[Congressional Record (Bound Edition), Volume 160 (2014), Part 12]
[House]
[Pages 16500-16522]
[From the U.S. Government Publishing Office, www.gpo.gov]




                  TAX INCREASE PREVENTION ACT OF 2014

  Mr. CAMP. Mr. Speaker, pursuant to House Resolution 766, I call up 
the bill (H.R. 5771) to amend the Internal Revenue Code of 1986 to 
extend certain expiring provisions and make technical corrections, and 
for other purposes, and ask for its immediate consideration.
  The Clerk read the title of the bill.
  The SPEAKER pro tempore. Pursuant to House Resolution 766, the 
amendment printed in part A of House Report 113-643 is adopted, and the 
bill, as amended, is considered read.
  The text of the bill, as amended, is as follows:

                               H.R. 5771

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

     SECTION 1. SHORT TITLE, ETC.

       (a) Short Title.--This Act may be cited as the ``Tax 
     Increase Prevention Act of 2014''.
       (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 for this Act 
     is as follows:

Sec. 1. Short title, etc.

                  TITLE I--CERTAIN EXPIRING PROVISIONS

                  Subtitle A--Individual Tax Extenders

Sec. 101. Extension of deduction for certain expenses of elementary and 
              secondary school teachers.
Sec. 102. Extension of exclusion from gross income of discharge of 
              qualified principal residence indebtedness.
Sec. 103. Extension of parity for employer-provided mass transit and 
              parking benefits.
Sec. 104. Extension of mortgage insurance premiums treated as qualified 
              residence interest.
Sec. 105. Extension of deduction of State and local general sales 
              taxes.
Sec. 106. Extension of special rule for contributions of capital gain 
              real property made for conservation purposes.
Sec. 107. Extension of above-the-line deduction for qualified tuition 
              and related expenses.
Sec. 108. Extension of tax-free distributions from individual 
              retirement plans for charitable purposes.

                   Subtitle B--Business Tax Extenders

Sec. 111. Extension of research credit.
Sec. 112. Extension of temporary minimum low-income housing tax credit 
              rate for non-federally subsidized buildings.
Sec. 113. Extension of military housing allowance exclusion for 
              determining whether a tenant in certain counties is low-
              income.
Sec. 114. Extension of Indian employment tax credit.
Sec. 115. Extension of new markets tax credit.
Sec. 116. Extension of railroad track maintenance credit.

[[Page 16501]]

Sec. 117. Extension of mine rescue team training credit.
Sec. 118. Extension of employer wage credit for employees who are 
              active duty members of the uniformed services.
Sec. 119. Extension of work opportunity tax credit.
Sec. 120. Extension of qualified zone academy bonds.
Sec. 121. Extension of classification of certain race horses as 3-year 
              property.
Sec. 122. Extension of 15-year straight-line cost recovery for 
              qualified leasehold improvements, qualified restaurant 
              buildings and improvements, and qualified retail 
              improvements.
Sec. 123. Extension of 7-year recovery period for motorsports 
              entertainment complexes.
Sec. 124. Extension of accelerated depreciation for business property 
              on an Indian reservation.
Sec. 125. Extension of bonus depreciation.
Sec. 126. Extension of enhanced charitable deduction for contributions 
              of food inventory.
Sec. 127. Extension of increased expensing limitations and treatment of 
              certain real property as section 179 property.
Sec. 128. Extension of election to expense mine safety equipment.
Sec. 129. Extension of special expensing rules for certain film and 
              television productions.
Sec. 130. Extension of deduction allowable with respect to income 
              attributable to domestic production activities in Puerto 
              Rico.
Sec. 131. Extension of modification of tax treatment of certain 
              payments to controlling exempt organizations.
Sec. 132. Extension of treatment of certain dividends of regulated 
              investment companies.
Sec. 133. Extension of RIC qualified investment entity treatment under 
              FIRPTA.
Sec. 134. Extension of subpart F exception for active financing income.
Sec. 135. Extension of look-thru treatment of payments between related 
              controlled foreign corporations under foreign personal 
              holding company rules.
Sec. 136. Extension of temporary exclusion of 100 percent of gain on 
              certain small business stock.
Sec. 137. Extension of basis adjustment to stock of S corporations 
              making charitable contributions of property.
Sec. 138. Extension of reduction in S-corporation recognition period 
              for built-in gains tax.
Sec. 139. Extension of empowerment zone tax incentives.
Sec. 140. Extension of temporary increase in limit on cover over of rum 
              excise taxes to Puerto Rico and the Virgin Islands.
Sec. 141. Extension of American Samoa economic development credit.

                    Subtitle C--Energy Tax Extenders

Sec. 151. Extension of credit for nonbusiness energy property.
Sec. 152. Extension of second generation biofuel producer credit.
Sec. 153. Extension of incentives for biodiesel and renewable diesel.
Sec. 154. Extension of production credit for Indian coal facilities 
              placed in service before 2009.
Sec. 155. Extension of credits with respect to facilities producing 
              energy from certain renewable resources.
Sec. 156. Extension of credit for energy-efficient new homes.
Sec. 157. Extension of special allowance for second generation biofuel 
              plant property.
Sec. 158. Extension of energy efficient commercial buildings deduction.
Sec. 159. Extension of special rule for sales or dispositions to 
              implement FERC or State electric restructuring policy for 
              qualified electric utilities.
Sec. 160. Extension of excise tax credits relating to certain fuels.
Sec. 161. Extension of credit for alternative fuel vehicle refueling 
              property.

Subtitle D--Extenders Relating to Multiemployer Defined Benefit Pension 
                                 Plans

Sec. 171. Extension of automatic extension of amortization periods.
Sec. 172. Extension of shortfall funding method and endangered and 
              critical rules.

                    TITLE II--TECHNICAL CORRECTIONS

Sec. 201. Short title.
Sec. 202. Amendments relating to American Taxpayer Relief Act of 2012.
Sec. 203. Amendment relating to Middle Class Tax Relief and Job 
              Creation Act of 2012.
Sec. 204. Amendment relating to FAA Modernization and Reform Act of 
              2012.
Sec. 205. Amendments relating to Regulated Investment Company 
              Modernization Act of 2010.
Sec. 206. Amendments relating to Tax Relief, Unemployment Insurance 
              Reauthorization, and Job Creation Act of 2010.
Sec. 207. Amendments relating to Creating Small Business Jobs Act of 
              2010.
Sec. 208. Clerical amendment relating to Hiring Incentives to Restore 
              Employment Act.
Sec. 209. Amendments relating to American Recovery and Reinvestment Tax 
              Act of 2009.
Sec. 210. Amendments relating to Energy Improvement and Extension Act 
              of 2008.
Sec. 211. Amendments relating to Tax Extenders and Alternative Minimum 
              Tax Relief Act of 2008.
Sec. 212. Clerical amendments relating to Housing Assistance Tax Act of 
              2008.
Sec. 213. Amendments and provision relating to Heroes Earnings 
              Assistance and Relief Tax Act of 2008.
Sec. 214. Amendments relating to Economic Stimulus Act of 2008.
Sec. 215. Amendments relating to Tax Technical Corrections Act of 2007.
Sec. 216. Amendment relating to Tax Relief and Health Care Act of 2006.
Sec. 217. Amendment relating to Safe, Accountable, Flexible, Efficient 
              Transportation Equity Act of 2005: A Legacy for Users.
Sec. 218. Amendments relating to Energy Tax Incentives Act of 2005.
Sec. 219. Amendments relating to American Jobs Creation Act of 2004.
Sec. 220. Other clerical corrections.
Sec. 221. Deadwood provisions.

                 TITLE III--JOINT COMMITTEE ON TAXATION

Sec. 301. Increased refund and credit threshold for Joint Committee on 
              Taxation review of C corporation return.

                      TITLE IV--BUDGETARY EFFECTS

Sec. 401. Budgetary effects.

                  TITLE I--CERTAIN EXPIRING PROVISIONS

                  Subtitle A--Individual Tax Extenders

     SEC. 101. EXTENSION OF DEDUCTION FOR CERTAIN EXPENSES OF 
                   ELEMENTARY AND SECONDARY SCHOOL TEACHERS.

       (a) In General.--Subparagraph (D) of section 62(a)(2) is 
     amended by striking ``or 2013'' and inserting ``2013, or 
     2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 102. EXTENSION OF EXCLUSION FROM GROSS INCOME OF 
                   DISCHARGE OF QUALIFIED PRINCIPAL RESIDENCE 
                   INDEBTEDNESS.

       (a) In General.--Subparagraph (E) of section 108(a)(1) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to indebtedness discharged after December 31, 
     2013.

     SEC. 103. EXTENSION OF PARITY FOR EMPLOYER-PROVIDED MASS 
                   TRANSIT AND PARKING BENEFITS.

       (a) In General.--Paragraph (2) of section 132(f) is amended 
     by striking ``January 1, 2014'' and inserting ``January 1, 
     2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to months after December 31, 2013.

     SEC. 104. EXTENSION OF MORTGAGE INSURANCE PREMIUMS TREATED AS 
                   QUALIFIED RESIDENCE INTEREST.

       (a) In General.--Subclause (I) of section 163(h)(3)(E)(iv) 
     is amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to amounts paid or accrued after December 31, 
     2013.

     SEC. 105. EXTENSION OF DEDUCTION OF STATE AND LOCAL GENERAL 
                   SALES TAXES.

       (a) In General.--Subparagraph (I) of section 164(b)(5) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 106. EXTENSION OF SPECIAL RULE FOR CONTRIBUTIONS OF 
                   CAPITAL GAIN REAL PROPERTY MADE FOR 
                   CONSERVATION PURPOSES.

       (a) In General.--Clause (vi) of section 170(b)(1)(E) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Contributions by Certain Corporate Farmers and 
     Ranchers.--Clause (iii) of section 170(b)(2)(B) is amended by 
     striking ``December 31, 2013'' and inserting ``December 31, 
     2014''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to contributions made in taxable years beginning 
     after December 31, 2013.

     SEC. 107. EXTENSION OF ABOVE-THE-LINE DEDUCTION FOR QUALIFIED 
                   TUITION AND RELATED EXPENSES.

       (a) In General.--Subsection (e) of section 222 is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

[[Page 16502]]



     SEC. 108. EXTENSION OF TAX-FREE DISTRIBUTIONS FROM INDIVIDUAL 
                   RETIREMENT PLANS FOR CHARITABLE PURPOSES.

       (a) In General.--Subparagraph (F) of section 408(d)(8) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to distributions made in taxable years beginning 
     after December 31, 2013.

                   Subtitle B--Business Tax Extenders

     SEC. 111. EXTENSION OF RESEARCH CREDIT.

       (a) In General.--Paragraph (1) of section 41(h) is amended 
     by striking ``paid or incurred'' and all that follows and 
     inserting ``paid or incurred after December 31, 2014.''.
       (b) Conforming Amendment.--Subparagraph (D) of section 
     45C(b)(1) is amended to read as follows:
       ``(D) Special rule.--If section 41 is not in effect for any 
     period, such section shall be deemed to remain in effect for 
     such period for purposes of this paragraph.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to amounts paid or incurred after December 31, 
     2013.

     SEC. 112. EXTENSION OF TEMPORARY MINIMUM LOW-INCOME HOUSING 
                   TAX CREDIT RATE FOR NON-FEDERALLY SUBSIDIZED 
                   BUILDINGS.

       (a) In General.--Subparagraph (A) of section 42(b)(2) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect on January 1, 2014.

     SEC. 113. EXTENSION OF MILITARY HOUSING ALLOWANCE EXCLUSION 
                   FOR DETERMINING WHETHER A TENANT IN CERTAIN 
                   COUNTIES IS LOW-INCOME.

       (a) In General.--Subsection (b) of section 3005 of the 
     Housing Assistance Tax Act of 2008 is amended by striking 
     ``January 1, 2014'' each place it appears and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect as if included in the enactment of section 
     3005 of the Housing Assistance Tax Act of 2008.

     SEC. 114. EXTENSION OF INDIAN EMPLOYMENT TAX CREDIT.

       (a) In General.--Subsection (f) of section 45A is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 115. EXTENSION OF NEW MARKETS TAX CREDIT.

       (a) In General.--Subparagraph (G) of section 45D(f)(1) is 
     amended by striking ``and 2013'' and inserting ``2013, and 
     2014''.
       (b) Carryover of Unused Limitation.--Paragraph (3) of 
     section 45D(f) is amended by striking ``2018'' and inserting 
     ``2019''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to calendar years beginning after December 31, 
     2013.

     SEC. 116. EXTENSION OF RAILROAD TRACK MAINTENANCE CREDIT.

       (a) In General.--Subsection (f) of section 45G is amended 
     by striking ``January 1, 2014'' and inserting ``January 1, 
     2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to expenditures paid or incurred in taxable years 
     beginning after December 31, 2013.

     SEC. 117. EXTENSION OF MINE RESCUE TEAM TRAINING CREDIT.

       (a) In General.--Subsection (e) of section 45N is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 118. EXTENSION OF EMPLOYER WAGE CREDIT FOR EMPLOYEES WHO 
                   ARE ACTIVE DUTY MEMBERS OF THE UNIFORMED 
                   SERVICES.

       (a) In General.--Subsection (f) of section 45P is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to payments made after December 31, 2013.

     SEC. 119. EXTENSION OF WORK OPPORTUNITY TAX CREDIT.

       (a) In General.--Paragraph (4) of section 51(c) is amended 
     by striking ``for the employer'' and all that follows and 
     inserting ``for the employer after December 31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to individuals who begin work for the employer 
     after December 31, 2013.

     SEC. 120. EXTENSION OF QUALIFIED ZONE ACADEMY BONDS.

       (a) Extension.--Paragraph (1) of section 54E(c) is amended 
     by striking ``and 2013'' and inserting ``2013, and 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to obligations issued after December 31, 2013.

     SEC. 121. EXTENSION OF CLASSIFICATION OF CERTAIN RACE HORSES 
                   AS 3-YEAR PROPERTY.

       (a) In General.--Clause (i) of section 168(e)(3)(A) is 
     amended--
       (1) by striking ``January 1, 2014'' in subclause (I) and 
     inserting ``January 1, 2015'', and
       (2) by striking ``December 31, 2013'' in subclause (II) and 
     inserting ``December 31, 2014''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 122. EXTENSION OF 15-YEAR STRAIGHT-LINE COST RECOVERY 
                   FOR QUALIFIED LEASEHOLD IMPROVEMENTS, QUALIFIED 
                   RESTAURANT BUILDINGS AND IMPROVEMENTS, AND 
                   QUALIFIED RETAIL IMPROVEMENTS.

       (a) In General.--Clauses (iv), (v), and (ix) of section 
     168(e)(3)(E) are each amended by striking ``January 1, 2014'' 
     and inserting ``January 1, 2015''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 123. EXTENSION OF 7-YEAR RECOVERY PERIOD FOR MOTORSPORTS 
                   ENTERTAINMENT COMPLEXES.

       (a) In General.--Subparagraph (D) of section 168(i)(15) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 124. EXTENSION OF ACCELERATED DEPRECIATION FOR BUSINESS 
                   PROPERTY ON AN INDIAN RESERVATION.

       (a) In General.--Paragraph (8) of section 168(j) is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 125. EXTENSION OF BONUS DEPRECIATION.

       (a) In General.--Paragraph (2) of section 168(k) is 
     amended--
       (1) by striking ``January 1, 2015'' in subparagraph (A)(iv) 
     and inserting ``January 1, 2016'', and
       (2) by striking ``January 1, 2014'' each place it appears 
     and inserting ``January 1, 2015''.
       (b) Special Rule for Federal Long-Term Contracts.--Clause 
     (ii) of section 460(c)(6)(B) is amended by striking ``January 
     1, 2014 (January 1, 2015'' and inserting ``January 1, 2015 
     (January 1, 2016''.
       (c) Extension of Election to Accelerate the AMT Credit in 
     Lieu of Bonus Depreciation.--
       (1) In general.--Subclause (II) of section 
     168(k)(4)(D)(iii) is amended by striking ``January 1, 2014'' 
     and inserting ``January 1, 2015''.
       (2) Round 4 extension property.--Paragraph (4) of section 
     168(k) is amended by adding at the end the following new 
     subparagraph:
       ``(K) Special rules for round 4 extension property.--
       ``(i) In general.--In the case of round 4 extension 
     property, in applying this paragraph to any taxpayer--

       ``(I) the limitation described in subparagraph (B)(i) and 
     the business credit increase amount under subparagraph 
     (E)(iii) thereof shall not apply, and
       ``(II) the bonus depreciation amount, maximum amount, and 
     maximum increase amount shall be computed separately from 
     amounts computed with respect to eligible qualified property 
     which is not round 4 extension property.

       ``(ii) Election.--

       ``(I) A taxpayer who has an election in effect under this 
     paragraph for round 3 extension property shall be treated as 
     having an election in effect for round 4 extension property 
     unless the taxpayer elects to not have this paragraph apply 
     to round 4 extension property.
       ``(II) A taxpayer who does not have an election in effect 
     under this paragraph for round 3 extension property may elect 
     to have this paragraph apply to round 4 extension property.

       ``(iii) Round 4 extension property.--For purposes of this 
     subparagraph, the term `round 4 extension property' means 
     property which is eligible qualified property solely by 
     reason of the extension of the application of the special 
     allowance under paragraph (1) pursuant to the amendments made 
     by section 125(a) of the Tax Increase Prevention Act of 2014 
     (and the application of such extension to this paragraph 
     pursuant to the amendment made by section 125(c) of such 
     Act).''.
       (d) Conforming Amendments.--
       (1) The heading for subsection (k) of section 168 is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (2) The heading for clause (ii) of section 168(k)(2)(B) is 
     amended by striking ``pre-january 1, 2014'' and inserting 
     ``pre-january 1, 2015''.
       (3) Subparagraph (C) of section 168(n)(2) is amended by 
     striking ``January 1, 2014'' and inserting ``January 1, 
     2015''.
       (4) Subparagraph (D) of section 1400L(b)(2) is amended by 
     striking ``January 1, 2014'' and inserting ``January 1, 
     2015''.
       (5) Subparagraph (B) of section 1400N(d)(3) is amended by 
     striking ``January 1, 2014'' and inserting ``January 1, 
     2015''.
       (e) Effective Date.--The amendments made by this section 
     shall apply to property placed in service after December 31, 
     2013, in taxable years ending after such date.

     SEC. 126. EXTENSION OF ENHANCED CHARITABLE DEDUCTION FOR 
                   CONTRIBUTIONS OF FOOD INVENTORY.

       (a) In General.--Clause (iv) of section 170(e)(3)(C) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.

[[Page 16503]]

       (b) Effective Date.--The amendment made by this section 
     shall apply to contributions made after December 31, 2013.

     SEC. 127. EXTENSION OF INCREASED EXPENSING LIMITATIONS AND 
                   TREATMENT OF CERTAIN REAL PROPERTY AS SECTION 
                   179 PROPERTY.

       (a) In General.--
       (1) Dollar limitation.--Section 179(b)(1) is amended--
       (A) by striking ``beginning in 2010, 2011, 2012, or 2013'' 
     in subparagraph (B) and inserting ``beginning after 2009 and 
     before 2015'', and
       (B) by striking ``2013'' in subparagraph (C) and inserting 
     ``2014''.
       (2) Reduction in limitation.--Section 179(b)(2) is 
     amended--
       (A) by striking ``beginning in 2010, 2011, 2012, or 2013'' 
     in subparagraph (B) and inserting ``beginning after 2009 and 
     before 2015'', and
       (B) by striking ``2013'' in subparagraph (C) and inserting 
     ``2014''.
       (b) Computer Software.--Section 179(d)(1)(A)(ii) is amended 
     by striking ``2014'' and inserting ``2015''.
       (c) Election.--Section 179(c)(2) is amended by striking 
     ``2014'' and inserting ``2015''.
       (d) Special Rules for Treatment of Qualified Real 
     Property.--
       (1) In general.--Section 179(f)(1) is amended by striking 
     ``beginning in 2010, 2011, 2012, or 2013'' and inserting 
     ``beginning after 2009 and before 2015''.
       (2) Carryover limitation.--
       (A) In general.--Section 179(f)(4) is amended by striking 
     ``2013'' each place it appears and inserting ``2014''.
       (B) Conforming amendment.--The heading of subparagraph (C) 
     of section 179(f)(4) is amended by striking ``2011 and 2012'' 
     and inserting ``2011, 2012, and 2013''.
       (e) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 128. EXTENSION OF ELECTION TO EXPENSE MINE SAFETY 
                   EQUIPMENT.

       (a) In General.--Subsection (g) of section 179E is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 129. EXTENSION OF SPECIAL EXPENSING RULES FOR CERTAIN 
                   FILM AND TELEVISION PRODUCTIONS.

       (a) In General.--Subsection (f) of section 181 is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Dates.--The amendment made by this section 
     shall apply to productions commencing after December 31, 
     2013.

     SEC. 130. EXTENSION OF DEDUCTION ALLOWABLE WITH RESPECT TO 
                   INCOME ATTRIBUTABLE TO DOMESTIC PRODUCTION 
                   ACTIVITIES IN PUERTO RICO.

       (a) In General.--Subparagraph (C) of section 199(d)(8) is 
     amended--
       (1) by striking ``first 8 taxable years'' and inserting 
     ``first 9 taxable years'', and
       (2) by striking ``January 1, 2014'' and inserting ``January 
     1, 2015''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 131. EXTENSION OF MODIFICATION OF TAX TREATMENT OF 
                   CERTAIN PAYMENTS TO CONTROLLING EXEMPT 
                   ORGANIZATIONS.

       (a) In General.--Clause (iv) of section 512(b)(13)(E) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to payments received or accrued after December 
     31, 2013.

     SEC. 132. EXTENSION OF TREATMENT OF CERTAIN DIVIDENDS OF 
                   REGULATED INVESTMENT COMPANIES.

       (a) In General.--Paragraphs (1)(C)(v) and (2)(C)(v) of 
     section 871(k) are each amended by striking ``December 31, 
     2013'' and inserting ``December 31, 2014''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 133. EXTENSION OF RIC QUALIFIED INVESTMENT ENTITY 
                   TREATMENT UNDER FIRPTA.

       (a) In General.--Clause (ii) of section 897(h)(4)(A) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Effective Date.--
       (1) In general.--The amendment made by this section shall 
     take effect on January 1, 2014. Notwithstanding the preceding 
     sentence, such amendment shall not apply with respect to the 
     withholding requirement under section 1445 of the Internal 
     Revenue Code of 1986 for any payment made before the date of 
     the enactment of this Act.
       (2) Amounts withheld on or before date of enactment.--In 
     the case of a regulated investment company--
       (A) which makes a distribution after December 31, 2013, and 
     before the date of the enactment of this Act, and
       (B) which would (but for the second sentence of paragraph 
     (1)) have been required to withhold with respect to such 
     distribution under section 1445 of such Code,

     such investment company shall not be liable to any person to 
     whom such distribution was made for any amount so withheld 
     and paid over to the Secretary of the Treasury.

