[Congressional Record Volume 171, Number 113 (Monday, June 30, 2025)]
[Senate]
[Pages S4124-S4125]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 2782. Ms. SMITH (for herself and Mrs. Shaheen) submitted an 
amendment intended to be proposed to amendment SA 2360 proposed by Mr. 
Thune (for Mr. Graham) to the bill H.R. 1, to provide for 
reconciliation pursuant to title II of H. Con. Res. 14; which was 
ordered to lie on the table; as follows:

       Strike section 70405 and insert the following:

     SEC. 70405. ENHANCEMENT OF CHILD AND DEPENDENT CARE TAX 
                   CREDIT.

       (a) In General.--Paragraph (2) of section 21(a) of the 
     Internal Revenue Code of 1986 is amended to read as follows:
       ``(2) Applicable percentage.--
       ``(A) In general.--For purposes of paragraph (1), the term 
     `applicable percentage' means 50 percent reduced (but not 
     below the phaseout percentage) by 1 percentage point for each 
     $2,000 (or fraction thereof) by which the taxpayer's adjusted 
     gross income for the taxable year exceeds $125,000.
       ``(B) Phaseout percentage.--For purposes of subparagraph 
     (A), the term `phaseout percentage' means 20 percent reduced 
     (but not below zero) by 1 percentage point for each $2,000 
     (or fraction thereof) by which the taxpayer's adjusted gross 
     income for the taxable year exceeds $400,000.''.
       (b) Increase in Dollar Limit on Amount Creditable.--
     Subsection (c) of section 21 of the Internal Revenue Code of 
     1986 is amended--
       (1) in paragraph (1), by striking ``$3,000'' and inserting 
     ``$8,000'', and
       (2) in paragraph (2), by striking ``$6,000'' and inserting 
     ``$16,000''.
       (c) Special Rule for Married Couples Filing Separate 
     Returns.--Paragraph (2) of section 21(e) of the Internal 
     Revenue Code of 1986 is amended to read as follows:
       ``(2) Married couples filing separate returns.--
       ``(A) In general.--In the case of married individuals who 
     do not file a joint return for the taxable year--
       ``(i) the applicable percentage under subsection (a)(2) and 
     the number of qualifying individuals and aggregate amount 
     excludable under section 129 for purposes of subsection (c) 
     shall be determined with respect to each such individual as 
     if the individual had filed a joint return with the 
     individual's spouse, and
       ``(ii) the aggregate amount of the credits allowed under 
     this section for such taxable year with respect to both 
     spouses shall not exceed the amount which would have been 
     allowed under this section if the individuals had filed a 
     joint return.
       ``(B) Regulations.--The Secretary shall prescribe such 
     regulations or other guidance as is necessary to carry out 
     the purposes of this subsection.''.
       (d) Adjustment for Inflation.--Section 21 of the Internal 
     Revenue Code of 1986 is amended by adding at the end the 
     following new subsection:
       ``(i) Inflation Adjustment.--
       ``(1) In general.--In the case of a calendar year beginning 
     after 2025, the $125,000 amount in paragraph (2) of 
     subsection (a) and the dollar amounts in subsection (c) shall 
     each be increased by an amount equal to--
       ``(A) such dollar amount, multiplied by
       ``(B) the cost-of-living adjustment determined under 
     section 1(f)(3) for the calendar year in which the taxable 
     year begins, determined by substituting `calendar year 2024' 
     for `calendar year 2016' in subparagraph (A)(ii) thereof.
       ``(2) Rounding.--If any dollar amount, after being 
     increased under paragraph (1), is not a multiple of $100, 
     such dollar amount shall be rounded to the next lowest 
     multiple of $100.''.
       (e) Credit Made Refundable.--Section 21(g) of the Internal 
     Revenue Code of 1986 is amended to read as follows:

[[Page S4125]]

       ``(g) Credit Made Refundable for Certain Individuals.--If 
     the taxpayer (in the case of a joint return, either spouse) 
     has a principal place of abode in the United States 
     (determined as provided in section 32) for more than one-half 
     of the taxable year, the credit allowed under subsection (a) 
     shall be treated as a credit allowed under subpart C (and not 
     allowed under this subpart).''.
       (f) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2025.
       At the appropriate place, insert the following:

     SEC. __. ESTABLISHMENT OF 39.6 PERCENT INDIVIDUAL INCOME TAX 
                   RATE BRACKET.

       (a) In General.--Section 1(j)(2) is amended by 
     redesignating subparagraph (F) as subparagraph (G) and by 
     inserting after subparagraph (E) the following new 
     subparagraph:
       ``(F) 39.6 percent rate bracket.--Notwithstanding 
     subparagraphs (A) through (E), in prescribing the tables 
     under this subsection for purposes of paragraph (3)(B)--
       ``(i) the excess of taxable income over $2,500,000, if any, 
     shall be taxed at a rate of 39.6 percent, and
       ``(ii) paragraph (3)(B)(i) shall be applied with respect to 
     such $2,500,000 amount by substituting `2024' for `2017'.''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2025.
                                 ______