[Congressional Record Volume 167, Number 88 (Thursday, May 20, 2021)]
[Senate]
[Pages S3279-S3283]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
SA 1859. Mr. CRUZ submitted an amendment intended to be proposed to
amendment SA 1502 proposed by Mr. Schumer to the bill S. 1260, to
establish a new Directorate for Technology and Innovation in the
National Science Foundation, to establish a regional technology hub
program, to require a strategy and report on economic security,
science, research, innovation, manufacturing, and job creation, to
establish a critical supply chain resiliency program, and for other
purposes; which was ordered to lie on the table; as follows:
At the appropriate place, insert the following:
TITLE IV--INDIVIDUAL TAX PROVISIONS MADE PERMANENT
SEC. __01. FINDINGS.
(a) Findings.--Congress makes the following findings:
(1) Innovation in the United States has been and will
continue to be the main driver of technological progress and
economic growth.
(2) Taxation, in the form of both personal income taxes and
corporate income taxes, matters for innovation along the
intensive and extensive margins and both at the micro and
macro levels.
(3) From 1900 to 2000, States with the most innovations
also witnessed the fastest growth.
(4) Globally, the evidence demonstrates that countries with
an overall lower tax burden will enjoy a higher level of
innovation, greater quality of innovation, and more robust
inventive activity.
(5) Efficient tax policy can provide effective incentives
for many economic activities, including innovation.
(6) Inefficient tax policy can create heavy, deadweight
burdens, hurt incentives, and slow down innovation.
(7) High rates of corporate and personal income taxation
negatively affect the quantity, quality, and location of
innovation at the individual, organizational, and State
level.
SEC. __02. PERMANENT MODIFICATION OF INDIVIDUAL RATE
BRACKETS.
(a) Married Individuals Filing Joint Returns and Surviving
Spouses.--The table contained in subsection (a) of section 1
of the Internal Revenue Code of 1986 is amended to read as
follows:
``If taxable income is: The tax is:
------------------------------------------------------------------------
Not over $19,050.......................... 10% of taxable income.
Over $19,050 but not over $77,400......... $1,905, plus 12% of the
excess over $19,050.
Over $77,400 but not over $165,000........ $8,907, plus 22% of the
excess over $77,400.
Over $165,000 but not over $315,000....... $28,179, plus 24% of the
excess over $165,000.
Over $315,000 but not over $400,000....... $64,179, plus 32% of the
excess over $315,000.
Over $400,000 but not over $600,000....... $91,379, plus 35% of the
excess over $400,000.
Over $600,000............................. $161,379, plus 37% of the
excess over $600,000.''.
(b) Heads of Households.--The table contained in subsection
(b) of section 1 of the Internal Revenue Code of 1986 is
amended to read as follows:
``If taxable income is: The tax is:
------------------------------------------------------------------------
Not over $13,600.......................... 10% of taxable income.
Over $13,600 but not over $51,800......... $1,360, plus 12% of the
excess over $13,600.
Over $51,800 but not over $82,500......... $5,944, plus 22% of the
excess over $51,800.
Over $82,500 but not over $157,500........ $12,698, plus 24% of the
excess over $82,500.
Over $157,500 but not over $200,000....... $30,698, plus 32% of the
excess over $157,500.
Over $200,000 but not over $500,000....... $44,298, plus 35% of the
excess over $200,000.
Over $500,000............................. $149,298, plus 37% of the
excess over $500,000.''.
(c) Unmarried Individuals Other Than Surviving Spouses and
Heads of Households.--The table contained in subsection (c)
of section 1 of the Internal Revenue Code of 1986 is amended
to read as follows:
``If taxable income is: The tax is:
------------------------------------------------------------------------
Not over $9,525........................... 10% of taxable income.
Over $9,525 but not over $38,700.......... $952.50, plus 12% of the
excess over $9,525.
Over $38,700 but not over $82,500......... $4,453.50, plus 22% of the
excess over $38,700.
Over $82,500 but not over $157,500........ $14,089.50, plus 24% of the
excess over $82,500.
Over $157,500 but not over $200,000....... $32,089.50, plus 32% of the
excess over $157,500.
Over $200,000 but not over $500,000....... $45,689.50, plus 35% of the
excess over $200,000.
Over $500,000............................. $150,689.50, plus 37% of the
excess over $500,000.''.
(d) Married Individuals Filing Separate Returns.--The table
contained in subsection (d) of section 1 of the Internal
Revenue Code of 1986 is amended to read as follows:
``If taxable income is: The tax is:
------------------------------------------------------------------------
Not over $9,525........................... 10% of taxable income.
Over $9,525 but not over $38,700.......... $952.50, plus 12% of the
excess over $9,525.
Over $38,700 but not over $82,500......... $4,453.50, plus 22% of the
excess over $38,700.
Over $82,500 but not over $157,500........ $14,089.50, plus 24% of the
excess over $82,500.
Over $157,500 but not over $200,000....... $32,089.50, plus 32% of the
excess over $157,500.
Over $200,000 but not over $300,000....... $45,689.50, plus 35% of the
excess over $200,000.
Over $300,000............................. $80,689.50, plus 37% of the
excess over $300,000.''.