     SEC. 134. EXTENSION OF SUBPART F EXCEPTION FOR ACTIVE 
                   FINANCING INCOME.

       (a) Exempt Insurance Income.--Paragraph (10) of section 
     953(e) is amended--
       (1) by striking ``January 1, 2014'' and inserting ``January 
     1, 2015'', and
       (2) by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Special Rule for Income Derived in the Active Conduct 
     of Banking, Financing, or Similar Businesses.--Paragraph (9) 
     of section 954(h) is amended by striking ``January 1, 2014'' 
     and inserting ``January 1, 2015''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years of foreign corporations 
     beginning after December 31, 2013, and to taxable years of 
     United States shareholders with or within which any such 
     taxable year of such foreign corporation ends.

     SEC. 135. EXTENSION OF LOOK-THRU TREATMENT OF PAYMENTS 
                   BETWEEN RELATED CONTROLLED FOREIGN CORPORATIONS 
                   UNDER FOREIGN PERSONAL HOLDING COMPANY RULES.

       (a) In General.--Subparagraph (C) of section 954(c)(6) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years of foreign corporations 
     beginning after December 31, 2013, and to taxable years of 
     United States shareholders with or within which such taxable 
     years of foreign corporations end.

     SEC. 136. EXTENSION OF TEMPORARY EXCLUSION OF 100 PERCENT OF 
                   GAIN ON CERTAIN SMALL BUSINESS STOCK.

       (a) In General.--Paragraph (4) of section 1202(a) is 
     amended--
       (1) by striking ``January 1, 2014'' and inserting ``January 
     1, 2015'', and
       (2) by striking ``and 2013'' in the heading and inserting 
     ``2013, and 2014''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to stock acquired after December 31, 2013.

     SEC. 137. EXTENSION OF BASIS ADJUSTMENT TO STOCK OF S 
                   CORPORATIONS MAKING CHARITABLE CONTRIBUTIONS OF 
                   PROPERTY.

       (a) In General.--Paragraph (2) of section 1367(a) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to contributions made in taxable years beginning 
     after December 31, 2013.

     SEC. 138. EXTENSION OF REDUCTION IN S-CORPORATION RECOGNITION 
                   PERIOD FOR BUILT-IN GAINS TAX.

       (a) In General.--Subparagraph (C) of section 1374(d)(7) is 
     amended--
       (1) by striking ``2012 or 2013'' and inserting ``2012, 
     2013, or 2014'', and
       (2) by striking ``2012 and 2013'' in the heading and 
     inserting ``2012, 2013, and 2014''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 139. EXTENSION OF EMPOWERMENT ZONE TAX INCENTIVES.

       (a) In General.--Clause (i) of section 1391(d)(1)(A) is 
     amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (b) Treatment of Certain Termination Dates Specified in 
     Nominations.--In the case of a designation of an empowerment 
     zone the nomination for which included a termination date 
     which is contemporaneous with the date specified in 
     subparagraph (A)(i) of section 1391(d)(1) of the Internal 
     Revenue Code of 1986 (as in effect before the enactment of 
     this Act), subparagraph (B) of such section shall not apply 
     with respect to such designation if, after the date of the 
     enactment of this section, the entity which made such 
     nomination amends the nomination to provide for a new 
     termination date in such manner as the Secretary of the 
     Treasury (or the Secretary's designee) may provide.
       (c) Effective Dates.--The amendment made by this section 
     shall apply to periods after December 31, 2013.

     SEC. 140. EXTENSION OF TEMPORARY INCREASE IN LIMIT ON COVER 
                   OVER OF RUM EXCISE TAXES TO PUERTO RICO AND THE 
                   VIRGIN ISLANDS.

       (a) In General.--Paragraph (1) of section 7652(f) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to distilled spirits brought into the United 
     States after December 31, 2013.

     SEC. 141. EXTENSION OF AMERICAN SAMOA ECONOMIC DEVELOPMENT 
                   CREDIT.

       (a) In General.--Subsection (d) of section 119 of division 
     A of the Tax Relief and Health Care Act of 2006 is amended--
       (1) by striking ``January 1, 2014'' each place it appears 
     and inserting ``January 1, 2015'',
       (2) by striking ``first 8 taxable years'' in paragraph (1) 
     and inserting ``first 9 taxable years'', and
       (3) by striking ``first 2 taxable years'' in paragraph (2) 
     and inserting ``first 3 taxable years''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

[[Page 16504]]



                    Subtitle C--Energy Tax Extenders

     SEC. 151. EXTENSION OF CREDIT FOR NONBUSINESS ENERGY 
                   PROPERTY.

       (a) In General.--Paragraph (2) of section 25C(g) is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 152. EXTENSION OF SECOND GENERATION BIOFUEL PRODUCER 
                   CREDIT.

       (a) In General.--Clause (i) of section 40(b)(6)(J) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to qualified second generation biofuel production 
     after December 31, 2013.

     SEC. 153. EXTENSION OF INCENTIVES FOR BIODIESEL AND RENEWABLE 
                   DIESEL.

       (a) Credits for Biodiesel and Renewable Diesel Used as 
     Fuel.--Subsection (g) of section 40A is amended by striking 
     ``December 31, 2013'' and inserting ``December 31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to fuel sold or used after December 31, 2013.

     SEC. 154. EXTENSION OF PRODUCTION CREDIT FOR INDIAN COAL 
                   FACILITIES PLACED IN SERVICE BEFORE 2009.

       (a) In General.--Subparagraph (A) of section 45(e)(10) is 
     amended by striking ``8-year period'' each place it appears 
     and inserting ``9-year period''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to coal produced after December 31, 2013.

     SEC. 155. EXTENSION OF CREDITS WITH RESPECT TO FACILITIES 
                   PRODUCING ENERGY FROM CERTAIN RENEWABLE 
                   RESOURCES.

       (a) In General.--The following provisions of section 45(d) 
     are each amended by striking ``January 1, 2014'' each place 
     it appears and inserting ``January 1, 2015'':
       (1) Paragraph (1).
       (2) Paragraph (2)(A).
       (3) Paragraph (3)(A).
       (4) Paragraph (4)(B).
       (5) Paragraph (6).
       (6) Paragraph (7).
       (7) Paragraph (9).
       (8) Paragraph (11)(B).
       (b) Extension of Election to Treat Qualified Facilities as 
     Energy Property.--Clause (ii) of section 48(a)(5)(C) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (c) Effective Dates.--The amendments made by this section 
     shall take effect on January 1, 2014.

     SEC. 156. EXTENSION OF CREDIT FOR ENERGY-EFFICIENT NEW HOMES.

       (a) In General.--Subsection (g) of section 45L is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to homes acquired after December 31, 2013.

     SEC. 157. EXTENSION OF SPECIAL ALLOWANCE FOR SECOND 
                   GENERATION BIOFUEL PLANT PROPERTY.

       (a) In General.--Subparagraph (D) of section 168(l)(2) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 158. EXTENSION OF ENERGY EFFICIENT COMMERCIAL BUILDINGS 
                   DEDUCTION.

       (a) In General.--Subsection (h) of section 179D is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2014''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 159. EXTENSION OF SPECIAL RULE FOR SALES OR DISPOSITIONS 
                   TO IMPLEMENT FERC OR STATE ELECTRIC 
                   RESTRUCTURING POLICY FOR QUALIFIED ELECTRIC 
                   UTILITIES.

       (a) In General.--Paragraph (3) of section 451(i) is amended 
     by striking ``January 1, 2014'' and inserting ``January 1, 
     2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to dispositions after December 31, 2013.

     SEC. 160. EXTENSION OF EXCISE TAX CREDITS RELATING TO CERTAIN 
                   FUELS.

       (a) Excise Tax Credits and Outlay Payments for Biodiesel 
     and Renewable Diesel Fuel Mixtures.--
       (1) Paragraph (6) of section 6426(c) is amended by striking 
     ``December 31, 2013'' and inserting ``December 31, 2014''.
       (2) Subparagraph (B) of section 6427(e)(6) is amended by 
     striking ``December 31, 2013'' and inserting ``December 31, 
     2014''.
       (b) Extension of Alternative Fuels Excise Tax Credits.--
       (1) In general.--Sections 6426(d)(5) and 6426(e)(3) are 
     each amended by striking ``December 31, 2013'' and inserting 
     ``December 31, 2014''.
       (2) Outlay payments for alternative fuels.--Subparagraph 
     (C) of section 6427(e)(6) is amended by striking ``December 
     31, 2013'' and inserting ``December 31, 2014''.
       (c) Extension of Alternative Fuels Excise Tax Credits 
     Relating to Liquefied Hydrogen.--
       (1) In general.--Sections 6426(d)(5) and 6426(e)(3), as 
     amended by subsection (b), are each amended by striking 
     ``(September 30, 2014 in the case of any sale or use 
     involving liquefied hydrogen)''.
       (2) Outlay payments for alternative fuels.--Paragraph (6) 
     of section 6427(e) is amended--
       (A) by striking ``except as provided in subparagraph (D), 
     any'' in subparagraph (C), as amended by this Act, and 
     inserting ``any'',
       (B) by striking the comma at the end of subparagraph (C) 
     and inserting ``, and'', and
       (C) by striking subparagraph (D) and redesignating 
     subparagraph (E) as subparagraph (D).
       (d) Effective Dates.--
       (1) In general.--Except as provided in paragraph (2), the 
     amendments made by this section shall apply to fuel sold or 
     used after December 31, 2013.
       (2) Liquefied hydrogen.--The amendments made by subsection 
     (c) shall apply to fuel sold or used after September 30, 
     2014.
       (e) Special Rule for Certain Periods During 2014.--
     Notwithstanding any other provision of law, in the case of--
       (1) any biodiesel mixture credit properly determined under 
     section 6426(c) of the Internal Revenue Code of 1986 for 
     periods after December 31, 2013, and before the date of the 
     enactment of this Act, and
       (2) any alternative fuel credit properly determined under 
     section 6426(d) of such Code for such periods,

     such credit shall be allowed, and any refund or payment 
     attributable to such credit (including any payment under 
     section 6427(e) of such Code) shall be made, only in such 
     manner as the Secretary of the Treasury (or the Secretary's 
     delegate) shall provide. Such Secretary shall issue guidance 
     within 30 days after the date of the enactment of this Act 
     providing for a one-time submission of claims covering 
     periods described in the preceding sentence. Such guidance 
     shall provide for a 180-day period for the submission of such 
     claims (in such manner as prescribed by such Secretary) to 
     begin not later than 30 days after such guidance is issued. 
     Such claims shall be paid by such Secretary not later than 60 
     days after receipt. If such Secretary has not paid pursuant 
     to a claim filed under this subsection within 60 days after 
     the date of the filing of such claim, the claim shall be paid 
     with interest from such date determined by using the 
     overpayment rate and method under section 6621 of such Code.

     SEC. 161. EXTENSION OF CREDIT FOR ALTERNATIVE FUEL VEHICLE 
                   REFUELING PROPERTY.

       (a) In General.--Subsection (g) of section 30C is amended 
     by striking ``placed in service'' and all that follows and 
     inserting ``placed in service after December 31, 2014.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

Subtitle D--Extenders Relating to Multiemployer Defined Benefit Pension 
                                 Plans

     SEC. 171. EXTENSION OF AUTOMATIC EXTENSION OF AMORTIZATION 
                   PERIODS.

       (a) In General.--Subparagraph (C) of section 431(d)(1) is 
     amended by striking ``December 31, 2014'' and inserting 
     ``December 31, 2015''.
       (b) Amendment to Employee Retirement Income Security Act of 
     1974.--Subparagraph (C) of section 304(d)(1) of the Employee 
     Retirement Income Security Act of 1974 (29 U.S.C. 
     1084(d)(1)(C)) is amended by striking ``December 31, 2014'' 
     and inserting ``December 31, 2015''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to applications submitted under section 
     431(d)(1)(A) of the Internal Revenue Code of 1986 and section 
     304(d)(1)(C) of the Employee Retirement Income Security Act 
     of 1974 after December 31, 2014.

     SEC. 172. EXTENSION OF SHORTFALL FUNDING METHOD AND 
                   ENDANGERED AND CRITICAL RULES.

       (a) In General.--Paragraphs (1) and (2) of section 221(c) 
     of the Pension Protection Act of 2006 are each amended by 
     striking ``December 31, 2014'' and inserting ``December 31, 
     2015''.
       (b) Conforming Amendment.--Paragraph (2) of section 221(c) 
     of the Pension Protection Act of 2006 is amended by striking 
     ``January 1, 2015'' and inserting ``January 1, 2016''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to plan years beginning after December 31, 2014.

                    TITLE II--TECHNICAL CORRECTIONS

     SEC. 201. SHORT TITLE.

       This title may be cited as the ``Tax Technical Corrections 
     Act of 2014''.

     SEC. 202. AMENDMENTS RELATING TO AMERICAN TAXPAYER RELIEF ACT 
                   OF 2012.

       (a) Amendment Relating to Section 101(b).--Subclause (I) of 
     section 642(b)(2)(C)(i) is amended by striking ``section 
     151(d)(3)(C)(iii)'' and inserting ``section 68(b)(1)(C)''.
       (b) Amendment Relating to Section 102.--Clause (ii) of 
     section 911(f)(2)(B) is amended by striking ``described in 
     section 1(h)(1)(B) shall be treated as a reference to such 
     excess as determined'' and inserting ``described in section 
     1(h)(1)(B), and the reference in section 55(b)(3)(C)(ii) to 
     the excess described in section 1(h)(1)(C)(ii), shall each be 
     treated as a reference to each such excess as determined''.
       (c) Amendments Relating to Section 104.--

[[Page 16505]]

       (1) Clause (ii) of section 55(d)(4)(B) is amended by 
     inserting ``subparagraphs (A), (B), and (D) of'' before 
     ``paragraph (1)''.
       (2) Subparagraph (C) of section 55(d)(4) is amended by 
     striking ``increase'' and inserting ``increased amount''.
       (d) Amendments Relating to Section 310.--Clause (iii) of 
     section 6431(f)(3)(A) is amended--
       (1) by striking ``2011'' and inserting ``years after 
     2010'', and
       (2) by striking ``of such allocation'' and inserting ``of 
     any such allocation''.
       (e) Amendment Relating to Section 331.--Clause (iii) of 
     section 168(k)(4)(J) is amended by striking ``any taxable 
     year'' and inserting ``its first taxable year''.
       (f) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provision of the 
     American Taxpayer Relief Act of 2012 to which they relate.

     SEC. 203. AMENDMENT RELATING TO MIDDLE CLASS TAX RELIEF AND 
                   JOB CREATION ACT OF 2012.

       (a) Amendment Relating to Section 7001.--Paragraph (1) of 
     section 7001 of the Middle Class Tax Relief and Job Creation 
     Act of 2012 is amended by striking ``201(b)'' and inserting 
     ``202(b)''.
       (b) Effective Date.--The amendment made by subsection (a) 
     shall take effect as if included in section 7001 of the 
     Middle Class Tax Relief and Job Creation Act of 2012.

     SEC. 204. AMENDMENT RELATING TO FAA MODERNIZATION AND REFORM 
                   ACT OF 2012.

       (a) Amendment Relating to Section 1107.--Section 4281 is 
     amended to read as follows:

     ``SEC. 4281. SMALL AIRCRAFT ON NONESTABLISHED LINES.

       ``(a) In General.--The taxes imposed by sections 4261 and 
     4271 shall not apply to transportation by an aircraft having 
     a maximum certificated takeoff weight of 6,000 pounds or 
     less, except when such aircraft is operated on an established 
     line or when such aircraft is a jet aircraft.
       ``(b) Maximum Certificated Takeoff Weight.--For purposes of 
     this section, the term `maximum certificated takeoff weight' 
     means the maximum such weight contained in the type 
     certificate or airworthiness certificate.
       ``(c) Sightseeing.--For purposes of this section, an 
     aircraft shall not be considered as operated on an 
     established line at any time during which such aircraft is 
     being operated on a flight the sole purpose of which is 
     sightseeing.
       ``(d) Jet Aircraft.--For purposes of this section, the term 
     `jet aircraft' shall not include any aircraft which is a 
     rotorcraft or propeller aircraft.''.
       (b) Effective Date.--The amendment made by subsection (a) 
     shall take effect as if included in section 1107 of the FAA 
     Modernization and Reform Act of 2012.

     SEC. 205. AMENDMENTS RELATING TO REGULATED INVESTMENT COMPANY 
                   MODERNIZATION ACT OF 2010.

       (a) Amendments Relating to Section 101.--
       (1) Subsection (c) of section 101 of the Regulated 
     Investment Company Modernization Act of 2010 is amended--
       (A) by striking ``paragraph (2)'' in paragraph (1) and 
     inserting ``paragraphs (2) and (3)'', and
       (B) by adding at the end the following new paragraph:
       ``(3) Excise tax.--
       ``(A) In general.--Except as provided in subparagraph (B), 
     for purposes of section 4982 of the Internal Revenue Code of 
     1986, paragraphs (1) and (2) shall apply by substituting `the 
     1-year periods taken into account under subsection (b)(1)(B) 
     of such section with respect to calendar years beginning 
     after December 31, 2010' for `taxable years beginning after 
     the date of the enactment of this Act'.
       ``(B) Election.--A regulated investment company may elect 
     to apply subparagraph (A) by substituting `2011' for `2010'. 
     Such election shall be made at such time and in such form and 
     manner as the Secretary of the Treasury (or the Secretary's 
     delegate) shall prescribe.''.
       (2) The first sentence of paragraph (2) of section 852(c) 
     is amended--
       (A) by striking ``and without regard to'' and inserting ``, 
     without regard to'', and
       (B) by inserting ``, and without regard to any capital loss 
     arising on the first day of the taxable year by reason of 
     clauses (ii) and (iii) of section 1212(a)(3)(A)'' before the 
     period at the end.
       (b) Amendment Relating to Section 304.--Paragraph (1) of 
     section 855(a) is amended by inserting ``on or'' before 
     ``before''.
       (c) Amendments Relating to Section 308.--
       (1) Paragraph (8) of section 852(b) is amended by 
     redesignating subparagraph (E) as subparagraph (G) and by 
     striking subparagraphs (C) and (D) and inserting the 
     following new subparagraphs:
       ``(C) Post-october capital loss.--For purposes of this 
     paragraph, the term `post-October capital loss' means--
       ``(i) any net capital loss attributable to the portion of 
     the taxable year after October 31, or
       ``(ii) if there is no such loss--

       ``(I) any net long-term capital loss attributable to such 
     portion of the taxable year, or
       ``(II) any net short-term capital loss attributable to such 
     portion of the taxable year.

       ``(D) Late-year ordinary loss.--For purposes of this 
     paragraph, the term `late-year ordinary loss' means the sum 
     of any post-October specified loss and any post-December 
     ordinary loss.
       ``(E) Post-october specified loss.--For purposes of this 
     paragraph, the term `post-October specified loss' means the 
     excess (if any) of--
       ``(i) the specified losses (as defined in section 
     4982(e)(5)(B)(ii)) attributable to the portion of the taxable 
     year after October 31, over
       ``(ii) the specified gains (as defined in section 
     4982(e)(5)(B)(i)) attributable to such portion of the taxable 
     year.
       ``(F) Post-december ordinary loss.--For purposes of this 
     paragraph, the term `post-December ordinary loss' means the 
     excess (if any) of--
       ``(i) the ordinary losses not described in subparagraph 
     (E)(i) and attributable to the portion of the taxable year 
     after December 31, over
       ``(ii) the ordinary income not described in subparagraph 
     (E)(ii) and attributable to such portion of the taxable 
     year.''.
       (2) Subparagraph (G) of section 852(b)(8), as so 
     redesignated, is amended by striking ``, (D)(i)(I), and 
     (D)(ii)(I)'' and inserting ``and (E)''.
       (3) The first sentence of paragraph (2) of section 852(c), 
     as amended by subsection (a), is amended--
       (A) by striking ``, and without regard to'' and inserting 
     ``, without regard to'', and
       (B) by inserting ``, and with such other adjustments as the 
     Secretary may prescribe'' before the period at the end.
       (d) Amendments Relating to Section 402.--
       (1) Subparagraph (B) of section 4982(e)(6) is amended by 
     inserting before the period at the end the following: ``or 
     which determines income by reference to the value of an item 
     on the last day of the taxable year''.
       (2) Subparagraph (A) of section 4982(e)(7) is amended by 
     striking ``such company'' and all that follows through ``any 
     net ordinary loss'' and inserting ``such company may elect to 
     determine its ordinary income and net ordinary loss (as 
     defined in paragraph (2)(C)(ii)) for the calendar year 
     without regard to any portion of any net ordinary loss''.
       (e) Clerical Amendment Relating to Section 201.--
     Subparagraph (A) of section 851(d)(2) is amended by inserting 
     ``of this paragraph'' after ``subparagraph (B)(i)''.
       (f) Effective Date.--
       (1) In general.--Except as provided in paragraph (2), the 
     amendments made by this section shall take effect as if 
     included in the provision of the Regulated Investment Company 
     Modernization Act of 2010 to which they relate.
       (2) Savings provision.--In the case of an election by a 
     regulated investment company under section 852(b)(8) of the 
     Internal Revenue Code of 1986 with respect to any taxable 
     year beginning before the date of the enactment of this Act, 
     such company may treat the amendments made by paragraphs (1) 
     and (2) of subsection (c) as not applying with respect to any 
     such election.

     SEC. 206. AMENDMENTS RELATING TO TAX RELIEF, UNEMPLOYMENT 
                   INSURANCE REAUTHORIZATION, AND JOB CREATION ACT 
                   OF 2010.

       (a) Amendment Relating to Section 103.--Clause (ii) of 
     section 32(b)(3)(B) is amended by striking ``in 2010'' and 
     inserting ``after 2009''.
       (b) Clerical Amendments Relating to Section 302.--
       (1) Paragraph (1) of section 2801(a) is amended by striking 
     ``(or, if greater, the highest rate of tax specified in the 
     table applicable under section 2502(a) as in effect on the 
     date)''.
       (2) Subsection (f) of section 302 of the Tax Relief, 
     Unemployment Insurance Reauthorization, and Job Creation Act 
     of 2010 is amended by striking ``subsection'' and inserting 
     ``section''.
       (c) Amendments Relating to Section 753.--Subparagraph (A) 
     of section 1397B(b)(1) is amended by striking ``and'' at the 
     end of clause (ii), by striking the period at the end of 
     clause (iii) and inserting ``, and'', and by adding at the 
     end the following new clause:
       ``(iv) the day after the date set forth in section 
     1391(d)(1)(A)(i) were substituted for `January 1, 2010' each 
     place it appears.''.
       (d) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the Tax 
     Relief, Unemployment Insurance Reauthorization, and Job 
     Creation Act of 2010 to which they relate.

