[Congressional Record Volume 167, Number 137 (Monday, August 2, 2021)]
[Senate]
[Pages S5627-S5630]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 2232. Mr. HOEVEN (for himself and Mr. Wyden) submitted an 
amendment intended to be proposed to amendment SA 2137 proposed by Mr. 
Schumer (for Ms. Sinema (for herself, Mr. Portman, Mr. Manchin, Mr. 
Cassidy, Mrs. Shaheen, Ms. Collins, Mr. Tester, Ms. Murkowski, Mr. 
Warner, and Mr. Romney)) to the bill H.R. 3684, to authorize funds for 
Federal-aid highways, highway safety programs, and transit programs, 
and for other purposes; which was ordered to lie on the table; as 
follows:

        At the end of title IV of division H, add the following:

     SEC. 804__. MOVE AMERICA BONDS.--

       (a) In General.--
       (1) Move america bonds.--Subpart A of part IV of subchapter 
     B of chapter 1 of the Internal Revenue Code of 1986 is 
     amended by inserting after section 142 the following new 
     section:

     ``SEC. 142A. MOVE AMERICA BONDS.

       ``(a) In General.--
       ``(1) Treatment as exempt facility bond.--Except as 
     otherwise provided in this section, a Move America bond shall 
     be treated for purposes of this part as an exempt facility 
     bond.
       ``(2) Exceptions.--
       ``(A) No government ownership requirement.--Paragraph (1) 
     of section 142(b) shall not apply to any Move America bond.
       ``(B) Special rules for high-speed rail bonds.--Paragraphs 
     (2) and (3) of section 142(i) shall not apply to any Move 
     America bond described in subsection (b)(6).
       ``(C) Special rules for highway and surface transportation 
     facilities.--Paragraphs (2), (3), and (4) of section 142(m) 
     shall not apply to any Move America bond described in 
     subsection (b)(7).
       ``(b) Move America Bond.--For purposes of this part, the 
     term `Move America bond' means any bond issued as part of an 
     issue 95 percent or more of the net proceeds of which are 
     used to provide--
       ``(1) airports,
       ``(2) docks and wharves, including--
       ``(A) waterborne mooring infrastructure,
       ``(B) dredging in connection with a dock or wharf, and
       ``(C) any associated rail and road infrastructure for the 
     purpose of integrating modes of transportation,
       ``(3) mass commuting facilities,
       ``(4) facilities for the furnishing of water (within the 
     meaning of section 142(e)),
       ``(5) sewage facilities,
       ``(6) railroads (as defined in section 20102 of title 49, 
     United States Code) and any associated rail and road 
     infrastructure for the purpose of integrating modes of 
     transportation,
       ``(7) any--
       ``(A) surface transportation project which is eligible for 
     Federal assistance under title 23, United States Code (as in 
     effect on the date of the enactment of this section),
       ``(B) project for an international bridge or tunnel for 
     which an international entity authorized under Federal or 
     State law is responsible and which is eligible for Federal 
     assistance under title 23, United States Code (as so in 
     effect), or
       ``(C) facility for the transfer of freight from truck to 
     rail or rail to truck (including any temporary storage 
     facilities directly related to such transfers) which is 
     eligible for Federal assistance under either title 23 or 
     title 49, United States Code (as so in effect),
       ``(8) flood diversions,
       ``(9) inland waterways, including construction and 
     rehabilitation expenditures for navigation on any inland or 
     intracoastal waterways of the United States (within the 
     meaning of section 4042(d)(2)), or
       ``(10) rural broadband service infrastructure.
       ``(c) Definitions.--For purposes of this section--
       ``(1) Flood diversions.--The term `flood diversion' means 
     any flood damage risk reduction project authorized under any 
     Act for authorizing water resources development projects.
       ``(2) Rural broadband service infrastructure.--The term 
     `rural broadband service infrastructure' means the 
     construction, improvement, or acquisition of facilities and 
     equipment for the provision of broadband services (as defined 
     in section 601 of the Rural Electrification Act of 1936) 
     which--
       ``(A) meet the minimum requirements in effect under section 
     601(e) of such Act, and
       ``(B) will be provided in an area which--
       ``(i) is a rural area (as defined in section 601 of such 
     Act), and
       ``(ii) meets the requirements of clauses (i) and (ii) of 
     section 601(d)(2)(A) of such Act.
       ``(d) Move America Volume Cap.--
       ``(1) In general.--The aggregate face amount of Move 
     America bonds issued pursuant to an issue, when added to the 
     aggregate face amount of Move America bonds previously issued 
     by the issuing authority during the calendar year, shall not 
     exceed such

