
``(j) Amount of Credit To Be Determined Under Tables.--The amount
of the credit allowed by this section shall be determined under tables
prescribed by the Secretary.
``(k) Denial of Credit for Individuals Having Excessive Investment
Income.--
``(1) In general.--No credit shall be allowed under
subsection (a) for the taxable year if the aggregate amount of
disqualified income of the taxpayer for the taxable year
exceeds $5,000.
``(2) Disqualified income.--For purposes of paragraph (1),
the term `disqualified income' means--
``(A) interest or dividends to the extent
includible in income for the taxable year,
``(B) interest received or accrued during the
taxable year which is exempt from tax imposed by this
chapter,
``(C) the excess (if any) of--
``(i) gross income from rents or royalties
not derived in the ordinary course of a trade
or business, over
``(ii) the sum of--
``(I) the deductions (other than
interest) which are clearly and
directly allocable to such gross
income, plus
``(II) interest deductions properly
allocable to such gross income,
``(D) the capital gain net income (as defined in
section 1222) of the taxpayer for such taxable year,
and
``(E) the excess (if any) of--
``(i) the aggregate income from all passive
activities for the taxable year (determined
without regard to any amount included in earned
income under subsection (f) or described in a
preceding subparagraph), over
``(ii) the aggregate losses from all
passive activities for the taxable year (as so
determined).
``(3) Passive activity.--For purposes of paragraph (2)(E),
the term `passive activity' has the meaning given such term by
section 469.
``(l) Inflation Adjustments.--
``(1) In general.--In the case of any taxable year
beginning after 2022, each of the dollar amounts in subsections
(b), (c), (d), and (j)(1) shall each be increased by an amount
equal to--
``(A) such dollar amount, multiplied by
``(B) the cost-of-living adjustment determined
under section 1(f)(3) for the calendar year in which
the taxable year begins, determined by substituting
`2021' for `2016' in subparagraph (A)(ii) thereof.
``(2) Rounding.--If any dollar amount in subsections (b),
(c), (d), and (j)(1), after being increased under paragraph
(1), is not a multiple of $100, such dollar amount shall be
rounded to the nearest multiple of $100.
``(m) Restrictions on Taxpayers Who Improperly Claimed Credit in
Prior Year.--
``(1) Taxpayers making prior fraudulent or reckless
claims.--
``(A) In general.--No credit shall be allowed under
this section for any taxable year in the disallowance
period.
``(B) Disallowance period.--For purposes of
subparagraph (A), the disallowance period is--
``(i) the period of 10 taxable years after
the most recent taxable year for which there
was a final determination that the taxpayer's
claim of credit under this section was due to
fraud, and
``(ii) the period of 2 taxable years after
the most recent taxable year for which there
was a final determination that the taxpayer's
claim of credit under this section was due to
reckless or intentional disregard of rules and
regulations (but not due to fraud).
``(2) Taxpayers making improper prior claims.--In the case
of a taxpayer who is denied credit under this section for any
taxable year as a result of the deficiency procedures under
subchapter B of chapter 63, no credit shall be allowed under
this section for any subsequent taxable year unless the
taxpayer provides such information as the Secretary may require
to demonstrate eligibility for such credit.''.
(b) Conforming Amendments.--
(1) Section 86(f)(2) is amended by striking ``section
32(c)(2)'' and inserting ``section 32(g)''.
(2) Section 129(e)(2) is amended by striking ``section
32(c)(2)'' and inserting ``section 32(g)''.
(3) Section 6213(g)(2) is amended--
(A) in subparagraph (G), by striking ``section
32(c)(2)(A)'' and inserting ``section 32(g)(1)'', and
(B) in subparagraph (K), by striking ``section
32(k)(2)'' and inserting ``section 32(m)(2)''.
(4) Paragraph (2) of section 1324(b) of title 31, United
States Code, is amended by inserting ``32,'' after ``25A,''.
(5) The table of sections for subpart C of part IV of
subchapter A of chapter 1 of subtitle A is amended by striking
the item relating to section 32 and inserting the following:
``Sec. 32. Progressive tax rebate.''.
(c) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2021.
SEC. 208. TECHNICAL AND CONFORMING AMENDMENTS.
The Secretary of the Treasury or the Secretary's delegate shall,
not later than 90 days after the date of the enactment of this Act,
submit to the Committee on Ways and Means of the House of
Representatives and the Committee on Finance of the Senate a draft of
any technical and conforming changes in the Internal Revenue Code of
1986 which are necessary to reflect throughout such Code the purposes
of the provisions of, and amendments made by, this title.
Subtitle B--Corporate Tax Reforms
SEC. 211. CORPORATE INCOME TAX RATE REDUCTION.
(a) In General.--Subsection (b) of section 11 is amended to read as
follows:
``(b) Amount of Tax.--The amount of the tax imposed by subsection
(a) shall be an amount equal to 17 percent of the taxable income.''.