     SEC. 207. AMENDMENTS RELATING TO CREATING SMALL BUSINESS JOBS 
                   ACT OF 2010.

       (a) Amendments Relating to Section 2102.--
       (1) Subsection (h) of section 2102 of the Creating Small 
     Business Jobs Act of 2010 is amended by inserting ``, and 
     payee statements required to be furnished,'' after 
     ``information returns required to be filed''.
       (2) Paragraphs (1) and (2) of subsection (b), and 
     subsection (c)(1)(C), of section 6722 are each amended by 
     striking ``the required filing date'' and inserting ``the 
     date prescribed for furnishing such statement''.
       (3) Subparagraph (B) of section 6722(c)(2) is amended by 
     striking ``filed'' and inserting ``furnished''.

[[Page 16506]]

       (b) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provision of the 
     Creating Small Business Jobs Act of 2010 to which they 
     relate.

     SEC. 208. CLERICAL AMENDMENT RELATING TO HIRING INCENTIVES TO 
                   RESTORE EMPLOYMENT ACT.

       (a) Amendment Relating to Section 512.--Paragraph (1) of 
     section 512(a) of the Hiring Incentives to Restore Employment 
     Act is amended by striking ``after paragraph (6)'' and 
     inserting ``after paragraph (5)''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect as if included in the provision of the 
     Hiring Incentives to Restore Employment Act to which it 
     relates.

     SEC. 209. AMENDMENTS RELATING TO AMERICAN RECOVERY AND 
                   REINVESTMENT TAX ACT OF 2009.

       (a) Amendment Relating to Section 1003.--Paragraph (4) of 
     section 24(d) is amended to read as follows:
       ``(4) Special rule for certain years.--In the case of any 
     taxable year beginning after 2008 and before 2018, paragraph 
     (1)(B)(i) shall be applied by substituting `$3,000' for 
     `$10,000'.''.
       (b) Amendment Relating to Section 1004.--Paragraph (3) of 
     section 25A(i) is amended by striking ``Subsection (f)(1)(A) 
     shall be applied'' and inserting ``For purposes of 
     determining the Hope Scholarship Credit, subsection (f)(1)(A) 
     shall be applied''.
       (c) Amendments Relating to Section 1008.--
       (1) Paragraph (6) of section 164(b) is amended by striking 
     subparagraph (E) and by redesignating subparagraphs (F) and 
     (G) as subparagraphs (E) and (F), respectively.
       (2) Subparagraphs (E) and (F) of section 164(b)(6), as so 
     redesignated, are each amended by striking ``This paragraph'' 
     and inserting ``Subsection (a)(6)''.
       (d) Amendment Relating to Section 1104.--Subparagraph (A) 
     of section 48(d)(3) is amended by inserting ``or alternative 
     minimum taxable income'' after ``includible in the gross 
     income''.
       (e) Amendments Relating to Section 1141.--
       (1) Subsection (f) of section 30D is amended--
       (A) by inserting ``(determined without regard to subsection 
     (c))'' before the period at the end of paragraph (1), and
       (B) by inserting ``(determined without regard to subsection 
     (c))'' before the period at the end of paragraph (2).
       (2) Paragraph (3) of section 30D(f) is amended by adding at 
     the end the following: ``For purposes of subsection (c), 
     property to which this paragraph applies shall be treated as 
     of a character subject to an allowance for depreciation.''.
       (f) Amendments Relating to Section 1142.--
       (1) Subsection (b) of section 38 is amended by striking 
     ``plus'' at the end of paragraph (35), by redesignating 
     paragraph (36) as paragraph (37), and by inserting after 
     paragraph (35) the following new paragraph:
       ``(36) the portion of the qualified plug-in electric 
     vehicle credit to which section 30(c)(1) applies, plus''.
       (2)(A) Subsection (e) of section 30 is amended--
       (i) by inserting ``(determined without regard to subsection 
     (c))'' before the period at the end of paragraph (1), and
       (ii) by inserting ``(determined without regard to 
     subsection (c))'' before the period at the end of paragraph 
     (2).
       (B) Paragraph (3) of section 30(e) is amended by adding at 
     the end the following: ``For purposes of subsection (c), 
     property to which this paragraph applies shall be treated as 
     of a character subject to an allowance for depreciation.''.
       (g) Amendment Relating to Section 1302.--Paragraph (3) of 
     section 48C(b) is amended by inserting ``as the qualified 
     investment'' after ``The amount which is treated''.
       (h) Amendments Related to Section 1541.--
       (1) Paragraph (2) of section 853A(a) is amended by 
     inserting ``(determined after the application of this 
     section)'' before the comma at the end.
       (2) Subsection (a) of section 853A is amended--
       (A) by striking ``with respect to credits'' and inserting 
     ``with respect to some or all of the credits'', and
       (B) by inserting ``(determined without regard to this 
     section and sections 54(c), 54A(c)(1), 54AA(c)(1), and 
     1397E(c))'' after ``credits allowable''.
       (3) Subsection (b) of section 853A is amended to read as 
     follows:
       ``(b) Effect of Election.--If the election provided in 
     subsection (a) is in effect with respect to any credits for 
     any taxable year--
       ``(1) the regulated investment company--
       ``(A) shall not be allowed such credits,
       ``(B) shall include in gross income (as interest) for such 
     taxable year the amount which would have been so included 
     with respect to such credits had the application of this 
     section not been elected,
       ``(C) shall include in earnings and profits the amount so 
     included in gross income, and
       ``(D) shall be treated as making one or more distributions 
     of money with respect to its stock equal to the amount of 
     such credits on the date or dates (on or after the applicable 
     date for any such credit) during such taxable year (or 
     following the close of the taxable year pursuant  to section 
     855)  selected by the company, and
       ``(2) each shareholder of such investment company shall--
       ``(A) be treated as receiving such shareholder's 
     proportionate share of any distribution of money which is 
     treated as made by such investment company under paragraph 
     (1)(D), and
       ``(B) be allowed credits against the tax imposed by this 
     chapter equal to the amount of such distribution, subject to 
     the provisions of this title applicable to the credit 
     involved.''.
       (4) Subsection (c) of section 853A is amended to read as 
     follows:
       ``(c) Notice to Shareholders.--The amount treated as a 
     distribution of money received by a shareholder under 
     subsection (b)(2)(A) (and as credits allowed to such 
     shareholder under subsection (b)(2)(B)) shall not exceed the 
     amount so reported by the regulated investment company in a 
     written statement furnished to such shareholder.''.
       (5) Clause (ii) of section 853A(e)(1)(A) is amended by 
     inserting ``other than a qualified bond described in section 
     54AA(g)'' after ``as defined in section 54AA(d))''.
       (i) Amendments Relating to Section 2202.--
       (1) Subparagraph (A) of section 2202(b)(1) of division B of 
     the American Recovery and Reinvestment Act of 2009 is amended 
     by inserting ``political subdivision of a State,'' after 
     ``any State,''.
       (2) Section 2202 of division B of the American Recovery and 
     Reinvestment Act of 2009 is amended by adding at the end the 
     following new subsection:
       ``(e) Treatment of Possessions.--
       ``(1) Payments to mirror code possessions.--The Secretary 
     of the Treasury shall pay to each possession of the United 
     States with a mirror code tax system amounts equal to the 
     loss to that possession by reason of credits allowed under 
     subsection (a) with respect to taxable years beginning in 
     2009. Such amounts shall be determined by the Secretary of 
     the Treasury based on information provided by the government 
     of the respective possession.
       ``(2) Coordination with credit allowed against united 
     states income taxes.--No credit shall be allowed against 
     United States income taxes for any taxable year under this 
     section to any person to whom a credit is allowed against 
     taxes imposed by the possession by reason of the credit 
     allowed under subsection (a) for such taxable year.
       ``(3) Definitions and special rules.--
       ``(A) Possession of the united states.--For purposes of 
     this subsection, the term `possession of the United States' 
     includes the Commonwealth of the Northern Mariana Islands.
       ``(B) Mirror code tax system.--For purposes of this 
     subsection, the term `mirror code tax system' means, with 
     respect to any possession of the United States, the income 
     tax system of such possession if the income tax liability of 
     the residents of such possession under such system is 
     determined by reference to the income tax laws of the United 
     States as if such possession were the United States.
       ``(C) Treatment of payments.--For purposes of section 
     1324(b)(2) of title 31, United States Code, the payments 
     under this subsection shall be treated in the same manner as 
     a refund due from the credit allowed under section 36A of the 
     Internal Revenue Code of 1986 (as added by this Act).''.
       (j) Clerical Amendments.--
       (1) Amendment relating to section 1131.--Paragraph (2) of 
     section 45Q(d) is amended by striking ``Administrator of the 
     Environmental Protection Agency'' and all that follows 
     through ``shall establish'' and inserting ``Administrator of 
     the Environmental Protection Agency, the Secretary of Energy, 
     and the Secretary of the Interior, shall establish''.
       (2) Amendment relating to section 1141.--Paragraph (37) of 
     section 1016(a) is amended by striking ``section 30D(e)(4)'' 
     and inserting ``section 30D(f)(1)''.
       (3) Amendment relating to section 3001.--Subparagraph (A) 
     of section 3001(a)(14) of the American Recovery and 
     Reinvestment Act of 2009 is amended by striking ``is amended 
     by redesignating paragraph (9) as paragraph (10)'' and 
     inserting ``, as amended by this Act, is amended by 
     redesignating paragraphs (9) and (10) as paragraphs (10) and 
     (11), respectively,''.
       (k) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the 
     American Recovery and Reinvestment Tax Act of 2009 to which 
     they relate.

     SEC. 210. AMENDMENTS RELATING TO ENERGY IMPROVEMENT AND 
                   EXTENSION ACT OF 2008.

       (a) Amendment Relating to Section 108.--Subparagraph (E) of 
     section 45K(g)(2) is amended to read as follows:
       ``(E) Coordination with section 45.--No credit shall be 
     allowed with respect to any coke or coke gas which is 
     produced using steel industry fuel (as defined in section 
     45(c)(7)) as feedstock if a credit is allowed to any taxpayer 
     under section 45 with respect to the production of such steel 
     industry fuel.''.

[[Page 16507]]

       (b) Amendment Relating to Section 113.--Paragraph (1) of 
     section 113(b) of the Energy Improvement and Extension Act of 
     2008 is amended by adding at the end the following new 
     subparagraph:
       ``(F) Trust fund.--The term `Trust Fund' means the Black 
     Lung Disability Trust Fund established under section 9501 of 
     the Internal Revenue Code of 1986.''.
       (c) Amendments Relating to Section 306.--
       (1) Clause (ii) of section 168(i)(18)(A) is amended by 
     striking ``10 years'' and inserting ``16 years''.
       (2) Clause (ii) of section 168(i)(19)(A) is amended by 
     striking ``10 years'' and inserting ``16 years''.
       (d) Amendment Relating to Section 308.--Clause (i) of 
     section 168(m)(2)(B) is amended by striking ``section 
     168(k)'' and inserting ``subsection (k) (determined without 
     regard to paragraph (4) thereof)''.
       (e) Amendment Relating to Section 402.--Subparagraph (A) of 
     section 907(f)(4) is amended by striking ``this subsection 
     shall be applied'' and all that follows through the period at 
     the end and inserting the following: ``this subsection, as in 
     effect on the day before the date of the enactment of the 
     Energy Improvement and Extension Act of 2008, shall apply to 
     unused oil and gas extraction taxes carried from such unused 
     credit year to a taxable year beginning after December 31, 
     2008.''.
       (f) Amendments Relating to Section 403.--
       (1) Subsection (c) of section 1012 is amended--
       (A) by striking ``funds'' in the heading for paragraph (2) 
     and inserting ``regulated investment companies'',
       (B) by striking ``fund'' in the heading for paragraph 
     (2)(B), and
       (C) by striking ``fund'' each place it appears in paragraph 
     (2) and inserting ``regulated investment company''.
       (2) Paragraph (1) of section 1012(d) is amended--
       (A) by striking ``December 31, 2010'' and inserting 
     ``December 31, 2011'', and
       (B) by striking ``an open-end fund'' and inserting ``a 
     regulated investment company''.
       (3) Paragraph (3) of section 1012(d) is amended to read as 
     follows:
       ``(3) Separate accounts; election for treatment as single 
     account.--
       ``(A) In general.--Rules similar to the rules of subsection 
     (c)(2) shall apply for purposes of this subsection.
       ``(B) Average basis method.--Notwithstanding paragraph (1), 
     in the case of an election under rules similar to the rules 
     of subsection (c)(2)(B) with respect to stock held in 
     connection with a dividend reinvestment plan, the average 
     basis method is permissible with respect to all such stock 
     without regard to the date of the acquisition of such 
     stock.''.
       (4) Subsection (g) of section 6045 is amended by adding at 
     the end the following new paragraph:
       ``(6) Special rule for certain stock held in connection 
     with dividend reinvestment plan.--For purposes of this 
     subsection, stock acquired before January 1, 2012, in 
     connection with a dividend reinvestment plan shall be treated 
     as stock described in clause (ii) of paragraph (3)(C) (unless 
     the broker with respect to such stock elects not to have this 
     paragraph apply with respect to such stock).''.
       (g) Clerical Amendments.--
       (1) Amendment relating to section 108.--Paragraph (2) of 
     section 45(b) is amended by striking ``$3 amount'' and 
     inserting ``$2 amount''.
       (2) Amendment relating to section 306.--
       (A) Paragraph (5) of section 168(b) is amended by striking 
     ``(2)(C)'' and inserting ``(2)(D)''.
       (B) The last sentence of section 168(k)(4)(C)(i) is amended 
     by striking ``(b)(2)(C)'' and inserting ``(b)(2)(D)''.
       (h) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the 
     Energy Improvement and Extension Act of 2008 to which they 
     relate.

     SEC. 211. AMENDMENTS RELATING TO TAX EXTENDERS AND 
                   ALTERNATIVE MINIMUM TAX RELIEF ACT OF 2008.

       (a) Amendment Relating to Section 208.--Subsection (b) of 
     section 208 of the Tax Extenders and Alternative Minimum Tax 
     Relief Act of 2008 is amended to read as follows:
       ``(b) Effective Date.--
       ``(1) In general.--The amendment made by subsection (a) 
     shall take effect on January 1, 2008. Notwithstanding the 
     preceding sentence, such amendment shall not apply with 
     respect to the withholding requirement under section 1445 of 
     the Internal Revenue Code of 1986 for any payment made before 
     October 4, 2008.
       ``(2) Amounts withheld on or before date of enactment.--In 
     the case of a regulated investment company--
       ``(A) which makes a distribution after December 31, 2007, 
     and before October 4, 2008, and
       ``(B) which would (but for the second sentence of paragraph 
     (1)) have been required to withhold with respect to such 
     distribution under section 1445 of such Code,

     such investment company shall not be liable to any person to 
     whom such distribution was made for any amount so withheld 
     and paid over to the Secretary of the Treasury.''.
       (b) Amendments Relating to Section 305.--Paragraphs (7)(B) 
     and (8)(D) of section 168(e) are each amended by inserting 
     ``which is not qualified leasehold improvement property'' 
     after ``Property described in this paragraph''.
       (c) Clerical Amendments.--
       (1) Amendments relating to section 706.--
       (A) Paragraph (2) of section 1033(h) is amended by 
     inserting ``is'' before ``compulsorily''.
       (B) Subclause (II) of section 172(b)(1)(F)(ii) is amended 
     by striking ``subsection (h)(3)(C)(i)'' and inserting 
     ``section 165(h)(3)(C)(i)''.
       (C) The heading for paragraph (1) of section 165(h) is 
     amended by striking ``$100'' and inserting ``Dollar''.
       (2) Amendment relating to section 709.--Subsection (k) of 
     section 143 is amended by redesignating the second paragraph 
     (12) (relating to special rules for residences destroyed in 
     Federally declared disasters) as paragraph (13).
       (3) Amendment relating to section 712.--Section 712 of the 
     Tax Extenders and Alternative Minimum Tax Relief Act of 2008 
     is amended by striking ``section 702(c)(1)(A)'' and inserting 
     ``section 702(b)(1)(A)''.
       (d) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the Tax 
     Extenders and Alternative Minimum Tax Relief Act of 2008 to 
     which they relate.

     SEC. 212. CLERICAL AMENDMENTS RELATING TO HOUSING ASSISTANCE 
                   TAX ACT OF 2008.

       (a) Amendment Relating to Section 3002.--Paragraph (1) of 
     section 42(b) is amended by striking ``For purposes of this 
     section, the term'' and inserting the following: ``For 
     purposes of this section--
       ``(A) In general.--The term''.
       (b) Amendment Relating to Section 3081.--Clause (iv) of 
     section 168(k)(4)(E) is amended by striking ``adjusted 
     minimum tax'' and inserting ``adjusted net minimum tax''.
       (c) Amendment Relating to Section 3092.--Subsection (b) of 
     section 121 is amended by redesignating the second paragraph 
     (4) (relating to exclusion of gain allocated to nonqualified 
     use) as paragraph (5).
       (d) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the 
     Housing Assistance Tax Act of 2008 to which they relate.

     SEC. 213. AMENDMENTS AND PROVISION RELATING TO HEROES 
                   EARNINGS ASSISTANCE AND RELIEF TAX ACT OF 2008.

       (a) Amendment Relating to Section 106.--Paragraph (2) of 
     section 106(c) of the Heroes Earnings Assistance and Relief 
     Tax Act of 2008 is amended by striking ``substituting for'' 
     and inserting ``substituting `June 17, 2008' for''.
       (b) Amendment Relating to Section 114.--Paragraph (1) of 
     section 125(h) is amended by inserting ``(and shall not fail 
     to be treated as an accident or health plan)'' before 
     ``merely''.
       (c) Clerical Amendments.--
       (1) Amendment relating to section 110.--Subparagraph (B) of 
     section 121(d)(12) is amended by inserting ``of paragraph 
     (9)'' after ``and (D)''.
       (2) Amendment relating to section 301.--Paragraph (2) of 
     section 877(e) is amended by striking ``subparagraph (A) or 
     (B) of''.
       (d) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the 
     Heroes Earnings Assistance and Relief Tax Act of 2008 to 
     which they relate.

     SEC. 214. AMENDMENTS RELATING TO ECONOMIC STIMULUS ACT OF 
                   2008.

       (a) Amendments Relating to Section 101.--Paragraph (2) of 
     section 6213(g) is amended--
       (1) by striking ``32, or 6428'' in subparagraph (L) and 
     inserting ``or 32'', and
       (2) by striking ``and'' at the end of subparagraph (O), by 
     striking the period at the end of subparagraph (P) and 
     inserting ``, and'', and by inserting after subparagraph (P) 
     the following new subparagraph:
       ``(Q) an omission of a correct valid identification number 
     required under section 6428(h) (relating to 2008 recovery 
     rebates for individuals) to be included on a return.''.
       (b) Clerical Amendment Relating to Section 103.--Subclause 
     (IV) of section 168(k)(2)(B)(i) is amended by striking 
     ``clauses also apply'' and inserting ``clause also applies''.
       (c) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the 
     Economic Stimulus Act of 2008 to which they relate.

     SEC. 215. AMENDMENTS RELATING TO TAX TECHNICAL CORRECTIONS 
                   ACT OF 2007.

       (a) Amendment Relating to Section 4(c).--Paragraph (1) of 
     section 911(f) is amended by adding at the end the following 
     flush sentence:
     ``For purposes of this paragraph, the amount excluded under 
     subsection (a) shall be reduced by the aggregate amount of 
     any deductions or exclusions disallowed under subsection 
     (d)(6) with respect to such excluded amount.''.
       (b) Clerical Amendment Relating to Section 11(g).--Clause 
     (iv) of section 56(g)(4)(C) is amended by striking ``a 
     cooperative described in section 927(a)(4)'' and inserting

[[Page 16508]]

     ``an organization to which part I of subchapter T (relating 
     to tax treatment of cooperatives) applies which is engaged in 
     the marketing of agricultural or horticultural products''.
       (c) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provisions of the Tax 
     Technical Corrections Act of 2007 to which they relate.

     SEC. 216. AMENDMENT RELATING TO TAX RELIEF AND HEALTH CARE 
                   ACT OF 2006.

       (a) Amendment Relating to Section 105.--Subparagraph (B) of 
     section 45A(b)(1) is amended by adding at the end the 
     following: ``If any portion of wages are taken into account 
     under subsection (e)(1)(A) of section 51, the preceding 
     sentence shall be applied by substituting `2-year period' for 
     `1-year period'.''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect as if included in the provision of the Tax 
     Relief and Health Care Act of 2006 to which it relates.

     SEC. 217. AMENDMENT RELATING TO SAFE, ACCOUNTABLE, FLEXIBLE, 
                   EFFICIENT TRANSPORTATION EQUITY ACT OF 2005: A 
                   LEGACY FOR USERS.

       (a) Amendment Relating to Section 11161.--Paragraph (1) of 
     section 9503(b) is amended by inserting before the period at 
     the end the following: ``and taxes received under section 
     4081 shall be determined without regard to tax receipts 
     attributable to the rate specified in section 
     4081(a)(2)(C)''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect as if included in the provision of the 
     Safe, Accountable, Flexible, Efficient Transportation Equity 
     Act of 2005: A Legacy for Users to which it relates.

     SEC. 218. AMENDMENTS RELATING TO ENERGY TAX INCENTIVES ACT OF 
                   2005.

       (a) Amendment Relating to Section 1341.--Subparagraph (B) 
     of section 30B(h)(5) is amended by inserting ``(determined 
     without regard to subsection (g))'' before the period at the 
     end.
       (b) Amendment Relating to Section 1342.--Paragraph (1) of 
     section 30C(e) is amended to read as follows:
       ``(1) Reduction in basis.--For purposes of this subtitle, 
     the basis of any property for which a credit is allowable 
     under subsection (a) shall be reduced by the amount of such 
     credit so allowed (determined without regard to subsection 
     (d)).''.
       (c) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provision of the 
     Energy Tax Incentives Act of 2005 to which it relates.

     SEC. 219. AMENDMENTS RELATING TO AMERICAN JOBS CREATION ACT 
                   OF 2004.

       (a) Amendment Relating to Section 101.--Subsection (d) of 
     section 101 of the American Jobs Creation Act of 2004 is 
     amended by adding at the end the following new paragraph:
       ``(3) Coordination with section 199.--This subsection shall 
     be applied without regard to any deduction allowable under 
     section 199.''.
       (b) Amendments Relating to Section 102.--Paragraph (3) of 
     section 199(b) is amended--
       (1) by inserting ``of a short taxable year or'' after ``in 
     cases'', and
       (2) by striking ``and dispositions'' and inserting ``, 
     dispositions, and short taxable years''.
       (c) Clerical Amendment Relating to Section 413.--Paragraph 
     (7) of section 904(h) is amended by striking ``as ordinary 
     income under section 1246 or''.
       (d) Effective Date.--The amendments made by this section 
     shall take effect as if included in the provision of the 
     American Jobs Creation Act of 2004 to which they relate.

