[Congressional Record Volume 172, Number 49 (Wednesday, March 18, 2026)]
[Senate]
[Pages S1220-S1223]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
SA 4477. Mr. WYDEN submitted an amendment intended to be proposed by
him to the bill S. 1383, to establish the Veterans Advisory Committee
on Equal Access, and for other purposes; which was ordered to lie on
the table; as follows:
At the appropriate place, insert the following:
TITLE __--PROGRESS OPPORTUNITIES FOR SMALL BUSINESS INVESTORS
SECTION __01. SHORT TITLE.
This Act may be cited as the ``Providing Real Opportunities
for Growth to Rising Entrepreneurs for Sustained Success
(PROGRESS) Act''.
SEC. __02. SMALL BUSINESS INVESTOR TAX CREDIT.
(a) In General.--Subpart D of part IV of subchapter A of
chapter 1 of the Internal Revenue Code of 1986 is amended by
adding at the end the following new section:
``SEC. 45BB. SMALL BUSINESS INVESTOR TAX CREDIT.
``(a) General Rule.--For purposes of section 38, the small
business investor credit determined under this section for
any taxable year is an amount equal to the sum of the credit
amounts determined for the taxable year for all qualified
investments of the taxpayer.
``(b) Credit Amount.--For purposes of this section--
``(1) In general.--The term `credit amount' means, with
respect to any qualified investment in a qualifying business
entity, the lesser of--
``(A) 10 percent of the amount of the qualified investment
determined under subsection (c)(3) for the taxable year, or
``(B) an amount equal to--
``(i) 50 percent of such qualified investment, reduced (but
not below zero) by
``(ii) the amount of the credit determined under this
section with respect to such qualified investment of the
taxpayer for all preceding taxable years.
``(2) Overall dollar limitation.--
``(A) In general.--The credit amount determined under
paragraph (1) with respect to any qualified investment of a
taxpayer in a qualifying business entity for any taxable year
shall not exceed the lesser of--
``(i) $10,000 (as increased for the taxable year by the
cost-of-living adjustment under subsection (e)(2)), or
``(ii) an amount equal to--
``(I) an amount equal to 5 times the amount under clause
(i) for the taxable year, reduced (but not below zero) by
``(II) the amount of the credit determined under this
section with respect to such qualified investment of the
taxpayer for all preceding taxable years.
``(B) No credit amount by reason of cost-of-living
adjustment after overall limit first reached.--No credit
amount shall be determined under this section with respect to
any qualified investment of a taxpayer in a qualifying
business entity for any taxable year after the first taxable
year for which the amount determined under subclause (II) of
subparagraph (A)(ii) equals or exceeds the amount determined
under subclause (I) of such subparagraph.
``(3) Reduction in credit amount where loan rate exceeds
prime rate.--
``(A) In general.--If--
``(i) the rate of interest (expressed as an annual
percentage rate) on a qualified investment which is a
qualifying loan, exceeds
``(ii) the bank prime rate as of the first day of the month
in which the loan is entered into (or such other time as the
Secretary may specify),
then each of the amounts determined under subparagraphs (A)
and (B)(i) of paragraph (1) shall be reduced (but not below
zero) by the amount which bears the same ratio to such amount
as the number of full percentage points by which such rate of
interest exceeds such bank prime rate bears to 25.
``(B) Special rules where qualifying loans treated as part
of single investment.--If 1 or more qualifying loans to which
subparagraph (A) applies are treated as part of a single
qualified investment under subsection (c)(1), then, for
purposes of this subsection--
``(i) the credit amount under paragraph (1) for such single
qualified investment shall be the sum of such credit amounts
computed separately for each such qualifying loan and such
credit amount computed for all other qualified investments
treated as part of such single qualified investment, and
``(ii) the limitation under paragraph (2) shall be applied
to such sum.
``(C) Rules relating to interest rates.--
``(i) Annual percentage rate.--The Secretary shall
prescribe guidance or regulations for the calculation of the
annual percentage rate of interest on a loan for purposes of
subparagraph (A)(i), including rules which provide for--
``(I) the calculation of the annual percentage rate in
cases where there is a variable rate of interest,
``(II) the recalculation of the annual percentage rate
where the terms of the loan are modified after the loan is
entered into, and
``(III) the proper taking into account of lump sum
payments, orientation and application fees, closing fees,
invoice discounting fees and any other loan fees.