(e) Estates and Trusts.--The table contained in subsection
(e) of section 1 of the Internal Revenue Code of 1986 is
amended to read as follows:
``If taxable income is: The tax is:
------------------------------------------------------------------------
Not over $2,550........................... 10% of taxable income.
Over $2,550 but not over $9,150........... $255, plus 24% of the excess
over $2,550.
Over $9,150 but not over $12,500.......... $1,839, plus 35% of the
excess over $9,150.
Over $12,500.............................. $3,011.50, plus 37% of the
excess over $12,500.''.
(f) Adjustment for Inflation.--Subsection (f) of section 1
of the Internal Revenue Code of 1986 is amended--
(1) by striking ``1993'' in paragraph (1) and inserting
``2018'',
(2) by striking ``determined--'' and all that follows in
paragraph (2)(A) and inserting ``determined by substituting
`2017' for `2016' in paragraph (3)(A)(ii),'',
(3) by striking ``a married individual filing a separate
return'' in paragraph (7)(B) and inserting ``any unmarried
individual other than a surviving spouse or head of
household'',
(4) by striking ``married individuals filing separately''
in the heading of subparagraph (B) of paragraph (7) and
inserting ``certain unmarried individuals'', and
(5) by striking paragraph (8).
(g) Capital Gains Brackets.--Subsection (h) of section 1 of
the Internal Revenue Code of 1986 is amended--
(1) by striking ``which would (without regard to this
paragraph) be taxed at a rate below 25 percent'' in paragraph
(1)(B)(i) and inserting ``below the maximum zero rate
amount'',
(2) by striking ``which would (without regard to this
paragraph) be taxed at a rate below 39.6 percent'' in
paragraph (1)(C)(ii)(I) and inserting ``below the maximum 15-
percent rate amount'', and
(3) by adding at the end the following new paragraph:
``(12) Maximum amounts defined.--For purposes of this
subsection--
``(A) Maximum zero rate amount.--The maximum zero rate
amount shall be--
``(i) in the case of a joint return or surviving spouse,
$77,200,
``(ii) in the case of an individual who is a head of
household (as defined in section 2(b)), $51,700,
``(iii) in the case of any other individual (other than an
estate or trust), an amount equal to \1/2\ of the amount in
effect for the taxable year under clause (i), and
``(iv) in the case of an estate or trust, $2,600.
``(B) Maximum 15-percent rate amount.--The maximum 15-
percent rate amount shall be--
``(i) in the case of a joint return or surviving spouse,
$479,000 (\1/2\ such amount in the case of a married
individual filing a separate return),
``(ii) in the case of an individual who is the head of a
household (as defined in section 2(b)), $452,400,
[[Page S3280]]
``(iii) in the case of any other individual (other than an
estate or trust), $425,800, and
``(iv) in the case of an estate or trust, $12,700.
``(C) Inflation adjustment.--In the case of any taxable
year beginning after 2018, each of the dollar amounts in
subparagraphs (A) and (B) 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, determined by substituting `calendar year 2017'
for `calendar year 2016' in subparagraph (A)(ii) thereof.
If any increase under this subparagraph is not a multiple of
$50, such increase shall be rounded to the next lowest
multiple of $50.''.
(h) Conforming Amendments.--
(1) Section 1 of the Internal Revenue Code of 1986 is
amended by striking subsections (i) and (j).
(2) Section 3402(q)(1) of such Code is amended by striking
``third lowest'' and inserting ``fourth lowest''.
(i) Section 15 Not To Apply.--Section 15 of the Internal
Revenue Code of 1986 shall not apply to any change in a rate
of tax by reason of this section.
(j) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __03. PERMANENT EXTENSION OF DEDUCTION FOR QUALIFIED
BUSINESS INCOME OF PASS-THRU ENTITIES.
(a) In General.--Section 199A of the Internal Revenue Code
of 1986 is amended by striking subsection (i).
(b) Effective Date.--The amendment made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __04. PERMANENT EXTENSION OF LIMITATION ON LOSSES FOR
TAXPAYERS OTHER THAN CORPORATIONS.
(a) In General.--Paragraph (1) of section 461(l) of the
Internal Revenue Code of 1986 is amended to read as follows:
``(1) Limitation.--In the case of taxable year of a
taxpayer other than a corporation, any excess business loss
of the taxpayer for the taxable year shall not be allowed.''.
(b) Conforming Amendment.--Section 461 of the Internal
Revenue Code of 1986 is amended by striking subsection (j)
(relating to limitation on excess farm losses of certain
taxpayers).
(c) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __05. PERMANENT EXTENSION OF INCREASE IN STANDARD
DEDUCTION.
(a) In General.--Section 63(c)(2) of the Internal Revenue
Code of 1986 is amended--
(1) by striking ``$4,400'' in subparagraph (B) and
inserting ``$18,800'', and
(2) by striking ``$3,000'' in subparagraph (C) and
inserting ``$12,000''.
(b) Inflation Adjustment.--Paragraph (4) of section 63(c)
of the Internal Revenue Code of 1986 is amended to read as
follows:
``(4) Adjustments for inflation.--
``(A) In general.--In the case of any taxable year
beginning in a calendar year after 2018, the $18,000 and
$12,000 amounts in subparagraph (A) shall each be increased
by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment determined under
section 1(f)(3) for the calendar year in which the taxable
year begins, by substituting `2017' for `2016' in
subparagraph (A)(ii) thereof.