[[Page S5628]]

     issuing authority's Move America volume cap for such year.
       ``(2) Move america volume cap.--For purposes of this 
     subsection--
       ``(A) In general.--The Move America volume cap for any 
     calendar year is an amount equal to 25 percent of the State 
     ceiling under section 146(d) for such State for such calendar 
     year.
       ``(B) Allocation of volume cap.--Each State may allocate 
     the Move America volume cap of such State among governmental 
     units (or other authorities) in such State having authority 
     to issue private activity bonds.
       ``(3) Carryforwards.--
       ``(A) In general.--If--
       ``(i) an issuing authority's Move America volume cap, 
     exceeds
       ``(ii) the aggregate amount of Move America bonds issued 
     during such calendar year by such authority,
     any Move America bond issued by such authority during the 5-
     calendar-year period following such calendar year shall not 
     be taken into account under paragraph (1) to the extent the 
     amount of such bonds does not exceed the amount of such 
     excess. Any excesses arising under this paragraph shall be 
     used under this paragraph in the order of calendar years in 
     which the excesses arose.
       ``(B) Reallocation of unused carryforwards.--
       ``(i) In general.--The Move America volume cap under 
     paragraph (2)(A) for any State for any calendar year shall be 
     increased by any amount allocated to such State by the 
     Secretary under clause (ii).
       ``(ii) Reallocation.--The Secretary shall allocate to each 
     qualified State for any calendar year an amount which bears 
     the same ratio to the aggregate unused carryforward amounts 
     of all issuing authorities in all States for such calendar 
     year as the qualified State's population for the calendar 
     year bears to the population of all qualified States for the 
     calendar year. For purposes of the preceding sentence, 
     population shall be determined in accordance with section 
     146(j).
       ``(iii) Qualified state.--For purposes of this 
     subparagraph, the term `qualified State' means, with respect 
     to a calendar year, any State--

       ``(I) which allocated its entire Move America volume cap 
     for the preceding calendar year, and
       ``(II) for which a request is made (not later than May 1 of 
     the calendar year) to receive an allocation under clause 
     (ii).

       ``(iv) Unused carryforward amount.--For purposes of this 
     paragraph, the term `unused carryforward amount' means, with 
     respect to any issuing authority for any calendar year, the 
     excess of--

       ``(I) the amount of the excess described in subparagraph 
     (A) for the sixth preceding calendar year, over
       ``(II) the amount of bonds issued by such issuing authority 
     to which subparagraph (A) applied during the 5 preceding 
     calendar years.

       ``(4) Facility must be located within state.--
       ``(A) In general.--No portion of the Move America volume 
     cap of an issuing authority for any calendar year may be used 
     with respect to financing for a facility located outside of 
     the authority's State.
       ``(B) Exception for certain facilities where state will get 
     proportionate share of benefit.--Subparagraph (A) shall not 
     apply to any Move America bond the proceeds of which are used 
     to provide a facility described in paragraph (4) or (5) of 
     subsection (b) if the issuer establishes that the State's 
     share of the use of the facility will equal or exceed the 
     State's share of the private activity bonds issued to finance 
     the facility.
       ``(e) Applicability of Certain Federal Laws.--
       ``(1) In general.--An issue shall not be treated as an 
     issue under subsection (b) unless the facility for which the 
     proceeds of such issue are used meets the requirements 
     applicable to construction, alteration, or repair of similar 
     facilities under any Federal law that would apply if the 
     facility were funded or financed under any other Federal 
     program (including under titles 23, 40, and 49, United States 
     Code) which would otherwise apply to similar facilities.
       ``(2) Public transportation capital projects.--In addition 
     to the requirements of paragraph (1), an issue the proceeds 
     of which are used to finance a capital project (as defined in 
     section 5302(3) of title 49, United States Code) relating to 
     public transportation (as defined in section 5302(14) of such 
     title) shall not be treated as an issue under subsection (b) 
     unless such project complies with the requirements of chapter 
     53 of title 49, United States Code.
       ``(f) Special Rule for Environmental Remediation Costs for 
     Docks and Wharves.--For purposes of this section, amounts 
     used for working capital expenditures relating to 
     environmental remediation required under State or Federal law 
     at or near a facility described in subsection (b)(2) 
     (including environmental remediation in the riverbed and land 
     within or adjacent to the Federal navigation channel used to 
     access such facility) shall be treated as an amount used to 
     provide for such a facility.
       ``(g) Regulations.--The Secretary shall prescribe such 
     regulations as may be necessary to carry out the purposes of 
     this section, including regulations requiring States to 
     report the amount of Move America volume cap of the State 
     carried forward for any calendar year under subsection 
     (d)(3).''.
       (2) Conforming amendment.--The table of sections for 
     subpart A of part IV of subchapter B of chapter 1 of such 
     Code is amended by inserting after the item relating to 
     section 142 the following new item:

``Sec. 142A. Move America bonds.''.
       (b) Application of Other Private Activity Bond Rules.--
       (1) Treatment under private activity bond volume cap.--
     Subsection (g) of section 146 of the Internal Revenue Code of 
     1986, as amended by sections 80401 and 80402, is amended by 
     striking ``and'' at the end of paragraph (5), by striking the 
     period at the end of paragraph (6) and inserting ``, and'', 
     and by inserting after paragraph (6) the following new 
     paragraph:
       ``(7) any Move America bond.''.
       (2) Special rule on use for land acquisition.--Subparagraph 
     (A) of section 147(c)(1) of the Internal Revenue Code of 1986 
     is amended by inserting ``(50 percent in the case of any 
     issue of Move America bonds)'' after ``25 percent''.
       (3) Special rules for rehabilitation expenditures.--
       (A) Inclusion of certain expenditures.--Subparagraph (B) of 
     section 147(d)(3) of the Internal Revenue Code of 1986 is 
     amended by inserting ``, except that, in the case of any Move 
     America bond, such term shall include any expenditure 
     described in clause (v) thereof'' before the period at the 
     end.
       (B) Period for expenditures.--Subparagraph (C) of section 
     147(d)(3) of such Code is amended by inserting ``(5 years, in 
     the case of any Move America bond)'' after ``2 years''.
       (c) Treatment Under the Alternative Minimum Tax.--
     Subparagraph (C) of section 57(a)(5) of the Internal Revenue 
     Code of 1986 is amended by adding at the end the following 
     new clause:
       ``(vii) Exception for move america bonds.--For purposes of 
     clause (i), the term `private activity bond' shall not 
     include any Move America bond (as defined in section 
     142A).''.
       (d) Effective Date.--The amendments made by this section 
     shall apply to obligations issued in calendar years beginning 
     after the date of the enactment of this Act.

     SEC. 804__. MOVE AMERICA CREDITS.

       (a) In General.--Subpart D of part IV of subchapter A of 
     chapter 1 of the Internal Revenue Code of 1986 is amended by 
     inserting after the section 42 the following new section:

     ``SEC. 42A. MOVE AMERICA CREDITS.