     SEC. 220. OTHER CLERICAL CORRECTIONS.

       (a) Paragraph (8) of section 30B(h) is amended by striking 
     ``vehicle)., except that'' and inserting ``vehicle), except 
     that''.
       (b) Subparagraph (A) of section 38(c)(2) is amended by 
     striking ``credit credit'' and inserting ``credit''.
       (c) Section 46 is amended by adding a comma at the end of 
     paragraph (4).
       (d) Subparagraph (E) of section 50(a)(2) is amended by 
     inserting ``, 48A(b)(3), 48B(b)(3), 48C(b)(2), or 48D(b)(4)'' 
     after ``in section 48(b)''.
       (e) Clause (i) of section 54A(d)(2)(A) is amended by 
     striking ``100 percent or more'' and inserting ``100 
     percent''.
       (f) Paragraph (2) of section 125(b) is amended by striking 
     ``statutory nontaxable benefits'' each place it appears and 
     inserting ``qualified benefits''.
       (g) Paragraph (2) of section 125(h) is amended by striking 
     ``means, any'' and inserting ``means any''.
       (h) Subparagraph (F) of section 163(h)(4) is amended by 
     striking ``Veterans Administration or the Rural Housing 
     Administration'' and inserting ``Department of Veterans 
     Affairs or the Rural Housing Service''.
       (i) Subsection (a) of section 249 is amended by striking 
     ``1563(a)(1)'' and inserting ``1563(a)(1))''.
       (j) Paragraphs (8) and (10) of section 280F(d) are each 
     amended by striking ``subsection (a)(2)'' and inserting 
     ``subsection (a)(1)''.
       (k) Clause (iii) of section 402A(c)(4)(E) is amended by 
     striking ``403(b)(7)(A)(i)'' and inserting 
     ``403(b)(7)(A)(ii)''.
       (l) Section 527 is amended--
       (1) by striking ``(2 U.S.C. 432(e))'' in subsection 
     (h)(2)(A)(i) and inserting ``(52 U.S.C. 30102(e))'', and
       (2) by striking ``(2 U.S.C. 431 et seq.)'' in subsections 
     (i)(6) and (j)(5)(A) and inserting ``(52 U.S.C. 30101 et 
     seq.)''.
       (m) Subsection (b) of section 858 is amended by striking 
     ``857(b)(8)'' and inserting ``857(b)(9)''.
       (n) Subparagraph (A) of section 1012(c)(2) is amended by 
     striking ``section 1012'' and inserting ``this section''.
       (o) The heading for section 1394(f) is amended by striking 
     ``Designated Under Section 1391(g)''.
       (p) Paragraphs (1) and (2)(A) of section 1394(f) are each 
     amended by striking ``a new empowerment zone facility bond'' 
     and inserting ``an empowerment zone facility bond''.
       (q) Clause (i) of section 1400N(c)(3)(A) is amended by 
     striking ``section 42(d)(5)(C)(iii)'' and inserting ``section 
     42(d)(5)(B)(iii)''.
       (r) Subsections (e)(3)(B) and (f)(7)(B) of section 4943 are 
     each amended by striking ``January 1, 1970'' and inserting 
     ``January 1, 1971''.
       (s) Paragraph (2) of section 4982(f) is amended by adding a 
     comma at the end.
       (t) Paragraph (3) of section 6011(e) is amended by striking 
     ``shall require than'' and inserting ``shall require that''.
       (u) Subsection (b) of section 6072 is amended by striking 
     ``6011(e)(2)'' and inserting ``6011(c)(2)''.
       (v) Subsection (d) of section 6104 is amended by 
     redesignating the second paragraph (6) (relating to 
     disclosure of reports by the Internal Revenue Service) and 
     third paragraph (6) (relating to application to nonexempt 
     charitable trusts and nonexempt private foundations) as 
     paragraphs (7) and (8), respectively.
       (w) Subsection (c) of section 6662A is amended by striking 
     ``section 6664(d)(2)(A)'' and inserting ``section 
     6664(d)(3)(A)''.
       (x) Subparagraph (FF) of section 6724(d)(2) is amended by 
     striking ``section 6050W(c)'' and inserting ``section 
     6050W(f)''.
       (y) Section 7122 is amended by redesignating the second 
     subsection (f) (relating to frivolous submissions, etc.) as 
     subsection (g).
       (z) Subsection (a) of section 9035 is amended by striking 
     ``section 320(b)(1)(A)'' and inserting ``section 
     315(b)(1)(A)''.
       (aa) Section 9802 is amended by redesignating the second 
     subsection (f) (relating to genetic information of a fetus or 
     embryo) as subsection (g).
       (bb) Paragraph (3) of section 13(e) of the Worker, 
     Homeownership, and Business Assistance Act of 2009 is amended 
     by striking ``subsection (d)'' and inserting ``subsection 
     (c)''.

     SEC. 221. DEADWOOD PROVISIONS.

       (a) In General.--
       (1) Adjustments in tax tables so that inflation will not 
     result in tax increases.--Paragraph (7) of section 1(f) is 
     amended to read as follows:
       ``(7) Special rule for certain brackets.--In prescribing 
     tables under paragraph (1) which apply to taxable years 
     beginning in a calendar year after 1994, the cost-of-living 
     adjustment used in making adjustments to the dollar amounts 
     at which the 36 percent rate bracket begins or at which the 
     39.6 percent rate bracket begins shall be determined under 
     paragraph (3) by substituting `1993' for `1992'.''.
       (2) Certain plug-in electric vehicles.--
       (A) Subpart B of part IV of subchapter A of chapter 1 is 
     amended by striking section 30 (and by striking the item 
     relating to such section in the table of sections for such 
     subpart).
       (B) Subsection (b) of section 38, as amended by section 
     209(f)(1) of this Act, is amended by inserting ``plus'' at 
     the end of paragraph (35), by striking paragraph (36), and by 
     redesignating paragraph (37) as paragraph (36).
       (C) Subclause (VI) of section 48C(c)(1)(A)(i) is amended by 
     striking ``, qualified plug-in electric vehicles (as defined 
     by section 30(d)),''.
       (D) Section 1016(a) is amended by striking paragraph (25).
       (E) Section 6501(m) is amended by striking ``section 
     30(e)(6),''.
       (3) Earned income credit.--
       (A) Paragraph (1) of section 32(b) is amended--
       (i) by striking subparagraphs (B) and (C), and
       (ii) by striking ``(A) In General.--In the case of taxable 
     years beginning after 1995:'' in subparagraph (A) and moving 
     the table 2 ems to the left.
       (B) Subparagraph (B) of section 32(b)(2) is amended by 
     striking ``increased by'' and all that follows and inserting 
     ``increased by $3,000.''.
       (4) First-time homebuyer credit.--Section 6213(g)(2), as 
     amended by section 214(a)(2) of this Act, is amended by 
     striking subparagraph (P).
       (5) Making work pay credit.--
       (A) Subpart C of part IV of subchapter A of chapter 1 is 
     amended by striking section 36A (and by striking the item 
     relating to such section in the table of sections for such 
     subpart).
       (B) Subparagraph (A) of section 6211(b)(4) is amended by 
     striking ``, 36A''.
       (C) Section 6213(g)(2) is amended by striking subparagraph 
     (N).
       (6) General business credits.--Subsection (d) of section 38 
     is amended by striking paragraph (3).

[[Page 16509]]

       (7) Low-income housing credit.--Subclause (I) of section 
     42(h)(3)(C)(ii) is amended by striking ``($1.50 for 2001)''.
       (8) Minimum tax credit.--
       (A)(i) Section 53 is amended by striking subsections (e) 
     and (f).
       (ii) The amendment made by clause (i) striking subsection 
     (f) of section 53 of the Internal Revenue Code of 1986 shall 
     not be construed to allow any tax abated by reason of section 
     53(f)(1) of such Code (as in effect before such amendment) to 
     be included in the amount determined under section 53(b)(1) 
     of such Code.
       (B) Paragraph (4) of section 6211(b)(4) is amended by 
     striking ``, 53(e)''.
       (9) Adjustments based on adjusted current earnings.--Clause 
     (ii) of section 56(g)(4)(F) is amended by striking ``In the 
     case of any taxable year beginning after December 31, 1992, 
     clause'' and inserting ``Clause''.
       (10) Items of tax preference; depletion.--Paragraph (1) of 
     section 57(a) is amended by striking ``Effective with respect 
     to taxable years beginning after December 31, 1992, this'' 
     and inserting ``This''.
       (11) Intangible drilling costs.--
       (A) Clause (i) of section 57(a)(2)(E) is amended by 
     striking ``In the case of any taxable year beginning after 
     December 31, 1992, this'' and inserting ``This''.
       (B) Clause (ii) of section 57(a)(2)(E) is amended by 
     striking ``(30 percent in case of taxable years beginning in 
     1993)''.
       (12) Environmental tax.--
       (A) Subchapter A of chapter 1 is amended by striking part 
     VII (and by striking the item relating to such part in the 
     table of parts for such subchapter).
       (B) Paragraph (2) of section 26(b) is amended by striking 
     subparagraph (B).
       (C) Section 30A(c) is amended by striking paragraph (1) and 
     by redesignating paragraphs (2), (3), and (4) as paragraphs 
     (1), (2), and (3), respectively.
       (D) Subsection (a) of section 164 is amended by striking 
     paragraph (5).
       (E) Section 275(a) is amended by striking the last 
     sentence.
       (F) Section 882(a)(1) is amended by striking ``, 59A''.
       (G) Section 936(a)(3) is amended by striking subparagraph 
     (A) and by redesignating subparagraphs (B), (C), and (D) as 
     subparagraphs (A), (B), and (C), respectively.
       (H) Section 1561(a) is amended--
       (i) by inserting ``and'' at the end of paragraph (2), by 
     striking ``, and'' at the end of paragraph (3) and inserting 
     a period, and by striking paragraph (4), and
       (ii) by striking ``, the amount specified in paragraph (3), 
     and the amount specified in paragraph (4)'' and inserting 
     ``and the amount specified in paragraph (3)''.
       (I) Section 4611(e) is amended--
       (i) by striking ``section 59A, this section,'' in paragraph 
     (2)(B) and inserting ``this section'', and
       (ii) in paragraph (3)(A)--

       (I) by striking ``section 59A,'', and
       (II) by striking the comma after ``rate)''.

       (J) Section 6425(c)(1)(A) is amended by inserting ``plus'' 
     at end of clause (i), by striking ``plus'' and inserting 
     ``over'' at the end of clause (ii), and by striking clause 
     (iii).
       (K) Section 6655 is amended--
       (i) in subsections (e)(2)(A)(i) and (e)(2)(B)(i), by 
     striking ``taxable income, alternative minimum taxable 
     income, and modified alternative minimum taxable income'' and 
     inserting ``taxable income and alternative minimum taxable 
     income'',
       (ii) in subsection (e)(2)(B), by striking clause (iii), and
       (iii) in subsection (g)(1)(A), by inserting ``plus'' at the 
     end of clause (ii), by striking clause (iii), and by 
     redesignating clause (iv) as clause (iii).
       (L) Section 9507(b)(1) is amended by striking ``59A,''.
       (13) Standard deduction.--
       (A) So much of paragraph (1) of section 63(c) as follows 
     ``the sum of--'' is amended to read as follows:
       ``(A) the basic standard deduction, and
       ``(B) the additional standard deduction.''.
       (B) Subsection (c) of section 63 is amended by striking 
     paragraphs (7), (8), and (9).
       (14) Annuities; certain proceeds of endowment and life 
     insurance contracts.--Section 72 is amended--
       (A) in subsection (c)(4), by striking ``; except that if 
     such date was before January 1, 1954, then the annuity 
     starting date is January 1, 1954'', and
       (B) in subsection (g)(3), by striking ``January 1, 1954, 
     or'' and ``, whichever is later''.
       (15) Unemployment compensation.--Section 85 is amended by 
     striking subsection (c).
       (16) Accident and health plans.--Section 105(f) is amended 
     by striking ``or (d)''.
       (17) Flexible spending arrangements.--Section 106(c)(1) is 
     amended by striking ``Effective on and after January 1, 1997, 
     gross'' and inserting ``Gross''.
       (18) Certain combat zone compensation of members of the 
     armed forces.--Subsection (c) of section 112 is amended--
       (A) by striking ``(after June 24, 1950)'' in paragraph (2), 
     and
       (B) by striking ``such zone;'' and all that follows in 
     paragraph (3) and inserting ``such zone.''.
       (19) Legal service plans.--
       (A) Part III of subchapter B of chapter 1 is amended by 
     striking section 120 (and by striking the item relating to 
     such section in the table of sections for such subpart).
       (B)(i) Section 414(n)(3)(C) is amended by striking 
     ``120,''.
       (ii) Section 414(t)(2) is amended by striking ``120,''.
       (iii) Section 501(c) is amended by striking paragraph (20).
       (iv) Section 3121(a) is amended by striking paragraph (17).
       (v) Section 3231(e) is amended by striking paragraph (7).
       (vi) Section 3306(b) is amended by striking paragraph (12).
       (vii) Section 6039D(d)(1) is amended by striking ``120,''.
       (viii) Section 209(a)(14) of the Social Security Act is 
     amended--
       (I) by striking subparagraph (B), and
       (II) by striking ``(14)(A)'' and inserting ``(14)''.
       (20) Principal residence.--Section 121(b)(3) is amended--
       (A) by striking subparagraph (B), and
       (B) in subparagraph (A), by striking ``(A) In general.--'' 
     and moving the text 2 ems to the left.
       (21) Certain reduced uniformed services retirement pay.--
     Section 122(b)(1) is amended by striking ``after December 31, 
     1965,''.
       (22) Great plains conservation program.--Section 126(a) is 
     amended by striking paragraph (6) and by redesignating 
     paragraphs (7), (8), (9), and (10) as paragraphs (6), (7), 
     (8), and (9), respectively.
       (23) Treble damage payments under the antitrust law.--
     Section 162(g) is amended by striking the last sentence.
       (24) State legislators' travel expenses away from home.--
     Paragraph (4) of section 162(h) is amended by striking ``For 
     taxable years beginning after December 31, 1980, this'' and 
     inserting ``This''.
       (25) Interest.--
       (A) Section 163 is amended--
       (i) by striking paragraph (6) of subsection (d), and
       (ii) by striking paragraph (5) of subsection (h).
       (B) Section 56(b)(1)(C) is amended by striking clause (ii) 
     and by redesignating clauses (iii), (iv), and (v) as clauses 
     (ii), (iii), and (iv), respectively.
       (26) Qualified motor vehicle taxes.--Section 164, as 
     amended by section 209(c) of this Act, is amended by striking 
     subsections (a)(6) and (b)(6).
       (27) Disaster losses.--
       (A) Subsection (h) of section 165 is amended by striking 
     paragraph (3) and by redesignating paragraphs (4) and (5) as 
     paragraphs (3) and (4), respectively.
       (B) Paragraph (3) of section 165(h), as so redesignated, is 
     amended by striking ``paragraphs (2) and (3)'' and inserting 
     ``paragraph (2)''.
       (C) Subsection (i) of section 165 is amended--
       (i) in paragraph (1)--

       (I) by striking ``(as defined by clause (ii) of subsection 
     (h)(3)(C))'', and
       (II) by striking ``(as defined by clause (i) of such 
     subsection)'',

       (ii) by striking ``(as defined by subsection (h)(3)(C)(i)'' 
     in paragraph (4), and
       (iii) by adding at the end the following new paragraph:
       ``(5) Federally declared disasters.--For purposes of this 
     subsection--
       ``(A) In general.--The term `Federally declared disaster' 
     means any disaster subsequently determined by the President 
     of the United States to warrant assistance by the Federal 
     Government under the Robert T. Stafford Disaster Relief and 
     Emergency Assistance Act.
       ``(B) Disaster area.--The term `disaster area' means the 
     area so determined to warrant such assistance.''.
       (D) Section 1033(h)(3) is amended by striking ``section 
     165(h)(3)(C)'' and inserting ``section 165(i)(5)''.
       (28) Charitable, etc., contributions and gifts.--Section 
     170 is amended--
       (A) by striking paragraph (3) of subsection (b),
       (B) by striking paragraph (6) of subsection (e), and
       (C) by striking subsection (k).
       (29) Amortizable bond premium.--
       (A) Subparagraph (B) of section 171(b)(1) is amended to 
     read as follows:
       ``(B)(i) with reference to the amount payable on maturity 
     (or if it results in a smaller amortizable bond premium 
     attributable to the period before the call date, with 
     reference to the amount payable on the earlier call date), in 
     the case of a bond described in subsection (a)(1), and
       ``(ii) with reference to the amount payable on maturity or 
     on an earlier call date, in the case of a bond described in 
     subsection (a)(2).''.
       (B) Paragraphs (2) and (3)(B) of section 171(b) are each 
     amended by striking ``paragraph (1)(B)(ii)'' and inserting 
     ``paragraph (1)(B)(i)''.
       (30) Net operating loss carrybacks, carryovers, and 
     carryforwards.--
       (A) Section 172, as amended by section 211(c)(1)(B) of this 
     Act, is amended--
       (i) by striking subparagraphs (D), (H), (I), and (J) of 
     subsection (b)(1) and by redesignating subparagraphs (E), 
     (F), and (G) as subparagraphs (D), (E), and (F), 
     respectively, and

[[Page 16510]]

       (ii) by striking subsections (g) and (j) and by 
     redesignating subsections (h), (i), and (k) as subsections 
     (g), (h), and (i), respectively.
       (B) Each of the following provisions of section 172 (as 
     amended by section 211(c)(1)(B) of this Act and as 
     redesignated by subparagraph (A)) are amended as follows:
       (i) By striking ``ending after August 2, 1989'' in 
     subsection (b)(1)(D)(i)(II).
       (ii) By striking ``subsection (h)'' in subsection 
     (b)(1)(D)(ii) and inserting ``subsection (g)''.
       (iii) By striking ``section 165(h)(3)(C)(i)'' in subsection 
     (b)(1)(E)(ii)(II) and inserting ``section 165(i)(5)''.
       (iv) By striking ``subsection (i)'' and all that follows in 
     the last sentence of subsection (b)(1)(E)(ii) and inserting 
     ``subsection (h)).''.
       (v) By striking ``subsection (i)'' in subsection (b)(1)(F) 
     and inserting ``subsection (h)''.
       (vi) By striking subparagraph (F) of paragraph (2) of 
     subsection (g).
       (vii) By striking ``subsection (b)(1)(E)'' each place it 
     appears in subsection (g)(4) and inserting ``subsection 
     (b)(1)(D)''.
       (viii) By striking the last sentence of subsection (h)(1).
       (ix) By striking ``subsection (b)(1)(G)'' each place it 
     appears in subsection (h)(3) and inserting ``subsection 
     (b)(1)(F)''.
       (C) Subsection (d) of section 56 is amended by striking 
     paragraph (3).
       (D) Paragraph (5) of section 382(l) is amended by striking 
     subparagraph (F) and by redesignating subparagraphs (G) and 
     (H) as subparagraphs (F) and (G), respectively.
       (31) Research and experimental expenditures.--Subparagraph 
     (A) of section 174(a)(2) is amended to read as follows:
       ``(A) Without consent.--A taxpayer may, without the consent 
     of the Secretary, adopt the method provided in this 
     subsection for his first taxable year for which expenditures 
     described in paragraph (1) are paid or incurred.''.
       (32) Amortization of certain research and experimental 
     expenditures.--Paragraph (2) of section 174(b) is amended by 
     striking ``beginning after December 31, 1953''.
       (33) Soil and water conservation expenditures.--Paragraph 
     (1) of section 175(d) is amended to read as follows:
       ``(1) Without consent.--A taxpayer may, without the consent 
     of the Secretary, adopt the method provided in this section 
     for the taxpayer's first taxable year for which expenditures 
     described in subsection (a) are paid or incurred.''.
       (34) Clean-fuel vehicles.--
       (A) Part VI of subchapter A of chapter 1 is amended by 
     striking section 179A (and by striking the item relating to 
     such section in the table of sections for such part).
       (B) Section 30C(e) is amended by adding at the end the 
     following:
       ``(7) Reference.--For purposes of this section, any 
     reference to section 179A shall be treated as a reference to 
     such section as in effect immediately before its repeal.''.
       (C) Section 62(a) is amended by striking paragraph (14).
       (D) Section 263(a)(1) is amended by striking subparagraph 
     (H).
       (E) Section 280F(a)(1) is amended by striking subparagraph 
     (C).
       (F) Section 312(k)(3) is amended by striking ``179A,'' each 
     place it appears.
       (G) Section 1016(a) is amended by striking paragraph (24).
       (H) Section 1245(a) is amended by striking ``179A,'' each 
     place it appears in paragraphs (2)(C) and (3)(C).
       (35) Qualified disaster expenses.--Part VI of subchapter A 
     of chapter 1 is amended by striking section 198A (and by 
     striking the item relating to such section in the table of 
     sections for such part).
       (36) Activities not engaged in for profit.--Section 
     183(e)(1) is amended by striking the last sentence.
       (37) Domestic production activities.--
       (A) Subsection (a) of section 199 is amended--
       (i) by striking paragraph (2),
       (ii) by redesignating subparagraphs (A) and (B) of 
     paragraph (1) as paragraphs (1) and (2), respectively, and by 
     moving paragraphs (1) and (2) (as so redesignated) 2 ems to 
     the left, and
       (iii) by striking ``Allowance of Deduction.--'' and all 
     that follows through ``There shall be allowed'' and inserting 
     the following:
       ``(a) Allowance of Deduction.--There shall be allowed''.
       (B) Paragraphs (2) and (6)(B) of section 199(d) are each 
     amended by striking ``(a)(1)(B)'' and inserting ``(a)(2)''.
       (38) Retirement savings.--
       (A) Subparagraph (A) of section 219(b)(5) is amended to 
     read as follows:
       ``(A) In general.--The deductible amount is $5,000.''.
       (B) Clause (ii) of section 219(b)(5)(B) is amended to read 
     as follows:
       ``(ii) Applicable amount.--For purposes of clause (i), the 
     applicable amount is $1,000.''.
       (C) Paragraph (5) of section 219(b) is amended by striking 
     subparagraph (C) and by redesignating subparagraph (D) as 
     subparagraph (C).
       (D) Clause (ii) of section 219(g)(2)(A) is amended by 
     striking ``for a taxable year beginning after December 31, 
     2006''.
       (E) Section 219(g)(3)(B) is amended by striking clauses (i) 
     and (ii) and inserting the following:
       ``(i) In the case of a taxpayer filing a joint return, 
     $80,000.
       ``(ii) In the case of any other taxpayer (other than a 
     married individual filing a separate return), $50,000.''.
       (F) Paragraph (8) of section 219(g) is amended by striking 
     ``the dollar amount in the last row of the table contained in 
     paragraph (3)(B)(i), the dollar amount in the last row of the 
     table contained in paragraph (3)(B)(ii), and the dollar 
     amount contained in paragraph (7)(A),'' and inserting ``each 
     of the dollar amounts in paragraphs (3)(B)(i), (3)(B)(ii), 
     and (7)(A)''.
       (39) Reports regarding qualified voluntary retirement 
     contributions.--
       (A) Section 219 is amended by striking paragraph (4) of 
     subsection (f) and subsection (h).
       (B) Section 6652 is amended by striking subsection (g).
       (40) Interest on education loans.--Paragraph (1) of section 
     221(b) is amended by striking ``shall not exceed'' and all 
     that follows and inserting ``shall not exceed $2,500.''.
       (41) Dividends received on certain preferred stock; and 
     dividends paid on certain preferred stock of public 
     utilities.--
       (A) Sections 244 and 247 are hereby repealed, and the table 
     of sections for part VIII of subchapter B of chapter 1 is 
     amended by striking the items relating to sections 244 and 
     247.
       (B) Paragraph (5) of section 172(d) is amended to read as 
     follows:
       ``(5) Computation of deduction for dividends received.--The 
     deductions allowed by section 243 (relating to dividends 
     received by corporations) and 245 (relating to dividends 
     received from certain foreign corporations) shall be computed 
     without regard to section 246(b) (relating to limitation on 
     aggregate amount of deductions).''.
       (C) Paragraph (1) of section 243(c) is amended to read as 
     follows:
       ``(1) In general.--In the case of any dividend received 
     from a 20-percent owned corporation, subsection (a)(1) shall 
     be applied by substituting `80 percent' for `70 percent'.''.
       (D) Section 243(d) is amended by striking paragraph (4).
       (E) Section 246 is amended--
       (i) by striking ``, 244,'' in subsection (a)(1),
       (ii) in subsection (b)(1)--