``(B) Certain amounts.--In the case of any taxable year
beginning in a calendar year after 1988, each dollar amount
contained in paragraph (5) or subsection (f) shall be
increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment determined under
section 1(f)(3) for the calendar year in which the taxable
year begins, by substituting for `calendar year 2016' in
subparagraph (A)(ii) thereof--
``(I) `calendar year 1987' in the case of the dollar
amounts contained in paragraph (5)(A) or subsection (f), and
``(II) `calendar year 1997' in the case of the dollar
amount contained in paragraph (5)(B).''.
(c) Conforming Amendment.--Section 63(c) of the Internal
Revenue Code of 1986 is amended by striking paragraph (7).
(d) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __06. PERMANENT INCREASE AND MODIFICATION OF CHILD TAX
CREDIT.
(a) Increase in Credit Amount.--Section 24(a) of the
Internal Revenue Code of 1986 is amended by striking
``$1,000'' and inserting ``$2,000''.
(b) Limitation.--Paragraph (2) of section 24(b) of the
Internal Revenue Code of 1986 is amended to read as follows:
``(2) Threshold amount.--For purposes of paragraph (1), the
term `threshold amount' means--
``(A) $400,000 in the case of a joint return, and
``(B) $200,000 in any other case.''.
(c) Partial Credit Allowed for Certain Other Dependents.--
Subsection (h) of section 24 of the Internal Revenue Code of
1986 is amended to read as follows:
``(h) Partial Credit Allowed for Certain Other
Dependents.--
``(1) In general.--The credit determined under subsection
(a) shall be increased by $500 for each dependent of the
taxpayer (as defined in section 7706) other than a qualifying
child described in subsection (c).
``(2) Exception for certain noncitizens.--Paragraph (1)
shall not apply with respect to any individual who would not
be a dependent if subparagraph (A) of section 7706(b)(3) were
applied without regard to all that follows `resident of the
United States'.
``(3) Certain qualifying children.--In the case of any
qualifying child with respect to whom a credit is not allowed
under this section by reason of subsection (e)(1), such child
shall be treated as a dependent to whom subparagraph (A)
applies.''.
(d) Maximum Amount of Refundable Credit.--Subsection (d) of
section 24 of the Internal Revenue Code of 1986 is amended by
inserting after paragraph (2) the following new paragraph:
``(3) Limitation.--
``(A) In general.--The amount determined under paragraph
(1)(A) with respect to any qualifying child shall not exceed
$1,400, and such paragraph shall be applied without regard to
subsection (h).
``(B) Adjustment for inflation.--In the case of a taxable
year beginning after 2018, the $1,400 amount in subparagraph
(A) shall be increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment determined under
section 1(f)(3) for the calendar year in which the taxable
year begins, determined by substituting `2017' for `2016' in
subparagraph (A)(ii) thereof.
If any increase under this clause is not a multiple of $100,
such increase shall be rounded to the next lowest multiple of
$100.''.
(e) Earned Income Threshold for Refundable Credit.--Section
24(d)(1)(B) of the Internal Revenue Code of 1986 is amended
by striking ``$3,000'' and inserting ``$2,500''.
(f) Social Security Number Required.--Paragraph (1) of
section 24(e) of the Internal Revenue Code of 1986 is amended
to read as follows:
``(1) Qualifying child social security number
requirement.--No credit shall be allowed under this section
to a taxpayer with respect to any qualifying child unless the
taxpayer includes the name and social security number of such
child on the return of tax for the taxable year. For purposes
of the preceding sentence, the term `social security number'
means a social security number issued to an individual by the
Social Security Administration, but only if the social
security number is issued--
``(A) to a citizen of the United States or pursuant to
subclause (I) (or that portion of subclause (III) that
relates to subclause (I)) of section 205(c)(2)(B)(i) of the
Social Security Act, and
``(B) before the due date for such return.''.
(g) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2021.
SEC. __07. PERMANENT EXTENSION OF INCREASED LIMITATION FOR
CERTAIN CHARITABLE CONTRIBUTIONS.
(a) In General.--Section 170(b)(1)(G) of the Internal
Revenue Code of 1986 is amended--
(1) by striking ``for any taxable year beginning after
December 31, 2017, and before January 1, 2026,'' in clause
(i),
(2) by striking ``for any taxable year described in such
clause'' in clause (ii), and
(3) by striking ``For each taxable year described in clause
(i), and each taxable year to which any contribution under
this subparagraph is carried over under clause (ii),
subparagraph (A)'' in clause (iii) and inserting
``Subparagraph (A)''.
(b) Effective Date.--The amendments made by this section
shall apply to contributions in taxable years beginning after
December 31, 2025.
SEC. __08. PERMANENT EXTENSION OF INCREASED CONTRIBUTIONS TO
ABLE ACCOUNTS.
(a) In General.--Section 529A(b)(2)(B)(ii) of the Internal
Revenue Code of 1986 is amended by striking ``before January
1, 2026''.
(b) Allowance of Savers Credit.--Section 25B(d)(1)(D) of
the Internal Revenue Code of 1986 is amended by striking
``before January 1, 2026,''.
(c) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after the date of the
enactment of this Act.
