[Congressional Record (Bound Edition), Volume 160 (2014), Part 6]
[Senate]
[Pages 7833-7855]
[From the U.S. Government Publishing Office, www.gpo.gov]




                           TEXT OF AMENDMENTS

  SA 3056. Mr. INHOFE submitted an amendment intended to be proposed by 
him to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       At the appropriate place, insert the following:

[[Page 7834]]



                       TITLE __--OTHER PROVISIONS

     SEC. ___. ELIMINATION OF TAXABLE INCOME LIMIT ON PERCENTAGE 
                   DEPLETION FOR OIL AND NATURAL GAS PRODUCED FROM 
                   MARGINAL PROPERTIES.

       (a) In General.--Subparagraph (H) of section 613A(c)(6) is 
     amended to read as follows:
       ``(H) Nonapplication of taxable income limit with respect 
     to marginal production.--The second sentence of subsection 
     (a) of section 613 shall not apply to so much of the 
     allowance for depletion as is determined under subparagraph 
     (A) for any taxable year beginning after December 31, 2013, 
     and before January 1, 2016.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.
       (c) Rescission of Funds.--The available unobligated balance 
     of any amounts that are appropriated for fiscal year 2013 are 
     rescinded, to the extent such amounts do not exceed the 
     reduction in revenues to the Treasury by reason of the 
     amendment made by subsection (a).
                                 ______
                                 
  SA 3057. Mr. THUNE submitted an amendment intended to be proposed by 
him to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       At the end, add the following:

                       TITLE _--OTHER PROVISIONS

     SEC. _01. LONG-TERM UNEMPLOYED INDIVIDUALS NOT TAKEN INTO 
                   ACCOUNT FOR EMPLOYER HEALTH CARE COVERAGE 
                   MANDATE.

       (a) In General.--Paragraph (4) of section 4980H(c) is 
     amended by adding at the end the following new subparagraph:
       ``(C) Exception for long-term unemployed individuals.--
       ``(i) In general.--The term `full-time employee' shall not 
     include any individual who is a long-term unemployed 
     individual with respect to such employer.
       ``(ii) Long-term unemployed individual.--For purposes of 
     this subparagraph, the term `long-term unemployed individual' 
     means, with respect to any employer, an individual who--

       ``(I) begins employment with such employer after the date 
     of the enactment of this subparagraph, and
       ``(II) has been unemployed for 27 weeks or longer, as 
     determined by the Secretary of Labor, immediately before the 
     date such employment begins.''.

       (b) Effective Date.--The amendment made by this section 
     shall apply to months beginning after December 31, 2013.
                                 ______
                                 
  SA 3058. Mr. THUNE submitted an amendment intended to be proposed by 
him to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       At the end, add the following:

TITLE _--ELIMINATION OF PENALTY FOR FAILURE OF INDIVIDUALS TO MAINTAIN 
                       MINIMUM ESSENTIAL COVERAGE

     SEC. _01. ELIMINATION OF PENALTY FOR FAILURE OF INDIVIDUALS 
                   TO MAINTAIN MINIMUM ESSENTIAL COVERAGE.

       (a) In General.--Section 5000A is amended by striking 
     subsections (b), (c), and (g).
       (b) Conforming Amendment.--Section 5000A(e) is amended by 
     striking ``No penalty shall be imposed under subsection (a) 
     with respect to'' and inserting ``Subsection (a) shall not 
     apply to''.
       (c) Effective Date.--The amendment made by this section 
     shall apply to taxable years ending after December 31, 2013.
                                 ______
                                 
  SA 3059. Ms. AYOTTE submitted an amendment intended to be proposed by 
her to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       At the appropriate place, insert the following:

                       TITLE __--OTHER PROVISIONS

     SEC. _01. POINT OF ORDER.

       (a) In General.--It shall not be in order in the Senate to 
     consider any bill, joint resolution, motion, amendment, or 
     conference report that authorizes States to require online 
     remote sales tax collection.
       (b) Supermajority Waiver and Appeal.--
       (1) Waiver.--This section may be waived or suspended in the 
     Senate only by an affirmative vote of \2/3\ of the Members, 
     duly chosen and sworn.
       (2) Appeal.--An affirmative vote of \2/3\ of the Members of 
     the Senate, duly chosen and sworn, shall be required in the 
     Senate to sustain an appeal of the ruling of the Chair on a 
     point of order raised under this section.
                                 ______
                                 
  SA 3060. Mr. WYDEN submitted an amendment intended to be proposed by 
him to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       Strike all after the enacting clause and insert the 
     following:

     SECTION 1. SHORT TITLE, ETC.