``(ii) Bank prime rate.--For purposes of subparagraph
(A)(ii), the term `bank prime rate' means the average
predominant prime rate quoted by commercial banks to large
businesses, as determined by the Board of Governors of the
Federal Reserve System.
``(4) Special rules for pass-thru entities.--For purposes
of this subsection, if a qualified investment in a qualifying
business entity is made by a partnership, trust, S
corporation, or other pass-thru entity, the limitations under
this subsection shall apply at the entity level.
``(c) Qualified Investment.--For purposes of this section--
``(1) In general.--The term `qualified investment' means,
with respect to any qualifying business entity, either of the
following of the taxpayer:
``(A) The direct or indirect acquisition of stock, or a
capital interest, in the entity at its original issue solely
in exchange for cash.
``(B) A qualifying loan made to the entity.
If a taxpayer has or had more than 1 qualified investment in
any qualifying business entity for the taxable year or any
prior taxable year, all such investments shall be treated as
a single qualified investment for purposes of applying this
section.
``(2) Exception for investments made by qualified active
investors and related persons.--Such term shall not include
any acquisition or loan made by a taxpayer who, immediately
before the acquisition or loan,
[[Page S1221]]
is a qualified active investor in the qualifying business
entity or is related to any qualified active investor.
``(3) Amount of qualified investment.--The amount of a
taxpayer's qualified investment with respect to any
qualifying business entity for any taxable year shall be the
monthly average for months ending within the taxable year
of--
``(A) the taxpayer's aggregate unadjusted bases in all
stock or interests described in paragraph (1)(A) as of the
close of each such month, and
``(B) the aggregate outstanding principal amount of all
qualified loans described in paragraph (1)(B) as of the close
of each such month.
``(4) Special rules for transfers of qualifying loans.--
``(A) In general.--If a taxpayer sells, exchanges, or
otherwise transfers all or any portion of a qualifying loan
which is a qualified investment in a qualifying business
entity, such investment shall be treated as a qualified
investment in the hands of the transferee (and not of the
transferor) for periods after the transfer. This paragraph
shall also apply to any subsequent transfer of such interest.
``(B) Coordination of limits.--In applying subsection (b)
to any qualifying loan treated as a qualified investment of a
transferee under this paragraph--
``(i) all credits determined under this section for any
periods before the transfer with respect to the qualified
investment of any prior holder of such investment shall be
taken into account under paragraphs (1)(B)(ii) and
(2)(A)(ii)(II) of such subsection in the same manner as if
such credits were determined for the transferee for prior
taxable years, and
``(ii) if only a portion of the qualified investment was
transferred, the amount taken into account under such
paragraphs by reason of clause (i) shall be ratably reduced
to reflect only the portion so transferred.
``(d) Qualifying Business Entity.--For purposes of this
section--
``(1) Definition.--
``(A) In general.--The term `qualifying business entity'
means, with respect to any qualified investment, any entity
which is engaged in 1 or more trades or businesses and with
respect to which--
``(i) the qualified active investor ownership requirements
of paragraph (2) are met immediately before and after the
qualified investment,
``(ii) the wage requirements of paragraph (3) are met, and
``(iii) the certification requirements of paragraph (4) are
met.
``(B) Entities under common control.--For purposes of this
section, all qualifying business entities treated as a single
employer under subsection (a) or (b) of section 52 or
subsection (m) or (o) of section 414 shall be treated as a
single qualifying business entity.
``(2) Qualified active investor ownership requirements.--
The requirements of this paragraph are met with respect to
any entity if qualified active investors own directly or
indirectly--
``(A) in the case of a corporation, more than 50 percent
(by vote and value) of the stock in the corporation, and
``(B) in the case of any other entity, more than 50 percent
of the capital or profits interests in the entity.
``(3) Wage requirements.--
``(A) In general.--The requirements of this paragraph are
met with respect to any entity if the entity, during the
taxable year of the entity preceding the taxable year in
which the qualified investment is made--
``(i) employed at least 1 full-time employee, or employees
constituting a full-time equivalent employee, in 1 or more
trades or businesses of the entity, and
``(ii) paid W-2 wages to such employee or employees with
respect to such employment.
``(B) Certain wages not taken into account.--W-2 wages
shall not be taken into account under subparagraph (A) if
paid by an entity to an employee, and such employee shall not
be taken into account under subparagraph (A)(i), during any
period the employee is--
``(i) a qualified active investor, or
``(ii) an employee other than a qualified active investor
who is a 5-percent owner (as defined in section
416(i)(1)(B)(i)) of the entity.