SEC. __09. PERMANENT EXTENSION OF ROLLOVERS TO ABLE PROGRAMS
FROM 529 PROGRAMS.
(a) In General.--Section 529(c)(3)(C)(i)(III) is amended by
striking ``before January 1, 2026,''.
(b) Effective Date.--The amendments made by this section
shall apply to distributions made after the date of the
enactment of this Act.
SEC. __10. PERMANENT EXTENSION OF TREATMENT OF CERTAIN
INDIVIDUALS PERFORMING SERVICES IN THE SINAI
PENINSULA OF EGYPT.
(a) In General.--Subsection (c) of section 11026 of Public
Law 115-97 is amended--
(1) by striking ``beginning before January 1, 2026'' in
paragraph (1)(B), and
(2) by striking ``beginning before January 1, 2026'' in
paragraph (2)(B).
(b) Effective Date.--The amendments made by this section
shall take effect on the date of the enactment of this Act.
SEC. __11. PERMANENT EXTENSION OF TREATMENT OF STUDENT LOANS
DISCHARGED ON ACCOUNT OF DEATH OR DISABILITY.
(a) In General.--Subparagraph (A) of section 108(f)(5) of
the Internal Revenue Code of 1986 is amended by striking
``and before January 1, 2026,''.
[[Page S3281]]
(b) Effective Date.--The amendment made by this section
shall apply to discharges of indebtedness after December 31,
2020.
SEC. __12. REPEAL OF DEDUCTION FOR PERSONAL EXEMPTIONS.
(a) In General.--Part V of subchapter B of chapter 1 of the
Internal Revenue Code of 1986 is hereby repealed.
(b) Definition of Dependent Retained.--Section 152 of the
Internal Revenue Code of 1986, prior to repeal by subsection
(a), is hereby redesignated as section 7706 of such Code and
moved to the end of chapter 79 of such Code.
(c) Application to Estates and Trusts.--Subparagraph (C) of
section 642(b)(2) of the Internal Revenue Code of 1986 is
amended--
(1) by striking ``the exemption amount under section
151(d)'' in clause (i) and inserting ``$4,150'', and
(2) by striking clause (iii) and inserting the following:
``(iii) Inflation adjustment.--In the case of any taxable
year beginning in a calendar year after 2018, the $4,150
amount in clause (i) shall be increased by an amount equal
to--
``(I) such dollar amount, multiplied by
``(II) the cost-of-living adjustment determined under
section 1(f)(3) for the calendar year in which the taxable
begins, determined by substituting `2017' for `2016' in
subparagraph (A)(ii) thereof.
If any increase determined under the preceding sentence is
not a multiple of $100, such increase shall be rounded to the
next lowest multiple of $100.''.
(d) Application to Nonresident Aliens.--Section 873(b) of
the Internal Revenue Code of 1986 is amended by striking
paragraph (3).
(e) Modification of Return Requirement.--
(1) In general.--Section 6012 of the Internal Revenue Code
of 1986 is amended--
(A) by striking paragraph (1) of subsection (a) and
inserting the following:
``(1) Every individual who has gross income for the taxable
year, except that a return shall not be required of--
``(A) an individual who is not married (determined by
applying section 7703) and who has gross income for the
taxable year which does not exceed the standard deduction
applicable to such individual for such taxable year under
section 63, or
``(B) an individual entitled to make a joint return if--
``(i) the gross income of such individual, when combined
with the gross income of such individual's spouse, for the
taxable year does not exceed the standard deduction which
would be applicable to the taxpayer for such taxable year
under section 63 if such individual and such individual's
spouse made a joint return,
``(ii) such individual and such individual's spouse have
the same household as their home at the close of the taxable
year,
``(iii) such individual's spouse does not make a separate
return, and
``(iv) neither such individual nor such individual's spouse
is an individual described in section 63(c)(2) who has income
(other than earned income) in excess of the amount in effect
under section 63(c)(2)(A).'', and
(B) by striking subsection (f).
(2) Bankruptcy estates.--Paragraph (8) of section 6012(a)
of such Code is amended by striking ``the sum of the
exemption amount plus the basic standard deduction under
section 63(c)(2)(D)'' and inserting ``the standard deduction
in effect under section 63(c)(1)(B)''.
(f) Conforming Amendments.--
(1) Section 2(a)(1)(B) of the Internal Revenue Code of 1986
is amended by striking ``a dependent'' and all that follows
through ``section 151'' and inserting ``a dependent who
(within the meaning of section 7706, determined without
regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof)
is a son, stepson, daughter, or stepdaughter of the
taxpayer''.
(2) Section 36B(b)(2)(A) of such Code is amended by
striking ``section 152'' and inserting ``section 7706''.
(3) Section 36B(b)(3)(B) of such Code 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''.
(4) Section 36B(c)(1)(D) of such Code 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''.
(5) Section 36B(d)(1) of such Code 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 the taxpayer's dependents for the
taxable year''.
(6) Section 36B(e)(1) of such Code 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''.
(7) Section 42(i)(3)(D)(ii)(I) of such Code is amended--
(A) by striking ``section 152'' and inserting ``section
7706'', and
(B) by striking the period at the end and inserting a
comma.
(8) Section 63(b) of such Code is amended by striking
``minus--'' and all that follows and inserting ``minus the
standard deduction.''.