       (a) Short Title.--This Act may be cited as the ``Expiring 
     Provisions Improvement, Reform, and Efficiency Act of 2014'' 
     or the ``EXPIRE 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 of this Act 
     is as follows:

Sec. 1. Short title, etc.
Sec. 2. Sense of the Senate.

   TITLE I--EXTENSIONS AND MODIFICATIONS OF EXPIRED AND EXPIRING TAX 
                               PROVISIONS

                Subtitle A--Provisions Expiring in 2013

                    PART I--Individual Tax Extenders

Sec. 101. Extension of health care tax credit.
Sec. 102. Extension of deduction for certain expenses of elementary and 
              secondary school teachers.
Sec. 103. Extension of exclusion from gross income of discharge of 
              qualified principal residence indebtedness.
Sec. 104. Extension of parity and modification of exclusion from income 
              for employer-provided mass transit and parking benefits.
Sec. 105. Extension of mortgage insurance premiums treated as qualified 
              residence interest.
Sec. 106. Extension of deduction of State and local general sales 
              taxes.
Sec. 107. Extension of special rule for contributions of capital gain 
              real property made for conservation purposes.
Sec. 108. Extension of above-the-line deduction for qualified tuition 
              and related expenses.
Sec. 109. Extension of tax-free distributions from individual 
              retirement plans for charitable purposes.

                    PART II--Business Tax Extenders

Sec. 111. Extension and modification of research credit.
Sec. 112. Extension and modification 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 and modification of new markets tax credit.
Sec. 116. Extension of railroad track maintenance credit.
Sec. 117. Extension of mine rescue team training credit.
Sec. 118. Extension and modification of employer wage credit for 
              employees who are active duty members of the uniformed 
              services.
Sec. 119. Extension and modification of work opportunity tax credit.
Sec. 120. Extension and modification 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 and modification of increased expensing limitations 
              and treatment of certain real property as section 179 
              property.

[[Page 7835]]

Sec. 128. Extension of election to expense mine safety equipment.
Sec. 129. Extension of special expensing rules for certain film and 
              television productions; special expensing for live 
              theatrical 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.

                     PART III--Energy Tax Extenders

Sec. 151. Extension and modification of credit for nonbusiness energy 
              property.
Sec. 152. Extension of credit for 2-wheeled plug-in electric vehicles.
Sec. 153. Extension of second generation biofuel producer credit.
Sec. 154. Extension of incentives for biodiesel and renewable diesel.
Sec. 155. Extension and modification of production credit for Indian 
              coal facilities placed in service before 2009.
Sec. 156. Extension of credits with respect to facilities producing 
              energy from certain renewable resources.
Sec. 157. Extension of credit for energy-efficient new homes.
Sec. 158. Extension of special allowance for second generation biofuel 
              plant property.
Sec. 159. Extension and modification of energy efficient commercial 
              buildings deduction.
Sec. 160. Extension of special rule for sales or dispositions to 
              implement FERC or State electric restructuring policy for 
              qualified electric utilities.
Sec. 161. Extension of excise tax credits relating to certain fuels.

                Subtitle B--Provisions Expiring in 2014

                      PART I--Energy Tax Extenders

Sec. 171. Extension of credit for new qualified fuel cell motor 
              vehicles.
Sec. 172. Extension of credit for alternative fuel vehicle refueling 
              property.

 PART II--Extenders Relating to Multiemployer Defined Benefit Pension 
                                 Plans

Sec. 181. Extension of automatic extension of amortization periods.
Sec. 182. Extension of funding improvement and rehabilitation plan 
              rules.

