[Congressional Record Volume 161, Number 118 (Sunday, July 26, 2015)]
[Senate]
[Page S5740]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 2413. Mr. REED (for himself and Mr. Brown) submitted an amendment 
intended to be proposed by him to the bill H.R. 22, to amend the 
Internal Revenue Code of 1986 to exempt employees with health coverage 
under TRICARE or the Veterans Administration from being taken into 
account for purposes of determining the employers to which the employer 
mandate applies under the Patient Protection and Affordable Care Act; 
which was ordered to lie on the table; as follows:

       Strike title LII and insert the following:

                           TITLE LII--OFFSETS

     SEC. 52101. EXPANSION OF DENIAL OF DEDUCTION FOR CERTAIN 
                   EXCESSIVE EMPLOYEE REMUNERATION.

       (a) Application to All Current and Former Employees.--
       (1) In general.--Section 162(m) of the Internal Revenue 
     Code of 1986 is amended--
       (A) by striking ``covered employee'' each place it appears 
     in paragraphs (1) and (4) and inserting ``covered 
     individual'', and
       (B) by striking ``such employee'' each place it appears in 
     subparagraphs (A) and (G) of paragraph (4) and inserting 
     ``such individual''.
       (2) Covered individual.--Paragraph (3) of section 162(m) of 
     such Code is amended to read as follows:
       ``(3) Covered individual.--For purposes of this subsection, 
     the term `covered individual' means any individual who is an 
     officer, director, or employee of the taxpayer or a former 
     officer, director, or employee of the taxpayer.''.
       (3) Conforming amendments.--
       (A) Section 48D(b)(3)(A) of such Code is amended by 
     inserting ``(as in effect for taxable years beginning before 
     January 1, 2015)'' after ``section 162(m)(3)''.
       (B) Section 409A(b)(3)(D)(ii) of such Code is amended by 
     inserting ``(as in effect for taxable years beginning before 
     January 1, 2015)'' after ``section 162(m)(3)''.
       (b) Expansion of Applicable Employee Remuneration.--
       (1) Elimination of exception for commission-based pay.--
       (A) In general.--Paragraph (4) of section 162(m) of such 
     Code, as amended by subsection (a), is amended by striking 
     subparagraph (B) and by redesignating subparagraphs (C) 
     through (G) as subparagraphs (B) through (F), respectively.
       (B) Conforming amendments.--
       (i) Section 162(m)(5) of such Code is amended--

       (I) by striking ``subparagraphs (B), (C), and (D) thereof'' 
     in subparagraph (E) and inserting ``subparagraphs (B) and (C) 
     thereof'', and
       (II) by striking ``subparagraphs (F) and (G)'' in 
     subparagraph (G) and inserting ``subparagraphs (E) and (F)''.

       (ii) Section 162(m)(6) of such Code is amended--

       (I) by striking ``subparagraphs (B), (C), and (D) thereof'' 
     in subparagraph (D) and inserting ``subparagraphs (B) and (C) 
     thereof'', and
       (II) by striking ``subparagraphs (F) and (G)'' in 
     subparagraph (G) and inserting ``subparagraphs (E) and (F)''.

       (2) Inclusion of performance-based compensation.--
       (A) In general.--Paragraph (4) of section 162(m) of the 
     Internal Revenue Code of 1986, as amended by subsection (a) 
     and paragraph (1) of this subsection, is amended by striking 
     subparagraph (B) and redesignating subparagraphs (C) through 
     (F) as subparagraphs (B) through (E), respectively.
       (B) Conforming amendments.--
       (i) Section 162(m)(5) of such Code, as amended by paragraph 
     (1), is amended--

       (I) by striking ``subparagraphs (B) and (C) thereof'' in 
     subparagraph (E) and inserting ``subparagraph (B) thereof'', 
     and
       (II) by striking ``subparagraphs (E) and (F)'' in 
     subparagraph (G) and inserting ``subparagraphs (D) and (E)''.

       (ii) Section 162(m)(6) of such Code, as amended by 
     paragraph (1), is amended--

       (I) by striking ``subparagraphs (B) and (C) thereof'' in 
     subparagraph (D) and inserting ``subparagraph (B) thereof'', 
     and
       (II) by striking ``subparagraphs (E) and (F)'' in 
     subparagraph (G) and inserting ``subparagraphs (D) and (E)''.

       (c) Expansion of Applicable Employer.--Paragraph (2) of 
     section 162(m) of the Internal Revenue Code of 1986 is 
     amended to read as follows:
       ``(2) Publicly held corporation.--For purposes of this 
     subsection, the term `publicly held corporation' means any 
     corporation which is an issuer (as defined in section 3 of 
     the Securities Exchange Act of 1934 (15 U.S.C. 78c))--
       ``(A) the securities of which are registered under section 
     12 of such Act (15 U.S.C. 78l), or
       ``(B) that is required to file reports under section 15(d) 
     of such Act (15 U.S.C. 780(d)).''.
       (d) Regulatory Authority.--
       (1) In general.--Section 162(m) of the Internal Revenue 
     Code of 1986 is amended by adding at the end the following 
     new paragraph:
       ``(7) Regulations.--The Secretary may prescribe such 
     guidance, rules, or regulations, including with respect to 
     reporting, as are necessary to carry out the purposes of this 
     subsection.''.
       (2) Conforming amendment.--Paragraph (6) of section 162(m) 
     of such Code is amended by striking subparagraph (H).
       (e) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.
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