       ``(a) Move America Equity Credits.--
       ``(1) In general.--For purposes of section 38, the Move 
     America equity credit for any taxable year in the credit 
     period is an amount equal to 10 percent of the qualified 
     basis of each qualified facility.
       ``(2) Definitions.--For purposes of this section--
       ``(A) Qualified basis.--
       ``(i) In general.--The qualified basis of any qualified 
     facility is the portion of the eligible basis of such 
     facility to which the State has allocated an amount of the 
     State credit limitation under subsection (c)(3)(A)(i).
       ``(ii) Determination.--The qualified basis of a facility 
     for purposes of all taxable years in the credit period shall 
     be determined as of the date of the last day of the calendar 
     year in which the qualified facility is placed in service.
       ``(iii) Exception.--Notwithstanding any other provision of 
     this section, the qualified basis of any qualified facility 
     shall be zero unless the chief executive officer (or the 
     equivalent) of the local jurisdiction in which the qualified 
     facility is located is provided a reasonable opportunity to 
     comment on the qualified facility.
       ``(B) Qualified facility.--The term `qualified facility' 
     means a facility described in section 142A(b), but only if 
     such facility--
       ``(i) meets the requirements applicable to similar 
     facilities under any Federal law which would apply if the 
     facility were financed under any other Federal program 
     (including titles 23, 40, and 49, United States Code),
       ``(ii) complies with the requirements of chapter 53 of 
     title 49, United States Code, in the case of a capital 
     project (as defined in section 5302(3) of title 49, United 
     States Code) relating to public transportation (as defined in 
     section 5302(14) of such title), and
       ``(iii) will be generally available for public use 
     throughout the credit period.
       ``(C) Credit period.--
       ``(i) In general.--Except as provided in clause (ii), the 
     credit period with respect to any qualified facility is the 
     period of 10 taxable years beginning with the first taxable 
     year beginning in the calendar year in which the facility is 
     placed in service.
       ``(ii) Early termination.--If at any time during the 10-
     taxable-year period described in clause (i) a facility ceases 
     to be a qualified facility, or ceases and then recommences to 
     be a qualified facility, the credit period with respect to 
     such facility shall include only the taxable years in such 
     10-year period in which the facility was a qualified facility 
     for the entire taxable year.
       ``(iii) Dispositions of property or interest relating to 
     qualified facility.--A facility shall not cease to be a 
     qualified facility solely by reason of the disposition of the 
     facility (or an interest therein) if it is reasonably 
     expected that such facility will otherwise continue to be a 
     qualified facility.
       ``(iv) Treatment of credit in case of disposition.--If at 
     any time during the 10-taxable-year period described in 
     clause (i) a qualified facility (or an interest therein) is 
     disposed of--

[[Page S5629]]

       ``(I) the credit under paragraph (1) for any year in such 
     period beginning after the date of the disposal shall be 
     allowed to the acquiring person, and not to the person 
     disposing of the facility (or interest), and
       ``(II) the credit under paragraph (1) for the year of the 
     disposal shall be allocated between such persons on the basis 
     of the number of days during such year the facility (or 
     interest) was held by each.

       ``(3) Reallocation.--
       ``(A) In general.--If any qualified facility is not placed 
     in service within 3 years of the date of the allocation under 
     subsection (c)(3), the State shall rescind the allocation 
     under subsection (c)(3)(A)(i). Any allocation so rescinded 
     may be reallocated by the State under subsection (c) 
     (including to qualified infrastructure funds for purposes of 
     the credit under subsection (b)) within the calendar year in 
     which it is so rescinded.
       ``(B) Reversion.--Any rescinded allocation which is not 
     reallocated under subparagraph (A) by the last day of the 
     calendar year in which it is so rescinded shall revert to 
     inclusion in the State's Move America volume cap under 
     section 142A(d) as if it had never been exchanged under 
     subsection (c)(1).
       ``(C) No multiple reallocations.--Any rescinded allocation 
     which is reallocated under subparagraph (A) and is 
     subsequently rescinded shall not be further reallocated and 
     shall immediately revert to inclusion in the Move America 
     volume cap as provided in subparagraph (B).
       ``(4) Coordination with deduction for depreciation, etc.--
     The basis of any property taken into account in determining 
     the qualified basis of a qualified facility with respect to 
     which a credit is allowed under this section shall be reduced 
     by the aggregate amount of the credit allowable under this 
     section during all taxable years in the credit period which 
     is properly allocable to the cost basis of such property. The 
     Secretary shall provide for adjustments to basis in cases 
     where the taxpayer is not allowed a full credit for all years 
     in the credit period.
       ``(b) Move America Infrastructure Fund Credits.--
       ``(1) Allowance of credit.--
       ``(A) In general.--For purposes of section 38, in the case 
     of a taxpayer who holds a Move America investment on a credit 
     allowance date of such investment which occurs during the 
     taxable year, the Move America infrastructure fund credit for 
     such taxable year is an amount equal to 5 percent of the 
     amount paid to the qualified infrastructure fund for such 
     investment at its original issue.
       ``(B) Credit allowance date.--For purposes of subparagraph 
     (A), except as provided in paragraph (3), the term `credit 
     allowance date' means with respect to any Move America 
     investment--
       ``(i) the date on which such investment is initially made, 
     and
       ``(ii) each of the 9 anniversary dates of such date 
     thereafter.
       ``(2) Definitions.--For purposes of this section--
       ``(A) Move america investment.--
       ``(i) In general.--The term `Move America investment' means 
     any equity investment in a qualified infrastructure fund, 
     if--

       ``(I) such investment is acquired by the taxpayer at its 
     original issue solely in exchange for cash,
       ``(II) substantially all of such cash is used by the 
     qualified infrastructure fund to make qualified investments, 
     and
       ``(III) such investment is designated for purposes of this 
     subsection by the qualified infrastructure fund, including a 
     designation of the qualified investment which will be made 
     with such investment.