                     Subtitle C--Revenue Provisions

Sec. 191. Penalty for failure to meet due diligence requirements for 
              the child tax credit.
Sec. 192. 100 percent continuous levy on payment to medicare providers 
              and suppliers.
Sec. 193. Exclusion from gross income of certain clean coal power 
              grants to non-corporate taxpayers.
Sec. 194. Reform of rules relating to qualified tax collection 
              contracts.
Sec. 195. Special compliance personnel program.
Sec. 196. Exclusion of dividends from controlled foreign corporations 
              from the definition of personal holding company income 
              for purposes of the personal holding company rules.
Sec. 197. Inflation adjustment for certain civil penalties under the 
              Internal Revenue Code of 1986.

                  TITLE II--TAX TECHNICAL CORRECTIONS

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

                      TITLE III--HIRE MORE HEROES

Sec. 301. Short title.
Sec. 302. Employees with health coverage under TRICARE or the Veterans 
              Administration may be exempted from employer mandate 
              under Patient Protection and Affordable Care Act.

                      TITLE IV--BUDGETARY EFFECTS

Sec. 401. Budgetary effects.

     SEC. 2. SENSE OF THE SENATE.

       It is the sense of the Senate that--
       (1) a process of comprehensive tax reform should commence 
     in the 114th Congress and should conclude before January 1, 
     2016;
       (2) Congress should endeavor, as part of such a tax reform 
     process, to eliminate temporary provisions from the Internal 
     Revenue Code of 1986 by making permanent those provisions 
     that merit permanency and allowing others to expire;
       (3) a major focus of such tax reform process should be 
     fostering economic growth and lowering tax rates by 
     broadening the tax base; and
       (4) the chairman and ranking member of the Committee on 
     Finance of the Senate should consult with the chairman and 
     ranking member of the Committee on the Budget of the Senate 
     to ensure that the appropriate baseline is used in 
     determining the economic effects of, and rate adjustments 
     under, tax reform.

   TITLE I--EXTENSIONS AND MODIFICATIONS OF EXPIRED AND EXPIRING TAX 
                               PROVISIONS

                Subtitle A--Provisions Expiring in 2013

                    PART I--INDIVIDUAL TAX EXTENDERS

     SEC. 101. EXTENSION OF HEALTH CARE TAX CREDIT.

       (a) In General.--Subparagraph (B) of section 35(b)(1) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to coverage months beginning after December 31, 
     2013.

     SEC. 102. 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, 2014, 
     or 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 103. 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, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to indebtedness discharged after December 31, 
     2013.

     SEC. 104. EXTENSION OF PARITY AND MODIFICATION OF EXCLUSION 
                   FROM INCOME FOR EMPLOYER-PROVIDED MASS TRANSIT 
                   AND PARKING BENEFITS.

       (a) Extension.--
       (1) In general.--Paragraph (2) of section 132(f) is amended 
     by striking ``January 1, 2014'' and inserting ``January 1, 
     2016''.
       (2) Effective date.--The amendment made by this subsection 
     shall apply to months after December 31, 2013.
       (b) Use of a Bike Share Program as a Qualified 
     Transportation Fringe.--
       (1) In general.--Section 132(f)(5)(F) is amended--
       (A) in clause (i), by striking ``repair, and storage, if 
     such bicycle'' and inserting ``repair, and storage (or use of 
     a bike sharing

[[Page 7836]]

     program, in the case of taxable years beginning before 
     January 1, 2016), if such bicycle or bike sharing program'', 
     and
       (B) in clause (iii)(I), by inserting ``or bike sharing 
     program'' after ``bicycle''.
       (2) Effective date.--The amendments made by this subsection 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 105. 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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to amounts paid or accrued after December 31, 
     2013.

     SEC. 106. 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, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 107. 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, 2015''.
       (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, 
     2015''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to contributions made in taxable years beginning 
     after December 31, 2013.

     SEC. 108. 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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 109. 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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to distributions made in taxable years beginning 
     after December 31, 2013.

                    PART II--BUSINESS TAX EXTENDERS

     SEC. 111. EXTENSION AND MODIFICATION OF RESEARCH CREDIT.