``(C) W-2 wages.--The term `W-2 wages' means, with respect
to any entity, the amounts described in paragraphs (3) and
(8) of section 6051(a) paid by the entity with respect to
employment of employees by the entity.
``(D) Full-time employees and equivalents.--For purposes of
this paragraph--
``(i) the term `full-time employee' has the meaning given
to such term by section 4980H(c)(4), and
``(ii) the determination of the number of employees
constituting a full-time equivalent shall be made in the same
manner as under section 4980H(c)(2)(E).
``(4) Certification requirements.--
``(A) In general.--The requirements of this paragraph are
met with respect to any entity if the entity certifies, in
such form and manner and at such time as the Secretary may
prescribe, that, at the time of the qualified investment, the
entity--
``(i) is engaged in 1 or more trades or businesses, and
``(ii) meets the requirements of paragraphs (2) and (3) to
be treated as a qualifying business entity.
``(B) Certification provided to investors and secretary.--
An entity shall--
``(i) provide the certification under subparagraph (A) to
the person making the qualified investment at the time such
investment is made, and
``(ii) include such certification, and the names,
addresses, and taxpayer identification numbers of the
entity's qualified active investors and the persons making
the qualified investment, with its return of tax for the
taxable year which includes the date of the qualified
investment.
``(C) Certification included with return claiming credit.--
No credit shall be determined under subsection (a) with
respect to any taxpayer making a qualified investment in a
qualifying business entity unless the taxpayer includes the
certification under subparagraph (A) with respect to the
investment with its return of tax for any taxable year for
which such credit is being claimed.
``(D) Timely filed return required.--The requirements of
subparagraph (B)(ii) or (C) shall be treated as met only if
the return described in such subparagraph is filed on or
before its due date (including extensions).
``(5) Qualified active investor.--
``(A) In general.--The term `qualified active investor'
means, with respect to any entity, an individual who--
``(i) is a citizen or resident of the United States,
``(ii) materially participates (within the meaning of
section 469(h)) in 1 or more trades or businesses of the
entity,
``(iii) holds stock, or a capital or profits interest, in
the entity, and
``(iv) meets the income requirements of subparagraph (B).
``(B) Income requirements.--The requirements of this
subparagraph are met with respect to an individual if the
average annual adjusted taxable income of the individual for
the 3 taxable years of the individual immediately preceding
the taxable year in which the qualified investment is made
does not exceed the applicable amount.
``(C) Applicable amount.--For purposes of this paragraph,
the term `applicable amount' means, with respect to any
taxable year in which a qualified investment is made--
``(i) in the case of an individual not described in clause
(ii), $100,000 (as increased for the taxable year by the
cost-of-living adjustment under subsection (e)(2)), and
``(ii) in the case of an individual who is a married
individual filing a joint return or who is a head of
household (as defined in section 2(b)) for the taxable year,
an amount equal to 2 times the amount in effect under clause
(i) for the taxable year.
``(D) Rules for determining average taxable income.--For
purposes of this paragraph--
``(i) a married individual filing a separate return of tax
for any taxable year shall include the adjusted taxable
income of their spouse in computing the individual's average
adjusted taxable income for any period unless the Secretary
determines that the spouse's information is not available to
the individual, and
``(ii) the Secretary shall prescribe rules for the
determination of average adjusted taxable income in cases
where the individual had different filing statuses for the 3
taxable years described in subparagraph (B).
``(E) Adjusted taxable income.--The term `adjusted taxable
income' means taxable income computed without regard to the
deductions under sections 172 and 199A.
``(e) Definitions and Special Rules.--For purposes of this
section--
``(1) Related persons.--A person shall be treated as
related to another person if the person bears a relationship
to such other person described in section 267(b), except that
section 267(b) shall be applied by substituting `5 percent'
for `50 percent' each place it appears.
``(2) Cost-of-living adjustments.--In the case of any
taxable year beginning after 2027, the $10,000 amount under
subsection (b)(2)(A)(i) and the $100,000 amount under
subsection (d)(5)(C)(i) shall each be increased by an amount
equal to--
``(A) such dollar amount, multiplied by
``(B) the cost-of-living adjustment under section 1(f)(3)
for the calendar year in which the taxable year begins,
determined by substituting `2026' for `2016' in subparagraph
(A)(ii) thereof.
If any increase in such $10,000 amount is not a multiple of
$100, such increase shall be rounded to the next lowest
multiple of $100 and if any increase in such $100,000 amount
is not a multiple of $1,000, such increase shall be rounded
to the next lowest multiple of $1,000.