       (I) by striking ``sections 243(a)(1), 244(a),'' and 
     inserting ``section 243(a)(1)'',
       (II) by striking ``244(a),'' the second place it appears, 
     and
       (III) by striking ``subsection (a) or (b) of section 245, 
     and 247,'' and inserting ``and subsection (a) or (b) of 
     section 245,'', and

       (iii) by striking ``, 244,'' in subsection (c)(1).
       (F) Section 246A is amended by striking ``, 244,'' both 
     places it appears in subsections (a) and (e).
       (G) Sections 263(g)(2)(B)(iii), 277(a), 301(e)(2), 
     469(e)(4), 512(a)(3)(A), subparagraphs (A), (C), and (D) of 
     section 805(a)(4), 805(b)(5), 812(e)(2)(A), 
     815(c)(2)(A)(iii), 832(b)(5), 833(b)(3)(E), and 1059(b)(2)(B) 
     are each amended by striking ``, 244,'' each place it 
     appears.
       (H) Section 1244(c)(2)(C) is amended by striking ``244,''.
       (I) Section 805(a)(4)(B) is amended by striking ``, 
     244(a),'' each place it appears.
       (J) Section 810(c)(2)(B) is amended by striking ``244 
     (relating to dividends on certain preferred stock of public 
     utilities),''.
       (K) The amendments made by this paragraph shall not apply 
     to preferred stock issued before October 1, 1942 (determined 
     in the same manner as under section 247 of the Internal 
     Revenue Code of 1986 as in effect before its repeal by such 
     amendments).
       (42) Organization expenses.--Section 248(c) is amended by 
     striking ``beginning after December 31, 1953,'' and by 
     striking the last sentence.
       (43) Bond repurchase premium.--Section 249(b)(1) is amended 
     by striking ``, in the case of bonds or other evidences of 
     indebtedness issued after February 28, 1913,''.
       (44) Amount of gain where loss previously disallowed.--
     Section 267(d) is amended by striking ``(or by reason of 
     section 24(b) of the Internal Revenue Code of 1939)'' in 
     paragraph (1), by striking ``after December 31, 1953,'' in 
     paragraph (2), by striking the second sentence, and by 
     striking ``or by reason of section 118 of the Internal 
     Revenue Code of 1939'' in the last sentence.
       (45) Acquisitions made to evade or avoid income tax.--
     Paragraphs (1) and (2) of section 269(a) are each amended by 
     striking ``or acquired on or after October 8, 1940,''.
       (46) Meals and entertainment.--Paragraph (3) of section 
     274(n) is amended--
       (A) by striking ``(A) In general.--'',
       (B) by striking ``substituting `the applicable percentage' 
     for'' and inserting ``substituting `80 percent' for'', and
       (C) by striking subparagraph (B).
       (47) Interest on indebtedness incurred by corporations to 
     acquire stock or assets of another corporation.--
       (A) Section 279 is amended--
       (i) by striking ``after December 31, 1967,'' in subsection 
     (a)(2),
       (ii) by striking ``after October 9, 1969,'' in subsection 
     (b),
       (iii) by striking ``after October 9, 1969, and'' in 
     subsection (d)(5), and
       (iv) by striking subsection (i) and redesignating 
     subsection (j) as subsection (i).

[[Page 16511]]

       (B) The amendments made by this paragraph shall not--
       (i) apply to obligations issued on or before October 9, 
     1969 (determined in the same manner as under section 279 of 
     the Internal Revenue Code of 1986 as in effect before such 
     amendments), and
       (ii) be construed to require interest on obligations issued 
     on or before December 31, 1967, to be taken into account 
     under section 279(a)(2) of such Code (as in effect after such 
     amendments).
       (48) Bank holding companies.--
       (A) Clause (iii) of section 304(b)(3)(D) is repealed.
       (B) The heading of subparagraph (D) of section 304(b)(3) is 
     amended by striking ``and special rule''.
       (49) Effect on earnings and profits.--Subsection (d) of 
     section 312 is amended by striking paragraph (2) and 
     redesignating paragraph (3) as paragraph (2).
       (50) Disqualified stock.--Paragraph (3) of section 355(d) 
     is amended by striking ``after October 9, 1990, and'' each 
     place it appears.
       (51) Basis to corporations.--Section 362 is amended by 
     striking ``on or after June 22, 1954'' in subsection (a) and 
     by striking ``, on or after June 22, 1954,'' each place it 
     appears in subsection (c).
       (52) Temporary waiver of minimum required distribution.--
     Section 401(a)(9) is amended by striking subparagraph (H).
       (53) Individual retirement accounts.--Clause (i) of section 
     408(p)(2)(E) is amended to read as follows:
       ``(i) In general.--For purposes of subparagraph (A)(ii), 
     the applicable amount is $10,000.''.
       (54) Tax credit employee stock ownership plans.--Section 
     409 is amended by striking subsection (q).
       (55) Catch-up contributions.--Clauses (i) and (ii) of 
     section 414(v)(2)(B) are amended to read as follows:
       ``(i) In the case of an applicable employer plan other than 
     a plan described in section 401(k)(11) or 408(p), the 
     applicable dollar amount is $5,000.
       ``(ii) In the case of an applicable employer plan described 
     in section 401(k)(11) or 408(p), the applicable dollar amount 
     is $2,500.''.
       (56) Employee stock purchase plans.--Section 423(a) is 
     amended by striking ``after December 31, 1963,''.
       (57) Pension related transition rules.--
       (A) Section 402(g)(1)(B) is amended by striking ``shall 
     be'' and all that follows and inserting ``is $15,000.''.
       (B)(i) Subparagraph (D) of section 417(e)(3) is amended--
       (I) by striking clauses (ii) and (iii),
       (II) by striking ``if--'' and all that follows through 
     ``section 430(h)(2)(D)'' and inserting ``if section 
     430(h)(2)(D)'', and
       (III) by striking ``described in such section,'' and 
     inserting ``described in such section.''.
       (ii) Clause (iii) of section 205(g)(3)(B) of the Employee 
     Retirement Income Security Act of 1974 (29 U.S.C. 
     1055(g)(3)(B)) is amended--
       (I) by striking subclauses (II) and (III),
       (II) by striking ``if--'' and all that follows through 
     ``section 303(h)(2)(D)'' and inserting ``if section 
     303(h)(2)(D)'', and
       (III) by striking ``described in such section,'' and 
     inserting ``described in such section.''.
       (C)(i) Paragraph (5) of section 430(c) is amended by 
     striking subparagraph (B) and by striking ``(A) In general.--
     ''.
       (ii) Paragraph (5) of section 303(c) of the Employee 
     Retirement Income Security Act of 1974 (29 U.S.C. 1083(c)) is 
     amended by striking subparagraph (B) and by striking ``(A) In 
     general.--''.
       (D)(i) Paragraph (2) of section 430(h) is amended by 
     striking subparagraph (G).
       (ii) Paragraph (2) of section 303(h) of the Employee 
     Retirement Income Security Act of 1974 (29 U.S.C. 1083(h)) is 
     amended by striking subparagraph (G).
       (E)(i) Paragraph (3) of section 436(j), as added by section 
     113(a)(1)(B) of the Pension Protection Act of 2006, is 
     amended by striking subparagraphs (B) and (C) and by striking 
     ``(A) In general.--''.
       (ii) Subparagraph (C) of section 206(g)(9) of the Employee 
     Retirement Income Security Act of 1974 (29 U.S.C. 1056(g)(9)) 
     is amended by striking clauses (ii) and (iii) and by striking 
     ``(i) In general.--''.
       (F)(i) Section 436(j) is amended by striking the paragraph 
     (3) added by section 203(a)(2) of the Preservation of Access 
     to Care for Medicare Beneficiaries and Pension Relief Act of 
     2010.
       (ii) Section 206(g)(9) of the Employee Retirement Income 
     Security Act of 1974 (29 U.S.C. 1056(g)(9)) is amended by 
     striking subparagraph (D).
       (G)(i) Section 436 is amended by striking subsection (m).
       (ii) Section 206(g) of the Employee Retirement Income 
     Security Act of 1974 (29 U.S.C. 1056(g)) is amended by 
     striking paragraph (11).
       (H) Section 457(e)(15)(A) is amended by striking ``shall 
     be'' and all that follows and inserting ``is $15,000.''.
       (58) Limitation on deductions for certain farming.--
       (A) Section 464 is amended by striking ``any farming 
     syndicate (as defined in subsection (c))'' both places it 
     appears in subsections (a) and (b) and inserting ``any 
     taxpayer to whom subsection (d) applies''.
       (B)(i) Subsection (c) of section 464 is hereby moved to the 
     end of section 461 and redesignated as subsection (j).
       (ii) Such subsection (j) is amended--
       (I) by striking ``For purposes of this section'' in 
     paragraph (1) and inserting ``For purposes of subsection 
     (i)(4)'', and
       (II) by adding at the end the following new paragraphs:
       ``(3) Farming.--For purposes of this subsection, the term 
     `farming' has the meaning given to such term by section 
     464(e).
       ``(4) Limited entrepreneur.--For purposes of this 
     subsection, the term `limited entrepreneur' means a person 
     who--
       ``(A) has an interest in an enterprise other than as a 
     limited partner, and
       ``(B) does not actively participate in the management of 
     such enterprise.''.
       (iii) Paragraph (4) of section 461(i) is amended by 
     striking ``section 464(c)'' and inserting ``subsection (j)''.
       (C) Section 464 is amended--
       (i) by striking subsections (e) and (g) and redesignating 
     subsections (d) and (f) as subsections (c) and (d), 
     respectively, and
       (ii) by adding at the end the following new subsection:
       ``(e) Farming.--For purposes of this section, the term 
     `farming' means the cultivation of land or the raising or 
     harvesting of any agricultural or horticultural commodity 
     including the raising, shearing, feeding, caring for, 
     training, and management of animals. For purposes of the 
     preceding sentence, trees (other than trees bearing fruit or 
     nuts) shall not be treated as an agricultural or 
     horticultural commodity.''.
       (D) Subsection (d) of section 464 of such Code (as 
     redesignated by subparagraph (C)) is amended--
       (i) by striking paragraph (1) and redesignating paragraphs 
     (2), (3), and (4) as paragraphs (1), (2), and (3), 
     respectively, and
       (ii) by striking ``Subsections (a) and (b) to Apply to'' in 
     the heading.
       (E) Subparagraph (A) of section 58(a)(2) is amended by 
     striking ``section 464(c)'' and inserting ``section 461(j)''.
       (59) Deductions limited to amount at risk.--Subparagraph 
     (A) of section 465(c)(3) is amended by striking ``In the case 
     of taxable years beginning after December 31, 1978, this'' 
     and inserting ``This''.
       (60) Passive activity losses and credits limited.--
       (A) Section 469 is amended by striking subsection (m).
       (B) Subsection (b) of section 58 is amended by adding 
     ``and'' at the end of paragraph (1), by striking paragraph 
     (2), and by redesignating paragraph (3) as paragraph (2).
       (61) Adjustments required by changes in method of 
     accounting.--Section 481(b)(3) is amended by striking 
     subparagraph (C).
       (62) Exemption from tax on corporations, certain trusts, 
     etc.--Section 501 is amended by striking subsection (s).
       (63) Requirements for exemption.--
       (A) Section 503(a)(1) is amended to read as follows:
       ``(1) General rule.--An organization described in paragraph 
     (17) or (18) of section 501(c), or described in section 
     401(a) and referred to in section 4975(g) (2) or (3), shall 
     not be exempt from taxation under section 501(a) if it has 
     engaged in a prohibited transaction.''.
       (B) Paragraph (2) of section 503(a) is amended by striking 
     ``described in section 501(c)(17) or (18) or paragraph 
     (a)(1)(B)'' and inserting ``described in paragraph (1)''.
       (C) Subsection (c) of section 503 is amended by striking 
     ``described in section 501(c)(17) or (18) or subsection 
     (a)(1)(B)'' and inserting ``described in subsection (a)(1)''.
       (64) Accumulated taxable income.--Paragraph (1) of section 
     535(b) and paragraph (1) of section 545(b) are each amended 
     by striking ``section 531'' and all that follows and 
     inserting ``section 531 or the personal holding company tax 
     imposed by section 541.''.
       (65) Definition of property.--Subsection (b) of section 614 
     is amended--
       (A) by striking paragraphs (3)(C) and (5), and
       (B) in paragraph (4), by striking ``whichever of the 
     following years is later: The first taxable year beginning 
     after December 31, 1963, or''.
       (66) Amounts received by surviving annuitant under joint 
     and survivor annuity contract.--Subparagraph (A) of section 
     691(d)(1) is amended by striking ``after December 31, 1953, 
     and''.
       (67) Income taxes of members of armed forces on death.--
     Section 692(a)(1) is amended by striking ``after June 24, 
     1950''.
       (68) Special rules for computing reserves.--Paragraph (7) 
     of section 807(e) is amended by striking subparagraph (B) and 
     redesignating subparagraph (C) as subparagraph (B).
       (69) Insurance company taxable income.--
       (A) Section 832(e) is amended by striking ``of taxable 
     years beginning after December 31, 1966,''.
       (B) Section 832(e)(6) is amended by striking ``In the case 
     of any taxable year beginning after December 31, 1970, the'' 
     and inserting ``The''.
       (70) Capitalization of certain policy acquisition 
     expenses.--Section 848 is amended by striking subsection (j).

[[Page 16512]]

       (71) Tax on nonresident alien individuals.--Subparagraph 
     (B) of section 871(a)(1) is amended to read as follows:
       ``(B) gains described in subsection (b) or (c) of section 
     631,''.
       (72) Limitation on credit.--Paragraph (2) of section 904(d) 
     is amended by striking subparagraph (J).
       (73) Foreign earned income.--Clause (i) of section 
     911(b)(2)(D) is amended to read as follows:
       ``(i) In general.--The exclusion amount for any calendar 
     year is $80,000.''.
       (74) Basis of property acquired from decedent.--
       (A) Section 1014(a)(2) is amended to read as follows:
       ``(2) in the case of an election under section 2032, its 
     value at the applicable valuation date prescribed by such 
     section,''.
       (B) Section 1014(b) is amended by striking paragraphs (7) 
     and (8).
       (75) Adjusted basis.--Section 1016(a) is amended by 
     striking paragraph (12).
       (76) Property on which lessee has made improvements.--
     Section 1019 is amended by striking the last sentence.
       (77) Involuntary conversion.--Section 1033 is amended by 
     striking subsection (j) and by redesignating subsections (k) 
     and (l) as subsections (j) and (k), respectively.
       (78) Property acquired during affiliation.--Section 1051 is 
     hereby repealed, and the table of sections for part IV of 
     subchapter O of chapter 1 is amended by striking the item 
     relating to section 1051.
       (79) Capital gains and losses.--Section 1222 is amended by 
     striking the last sentence.
       (80) Holding period of property.--
       (A) Paragraph (1) of section 1223 is amended by striking 
     ``after March 1, 1954,''.
       (B) Paragraph (4) of section 1223 is amended by striking 
     ```(or under so much of section 1052(c) as refers to section 
     113(a)(23) of the Internal Revenue Code of 1939)'''.
       (C) Paragraphs (6) and (8) of section 1223 are repealed.
       (81) Property used in the trade or business and involuntary 
     conversions.--Subparagraph (A) of section 1231(c)(2) is 
     amended by striking ``beginning after December 31, 1981''.
       (82) Sale or exchange of patents.--Section 1235 is 
     amended--
       (A) by striking subsection (c) and by redesignating 
     subsections (d) and (e) as subsections (c) and (d), 
     respectively, and
       (B) by striking ``subsection (d)'' in subsection (b)(2)(B) 
     and inserting ``subsection (c)''.
       (83) Dealers in securities.--Subsection (b) of section 1236 
     is amended by striking ``after November 19, 1951,''.
       (84) Sale of patents.--Subsection (a) of section 1249 is 
     amended by striking ``after December 31, 1962,''.
       (85) Gain from disposition of farmland.--Paragraph (1) of 
     section 1252(a) is amended--
       (A) by striking ``after December 31, 1969'' the first place 
     it appears, and
       (B) by striking ``after December 31, 1969,'' in 
     subparagraph (A).
       (86) Treatment of amounts received on retirement or sale or 
     exchange of debt instruments.--Subsection (c) of section 1271 
     is amended to read as follows:
       ``(c) Special Rule for Certain Obligations With Respect to 
     Which Original Issue Discount Not Currently Includible.--
       ``(1) In general.--On the sale or exchange of debt 
     instruments issued by a government or political subdivision 
     thereof after December 31, 1954, and before July 2, 1982, or 
     by a corporation after December 31, 1954, and on or before 
     May 27, 1969, any gain realized which does not exceed--
       ``(A) an amount equal to the original issue discount, or
       ``(B) if at the time of original issue there was no 
     intention to call the debt instrument before maturity, an 
     amount which bears the same ratio to the original issue 
     discount as the number of complete months that the debt 
     instrument was held by the taxpayer bears to the number of 
     complete months from the date of original issue to the date 
     of maturity, shall be considered as ordinary income.
       ``(2) Subsection (a)(2)(A) not to apply.--Subsection 
     (a)(2)(A) shall not apply to any debt instrument referred to 
     in paragraph (1) of this subsection.
       ``(3) Cross reference.--For current inclusion of original 
     issue discount, see section 1272.''.
       (87) Amount and method of adjustment.--Section 1314 is 
     amended by striking subsection (d) and by redesignating 
     subsection (e) as subsection (d).
       (88) Election; revocation; termination.--Clause (iii) of 
     section 1362(d)(3)(A) is amended by striking ``unless'' and 
     all that follows and inserting ``unless the corporation was 
     an S corporation for such taxable year.''.
       (89) Old-age, survivors, and disability insurance.--
     Subsection (a) of section 1401 is amended by striking ``the 
     following percent'' and all that follows and inserting ``12.4 
     percent of the amount of the self-employment income for such 
     taxable year.''.
       (90) Hospital insurance.--Paragraph (1) of section 1401(b) 
     is amended by striking: ``the following percent'' and all 
     that follows and inserting ``2.9 percent of the amount of the 
     self-employment income for such taxable year.''.
       (91) Ministers, members of religious orders, and christian 
     science practitioners.--Paragraph (3) of section 1402(e) is 
     amended--
       (A) by striking ``whichever of the following dates is 
     later: (A)'', and
       (B) by striking ``;or (B)''' and all that follows and 
     inserting a period.
       (92) Withholding of tax on nonresident aliens.--The first 
     sentence of subsection (b) of section 1441 and the first 
     sentence of paragraph (5) of section 1441(c) are each amended 
     by striking ``gains subject to tax'' and all that follows 
     through ``October 4, 1966'' and inserting ``and gains subject 
     to tax under section 871(a)(1)(D)''.
       (93) Affiliated group defined.--Subparagraph (A) of section 
     1504(a)(3) is amended by striking ``for a taxable year which 
     includes any period after December 31, 1984'' in clause (i) 
     and by striking ``in a taxable year beginning after December 
     31, 1984'' in clause (ii).
       (94) Disallowance of the benefits of the graduated 
     corporate rates and accumulated earnings credit.--
       (A) Subsection (a) of section 1551 is amended--
       (i) by striking paragraph (1) and by redesignating 
     paragraphs (2) and (3) as paragraphs (1) and (2), 
     respectively, and
       (ii) by striking ``after June 12, 1963,'' each place it 
     appears.
       (B) Section 1551(b) is amended--
       (i) by striking ``or (2)'' in paragraph (1), and
       (ii) by striking ``(a)(3)'' in paragraph (2) and inserting 
     ``(a)(2)''.
       (95) Credit for state death taxes.--
       (A)(i) Part II of subchapter A of chapter 11 is amended by 
     striking section 2011 (and by striking the item relating to 
     such section in the table of sections for such subpart).
       (ii) Section 2106(a)(4) is amended by striking ``section 
     2011(a)'' and inserting ``2058(a)''.
       (B)(i) Subchapter A of chapter 13 is amended by striking 
     section 2604 (and by striking the item relating to such 
     section in the table of sections for such subpart).
       (ii) Clause (ii) of section 164(b)(4)(A) is amended by 
     inserting ``(as in effect before its repeal)'' after 
     ``section 2604''.
       (iii) Section 2654(a)(1) is amended by striking ``(computed 
     without regard to section 2604)''.
       (96) Gross estate.--Subsection (c) of section 2031 is 
     amended by striking paragraph (3) and by amending paragraph 
     (1)(B) to read as follows:
       ``(II) $500,000.''.
       (97)(A) Part IV of subchapter A of chapter 11 is amended by 
     striking section 2057 (and by striking the item relating to 
     such section in the table of sections for such subpart).
       (B) Paragraph (10) of section 2031(c) is amended by 
     inserting ``(as in effect before its repeal)'' immediately 
     before the period at the end thereof.
       (98) Property within the united states.--Subsection (c) of 
     section 2104 is amended by striking ``With respect to estates 
     of decedents dying after December 31, 1969, deposits'' and 
     inserting ``Deposits''.
       (99) FICA taxes.--
       (A) Subsection (a) of section 3101 is amended by striking 
     ``the following percentages'' and all that follows and 
     inserting ``6.2 percent of the wages (as defined in section 
     3121(a)) received by the individual with respect to 
     employment (as defined in section 3121(b))''.
       (B)(i) Subsection (a) of section 3111 is amended by 
     striking ``the following percentages'' and all that follows 
     and inserting ``6.2 percent of the wages (as defined in 
     section 3121(a)) paid by the employer with respect to 
     employment (as defined in section 3121(b)).''.
       (ii) Subsection (b) of section 3111 is amended by striking 
     ``the following percentages'' and all that follows and 
     inserting ``1.45 percent of the wages (as defined in section 
     3121(a)) paid by the employer with respect to employment (as 
     defined in section 3121(b)).''.
       (C)(i) Section 3121(b) is amended by striking paragraph 
     (17).
       (ii) Section 210(a) of the Social Security Act is amended 
     by striking paragraph (17).
       (100) Railroad retirement.--
       (A) Subsection (b) of section 3201 is amended to read as 
     follows:
       ``(b) Tier 2 Tax.--In addition to other taxes, there is 
     hereby imposed on the income of each employee a tax equal to 
     the percentage determined under section 3241 for any calendar 
     year of the compensation received during such calendar year 
     by such employee for services rendered by such employee.''.
       (B) Subsection (b) of section 3211 is amended to read as 
     follows:
       ``(b) Tier 2 Tax.--In addition to other taxes, there is 
     hereby imposed on the income of each employee representative 
     a tax equal to the percentage determined under section 3241 
     for any calendar year of the compensation received during 
     such calendar year by such employee representative for 
     services rendered by such employee representative.''.
       (C) Subsection (b) of section 3221 is amended to read as 
     follows:
       ``(b) Tier 2 Tax.--In addition to other taxes, there is 
     hereby imposed on every employer an excise tax, with respect 
     to having individuals in his employ, equal to the percentage 
     determined under section 3241 for any calendar year of the 
     compensation paid