       (a) Extension.--
       (1) 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, 2015.''.
       (2) 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.''.
       (3) Effective date.--The amendments made by this subsection 
     shall apply to amounts paid or incurred after December 31, 
     2013.
       (b) Treatment of Research Credit for Certain Startup 
     Companies.--
       (1) In general.--Section 41 is amended by adding at the end 
     the following new subsection:
       ``(i) Treatment of Credit for Qualified Small Businesses.--
       ``(1) In general.--At the election of a qualified small 
     business for any taxable year, section 3111(f) shall apply to 
     the payroll tax credit portion of the credit otherwise 
     determined under subsection (a) for the taxable year and such 
     portion shall not be treated (other than for purposes of 
     section 280C) as a credit determined under subsection (a).
       ``(2) Payroll tax credit portion.--For purposes of this 
     subsection, the payroll tax credit portion of the credit 
     determined under subsection (a) with respect to any qualified 
     small business for any taxable year is the least of--
       ``(A) the amount specified in the election made under this 
     subsection,
       ``(B) the credit determined under subsection (a) for the 
     taxable year (determined before the application of this 
     subsection), or
       ``(C) in the case of a qualified small business other than 
     a partnership or S corporation, the amount of the business 
     credit carryforward under section 39 carried from the taxable 
     year (determined before the application of this subsection to 
     the taxable year).
       ``(3) Qualified small business.--For purposes of this 
     subsection--
       ``(A) In general.--The term `qualified small business' 
     means, with respect to any taxable year--
       ``(i) a corporation or partnership, if--

       ``(I) the gross receipts (as determined under the rules of 
     section 448(c)(3), without regard to subparagraph (A) 
     thereof) of such entity for the taxable year is less than 
     $5,000,000, and
       ``(II) such entity did not have gross receipts (as so 
     determined) for any taxable year preceding the 5-taxable-year 
     period ending with such taxable year, and

       ``(ii) any person (other than a corporation or partnership) 
     who meets the requirements of subclauses (I) and (II) of 
     clause (i), determined--

       ``(I) by substituting `person' for `entity' each place it 
     appears, and
       ``(II) by only taking into account the aggregate gross 
     receipts received by such person in carrying on all trades or 
     businesses of such person.

       ``(B) Limitation.--Such term shall not include an 
     organization which is exempt from taxation under section 501.
       ``(4) Election.--
       ``(A) In general.--Any election under this subsection for 
     any taxable year--
       ``(i) shall specify the amount of the credit to which such 
     election applies,
       ``(ii) shall be made on or before the due date (including 
     extensions) of--

       ``(I) in the case of a qualified small business which is a 
     partnership, the return required to be filed under section 
     6031,
       ``(II) in the case of a qualified small business which is 
     an S corporation, the return required to be filed under 
     section 6037, and
       ``(III) in the case of any other qualified small business, 
     the return of tax for the taxable year, and