       ``(ii) Limitation.--

       ``(I) In general.--The maximum amount of equity investments 
     issued by a qualified infrastructure fund in a calendar year 
     which may be designated under clause (i)(III) by such fund 
     shall not exceed 200 percent of the portion of the State 
     credit limitation allocated under subsection (c)(3)(A)(ii) to 
     such fund in such calendar year.
       ``(II) Expiration.--If the limitation determined under 
     subclause (I) with respect to an infrastructure fund for a 
     calendar year exceeds the amount of equity investments 
     designated under clause (i)(III) by such fund in such year, 
     the State shall rescind such excess allocation. Any 
     allocation so rescinded may be reallocated by the State under 
     subsection (c) (including to qualified facilities for 
     purposes of the credit under subsection (a)) within the 
     immediately succeeding calendar year.
       ``(III) Reversion.--Any rescinded allocation which is not 
     reallocated under subclause (II) by the last day of such 
     immediately succeeding calendar year shall revert to 
     inclusion in the State's Move America volume cap under 
     section 142A(d) as if it had never been exchanged under 
     subsection (c)(1).
       ``(IV) No multiple reallocations.--Any rescinded allocation 
     which is reallocated under subclause (II) and is subsequently 
     rescinded shall not be further reallocated and shall 
     immediately revert to inclusion in the Move America volume 
     cap as provided in subclause (III).

       ``(iii) Safe harbor for determining use of cash.--The 
     requirement of clause (i)(II) shall be treated as met if at 
     least 95 percent of the aggregate gross assets of the 
     qualified infrastructure fund (determined without regard to 
     any cash received under clause (i)(I) that has not been 
     invested in any other asset before the date that is 3 years 
     after the date such cash is received) are invested in 
     qualified investments.
       ``(iv) Treatment of subsequent purchasers.--The term `Move 
     America investment' includes any equity investment which 
     would (but for clause (i)(I)) be a Move America investment in 
     the hands of the taxpayer if such investment was a Move 
     America investment in the hands of a prior holder.
       ``(B) Qualified infrastructure fund.--The term `qualified 
     infrastructure fund' means--
       ``(i) a State infrastructure bank established under section 
     610 of title 23, United States Code,
       ``(ii) a water pollution control revolving fund established 
     under title VI of the Federal Water Pollution Control Act (33 
     U.S.C. 1381 et seq.),
       ``(iii) a drinking water treatment revolving loan fund 
     established under section 1452 of the Safe Drinking Water Act 
     (42 U.S.C. 300j-12), or
       ``(iv) an equivalent fund established or designated by the 
     State or any instrumentality thereof and certified by the 
     Secretary as having a primary purpose of financing qualified 
     facilities.
     In the case of a fund described in clause (ii) or (iii), the 
     amount of any Move America investment shall not be included 
     in determining the amount of State or other non-Federal 
     contributions to such fund.
       ``(C) Qualified investment.--The term `qualified 
     investment' means an investment (whether by loan, loan 
     guarantee, or equity investment) in--
       ``(i) qualified facilities, or
       ``(ii) in the case of a fund described in clause (i), (ii), 
     or (iii) of subparagraph (B), projects and activities for 
     which such funds are authorized to be used under any other 
     provision of law.
       ``(3) Early termination.--
       ``(A) In general.--If at any time during the compliance 
     period the fund which issued a Move America investment ceases 
     to be a qualified infrastructure fund, or ceases and then 
     recommences to be a qualified infrastructure fund, any date 
     described in paragraph (1)(B) (including the date described 
     in clause (i) thereof) occurring in--
       ``(i) the taxable year in which the fund ceased to be a 
     qualified infrastructure fund, or
       ``(ii) any other taxable year in such period in which the 
     fund is not a qualified infrastructure fund for the entire 
     taxable year,
     shall not be treated as a credit allowance date for purposes 
     of paragraph (1).
       ``(B) Compliance period.--For purposes of subparagraph (A), 
     the term `compliance period' means the 10-taxable-year period 
     beginning with the taxable year that includes the date of the 
     original issue of the Move America investment.
       ``(C) Loss of qualification.--A fund shall cease to be a 
     qualified infrastructure fund as of the date more than 5 
     percent of the investments made by the fund are not qualified 
     investments. For purposes of the preceding sentence, the 
     amount of any cash received under subparagraph (A)(i)(I) that 
     has not been invested in any other asset before the date that 
     is 3 years after the date such cash is received shall not be 
     taken into account in determining investments made by the 
     fund.
       ``(D) Expiration of credit.--If substantially all of the 
     cash paid for any Move America investment is not used to make 
     qualified investments designated under paragraph 
     (2)(A)(i)(III) within 3 years of the date of original issue 
     of such investment, any date described in paragraph (1)(B) 
     occurring in a taxable year which ends after the date which 
     is 3 years after such date of original issue shall not be 
     treated as a credit allowance date for purposes of paragraph 
     (1).
       ``(c) Move America Credit Allocation.--
       ``(1) Exchange of move america bond volume cap.--
       ``(A) In general.--If a State has in effect a qualified 
     allocation plan for a calendar year, the State may exchange 
     (in such manner as the Secretary may prescribe) all or a 
     portion of the State's Move America volume cap under section 
     142A(d) for such year for a State credit limitation.
       ``(B) Limitation.--The amount of a State's Move America 
     volume cap for a calendar year which may be exchanged under 
     subparagraph (A) shall not include any portion of such cap 
     which is attributable to an amount of State credit limitation 
     which has reverted under paragraph (3)(D) or subsection 
     (a)(3)(B) or (b)(2)(A)(ii)(IV).
       ``(2) State credit limitation.--For purposes of this 
     section, the State credit limitation with respect to any 
     State for a calendar year is a dollar amount equal to 25 
     percent of the Move America volume cap exchanged under 
     paragraph (1) for such calendar year.
       ``(3) Allocation.--
       ``(A) In general.--A State may allocate the State credit 
     limitation, according to the qualified allocation plan, for 
     any calendar year among--
       ``(i) qualified facilities in the State for purposes of the 
     Move America equity credit under subsection (a), and
       ``(ii) qualified infrastructure funds in the State for 
     purposes of the Move America infrastructure fund credit under 
     subsection (b).
       ``(B) Qualified allocation plan.--
       ``(i) In general.--For purposes of this subsection, the 
     term `qualified allocation plan' means any plan--