[[Page 16513]]

     during such calendar year by such employer for services 
     rendered to such employer.''.
       (D) Subsection (b) of section 3231 is amended--
       (i) by striking ``compensation; except'' and all that 
     follows in the first sentence and inserting 
     ``compensation.'', and
       (ii) by striking the second sentence.
       (101) Credits against federal unemployment tax.--
       (A) Paragraph (4) of section 3302(f) is amended--
       (i) by striking ``subsection--'' and all that follows 
     through ``(A) In general.--The'' and inserting ``subsection, 
     the'',
       (ii) by striking subparagraph (B),
       (iii) by redesignating clauses (i) and (ii) as 
     subparagraphs (A) and (B), respectively, and
       (iv) by moving the text of such subparagraphs (as so 
     redesignated) 2 ems to the left.
       (B) Paragraph (5) of section 3302(f) is amended by striking 
     subparagraph (D) and by redesignating subparagraph (E) as 
     subparagraph (D).
       (102) Domestic service employment taxes.--Section 3510(b) 
     is amended by striking paragraph (4).
       (103) Luxury passenger automobiles.--
       (A) Chapter 31 is amended by striking subchapter A (and by 
     striking the item relating to such subchapter in the table of 
     subchapters for such chapter).
       (B)(i) Section 4221 is amended--
       (I) in subsections (a) and (d)(1), by striking ``subchapter 
     A or'' and inserting ``subchapter'',
       (II) in subsection (a), by striking ``In the case of taxes 
     imposed by subchapter A of chapter 31, paragraphs (1), (3), 
     (4), and (5) shall not apply.'', and
       (III) in subsection (c), by striking ``4001(c), 4001(d), 
     or''.
       (ii) Section 4222 is amended by striking ``4001(c), 
     4001(d),''.
       (iii) Section 4293 is amended by striking ``subchapter A of 
     chapter 31,''.
       (104) Transportation by air.--Section 4261(e) is amended--
       (A) in paragraph (1), by striking subparagraph (C), and
       (B) by striking paragraph (5).
       (105) Taxes on failure to distribute income.--
       (A) Subsection (g) of section 4942 is amended by striking 
     ``For all taxable years beginning on or after January 1, 
     1975, subject'' in paragraph (2)(A) and inserting 
     ``Subject''.
       (B) Section 4942(i)(2) is amended by striking ``beginning 
     after December 31, 1969, and''.
       (106) Taxes on taxable expenditures.--Section 4945(f) is 
     amended by striking ``(excluding therefrom any preceding 
     taxable year which begins before January 1, 1970)''.
       (107) Definitions and special rules.--Section 4682(h) is 
     amended--
       (A) by striking paragraph (1) and redesignating paragraphs 
     (2), (3), and (4) as paragraphs (1), (2), and (3), 
     respectively, and
       (B) in paragraph (1) (as so redesignated)--
       (i) by striking the heading and inserting ``In general'', 
     and
       (ii) by striking ``after 1991'' in subparagraph (C).
       (108) Returns.--Subsection (a) of section 6039D is amended 
     by striking ``beginning after December 31, 1984,''.
       (109) Information returns.--Subsection (c) of section 6060 
     is amended by striking ```year''' and all that follows and 
     inserting ``year.''.
       (110) Collection.--Section 6302 is amended--
       (A) in subsection (e)(2), by striking ``imposed by'' and 
     all that follows through ``with respect to'' and inserting 
     ``imposed by sections 4251, 4261, or 4271 with respect to'',
       (B) by striking the last sentence of subsection (f)(1), and
       (C) in subsection (h)--
       (i) by striking paragraph (2) and redesignating paragraphs 
     (3) and (4) as paragraphs (2) and (3), respectively, and
       (ii) by amending paragraph (3) (as so redesignated) to read 
     as follows:
       ``(3) Coordination with other electronic fund transfer 
     requirements.--Under regulations, any tax required to be paid 
     by electronic fund transfer under section 5061(e) or 5703(b) 
     shall be paid in such a manner as to ensure that the 
     requirements of the second sentence of paragraph (1)(A) of 
     this subsection are satisfied.''.
       (111) Abatements.--Section 6404(f) is amended by striking 
     paragraph (3).
       (112) 2008 recovery rebate for individuals.--
       (A) Subchapter B of chapter 65 is amended by striking 
     section 6428 (and by striking the item relating to such 
     section in the table of sections for such subchapter).
       (B) Subparagraph (A) of section 6211(b)(4) is amended by 
     striking ``6428,''.
       (C) Paragraph (2) of section 6213(g), as amended by section 
     214(a)(2) of this Act and paragraphs (4) and (5)(C) of this 
     subsection, is amended by striking subparagraph (Q), by 
     redesignating subparagraph (O) as subparagraph (N), by 
     inserting ``and'' at the end of subparagraph (M), and by 
     striking the comma at the end of subparagraph (N) (as so 
     redesignated) and inserting a period.
       (D) Paragraph (2) of section 1324(b) of title 31, United 
     States Code, is amended by striking ``6428, or 6431,'' and 
     inserting ``or 6431''.
       (113) Advance payment of portion of increased child credit 
     for 2003.--Subchapter B of chapter 65 is amended by striking 
     section 6429 (and by striking the item relating to such 
     section in the table of sections for such subchapter).
       (114) Failure by corporation to pay estimated income tax.--
     Clause (i) of section 6655(g)(4)(A) is amended by striking 
     ``(or the corresponding provisions of prior law)''.
       (115) Retirement.--Section 7447(i)(3)(B)(ii) is amended by 
     striking ``at 4 percent per annum to December 31, 1947, and 3 
     percent per annum thereafter'', and inserting ``at 3 percent 
     per annum''.
       (116) Annuities to surviving spouses and dependent children 
     of judges.--
       (A) Paragraph (2) of section 7448(a) is amended--
       (i) by striking ``or under section 1106 of the Internal 
     Revenue Code of 1939'', and
       (ii) by striking ``or pursuant to section 1106(d) of the 
     Internal Revenue Code of 1939''.
       (B) Subsection (g) of section 7448 is amended by striking 
     ``or other than pursuant to section 1106 of the Internal 
     Revenue Code of 1939''.
       (C) Subsections (g), (j)(1), and (j)(2) of section 7448 are 
     each amended by striking ``at 4 percent per annum to December 
     31, 1947, and 3 percent per annum thereafter'' and inserting 
     ``at 3 percent per annum''.
       (117) Merchant marine capital construction funds.--
     Paragraph (4) of section 7518(g) is amended by striking ``any 
     nonqualified withdrawal'' and all that follows through 
     ```shall be determined'' and inserting ``any nonqualified 
     withdrawal shall be determined''.
       (118) Valuation tables.--
       (A) Subsection (c) of section 7520 is amended by striking 
     paragraph (2) and redesignating paragraph (3) as paragraph 
     (2).
       (B) Paragraph (2) of section 7520(c) (as redesignated by 
     subparagraph (A)) is amended--
       (i) by striking ``Not later than December 31, 1989, the'' 
     and inserting ``The'', and
       (ii) by striking ``thereafter'' in the last sentence 
     thereof.
       (119) Definition of employee.--Section 7701(a)(20) is 
     amended by striking ``chapter 21'' and all that follows and 
     inserting ``chapter 21.''.
       (b) Effective Date.--
       (1) General rule.--Except as otherwise provided in 
     subsection (a) or paragraph (2) of this subsection, the 
     amendments made by this section shall take effect on the date 
     of enactment of this Act.
       (2) Savings provision.--If--
       (A) any provision amended or repealed by the amendments 
     made by this section applied to--
       (i) any transaction occurring before the date of the 
     enactment of this Act,
       (ii) any property acquired before such date of enactment, 
     or
       (iii) any item of income, loss, deduction, or credit taken 
     into account before such date of enactment, and
       (B) the treatment of such transaction, property, or item 
     under such provision would (without regard to the amendments 
     or repeals made by this section) affect the liability for tax 
     for periods ending after date of enactment, nothing in the 
     amendments or repeals made by this section shall be construed 
     to affect the treatment of such transaction, property, or 
     item for purposes of determining liability for tax for 
     periods ending after such date of enactment.

                 TITLE III--JOINT COMMITTEE ON TAXATION

     SEC. 301. INCREASED REFUND AND CREDIT THRESHOLD FOR JOINT 
                   COMMITTEE ON TAXATION REVIEW OF C CORPORATION 
                   RETURN.

       (a) In General.--Subsections (a) and (b) of section 6405 
     are each amended by inserting ``($5,000,000 in the case of a 
     C corporation)'' after ``$2,000,000''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect on the date of the enactment of this Act, 
     except that such amendment shall not apply with respect to 
     any refund or credit with respect to a report that has been 
     made before such date under section 6405 of the Internal 
     Revenue Code of 1986.

                      TITLE IV--BUDGETARY EFFECTS

     SEC. 401. BUDGETARY EFFECTS.

       (a) Paygo Scorecard.--The budgetary effects of this Act 
     shall not be entered on either PAYGO scorecard maintained 
     pursuant to section 4(d) of the Statutory Pay-As-You-Go Act 
     of 2010.
       (b) Senate Paygo Scorecard.--The budgetary effects of this 
     Act shall not be entered on any PAYGO scorecard maintained 
     for purposes of section 201 of S. Con. Res. 21 (110th 
     Congress).

  The SPEAKER pro tempore. The gentleman from Michigan (Mr. Camp) and 
the gentleman from Michigan (Mr. Levin) each will control 30 minutes.
  The Chair recognizes the gentleman from Michigan (Mr. Camp).


                             General Leave

  Mr. CAMP. Mr. Speaker, I ask unanimous consent that all Members have 
5 legislative days in which to revise and extend their remarks and to 
include extraneous material on H.R. 5771.

[[Page 16514]]

  The SPEAKER pro tempore. Is there objection to the request of the 
gentleman from Michigan?
  There was no objection.
  Mr. CAMP. Mr. Speaker, I yield myself such time as I may consume.
  As we all know, there is a series of tax provisions that routinely 
expire that Congress must then renew, typically extending them for 1 
year retroactively and 1 year prospectively. Congress routinely extends 
these policies without offsetting the revenue loss.
  This on again-off again style of legislating on a temporary basis is 
a terrible way to make tax policy. We are the only Nation in the world 
that lets large pieces of its Tax Code expire.
  Hard-working taxpayers deserve to know whether these tax policies are 
going to be there year in and year out on a permanent basis. Temporary 
renewals cannot provide the certainty that American businesses need in 
order to make the best decisions about how to invest in cutting-edge 
research, whether to buy new pieces of equipment, and most importantly, 
whether to hire that additional worker. These temporary renewals mean 
uncertainty for families as well as they try to plan their family 
budgets.
  Throughout the year, the Ways and Means Committee has produced 
legislation that carefully examined many of these temporary extenders 
and reformed and made permanent several of the most important ones. The 
whole House on a bipartisan basis later passed this legislation.
  This included important policies such as a permanent and improved 
credit for research and development and permanently higher section 179 
expensing levels for small businesses--policies that were also included 
in the President's budget proposals.
  Analysis by the nonpartisan experts at the Joint Committee on 
Taxation confirmed that permanent extensions of these policies would 
result in companies spending more on R&D and making new investments, 
all of which would promote job creation and higher wages.
  Having passed a number of these policies through the House on a 
bipartisan basis, we proceeded with the rather old-fashioned approach 
of beginning bipartisan negotiations with the Senate.

                              {time}  1615

  Until last week, we were making significant progress in those 
negotiations as everyone involved worked in good faith to reach a 
successful conclusion. We were close to reaching an agreement that 
would ensure that many of the bills that passed the House on a 
bipartisan basis would be included.
  In addition, we were going beyond the list of traditional tax 
extenders and including additional policies designed specifically to 
assist low- and middle-income American families, in particular, 
policies such as the American Opportunity Tax Credit, which helps low- 
and middle-income families afford college, which was also included in 
the President's budget proposals. Other policies included making 
permanent the deduction for State and local sales taxes and the tax 
rules for mass transit benefits.
  However, before these negotiations could conclude, the administration 
took the unbelievable step of issuing a veto threat. The President 
issued a veto threat over bipartisan, bicameral negotiations.
  Now, I can't tell you with certainty exactly what the administration 
wants because the administration has not even bothered to reach out and 
tell us what the President's priorities are; rather than trying to 
engage and work with Congress, the administration is only communicating 
through press statements.
  The President has often said that he wants to work with Congress to 
find bipartisan solutions. In fact, in his press conference after the 
election, the President said:

       I am eager to work with the new Congress to make the next 2 
     years as productive as possible. I am committed to making 
     sure that I measure ideas not by whether they are from 
     Democrats or Republicans, but whether they work for the 
     American people.

  That statement is completely at odds with the President's actions 
last week, and we all know that actions speak louder than words. As a 
result of the administration's actions, negotiations with the Senate 
have come to a standstill.
  Inexplicably, the administration and some Senate Democrats have taken 
the position that policies that promote savings, investment, charitable 
donations, and job creation are a ``giveaway'' to big corporations.
  These Senators and the administration should listen to the 1,032 
charitable organizations that have written to every Member of Congress 
in support of the permanent tax incentives for charitable giving that 
would have been included in the agreement with the Senate. I don't 
think that policies that promote donations to food banks, homeless 
shelters, and hospitals are giveaways to corporate America.
  The administration's actions now force us to take a different and 
less effective approach. With the end of the year and a new tax filing 
season rapidly approaching, we need to act. The IRS has been clear, 
unless Congress acts quickly, it will be forced to delay the start of 
the tax filing season.
  American families are struggling to make ends meet as wages remain 
flat, even as expenses increase. These families can't and should not 
face a delay in getting their tax refund.
  The legislation before us today will address the concerns raised by 
the IRS and ensure the tax filing season can open on time. We should 
ensure that the President's actions do not hurt hardworking taxpayers 
who are counting on that tax refund; therefore, I urge the House to 
pass this legislation and ensure that the tax filing season opens on 
time.
  I reserve the balance of my time.
  Mr. LEVIN. Mr. Speaker, I yield myself such time as I may consume.
  This legislation is crucial as much for what it avoids as what it 
accomplishes. A 1-year extension avoids the dangerous plan pushed by 
House Republicans for much of this last year to make permanent a select 
number of provisions at a cost of nearly $1 trillion.
  That plan was not only fiscally irresponsible, it also left many 
provisions behind that are vital to working families and small 
businesses, including the exclusion for mortgage debt forgiveness, new 
market tax credits, continuations of the expansions to the earned 
income tax credit, and the refundable portion of the child tax credit.
  This bill also avoids an almost equally harmful proposal under 
consideration last week that would have permanently extended a select 
group of expiring provisions and would also have given permanent breaks 
to a relative few while costing more than $400 billion and leaving out 
critical provisions that help working families.
  I actively and publicly opposed that proposal. Fortunately, it 
generated a veto threat from the President.
  The provisions in today's extender bill need more serious 
consideration than would have been provided in that proposal both as to 
substance, whether they contribute to economic growth and jobs, and how 
they fit into the need for both equity and fiscal responsibility.
  Some of the extender provisions have contributed to economic growth, 
such as the provisions for R&D, promoting development of renewable 
energy, encouraging development of small business, and increasing 
educational opportunity. Others should not be part of any permanent 
action, such as bonus depreciation, which was always contemplated as a 
temporary measure to stimulate economic growth and activity.
  Some of the provisions in tax extenders should end, and others need 
to be addressed as we make better sense of the international tax 
structure, including closing tax loopholes. While I did not agree with 
many of the provisions of the tax reform proposal of the chairman, he 
did attempt to address issues in a more comprehensive way, unlike what 
was passed through the House up to $1 trillion and was attempted last 
week.
  It was a serious mistake, as I said, for the Republicans to have 
taken pieces of it, trying to make them permanent without paying a dime 
to offset the more than $800 billion cost of doing so.

[[Page 16515]]

  The bill today, therefore, only maintains the status quo for this 
year. Not to act would disrupt the coming tax filing season for 
millions of American workers and businesses which have relied on 
Congress to extend these provisions and will, in a matter of weeks, 
begin filing their 2014 tax returns. As a result, I will support this 
measure.
  As we act in the future, including on tax reform, I believe the 
lesson that should be learned from the past is that it is critical to 
try to work on a bipartisan basis, recognizing the importance of 
maintaining support for the values that must underpin legislative 
action.
  I reserve the balance of my time.
  Mr. CAMP. Mr. Speaker, I yield myself such time as I may consume.
  I do want to thank my friend from Michigan for his support of this 
legislation before us today. It is something that we do need to do. We 
cannot allow these provisions to be expired for all of 2014, but I 
would say that, if you look around, we are not seeing the kind of 
growth and opportunity that we should see in America. We are not seeing 
the kind of job creation, we are not seeing the kind of income 
increases; yet expenses are going up for families.
  The items that the gentleman talked about, whether it was research 
and development or section 179 or the American Opportunity Tax Credit, 
all of those were going to be permanent in the package that we were 
working on, and even the mortgage debt forgiveness for those who are 
selling their homes and their mortgages were underwater, we were 
extending that for 2 years, so there were a lot of things for families.
  Certainly, the charitable provisions for food banks and for 
charitable giving, those would certainly help middle class Americans as 
well.
  The reason why I think it is important to get permanent policy is 
that we haven't seen the kind of growth that we need to see, and the 
more of these items that we can make permanent, the more stability we 
have, the more likely it is that employers and individuals and families 
are going to make the kind of long-term decisions that will cause our 
economy to grow.
  It is not just me saying this; it is the nonpartisan Joint Committee 
on Taxation that says permanent policies such as these, as we were 
working on, are the kinds of things that the country needs to do to 
grow.
  Again, I want to thank him for his support of the legislation. 
Hopefully, in the future, we will be able to get at some of these 
issues in a more permanent way, so that we don't have this unusual 
system where we have had all of these policies expired for all of 2014 
and, in the final 2 weeks, we are going to retroactively put them into 
place for the final weeks of the year, so that when people file in 
April, they will be able to take advantage of these items. We should 
really do this on a more regular basis.
  I reserve the balance of my time.
  Mr. LEVIN. Mr. Speaker, I yield myself 1 minute.
  Look, you made provisions permanent, Mr. Chairman, and you paid for 
them in your bill. There is disagreement how you paid for them, but you 
paid for them, and then you come forth with up to $1 trillion permanent 
unpaid for and leave out the child tax credit and the EITC.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. LEVIN. I yield myself an additional 1 minute.
  Then we hear last week a proposal for $400 billion of it unpaid for, 
permanent--unpaid for, permanent--leaving out the EITC and the child 
tax credit, so that is why the President acted, and that is why it was 
essential he act.
  The SPEAKER pro tempore. Members are reminded to address their 
remarks to the Chair and not to other Members in the second person.
  Mr. LEVIN. I now yield 4 minutes to the distinguished gentleman from 
Maryland (Mr. Hoyer).
  Mr. HOYER. Mr. Speaker, I thank Chairman Camp for his courage. I am 
not going to thank him for this bill, however, but I am going to vote 
for this bill.
  Mr. Speaker, American families and businesses deserve certainty from 
their tax system--confidence, stability. I am glad we are able to move 
forward on this legislation rather than pursue a plan to make certain 
tax preferences permanent while ballooning our debt.
  While I am supporting this tax extender package, Mr. Speaker, I do so 
with two very serious reservations. First, it adds the cost of 
extending this preference to our deficit. It is good, however, that we 
did not make unpaid-for extensions on a permanent basis, as the ranking 
member has just discussed.
  Second, this is a very short-term fix when Congress needs to work 
toward a long-term solution. I join the ranking member in 
congratulating Mr. Camp for bringing that forward--well, at least he 
put it on the table. It didn't come forward.
  We ought to make the research and experimentation tax credit 
permanent, but we need to pay for it. While this legislation allows 
teachers to deduct their out-of-pocket expenses, it does not give them 
the certainty that they will be able to do so in 2015 or beyond. To 
that extent, they are in the same position as everybody else covered by 
this bill will be.
  Neither does this bill provide appropriate tax support for renewable 
energy, biofuels, and energy efficiency--sadly, the failure to extend 
this for at least 2 years may result in the loss of up to 30,000 jobs--
nor, Mr. Speaker, does it provide long-term clarity on long-term bonus 
depreciation or small business expensing, all of which would give 
greater confidence to the growth of jobs.
  This all speaks to a larger challenge that Congress has an 
opportunity to address in the new year; instead of this annual ritual 
of extending individual credits and deductions, we ought to engage in 
meaningful, comprehensive, and pro-growth tax reform that provides 
greater certainty across our economy to businesses and individuals 
alike.
  We all know that doing so will not be easy. It will involve difficult 
choices on both sides of the aisle.
  Again, Mr. Chairman, I want to congratulate you. You had the courage 
to put forward a bill earlier this year that made tough decisions in 
order to show a path to lower rates and a simpler Code without adding 
to the deficit, but that path wasn't the path taken by the majority in 
this Congress.
  Instead, the House voted on bill after bill after bill to cut taxes 
recklessly without any plan to stabilize the debt, invest in our future 
priorities, and create jobs in a meaningful way.
  This package we will be voting on today is the least we can do. It 
isn't what I hoped for, and it isn't what I hoped I would stand in this 
well and urge my colleagues to support at the beginning of the 113th 
Congress, but it is better than many of the cynical alternatives that 
we have heard about.