``(3) Rules relating to entities.--
``(A) Sole proprietorships.--If a taxpayer carries on 1 or
more trades or businesses as sole proprietorships, all such
trades or businesses shall be treated as a single entity for
purposes of applying this section.
``(B) Application to disregarded entities.--In the case of
any entity with a single owner which is disregarded as an
entity separate from its owner for purposes of this title,
this section shall be applied in the same manner as if such
entity were a corporation.
``(f) Regulations.--The Secretary shall prescribe such
regulations or other guidance as may be necessary to carry
out the provisions of this section.''.
(b) Credit to Be Part of General Business Credit.--Section
38(b) of such Code is amended by striking ``plus'' at the end
of paragraph (40), by striking the period at the end of
paragraph (41) and inserting ``, plus'',
[[Page S1222]]
and by adding at the end the following new paragraph:
``(42) the small business investor credit determined under
section 45BB(a).''.
(c) Credit Allowed Against Alternative Minimum Tax.--
Section 38(c)(4)(B) of such Code is amended by redesignating
clauses (x), (xi), and (xii) as clauses (xi), (xii), and
(xiii), respectively, and by inserting after clause (ix) the
following new clause:
``(x) the credit determined under section 45BB,''.
(d) Clerical Amendment.--The table of sections for subpart
D of part IV of subchapter A of chapter 1 of such Code is
amended by adding at the end the following new item:
``Sec. 45BB. Small business investor tax credit.''.
(e) Effective Date.--The amendments made by this section
shall apply to qualified investments made in taxable years
beginning after December 31, 2026.
SEC. 3. FIRST EMPLOYEE BUSINESS WAGE CREDIT.
(a) Allowance of Credit.--
(1) In general.--Subpart D of part IV of subchapter A of
chapter 1 of the Internal Revenue Code of 1986, as amended by
section __02, is amended by adding at the end the following
new section:
``SEC. 45CC. FIRST EMPLOYEE BUSINESS WAGE CREDIT.
``(a) General Rule.--For purposes of section 38, in the
case of a qualifying business entity, the first employee
business wage credit determined under this section for any
taxable year is an amount equal to 25 percent of the
qualified wages of the entity for the taxable year.
``(b) Dollar Limitations.--
``(1) In general.--The amount of the credit determined
under subsection (a) with respect to any qualifying business
entity for any taxable year shall not exceed the lesser of--
``(A) $10,000 (as increased for the taxable year by the
cost-of-living adjustment under subsection (f)), or
``(B) the excess (if any) of--
``(i) an amount equal to 4 times the amount under
subparagraph (A) for the taxable year, over
``(ii) the amount of the credit determined under this
section with respect to such entity for all preceding taxable
years.
``(2) No credit by reason of cost-of-living adjustment
after overall limit first reached.--No credit shall be
determined under this section with respect to any qualifying
business entity for any taxable year after the first taxable
year for which the amount determined under clause (ii) of
paragraph (1)(B) equals or exceeds the amount determined
under clause (i) of such paragraph.
``(3) Pass-thru entities.--If a qualifying business entity
is a partnership, trust, S corporation, or other pass-thru
entity, the limitations under this subsection shall apply at
the entity level.
``(c) Qualified Wages.--For purposes of this section--
``(1) In general.--The term `qualified wages' means, with
respect to any qualifying business entity, the amount of W-2
wages paid or incurred during any eligible taxable year to
employees for services performed in connection with a trade
or business of the entity.
``(2) Exception for qualified active investors and 5-
percent owner-employees.--W-2 wages shall not be taken into
account under paragraph (1) if paid by an entity to an
employee, and such employee shall not be taken into account
under paragraph (3)(A), during any period the employee is--
``(A) a qualified active investor, or
``(B) an employee other than a qualified active investor
who is a 5-percent owner (as defined in section
416(i)(1)(B)(i)) of the entity.
``(3) Eligible taxable year.--
``(A) In general.--The term `eligible taxable year' means
any taxable year of a qualifying business entity--
``(i) which occurs during the period--
``(I) beginning with the first taxable year of the entity
in which the entity employed at least 1 full-time employee
(or employees constituting a full-time equivalent employee)
in 1 or more trades or businesses of the entity during the
taxable year and paid W-2 wages to such employee or employees
with respect to such employment, and
``(II) ending with the last taxable year for which a credit
may be determined for the entity under this section by reason
of the limitation under subsection (b)(2), and
``(ii) in the case of a taxable year other than the first
taxable year described in clause (i)(I), with respect to
which the entity meets the employment and wage requirements
of such clause.
