[Congressional Record Volume 170, Number 18 (Wednesday, January 31, 2024)]
[House]
[Pages H343-H358]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]




        TAX RELIEF FOR AMERICAN FAMILIES AND WORKERS ACT OF 2024

  Mr. SMITH of Missouri. Mr. Speaker, I move to suspend the rules and 
pass the bill (H.R. 7024) to make improvements to the child tax credit, 
to provide tax incentives to promote economic growth, to provide 
special rules for the taxation of certain residents of Taiwan with 
income from sources within the United States, to provide tax relief 
with respect to certain Federal disasters, to make improvements to the 
low-income housing tax credit, and for other purposes, as amended.
  The Clerk read the title of the bill.
  The text of the bill is as follows:

                               H.R. 7024

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

     SECTION 1. SHORT TITLE; TABLE OF CONTENTS; ETC.

       (a) Short Title.--This Act may be cited as the ``Tax Relief 
     for American Families and Workers Act of 2024''.
       (b) Amendment of 1986 Code.--Except as otherwise expressly 
     provided, whenever in this Act an amendment or repeal is 
     expressed in terms of an amendment to, or repeal of, a 
     section or other provision, the reference shall be considered 
     to be made to a section or other provision of the Internal 
     Revenue Code of 1986.
       (c) Table of Contents.--The table of contents of this Act 
     is as follows:

Sec. 1. Short title; table of contents; etc.

                TITLE I--TAX RELIEF FOR WORKING FAMILIES

Sec. 101. Per-child calculation of refundable portion of child tax 
              credit.
Sec. 102. Increase in refundable portion.
Sec. 103. Inflation of credit amount.
Sec. 104. Rule for determination of earned income.
Sec. 105. Special rule for certain early-filed 2023 returns.

                TITLE II--AMERICAN INNOVATION AND GROWTH

Sec. 201. Deduction for domestic research and experimental 
              expenditures.
Sec. 202. Extension of allowance for depreciation, amortization, or 
              depletion in determining the limitation on business 
              interest.
Sec. 203. Extension of 100 percent bonus depreciation.
Sec. 204. Increase in limitations on expensing of depreciable business 
              assets.

              TITLE III--INCREASING GLOBAL COMPETITIVENESS

    Subtitle A--United States-Taiwan Expedited Double-Tax Relief Act

Sec. 301. Short title.
Sec. 302. Special rules for taxation of certain residents of Taiwan.

    Subtitle B--United States-Taiwan Tax Agreement Authorization Act

Sec. 311. Short title.
Sec. 312. Definitions.
Sec. 313. Authorization to negotiate and enter into agreement.
Sec. 314. Consultations with Congress.
Sec. 315. Approval and implementation of agreement.
Sec. 316. Submission to Congress of agreement and implementation 
              policy.
Sec. 317. Consideration of approval legislation and implementing 
              legislation.
Sec. 318. Relationship of agreement to Internal Revenue Code of 1986.
Sec. 319. Authorization of subsequent tax agreements relative to 
              Taiwan.
Sec. 320. United States treatment of double taxation matters with 
              respect to Taiwan.

         TITLE IV--ASSISTANCE FOR DISASTER-IMPACTED COMMUNITIES

Sec. 401. Short title.
Sec. 402. Extension of rules for treatment of certain disaster-related 
              personal casualty losses.
Sec. 403. Exclusion from gross income for compensation for losses or 
              damages resulting from certain wildfires.
Sec. 404. East Palestine disaster relief payments.

                    TITLE V--MORE AFFORDABLE HOUSING

Sec. 501. State housing credit ceiling increase for low-income housing 
              credit.
Sec. 502. Tax-exempt bond financing requirement.

           TITLE VI--TAX ADMINISTRATION AND ELIMINATING FRAUD

Sec. 601. Increase in threshold for requiring information reporting 
              with respect to certain payees.
Sec. 602. Enforcement provisions with respect to COVID-related employee 
              retention credits.

                TITLE I--TAX RELIEF FOR WORKING FAMILIES

     SEC. 101. PER-CHILD CALCULATION OF REFUNDABLE PORTION OF 
                   CHILD TAX CREDIT.

       (a) In General.--Subparagraph (A) of section 24(h)(5) is 
     amended to read as follows:
       ``(A) In general.--In applying subsection (d)--
       ``(i) the amount determined under paragraph (1)(A) of such 
     subsection with respect to any qualifying child shall not 
     exceed $1,400, and such paragraph shall be applied without 
     regard to paragraph (4) of this subsection, and
       ``(ii) paragraph (1)(B) of such subsection shall be applied 
     by multiplying each of--

       ``(I) the amount determined under clause (i) thereof, and
       ``(II) the excess determined under clause (ii) thereof,

     by the number of qualifying children of the taxpayer.''.
       (b) Conforming Amendment.--The heading of paragraph (5) of 
     section 24(h) is amended by striking ``Maximum amount of'' 
     and inserting ``Special rules for''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2022.

     SEC. 102. INCREASE IN REFUNDABLE PORTION.

       (a) In General.--Paragraph (5) of section 24(h) is amended 
     by redesignating subparagraph (B) as subparagraph (C) and by 
     inserting after subparagraph (A) the following new 
     subparagraph:
       ``(B) Amounts for 2023, 2024, and 2025.--In the case of a 
     taxable year beginning after 2022, subparagraph (A) shall be 
     applied by substituting for `$1,400'--
       ``(i) in the case of taxable year 2023, `$1,800',
       ``(ii) in the case of taxable year 2024, `$1,900', and
       ``(iii) in the case of taxable year 2025, `$2,000'.''.
       (b) Conforming Amendment.--Subparagraph (C) of section 
     24(h)(5), as redesignated by subsection (a), is amended by 
     inserting ``and before 2023'' after ``2018''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2022.

     SEC. 103. INFLATION OF CREDIT AMOUNT.

       (a) In General.--Paragraph (2) of section 24(h) is 
     amended--
       (1) by striking ``amount.--Subsection'' and inserting 
     ``amount.--
       ``(A) In general.--Subsection'', and
       (2) by adding at the end the following new subparagraph:
       ``(B) Adjustment for inflation.--In the case of a taxable 
     year beginning after 2023, the $2,000 amounts in subparagraph 
     (A) and paragraph (5)(B)(iii) 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, determined by substituting `2022' 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.''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2023.

     SEC. 104. RULE FOR DETERMINATION OF EARNED INCOME.

       (a) In General.--Paragraph (6) of section 24(h) of the 
     Internal Revenue Code of 1986 is amended--
       (1) by striking ``credit.--Subsection'' and inserting 
     ``credit.--
       ``(A) In general.--Subsection'', and
       (2) by adding at the end the following new subparagraphs
       ``(B) Rule for determination of earned income.--
       ``(i) In general.--In the case of a taxable year beginning 
     after 2023, if the earned income of the taxpayer for such 
     taxable year is less than the earned income of the taxpayer 
     for the preceding taxable year, subsection (d)(1)(B)(i) may, 
     at the election of the taxpayer, be applied by substituting--

       ``(I) the earned income for such preceding taxable year, 
     for
       ``(II) the earned income for the current taxable year.

       ``(ii) Application to joint returns.--For purposes of 
     clause (i), in the case of a joint return, the earned income 
     of the taxpayer for the preceding taxable year shall be the 
     sum of the earned income of each spouse for such preceding 
     taxable year.''.
       (b) Errors Treated as Mathematical Errors.--Paragraph (2) 
     of section 6213(g) of the Internal Revenue Code of 1986 is 
     amended by striking ``and'' at the end of subparagraph (U), 
     by striking the period at the end of subparagraph (V) and 
     inserting ``, and'', and by inserting after subparagraph (V) 
     the following new subparagraph:
       ``(W) in the case of a taxpayer electing the application of 
     section 24(h)(6)(B) for any taxable year, an entry on a 
     return of earned income pursuant to such section which is 
     inconsistent with the amount of such earned income determined 
     by the Secretary for the preceding taxable year.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2023.

     SEC. 105. SPECIAL RULE FOR CERTAIN EARLY-FILED 2023 RETURNS.

       In the case of an individual who claims, on the taxpayer's 
     return of tax for the first taxable

[[Page H344]]

     year beginning after December 31, 2022, a credit under 
     section 24 of the Internal Revenue Code of 1986 which is 
     determined without regard to the amendments made by sections 
     101 and 102 of this Act, the Secretary of the Treasury (or 
     the Secretary's delegate) shall, to the maximum extent 
     practicable--
       (1) redetermine the amount of such credit (after taking 
     into account such amendments) on the basis of the information 
     provided by the taxpayer on such return, and
       (2) to the extent that such redetermination results in an 
     overpayment of tax, credit or refund such overpayment as 
     expeditiously as possible.

                TITLE II--AMERICAN INNOVATION AND GROWTH

     SEC. 201. DEDUCTION FOR DOMESTIC RESEARCH AND EXPERIMENTAL 
                   EXPENDITURES.

       (a) Delay of Amortization of Domestic Research and 
     Experimental Expenditures.--Section 174 is amended by adding 
     at the end the following new subsection:
       ``(e) Suspension of Application of Section to Domestic 
     Research and Experimental Expenditures.--In the case of any 
     domestic research or experimental expenditures (as defined in 
     section 174A(b)), this section--
       ``(1) shall apply to such expenditures paid or incurred in 
     taxable years beginning after December 31, 2025, and
       ``(2) shall not apply to such expenditures paid or incurred 
     in taxable years beginning on or before such date.''.
       (b) Reinstatement of Expensing for Domestic Research and 
     Experimental Expenditures.--Part VI of subchapter B of 
     chapter 1 is amended by inserting after section 174 the 
     following new section:

     ``SEC. 174A. TEMPORARY RULES FOR DOMESTIC RESEARCH AND 
                   EXPERIMENTAL EXPENDITURES.

       ``(a) Treatment as Expenses.--Notwithstanding section 263, 
     there shall be allowed as a deduction any domestic research 
     or experimental expenditures which are paid or incurred by 
     the taxpayer during the taxable year.
       ``(b) Domestic Research or Experimental Expenditures.--For 
     purposes of this section, the term `domestic research or 
     experimental expenditures' means research or experimental 
     expenditures paid or incurred by the taxpayer in connection 
     with the taxpayer's trade or business other than such 
     expenditures which are attributable to foreign research 
     (within the meaning of section 41(d)(4)(F)).
       ``(c) Amortization of Certain Domestic Research and 
     Experimental Expenditures.--
       ``(1) In general.--At the election of the taxpayer, made in 
     accordance with regulations or other guidance provided by the 
     Secretary, in the case of domestic research or experimental 
     expenditures which would (but for subsection (a)) be 
     chargeable to capital account but not chargeable to property 
     of a character which is subject to the allowance under 
     section 167 (relating to allowance for depreciation, etc.) or 
     section 611 (relating to allowance for depletion), subsection 
     (a) shall not apply and the taxpayer shall--
       ``(A) charge such expenditures to capital account, and
       ``(B) be allowed an amortization deduction of such 
     expenditures ratably over such period of not less than 60 
     months as may be selected by the taxpayer (beginning with the 
     month in which the taxpayer first realizes benefits from such 
     expenditures).
       ``(2) Time for and scope of election.--The election 
     provided by paragraph (1) may be made for any taxable year, 
     but only if made not later than the time prescribed by law 
     for filing the return for such taxable year (including 
     extensions thereof). The method so elected, and the period 
     selected by the taxpayer, shall be adhered to in computing 
     taxable income for the taxable year for which the election is 
     made and for all subsequent taxable years unless, with the 
     approval of the Secretary, a change to a different method (or 
     to a different period) is authorized with respect to part or 
     all of such expenditures. The election shall not apply to any 
     expenditure paid or incurred during any taxable year before 
     the taxable year for which the taxpayer makes the election.
       ``(d) Election to Capitalize Expenses.--In the case of a 
     taxpayer which elects (at such time and in such manner as the 
     Secretary may provide) the application of this subsection, 
     subsections (a) and (c) shall not apply and domestic research 
     or experimental expenditures shall be chargeable to capital 
     account. Such election shall not apply to any expenditure 
     paid or incurred during any taxable year before the taxable 
     year for which the taxpayer makes the election and may be 
     made with respect to part of the expenditures paid or 
     incurred during any taxable year only with the approval of 
     the Secretary.
       ``(e) Special Rules.--
       ``(1) Land and other property.--This section shall not 
     apply to any expenditure for the acquisition or improvement 
     of land, or for the acquisition or improvement of property to 
     be used in connection with the research or experimentation 
     and of a character which is subject to the allowance under 
     section 167 (relating to allowance for depreciation, etc.) or 
     section 611 (relating to allowance for depletion); but for 
     purposes of this section allowances under section 167, and 
     allowances under section 611, shall be considered as 
     expenditures.
       ``(2) Exploration expenditures.--This section shall not 
     apply to any expenditure paid or incurred for the purpose of 
     ascertaining the existence, location, extent, or quality of 
     any deposit of ore or other mineral (including oil and gas).
       ``(3) Software development.--For purposes of this section, 
     any amount paid or incurred in connection with the 
     development of any software shall be treated as a research or 
     experimental expenditure.
       ``(f) Termination.--
       ``(1) In general.--This section shall not apply to amounts 
     paid or incurred in taxable years beginning after December 
     31, 2025.
       ``(2) Change in method of accounting.--In the case of a 
     taxpayer's first taxable year beginning after December 31, 
     2025, paragraph (1) (and the corresponding application of 
     section 174) shall be treated as a change in method of 
     accounting for purposes of section 481 and--
       ``(A) such change shall be treated as initiated by the 
     taxpayer,
       ``(B) such change shall be treated as made with the consent 
     of the Secretary, and
       ``(C) such change shall be applied only on a cut-off basis 
     for any domestic research or experimental expenditures paid 
     or incurred in taxable years beginning after December 31, 
     2025, and no adjustment under section 481(a) shall be 
     made.''.
       (c) Coordination With Certain Other Provisions.--
       (1) Research credit.--
       (A) Section 41(d)(1)(A) is amended by inserting ``or 
     domestic research or experimental expenditures under section 
     174A'' after ``section 174''.
       (B) Section 280C(c)(1) is amended to read as follows:
       ``(1) In general.--The domestic research or experimental 
     expenditures otherwise taken into account under section 174 
     or 174A (as the case may be) shall be reduced by the amount 
     of the credit allowed under section 41(a).''.
       (2) AMT adjustment.--Section 56(b)(2) is amended by 
     striking ``174(a)'' each place it appears and inserting 
     ``174A(a)''.
       (3) Optional 10-year writeoff.--Section 59(e)(2)(B) is 
     amended by striking ``section 174(a) (relating to research 
     and experimental expenditures)'' and inserting ``section 
     174A(a) (relating to temporary rules for domestic research 
     and experimental expenditures)''.
       (4) Qualified small issue bonds.--Section 144(a)(4)(C)(iv) 
     is amended by striking ``174(a)'' and inserting ``174A(a)''.
       (5) Start-up expenditures.--Section 195(c)(1) is amended by 
     striking ``or 174'' in the last sentence and inserting ``174, 
     or 174A''.
       (6) Capital expenditures.--
       (A) Section 263(a)(1)(B) is amended by inserting `` or 
     174A'' after ``174''.
       (B) Section 263A(c)(2) is amended by inserting ``or 174A'' 
     after ``174''.
       (7) Active business computer software royalties.--Section 
     543(d)(4)(A)(i) is amended by inserting ``174A,'' after 
     ``174,''.
       (8) Source rules.--Section 864(g)(2) is amended in the last 
     sentence--
       (A) by striking ``treated as deferred expenses under 
     subsection (b) of section 174'' and inserting ``allowed as an 
     amortization deduction under section 174(a) or section 
     174A(c),'', and
       (B) by striking ``such subsection'' and inserting ``such 
     section (as the case may be)''.
       (9) Basis adjustment.--Section 1016(a)(14) is amended by 
     striking ``deductions as deferred expenses under section 
     174(b)(1) (relating to research and experimental 
     expenditures)'' and inserting ``deductions under section 174 
     or 174A''.
       (10) Small business stock.--Section 1202(e)(2)(B) is 
     amended by striking ``research and experimental expenditures 
     under section 174'' and inserting ``specified research or 
     experimental expenditures under section 174 or domestic 
     research or experimental expenditures under section 174A''.
       (d) Conforming Amendments.--
       (1) Section 13206 of Public Law 115-97 is amended by 
     striking subsection (b) (relating to change in method of 
     accounting).
       (2) The table of sections for part VI of subchapter B of 
     chapter 1 is amended by inserting after the item relating to 
     section 174 the following new item:

``Sec. 174A. Temporary rules for domestic research and experimental 
              expenditures.''.
       (e) Effective Date.--
       (1) In general.--Except as otherwise provided in this 
     subsection, the amendments made by this section shall apply 
     to amounts paid or incurred in taxable years beginning after 
     December 31, 2021.
       (2) Coordination with research credit.--The amendment made 
     by subsection (c)(1)(B) shall apply to taxable years 
     beginning after December 31, 2022.
       (3) Repeal of superceded change in method of accounting 
     rules.--The amendment made by subsection (d)(1) shall take 
     effect as if included in Public Law 115-97.
       (4) No inference with respect to coordination with research 
     credit for prior periods.--The amendment made by subsection 
     (c)(1)(B) shall not be construed to create any inference with 
     respect to the proper application of section 280C(c) of the 
     Internal Revenue Code of 1986 with respect to taxable years 
     beginning before January 1, 2023.
       (f) Transition Rules.--
       (1) In general.--Except as otherwise provided by the 
     Secretary, an election made under subsection (c) or (d) of 
     section 174A of the Internal Revenue Code of 1986 (as added 
     by this section) for the taxpayer's first taxable year 
     beginning after December 31, 2021, shall not fail to be 
     treated as timely made (or as made on the return) if made 
     during the 1-year period beginning on the date of the 
     enactment of this Act on an amended return for the taxpayer's 
     first taxable year beginning after December 31, 2021, or in 
     such other manner as the Secretary may provide.
       (2) Election regarding treatment as change in method of 
     accounting.--In the case of any taxpayer which (as of the 
     date of the enactment of this Act) had adopted a method of 
     accounting provided by section 174 of the Internal Revenue 
     Code of 1986 (as in effect prior to the amendments made by 
     this section) for the taxpayer's first taxable year beginning 
     after December 31, 2021, and elects the application of this 
     paragraph--

[[Page H345]]

       (A) the amendments made by this section shall be treated as 
     a change in method of accounting for purposes of section 481 
     of such Code,
       (B) such change shall be treated as initiated by the 
     taxpayer for the taxpayer's immediately succeeding taxable 
     year,
       (C) such change shall be treated as made with the consent 
     of the Secretary,
       (D) such change shall be applied on a modified cut-off 
     basis, taking into account for purposes of section 481(a) of 
     such Code only the domestic research or experimental 
     expenditures (as defined in section 174A(b) of such Code (as 
     added by this section) and determined by applying the rules 
     of section 174A(e) of such Code) paid or incurred in the 
     taxpayer's first taxable year beginning after December 31, 
     2021, and not allowed as a deduction in such taxable year, 
     and
       (E) in the case of a taxpayer which elects the application 
     of this subparagraph, the amount of such change (as 
     determined under subparagraph (D)) shall be taken into 
     account ratably over the 2-taxable-year period beginning with 
     the taxable year referred to in subparagraph (B).
       (3) Election regarding 10-year writeoff.--
       (A) In general.--Except as otherwise provided by the 
     Secretary, an eligible taxpayer which files, during the 1-
     year period beginning on the date of the enactment of this 
     Act, an amended income tax return for the taxable year 
     described in subparagraph (B)(ii) may elect the application 
     of section 59(e) of the Internal Revenue Code of 1986 with 
     respect to qualified expenditures described in section 
     59(e)(2)(B) of such Code (as amended by subsection (c)(3)) 
     with respect to such taxable year. Such election shall be 
     filed with such amended income tax return and shall be 
     effective only to the extent that such election would have 
     been effective if filed with the original income tax return 
     for such taxable year (determined after taking into account 
     the amendment made by subsection (c)(3)).
       (B) Eligible taxpayer.--For purposes of subparagraph (A), 
     the term ``eligible taxpayer'' means any taxpayer which--
       (i) does not elect the application of paragraph (2), and
       (ii) filed an income tax return for such taxpayer's first 
     taxable year beginning after December 31, 2021, before the 
     earlier of--

       (I) the due date for such return, and
       (II) the date of the enactment of this Act.

       (4) Election regarding coordination with research credit.--
     Except as otherwise provided by the Secretary, an eligible 
     taxpayer (as defined in paragraph (3)(B) without regard to 
     clause (i) thereof) which files, during the 1-year period 
     beginning on the date of the enactment of this Act, an 
     amended income tax return for the taxpayer's first taxable 
     year beginning after December 31, 2021, may, notwithstanding 
     subparagraph (C) of section 280C(c)(2) of the Internal 
     Revenue Code of 1986 make, or revoke, on such amended return 
     the election under such section for such taxable year.

     SEC. 202. EXTENSION OF ALLOWANCE FOR DEPRECIATION, 
                   AMORTIZATION, OR DEPLETION IN DETERMINING THE 
                   LIMITATION ON BUSINESS INTEREST.

       (a) In General.--Section 163(j)(8)(A)(v) is amended by 
     striking ``January 1, 2022'' and inserting ``January 1, 
     2026''.
       (b) Effective Date.--
       (1) In general.--Except as otherwise provided in this 
     subsection, the amendment made by this section shall apply to 
     taxable years beginning after December 31, 2023.
       (2) Election to apply extension retroactively.--In the case 
     of a taxpayer which elects (at such time and in such manner 
     as the Secretary may provide) the application of this 
     paragraph, paragraph (1) shall be applied by substituting 
     ``December 31, 2021'' for ``December 31, 2023''.

     SEC. 203. EXTENSION OF 100 PERCENT BONUS DEPRECIATION.

       (a) In General.--Section 168(k)(6)(A) is amended--
       (1) in clause (i)--
       (A) by striking ``2023'' and inserting ``2026'', and
       (B) by adding ``and'' at the end, and
       (2) by striking clauses (ii), (iii), and (iv), and 
     redesignating clause (v) as clause (ii).
       (b) Property With Longer Production Periods.--Section 
     168(k)(6)(B) is amended--
       (1) in clause (i)--
       (A) by striking ``2024'' and inserting ``2027'', and
       (B) by adding ``and'' at the end, and
       (2) by striking clauses (ii), (iii), and (iv), and 
     redesignating clause (v) as clause (ii).
       (c) Plants Bearing Fruits and Nuts.--Section 168(k)(6)(C) 
     is amended--
       (1) in clause (i)--
       (A) by striking ``2023'' and inserting ``2026'', and
       (B) by adding ``and'' at the end, and
       (2) by striking clauses (ii), (iii), and (iv), and 
     redesignating clause (v) as clause (ii).
       (d) Effective Dates.--
       (1) In general.--Except as otherwise provided in this 
     subsection, the amendments made by this section shall apply 
     to property placed in service after December 31, 2022.
       (2) Plants bearing fruits and nuts.--The amendments made by 
     subsection (c) shall apply to specified plants planted or 
     grafted after December 31, 2022.

     SEC. 204. INCREASE IN LIMITATIONS ON EXPENSING OF DEPRECIABLE 
                   BUSINESS ASSETS.

       (a) In General.--Section 179(b) is amended--
       (1) by striking ``$1,000,000'' in paragraph (1) and 
     inserting ``$1,290,000'', and
       (2) by striking ``$2,500,000'' in paragraph (2) and 
     inserting ``$3,220,000''.
       (b) Inflation Adjustment.--Section 179(b)(6) is amended--
       (1) by striking ``2018'' and inserting ``2024 (2018 in the 
     case of the dollar amount in paragraph (5)(A))'', and
       (2) by striking `` `calendar year 2017'' and inserting `` 
     `calendar year 2024' (`calendar year 2017' in the case of the 
     dollar amount in paragraph (5)(A))''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to property placed in service in taxable years 
     beginning after December 31, 2023.

              TITLE III--INCREASING GLOBAL COMPETITIVENESS

    Subtitle A--United States-Taiwan Expedited Double-Tax Relief Act

     SEC. 301. SHORT TITLE.

       This subtitle may be cited as the ``United States-Taiwan 
     Expedited Double-Tax Relief Act''.

     SEC. 302. SPECIAL RULES FOR TAXATION OF CERTAIN RESIDENTS OF 
                   TAIWAN.

       (a) In General.--Subpart D of part II of subchapter N of 
     chapter 1 is amended by inserting after section 894 the 
     following new section:

     ``SEC. 894A. SPECIAL RULES FOR QUALIFIED RESIDENTS OF TAIWAN.

       ``(a) Certain Income From United States Sources.--
       ``(1) Interest, dividends, and royalties, etc.--
       ``(A) In general.--In the case of interest (other than 
     original issue discount), dividends, royalties, amounts 
     described in section 871(a)(1)(C), and gains described in 
     section 871(a)(1)(D) received by or paid to a qualified 
     resident of Taiwan--
       ``(i) sections 871(a), 881(a), 1441(a), 1441(c)(5), and 
     1442(a) shall each be applied by substituting `the applicable 
     percentage (as defined in section 894A(a)(1)(C))' for `30 
     percent' each place it appears, and
       ``(ii) sections 871(a), 881(a), and 1441(c)(1) shall each 
     be applied by substituting `a United States permanent 
     establishment of a qualified resident of Taiwan' for `a trade 
     or business within the United States' each place it appears.
       ``(B) Exceptions.--
       ``(i) In general.--Subparagraph (A) shall not apply to--

       ``(I) any dividend received from or paid by a real estate 
     investment trust which is not a qualified REIT dividend,
       ``(II) any amount subject to section 897,
       ``(III) any amount received from or paid by an expatriated 
     entity (as defined in section 7874(a)(2)) to a foreign 
     related person (as defined in section 7874(d)(3)), and
       ``(IV) any amount which is included in income under section 
     860C to the extent that such amount does not exceed an excess 
     inclusion with respect to a REMIC.

       ``(ii) Qualified reit dividend.--For purposes of clause 
     (i)(I), the term `qualified REIT dividend' means any dividend 
     received from or paid by a real estate investment trust if 
     such dividend is paid with respect to a class of shares that 
     is publicly traded and the recipient of the dividend is a 
     person who holds an interest in any class of shares of the 
     real estate investment trust of not more than 5 percent.
       ``(C) Applicable percentage.--For purposes of applying 
     subparagraph (A)(i)--
       ``(i) In general.--Except as provided in clause (ii), the 
     term `applicable percentage' means 10 percent.
       ``(ii) Special rules for dividends.-- In the case of any 
     dividend in respect of stock received by or paid to a 
     qualified resident of Taiwan, the applicable percentage shall 
     be 15 percent (10 percent in the case of a dividend which 
     meets the requirements of subparagraph (D) and is received by 
     or paid to an entity taxed as a corporation in Taiwan).
       ``(D) Requirements for lower dividend rate.--
       ``(i) In general.--The requirements of this subparagraph 
     are met with respect to any dividend in respect of stock in a 
     corporation if, at all times during the 12-month period 
     ending on the date such stock becomes ex-dividend with 
     respect to such dividend--

       ``(I) the dividend is derived by a qualified resident of 
     Taiwan, and
       ``(II) such qualified resident of Taiwan has held directly 
     at least 10 percent (by vote and value) of the total 
     outstanding shares of stock in such corporation.

     For purposes of subclause (II), a person shall be treated as 
     directly holding a share of stock during any period described 
     in the preceding sentence if the share was held by a 
     corporation from which such person later acquired that share 
     and such corporation was, at the time the share was acquired, 
     both a connected person to such person and a qualified 
     resident of Taiwan.
       ``(ii) Exception for rics and reits.--Notwithstanding 
     clause (i), the requirements of this subparagraph shall not 
     be treated as met with respect to any dividend paid by a 
     regulated investment company or a real estate investment 
     trust.
       ``(2) Qualified wages.--
       ``(A) In general.--No tax shall be imposed under this 
     chapter (and no amount shall be withheld under section 
     1441(a) or chapter 24) with respect to qualified wages paid 
     to a qualified resident of Taiwan who--
       ``(i) is not a resident of the United States (determined 
     without regard to subsection (c)(3)(E)), or
       ``(ii) is employed as a member of the regular component of 
     a ship or aircraft operated in international traffic.
       ``(B) Qualified wages.--
       ``(i) In general.--The term `qualified wages' means wages, 
     salaries, or similar remunerations with respect to employment 
     involving the performance of personal services within the 
     United States which--

       ``(I) are paid by (or on behalf of) any employer other than 
     a United States person, and

[[Page H346]]

       ``(II) are not borne by a United States permanent 
     establishment of any person other than a United States 
     person.

       ``(ii) Exceptions.--Such term shall not include directors' 
     fees, income derived as an entertainer or athlete, income 
     derived as a student or trainee, pensions, amounts paid with 
     respect to employment with the United States, any State (or 
     political subdivision thereof), or any possession of the 
     United States (or any political subdivision thereof), or 
     other amounts specified in regulations or guidance under 
     subsection (f)(1)(F).
       ``(3) Income derived from entertainment or athletic 
     activities.--
       ``(A) In general.--No tax shall be imposed under this 
     chapter (and no amount shall be withheld under section 
     1441(a) or chapter 24) with respect to income derived by an 
     entertainer or athlete who is a qualified resident of Taiwan 
     from personal activities as such performed in the United 
     States if the aggregate amount of gross receipts from such 
     activities for the taxable year do not exceed $30,000.
       ``(B) Exception.--Subparagraph (A) shall not apply with 
     respect to--
       ``(i) income which is qualified wages (as defined in 
     paragraph (2)(B), determined without regard to clause (ii) 
     thereof), or
       ``(ii) income which is effectively connected with a United 
     States permanent establishment.
       ``(b) Income Connected With a United States Permanent 
     Establishment of a Qualified Resident of Taiwan.--
       ``(1) In general.--
       ``(A) In general.--In lieu of applying sections 871(b) and 
     882, a qualified resident of Taiwan that carries on a trade 
     or business within the United States through a United States 
     permanent establishment shall be taxable as provided in 
     section 1, 11, 55, or 59A, on its taxable income which is 
     effectively connected with such permanent establishment.
       ``(B) Determination of taxable income.--In determining 
     taxable income for purposes of paragraph (1), gross income 
     includes only gross income which is effectively connected 
     with the permanent establishment.
       ``(2) Treatment of dispositions of united states real 
     property.--In the case of a qualified resident of Taiwan, 
     section 897(a) shall be applied--
       ``(A) by substituting `carried on a trade or business 
     within the United States through a United States permanent 
     establishment' for `were engaged in a trade or business 
     within the United States', and
       ``(B) by substituting `such United States permanent 
     establishment' for `such trade or business'.
       ``(3) Treatment of branch profits taxes.--In the case of 
     any corporation which is a qualified resident of Taiwan, 
     section 884 shall be applied--
       ``(A) by substituting `10 percent' for `30 percent ' in 
     subsection (a) thereof, and
       ``(B) by substituting `a United States permanent 
     establishment of a qualified resident of Taiwan' for `the 
     conduct of a trade or business within the United States' in 
     subsection (d)(1) thereof.
       ``(4) Special rule with respect to income derived from 
     certain entertainment or athletic activities.--
       ``(A) In general.--Paragraph (1) shall not apply to the 
     extent that the income is derived--
       ``(i) in respect of entertainment or athletic activities 
     performed in the United States, and
       ``(ii) by a qualified resident of Taiwan who is not the 
     entertainer or athlete performing such activities.
       ``(B) Exception.--Subparagraph (A) shall not apply if the 
     person described in subparagraph (A)(ii) is contractually 
     authorized to designate the individual who is to perform such 
     activities.
       ``(5) Special rule with respect to certain amounts.--
     Paragraph (1) shall not apply to any income which is wages, 
     salaries, or similar remuneration with respect to employment 
     or with respect to any amount which is described in 
     subsection (a)(2)(B)(ii).
       ``(c) Qualified Resident of Taiwan.--For purposes of this 
     section--
       ``(1) In general.--The term `qualified resident of Taiwan' 
     means any person who--
       ``(A) is liable to tax under the laws of Taiwan by reason 
     of such person's domicile, residence, place of management, 
     place of incorporation, or any similar criterion,
       ``(B) is not a United States person (determined without 
     regard to paragraph (3)(E)), and
       ``(C) in the case of an entity taxed as a corporation in 
     Taiwan, meets the requirements of paragraph (2).
       ``(2) Limitation on benefits for corporate entities of 
     taiwan.--
       ``(A) In general.--Subject to subparagraphs (E) and (F), an 
     entity meets the requirements of this paragraph only if it--
       ``(i) meets the ownership and income requirements of 
     subparagraph (B),
       ``(ii) meets the publicly traded requirements of 
     subparagraph (C), or
       ``(iii) meets the qualified subsidiary requirements of 
     subparagraph (D).
       ``(B) Ownership and income requirements.--The requirements 
     of this subparagraph are met for an entity if--
       ``(i) at least 50 percent (by vote and value) of the total 
     outstanding shares of stock in such entity are owned directly 
     or indirectly by qualified residents of Taiwan, and
       ``(ii) less than 50 percent of such entity's gross income 
     (and in the case of an entity that is a member of a tested 
     group, less than 50 percent of the tested group's gross 
     income) is paid or accrued, directly or indirectly, in the 
     form of payments that are deductible for purposes of the 
     income taxes imposed by Taiwan, to persons who are not--

       ``(I) qualified residents of Taiwan, or
       ``(II) United States persons who meet such requirements 
     with respect to the United States as determined by the 
     Secretary to be equivalent to the requirements of this 
     subsection (determined without regard to paragraph (1)(B)) 
     with respect to residents of Taiwan.