       ``(iii) may be revoked only with the consent of the 
     Secretary.
       ``(B) Limitations.--
       ``(i) Amount.--The amount specified in any election made 
     under this subsection shall not exceed $250,000.
       ``(ii) Number of taxable years.--A person may not make an 
     election under this subsection if such person (or any other 
     person treated as a single taxpayer with such person under 
     paragraph (5)(A)) has made an election under this subsection 
     for 5 or more preceding taxable years.
       ``(C) Special rule for partnerships and s corporations.--In 
     the case of a qualified small business which is a partnership 
     or S corporation, the election made under this subsection 
     shall be made at the entity level.
       ``(5) Aggregation rules.--
       ``(A) In general.--Except as provided in subparagraph (B), 
     all persons or entities treated as a single taxpayer under 
     subsection (f)(1) shall be treated as a single taxpayer for 
     purposes of this subsection.
       ``(B) Special rules.--For purposes of this subsection and 
     section 3111(f)--
       ``(i) each of the persons treated as a single taxpayer 
     under subparagraph (A) may separately make the election under 
     paragraph (1) for any taxable year, and
       ``(ii) the $250,000 amount under paragraph (4)(B)(i) shall 
     be allocated among all persons treated as a single taxpayer 
     under subparagraph (A) in the same manner as under 
     subparagraph (A)(ii) or (B)(ii) of subsection (f)(1), 
     whichever is applicable.
       ``(6) Regulations.--The Secretary shall prescribe such 
     regulations as may be necessary to carry out the purposes of 
     this subsection, including--
       ``(A) regulations to prevent the avoidance of the purposes 
     of the limitations and aggregation rules under this 
     subsection through the use of successor companies or other 
     means,
       ``(B) regulations to minimize compliance and record-keeping 
     burdens under this subsection, and
       ``(C) regulations for recapturing the benefit of credits 
     determined under section 3111(f) in cases where there is a 
     subsequent adjustment to the payroll tax credit portion of 
     the credit determined under subsection (a), including 
     requiring amended income tax returns in the cases where there 
     is such an adjustment.''.
       (2) Credit allowed against fica taxes.--Section 3111 is 
     amended by adding at the end the following new subsection:
       ``(f) Credit for Research Expenditures of Qualified Small 
     Businesses.--
       ``(1) In general.--In the case of a taxpayer who has made 
     an election under section 41(i) for a taxable year, there 
     shall be allowed as a credit against the tax imposed by 
     subsection (a) for the first calendar quarter which begins 
     after the date on which the taxpayer files the return 
     specified in section 41(i)(4)(A)(ii) an amount equal to the 
     payroll tax credit portion determined under section 41(i)(2).
       ``(2) Limitation.--The credit allowed by paragraph (1) 
     shall not exceed the tax imposed by subsection (a) for any 
     calendar quarter on the wages paid with respect to the 
     employment of all individuals in the employ of the employer.
       ``(3) Carryover of unused credit.--If the amount of the 
     credit under paragraph (1) exceeds the limitation of 
     paragraph (2) for any calendar quarter, such excess shall be 
     carried to the succeeding calendar quarter and allowed as a 
     credit under paragraph (1) for such quarter.
       ``(4) Deduction allowed for credited amounts.--The credit 
     allowed under paragraph (1) shall not be taken into account 
     for purposes of determining the amount of any deduction 
     allowed under chapter 1 for taxes imposed under subsection 
     (a).''.
       (3) Effective date.--The amendments made by this subsection 
     shall apply to credits determined for taxable years beginning 
     after December 31, 2013.

[[Page 7837]]

       (c) Credit Allowed Against Alternative Minimum Tax.--
       (1) In general.--Subparagraph (B) of section 38(c)(4) is 
     amended--
       (A) by redesignating clauses (ii), (iii), (iv), (v), (vi), 
     (vii), (viii), and (ix) as clauses (iii), (iv), (v), (vi), 
     (vii), (viii), (ix), and (x), respectively, and
       (B) by inserting after clause (i) the following new clause:
       ``(ii) the credit determined under section 41 with respect 
     to an eligible small business (as defined in paragraph 
     (5)(C), after application of rules similar to the rules of 
     paragraph (5)(D)),''.
       (2) Effective date.--The amendments made by this subsection 
     shall apply to credits determined for taxable years beginning 
     after December 31, 2013, and to carrybacks of such credits.

     SEC. 112. EXTENSION AND MODIFICATION 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, 2016''.
       (b) Temporary Minimum Credit Rate for Non-federally 
     Subsidized Existing Buildings.--Subsection (b) of section 42 
     is amended by redesignating paragraph (3) as paragraph (4) 
     and by inserting after paragraph (2) the following new 
     paragraph:
       ``(3) Temporary minimum credit rate for non-federally 
     subsidized existing buildings.--In the case of any existing 
     building--
       ``(A) which is placed in service by the taxpayer after the 
     date of the enactment of the EXPIRE Act of 2014 with respect 
     to housing credit dollar amount allocations made before 
     January 1, 2016, and
       ``(B) which is not federally subsidized for the taxable 
     year,
     the applicable percentage shall not be less than 4 
     percent.''.
       (c) Effective Date.--The amendments 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, 2016''.
       (b) Effective Date.--The amendments 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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 115. EXTENSION AND MODIFICATION OF NEW MARKETS TAX 
                   CREDIT.