       ``(I) which sets forth selection criteria to be used in 
     determining infrastructure priorities of the State and 
     allocating the State credit limitation among facilities (in 
     accordance with clause (ii)) and infrastructure funds in the 
     State, and

[[Page S5630]]

       ``(II) which provides a procedure that the State (or an 
     agent or other private contractor of the State) will follow 
     in monitoring for noncompliance with the provisions of this 
     section and in notifying the Internal Revenue Service of such 
     noncompliance.

       ``(ii) Limitation based on facility feasibility for move 
     america equity credits.--

       ``(I) In general.--In the case of an allocation with 
     respect to any qualified facility for purposes of the Move 
     America equity credit under subsection (a), such allocation 
     shall not exceed the minimum amount which the State 
     transportation authority or other applicable agency 
     determines is required for the financial feasibility of the 
     facility and its viability for completion and availability 
     for public use throughout the credit period.
       ``(II) Minimum feasibility determination.--In making the 
     determination under subclause (I), such entity shall consider 
     the sources and uses of funds and the total financing planned 
     for the facility, any proceeds or receipts expected to be 
     generated by reason of tax benefits, the reasonableness of 
     the developmental and operational costs of the facility over 
     the full expected operational life of the facility, ancillary 
     costs (including right-of-way and procurement costs), 
     financing costs, and retained and transferred risk.

       ``(C) Special rules relating to move america equity 
     credit.--
       ``(i) Limitation.--The amount allocated to a qualified 
     facility under subparagraph (A)(i) shall not exceed the 
     eligible basis of such facility.
       ``(ii) Eligible basis.--For purposes of this section, 
     except as provided in clause (iii), the eligible basis of any 
     qualified facility is the lesser of--

       ``(I) the portion of the basis of such facility which is 
     attributable to the aggregate amount of equity investment of 
     all taxpayers in the costs of the facility which are subject 
     to the allowance for depreciation (determined as of the last 
     day of the calendar year in which the facility is placed in 
     service), or
       ``(II) 20 percent of the costs of the facility which are 
     subject to the allowance for depreciation (determined as of 
     the last day of the calendar year in which the facility is 
     placed in service).