       ``(C) Publicly traded requirements.--An entity meets the 
     requirements of this subparagraph if--
       ``(i) the principal class of its shares (and any 
     disproportionate class of shares) of such entity are 
     primarily and regularly traded on an established securities 
     market in Taiwan, or
       ``(ii) the primary place of management and control of the 
     entity is in Taiwan and all classes of its outstanding shares 
     described in clause (i) are regularly traded on an 
     established securities market in Taiwan.
       ``(D) Qualified subsidiary requirements.--An entity meets 
     the requirement of this subparagraph if--
       ``(i) at least 50 percent (by vote and value) of the total 
     outstanding shares of the stock of such entity are owned 
     directly or indirectly by 5 or fewer entities--

       ``(I) which meet the requirements of subparagraph (C), or
       ``(II) which are United States persons the principal class 
     of the shares (and any disproportionate class of shares) of 
     which are primarily and regularly traded on an established 
     securities market in the United States, and

       ``(ii) the entity meets the requirements of clause (ii) of 
     subparagraph (B).
       ``(E) Only indirect ownership through qualifying 
     intermediaries counted.--
       ``(i) In general.--Stock in an entity owned by a person 
     indirectly through 1 or more other persons shall not be 
     treated as owned by such person in determining whether the 
     person meets the requirements of subparagraph (B)(i) or 
     (D)(i) unless all such other persons are qualifying 
     intermediate owners.
       ``(ii) Qualifying intermediate owners.--The term 
     `qualifying intermediate owner' means a person that is--

       ``(I) a qualified resident of Taiwan, or
       ``(II) a resident of any other foreign country (other than 
     a foreign country that is a foreign country of concern) that 
     has in effect a comprehensive convention with the United 
     States for the avoidance of double taxation.

       ``(iii) Special rule for qualified subsidiaries.--For 
     purposes of applying subparagraph (D)(i), the term 
     `qualifying intermediate owner' shall include any person who 
     is a United States person who meets such requirements with 
     respect to the United States as determined by the Secretary 
     to be equivalent to the requirements of this subsection 
     (determined without regard to paragraph (1)(B)) with respect 
     to residents of Taiwan.
       ``(F) Certain payments not included.--In determining 
     whether the requirements of subparagraph (B)(ii) or (D)(ii) 
     are met with respect to an entity, the following payments 
     shall not be taken into account:
       ``(i) Arm's-length payments by the entity in the ordinary 
     course of business for services or tangible property.
       ``(ii) In the case of a tested group, intra-group 
     transactions.
       ``(3) Dual residents.--
       ``(A) Rules for determination of status.--
       ``(i) In general.--An individual who is an applicable dual 
     resident and who is described in subparagraph (B), (C), or 
     (D) shall be treated as a qualified resident of Taiwan.
       ``(ii) Applicable dual resident.--For purposes of this 
     paragraph, the term `applicable dual resident' means an 
     individual who--

       ``(I) is not a United States citizen,
       ``(II) is a resident of the United States (determined 
     without regard to subparagraph (E)), and
       ``(III) would be a qualified resident of Taiwan but for 
     paragraph (1)(B).

       ``(B) Permanent home.--An individual is described in this 
     subparagraph if such individual--
       ``(i) has a permanent home available to such individual in 
     Taiwan, and
       ``(ii) does not have a permanent home available to such 
     individual in the United States.
       ``(C) Center of vital interests.--An individual is 
     described in this subparagraph if--
       ``(i) such individual has a permanent home available to 
     such individual in both Taiwan and the United States, and
       ``(ii) such individual's personal and economic relations 
     (center of vital interests) are closer to Taiwan than to the 
     United States.
       ``(D) Habitual abode.--An individual is described in this 
     subparagraph if--
       ``(i) such individual--

       ``(I) does not have a permanent home available to such 
     individual in either Taiwan or the United States, or
       ``(II) has a permanent home available to such individual in 
     both Taiwan and the United States but such individual's 
     center of vital interests under subparagraph (C)(ii) cannot 
     be determined, and

       ``(ii) such individual has a habitual abode in Taiwan and 
     not the United States.
       ``(E) United states tax treatment of qualified resident of 
     taiwan.--Notwithstanding section 7701, an individual who is 
     treated as a qualified resident of Taiwan by reason of this 
     paragraph for all or any portion of a taxable year shall not 
     be treated as a resident of the United States for purposes of 
     computing such individual's United States income tax 
     liability for such taxable year or portion thereof.
       ``(4) Rules of special application.--
       ``(A) Dividends.--For purposes of applying this section to 
     any dividend, paragraph (2)(D) shall be applied without 
     regard to clause (ii) thereof.
       ``(B) Items of income emanating from an active trade or 
     business in taiwan.--For purposes of this section--
       ``(i) In general.--Notwithstanding the preceding paragraphs 
     of this subsection, if an entity taxed as a corporation in 
     Taiwan is not a

[[Page H347]]

     qualified resident of Taiwan but meets the requirements of 
     subparagraphs (A) and (B) of paragraph (1), any qualified 
     item of income such entity derived from the United States 
     shall be treated as income of a qualified resident of Taiwan.
       ``(ii) Qualified items of income.--

       ``(I) In general.--The term `qualified item of income' 
     means any item of income which emanates from, or is 
     incidental to, the conduct of an active trade or business in 
     Taiwan (other than operating as a holding company, providing 
     overall supervision or administration of a group of 
     companies, providing group financing, or making or managing 
     investments (unless such making or managing investments is 
     carried on by a bank, insurance company, or registered 
     securities dealer in the ordinary course of its business as 
     such)).
       ``(II) Substantial activity requirement.--An item of income 
     which is derived from a trade or business conducted in the 
     United States or from a connected person shall be a qualified 
     item of income only if the trade or business activity 
     conducted in Taiwan to which the item is related is 
     substantial in relation to the same or a complementary trade 
     or business activity carried on in the United States. For 
     purposes of applying this subclause, activities conducted by 
     persons that are connected to the entity described in clause 
     (i) shall be deemed to be conducted by such entity.

       ``(iii) Exception.--This subparagraph shall not apply to 
     any item of income derived by an entity if at least 50 
     percent (by vote or value) of such entity is owned (directly 
     or indirectly) or controlled by residents of a foreign 
     country of concern.
       ``(d) Other Definitions and Special Rules.--For purposes of 
     this section--
       ``(1) United states permanent establishment.--
       ``(A) In general.--The term `United States permanent 
     establishment' means, with respect to a qualified resident of 
     Taiwan, a permanent establishment of such resident which is 
     within the United States.
       ``(B) Special rule.--The determination of whether there is 
     a permanent establishment of a qualified resident of Taiwan 
     within the United States shall be made without regard to 
     whether an entity which is taxed as a corporation in Taiwan 
     and which is a qualified resident of Taiwan controls or is 
     controlled by--
       ``(i) a domestic corporation, or
       ``(ii) any other person that carries on business in the 
     United States (whether through a permanent establishment or 
     otherwise).
       ``(2) Permanent establishment.--
       ``(A) In general.--The term `permanent establishment' means 
     a fixed place of business through which a trade or business 
     is wholly or partly carried on. Such term shall include--
       ``(i) a place of management,
       ``(ii) a branch,
       ``(iii) an office,
       ``(iv) a factory,
       ``(v) a workshop, and
       ``(vi) a mine, an oil or gas well, a quarry, or any other 
     place of extraction of natural resources.
       ``(B) Special rules for certain temporary projects.--
       ``(i) In general.--A building site or construction or 
     installation project, or an installation or drilling rig or 
     ship used for the exploration or exploitation of the sea bed 
     and its subsoil and their natural resources, constitutes a 
     permanent establishment only if it lasts, or the activities 
     of the rig or ship lasts, for more than 12 months.
       ``(ii) Determination of 12-month period.--For purposes of 
     clause (i), the period over which a building site or 
     construction or installation project of a person lasts shall 
     include any period of more than 30 days during which such 
     person does not carry on activities at such building site or 
     construction or installation project but connected activities 
     are carried on at such building site or construction or 
     installation project by one or more connected persons.
       ``(C) Habitual exercise of contract authority treated as 
     permanent establishment.--Notwithstanding subparagraphs (A) 
     and (B), where a person (other than an agent of an 
     independent status to whom subparagraph (D)(ii) applies) is 
     acting on behalf of a trade or business of a qualified 
     resident of Taiwan and has and habitually exercises an 
     authority to conclude contracts that are binding on the trade 
     or business, that trade or business shall be deemed to have a 
     permanent establishment in the country in which such 
     authority is exercised in respect of any activities that the 
     person undertakes for the trade or business, unless the 
     activities of such person are limited to those described in 
     subparagraph (D)(i) that, if exercised through a fixed place 
     of business, would not make this fixed place of business a 
     permanent establishment under the provisions of that 
     subparagraph.
       ``(D) Exclusions.--
       ``(i) In general.--Notwithstanding subparagraphs (A) and 
     (B), the term `permanent establishment' shall not include--

       ``(I) the use of facilities solely for the purpose of 
     storage, display, or delivery of goods or merchandise 
     belonging to the trade or business,
       ``(II) the maintenance of a stock of goods or merchandise 
     belonging to the trade or business solely for the purpose of 
     storage, display, or delivery,
       ``(III) the maintenance of a stock of goods or merchandise 
     belonging to the trade or business solely for the purpose of 
     processing by another trade or business,
       ``(IV) the maintenance of a fixed place of business solely 
     for the purpose of purchasing goods or merchandise, or of 
     collecting information, for the trade or business,
       ``(V) the maintenance of a fixed place of business solely 
     for the purpose of carrying on, for the trade or business, 
     any other activity of a preparatory or auxiliary character, 
     or
       ``(VI) the maintenance of a fixed place of business solely 
     for any combination of the activities mentioned in subclauses 
     (I) through (V), provided that the overall activity of the 
     fixed place of business resulting from this combination is of 
     a preparatory or auxiliary character.

       ``(ii) Brokers and other independent agents.--A trade or 
     business shall not be considered to have a permanent 
     establishment in a country merely because it carries on 
     business in such country through a broker, general commission 
     agent, or any other agent of an independent status, provided 
     that such persons are acting in the ordinary course of their 
     business as independent agents.
       ``(3) Tested group.--The term `tested group' includes, with 
     respect to any entity taxed as a corporation in Taiwan, such 
     entity and any other entity taxed as a corporation in Taiwan 
     that--
       ``(A) participates as a member with such entity in a tax 
     consolidation, fiscal unity, or similar regime that requires 
     members of the group to share profits or losses, or
       ``(B) shares losses with such entity pursuant to a group 
     relief or other loss sharing regime.
       ``(4) Connected person.--Two persons shall be `connected 
     persons' if one owns, directly or indirectly, at least 50 
     percent of the interests in the other (or, in the case of a 
     corporation, at least 50 percent of the aggregate vote and 
     value of the corporation's shares) or another person owns, 
     directly or indirectly, at least 50 percent of the interests 
     (or, in the case of a corporation, at least 50 percent of the 
     aggregate vote and value of the corporation's shares) in each 
     person. In any case, a person shall be connected to another 
     if, based on all the relevant facts and circumstances, one 
     has control of the other or both are under the control of the 
     same person or persons.
       ``(5) Foreign country of concern.--The term `foreign 
     country of concern' has the meaning given such term under 
     paragraph (7) of section 9901 of the William M. (Mac) 
     Thornberry National Defense Authorization Act for Fiscal Year 
     2021 (15 U.S.C. 4651(7)), as added by section 103(a)(4) of 
     the CHIPS Act of 2022).
       ``(6) Partnerships; beneficiaries of estates and trusts.--
     For purposes of this section--
       ``(A) a qualified resident of Taiwan which is a partner of 
     a partnership which carries on a trade or business within the 
     United States through a United States permanent establishment 
     shall be treated as carrying on such trade or business 
     through such permanent establishment, and
       ``(B) a qualified resident of Taiwan which is a beneficiary 
     of an estate or trust which carries on a trade or business 
     within the United States through a United States permanent 
     establishment shall be treated as carrying on such trade or 
     business through such permanent establishment.
       ``(7) Denial of benefits for certain payments through 
     hybrid entities.--For purposes of this section, rules similar 
     to the rules of section 894(c) shall apply.
       ``(e) Application.--
       ``(1) In general.--This section shall not apply to any 
     period unless the Secretary has determined that Taiwan has 
     provided benefits to United States persons for such period 
     that are reciprocal to the benefits provided to qualified 
     residents of Taiwan under this section.
       ``(2) Provision of reciprocity.--The President or his 
     designee is authorized to exchange letters, enter into an 
     agreement, or take other necessary and appropriate steps 
     relative to Taiwan for the reciprocal provision of the 
     benefits described in this section.
       ``(f) Regulations or Other Guidance.--
       ``(1) In general.--The Secretary shall issue such 
     regulations or other guidance as may be necessary or 
     appropriate to carry out the provisions of this section, 
     including such regulations or guidance for--
       ``(A) determining--
       ``(i) what constitutes a United States permanent 
     establishment of a qualified resident of Taiwan, and
       ``(ii) income that is effectively connected with such a 
     permanent establishment,
       ``(B) preventing the abuse of the provisions of this 
     section by persons who are not (or who should not be treated 
     as) qualified residents of Taiwan,
       ``(C) requirements for record keeping and reporting,
       ``(D) rules to assist withholding agents or employers in 
     determining whether a foreign person is a qualified resident 
     of Taiwan for purposes of determining whether withholding or 
     reporting is required for a payment (and, if withholding is 
     required, whether it should be applied at a reduced rate),
       ``(E) the application of subsection (a)(1)(D)(i) to stock 
     held by predecessor owners,
       ``(F) determining what amounts are to be treated as 
     qualified wages for purposes of subsection (a)(2),
       ``(G) determining the amounts to which subsection (a)(3) 
     applies,
       ``(H) defining established securities market for purposes 
     of subsection (c),
       ``(I) the application of the rules of subsection (c)(4)(B),
       ``(J) the application of subsection (d)(6) and section 
     1446,
       ``(K) determining ownership interests held by residents of 
     a foreign country of concern, and
       ``(L) determining the starting and ending dates for periods 
     with respect to the application of this section under 
     subsection (e), which may be separate dates for taxes 
     withheld at the source and other taxes.
       ``(2) Regulations to be consistent with model treaty.--Any 
     regulations or other guidance issued under this section 
     shall, to the extent practical, be consistent with the 
     provisions of the United States model income tax convention 
     dated February 7, 2016.''.