       (a) In General.--Subparagraph (G) of section 45D(f)(1) is 
     amended by striking ``and 2013'' and inserting ``2013, 2014, 
     and 2015''.
       (b) Carryover of Unused Limitation.--Paragraph (3) of 
     section 45D(f) is amended by striking ``2018'' and inserting 
     ``2020''.
       (c) Allocations Designated for Areas Impacted by Decline in 
     Manufacturing.--Paragraph (3) of section 45D(f), as amended 
     by subsection (b), is amended--
       (1) by striking ``If the new markets tax credit 
     limitation'' and inserting the following:
       ``(A) In general.--If the new markets tax credit 
     limitation'',
       (2) by striking ``No'' in the last sentence and inserting 
     ``Except as provided in subparagraph (B), no'', and
       (3) by adding at the end, the following new subparagraph:
       ``(B) Certain amounts available for areas impacted by 
     decline in manufacturing.--Any amount carried to a calendar 
     year after the year described in the second sentence of 
     subparagraph (A) shall be available only for allocation to 
     qualified community development entities a significant 
     mission of which is providing investments and services to 
     persons in the trade or business of manufacturing products in 
     communities which have suffered major manufacturing job 
     losses or a major manufacturing job loss event, as designated 
     by the Secretary.''.
       (d) 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, 
     2016''.
       (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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

     SEC. 118. EXTENSION AND MODIFICATION 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, 2015''.
       (b) Applicability to All Employers.--
       (1) In general.--Subsection (a) of section 45P is amended 
     by striking ``, in the case of an eligible small business 
     employer''.
       (2) Conforming amendment.--Paragraph (3) of section 45P(b) 
     is amended to read as follows:
       ``(3) Controlled groups.--All persons treated as a single 
     employer under subsection (b), (c), (m), or (o) of section 
     414 shall be treated as a single employer.''.
       (c) Expansion to 100 Percent of Eligible Differential Wage 
     Payments.--Subsection (a) of section 45P is amended by 
     striking ``20 percent of the sum'' and inserting ``the sum''.
       (d) Effective Date.--The amendments made by this section 
     shall apply to payments made after December 31, 2013.

     SEC. 119. EXTENSION AND MODIFICATION 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, 2015''.
       (b) Credit for Hiring Long-term Unemployment Recipients.--
       (1) In general.--Paragraph (1) of section 51(d) is amended 
     by striking ``or'' at the end of subparagraph (H), by 
     striking the period at the end of subparagraph (I) and 
     inserting ``, or'', and by adding at the end the following 
     new subparagraph:
       ``(J) a qualified long-term unemployment recipient.''.
       (2) Qualified long-term unemployment recipient.--Subsection 
     (d) of section 51 is amended by adding at the end the 
     following new paragraph:
       ``(15) Qualified long-term unemployment recipient.--The 
     term `qualified long-term unemployment recipient' means any 
     individual who is certified by the designated local agency as 
     being in a period of unemployment which--
       ``(A) is not less than 27 consecutive weeks, and
       ``(B) includes a period in which the individual was 
     receiving unemployment compensation under State or Federal 
     law.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to individuals who begin work for the employer 
     after December 31, 2013.

     SEC. 120. EXTENSION AND MODIFICATION OF QUALIFIED ZONE 
                   ACADEMY BONDS.

       (a) Extension.--Paragraph (1) of section 54E(c) is amended 
     by striking ``and 2013'' and inserting ``2013, 2014, and 
     2015''.
       (b) Reduction of Private Business Contribution 
     Requirement.--Subsection (b) of section 54E is amended by 
     striking ``10 percent'' and inserting ``5 percent''.
       (c) Effective Date.--The amendments made by subsections (a) 
     and (b) shall apply to obligations issued after December 31, 
     2013.
       (d) Technical Correction and Conforming Amendment.--
       (1) In general.--Clause (iii) of section 6431(f)(3)(A) is 
     amended--
       (A) by striking ``2011'' and inserting ``years after 
     2010'', and
       (B) by striking ``of such allocation'' and inserting ``of 
     any such allocation''.
       (2) Effective date.--The amendments made by this subsection 
     shall take effect as if included in section 310 of the 
     American Taxpayer Relief Act of 2012.