Such term shall not include any taxable year during such a
period if the first taxable year described in clause (i)(I)
of the entity (or any predecessor) begins before January 1,
2024.
``(B) W-2 wages; full-time employees.--For purposes of this
subsection, W-2 wages, full-time employees, and full-time
employee equivalents shall be determined in the same manner
as under section 45BB.
``(d) Qualifying Business Entity.--For purposes of this
section--
``(1) Qualifying business entity defined.--
``(A) In general.--The term `qualifying business entity'
means, with respect to any taxable year for which a credit
under this section is being determined, any entity--
``(i) which is engaged in 1 or more trades or businesses,
``(ii) with respect to which the qualified active investor
ownership requirements of paragraph (2) of section 45BB(d)
are met as of the close of such taxable year (rather than
immediately before and after the qualified investment), and
``(iii) with respect to which the certification
requirements of paragraph (2) are met.
``(B) Entities under common control.--For purposes of this
section--
``(i) In general.--All qualifying business entities treated
as a single employer under subsection (a) or (b) of section
52 or subsection (m) or (o) of section 414 shall be treated
as a single qualifying business entity.
``(ii) Allocation of credit.--Except as provided in
regulations, the credit under this section shall be allocated
among the entities comprising the single entity described in
clause (i) in proportion to the qualified wages of each such
entity taken into account under subsection (a).
``(2) Certification requirements.--
``(A) In general.--The requirements of this paragraph are
met with respect to any entity for any taxable year described
in paragraph (1) if the entity certifies, in such form and
manner and at such time as the Secretary may prescribe, that
the entity meets the requirements described in clauses (i)
and (ii) of paragraph (1)(A).
``(B) Certification provided to secretary.--An entity shall
include the certification under subparagraph (A), and the
names, addresses, and taxpayer identification numbers of the
entity's qualified active investors (and employees who are 5-
percent owners described in subsection (c)(2)(B)), with its
return of tax for the taxable year to which the certification
relates. The requirement of this subparagraph is met only if
such return is filed before its due date (including
extensions).
``(3) Qualified active investor.--For purposes of this
section (including applying the requirements of paragraph (2)
of section 45BB(d) for purposes of paragraph (1)(A)(ii)), the
term `qualified active investor' has the same meaning given
such term by section 45BB(d)(5), except that such section
shall be applied separately for each taxable year described
in paragraph (1) (rather than the taxable year of the
qualified investment).
``(e) Election to Apply Credit Against Payroll Taxes.--
``(1) In general.--At the election of a qualifying business
entity, section 3111(g) shall apply to the payroll tax credit
portion of the credit otherwise determined under subsection
(a) for the taxable year and such portion shall not be
treated (other than for purposes of section 280C) as a credit
determined under subsection (a).
``(2) Payroll tax credit portion.--For purposes of this
subsection, the payroll tax credit portion of the credit
determined under subsection (a) with respect to any
qualifying business entity for any taxable year is the least
of--
``(A) the amount specified in the election made under this
subsection,
``(B) the credit determined under subsection (a) for the
taxable year (determined before the application of this
subsection), or
``(C) in the case of a qualifying business entity other
than a partnership, estate, S corporation or other pass-thru
entity, the amount of the business credit carryforward under
section 39 carried from the taxable year (determined before
the application of this subsection to the taxable year).
``(3) Election.--
``(A) In general.--Any election under this subsection for
any taxable year--
``(i) shall specify the amount of the credit to which such
election applies,
``(ii) shall be made on or before the due date (including
extensions) of the return for the taxable year, and
``(iii) may be revoked only with the consent of the
Secretary.
``(B) Special rule for pass-thru entities.--In the case of
a partnership, estate, S corporation, or other pass-thru
entity, the election made under this subsection shall be made
at the entity level.
``(f) Cost-of-living Adjustments.--In the case of any
taxable year beginning after 2027, the $10,000 amount under
subsection (b)(1)(A) shall be increased by an amount equal
to--
``(1) such dollar amount, multiplied by
``(2) the cost-of-living adjustment under section 1(f)(3)
for the calendar year in which the taxable year begins,
determined by substituting `2026' for `2016' in subparagraph
(A)(ii) thereof.