[[Page H348]]

       (b) Conforming Amendment to Withholding Tax.--Subchapter A 
     of chapter 3 is amended by adding at the end the following 
     new section:

     ``SEC. 1447. WITHHOLDING FOR QUALIFIED RESIDENTS OF TAIWAN.

       ``For reduced rates of withholding for certain residents of 
     Taiwan, see section 894A.''.
       (c) Clerical Amendments.--
       (1) The table of sections for subpart D of part II of 
     subchapter N of chapter 1 is amended by inserting after the 
     item relating to section 894 the following new item:

``Sec. 894A. Special rules for qualified residents of Taiwan.''.
       (2) The table of sections for subchapter A of chapter 3 is 
     amended by adding at the end the following new item:

``Sec. 1447. Withholding for qualified residents of Taiwan.''.

    Subtitle B--United States-Taiwan Tax Agreement Authorization Act

     SEC. 311. SHORT TITLE.

       This subtitle may be cited as the ``United States-Taiwan 
     Tax Agreement Authorization Act''.

     SEC. 312. DEFINITIONS.

       In this subtitle:
       (1) Agreement.--The term ``Agreement'' means the tax 
     agreement authorized by section 313(a).
       (2) Appropriate congressional committees.--The term 
     ``appropriate congressional committees'' means--
       (A) the Committee on Foreign Relations and the Committee on 
     Finance of the Senate; and
       (B) the Committee on Ways and Means of the House of 
     Representatives.
       (3) Approval legislation.--The term ``approval 
     legislation'' means legislation that approves the Agreement.
       (4) Implementing legislation.--The term ``implementing 
     legislation'' means legislation that makes any changes to the 
     Internal Revenue Code of 1986 necessary to implement the 
     Agreement.

     SEC. 313. AUTHORIZATION TO NEGOTIATE AND ENTER INTO 
                   AGREEMENT.

       (a) In General.--Subsequent to a determination under 
     section 894A(e)(1) of the Internal Revenue Code of 1986 (as 
     added by the United States-Taiwan Expedited Double-Tax Relief 
     Act), the President is authorized to negotiate and enter into 
     a tax agreement relative to Taiwan.
       (b) Elements of Agreement.--
       (1) Conformity with bilateral income tax conventions.--The 
     President shall ensure that--
       (A) any provisions included in the Agreement conform with 
     provisions customarily contained in United States bilateral 
     income tax conventions, as exemplified by the 2016 United 
     States Model Income Tax Convention; and
       (B) the Agreement does not include elements outside the 
     scope of the 2016 United States Model Income Tax Convention.
       (2) Incorporation of tax agreements and laws.--
     Notwithstanding paragraph (1), the Agreement may incorporate 
     and restate provisions of any agreement, or existing United 
     States law, addressing double taxation for residents of the 
     United States and Taiwan.
       (3) Authority.--The Agreement shall include the following 
     statement: ``The Agreement is entered into pursuant to the 
     United States-Taiwan Tax Agreement Authorization Act.''
       (4) Entry into force.--The Agreement shall include a 
     provision conditioning entry into force upon--
       (A) enactment of approval legislation and implementing 
     legislation pursuant to section 317; and
       (B) confirmation by the Secretary of the Treasury that the 
     relevant authority in Taiwan has approved and taken 
     appropriate steps required to implement the Agreement.

     SEC. 314. CONSULTATIONS WITH CONGRESS.

       (a) Notification Upon Commencement of Negotiations.--The 
     President shall provide written notification to the 
     appropriate congressional committees of the commencement of 
     negotiations between the United States and Taiwan on the 
     Agreement at least 15 calendar days before commencing such 
     negotiations.
       (b) Consultations During Negotiations.--
       (1) Briefings.--Not later than 90 days after commencement 
     of negotiations with respect to the Agreement, and every 180 
     days thereafter until the President enters into the 
     Agreement, the President shall provide a briefing to the 
     appropriate congressional committees on the status of the 
     negotiations, including a description of elements under 
     negotiation.
       (2) Meetings and other consultations.--
       (A) In general.--In the course of negotiations with respect 
     to the Agreement, the Secretary of the Treasury, in 
     coordination with the Secretary of State, shall--
       (i) meet, upon request, with the chairman or ranking member 
     of any of the appropriate congressional committees regarding 
     negotiating objectives and the status of negotiations in 
     progress; and
       (ii) consult closely and on a timely basis with, and keep 
     fully apprised of the negotiations, the appropriate 
     congressional committees.
       (B) Elements of consultations.--The consultations described 
     in subparagraph (A) shall include consultations with respect 
     to--
       (i) the nature of the contemplated Agreement;
       (ii) how and to what extent the contemplated Agreement is 
     consistent with the elements set forth in section 313(b); and
       (iii) the implementation of the contemplated Agreement, 
     including--

       (I) the general effect of the contemplated Agreement on 
     existing laws;
       (II) proposed changes to any existing laws to implement the 
     contemplated Agreement; and
       (III) proposed administrative actions to implement the 
     contemplated Agreement.

     SEC. 315. APPROVAL AND IMPLEMENTATION OF AGREEMENT.

       (a) In General.--The Agreement may not enter into force 
     unless--
       (1) the President, at least 60 days before the day on which 
     the President enters into the Agreement, publishes the text 
     of the contemplated Agreement on a publicly available website 
     of the Department of the Treasury; and
       (2) there is enacted into law, with respect to the 
     Agreement, approval legislation and implementing legislation 
     pursuant to section 317.
       (b) Entry Into Force.--The President may provide for the 
     Agreement to enter into force upon--
       (1) enactment of approval legislation and implementing 
     legislation pursuant to section 317; and
       (2) confirmation by the Secretary of the Treasury that the 
     relevant authority in Taiwan has approved and taken 
     appropriate steps required to implement the Agreement.

     SEC. 316. SUBMISSION TO CONGRESS OF AGREEMENT AND 
                   IMPLEMENTATION POLICY.

       (a) Submission of Agreement.--Not later than 270 days after 
     the President enters into the Agreement, the President or the 
     President's designee shall submit to Congress--
       (1) the final text of the Agreement; and
       (2) a technical explanation of the Agreement.
       (b) Submission of Implementation Policy.--Not later than 
     270 days after the President enters into the Agreement, the 
     Secretary of the Treasury shall submit to Congress--
       (1) a description of those changes to existing laws that 
     the President considers would be required in order to ensure 
     that the United States acts in a manner consistent with the 
     Agreement; and
       (2) a statement of anticipated administrative action 
     proposed to implement the Agreement.

     SEC. 317. CONSIDERATION OF APPROVAL LEGISLATION AND 
                   IMPLEMENTING LEGISLATION.

       (a) In General.--The approval legislation with respect to 
     the Agreement shall include the following: ``Congress 
     approves the Agreement submitted to Congress pursuant to 
     section 316 of the United States-Taiwan Tax Agreement 
     Authorization Act on ____.'', with the blank space being 
     filled with the appropriate date.
       (b) Approval Legislation Committee Referral.--The approval 
     legislation shall--
       (1) in the Senate, be referred to the Committee on Foreign 
     Relations; and
       (2) in the House of Representaives, be referred to the 
     Committee on Ways and Means.
       (c) Implementing Legislation Committee Referral.--The 
     implementing legislation shall--
       (1) in the Senate, be referred to the Committee on Finance; 
     and
       (2) in the House of Representatives, be referred to the 
     Committee on Ways and Means.

     SEC. 318. RELATIONSHIP OF AGREEMENT TO INTERNAL REVENUE CODE 
                   OF 1986.

       (a) Internal Revenue Code of 1986 to Control.--No provision 
     of the Agreement or approval legislation, nor the application 
     of any such provision to any person or circumstance, which is 
     inconsistent with any provision of the Internal Revenue Code 
     of 1986, shall have effect.
       (b) Construction.--Nothing in this subtitle shall be 
     construed--
       (1) to amend or modify any law of the United States; or
       (2) to limit any authority conferred under any law of the 
     United States,
     unless specifically provided for in this subtitle.

     SEC. 319. AUTHORIZATION OF SUBSEQUENT TAX AGREEMENTS RELATIVE 
                   TO TAIWAN.

       (a) In General.--Subsequent to the enactment of approval 
     legislation and implementing legislation pursuant to section 
     317--
       (1) the term ``tax agreement'' in section 313(a) shall be 
     treated as including any tax agreement relative to Taiwan 
     which supplements or supersedes the Agreement to which such 
     approval legislation and implementing legislation relates, 
     and
       (2) the term ``Agreement'' shall be treated as including 
     such tax agreement.
       (b) Requirements, etc., to Apply Separately.--The 
     provisions of this subtitle (including section 314) shall be 
     applied separately with respect to each tax agreement 
     referred to in subsection (a).

     SEC. 320. UNITED STATES TREATMENT OF DOUBLE TAXATION MATTERS 
                   WITH RESPECT TO TAIWAN.

       (a) Findings.--Congress makes the following findings:
       (1) The United States addresses issues with respect to 
     double taxation with foreign countries by entering into 
     bilateral income tax conventions (known as tax treaties) with 
     such countries, subject to the advice and consent of the 
     Senate to ratification pursuant to article II of the 
     Constitution.
       (2) The United States has entered into more than sixty such 
     tax treaties, which facilitate economic activity, strengthen 
     bilateral cooperation, and benefit United States workers, 
     businesses, and other United States taxpayers.
       (3) Due to Taiwan's unique status, the United States is 
     unable to enter into an article II tax treaty with Taiwan, 
     necessitating an agreement to address issues with respect to 
     double taxation.
       (b) Statement of Policy.--It is the policy of the United 
     States to--
       (1) provide for additional bilateral tax relief with 
     respect to Taiwan, beyond that provided for in section 894A 
     of the Internal Revenue Code of 1986 (as added by the United 
     States-Taiwan Expedited Double-Tax Relief Act), only after 
     entry into force of an Agreement, as provided for in section 
     315, and only in a manner consistent with such Agreement; and

[[Page H349]]

       (2) continue to provide for bilateral tax relief with 
     sovereign states to address double taxation and other related 
     matters through entering into bilateral income tax 
     conventions, subject to the Senate's advice and consent to 
     ratification pursuant to article II of the Constitution.

         TITLE IV--ASSISTANCE FOR DISASTER-IMPACTED COMMUNITIES

     SEC. 401. SHORT TITLE.

       This title may be cited as the ``Federal Disaster Tax 
     Relief Act of 2024''.

     SEC. 402. EXTENSION OF RULES FOR TREATMENT OF CERTAIN 
                   DISASTER-RELATED PERSONAL CASUALTY LOSSES.

       For purposes of applying section 304(b) of the Taxpayer 
     Certainty and Disaster Tax Relief Act of 2020, section 301 of 
     such Act shall be applied by substituting ``the Federal 
     Disaster Tax Relief Act of 2024'' for ``this Act'' each place 
     it appears.

     SEC. 403. EXCLUSION FROM GROSS INCOME FOR COMPENSATION FOR 
                   LOSSES OR DAMAGES RESULTING FROM CERTAIN 
                   WILDFIRES.

       (a) In General.--For purposes of the Internal Revenue Code 
     of 1986, gross income shall not include any amount received 
     by an individual as a qualified wildfire relief payment.
       (b) Qualified Wildfire Relief Payment.--For purposes of 
     this section--
       (1) In general.--The term ``qualified wildfire relief 
     payment'' means any amount received by or on behalf of an 
     individual as compensation for losses, expenses, or damages 
     (including compensation for additional living expenses, lost 
     wages (other than compensation for lost wages paid by the 
     employer which would have otherwise paid such wages), 
     personal injury, death, or emotional distress) incurred as a 
     result of a qualified wildfire disaster, but only to the 
     extent the losses, expenses, or damages compensated by such 
     payment are not compensated for by insurance or otherwise.
       (2) Qualified wildfire disaster.--The term ``qualified 
     wildfire disaster'' means any federally declared disaster (as 
     defined in section 165(i)(5)(A) of the Internal Revenue Code 
     of 1986) declared, after December 31, 2014, as a result of 
     any forest or range fire.
       (c) Denial of Double Benefit.--Notwithstanding any other 
     provision of the Internal Revenue Code of 1986--
       (1) no deduction or credit shall be allowed (to the person 
     for whose benefit a qualified wildfire relief payment is 
     made) for, or by reason of, any expenditure to the extent of 
     the amount excluded under this section with respect to such 
     expenditure, and
       (2) no increase in the basis or adjusted basis of any 
     property shall result from any amount excluded under this 
     subsection with respect to such property.
       (d) Limitation on Application.--This section shall only 
     apply to qualified wildfire relief payments received by the 
     individual during taxable years beginning after December 31, 
     2019, and before January 1, 2026.

     SEC. 404. EAST PALESTINE DISASTER RELIEF PAYMENTS.

       (a) Disaster Relief Payments to Victims of East Palestine 
     Train Derailment.--East Palestine train derailment payments 
     shall be treated as qualified disaster relief payments for 
     purposes of section 139(b) of the Internal Revenue Code of 
     1986.
       (b) East Palestine Train Derailment Payments.--For purposes 
     of this section, the term ``East Palestine train derailment 
     payment'' means any amount received by or on behalf of an 
     individual as compensation for loss, damages, expenses, loss 
     in real property value, closing costs with respect to real 
     property (including realtor commissions), or inconvenience 
     (including access to real property) resulting from the East 
     Palestine train derailment if such amount was provided by--
       (1) a Federal, State, or local government agency,
       (2) Norfolk Southern Railway, or
       (3) any subsidiary, insurer, or agent of Norfolk Southern 
     Railway or any related person.
       (c) Train Derailment.--For purposes of this section, the 
     term ``East Palestine train derailment'' means the derailment 
     of a train in East Palestine, Ohio, on February 3, 2023.
       (d) Effective Date.--This section shall apply to amounts 
     received on or after February 3, 2023.

                    TITLE V--MORE AFFORDABLE HOUSING

     SEC. 501. STATE HOUSING CREDIT CEILING INCREASE FOR LOW-
                   INCOME HOUSING CREDIT.

       (a) In General.--Section 42(h)(3)(I) is amended--
       (1) by striking ``and 2021,'' and inserting ``2021, 2023, 
     2024, and 2025,'', and
       (2) by striking ``2018, 2019, 2020, and 2021'' in the 
     heading and inserting ``certain calendar years''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to calendar years after 2022.

     SEC. 502. TAX-EXEMPT BOND FINANCING REQUIREMENT.

       (a) In General.--Section 42(h)(4) is amended by striking 
     subparagraph (B) and inserting the following:
       ``(B) Special rule where minimum percent of buildings is 
     financed with tax-exempt bonds subject to volume cap.--For 
     purposes of subparagraph (A), paragraph (1) shall not apply 
     to any portion of the credit allowable under subsection (a) 
     with respect to a building if--
       ``(i) 50 percent or more of the aggregate basis of such 
     building and the land on which the building is located is 
     financed by 1 or more obligations described in subparagraph 
     (A), or
       ``(ii)(I) 30 percent or more of the aggregate basis of such 
     building and the land on which the building is located is 
     financed by 1 or more qualified obligations, and
       ``(II) 1 or more of such qualified obligations--

       ``(aa) are part of an issue the issue date of which is 
     after December 31, 2023, and
       ``(bb) provide the financing for not less than 5 percent of 
     the aggregate basis of such building and the land on which 
     the building is located.