                              {time}  1630

  I want to congratulate the ranking member and, frankly, the President 
of the United States for saying ``no'' to an irresponsible package.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. LEVIN. Mr. Speaker, I yield an additional 2 minutes to the 
gentleman.
  Mr. HOYER. Mr. Speaker, I thank the gentleman for yielding.
  While I support this measure, I do so believing that America deserves 
better, wants better, hopes to get better. That is what each and every 
one of us was sent here to deliver: responsible policy for our country. 
This is not that policy. It is, however, as I said, better than the 
alternative in that it would at least give those in 2014 who have 
operated on the expectation of getting the credit the assurance that 
they will get it.
  My hope, Mr. Speaker, is that, come next December, we won't be here 
again considering another tax extender bill to keep the economy from 
collapsing. It is my hope, Mr. Speaker, that the Republican majority 
and the Democratic minority can work together to effect responsible, 
fiscally sound tax reform which will help grow our economy and give the 
business community and our people the confidence they need to have to 
grow our economy and to participate effectively in making America 
better.
  Mr. Speaker, again, in closing, I want to congratulate Mr. Camp, 
because I think he did bring forth a bill that could have engendered 
that responsible

[[Page 16516]]

debate that we needed, a fiscally sound proposal making tough tradeoffs 
that we ought to have the courage to make. He had that courage, and I 
congratulate him for it.
  Mr. CAMP. Mr. Speaker, I just want to thank the distinguished 
gentleman from Maryland for his remarks. This is a debate America needs 
to have and, hopefully, next year that debate will move forward.
  With that, I yield 3 minutes to the distinguished gentleman from 
Indiana (Mr. Stutzman).
  Mr. STUTZMAN. Mr. Speaker, I rise today in support of the Tax 
Increase Prevention Act of 2014.
  Mr. Speaker, American workers and businesses are most successful when 
they are able to keep, spend, and invest more of their hard-earned 
money. Our economy, which has already remained too weak for too long, 
simply cannot afford a series of irresponsible tax hikes that will 
target individuals, small businesses, and job creators all across the 
country. So this legislation will help protect those taxpayers--our 
taxpayers--and their pocketbooks and provide them some level of clarity 
as they plan for the new year.
  Right now, working families and businesses are simply trying to make 
ends meet. I know from speaking with families and workers back home in 
Indiana that the last thing that they can afford is higher taxes when 
they need to be providing for their kids' education, savings, or 
growing their business.
  In this legislation, Mr. Speaker, I am especially pleased to support 
the provisions that would extend the increased section 179 deduction 
levels, as well as the extension of bonus depreciation. Countless 
farms, small businesses, and manufacturers in the Hoosier State and 
across the country use these important tools to make business-building 
capital investments. A failure to act on those tax extensions would 
only slow an economic recovery that desperately needs to pick up the 
pace.
  Today, we have an opportunity to stand together as Republicans and 
Democrats and pass legislation that will prevent economic harm to 
millions of families and businesses across the United States. While 
this may not be the intention that we would all like to have, I do 
believe that this is the best that we can do for right now to prevent 
any sort of further damage to the economy.
  I would like to, in closing, thank Chairman Camp and the members of 
the Ways and Means Committee for their hard work on this issue, and I 
would urge my colleagues to support their efforts.
  I would also like to take a brief moment to thank Chairman Camp for 
his many years of service as a tireless advocate for the constituents 
back in Michigan. I have the opportunity to travel with him to Detroit 
from time to time and appreciate his thoughtfulness and his leadership 
and his desire to do what is best for America. He is an honorable 
colleague, and I have been honored to have had the chance to serve with 
him. I wish him the very best in his retirement and know that he will 
continue to stay busy one way or another.
  Thank you again, Mr. Chairman, for your work on this. I know that you 
definitely set the table for further tax reform, which is desperately 
needed here in our country, and know that it would be good for our 
economy. Thank you for what you have done. This has given folks back 
home some clarity and certainty for this year.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from 
Washington (Mr. McDermott), another distinguished member of our 
committee.
  Mr. McDERMOTT. Mr. Speaker, there is a fundamental issue with our 
current policy on tax extenders.
  I was a Ways and Means chairman in the State legislature and was told 
by a very important businessman in the State of Washington once: I 
don't care what rate you give me, tell me how long it is going to be; 
how am I going to amortize this? I need to know the length of time.
  This bill, so people really understand, lasts exactly 28 days. It 
will die on January 1. It is for last year.
  Now, businesses and individuals can't be certain they are going to 
get a tax break because of the stop-and-start, temporary nature of 
Congress reauthorizing these tax bills. Businesses and individuals need 
to know what the tax is going to be in the beginning of the year so 
that they can plan and take advantage of incentives rather than waiting 
until the last 2 weeks of the year when the Congress may or may not 
act.
  This year, businesses that want to take advantage of the research tax 
credit have either been sitting on the sidelines or making investments 
or not making investments not knowing, or maybe they gambled and said: 
Well, we figure that Congress will do something some day.
  Everyone should take note of today, the 3rd of December. Next year, 
right about this time, we will be right back here with the same bill--
we can have the same speeches put right out here--because we simply do 
not give businesses certainty. If we did, we would have the economy 
rolling better.
  Individuals and businesses are going into this year wondering whether 
they will have to act retroactively on these provisions. I am going to 
vote ``yes'' like everybody else, but it makes no sense that you have a 
bill like this 28 days before the end of the year. You have got the IRS 
wondering if they are going to be able to do the tax stuff and all of 
this chaos that is created. There are calls coming into our office: Are 
you going to pass this? Are you going to pass that? What should I do 
for next year? The answer that a Congressman has to give if he is 
honest is, ``I don't know.''
  This place is dysfunctional. It may be some of the explanation of why 
people didn't vote in the last election. They figured that Congress 
isn't going to do anything, and this is a perfect example of it. We 
should have done it a long time ago, and done it permanently.
  Mr. CAMP. Mr. Speaker, at this time, I yield such time as he may 
consume to the distinguished gentleman from Wisconsin (Mr. Ryan), the 
chairman of the Budget Committee and the incoming chairman of the Ways 
and Means Committee.
  Mr. RYAN of Wisconsin. Mr. Speaker, I thank the chair.
  The reason I came down here is to speak in favor of this legislation, 
to suggest that I wish we could have gotten where we were with the 
bipartisan negotiations that occurred before White House involvement. 
This is obviously something that is necessary that has to pass.
  But here is the reason that I came down. I came down to say thank you 
to Dave Camp for being an absolutely stellar chairman of the House Ways 
and Means Committee. This is a man who spent 24 years in this room 
making a difference in the lives of the people from Michigan and the 
lives of the 300 million Americans in this country. This country is so 
much better off because of the dedicated service of this man, the 
chairman of the Ways and Means Committee. He came in at a young age, 
reforming a lot of different programs, but one of the biggest marks he 
made in his early days in Congress is welfare reform.
  Dave Camp was one of the principal architects of that 1996 welfare 
reform, which did so much to move people from welfare to work, to 
reduce child poverty, to help single moms get back to work, to get 
people lives of dignity. And he went from there to trade, to tax 
reform, to health care reform, on and on and on.
  I only hope that I can do somewhat of the job that he has done in 
being a stellar steward of this magnificent committee and being a 
fantastic chairman. Mr. Speaker, I simply wish him great success in his 
future endeavors.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from 
Oregon (Mr. Blumenauer), another distinguished member of our committee.
  Mr. BLUMENAUER. Mr. Speaker, I, too, would extend my congratulations 
to Mr. Camp. I have enjoyed being able to work with him for a lot of 
these 20 years. I enjoy his leadership, his dedication, and his 
friendship. In a sense, I feel that it was unfortunate that he had to 
navigate all these bizarre, choppy waters. It would have been fun to

[[Page 16517]]

see what would have happened in a little more measured environment.
  The legislation we are dealing with here today is kind of a symbol of 
the difficulty he faces and the frustrations we all met. This should be 
the first legislation that we deal with in the next Congress, not the 
last legislation we deal with now.
  It has been referenced that this is only going to be in effect for a 
few days. Look at what has happened when we deal with areas that I care 
deeply about. I have worked for years with short-line railroad 
interests. They rely on a tax credit to be able to make a difference in 
rural and small town America. Some of them are plunging in and have 
taken the risk that will be extended, some have not. These are 
investments that can't be made in that fashion.
  I have enjoyed working with the wind energy industry and looking at 
what we have done over the course of 2005 to 2012. When we had the 
production tax credit in place and there was some certainty, we had the 
wind industry grow nine times over, over $100 billion in investment and 
helping us generate clean energy and drop the price per unit 
profoundly. Now who knows what they are facing.
  Looking at the transit benefit, I was pleased to have worked to be 
able to give transit parity to the millions of Americans who take buses 
and trains to work, to treat them the way we treat people who drive a 
car. For 3 years, they were treated that way. And then Congress, after 
the change in power had dropped to $125 a month, and then we kind of 
got it back when we dealt with the fiscal cliff, now it is back to 
$130. It is not fair to people in Chicago, in Detroit, in Metropolitan 
Washington, in New Jersey, in small town America where they take 
advantage of this. It is another example of where we are in this 
squirrel cage.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. LEVIN. Mr. Speaker, I yield an additional minute to the 
gentleman.
  Mr. BLUMENAUER. Mr. Speaker, I thank the gentleman. I appreciate his 
courtesy.
  I am to the point where I don't actually know what is the right vote. 
I have no doubt that it will pass, but is it the right signal to send 
for so many industries that have a right to expect certainty, that have 
a right to expect the things that they have relied upon for years, 
built their business models around, are treated in the cavalier fashion 
by this Congress? I don't think that is right.
  I think there are many areas of reform. I appreciate my friend Mr. 
Camp diving in and dealing with some of these tough issues. We had a 
demonstration that it is not going to be easy to deal with tax reform. 
But it is not going to help anybody for the long term or short term to 
have businesses roll the dice on things in many cases that are critical 
to the national interest and that they rely upon. They deserve better, 
and so does the American public.

                              {time}  1645

  Mr. CAMP. Mr. Speaker, I reserve the balance of my time.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from 
Wisconsin (Mr. Kind), another member of our committee.
  Mr. KIND. I thank my friend for yielding.
  Mr. Speaker, this may be one of the last times I have an opportunity 
to address the current chairman of the Ways and Means Committee, Mr. 
Camp from Michigan, and I just want to commend him for such a 
distinguished career in the United States Congress. He has been an 
honest broker on the issues, a good friend, and I know all of us are 
going to miss him terribly when he decides to retire and go on to other 
ventures in his life. We all wish him well.
  Mr. Speaker, I think all of us, it is safe to assume, are not happy 
with this process or the fact that we are here again at the end of the 
year trying to do a 1-year extension on tax breaks that will be 
retroactive to 2014, mind you, and not paid for. This is a lousy way to 
run a Tax Code. It is a lousy way to run a government. I think 
individuals and businesses, large and small, need greater certainty for 
the decisions they have got to make with their lives and their 
businesses, especially the investment decisions; and by doing things 
retroactively around here and maintaining that uncertainty in future 
years, it is not the right way to go. And, also, not paying for it.
  I think there are opportunities. Certainly the Committee for a 
Responsible Federal Budget laid out a whole list of potential pay-fors 
that, if we had real interest, we could have very easily scrubbed the 
Code to find some offsets to pay for the $40 billion cost that this 1-
year extension has today, rather than just adding it to the debt and 
deficit in our country. We have got to do a better job at that.
  But if this also means we have an opportunity moving into next year 
of being serious about comprehensive tax reform, something that is long 
overdue--again, with the leadership of the Ways and Means Committee and 
Mr. Camp and introducing his discussion draft proposal earlier this 
year, so a lot of a groundwork has been made--then this might be the 
pressure that we need to get the committee and this body to do what is 
long overdue, and that is reform an antiquated Tax Code to make it more 
fair, more simple, to make it more competitive in the global 
environment.
  I think that is a goal that, again, hopefully, we share, and it might 
be an avenue of bipartisan cooperation as we do move forward.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. LEVIN. Mr. Speaker, I yield the gentleman an additional 1 minute.
  Mr. KIND. Thank you.
  Mr. Speaker, I continuously hear from small business owners and 
farmers back home about the need for greater certainty and the need to 
revamp a Tax Code that has outlived its usefulness. It is riddled with 
inefficiencies. It is riddled with certain expenditures that have been 
included in it throughout the years due to powerful special interests 
who know how to work the Halls of Congress to get their special 
provisions in it, and who we are leaving behind are hardworking 
families back home and the small businesses on Main Street who can't 
hire their legion of lobbyists out here to protect their interests or 
to get their special provisions in.
  So as we move forward, hopefully this will be one of those areas 
where we can find some common ground and do what is right for our 
Nation. That would help jump-start the U.S. economy and put us in a 
much more competitive place, when it comes to the global economy, at 
the same time.
  I reluctantly support it. I think we could have done a better job. 
But I think it is also important for policy reasons to maintain these 
tax provisions until we get a chance to do comprehensive reform around 
here.
  Mr. CAMP. Mr. Speaker, I continue to reserve the balance of my time.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from New 
Jersey (Mr. Pascrell), another distinguished member of our committee.
  (Mr. PASCRELL asked and was given permission to revise and extend his 
remarks.)
  Mr. PASCRELL. Thank you, Mr. Ranking Member, and thank you, Mr. 
Chairman. I listened to both sides, and you have given me the reasons 
that I am going to be opposed to this legislation.
  For the past 4 years, the Ways and Means Committee has debated 
comprehensive tax reform. Sadly, the fruit of that discussion before us 
is a 1-year retroactive extension of a temporary tax provision. This is 
an illusion. This is a Fellini movie we are seeing on a late afternoon 
in Washington, D.C. It is completely unpaid for. It gives no certainty 
to businesses or individuals because it expires 1 month from today.
  Unlike today's bill, Chairman Camp's tax reform draft dealt with many 
expiring tax provisions in a courageous way. We were dealing with wind 
credits, R&D tax credits, mortgage debt forgiveness, all the way down 
the line, as well as the mortgage principal extension, which is needed 
for people who have had catastrophic problems within their own States. 
This is an example of

[[Page 16518]]

what a responsible approach to extenders looks like.
  This bill before us today is wholly inadequate. Not only does it add 
billions of dollars to the deficit, we kick the can down the road by 
only dealing with extenders in a retroactive manner. In other words, 
this money has been spent over the last 11 months, hopefully, getting 
to the point where we would pay for it. That is not the way to run the 
show, and you know that only puts us deeper into uncertainty and 
certainly deeper into debt.
  Does anyone believe the 2 weeks these provisions will be in effect 
will encourage any business to make decisions about whether to hire 
more workers or invest in alternative energy or research, new equipment 
for small businesses or development in disadvantaged communities?
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. LEVIN. Mr. Speaker, I yield the gentleman an additional 1 minute.
  Mr. PASCRELL. Thank you.
  I am not finished yet, but I want to say to Mr. Camp, you have been a 
civil voice that will be missed in this hallowed Hall. And I mean that 
sincerely from my heart, because civil discussion is necessary in the 
House of Representatives.
  Many times, in other places, it has not been civil. It will do 
nothing to encourage this legislation, this new development in 
renewable energy.
  I want to be clear. I strongly support, my record will show, many of 
these tax provisions. I want to work with colleagues on the other side 
and my own side to make many of them permanent.
  While this approach may help taxpayers and businesses who made 
decisions assuming Congress would act responsibly, it is not in the 
country's long-term interest, Mr. Speaker. At a bare minimum, Congress 
should be extending these provisions until the end of 2015 in a 
fiscally responsible way.
  Mr. Speaker, I unfortunately must oppose this legislation, the so 
called ``Tax Increase Prevention Act.'' For the past four years, the 
Ways and Means Committee has debated comprehensive tax reform. Sadly, 
the fruit of that discussion before us is a one-year, retroactive 
extension of temporary tax provisions, completely unpaid for, and that 
gives no certainty to businesses or individuals because it expires one 
month from today.
  It didn't have to be this way. Earlier this year, Chairman Camp 
released an ambitious proposal for a comprehensive reform of our tax 
code. I did not agree with everything in that proposal, and neither did 
many of my friends on the other side of the aisle. But I was confident 
that both sides could use Chairman's Camp's draft as a starting point 
to come together around a reform plan that would finally address the 
many loopholes and inefficiencies in our tax code.
  Mr. Camp's draft also dealt with the many expiring tax provisions 
before us today in a courageous way. He resisted the temptation to 
assume these breaks would be indefinitely extended and added to the 
deficit. Instead, he made permanent the ones he wanted to keep and paid 
for them, while separately identifying ones he would let expire. This 
is an example of what a responsible approach to extenders looks like. 
Unfortunately, what happened next could not have been less reflective 
of Mr. Camp's earlier work.

       Before the ink had even dried on Chairman Camp's tax reform 
     draft, the majority of Ways and Means began passing permanent 
     extensions of nearly $1 trillion in tax provisions and did 
     not even make an attempt to pay for one dime of them. This 
     approach is the height of irresponsibility and has squandered 
     any good will that had been developed during the years of 
     debate over tax reform.

  This bill before us today is wholly inadequate. Not only does it add 
to the deficit and kick the can down the road, but by only dealing with 
extenders in a retroactive manner, it will not even encourage any 
business investment in the future. Does anyone really believe that the 
two weeks these provisions will be in effect will really encourage any 
business make decisions about whether to hire more workers, or invest 
in alternative energy, research and development, new equipment for 
small businesses or development in disadvantaged communities?
  A retroactive extension will do nothing for commuters in New Jersey, 
who have been denied parity in their transit benefits for the last 11 
months and will now be denied them again next year. It will do nothing 
to encourage new development in renewable energy, including offshore 
wind in my home state, as developers will have no certainty at all that 
the critical tax credits in this bill will be there for them next year.
  I want to be clear: I strongly support many of these tax provisions, 
and I want to work with my colleagues on the other side of the aisle to 
make many of them permanent. However, while this bare minimum approach 
might help taxpayers and businesses who made decisions assuming 
Congress would act responsibly, it is not in the country's long-term 
interest. At a bare minimum, Congress should be extending these 
provisions until the end of 2015, in a fiscally responsible way, and 
then get back to work on real, permanent tax reform that ends this 
destructive cycle of expiring and renewing temporary tax policy once 
and for all.
  Mr. CAMP. Mr. Speaker, I yield myself such time as I may consume.
  I just want to say to my friend from New Jersey, I agree with you on 
the need for certainty. We have heard today a lot of common discussion 
about the need for certainty in our Tax Code and how difficult it is to 
be the only country in the world that let's tax policy expire and what 
that means for families and employers. But in terms of the concerns you 
raise about the deficit, as the gentleman well knows, these measures 
have never been offset. These measures have never been paid for, 
whether it was a Republican majority or a Democrat majority. Whether it 
was a Republican President or a Democrat President, these provisions 
have never been paid for.
  I would just say to the gentleman and to the Members of this body, 
why do we need to raise taxes on somebody to keep taxes the same? What 
we are doing is continuing current policy. In many cases, like R&D, it 
has been continued since 1981. Let's call it what it is.
  If we are continuing something in a piecemeal fashion every few 
years, let's just make it permanent so we can get the benefits of those 
provisions in terms of reliability and certainty, as the gentleman 
raised, so that the small businesses all throughout the country can 
actually plan and expect that these items will be in place.
  I share the concerns that have been raised by a number of speakers. 
Here we are at the end of 2014, retroactively putting in policies for 
the whole year.
  I reserve the balance of my time.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from 
Illinois (Mr. Danny K. Davis) another member of our committee.
  Mr. DANNY K. DAVIS of Illinois. Mr. Speaker, this 1-year retroactive 
extension is not ideal. It is not the best that we should or could do. 
It does little to provide certainty to individuals and businesses for 
2015. My constituent, Mary Jo, still will not know whether she can give 
money from her IRA to a Chicago charity without tax liability in 2015, 
nor does my constituent, Henry, know if he can receive enhanced tax 
benefits for donating food to the Chicago Food Depository.
  Further, I am deeply disappointed that this bill fails to extend the 
Trade Adjustment Assistance for health care workers laid off through no 
fault of their own. However, I believe that this bill may be our only 
option for this year to provide these tax benefits for 2014 and to 
ensure the taxpayers can begin filing their taxes and receiving their 
refunds early next year. There are many provisions included that are 
critical to Chicago and Illinois, and that must be covered in 2014.
  This is not the best bill, but it is a necessary bill. I look forward 
to working in a bipartisan way to ensure comprehensive permanent 
reforms to the Tax Code that help all Americans, including provisions 
that help the lowest income workers, such as the earned income tax 
credit and enhanced child tax credit.
  I end, Mr. Speaker, by commending Chairman Camp.
  Mr. Camp, I commend you on your efforts to bring comprehensive tax 
reform to the forefront, and I wish you well as you finish out a very 
distinguished career in the people's House. Sir, I salute you.
  Mr. CAMP. Mr. Speaker, I continue to reserve the balance of my time.
  Mr. LEVIN. Mr. Speaker, I yield myself such time as I may consume.
  You are never sure what is going to happen the next day around here, 
so I

[[Page 16519]]

am not sure if this is the last time you will be presenting a bill--
something could come up next week--but let me assume that it is for 
just a moment and speak on a personal basis if I might. I hope the 
speaker won't cut me off. You are not supposed to talk to each other, 
so I will try to speak to you while I speak to the chair. I will try to 
do both.
  Around here we can question each other's positions. In a sense, that 
is why we are here. Dave Camp leaves here having participated in a 
discussion of substance and questioning each other's positions in a way 
to try to come forth with legislation. But I think, in a rather unique 
way, our chairman has been able to do that with complete integrity, 
with complete seriousness--now and then a sense of humor, but complete 
seriousness--and the ability to question within a framework of some 
friendship.
  So if this is your last management of a bill, I simply want to say 
for myself and, more importantly, I think, for this institution, if I 
might, that your decision to leave here means that you are leaving with 
your head so high and with, I hope, a feeling of real accomplishment 
and complete integrity and seriousness about your work. I am sure that 
your constituents are very proud to have voted for you 12 times. That 
was a commendable dozen.
  So with some feeling of gratitude for having been able to serve with 
you, Dave, I yield back the balance of my time.
  Mr. CAMP. Mr. Speaker, I yield myself such time as I may consume.
  I want to thank my friend, colleague, and partner on the Ways and 
Means Committee from Michigan for those very gracious and kind remarks.
  I think the Ways and Means Committee is the best committee in 
Congress. We have a lot of bills that come to us. We have a lot of hard 
decisions. There is a lot of discussion. As you know, this is a big 
country and there are a lot of different opinions, but we always try to 
find a way to at least do that in a manner that is productive for the 
people we represent and that sent us here.
  I want to thank you for the ability to work with you over these last 
few years. Maybe I should have turned that 12 into a baker's dozen, 
with all the kind remarks that have been said here today. I just want 
thank you and thank the members of the committee and staff on both 
sides of the aisle.
  One of the things that is required in a committee like Ways and 
Means, with all of the responsibilities, is a staff that is able to 
work together as well.