(9) Section 63(d) of such Code is amended by striking
``other than--'' and all that follows and inserting ``other
than the deductions allowable in arriving at adjusted gross
income.''.
(10) Section 72(t)(2)(D)(i)(III) of such Code is amended by
striking ``section 152'' and inserting ``section 7706''.
(11) Section 72(t)(7)(A)(iii) of such Code is amended by
striking ``section 152(f)(1)'' and inserting ``section
7706(f)(1)''.
(12) Section 105(b) of such Code 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)''.
(13) Section 105(c)(1) of such Code is amended by striking
``section 152'' and inserting ``section 7706''.
(14) Section 125(e)(1)(D) of such Code is amended by
striking ``section 152'' and inserting ``section 7706''.
(15) Section 129(c) of such Code is amended--
(A) by striking ``with respect to whom, for such taxable
year, a deduction is allowable under section 151(c) (relating
to personal exemptions for dependents) to'' in paragraph (1)
and inserting ``who is a dependent of'', and
(B) by striking ``section 152(f)(1)'' in paragraph (2) and
inserting ``section 7706(f)(1)''.
(16) Section 132(h)(2)(B) of such Code 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)''.
(17) Section 139D(c)(5) of such Code is amended by striking
``section 152'' and inserting ``section 7706''.
(18) Section 162(l)(1)(D) of such Code is amended by
striking ``section 152(f)(1)'' and inserting ``section
7706(f)(1)''.
(19) Section 170(g)(1) of such Code is amended by striking
``section 152'' and inserting ``section 7706''.
(20) Section 170(g)(3) of such Code is amended by striking
``section 152(d)(2)'' and inserting ``section 7706(d)(2)''.
(21) Section 172(d) of such Code is amended by striking
paragraph (3).
(22) Section 220(b)(6) of such Code is amended by striking
``with respect to whom a deduction under section 151 is
allowable to'' and inserting ``who is a dependent of''.
(23) Section 220(d)(2)(A) of such Code is amended by
striking ``section 152'' and inserting ``section 7706''.
(24) Section 223(b)(6) of such Code is amended by striking
``with respect to whom a deduction under section 151 is
allowable to'' and inserting ``who is a dependent of''.
(25) Section 223(d)(2)(A) of such Code is amended by
striking ``section 152'' and inserting ``section 7706''.
(26) Section 401(h) of such Code is amended by striking
``section 152(f)(1)'' in the last sentence and inserting
``section 7706(f)(1)''.
(27) Section 402(l)(4)(D) of such Code is amended by
striking ``section 152'' and inserting ``section 7706''.
(28) Section 409A(a)(2)(B)(ii)(I) of such Code is amended
by striking ``section 152(a)'' and inserting ``section
7706(a)''.
(29) Section 501(c)(9) of such Code is amended by striking
``section 152(f)(1)'' and inserting ``section 7706(f)(1)''.
(30) Section 529(e)(2)(B) of such Code is amended by
striking ``section 152(d)(2)'' and inserting ``section
7706(d)(2)''.
(31) Section 703(a)(2) of such Code is amended by striking
subparagraph (A) and by redesignating subparagraphs (B)
through (F) as subparagraphs (A) through (E), respectively.
(32) Section 874 of such Code is amended by striking
subsection (b) and by redesignating subsection (c) as
subsection (b).
(33) Section 891 of such Code is amended by striking
``under section 151 and''.
(34) Section 904(b) of such Code is amended by striking
paragraph (1).
(35) Section 931(b)(1) of such Code is amended by striking
``(other than the deduction under section 151, relating to
personal exemptions)''.
(36) Section 933 of such Code is amended--
(A) by striking ``(other than the deduction under section
151, relating to personal exemptions)'' in paragraph (1), and
(B) by striking ``(other than the deduction for personal
exemptions under section 151)'' in paragraph (2).
(37) Section 1212(b)(2)(B)(ii) of such Code 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).''.
(38) Section 1361(c)(1)(C) of such Code is amended by
striking ``section 152(f)(1)(C)'' and inserting ``section
7706(f)(1)(C)''.
(39) Section 1402(a) of such Code is amended by striking
paragraph (7).
(40) Section 2032A(c)(7)(D) of such Code is amended by
striking ``section 152(f)(2)'' and inserting ``section
7706(f)(2)''.
(41) Section 3402(m)(1) of such Code is amended by striking
``other than the deductions referred to in section 151 and''.
(42) Section 3402(r)(2) of such Code is amended by striking
``the sum of--'' and all that follows and inserting ``the
standard deduction in effect under section 63(c)(1)(B).''.
[[Page S3282]]
(43) Section 5000A(b)(3)(A) of such Code is amended by
striking ``section 152'' and inserting ``section 7706''.
(44) Section 5000A(c)(4)(A) of such Code 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''.
(45) Section 6013(b)(3)(A) of such Code is amended--
(A) by striking ``had less than the exemption amount of
gross income'' in clause (ii) and inserting ``had no gross
income'',
(B) by striking ``had gross income of the exemption amount
or more'' in clause (iii) and inserting ``had any gross
income'', and
(C) by striking the flush language following clause (iii).
(46) Section 6103(l)(21)(A)(iii) of such Code is amended to
read as follows:
``(iii) the number of the taxpayer's dependents,''.