       ``(C) Qualified obligation.--For purposes of subparagraph 
     (B)(ii), the term `qualified obligation' means an obligation 
     which is described in subparagraph (A) and which is part of 
     an issue the issue date of which is before January 1, 
     2026.''.
       (b) Effective Date.--
       (1) In general.--The amendment made by this section shall 
     apply to buildings placed in service in taxable years 
     beginning after December 31, 2023.
       (2) Rehabilitation expenditures treated as separate new 
     building.--In the case of any building with respect to which 
     any expenditures are treated as a separate new building under 
     section 42(e) of the Internal Revenue Code of 1986, for 
     purposes of paragraph (1), both the existing building and the 
     separate new building shall be treated as having been placed 
     in service on the date such expenditures are treated as 
     placed in service under section 42(e)(4) of such Code.

           TITLE VI--TAX ADMINISTRATION AND ELIMINATING FRAUD

     SEC. 601. INCREASE IN THRESHOLD FOR REQUIRING INFORMATION 
                   REPORTING WITH RESPECT TO CERTAIN PAYEES.

       (a) In General.--Sections 6041(a) is amended by striking 
     ``$600'' and inserting ``$1,000''.
       (b) Inflation Adjustment.--Section 6041 is amended by 
     adding at the end the following new subsection:
       ``(h) Inflation Adjustment.--In the case of any calendar 
     year after 2024, the dollar amount in subsection (a) shall be 
     increased by an amount equal to--
       ``(1) such dollar amount, multiplied by
       ``(2) the cost-of-living adjustment determined under 
     section 1(f)(3) for such calendar year, determined by 
     substituting `calendar year 2023' for `calendar year 2016' in 
     subparagraph (A)(ii) thereof.
     If any increase under the preceding sentence is not a 
     multiple of $100, such increase shall be rounded to the 
     nearest multiple of $100.''.
       (c) Application to Reporting on Remuneration for Services 
     and Direct Sales.--Section 6041A is amended--
       (1) in subsection (a)(2), by striking ``is $600 or more'' 
     and inserting ``equals or exceeds the dollar amount in effect 
     for such calendar year under section 6041(a)'', and
       (2) in subsection (b)(1)(B), by striking ``is $5,000 or 
     more'' and inserting ``equals or exceeds the dollar amount in 
     effect for such calendar year under section 6041(a)''.
       (d) Application to Backup Withholding.--Section 3406(b)(6) 
     is amended--
       (1) by striking ``$600'' in subparagraph (A) and inserting 
     ``the dollar amount in effect for such calendar year under 
     section 6041(a)'', and
       (2) by striking ``only where aggregate for calendar year is 
     $600 or more'' in the heading and inserting ``only if in 
     excess of threshold''.
       (e) Conforming Amendments.--
       (1) The heading of section 6041(a) is amended by striking 
     ``of $600 or More'' and inserting ``Exceeding Threshold''.
       (2) Section 6041(a) is amended by striking ``taxable year'' 
     and inserting ``calendar year''.
       (f) Effective Date.--The amendments made by this section 
     shall apply with respect to payments made after December 31, 
     2023.

     SEC. 602. ENFORCEMENT PROVISIONS WITH RESPECT TO COVID-
                   RELATED EMPLOYEE RETENTION CREDITS.

       (a) Increase in Assessable Penalty on COVID-ERTC Promoters 
     for Aiding and Abetting Understatements of Tax Liability.--
       (1) In general.--If any COVID-ERTC promoter is subject to 
     penalty under section 6701(a) of the Internal Revenue Code of 
     1986 with respect to any COVID-ERTC document, notwithstanding 
     paragraphs (1) and (2) of section 6701(b) of such Code, the 
     amount of the penalty imposed under such section 6701(a) 
     shall be the greater of--
       (A) $200,000 ($10,000, in the case of a natural person), or
       (B) 75 percent of the gross income derived (or to be 
     derived) by such promoter with respect to the aid, 
     assistance, or advice referred to in section 6701(a)(1) of 
     such Code with respect to such document.
       (2) No inference.--Paragraph (1) shall not be construed to 
     create any inference with respect to the proper application 
     of the knowledge requirement of section 6701(a)(3) of the 
     Internal Revenue Code of 1986.
       (b) Failure to Comply With Due Diligence Requirements 
     Treated as Knowledge for Purposes of Assessable Penalty for 
     Aiding and Abetting Understatement of Tax Liability.--In the 
     case of any COVID-ERTC promoter, the knowledge requirement of 
     section 6701(a)(3) of the Internal Revenue Code of 1986 shall 
     be treated as satisfied with respect to any COVID-ERTC 
     document with respect to which such promoter provided aid, 
     assistance, or advice, if such promoter fails to comply with 
     the due diligence requirements referred to in subsection 
     (c)(1).
       (c) Assessable Penalty for Failure to Comply With Due 
     Diligence Requirements.--
       (1) In general.--Any COVID-ERTC promoter which provides 
     aid, assistance, or advice with respect to any COVID-ERTC 
     document and which fails to comply with due diligence 
     requirements imposed by the Secretary with respect to 
     determining eligibility for, or the amount of, any COVID-
     related employee retention tax credit, shall pay a penalty of 
     $1,000 for each such failure.

[[Page H350]]

       (2) Due diligence requirements.--Except as otherwise 
     provided by the Secretary, the due diligence requirements 
     referred to in paragraph (1) shall be similar to the due 
     diligence requirements imposed under section 6695(g).
       (3) Restriction to documents used in connection with 
     returns or claims for refund.--Paragraph (1) shall not apply 
     with respect to any COVID-ERTC document unless such document 
     constitutes, or relates to, a return or claim for refund.
       (4) Treatment as assessable penalty, etc.--For purposes of 
     the Internal Revenue Code of 1986, the penalty imposed under 
     paragraph (1) shall be treated in the same manner as a 
     penalty imposed under section 6695(g).
       (5) Secretary.--For purposes of this subsection, the term 
     ``Secretary'' means the Secretary of the Treasury or the 
     Secretary's delegate.
       (d) Assessable Penalties for Failure to Disclose 
     Information, Maintain Client Lists, etc.--For purposes of 
     sections 6111, 6112, 6707 and 6708 of the Internal Revenue 
     Code of 1986--
       (1) any COVID-related employee retention tax credit 
     (whether or not the taxpayer claims such COVID-related 
     employee retention tax credit) shall be treated as a listed 
     transaction (and as a reportable transaction) with respect to 
     any COVID-ERTC promoter if such promoter provides any aid, 
     assistance, or advice with respect to any COVID-ERTC document 
     relating to such COVID-related employee retention tax credit, 
     and
       (2) such COVID-ERTC promoter shall be treated as a material 
     advisor with respect to such transaction.
       (e) COVID-ERTC Promoter.--For purposes of this section--
       (1) In general.--The term ``COVID-ERTC promoter'' means, 
     with respect to any COVID-ERTC document, any person which 
     provides aid, assistance, or advice with respect to such 
     document if--
       (A) such person charges or receives a fee for such aid, 
     assistance, or advice which is based on the amount of the 
     refund or credit with respect to such document and, with 
     respect to such person's taxable year in which such person 
     provided such assistance or the preceding taxable year, the 
     aggregate gross receipts of such person for aid, assistance, 
     and advice with respect to all COVID-ERTC documents exceeds 
     20 percent of the gross receipts of such person for such 
     taxable year, or
       (B) with respect to such person's taxable year in which 
     such person provided such assistance or the preceding taxable 
     year--
       (i) the aggregate gross receipts of such person for aid, 
     assistance, and advice with respect to all COVID-ERTC 
     documents exceeds 50 percent of the gross receipts of such 
     person for such taxable year, or
       (ii) both--

       (I) such aggregate gross receipts exceeds 20 percent of the 
     gross receipts of such person for such taxable year, and
       (II) the aggregate gross receipts of such person for aid, 
     assistance, and advice with respect to all COVID-ERTC 
     documents (determined after application of paragraph (3)) 
     exceeds $500,000.

       (2) Exception for certified professional employer 
     organizations.--The term ``COVID-ERTC promoter'' shall not 
     include a certified professional employer organization (as 
     defined in section 7705).
       (3) Aggregation rule.--For purposes of paragraph 
     (1)(B)(ii)(II), all persons treated as a single employer 
     under subsection (a) or (b) of section 52 of the Internal 
     Revenue Code of 1986, or subsection (m) or (o) of section 414 
     of such Code, shall be treated as 1 person.
       (4) Short taxable years.--In the case of any taxable year 
     of less than 12 months, paragraph (1) shall be applied with 
     respect to the calendar year in which such taxable year 
     begins (in addition to applying to such taxable year).
       (f) COVID-ERTC Document.--For purposes of this section, the 
     term ``COVID-ERTC document'' means any return, affidavit, 
     claim, or other document related to any COVID-related 
     employee retention tax credit, including any document related 
     to eligibility for, or the calculation or determination of 
     any amount directly related to any COVID-related employee 
     retention tax credit.
       (g) COVID-related Employee Retention Tax Credit.--For 
     purposes of this section, the term ``COVID-related employee 
     retention tax credit'' means--
       (1) any credit, or advance payment, under section 3134 of 
     the Internal Revenue Code of 1986, and
       (2) any credit, or advance payment, under section 2301 of 
     the CARES Act.
       (h) Limitation on Credit and Refund of COVID-related 
     Employee Retention Tax Credits.--Notwithstanding section 6511 
     of the Internal Revenue Code of 1986 or any other provision 
     of law, no credit or refund of any COVID-related employee 
     retention tax credit shall be allowed or made after January 
     31, 2024, unless a claim for such credit or refund is filed 
     by the taxpayer on or before such date.
       (i) Amendments to Extend Limitation on Assessment.--
       (1) In general.--Section 3134(l) of the Internal Revenue 
     Code of 1986 is amended to read as follows:
       ``(l) Extension of Limitation on Assessment.--
       ``(1) In general.--Notwithstanding section 6501, the 
     limitation on the time period for the assessment of any 
     amount attributable to a credit claimed under this section 
     shall not expire before the date that is 6 years after the 
     latest of--
       ``(A) the date on which the original return which includes 
     the calendar quarter with respect to which such credit is 
     determined is filed,
       ``(B) the date on which such return is treated as filed 
     under section 6501(b)(2), or
       ``(C) the date on which the claim for credit or refund with 
     respect to such credit is made.
       ``(2) Deduction for wages taken into account in determining 
     improperly claimed credit.--
       ``(A) In general.--Notwithstanding section 6511, in the 
     case of an assessment attributable to a credit claimed under 
     this section, the limitation on the time period for credit or 
     refund of any amount attributable to a deduction for 
     improperly claimed ERTC wages shall not expire before the 
     time period for such assessment expires under paragraph (1).
       ``(B) Improperly claimed ertc wages.--For purposes of this 
     paragraph, the term `improperly claimed ERTC wages' means, 
     with respect to an assessment attributable to a credit 
     claimed under this section, the wages with respect to which a 
     deduction would not have been allowed if the portion of the 
     credit to which such assessment relates had been properly 
     claimed.''.
       (2) Application to cares act credit.--Section 2301 of the 
     CARES Act is amended by adding at the end the following new 
     subsection:
       ``(o) Extension of Limitation on Assessment.--
       ``(1) In general.--Notwithstanding section 6501 of the 
     Internal Revenue Code of 1986, the limitation on the time 
     period for the assessment of any amount attributable to a 
     credit claimed under this section shall not expire before the 
     date that is 6 years after the latest of--
       ``(A) the date on which the original return which includes 
     the calendar quarter with respect to which such credit is 
     determined is filed,
       ``(B) the date on which such return is treated as filed 
     under section 6501(b)(2) of such Code, or
       ``(C) the date on which the claim for credit or refund with 
     respect to such credit is made.
       ``(2) Deduction for wages taken into account in determining 
     improperly claimed credit.--
       ``(A) In general.--Notwithstanding section 6511 of such 
     Code, in the case of an assessment attributable to a credit 
     claimed under this section, the limitation on the time period 
     for credit or refund of any amount attributable to a 
     deduction for improperly claimed ERTC wages shall not expire 
     before the time period for such assessment expires under 
     paragraph (1).
       ``(B) Improperly claimed ertc wages.--For purposes of this 
     paragraph, the term `improperly claimed ERTC wages' means, 
     with respect to an assessment attributable to a credit 
     claimed under this section, the wages with respect to which a 
     deduction would not have been allowed if the portion of the 
     credit to which such assessment relates had been properly 
     claimed.''.
       (j) Effective Dates.--
       (1) In general.--Except as otherwise provided in this 
     subsection, the provisions of this section shall apply to 
     aid, assistance, and advice provided after March 12, 2020.
       (2) Due diligence requirements.--Subsections (b) and (c) 
     shall apply to aid, assistance, and advice provided after the 
     date of the enactment of this Act.
       (3) Limitation on credit and refund of covid-related 
     employee retention tax credits.--Subsection (h) shall apply 
     to credits and refunds allowed or made after January 31, 
     2024.
       (4) Amendments to extend limitation on assessment.--The 
     amendments made by subsection (i) shall apply to assessments 
     made after the date of the enactment of this Act.
       (k) Transition Rule With Respect to Requirements to 
     Disclose Information, Maintain Client Lists, etc.--Any return 
     under section 6111 of the Internal Revenue Code of 1986, or 
     list under section 6112 of such Code, required by reason of 
     subsection (d) of this section to be filed or maintained, 
     respectively, with respect to any aid, assistance, or advice 
     provided by a COVID-ERTC promoter with respect to a COVID-
     ERTC document before the date of the enactment of this Act, 
     shall not be required to be so filed or maintained (with 
     respect to such aid, assistance or advice) before the date 
     which is 90 days after such date.
       (l) Provisions Not to Be Construed to Create Negative 
     Inferences.--
       (1) No inference with respect to application of knowledge 
     requirement to pre-enactment conduct of covid-ertc promoters, 
     etc.--Subsection (b) shall not be construed to create any 
     inference with respect to the proper application of section 
     6701(a)(3) of the Internal Revenue Code of 1986 with respect 
     to any aid, assistance, or advice provided by any COVID-ERTC 
     promoter on or before the date of the enactment of this Act 
     (or with respect to any other aid, assistance, or advice to 
     which such subsection does not apply).
       (2) Requirements to disclose information, maintain client 
     lists, etc.--Subsections (d) and (k) shall not be construed 
     to create any inference with respect to whether any COVID-
     related employee retention tax credit is (without regard to 
     subsection (d)) a listed transaction (or reportable 
     transaction) with respect to any COVID-ERTC promoter; and, 
     for purposes of subsection (j), a return or list shall not be 
     treated as required (with respect to such aid, assistance, or 
     advice) by reason of subsection (d) if such return or list 
     would be so required without regard to subsection (d).
       (m) Regulations.--The Secretary (as defined in subsection 
     (c)(5)) shall issue such regulations or other guidance as may 
     be necessary or appropriate to carry out the purposes of this 
     section (and the amendments made by this section).

  The SPEAKER pro tempore. Pursuant to the rule, the gentleman from 
Missouri (Mr. Smith) and the gentleman from Massachusetts (Mr. Neal) 
each will control 20 minutes.
  The Chair recognizes the gentleman from Missouri.
  Mr. ROY. Mr. Speaker, I claim the time in actual opposition to the 
bill.

[[Page H351]]

  The SPEAKER pro tempore. Is the gentleman from Massachusetts opposed 
to the bill?
  Mr. NEAL. Mr. Speaker, I am not opposed to the legislation, no. I am 
not claiming time in opposition. That is the point.
  The SPEAKER pro tempore. Pursuant to the rule, the gentleman from 
Missouri (Mr. Smith), and the gentleman from Texas (Mr. Roy) each will 
control 20 minutes.
  The Chair recognizes the gentleman from Missouri.