If any increase in such amount is not a multiple of $100,
such increase shall be rounded to the next lowest multiple of
$100.
``(g) Other Rules.--For purposes of this section--
``(1) Rules relating to entities.--Rules similar to the
rules of section 45BB(e)(3) shall apply.
``(2) Election not to have credit apply.--
``(A) In general.--A taxpayer may elect not to have this
section apply for any taxable year.
``(B) Other rules.--Rules similar to the rules of
paragraphs (2) and (3) of section 51(j) shall apply for
purposes of this paragraph.
``(3) Certain other rules made applicable.--Rules similar
to the rules of subsections (c), (d), and (e) of section 52
shall apply.
``(h) Regulations.--The Secretary shall prescribe such
regulations or other guidance as may be necessary to carry
out the provisions of this section, including regulations--
``(1) preventing the avoidance of the limitations under
this section in cases in which there is a successor or new
qualified business entity with respect to the same trade or
[[Page S1223]]
business for which a predecessor qualified business entity
already claimed the credit under this section,
``(2) to minimize compliance and recordkeeping burdens
under the provisions of this section, and
``(3) for recapturing the benefit of credits determined
under section 3111(g) in cases where there is a recapture or
a subsequent adjustment to the payroll tax credit portion of
the credit determined under subsection (a), including
requiring amended income tax returns in the cases where there
is such an adjustment.''.
(2) Credit to be part of general business credit.--Section
38(b) of such Code, as amended by section __02, is amended by
striking ``plus'' at the end of paragraph (41), by striking
the period at the end of paragraph (42) and inserting ``,
plus'', and by adding at the end the following new paragraph:
``(43) the first employee business wage credit determined
under section 45CC(a).''.
(3) Credit allowed against alternative minimum tax.--
Section 38(c)(4)(B) of such Code, as amended by section __02,
is amended by redesignating clauses (xi), (xii), and (xiii)
as clauses (xii), (xiii), and (xiv), respectively, and by
inserting after clause (x) the following new clause:
``(xi) the credit determined under section 45CC,''.
(4) Clerical amendment.--The table of sections for subpart
D of part IV of subchapter A of chapter 1 of such Code, as
amended by section __02, is amended by adding at the end the
following new item:
``Sec. 45CC. First employee business wage credit.''.
(b) Payroll Tax Credit.--Section 3111 of the Internal
Revenue Code of 1986 is amended by adding at the end the
following new subsection:
``(g) Credit for First Employee Business Wage Expenses.--
``(1) In general.--In the case of a taxpayer who has made
an election under section 45CC(e) for a taxable year, there
shall be allowed as a credit against the tax imposed by
subsection (a) for the first calendar quarter which begins
after the date on which the taxpayer files the return for the
taxable year an amount equal to the payroll tax credit
portion determined under section 45CC(e)(2).
``(2) Limitation.--The credit allowed by paragraph (1)
shall not exceed the tax imposed by subsection (a) for any
calendar quarter on the wages paid with respect to the
employment of all individuals in the employ of the employer.
``(3) Carryover of unused credit.--If the amount of the
credit under paragraph (1) exceeds the limitation of
paragraph (2) for any calendar quarter, such excess shall be
carried to the succeeding calendar quarter and allowed as a
credit under paragraph (1) for such quarter.
``(4) Deduction allowed for credited amounts.--
Notwithstanding section 280C(a), the credit allowed under
paragraph (1) shall not be taken into account for purposes of
determining the amount of any deduction allowed under chapter
1 for taxes imposed under subsection (a).''.
(c) Coordination With Deductions and Other Credits.--
(1) Deductions.--Section 280C(a) of the Internal Revenue
Code of 1986 is amended by inserting ``45CC(a),'' after
``45S(a),''.
(2) Other credits.--
(A) Section 41(b)(2)(D) of such Code is amended by adding
at the end the following:
``(iv) Exclusion for wages to which first employee wage
credit applies.--The term `wages' shall not include any
amount taken into account in determining the credit under
section 45CC.''.
(B) Section 45A(b)(1) of such Code is amended by adding at
the end the following:
``(C) Coordination with first employee wage credit.--The
term `qualified wages' shall not include wages if any portion
of such wages is taken into account in determining the credit
under section 45CC.''.
(C) Section 1396(c)(3) of such Code is amended--
(i) by striking ``section 51'' each place it appears and
inserting ``section 45CC or 51'', and
(ii) by inserting ``and first employee wage'' after
``opportunity'' in the heading thereof.
(d) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2026.
______