(47) Section 6213(g)(2) of such Code is amended by striking
subparagraph (H).
(48) Section 6334(d)(2) of such Code is amended to read as
follows:
``(2) Exempt amount.--
``(A) In general.--For purposes of paragraph (1), the term
`exempt amount' means an amount equal to--
``(i) the sum of the amount determined under subparagraph
(B) and the standard deduction, divided by
``(ii) 52.
``(B) Amount determined.--For purposes of subparagraph (A),
the amount determined under this subparagraph is $4,150
multiplied by the number of the taxpayer's dependents for the
taxable year in which the levy occurs.
``(C) Inflation adjustment.--In the case of any taxable
year beginning after 2018, the $4,150 amount in subparagraph
(B) shall be increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment determined under
section 1(f)(3) for the calendar year in which the taxable
year begins, by substituting `calendar year 2017' for
`calendar year 2016' in subparagraph (A) thereof.
If any increase determined under the preceding sentence is
not a multiple of $100, such increase shall be rounded to the
next lowest multiple of $100.
``(D) Verified statement.--Unless the taxpayer submits to
the Secretary a written and properly verified statement
specifying the facts necessary to determine the proper amount
under subparagraph (A), subparagraph (A) shall be applied as
if the taxpayer were a married individual filing a separate
return with no dependents.''.
(49) Section 7702B(f)(2)(C)(iii) of such Code is amended by
striking ``section 152(d)(2)'' and inserting ``section
7706(d)(2)''.
(50) Section 7703(a) of such Code is amended by striking
``part V of subchapter B of chapter 1 and''.
(51) Section 7703(b)(1) of such Code is amended by striking
``section 152(f)(1)'' and all that follows and inserting
``section 7706(f)(1),''.
(52) Section 7706(a) of such Code, as redesignated by this
section, is amended by striking ``this subtitle'' and
inserting ``subtitle A''.
(53)(A) Section 7706(d)(1)(B) of such Code, as redesignated
by this section, is amended by striking ``the exemption
amount (as defined in section 151(d))'' and inserting
``$4,150''.
(B) Section 7706(d) of such Code, as redesignated by this
section, is amended by adding at the end the following new
paragraph:
``(6) Inflation adjustment.--In the case of any 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(f)(3) for such calendar year, determined by
substituting `calendar year 2017' for `calendar year 2016' in
subparagraph (A)(ii) thereof.
If any increase determined under the preceding sentence is
not a multiple of $100, such increase shall be rounded to the
next lowest multiple of $100.''.
(54) The table of sections for chapter 79 of such Code is
amended by adding at the end the following new item:
``Sec. 7706. Dependent defined.''.
(g) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __13. PERMANENT EXTENSION OF LIMITATION ON DEDUCTION FOR
STATE AND LOCAL, ETC., TAXES.
(a) In General.--Paragraph (6) of section 164(b) of the
Internal Revenue Code of 1986 is amended--
(1) by striking ``, and before January 1, 2026'', and
(2) by striking ``2018 through 2025'' in the heading and
inserting ``after 2017''.
(b) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __14. PERMANENT EXTENSION OF LIMITATION ON DEDUCTION FOR
QUALIFIED RESIDENCE INTEREST.
(a) Repeal of Home Equity Indebtedness.--
(1) In general.--Section 163(h)(3)(A) of the Internal
Revenue Code of 1986 is amended by striking ``during the
taxable year on'' and all that follows through ``For purposes
of'' and inserting ``during the taxable year on acquisition
indebtedness with respect to any qualified principal
residence of the taxpayer. For purposes of''.
(2) Conforming amendment.--Section 163(h)(3) of such Code
is amended by striking subparagraph (C).
(b) Limitation on Acquisition Indebtedness.--
(1) In general.--Section 163(h)(3)(B)(ii) of the Internal
Revenue Code of 1986 is amended by striking ``$1,000,000
($500,000'' and inserting ``$750,000 ($375,000''.
(2) Treatment of indebtedness incurred on or before
december 31, 2017; refinancings.--Section 163(h)(3) of the
Internal Revenue Code of 1986, as amended by subsection
(a)(2), is amended by inserting after subparagraph (B) the
following new subparagraph:
``(C) Treatment of indebtedness incurred on or before
december 15, 2017; refinancings.--
``(i) In general.--In the case of any indebtedness incurred
on or before December 15, 2017, subparagraph (B)(ii) shall
apply as in effect immediately before the enactment of the
Public Law 115-97, and, in applying such subparagraph to any
indebtedness incurred after such date, the limitation under
such subparagraph shall be reduced (but not below zero) by
the amount of any indebtedness incurred on or before December
15, 2017, which is treated as acquisition indebtedness for
purposes of this subsection for the taxable year.
``(ii) Binding contract exception.--In the case of a
taxpayer who enters into a written binding contract before
December 15, 2017, to close on the purchase of a principal
residence before January 1, 2018, and who purchases such
residence before April 1, 2018, subclause (III) shall be
applied by substituting `April 1, 2018' for `December 15,
2017'.