                             General Leave

  Mr. SMITH of Missouri. Mr. Speaker, I ask unanimous consent that all 
Members may have 5 legislative days in which to revise and extend their 
remarks and include extraneous material on the bill under 
consideration.
  The SPEAKER pro tempore. Is there objection to the request of the 
gentleman from Missouri?
  There was no objection.
  Mr. SMITH of Missouri. Mr. Speaker, I yield myself such time as I may 
consume.
  Mr. Speaker, the Tax Relief for American Families and Workers Act is 
pro-growth, pro-jobs, pro-American.
  The legislation locks in $600 billion in pro-growth tax policies by 
restoring three key provisions from President Trump's successful 2017 
tax reform that have a proven record of creating millions of jobs, 
raising workers' wages, and sparking more investment and economic 
growth right here at home.
  This bill restores full R&D expensing, interest deductibility, and 
100 percent expensing. Each of these policies will help American 
businesses grow, create jobs, and sharpen their competitive advantage 
against China.
  This will create over $70 billion in new R&D investment and over 
900,000 new jobs, increase small business investment by $400 billion, 
and generate $58 billion in additional take-home pay for American 
workers.
  Today, America's small businesses are being pummeled by high prices 
and interest rates. This package raises the expensing cap for small 
businesses beyond the limit set in the 2017 tax reform, and it cuts 
paperwork for those small businesses by updating the IRS form, last 
changed when Eisenhower was President.
  This bill is not only helping businesses here at home, but this tax 
relief package also ensures America is standing with our key economic 
partner, Taiwan, by ending double taxation on American workers and 
businesses operating in both countries.
  The child tax credit provisions reflect the same structure 
established by the 2017 tax reform. We maintain work requirements while 
enhancing the benefit to support families crushed by today's inflation 
and remove the penalty for families with multiple children. It is both 
pro-worker and pro-family.
  The reforms include meaningful tax relief for those affected by 
natural and manmade disasters and encourage more construction of safe, 
affordable housing.
  At the end of the day, we are replacing bad tax policy with good tax 
policy by cutting off funding for the employee retention tax credit, a 
COVID-era program that costs six times its original amount and is so 
riddled with fraud that the IRS put it on its Dirty Dozen list of the 
worst scams in America. This will save America taxpayers over $75 
billion.
  There is a reason that over 450 groups, representing Americans from 
all walks of life, support this legislation. That includes job 
creators, those supporting workers and families, and those defending 
the right to life. It is a strong, commonsense, bipartisan step forward 
in providing urgent tax relief for working families and small 
businesses.
  Parents and Main Street communities across this country will see 
lower taxes, more opportunity, and greater financial security after we 
pass this legislation.
  I urge my colleagues to support this legislation.
  Mr. Speaker, I reserve the balance of my time.
  Mr. ROY. Mr. Speaker, I rise in opposition to this legislation, and I 
do so reluctantly, because I know of the significant amount of work by 
my friend from Missouri; by those, frankly, on both sides of the aisle 
to reach agreement; and my friends on Ways and Means.
  There are important provisions in this legislation that are critical 
for job growth, for economic growth, and critical for the well-being of 
our country. There are numerous businesses I know in Texas and around 
this country that understand the importance of the expensing 
provisions, the interest provisions, and research and development.
  However, unfortunately, as happens in this town, this legislation 
comes with provisions that the people I represent are tired of. They 
are provisions that would continue to expand the welfare state--as The 
Wall Street Journal editorialized about--by expanding the child tax 
credit in ways that will continue to fund people directly through 
refundable credits, which we find to be problematic, and we think 
undermines the kind of economic activity and incentive to work and 
incentive to produce value that we think is critically important for 
economic growth.
  Importantly, that provision is also available to parents who are here 
in this country illegally with children born in the United States. We 
think that is a problem. We think that is not just allowing, 
essentially, birthright citizenship anchor babies, but funding it. That 
is a problem.
  Now, my colleagues on this side of the aisle will rejoin that that 
was a product of the 2017 bill that was pushed by and passed by 
Republicans, including President Trump, to which I say: Right. So what? 
It is still wrong. It is still bad policy. We shouldn't do it, and we 
should not be perpetuating it now.
  All through the eleventh hour last night, I worked hard trying to 
find a way to come up with a provision that might be palatable on both 
sides of the aisle, this side of the aisle, to find a way to say: Let's 
get that provision pulled off so we can move the pieces that will be 
good for economic growth and prosperity that I think has bipartisan 
support and clear support on this side of the aisle.

  Unfortunately, we have not done that.
  I am getting a lot of correspondence from people that I represent who 
are sick of the same old game in this town. They are sick of everyone 
saying that we are just going to keep doing the same thing, and that we 
are going to, in this case, again, continue to expand the welfare state 
in a way that entices people to come and benefit from the United States 
illegally at a time when we have a heightened level of illegal traffic 
into the United States: 300,000 people crossing the border in December, 
and millions who have crossed under this President. We are now, in the 
middle of that crisis, going to continue to fuel the fire.
  I think that is a mistake. I think it is a mistake for the country. I 
think it is a mistake on policy. I think it is a mistake politically.
  Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 1 minute to the gentleman 
from Nebraska (Mr. Smith).
  Mr. SMITH of Nebraska. Mr. Speaker, I rise today in support of this 
tax bill.
  I am particularly pleased this bill includes language that I 
introduced to ensure capital-intensive industries can fully deduct the 
cost of interest from their taxes. This is particularly important right 
now as Americans continue to deal with recent high inflation and higher 
interest rates.
  Alongside provisions ensuring domestic research and development in 
small business capital expenses are fully deductible, this bill 
enhances the opportunity to develop new products in America, create 
jobs, making those products here, and then sell those products around 
the world.
  I am also glad this bill includes language ensuring Americans living, 
working, and investing in companies within our ally, Taiwan, do not 
face double taxation.
  Also, I especially appreciate that the language of the Tax Cuts and 
Jobs Act applying to the child tax credit is continued in this bill.
  Mr. Speaker, this is a strong bill. It deserves strong bipartisan 
support. I look forward to voting for it. I urge my colleagues to do 
the same.
  Mr. SMITH of Missouri. Mr. Speaker, I ask unanimous consent that 
debate on the pending motion be extended by 20 minutes, to be 
controlled by the gentleman from Massachusetts (Mr. Neal).
  Mr. GAETZ. Mr. Speaker, I object.

[[Page H352]]

  The SPEAKER pro tempore. Objection is heard.
  Mr. ROY. Mr. Speaker, I yield such time as he may consume to the 
gentleman from Florida (Mr. Gaetz).

                              {time}  1715

  Mr. ROY. Mr. Speaker, I yield such time as he may consume to the 
gentleman from Florida (Mr. Gaetz).
  Mr. GAETZ. To the extent that this is a tax bill, there are good 
provisions in it on business expensing for economic growth. 
Nonetheless, Mr. Speaker, this is not a tax bill. This is a welfare 
bill masquerading as a tax bill. The Wall Street Journal was correct to 
identify the ways in which this legislation vastly expands the welfare 
state.
  This is how the bipartisan agreement came together: If the 
Republicans were willing to give the Democrats what they wanted for 
illegal aliens to get massive subsidies and welfare, then the Democrats 
were willing to give the Republicans what they wanted on a bunch of 
business welfare.
  The child tax credit, as currently contemplated, will be a massive 
pull factor to bring people into this country illegally, and we could 
have, as the majority party, demanded constraints to stop them from 
being able to use the money that way. Nevertheless, bipartisanship was 
more important than good policy.
  As my friend from Kentucky (Mr. Massie) noted recently, Mr. Speaker, 
if you aren't paying taxes and you get a refundable tax credit in the 
form of a check, that is not a tax cut. That is not even tax policy. 
That is just welfare. That is just giving people money who didn't 
initially pay it in, and a bunch of them are here illegally.
  It is not just a welfare bill in that respect. It is also corporate 
welfare. Indeed, these tax credits they have put in there are so 
targeted, they are bought and paid for by the lobbyists who fund their 
campaigns and give them donations, and it is entirely wrong. We should 
have a flat tax code.
  The R&D tax credits they are putting in are deeply misguided. They 
continue to distort the economy, and, frankly, it is just another 
flavor of a lot of the Green New Deal tax credits that you act like you 
are against, but, indeed, Mr. Speaker, that is not the case.
  This is not a tax bill. It is a welfare bill in drag, and that may be 
appealing to some of the proponents.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 1\1/2\ minutes to the 
gentleman from Massachusetts (Mr. Neal), who is the ranking member of 
the Ways and Means Committee.
  Mr. NEAL. Mr. Speaker, this is not the bill I would have written, but 
this is sensible policy. There is no denying the fact that, despite 
what the two previous speakers have said, 16 million children will 
benefit immediately from the expansion of the child tax credit.
  This is not welfare. Addressing childhood poverty in America ought to 
be a priority for us every single day. Low-income housing tax credit is 
sound policy. Our economy grew 3.1 percent last year thanks, in some 
measure, to Joe Biden's economic policies.
  I can't believe that we would sit here tonight and hear that 
addressing childhood poverty is welfare. The number of children in 
America who live outside of the mainstream because of concerns that 
they did not create tells much of the whole story.
  This is a bipartisan piece of legislation. It is not perfection. It 
is not what I would have written, but this is a decent tax package to 
go forward.
  Mr. ROY. Mr. Speaker, I yield 1 minute to the gentleman Texas (Mr. 
Doggett).
  Mr. DOGGETT. Mr. Speaker, this corporate tax windfall bill, thinly 
disguised as help for children, offers even more tax advantages to 
corporations that are paying today a mere 7.8 percent tax rate.
  A working mother of two earning the average wage pays a Federal 
effective rate of 20 percent. Even The Wall Street Journal called one 
provision in this bill a retroactive sop. It is minimal help for 
children and maximum benefits for those who are failing to pay their 
fair share. For every $1 that goes to children under this bill, $5 goes 
to corporations.
  Republicans are enabled to lock in $600 billion in extended Trump tax 
breaks while millions of children are left in preventable poverty and 
are denied a full tax credit. While bipartisan, this bill is no more 
equitable than our broken bipartisan tax code overflowing with 
loopholes and special advantages for the well-connected.
  This deal only continues slanting our tax system against working 
families. Reject the unjustified corporate ransom and lock in genuine 
relief for children.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to gentleman 
from Illinois (Mr. LaHood).
  Mr. LaHOOD. Mr. Speaker, I thank Chairman Smith for negotiating this 
good, monumental tax bill.
  I particularly want to highlight the inclusion of two affordable 
housing provisions in the bill. They are provisions that stem from my 
bill, the Affordable Housing Credit Improvement Act, which has garnered 
the support of 212 cosponsors in the House equally divided between 
Republicans and Democrats.
  We are facing an affordable housing crisis in this country, and 
strengthening the low-income housing tax credit, LIHTC, established by 
Ronald Reagan is key in this and will be very successful to bridging 
the gap to more affordable housing in this country.
  Mr. Speaker, I urge a ``yes'' vote on this very good tax bill.
  Mr. ROY. Mr. Speaker, I yield such time as he may consume to the 
gentleman from Kentucky (Mr. Massie).
  Mr. MASSIE. Mr. Speaker, I thank the gentleman from Texas for 
yielding.
  Mr. Speaker, there is something in this bill called tax credits, but 
they are also called refundable.
  So what is a refundable tax credit?
  It is welfare by a different name.
  We are going to give cash payments--checks--to people who don't even 
pay taxes. The hardworking constituents whom I represent in Kentucky 
are tired of getting up at 6:00 a.m., driving an hour or two to work 
and working their hind ends off to watch their neighbors collect these 
checks of which there will be more of after this bill. It is just 
wrong.
  Now, does anybody find it interesting that the Democratic leadership 
has not even claimed time in opposition to this bill?
  Why is that?
  Why aren't they opposed?
  Now, there are a few Democrats opposed. Maybe some don't think it 
goes far enough, or some are opposed to what they call corporate 
welfare in here, but, by and large, the Democrats are not opposed to 
this because this is an expansion of the welfare state. That is what it 
is.
  So here is my concern about that: Is it mean to give away money?
  No. It is not mean. We could consider it compassionate until you 
think about the implications.
  Now, they say this tax bill is paid for.
  What does that mean?
  What does it mean when it is paid for?
  There are some gimmicks in here that are not going to reduce the 
debt. This is actually going to cost. Now, by Washington, D.C., math, 
it is paid for. Nonetheless, Mr. Speaker, when you look at the national 
debt, it will go up as a result of this bill. Everybody in here knows 
it. We know these are gimmicks when you call it a pay-for. This bill 
will increase our debt.
  What is that going to do?
  It is going to cause inflation to go up. That is going to affect 
everybody, including the people you are trying to give the money to for 
having kids.
  This is bad policy. I am opposed to it, and I urge a ``no'' vote.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentlewoman from Washington (Ms. DelBene).
  Ms. DelBENE. Mr. Speaker, the tax bill we are considering today 
contains several wins for families and our economy, but one piece falls 
short. The child tax credit expansion would still leave behind millions 
of kids in families that need it the most.
  Democrats offered a solution proven to cut child poverty in half, but 
Republicans rejected it. I will still continue leading the effort to 
fully expand the child tax credit, invest in our children, and lift up 
families.
  While today's bill is imperfect, it does include policies I have 
championed, including the largest expansion of the low-income housing 
tax credit in several decades and policies to reduce double taxation on 
American and Taiwanese businesses and workers.
  Mr. Speaker, I urge my colleagues to support this bill.
  Mr. ROY. Mr. Speaker, may I inquire how much time is remaining.

[[Page H353]]

  The SPEAKER pro tempore. The gentleman from Texas has 12 minutes 
remaining.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Arizona (Mr. Schweikert).
  Mr. SCHWEIKERT. Mr. Speaker, this is sort of elementary school 
economics. A dozen things have been said here that are absolutely 
wrong.
  Mr. Speaker, if you look at the 2017 tax reform, where did we get the 
greatest economic boost with the least amount of cost?
  It was actually the R&D and the expensing. We actually have models 
that make it perfectly clear the expensing actually was the one portion 
of the tax reform that actually paid for itself. That is because in a 
higher interest rate world--and I believe higher interest rates came 
from Democrat spending, but that is a different discussion--the fact of 
the matter is that if you do research and development then you have to 
finance it. This is where you get the economic growth that actually 
knocks down inflation and makes our society more prosperous. It is a 
good bill.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from California (Mr. Thompson).
  Mr. THOMPSON of California. Mr. Chairman, I agree with my Democratic 
colleagues that the child tax credit portion of this bill should be 
stronger. Be that as it may, in a divided government, you don't always 
get exactly what you want, and this bill is an improvement over the 
status quo.
  I am especially pleased at the inclusion of my legislation providing 
critical relief to wildfire survivors which passed the Ways and Means 
Committee unanimously.
  Mr. Speaker, I urge my colleagues to pass this bill.
  Mr. SMITH of Missouri. Mr. Speaker, I reserve the balance of my time.
  Mr. ROY. Mr. Speaker, I yield 1 minute to the gentlewoman from 
California (Ms. Sanchez).
  Ms. SANCHEZ. Mr. Speaker, I always support good-faith efforts to 
improve our Nation's tax code.
  I don't oppose reasonable benefits for the American businesses that 
drive economic growth and strength. However, I can't support a bill 
that provides generous tax breaks to large corporations while offering 
only minimal tax relief for working families.
  Republicans have refused again and again to enact Democratic tax 
writers' proposals that would enact a more generous version of the 
poverty-busting child tax credit.
  Under President Biden's American Rescue Plan, the child tax credit 
lifted millions of kids out of poverty and helped their families buy 
groceries, pay for healthcare, and cover their rent.
  As a mother and a legislator, I will never stop fighting on behalf of 
our country's poorest babies and children and the moms, dads, 
grandparents, and other caregivers who raise them.