(b) Conforming Amendment.--Section 1551 is amended--
(1) by striking ``benefits of the graduated corporate rates
and'' in the heading,
(2) by striking ``the benefits of the rates contained in
section 11(b) which are lower than the highest rate specified
in such section, or'' in subsection (a), and
(3) by striking ``such benefits or credit'' in subsection
(a) and inserting ``such credit''.
(c) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2021.
TITLE III--REFUND OF EXCESS CONSUMPTION TAX REVENUE
SEC. 301. REFUNDS OF EXCESS CONSUMPTION TAX REVENUE.
(a) In General.--Subchapter B of chapter 65 is amended by adding at
the end the following new section:
``SEC. 6433. REFUNDS OF EXCESS CONSUMPTION TAX REVENUE.
``(a) In General.--In the case of any qualifying excess consumption
tax revenue year, the Secretary shall pay to each eligible filer an
amount equal to the consumption tax refund amount.
``(b) Qualifying Excess Consumption Tax Revenue Year.--For purposes
of this section--
``(1) In general.--The term `qualifying excess consumption
tax revenue year' means any calendar year for which the net
consumption tax revenues exceed 10 percent of gross domestic
product for such year.
``(2) Net consumption tax revenues.--The net consumption
tax revenues for any calendar year shall be the excess of--
``(A) the tax imposed under section 3901 with
respect to taxable supplies the tax point for which is
during such calendar year, over
``(B) the credits allowed under section 3916 for
such calendar year.
``(3) Gross domestic product.--The gross domestic product
for any calendar year shall be the last estimate of the gross
domestic product for such calendar year by the Department of
Commerce which is published before the date that is 3 months
after the close of such calendar year.
``(c) Eligible Filer.--For purposes of this section--
``(1) Definition.--
``(A) In general.--The term `eligible filer' means,
with respect to any qualifying excess consumption tax
revenue year, any individual (other than an individual
described in paragraph (2)) who filed a return of
income tax for the individual's qualifying rebate
taxable year.
``(B) Exclusion.--The term `eligible filer' shall
not include--
``(i) any nonresident alien individual,
``(ii) any individual who is a dependent
(as defined in section 152) of another taxpayer
for the individual's qualifying rebate taxable
year, or
``(iii) an estate or trust.
``(2) Qualifying rebate taxable year.--The term `qualifying
rebate taxable year' means, with respect to any individual in
connection with a qualifying excess consumption tax revenue
year, the taxable year of such individual which contains 6 or
more months of such qualifying excess consumption tax revenue
year.
``(3) Identification requirement.--
``(A) In general.--An individual shall not be
treated as an eligible filer for any year unless such
individual includes on the return of tax for such
year--
``(i) such individual's valid
identification number,
``(ii) in the case of a joint return, the
valid identification number of such
individual's spouse, and
``(iii) the valid identification number of
any qualifying child (as defined in section
32(f)) claimed on such return.
``(B) Valid identification number.--For purposes of
subparagraph (A), the term `valid identification
number' means a social security number issued to an
individual by the Social Security Administration. Such
term shall not include a TIN issued by the Internal
Revenue Service.
``(C) Special rule for members of the armed
forces.--Subparagraph (A) shall not apply to a joint
return where at least 1 spouse was a member of the
Armed Forces of the United States at any time during
the taxable year.
``(d) Consumption Tax Refund Amount.--
``(1) In general.--The consumption tax refund amount for
any eligible filer for any qualifying excess consumption tax
year shall be the product of--
``(A) the applicable amount, times
``(B) the applicable shares of the eligible filer.
``(2) Applicable amount.--The applicable amount for any
qualifying excess revenue consumption tax year is an amount
equal to--
``(A) the excess described in subsection (b)(1),
divided by
``(B) the total number of applicable shares of all
eligible filers for such year.
``(3) Applicable share.--The number of applicable shares
for any eligible filer shall be the sum of--
``(A) 1 (2 in the case of a joint return), plus
``(B) \1/2\ of the number of qualifying children
(as defined in section 32(f)) claimed on the eligible
filer's return for the filer's qualifying rebate
taxable year.
``(e) Time for Payment.--Payments under subsection (a) shall be
made as soon as practical after the Secretary has determined the
consumption tax refund amount.''.
(b) Conforming Amendments.--
(1) Section 1324(b)(2) of title 31, United States Code, is
amended by striking ``or 6431'' and inserting ``6431, or
6433''.
(2) The table of sections for subchapter B of chapter 65 is
amended by adding at the end the following new item:
``Sec. 6433. Refunds of excess consumption tax revenue.''.
(c) Effective Date.--The amendments made by this section shall
apply to calendar years beginning after the date of the enactment of
this Act.
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