``(iii) Treatment of refinancings of indebtedness.--
``(I) In general.--In the case of any indebtedness which is
incurred to refinance indebtedness, such refinanced
indebtedness shall be treated for purposes of clause (i) as
incurred on the date that the original indebtedness was
incurred to the extent the amount of the indebtedness
resulting from such refinancing does not exceed the amount of
the refinanced indebtedness.
``(II) Limitation on period of refinancing.--Subclause (I)
shall not apply to any indebtedness after the expiration of
the term of the original indebtedness or, if the principal of
such original indebtedness is not amortized over its term,
the expiration of the term of the 1st refinancing of such
indebtedness (or if earlier, the date which is 30 years after
the date of such 1st refinancing).''.
(c) Coordination With Exclusion of Income From Discharge of
Indebtedness.--Section 108(h)(2) of the Internal Revenue Code
of 1986 is amended by striking ``, applied by substituting''
and all that follows through ``section 163(h)(3)(F)(i)(II)''.
(d) Conforming Amendments.--Section 163(h)(3) of the
Internal Revenue Code of 1986 is amended--
(1) in the heading of subparagraph (D)(ii), by striking
``$1,000,000'', and
(2) by striking subparagraph (F).
(e) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __15. PERMANENT EXTENSION OF MODIFICATIONS TO DEDUCTION
FOR PERSONAL CASUALTY LOSSES.
(a) In General.--Paragraph (5) of section 165(h) of the
Internal Revenue Code of 1986 is amended--
(1) by striking ``, and before January 1, 2026'' in
subparagraph (A), and
(2) by striking ``2018 through 2025'' in the heading and
inserting ``after 2017''.
(b) Effective Date.--The amendments made by this section
shall apply to losses incurred in taxable years beginning
after December 31, 2020.
SEC. __16. REPEAL OF MISCELLANEOUS ITEMIZED DEDUCTIONS.
(a) In General.--Section 67 of the Internal Revenue Code of
1986 is amended--
(1) by striking subsection (a) and inserting the following:
``(a) General Rule.--No miscellaneous itemized deduction
shall be allowed for any taxable year beginning after
December 31, 2017.'',
(2) by striking subsection (g), and
(3) by striking ``2-percent floor on'' in the heading and
inserting ``treatment of''.
(b) Conforming Amendment.--The table of sections for part I
of subchapter B of chapter 1 of the Internal Revenue Code of
1986 is amended by striking ``2-percent floor on'' in the
item relating to section 67 and inserting ``Treatment of''.
(c) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __17. REPEAL OF OVERALL LIMITATION ON ITEMIZED
DEDUCTIONS.
(a) In General.--Part 1 of subchapter B of chapter 1 of the
Internal Revenue Code of 1986 is amended by striking section
68 (and the item relating to such section in the table of
sections for such part).
(b) Conforming Amendments.--
(1) Section 1(f)(7) of the Internal Revenue Code of 1986 is
amended by striking ``section 68(b)(2),''.
(2) Section 56(b)(1) of such Code is amended by striking
subparagraph (F).
(3) Section 164(b)(5)(H)(ii)(III) of such Code is amended
by inserting ``(as in effect before
[[Page S3283]]
the date of the enactment of the Tax Cuts and Jobs Act)''
after ``68(b)''.
(4) Section 642(b)(2)(C)(i)(I) of such Code is amended by
striking ``as an individual described in section
68(b)(1)(C)'' and inserting ``as an individual who is not
married and who is not a surviving spouse or head of
household''.
(5) Section 773(a)(3)(B) of such Code is amended by
striking clause (i) and redesignating clauses (ii) through
(iv) as clauses (i) through (iii), respectively.
(c) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __18. REPEAL OF EXCLUSION FOR QUALIFIED BICYCLE
COMMUTING REIMBURSEMENT.
(a) In General.--Section 132(f)(1) of the Internal Revenue
Code of 1986 is amended by striking subparagraph (D).
(b) Conforming Amendments.--
(1) Section 132(f)(2) of the Internal Revenue Code of 1986
is amended by inserting ``and'' at the end of subparagraph
(A), by striking ``, and'' at the end of subparagraph (B) and
inserting a period, and by striking subparagraph (C).
(2) Section 132(f)(4) of such Code is amended by striking
``(other than a qualified bicycle commuting reimbursement)''.
(3) Section 132(f)(5) of such Code is amended by striking
subparagraph (F).
(4) Section 132(f) of such Code is amended by striking
paragraph (8).
(c) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __19. PERMANENT EXTENSION OF MODIFICATION OF EXCLUSION
FOR QUALIFIED MOVING EXPENSE REIMBURSEMENT.
(a) In General.--Section 132(g) of the Internal Revenue
Code of 1986 is amended--
(1) in paragraph (1), by striking ``individual'' and
inserting ``qualified military member'', and
(2) by striking paragraph (2) and inserting the following:
``(2) Qualified military member.--For purposes of paragraph
(1), the term `qualified military member' means a member of
the Armed Forces of the United States on active duty who
moves pursuant to a military order and incident to a
permanent change of station.''.
(b) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __20. REPEAL OF DEDUCTION FOR MOVING EXPENSES.
(a) In General.--Subsection (a) of section 217 of the
Internal Revenue Code of 1986 is amended to read as follows:
``(a) Deduction Allowed.--There shall be allowed as a
deduction moving expenses paid or incurred during the taxable
year in connection with the commencement of work by a member
of the Armed Forces of the United States on active duty who
moves pursuant to a military order and incident to a
permanent change of station.''.