  Unfortunately, I have to vote against this tax scheme because I, for 
one, recognize that working families matter, or should matter, just as 
much as businesses.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 1 minute to the gentleman 
from Georgia (Mr. Ferguson).
  Mr. FERGUSON. Mr. Speaker, I rise today in support of this piece of 
legislation. I do not worry one single bit about making sure that 
American business is more competitive on the global stage. Making sure 
that our businesses are competitive through research and development 
and then having the capital to turn those ideas into a product and then 
turn those products into jobs here in America is something that we 
should be doing.
  Staying competitive against our adversaries on the global stage is 
something that we should be doing.
  This is not about giving businesses a tax break. This is about 
investing in America and American jobs.
  Moreover, the complete mischaracterization about the child tax credit 
is the most intellectually dishonest conversation that I have heard on 
this floor in a very long time.
  This is about making sure that people who work and their families 
have the ability to get ahead.
  Let me tell you something, Mr. Speaker, we all believe on this side 
of the aisle that you should work in order to receive Federal benefits. 
That is something that this bill does, and I think it is important.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. SMITH of Missouri. Mr. Speaker, I yield an additional 15 seconds 
to the gentleman from Georgia.
  Mr. FERGUSON. Mr. Speaker, the gentleman from Florida just 
characterized the child tax credit piece of this bill, which is 
something that President Trump signed into law, as giving people who 
are here illegally a check. I hate to see that mischaracterization from 
my colleague from Florida about President Trump's signature bill.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Connecticut (Mr. Larson).
  Mr. LARSON of Connecticut. Mr. Speaker, I rise in strong support of 
this bill. I especially want to commend my colleague, Ron Estes, for 
working directly on this R&D tax credit.
  Mr. Speaker, what you are hearing today on this floor is what happens 
when we work and pull together. We are in a race with China, and we had 
better be well aware of what we have to do with R&D, because that is 
critical to it.
  I also commend Rosa DeLauro, whom you will hear from as well, Mr. 
Speaker. I thank Dr. Ferguson for what he has to say just about the 
child tax credit and how important that is. Children need to be 
protected.
  Mr. ROY. Mr. Speaker, I yield such time as he may consume to the 
gentleman from Florida (Mr. Gaetz).
  Mr. GAETZ. Mr. Speaker, if my characterization of the child tax 
credit is intellectually dishonest, then I would love to hear the 
warrant behind that claim because none of my colleagues can state how a 
huge sum of this money is not going to end up in the hands of illegal 
immigrants.
  When it comes to evaluating that context in the era of Trump versus 
the era of Biden, it is somewhat embarrassing that I would have to 
remind a Republican colleague that it is the Biden administration that 
has let in 10 million additional people which vastly blows out the cost 
of this particular endeavor.
  Under Trump, we didn't have an open border, so there was less of a 
concern about drawing more people here illegally to this child tax 
credit.

                              {time}  1730

  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentlewoman from Texas (Ms. Van Duyne).
  Ms. VAN DUYNE. Mr. Speaker, I rise in support of the Tax Relief for 
American Families Act. This is actually paid for. It will extend the 
Trump-era tax cuts that brought us record employment, economic growth, 
and wages that grew at a rate nearly 5 percent higher than inflation.
  If we do not make these important reforms to our tax code, my home 
State of Texas will lose more than 8,000 jobs and nearly $700 million 
in wages.
  Importantly, this bill will maintain Trump-era safeguards in work 
requirements to the child tax credit to ensure that it only goes to 
American citizens, making it one of the few tax credits to actually 
have the strong requirement for block claims from illegal immigrants 
and noncitizens.
  Mr. Speaker, I stand with north Texas families.
  Mr. ROY. Mr. Speaker, I yield myself such time as I may consume.
  Mr. Speaker, the truth is, illegal immigrants are eligible for the 
CTC expansion because they can get an individual taxpayer 
identification number in lieu of a Social Security number.
  In fact, in the USA Today, somebody who is a proponent of this 
actually opined and wrote in the USA Today, ``How the Child Tax Credit 
Could Lift Undocumented Immigrants out of Poverty.''
  That is just the truth. It is what we actually did in 2017. I don't 
care if my colleagues on this side of the aisle think that is a good 
idea. I don't care if they are willing to weigh that against what they 
believe is good for the corporate changes to the law, but don't try to 
snow the American people. That is what we are doing.
  But my colleagues on this side of the aisle will thump their chest 
about being so great on the border, and yet,

[[Page H354]]

the border is wide open. There was still 300,000 pouring across in 
December.
  Oh, what have we done? We had some votes, but we are still funding 
it. Here, we are not just funding it, we are juicing it. We are 
actually encouraging it. We are supplementing it. We are saying: Come 
on over here, have children, and get a tax credit.
  How is that a policy that the American people want to support?
  Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Oregon (Mr. Blumenauer).
  Mr. BLUMENAUER. Mr. Speaker, I thank the gentleman for yielding.
  Mr. Speaker, listening on the floor of the House, there are arguments 
that are legitimate in terms of the shortcomings of this. It is not 
perfect, but I don't want the perfect to be the enemy of the good. I 
don't want to deny 16 million children an opportunity for this Federal 
support in order to make a point.
  I hope we will come to the point we are able to deal with tax policy 
in a more rational fashion. Under Chairman Neal, I think we will, but 
in the meantime, it is important to pass this legislation to meet the 
needs of American families.
  Mr. ROY. Mr. Speaker, I yield such time as he may consume to the 
gentleman from Pennsylvania (Mr. Perry).
  Mr. PERRY. Mr. Speaker, I applaud my colleagues on our side of the 
aisle for working hard to try and return some of the money to 
hardworking people. I am always for that. If you are working, you 
should keep the money that you earn. Whether you are corporate or 
whether you are an individual, but here is where I have a problem--this 
refundable tax credit.
  See, my folks get up every day. They get up early. It is usually 
dark. They put their kids on the schoolbus and they go to work to 
afford their bills, which they can barely afford right now. They can't 
afford their groceries, their gasoline, their credit card bills. They 
can't afford them because the Federal Government is flooding the 
economy with money.
  Now, we are getting ready to flood more because, Mr. Speaker, 
regardless of what anybody thinks, if you are here illegally with a 
Social Security number, you are going to get the money.
  I have a news flash for you: Little kids don't get the checks sent to 
them, even though they got a Social Security number, but their parents, 
who are here illegally, do, and it is going to happen by the millions.
  My folks, the folks that are working hard to put food on their table, 
are tired of paying for that. We should reject this.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Kansas (Mr. Estes), who has led the legislation on 
research and development.
  Mr. ESTES. Mr. Speaker, I thank Chairman Smith for his tireless work 
on this tax package that we are about to pass. American families and 
small businesses are in desperate need of economic relief. High costs 
of goods and services and burdensome regulations have strained 
pocketbooks and the economy, and Americans need a break.
  The Tax Relief for American Families and Workers Act provides the win 
we need. This bill includes a provision that I have been advocating 
for--the immediate R&D expensing. Without this, we have seen the growth 
rate of R&D spending slow, and since three-quarters of R&D spending is 
on wages and salaries, R&D amortization is primarily a jobs issue.
  Countless Kansas small businesses expressed their grave concern about 
this expired provision. I am glad we are taking a positive step to 
restore immediate R&D expenses.
  Mr. ROY. Mr. Speaker, I yield 1 minute to the gentlewoman from 
Wisconsin (Ms. Moore).
  Ms. MOORE of Wisconsin. Mr. Speaker, do you all remember when our 
good friend, Mitt Romney, talked about the 47 percent of the takers?
  This bill locks in the principle that we have takers and makers. We 
have $600 billion of permanent tax cuts to the wealthiest people, and 
yet some woman who gets up in a rural area and marches off to the 
grocery store and works 30 hours a week won't see a dime of this tax 
credit because she is too poor. She is a taker; she is not a maker.

  You know, I think it is all right. This is a compromised bill. It is 
better than current law where that same minimum wage worker would have 
to work 70 hours a week in order to get this tax credit now only has to 
work 40 hours a week, plus do a little Uber on the side to get the tax 
credit.
  So I think we need to compromise, but we don't need to capitulate. We 
are not going to expand this tax credit for poor children, but the 
poorest will be even poorer.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Pennsylvania (Mr. Smucker).
  Mr. SMUCKER. Mr. Speaker, the Tax Cuts and Jobs Act worked. It grew 
the economy. It increased revenue and it helped every American family 
to achieve a better life. It also, for those in opposition to this 
bill, for the first time, required a Social Security number for the 
child in order for a family to receive the child tax credit.
  Many who are in opposition to this bill today voted for the Tax Cuts 
and Jobs Act. Are you telling me you regret that vote? This continues 
the provision to require children to have a Social Security number for 
the family to benefit from the child tax credit.
  Mr. ROY. Mr. Speaker, may I inquire as to the time remaining.
  The SPEAKER pro tempore. The gentleman from Texas has 6 minutes 
remaining.
  Mr. ROY. Mr. Speaker, I yield 2 minutes to the gentleman from 
Virginia (Mr. Good).
  Mr. GOOD of Virginia. Mr. Speaker, I thank the gentleman from Texas 
for yielding me the time. I appreciate it.
  Mr. Speaker, here we are again where the minority party isn't even 
using their time to oppose the bill put forward by the majority.
  Just 2 weeks ago, the last major piece of legislation that we passed 
by suspension of the rules, the Democrat minority party voted for it 
207-2. It will be interesting tonight to see how many Democrats vote 
for this and how many Republicans vote for it.
  I am against this because of the suspension of the rules, the process 
that we are using. I am against it because the expansion of the welfare 
state. I am against it because we are not correcting the fact that 
illegals can have access to the child tax credit.
  I have never done this on the House floor before, but I am going to 
read what someone else wrote about this bill.
  This is from Kevin Roberts with Heritage Foundation. I commend them 
for what they said: ``Although, the bill claims that its aim is to 
provide `tax relief' to families with children, it contains very little 
relief for working families. Instead, nearly 91.5 percent of the 
`family benefits' in this bill are cash welfare payments to families 
who pay no Federal income taxes.
  . . . the bill provides $30.6 billion in new welfare cash payments. 
If these new cash welfare benefits were extended over 10 years (which 
is very likely) the total cost would exceed $140 billion.''
  The Ways and Means bill moves toward fulfilling President Biden's 
aims. The bill embraces the premise and goals of Biden's plan to 
greatly increase cash welfare payments, predominantly for single 
parents while weakening the already poorest work requirements.
  This bill obviously sets the ground for a future compromise that 
would fully enact the Biden child allowance program. Overall, this 
portion of the Ways and Means bill represents an enormous political 
victory for President Biden.
  Under current law, illegal aliens who have children that were born in 
the U.S., and many do, can claim welfare payments from the additional 
child tax credit. The Ways and Means bill expands these welfare 
payments for millions of people who are in the U.S. illegally and for 
millions more entering in the future. The bill weakens welfare work 
requirements and continues a longstanding push by Congress to dress up 
welfare benefits as tax relief.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Illinois (Mr. Davis).
  Mr. DAVIS of Illinois. Mr. Speaker, I have been told that a half a 
loaf is better than none, but this isn't even a half a loaf, but I am 
going to vote for it because our families and businesses need

[[Page H355]]

help. While it does help, it does not create a 50 percent reduction in 
child poverty as we did in 2021. It is more like a deal than a bill, 
but I am going to vote for it.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 1 minute to the gentleman 
from Oklahoma (Mr. Hern).
  Mr. HERN. Mr. Speaker, as a result of President Trump's tax reform, 
our economy was strong, wages were up, unemployment was at all-time 
lows. We have a critical tax cliff fast approaching at the end of 
2025--just 20 months from now--with the majority of President Trump's 
progrowth policies expiring.
  Extending these expired provisions is not just an economic issue, one 
could argue this is a national security issue.
  Mr. Speaker, we can't expect to compete with China when it is more 
expensive to invest, innovate, and grow here in the United States. I 
urge all of my colleagues to support this bill, which extends President 
Trump's progrowth policy agenda and increases U.S. competitiveness and 
resilience against China's economic influence.
  Mr. ROY. Mr. Speaker, I yield 1 minute to the gentlewoman from 
Connecticut (Ms. DeLauro), the ranking member of the Appropriations 
Committee.
  Ms. DeLAURO. Mr. Speaker, I cannot vote for a deal that so lopsidedly 
benefits big corporations while failing to ensure a substantial tax cut 
to middle- and working-class families.
  The deal is inequitable at a time when we have seen the greatest rise 
in inequality. Big corporations made super profits at the expense of 
the consumer. It is a mockery of who representative government works 
for: massive tax cuts for the biggest corporations, while denying 
middle-class families the economic security they had under the 
expanded, monthly child tax credit.

  Let us be unequivocal. This is a reversal of the largest middle-class 
tax cut in history. This bill provides billions of dollars in tax 
relief for the wealthy, pennies for the poor.
  The biggest corporations, who have paid no Federal income tax, are 
the beneficiaries of this deal. Big corporations are richer than ever. 
This is no even split.
  Families today live paycheck to paycheck, not seeing their wages keep 
up with rising costs. The economy is not working for them. The bill 
fails to improve the child tax credit, leaving millions of middle-class 
families without the tax cut they received in 2021. It keeps millions 
of children in preventable poverty while giving the biggest tax breaks 
to the biggest corporations.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentlewoman from West Virginia (Mrs. Miller).
  Mrs. MILLER of West Virginia. Mr. Speaker, I commend Chairman Smith 
for his diligent work. It is a huge win for working families, small 
businesses, and employers throughout our country. This has set the tone 
for the Ways and Means' agenda where we are able to make the best 
package possible.
  The child tax credit expansion will help working families, while 
protecting the important guardrails that we fought so hard to ensure 
that the program is going to help Americans in need.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentlewoman from Alabama (Ms. Sewell).
  Ms. SEWELL. Mr. Speaker, Democrats today will make good on a promise 
to deliver tax relief for American families.
  This bill expands the child tax credit for 16 million children, 
including 280,000 children in Alabama.
  The tax credit is one of the most effective antipoverty programs in 
the country and will, again, provide much-needed assistance to families 
throughout Alabama.
  This bill will also provide much-needed disaster tax relief to the 
families of the Black Belt, Dallas County, Hale County, Greene County, 
and Sumter County that fight to rebuild in the wake of last year's 
tornado.
  Mr. Speaker, I ask my colleagues to support this measure.

                              {time}  1745

  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Florida (Mr. Steube), the author of the disaster tax 
language.
  Mr. STEUBE. Mr. Speaker, in September 2022, my district in southwest 
Florida was devastated by Hurricane Ian. Totaling over $112 billion in 
damages, Ian was the third costliest hurricane in American history and 
the most expensive ever to hit Florida. Over a year later, my 
constituents are still working toward rebuilding their lives.
  I introduced the Federal Disaster Tax Relief Act, which is included 
in this bill, to deliver relief for American families in 45 States who 
were victims of federally declared disasters. This includes victims of 
wildfires, chemical spills, and hurricanes that have affected millions 
of Americans over the past several years.
  Mr. Speaker, we should pass this important tax relief for victims of 
natural disasters. I urge my colleagues to support this legislation.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Virginia (Mr. Beyer).
  Mr. BEYER. Mr. Speaker, this bill is not perfect, but no bill ever 
is. This act is win-win-win. There will be 400,000 children who will be 
lifted out of poverty. There will be 200,000 new affordable homes 
built. Research and development, the absolute essential investment for 
economic prosperity, will be incentivized again.
  Politics is the art of the possible. In a divided Congress, this is 
the best we can accomplish. I urge a ``yes'' vote.
  Mr. ROY. Mr. Speaker, The Wall Street Journal editorial last week 
said about this bill:
  ``Up to $1,600 of the $2,000 credit is refundable, and the bipartisan 
bill would make $2,000 refundable by 2025.'' Now, in fairness, ``A 
$1,400 limit was tethered to inflation under the 2017 GOP tax law and 
is thus increasing over time anyway.''
  The general point here is: ``But at least admit this is income 
redistribution, not `tax relief'. . . . '' It is income redistribution.
  ``Worse, the deal undermines the incentive to work in return for the 
credit. The current credit at least requires a small amount of income--
a mere $2,500--to begin to claim it. That means it gives low-income 
Americans an incentive to work more to earn more, which is good for 
them and their children.''
  However, this would allow parents to ``rely on the prior year's 
income to trigger the credit for 2024 and 2025. Work one year--and earn 
benefits for two. The practical effect is to `cut the work requirement 
in half,' '' according to a report by the American Enterprise 
Institute.
  The fact is the editorial closes: ``The business lobby wants the tax 
breaks.'' By the way, this is The Wall Street Journal editorial. ``The 
business lobby wants the tax breaks, and some Democrats in Congress 
want them as well. But those policies ought to stand or fall on their 
merits, not on a political trade that will do more harm than good.''
  Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, this legislation strengthens our 
workforce.
  There is a report from experts at the Joint Committee on Taxation 
which confirms that the child tax credit changes will have a net 
positive effect on jobs and workforce participation can be found in the 
following location: https://www.jct.gov/getattachment/dce63c47-9b1d-
4f10-8a55-2471681f7685/x-6-24.pdf
  Mr. Speaker, I yield 30 seconds to the gentleman from Utah (Mr. 
Moore).
  Mr. MOORE of Utah. Mr. Speaker, I rise in strong support of the Tax 
Relief for American Families and Workers Act of 2024.
  Not a lot of legislation actually affects every single American. 
Today, we get a chance to actually pass a piece that does. Folks back 
home hear a lot of the drama that we do, and they hear what gets put in 
the headlines, but never have I seen neighbors of mine, literally 
coaches that I coach with say: Look, this is a killer for my small 
business. Losing the R&D tax credit has destroyed my ability to grow my 
small business.