       ``(iii) Exclusion of government assistance.--Eligible basis 
     shall not include any portion of the basis of such facility 
     which is attributable to any assistance or financing provided 
     by a Federal, State, or local government (determined as of 
     the last day of the calendar year in which the facility is 
     placed in service).
       ``(D) Reversion of unallocated limitation.--Any portion of 
     the State credit limitation for any calendar year which 
     remains unallocated as of the last day of such calendar year 
     shall revert to inclusion in the State's Move America volume 
     cap under section 142A(d) as if it had never been exchanged 
     under paragraph (1).''.
       (b) Credits Made Part of General Business Credit.--
     Subsection (b) of section 38 of the Internal Revenue Code of 
     1986 is amended--
       (1) by striking ``plus'' at the end of paragraph (32),
       (2) by striking the period at the end of paragraph (33) and 
     inserting a comma, and
       (3) by adding at the end the following new paragraphs:
       ``(34) the Move America equity credit under section 
     42A(a)(1), plus
       ``(35) the Move America infrastructure fund credit under 
     section 42A(b)(1).''.
       (c) Treatment Under Alternative Minimum Tax and Base 
     Erosion Tax.--
       (1) Alternative minimum tax.--Section 38(c)(4)(B) of the 
     Internal Revenue Code of 1986 is amended by redesignating 
     clauses (iv) through (xii) as clauses (vi) through (xiv), 
     respectively, and by inserting after clause (iii) the 
     following new clauses:
       ``(iv) the credit determined under section 42A(a)(1),
       ``(v) the credit determined under section 42A(b)(1),''.
       (2) Base erosion tax.--Section 59A(b)(1)(B)(ii) of such 
     Code is amended by striking ``plus'' at the end of subclause 
     (I), by redesignating subclause (II) as subclause (III), and 
     by inserting after subclause (I) the following new subclause:

       ``(II) the credit allowed under section 38 for the taxable 
     year which is properly allocable to the sum of the Move 
     America equity credit under section 42A(a)(1) and the Move 
     America infrastructure fund credit under section 42A(b)(1), 
     plus''.

       (d) Clerical Amendment.--The table of sections for subpart 
     D of part IV of subchapter A of chapter 1 of the Internal 
     Revenue Code of 1986 is amended by inserting after the item 
     relating to section 42 the following new item:

``Sec. 42A. Move America credits.''.
       (e) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after the date of the 
     enactment of this Act.
       (f) Reporting.--A State shall, at such time and in such 
     manner as the Secretary of the Treasury shall require, 
     report--
       (1) to the Secretary of the Treasury--
       (A) the amount of the Move America volume cap of the State 
     for the calendar year which is exchanged under section 
     42A(c)(1) of the Internal Revenue Code of 1986 for a State 
     credit limitation;
       (B) the amount (if any) of the State credit limitation 
     allocated under section 42A(c)(3)(A)(i) of such Code to 
     qualified facilities, the amount so allocated to each such 
     facility, and the taxpayer with respect to such facility 
     (including the name of the taxpayer and any other identifying 
     information as the Secretary of the Treasury shall require); 
     and
       (C) the amount (if any) of the State credit limitation 
     allocated under section 42A(c)(3)(A)(ii) of such Code to 
     qualified infrastructure funds, the amount so allocated to 
     each such fund, and each taxpayer holding any Move America 
     investment with respect to any such fund (including the name 
     of the taxpayer and any other identifying information as the 
     Secretary of the Treasury shall require);
       (2) to the Secretary of the Treasury and any taxpayer who 
     is the sponsor of a qualified facility receiving an 
     allocation under section 42A(c)(3)(A)(i) of such Code, the 
     date on which the qualified facility is placed in service; 
     and
       (3) to the Secretary of the Treasury and any taxpayer 
     holding a Move America investment, a certification that the 
     entity which issued the investment is a qualified 
     infrastructure fund and that the investment will be used to 
     make qualified investments designated for purposes of section 
     42A(b)(2)(A)(i)(III) of the Internal Revenue Code of 1986.
     For purposes of this subsection, any term used in this 
     subsection that is also used in section 42A or 142A of such 
     Code has the same meaning as when used in such section.
                                 ______