                              {time}  1700

  So they help make us do the job well. They help keep us informed and 
really help make all the things that we do come together, including 
items like this legislation today so, thank you.
  I would just urge passage of H.R. 5771, what we call the extenders 
bill, or the Tax Increase Prevention Act of 2014.
  Mr. Speaker, I yield back the balance of my time.
  The SPEAKER pro tempore. All time for debate has expired.
  Pursuant to House Resolution 766, the previous question is ordered on 
the bill, as amended.
  The question is on the engrossment and third reading of the bill.
  The bill was ordered to be engrossed and read a third time, and was 
read the third time.


                           Motion to Recommit

  Mr. NEAL. Mr. Speaker, I have a motion to recommit at the desk.
  The SPEAKER pro tempore. Is the gentleman opposed to the bill?
  Mr. NEAL. I am opposed to the bill in its current form, Mr. Speaker.
  Mr. CAMP. Mr. Speaker, I reserve a point of order against the motion 
to recommit.
  The SPEAKER pro tempore. A point of order is reserved.
  The Clerk will report the motion to recommit.
  The Clerk read as follows:

       Mr. NEAL moves to recommit the bill H.R. 5771 to the 
     Committee on Ways and Means with instructions to report the 
     same back to the House forthwith with the following 
     amendment:
       Add at the end of title I the following (and conform the 
     table of contents accordingly):

 Subtitle E--No Government Subsidies for Corporations That Move Their 
              Headquarters Overseas to Avoid Paying Taxes

     SEC. 191. TAX BENEFITS DISALLOWED IN CASE OF INVERTED 
                   CORPORATIONS.

       (a) In General.--In the case of a taxpayer which is, or is 
     a member of an expanded affiliated group which includes, an 
     applicable inverted corporation, the Internal Revenue Code of 
     1986 shall be applied and administered as if the provisions 
     of, and amendments made by, this title (other than this 
     subtitle) had never been enacted.
       (b) Applicable Inverted Corporations.--
       (1) In general.--For purposes of this section, the term 
     ``applicable inverted corporation'' means any foreign 
     corporation which--
       (A) would be a surrogate foreign corporation under 
     subsection (a)(2) of section 7874 of the Internal Revenue 
     Code of 1986 if such subsection were applied by substituting 
     ``80 percent'' for ``60 percent'', or
       (B) is an inverted domestic corporation.
       (2) Inverted domestic corporation.--For purposes of this 
     subsection, a foreign corporation shall be treated as an 
     inverted domestic corporation if, pursuant to a plan (or a 
     series of related transactions)--
       (A) the entity completes after May 8, 2014, the direct or 
     indirect acquisition of--
       (i) substantially all of the properties held directly or 
     indirectly by a domestic corporation, or
       (ii) substantially all of the assets of, or substantially 
     all of the properties constituting a trade or business of, a 
     domestic partnership, and
       (B) after the acquisition, either--
       (i) more than 50 percent of the stock (by vote or value) of 
     the entity is held--

       (I) in the case of an acquisition with respect to a 
     domestic corporation, by former shareholders of the domestic 
     corporation by reason of holding stock in the domestic 
     corporation, or
       (II) in the case of an acquisition with respect to a 
     domestic partnership, by former partners of the domestic 
     partnership by reason of holding a capital or profits 
     interest in the domestic partnership, or

       (ii) the management and control of the expanded affiliated 
     group which includes the entity occurs, directly or 
     indirectly, primarily within the United States, and such 
     expanded affiliated group has significant domestic business 
     activities.
       (3) Exception for corporations with substantial business 
     activities in foreign country of organization.--A foreign 
     corporation described in paragraph (2) shall not be treated 
     as an inverted domestic corporation if after the acquisition 
     the expanded affiliated group which includes the entity has 
     substantial business activities in the foreign country in 
     which or under the law of which the entity is created or 
     organized when compared to the total business activities of 
     such expanded affiliated group. For purposes of applying 
     section 7874(a)(2)(B)(iii) of the Internal Revenue Code of 
     1986 and the preceding sentence, the term ``substantial 
     business activities'' shall have the meaning given such term 
     under Treasury regulations in effect on May 8, 2014, except 
     that the Secretary of the Treasury may issue regulations 
     increasing the threshold percent in any of the tests under 
     such regulations for determining if business activities 
     constitute substantial business activities for purposes of 
     this paragraph.
       (4) Management and control.--For purposes of paragraph 
     (2)(B)(ii)--
       (A) In general.--The Secretary of the Treasury shall 
     prescribe regulations for purposes of determining cases in 
     which the management and control of an expanded affiliated 
     group is to be treated as occurring, directly or indirectly, 
     primarily within the United States. The regulations 
     prescribed under the preceding sentence shall apply to 
     periods after May 8, 2014.
       (B) Executive officers and senior management.--Such 
     regulations shall provide that the management and control of 
     an expanded affiliated group shall be treated as occurring, 
     directly or indirectly, primarily within the United States if 
     substantially all of the executive officers and senior 
     management of the expanded affiliated group who exercise day-
     to-day responsibility for making decisions involving 
     strategic, financial, and operational policies of the 
     expanded affiliated group are based or primarily located 
     within the United States. Individuals who in fact exercise 
     such day-to-day responsibilities shall be treated as 
     executive officers and senior management regardless of their 
     title.
       (5) Significant domestic business activities.--For purposes 
     of paragraph (2)(B)(ii), an expanded affiliated group has 
     significant domestic business activities if at least 25 
     percent of--
       (A) the employees of the group are based in the United 
     States,
       (B) the employee compensation incurred by the group is 
     incurred with respect to employees based in the United 
     States,
       (C) the assets of the group are located in the United 
     States, or
       (D) the income of the group is derived in the United 
     States,
     determined in the same manner as such determinations are made 
     for purposes of determining substantial business activities 
     under

[[Page 16520]]

     regulations referred to in paragraph (3) as in effect on May 
     8, 2014, but applied by treating all references in such 
     regulations to ``foreign country'' and ``relevant foreign 
     country'' as references to ``the United States''. The 
     Secretary of the Treasury may issue regulations decreasing 
     the threshold percent in any of the tests under such 
     regulations for determining if business activities constitute 
     significant domestic business activities for purposes of this 
     paragraph.
       (c) Definitions.--For purposes of this section, the terms 
     ``domestic corporation'', ``foreign corporation'', and 
     ``expanded affiliated group'' shall each have the same 
     meaning as when used in section 7874 of the Internal Revenue 
     Code of 1986.

  Mr. NEAL (during the reading). Mr. Speaker, I ask unanimous consent 
that we dispense with the reading of the motion.
  The SPEAKER pro tempore. Is there objection to the request of the 
gentleman from Massachusetts?
  There was no objection.
  The SPEAKER pro tempore. The gentleman from Massachusetts is 
recognized for 5 minutes.
  Mr. NEAL. Mr. Speaker, I am opposed to this bill in its current form, 
and I want to remind colleagues that this amendment to the bill will 
not kill the bill, nor will it send it back to committee, and, in fact, 
if adopted, we will immediately proceed to final passage.
  Mr. Speaker, we are here today debating this faulty effort for one 
reason and one reason only: the failure fundamentally to change the Tax 
Code.
  Now, let me say to my friends, the praise delivered on behalf of Mr. 
Camp is well-earned. But I also want to say something today. We all 
love to say, ``I hate to say I told you so,'' but we really like to 
say, ``I told you so.''
  I told you so. The staff would be rich if they took that bet that I 
offered not long ago on the very floor of this House.
  Now, Mr. Camp, the wily sorcerer of tax policies that he is, he 
employed every bit of magic at his disposal to bring forth tax reform. 
He put together a great model and, for 3 years, without the glare of 
publicity, we actually had an adult conversation between the parties, 
principals and the stakeholders, who listened carefully to what 
everyone had to say.
  Unfortunately, the Republican leadership was not spellbound by the 
sorcerer's good deeds. When he was pleased to release his tax proposal, 
the leadership of the Republican side said, Blah, blah, blah.
  Well, one blah in support of continuing uncertainty for the American 
family and for business; two blahs, or a second blah, for cutting 
economic growth and business investment; and finally, a third blah to 
the lowest worker participation rate in 36 years.
  Seven to 8 million Americans still looking for work, but we can't do 
tax reform.
  The last time we reformed our code, the Internet didn't exist, but we 
can't do tax reform.
  Economic growth at 2 percent, but we can't do tax reform.
  Forty percent of the Business Roundtable's major alliances said this 
week they plan on hiring new employees. That means 60 percent don't--
but we can't do tax reform.
  Thirteen percent of these companies said they are committing to 
investing in buying new equipment, but that means 87 percent are not.
  Our inaction on tax reform is harming this economy, and it is not Mr. 
Camp's fault. Rather than working on this bill and staying with it, 
with wage stagnation, low worker participation rate, depressed business 
investment, instead of addressing these problems, we are debating a 
bill that, once the President signs it, we will immediately see it as 
being outdated, and we are going to start the process all over again, 
maybe in just a couple of days.
  What we have before us, in terms of process, is the pinnacle of 
congressional nonsense. This bill does not incentivize companies to 
invest more; no more for research. We are rewarding companies for their 
past behavior.
  You cannot find any economist with credibility that will suggest that 
retroactivity in the Tax Code is sound policy.
  Pick up the newspaper and you are going to find very quickly that, as 
we released this draft, over that same period of time, more companies 
inverted. The sound of the dam breaking is all around us.
  Recent reports have stated that the United States stands to lose $2 
billion next year alone, and since the first inversion in 1982, we have 
lost more than $9 billion. Sadly, these inversions are a part of an 
epidemic that started a decade ago.
  CRS points out that at least 47 companies have inverted since the 
beginning of the last year, 19 inversion deals are still pending, and 
14 more are sure to come in the coming year alone.
  The Joint Committee on Taxation says now it is costing us $33.6 
billion in lost tax revenue because of our inability to deal with 
corporate tax inversions.
  I understand the argument about tax avoidance versus tax evasion. We 
have done a reasonably good job at cracking down on Switzerland and 
Liechtenstein and other places, but we need to address this question of 
Bermuda and these other tax havens where corporate residents of America 
pay their fair share, and those who invert to escape taxes--while, 
incidentally, we are engaged militarily across the globe with a 
substantial bill--they feel as though they don't have to deliver 
anything.
  Now, my motion to recommit today is very simple. Those companies that 
have inverted cannot take advantage of the very tax benefits that we 
are going to vote upon in a few minutes, which, by the way, I favor 
extending. If you have inverted, you should not be allowed the same 
credits and deductions and exclusions that American businesses who have 
stayed here dutifully, respectfully, and with great patriotic fervor 
continue to pay.
  I don't understand, for the life of me, why Republicans can't support 
doing something about corporate tax inversions.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. CAMP. Mr. Speaker, I withdraw my point of order.
  The SPEAKER pro tempore. The reservation is withdrawn.
  Mr. CAMP. Mr. Speaker, I seek time in opposition.
  The SPEAKER pro tempore. The gentleman from Michigan is recognized 
for 5 minutes.
  Mr. CAMP. Mr. Speaker, I would just say, in brief, there is nothing 
in this motion to recommit that addresses the issues raised by my 
friend from Massachusetts. The problems the gentleman identified are 
not dealt with at all here.
  Does this motion to recommit increase investment, create jobs, and 
raise wages?
  Does this motion to recommit create certainty in what is an uncertain 
Tax Code with this process?
  It doesn't. What this does is make our Tax Code more complex, makes 
American workers and American employers less competitive, and it will 
actually hurt our economy and stifle growth.
  I urge a ``no'' vote on this motion to recommit, and I yield back the 
balance of my time.
  The SPEAKER pro tempore. Without objection, the previous question is 
ordered on the motion to recommit.
  There was no objection.
  The SPEAKER pro tempore. The question is on the motion to recommit.
  The question was taken; and the Speaker pro tempore announced that 
the noes appeared to have it.
  Mr. NEAL. Mr. Speaker, on that I demand the yeas and nays.
  The yeas and nays were ordered.
  The SPEAKER pro tempore. Pursuant to clause 8 and clause 9 of rule 
XX, this 15-minute vote on the motion to recommit will be followed by 
5-minute votes on the question of passage, if ordered, and passage of 
H.R. 647.
  The vote was taken by electronic device, and there were--yeas 197, 
nays 223, not voting 14, as follows:

                             [Roll No. 543]

                               YEAS--197

     Adams
     Barber
     Barrow (GA)
     Bass
     Beatty
     Becerra
     Bera (CA)
     Bishop (GA)
     Bishop (NY)
     Blumenauer
     Bonamici
     Brady (PA)
     Braley (IA)
     Brown (FL)
     Brownley (CA)
     Bustos
     Butterfield
     Capps
     Cardenas
     Carney
     Carson (IN)
     Cartwright
     Castor (FL)
     Castro (TX)
     Chu
     Cicilline
     Clark (MA)
     Clarke (NY)
     Clay
     Cleaver

[[Page 16521]]


     Clyburn
     Cohen
     Connolly
     Conyers
     Cooper
     Costa
     Courtney
     Crowley
     Cuellar
     Cummings
     Davis (CA)
     Davis, Danny
     DeFazio
     DeGette
     Delaney
     DeLauro
     DelBene
     Deutch
     Dingell
     Doggett
     Duncan (TN)
     Edwards
     Ellison
     Engel
     Enyart
     Eshoo
     Esty
     Farr
     Fattah
     Foster
     Frankel (FL)
     Fudge
     Gabbard
     Gallego
     Garamendi
     Garcia
     Grayson
     Green, Al
     Green, Gene
     Grijalva
     Gutierrez
     Hahn
     Hanabusa
     Hastings (FL)
     Heck (WA)
     Higgins
     Himes
     Hinojosa
     Holt
     Honda
     Horsford
     Hoyer
     Huffman
     Israel
     Jackson Lee
     Jeffries
     Johnson (GA)
     Johnson, E. B.
     Jones
     Kaptur
     Keating
     Kelly (IL)
     Kennedy
     Kildee
     Kilmer
     Kind
     Kirkpatrick
     Kuster
     Langevin
     Larsen (WA)
     Larson (CT)
     Lee (CA)
     Levin
     Lewis
     Lipinski
     Loebsack
     Lofgren
     Lowenthal
     Lowey
     Lujan Grisham (NM)
     Lujan, Ben Ray (NM)
     Lynch
     Maffei
     Maloney, Carolyn
     Maloney, Sean
     Matheson
     Matsui
     McCollum
     McDermott
     McGovern
     McIntyre
     McNerney
     Meeks
     Meng
     Michaud
     Miller, George
     Moore
     Moran
     Murphy (FL)
     Nadler
     Napolitano
     Neal
     Nolan
     Norcross
     O'Rourke
     Owens
     Pallone
     Pascrell
     Pastor (AZ)
     Payne
     Pelosi
     Perlmutter
     Peters (CA)
     Peters (MI)
     Peterson
     Pingree (ME)
     Pocan
     Polis
     Price (NC)
     Quigley
     Rahall
     Rangel
     Richmond
     Roybal-Allard
     Ruiz
     Ruppersberger
     Rush
     Ryan (OH)
     Sanchez, Linda T.
     Sanchez, Loretta
     Sarbanes
     Schakowsky
     Schiff
     Schneider
     Schrader
     Schwartz
     Scott (VA)
     Scott, David
     Serrano
     Sewell (AL)
     Shea-Porter
     Sherman
     Sinema
     Sires
     Slaughter
     Smith (WA)
     Speier
     Swalwell (CA)
     Takano
     Thompson (CA)
     Thompson (MS)
     Tierney
     Titus
     Tonko
     Tsongas
     Van Hollen
     Vargas
     Veasey
     Vela
     Velazquez
     Visclosky
     Walz
     Waters
     Waxman
     Welch
     Wilson (FL)
     Yarmuth

                               NAYS--223

     Amash
     Amodei
     Bachmann
     Bachus
     Barletta
     Barr
     Barton
     Benishek
     Bentivolio
     Bilirakis
     Black
     Blackburn
     Boustany
     Brady (TX)
     Brat
     Bridenstine
     Brooks (AL)
     Brooks (IN)
     Broun (GA)
     Buchanan
     Bucshon
     Burgess
     Byrne
     Calvert
     Camp
     Campbell
     Carter
     Cassidy
     Chabot
     Chaffetz
     Clawson (FL)
     Coble
     Coffman
     Cole
     Collins (GA)
     Collins (NY)
     Conaway
     Cook
     Cotton
     Cramer
     Crawford
     Crenshaw
     Culberson
     Daines
     Davis, Rodney
     Denham
     Dent
     DeSantis
     DesJarlais
     Diaz-Balart
     Duffy
     Duncan (SC)
     Ellmers
     Farenthold
     Fincher
     Fitzpatrick
     Fleischmann
     Fleming
     Flores
     Forbes
     Fortenberry
     Foxx
     Franks (AZ)
     Frelinghuysen
     Gardner
     Garrett
     Gerlach
     Gibbs
     Gibson
     Gingrey (GA)
     Gohmert
     Goodlatte
     Gosar
     Gowdy
     Granger
     Graves (GA)
     Graves (MO)
     Griffin (AR)
     Griffith (VA)
     Grimm
     Guthrie
     Hanna
     Harper
     Harris
     Hartzler
     Hastings (WA)
     Heck (NV)
     Hensarling
     Herrera Beutler
     Holding
     Hudson
     Huelskamp
     Huizenga (MI)
     Hultgren
     Hunter
     Hurt
     Issa
     Jenkins
     Johnson (OH)
     Johnson, Sam
     Jolly
     Jordan
     Joyce
     Kelly (PA)
     King (IA)
     King (NY)
     Kingston
     Kinzinger (IL)
     Kline
     Labrador
     LaMalfa
     Lamborn
     Lance
     Lankford
     Latham
     Latta
     LoBiondo
     Long
     Lucas
     Luetkemeyer
     Lummis
     Marchant
     Marino
     Massie
     McAllister
     McCarthy (CA)
     McClintock
     McHenry
     McKinley
     McMorris Rodgers
     Meadows
     Meehan
     Messer
     Mica
     Miller (FL)
     Miller (MI)
     Mullin
     Mulvaney
     Murphy (PA)
     Neugebauer
     Noem
     Nugent
     Nunes
     Nunnelee
     Olson
     Palazzo
     Paulsen
     Pearce
     Perry
     Petri
     Pittenger
     Pitts
     Poe (TX)
     Pompeo
     Posey
     Price (GA)
     Reed
     Reichert
     Renacci
     Ribble
     Rice (SC)
     Rigell
     Roby
     Roe (TN)
     Rogers (AL)
     Rogers (KY)
     Rogers (MI)
     Rohrabacher
     Rokita
     Rooney
     Ros-Lehtinen
     Roskam
     Ross
     Rothfus
     Royce
     Runyan
     Ryan (WI)
     Salmon
     Sanford
     Scalise
     Schock
     Schweikert
     Scott, Austin
     Sensenbrenner
     Sessions
     Shimkus
     Shuster
     Simpson
     Smith (MO)
     Smith (NE)
     Smith (NJ)
     Smith (TX)
     Stewart
     Stivers
     Stockman
     Stutzman
     Terry
     Thompson (PA)
     Thornberry
     Tiberi
     Tipton
     Turner
     Upton
     Valadao
     Wagner
     Walberg
     Walden
     Walorski
     Weber (TX)
     Webster (FL)
     Wenstrup
     Westmoreland
     Whitfield
     Williams
     Wilson (SC)
     Wittman
     Wolf
     Womack
     Woodall
     Yoder
     Yoho
     Young (AK)
     Young (IN)

                             NOT VOTING--14

     Aderholt
     Bishop (UT)
     Capito
     Capuano
     Doyle
     Duckworth
     Hall
     McCarthy (NY)
     McCaul
     McKeon
     Miller, Gary
     Negrete McLeod
     Southerland
     Wasserman Schultz

                              {time}  1737

  Messrs. PEARCE, BARR, BACHUS, YOHO, BRIDENSTINE, and Ms. GRANGER 
changed their vote from ``yea'' to ``nay.''
  Ms. EDWARDS and Mr. WAXMAN changed their vote from ``nay'' to 
``yea.''
  So the motion to recommit was rejected.
  The result of the vote was announced as above recorded.
  The SPEAKER pro tempore. The question is on the passage of the bill.
  The question was taken; and the Speaker pro tempore announced that 
the ayes appeared to have it.


                             Recorded Vote

  Mr. BRADY of Texas. Mr. Speaker, I demand a recorded vote.
  A recorded vote was ordered.
  The SPEAKER pro tempore. This will be a 5-minute vote.
  The vote was taken by electronic device, and there were--ayes 378, 
noes 46, not voting 10, as follows:

                             [Roll No. 544]

                               AYES--378

     Adams
     Amodei
     Bachmann
     Bachus
     Barber
     Barletta
     Barr
     Barrow (GA)
     Barton
     Bass
     Beatty
     Benishek
     Bentivolio
     Bera (CA)
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[[Page 16522]]


     Sewell (AL)
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                                NOES--46

     Amash
     Becerra
     Blumenauer
     Broun (GA)
     Clarke (NY)
     Clawson (FL)
     Clay
     Cooper
     Cotton
     Duffy
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     Polis
     Pompeo
     Ribble
     Sanford
     Schakowsky
     Shuster
     Stockman
     Thompson (CA)
     Visclosky
     Welch
     Whitfield

                             NOT VOTING--10

     Aderholt
     Bishop (UT)
     Capuano
     Doyle
     Duckworth
     Hall
     McCarthy (NY)
     McKeon
     Miller, Gary
     Negrete McLeod

                              {time}  1745

  So the bill was passed.
  The result of the vote was announced as above recorded.
  A motion to reconsider was laid on the table.

                          ____________________