(b) Conforming Amendments.--
(1) Section 217 of the Internal Revenue Code of 1986 is
amended--
(A) by striking subsections (c), (d), (f), and (i),
(B) by redesignating subsections (g), (h), and (j) as
subsections (c), (d), and (e), respectively, and
(C) in subsection (c), as so redesignated--
(i) by striking paragraph (1) and redesignating paragraphs
(2) and (3) as paragraphs (1) and (2), respectively, and
(ii) in paragraph (2) (as so redesignated), by striking
``moving expenses of his spouse and dependents'' and all that
follows and inserting ``moving expenses of his spouse and
dependents as if his spouse commenced work as an employee at
a new principal place of work at such location.''.
(2) Section 23 of such Code is amended by striking
``217(h)(3)'' each place it appears in subsections (d)(3) and
(e) and inserting ``217(d)(3)''.
(c) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __21. PERMANENT EXTENSION OF LIMITATION ON WAGERING
LOSSES.
(a) In General.--The second sentence of section 165(d) of
the Internal Revenue Code of 1986 is amended by striking ``in
the case of taxable years beginning after December 31, 2017,
and before January 1, 2026,''.
(b) Effective Date.--The amendments made by this section
shall not apply to taxable years beginning after December 31,
2020.
SEC. __22. INCREASE IN ESTATE AND GIFT TAX EXEMPTION MADE
PERMANENT.
(a) In General.--Section 2010(c)(3)(A) of the Internal
Revenue Code of 1986 is amended by striking ``$5,000,000''
and inserting ``$10,000,000''.
(b) Conforming Amendments.--
(1) Section 2010(c)(3) of the Internal Revenue Code of 1986
is amended by striking subparagraph (C).
(2) Subsection (g) of section 2001 of such Code is amended
to read as follows:
``(g) Modifications to Gift Tax Payable To Reflect
Different Tax Rates.--For purposes of applying subsection
(b)(2) with respect to 1 or more gifts, the rates of tax
under subsection (c) in effect at the decedent's death shall,
in lieu of the rates of tax in effect at the time of such
gifts, be used both to compute--
``(1) the tax imposed by chapter 12 with respect to such
gifts, and
``(2) the credit allowed against such tax under section
2505, including in computing--
``(A) the applicable credit amount under section
2505(a)(1), and
``(B) the sum of the amounts allowed as a credit for all
preceding periods under section 2505(a)(2).''.
(c) Effective Date.--The amendments made by this section
shall apply to estates of decedents dying and gifts made
after December 31, 2020.
SEC. __23. INCREASE IN ALTERNATIVE MINIMUM TAX EXEMPTION MADE
PERMANENT.
(a) In General.--Section 55(d) of the Internal Revenue Code
of 1986 is amended--
(1) in paragraph (1)--
(A) by striking ``$78,750'' in subparagraph (A) and
inserting ``$109,400'', and
(B) by striking ``$50,600'' in subparagraph (B) and
inserting ``$70,300'', and
(2) in paragraph (2)--
(A) by striking ``$150,000'' in subparagraph (A) and
inserting ``$1,000,000'', and
(B) by striking subparagraphs (B) and (C) and inserting the
following:
``(B) 50 percent of the dollar amount applicable under
subparagraph (A) in the case of a taxpayer described in
subparagraph (B) or (C) of paragraph (1), and
``(C) 50 percent of $150,000 in the case of a taxpayer
described in paragraph (1)(D).''.
(b) Inflation Adjustment.--
(1) In general.--Section 55(d)(3)(A)(ii) of the Internal
Revenue Code of 1986 is amended to read as follows:
``(ii) the cost-of-living adjustment determined under
section 1(f)(3) for the calendar year in which the taxable
year begins, by substituting for `calendar year 2016' in
subparagraph (A)(ii) thereof--
``(I) `calendar year 2011' in the case of the dollar
amounts described in clauses (i), (iv), and (v) of
subparagraph (B), and
``(II) `calendar year 2017' in the case of the dollar
amounts described in clauses (ii) and (iii) of subparagraph
(B).''.
(2) Conforming amendments.--Section 55(d)(3)(B) of such
Code is amended--
(A) by striking ``subparagraphs (A), (B), and (D) of
paragraph (1), and'' in clause (ii) and inserting
``subparagraphs (A) and (B) of paragraph (1),'',
(B) by striking ``subparagraphs (A) and (B) of paragraph
(2).'' in clause (iii) and inserting ``paragraph (2)(A),'',
and
(C) by adding at the end the following:
``(iv) the dollar amount contained in paragraph (1)(D), and
``(v) the dollar amount contained in paragraph (2)(C).''.
(c) Treatment of Unearned Income of Minor Children.--
Section 59 of the Internal Revenue Code of 1986 is amended by
striking subsection (j).
(d) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2020.
SEC. __24. TECHNICAL AMENDMENT.
Section 11000 of Public Law 115-97 is amended by
redesignating subsection (a) as subsection (b) and by
inserting before subsection (b) (as so redesignated) the
following new subsection:
``(a) Short Title.--This title may be cited as the `Tax
Cuts and Jobs Act'.''.
______