[[Page H356]]

  This affects every single American and will be one of the most 
productive, positive, progrowth tax policies that this Congress and 
Congresses to come will do.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Pennsylvania (Mr. Evans).
  Mr. EVANS. Mr. Speaker, I rise to discuss an underappreciated part of 
this bill, improvements to the low-income housing tax credit. This is 
urgently needed. Millions of American families struggle to pay their 
rent or buy a house. We must do more.

  This bill is one step toward eliminating housing insecurity in 
America. I urge my colleagues to support it. We must make sure that no 
child goes without a roof over their head in this country. I will 
continue to work to make that a reality.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Iowa (Mr. Feenstra).
  Mr. FEENSTRA. Mr. Speaker, agriculture is the economic engine of my 
district, and our tax policies must help our farmers grow, invest, and 
compete with China. This legislation does exactly that.
  Our farmers will benefit from two key provisions in this bill: 100 
percent bonus appreciation and the expansion of the section 179 
deduction limit. Our producers rely on these tools to buy farm 
equipment and invest in their operations.
  This legislation is a victory for our farmers and rural communities.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Illinois (Mr. Schneider).
  Mr. SCHNEIDER. Mr. Speaker, today I rise in support of this truly 
meaningful bipartisan legislation that will benefit millions of needy 
children.
  This bipartisan bill is the most significant, if not the only 
significant legislation passed so far this Congress, helping lift kids 
out of poverty, lowering the tax burden for working families, 
supporting innovative businesses, and expanding the supply of 
affordable housing.
  Mr. Speaker, despite the exotic arguments those opposed to this bill 
tonight are trying to make, these are things we should all be proud of. 
I urge my colleagues to support this bill.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 1 minute to the 
gentlewoman from New York (Ms. Malliotakis).
  Ms. MALLIOTAKIS. Mr. Speaker, I thank Chairman Smith and the entire 
committee for their hard work on this. Trump's tax cuts created jobs, 
lifted wages, led to 50-year low unemployment, and lifted millions from 
poverty.
  Today, we are building on that success with projobs, progrowth, 
profamily policies by extending these priorities and increasing the 
child tax credit as well, but we are also helping build affordable 
housing by expanding Reagan's initiatives, and we are enabling 
Taiwanese investment in semiconductor manufacturing here in the United 
States to further create jobs, enhance our supply chain, and reduce 
dependency on China.
  We still have so much work to do. Over the next 2 years, there will 
be more tax policies coming out of this House. I hope we will be able 
to increase the standard deduction; that we will be able to provide 
SALT--State and local tax--relief; and exempt more Social Security 
income from taxation to help our seniors, who have not seen that change 
in four decades.
  Mr. Speaker, I thank everyone on this committee who worked so hard in 
a bipartisan manner to get this done. I look forward to seeing it pass 
in both Houses.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from California (Mr. Panetta).
  Mr. PANETTA. Mr. Speaker, this is a good bill. It includes tax 
credits for childcare, immediate expensing for small business R&D, tax-
free settlement for natural disasters and, yes, more affordable 
housing. This is a good bill, not just for my district, but for our 
country and our country's faith in Congress' ability to actually affect 
the lives and livelihoods of all Americans.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I ask unanimous consent to 
include in the Record a letter signed by a dozen pro-life 
organizations, including Concerned Women for America, Susan B. Anthony 
Pro-Life America, and the Eagle Forum in support of this legislation 
and its important profamily and prowork provisions.
  The SPEAKER pro tempore. Is there objection to the request of the 
gentleman from Missouri?
  There was no objection.

                                                 January 29, 2024.
     Hon. Mike Johnson,
     Speaker, House of Representatives,
     Washington, DC.
     Hon. Charles Schumer,
     Majority Leader, U.S. Senate,
     Washington, DC.
     Hon. Hakeem Jeffries,
     Minority Leader, House of Representatives,
     Washington, DC.
     Hon. Mitch McConnell,
     Minority Leader, U.S. Senate,
     Washington, DC.
       Dear Speaker Johnson, Minority Leader Jeffries, Majority 
     Leader Schumer, and Minority Leader McConnell: As pro-life 
     organizations, we support making sure mothers, fathers and 
     their children have every tool and resource available to 
     choose life and support families. American families face 
     unprecedented challenges with higher costs of the most 
     essential items for families such as food, gas, energy, 
     health care, and housing. We write to you in support of an 
     opportunity to advance a pro-family, pro-parent tax package 
     that recognizes the unique challenges facing American parents 
     today.
       The Tax Relief for American Families and Workers Act (H.R. 
     7024) would enhance the Child Tax Credit (CTC) to financially 
     bolster families, promote life, and support growing families. 
     This is especially critical during this time of devastating 
     inflation and paralyzing economic uncertainty.
       H.R. 7024 improves the CTC to better serve all families in 
     need by adjusting the CTC for inflation so that they receive 
     tax relief. This means as the costs of having a family 
     increase, so will the resources moms and dads have to make 
     ends meet and provide for their kids.
       The legislation would also stop penalizing parents for 
     having more than one child by treating all children equally. 
     This is not only fair for families no matter their size but 
     also ensures support for growing families. The bill also 
     promotes economic growth by strengthening incentives to work 
     by reducing families' marginal rate by 15 percentage points 
     per child for parents with earned income.
       H.R. 7024 provides commonsense protection for families and 
     supports growing families at a time when the cost of raising 
     children continues to increase. If Congress does not act to 
     pass H.R. 7024 now, the CTC will continue to discriminate 
     against and financially penalize growing families. Congress 
     has the opportunity within a limited window of time to enact 
     a pro-family, pro-life tax policy that will provide immediate 
     benefit to families in need.
       We are grateful for your strong leadership to promote and 
     protect American families and we urge you to resolve any 
     outstanding differences and then support the enhanced CTC in 
     the Tax Relief for American Families and Workers Act to 
     support families who are struggling today while encouraging 
     families to grow for tomorrow.
           Sincerely,
       Penny Nance, CEO and President, Concerned Women for America 
     LAC; Marjorie Dannenfelser, President, Susan B. Anthony Pro-
     Life America; Walter Kim, President, National Association of 
     Evangelicals; Gary L. Bauer, President, American Values; Joel 
     Grewe, Executive Director, HSLDA Action; Kelsey Hazzard, 
     Board President, Secular Pro-Life; Kristen A. Ullman, 
     President, Eagle Forum; F. Brent Leatherwood, President, 
     Ethics & Religious Liberty Commission of the Southern Baptist 
     Convention; Steven H. Aden, Chief Legal Officer & General 
     Counsel, Americans United For Life; Dave Donaldson, Co-
     founder & CEO, CityServe International; Robert P. George, 
     McCormick Professor of Jurisprudence, Princeton University; 
     Eric Metaxas, Host, The Eric Metaxas Show and Socrates in the 
     City.

  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Pennsylvania (Mr. Fitzpatrick).
  Mr. FITZPATRICK. Mr. Speaker, Americans across the Nation will 
benefit from this progrowth, pro-America, bipartisan tax bill.
  The research and development provision will boost innovation here at 
home, making our Nation much more competitive against China. Enhanced 
small business expensing will allow our community businesses to thrive 
and prosper. Finally, more than 500,000 children in my home State of 
Pennsylvania will benefit from the expanded child tax credit.
  Mr. Chairman, I commend Chairman Smith and Ranking Member Neal for 
working together to advance policies for all Americans.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.

[[Page H357]]

  

  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentlewoman from New York (Ms. Tenney).
  Ms. TENNEY. Mr. Speaker, as a small business owner for a long time in 
upstate New York, I join my colleagues today in supporting H.R. 7024, 
the Tax Relief for American Families and Workers Act.
  This comprehensive package was shaped by critical feedback that we 
received from everyday Americans across this Nation through field 
hearings conducted by the Ways and Means Committee. H.R. 7024 will have 
a meaningful impact on my constituents in upstate New York, way up in 
New York's 24th District, from hardworking families to manufacturers to 
multigenerational family farms, and the largest agricultural district 
in the Northeast. This package will have wide-ranging benefits for so 
many Americans.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I yield 30 seconds to the 
gentleman from Massachusetts (Mr. Neal).
  Mr. NEAL. Mr. Speaker, we have heard the arguments here. This is what 
is possible. Despite what some have said here, this does expand the 
child tax credit. It is clear.
  No legislation that comes to this floor is perfect. We tried very 
hard, and we succeeded on the Democratic side in improving this 
legislation.
  What is in front of us tonight is pretty simple: 16 million children 
will benefit from the improvement to the child tax credit. That is a 
fact.
  Mr. ROY. Mr. Speaker, may I inquire how much time remains.
  The SPEAKER pro tempore. The gentleman from Texas has 1\3/4\ minutes 
remaining.
  Mr. ROY. Mr. Speaker, I reserve the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I am prepared to close, and I 
reserve the balance of my time.
  Mr. ROY. Mr. Speaker, I reiterate my appreciation to my friend, the 
chairman, and all those who worked on this bill in the Ways and Means 
Committee.
  There are a lot of good provisions in this bill, many of which I 
support. There are good provisions in there to help economic growth--
the expensing provisions, interest, R&D--but I have serious 
reservations. The fact of the matter is for all those watching at home, 
to my constituents, this bill does not fix the problem that allows 
illegal aliens who have children who were born in the United States to 
claim the tax credit. It takes the problem we have with so-called 
birthright citizenship and anchor babies and doubles down on it, makes 
it worse. That was a mistake in 2017. We should rectify that mistake.
  However, worse, it goes on and expands the credit.
  Mr. Speaker, 91\1/2\ percent of the relief in this bill are cash 
welfare payments to families that pay no Federal income taxes. It 
provides a total of just $2.8 billion to working families that pay 
taxes over 3 years. The fact is, the credit does expand, and it gets to 
be refundable to the full tune of $2,000 by 2025.
  These provisions undermine the benefits that we are trying to provide 
for economic growth which, I might add, are only a 2-year extension. It 
puts all of this in one big basket in 2025, taking away any leverage we 
are going to have by giving the other side what they want on the child 
tax credit.
  The fact of the matter is, we should not be supporting this bill. We 
should be doing what we said we would do when we got into power: We 
should secure the border of the United States, we should cut spending, 
and we should honor what we campaigned on in this body.
  Mr. Speaker, I yield back the balance of my time.
  Mr. SMITH of Missouri. Mr. Speaker, I confirm for my colleagues that 
this bill preserves existing safeguards of the child tax credit and 
does not open the door for illegal immigrants to claim the credit. No 
other tax credit or deduction can match the child tax credit's 
protections from improper claims combined with safeguards against 
payments to non-U.S. citizens.
  Mr. Speaker, this is a win for millions of small businesses, a win 
for millions of working families. This is a win for America. I urge the 
body to support this great piece of legislation, and I yield back the 
balance of my time.
  Mr. PASCRELL. Mr. Speaker, the enhanced Child Tax Credit enacted by 
Democrats in 2021 slashed childhood poverty in half. I repeat: in half. 
It is not hyperbole to call it one of the most successful policies ever 
passed by this Congress. And it is a tragedy its extension was blocked 
by the other side.
  Restoring some of our policy, as this bill does, will be a lifeline 
for millions of families. And that is vital progress. I do not love 
every element in this package. In committee, Republicans unanimously 
voted to defeat my amendment to add real SALT relief for middle class 
families.
  But this is a start, and we will keep pushing to bring back the full 
enhanced Child Tax Credit and enshrine it for good.
  Mrs. GONZALEZ-COLON. Mr. Speaker, I join in support of H.R. 7024, the 
Tax Relief for American Families and Workers Act, being considered in 
the House today. This bipartisan bill, championed by House Ways and 
Means Committee Chairman Jason Smith and Senate Finance Chairman Ron 
Wyden, improves existing pro-growth tax policies to support America's 
families, strengthen our economy, and boost innovation by helping U.S. 
companies compete against China.
  One of the main provisions in this bill is the Child Tax Credit, 
which benefits more than 250,000 families in Puerto Rico. A study made 
by the Youth Development Institute (Instituto del Desarrollo de la 
Juventud), a non-profit organization focused in reducing child poverty 
on the island, found, youth poverty may have declined from 55 to 39 
percent in 2021 when eligibility for the Child Tax Credit was expanded 
to residents of Puerto Rico with one or two qualifying children. 
Previously this tax benefit only applied to three or more qualifying 
children. I am proud that my legislation recognizing the need to 
include families with one or two children was adopted, and families can 
claim this credit in the same manner as families in the rest of the 
country.
  From hurricanes to earthquakes. Puerto Rico has suffered several 
natural disasters over the last few years. The support we have received 
from Congress and federal agencies has been instrumental in our 
recovery. As such, I sympathize with my colleagues who have been 
afflicted by recent disasters and support the tax provisions that are 
presented on this bill that would bring much needed relief to 
communities across the country.
  I am encouraged by the bipartisan and bicameral work that produced 
this bill, and I strongly encourage my colleagues on the House and Ways 
and Means Committee and Senate Finance Committee to continue working on 
expired tax provisions, including the Rum Excise Tax Cover-Over.
  Earlier this Congress, I reintroduced H.R. 3146, bipartisan and 
bicameral legislation that would modify the amount of money transferred 
to Puerto Rico and the U.S. Virgin Islands from the excise taxes 
collected on rum that is produced in or imported into the rest of the 
United States, known as ``rum cover-over.'' It is used to support 
critical services such as healthcare and education, as well as 
agricultural and conservation efforts.
  I was proud when Congress last approved my bill to extend the rum 
cover over for five years as part of the Bipartisan Budget Act of 2018. 
However, that increased rate of the rum cover over expired at the end 
of December 2021 and has yet to be renewed, resulting in continued 
uncertainty, and negatively impacting the economies of both 
jurisdictions.
  Puerto Rico's rum industry is one of the major drivers of the 
island's economy, producing more than 70 percent of the rum that is 
consumed in the U.S. and 80 percent of the rum consumed around the 
world.
  With that in mind is that Congress created the rum cover over program 
in 1917 and has continued to be part of tax extenders legislation 
since. I encourage my colleagues to include my bill in any forthcoming 
tax legislation,
  The SPEAKER pro tempore. All time for debate has expired. The 
question is on the motion offered by the gentleman from Missouri (Mr. 
Smith) that the House suspend the rules and pass the bill, H.R. 7024, 
as amended.
  The question was taken.
  The SPEAKER pro tempore. In the opinion of the Chair, two-thirds 
being in the affirmative, the ayes have it.
  Mr. ROY. Mr. Speaker, on that I demand the yeas and nays.

[[Page H358]]

  The yeas and nays were ordered.
  The SPEAKER pro tempore. Pursuant to clause 8 of rule XX, further 
proceedings on this motion will be postponed.

                          ____________________