     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, 2016'', and
       (2) by striking ``December 31, 2013'' in subclause (II) and 
     inserting ``December 31, 2015''.
       (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, 2016''.
       (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, 2015''.
       (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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

[[Page 7838]]



     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, 2017'', and
       (2) by striking ``January 1, 2014'' each place it appears 
     and inserting ``January 1, 2016''.
       (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, 2016 
     (January 1, 2017''.
       (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, 2016''.
       (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, and, in the case of 
     round 4 extension property, shall be computed separately with 
     respect to round 4 extension property placed in service 
     before January 1, 2015 (January 1, 2016, in the case of 
     property described in subparagraph (B) or (C) of paragraph 
     (2)) and with respect to other 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 EXPIRE 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, 2016''.
       (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, 2016''.
       (3) Subparagraph (C) of section 168(n)(2) is amended by 
     striking ``January 1, 2014'' and inserting ``January 1, 
     2016''.
       (4) Subparagraph (D) of section 1400L(b)(2) is amended by 
     striking ``January 1, 2014'' and inserting ``January 1, 
     2016''.
       (5) Subparagraph (B) of section 1400N(d)(3) is amended by 
     striking ``January 1, 2014'' and inserting ``January 1, 
     2016''.
       (e) Technical Amendment Relating to Section 331 of the 
     American Taxpayer Relief Act of 2012.--
       (1) In general.--Clause (iii) of section 168(k)(4)(J) is 
     amended by striking ``any taxable year'' and inserting ``its 
     first taxable year''.
       (2) Effective date.--The amendment made by this subsection 
     shall take effect as if included in the provision of the 
     American Taxpayer Relief Act of 2012 to which it relates.
       (f) Effective Date.--Except as provided in subsection 
     (e)(2), 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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to contributions made after December 31, 2013.

     SEC. 127. EXTENSION AND MODIFICATION 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 2016'', and
       (B) by striking ``2013'' in subparagraph (C) and inserting 
     ``2015''.
       (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 2016'', and
       (B) by striking ``2013'' in subparagraph (C) and inserting 
     ``2015''.
       (b) Computer Software.--Section 179(d)(1)(A)(ii) is amended 
     by striking ``2014'' and inserting ``2016''.
       (c) Election.--Section 179(c)(2) is amended by striking 
     ``2014'' and inserting ``2016''.
       (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 2016''.
       (2) Carryover limitation.--
       (A) In general.--Section 179(f)(4) is amended by striking 
     ``2013'' each place it appears and inserting ``2015''.
       (B) Conforming amendment.--The heading of subparagraph (C) 
     of section 179(f)(4) is amended by striking ``2011 and 2012'' 
     and inserting ``2011, 2012, 2013, and 2014''.
       (e) Adjustment for Inflation.--Subsection (b) of section 
     179 of the Internal Revenue Code of 1986 is amended by adding 
     at the end the following new paragraph:
       ``(6) Inflation adjustment.--
       ``(A) In general.--In the case of any taxable year 
     beginning after 2013, the $500,000 amount in paragraph (1)(B) 
     and the $2,000,000 amount in paragraph (2)(B) shall each be 
     increased by an amount equal to--
       ``(i) such dollar amount, multiplied by
       ``(ii) the cost-of-living adjustment determined under 
     section 1(f)(3) for the calendar year in which the taxable 
     year begins, by substituting `calendar year 2012' for 
     `calendar year 1992' in subparagraph (B) thereof.
       ``(B) Rounding.--
       ``(i) Dollar limitation.--If the amount in paragraph (1)(B) 
     as increased under subparagraph (A) is not a multiple of 
     $1,000, such amount shall be rounded to the nearest multiple 
     of $1,000.
       ``(ii) Phaseout amount.--If the amount in paragraph (2)(B) 
     as increased under subparagraph (A) is not a multiple of 
     $10,000, such amount shall be rounded to the nearest multiple 
     of $10,000.''.
       (f) 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, 2015''.
       (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; SPECIAL 
                   EXPENSING FOR LIVE THEATRICAL PRODUCTIONS.

       (a) In General.--Subsection (f) of section 181 is amended 
     by striking ``December 31, 2013'' and inserting ``December 
     31, 2015''.
       (b) Application to Live Productions.--
       (1) In general.--Paragraph (1) of section 181(a) is amended 
     by inserting ``, and any qualified live theatrical 
     production,'' after ``any qualified film or television 
     production''.
       (2) Conforming amendments.--Section 181 is amended--
       (A) by inserting ``or any qualified live theatrical 
     production'' after ``qualified film or television 
     production'' each place it appears in subsections (a)(2), 
     (b), and (c)(1),
       (B) by inserting ``or qualified live theatrical 
     productions'' after ``qualified film or television 
     productions'' in subsection (f), and
       (C) by inserting ``and live theatrical'' after ``film and 
     television'' in the heading.
       (3) Clerical amendment.--The item relating to section 181 
     in the table of sections for part VI of subchapter B of 
     chapter 1 is amended to read as follows:

``Sec. 181. Treatment of certain qualified film and television and live 
              theatrical productions.''.

       (c) Qualified Live Theatrical Production.--Section 181 is 
     amended--
       (1) by redesignating subsections (e) and (f), as amended by 
     subsections (a) and (b), as subsections (f) and (g), 
     respectively, and
       (2) by inserting after subsection (d) the following new 
     subsection:
       ``(e) Qualified Live Theatrical Production.--For purposes 
     of this section--
       ``(1) In general.--The term `qualified live theatrical 
     production' means any production described in paragraph (2) 
     if 75 percent of the total compensation of the production is 
     qualified compensation (as defined in subsection (d)(3)).
       ``(2) Production.--
       ``(A) In general.--A production is described in this 
     paragraph if such production is a live staged production of a 
     play (with or without music) which is derived from a written 
     book or script and is produced or presented by a taxable 
     entity in any venue which has an audience capacity of not 
     more than 3,000 or a series of venues the majority of which 
     have an audience capacity of not more than 3,000.
       ``(B) Touring companies, etc.--In the case of multiple live 
     staged productions--

[[Page 7839]]

       ``(i) for which the election under this section would be 
     allowable to the same taxpayer, and
       ``(ii) which are--

       ``(I) separate phases of a production, or
       ``(II) separate simultaneous stagings of the same 
     production in different geographical locations (not including 
     multiple performance locations of any one touring 
     production),

     each such live staged production shall be treated as a 
     separate production.
       ``(C) Phase.--For purposes of subparagraph (B), the term 
     `phase' with respect to any qualified live theatrical 
     production refers to each of the following, but only if each 
     of the following is treated by the taxpayer as a separate 
     activity for all purposes of this title:
       ``(i) The initial staging of a live theatrical production.
       ``(ii) Subsequent additional stagings or touring of such 
     production which are produced by the same producer as the 
     initial staging.
       ``(D) Exception.--A production is not described in this 
     paragraph if such production includes or consists of any 
     performance of conduct described in section 2257(h)(1) of 
     title 18, United States Code.''.
       (d) Effective Dates.--
       (1) In general.--The amendments made by this section shall 
     apply to productions commencing after December 31, 2013.
       (2) Commencement.--For purposes of paragraph (1), the date 
     on which a qualified live theatrical production commences is 
     the date of the first public performance of such production 
     for a paying audience.

     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 10 taxable years'', and
       (2) by striking ``January 1, 2014'' and inserting ``January 
     1, 2016''.
       (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, 2015''.
       (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, 2015''.
       (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, 2015''.
       (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, 2016'', and
       (2) by striking ``December 31, 2013'' and inserting 
     ``December 31, 2015''.
       (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, 2016''.
       (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, 2016''.
       (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, 2016'', and
       (2) by striking ``and 2013'' in the heading and inserting 
     ``2013, 2014, and 2015''.
       (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, 2015''.
       (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, 2014, or 2015'', and
       (2) by striking ``2012 and 2013'' in the heading and 
     inserting ``2012, 2013, 2014, and 2015''.
       (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, 2015''.
       (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) Technical Amendments Relating to Section 753 of the Tax 
     Relief, Unemployment Insurance Reauthorization, and Job 
     Creation Act of 2010; Extension of Nonrecognition of Gain on 
     Rollover of Empowerment Zone Investments.--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) `January 1, 2016' were substituted for `January 1, 
     2010' each place it appears.''.
       (d) Effective Dates.--
       (1) In general.--The amendment made by subsection (a) shall 
     apply to periods after December 31, 2013.
       (2) Technical amendments.--The amendments made by 
     subsection (c) shall take effect as if included in section 
     753 of the Tax Relief, Unemployment Insurance 
     Reauthorization, and Job Creation Act of 2010.

     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, 2016''.
       (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, 2016'',
       (2) by striking ``first 8 taxable years'' in paragraph (1) 
     and inserting ``first 10 taxable years'', and
       (3) by striking ``first 2 taxable years'' in paragraph (2) 
     and inserting ``first 4 taxable years''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2013.

                     PART III--ENERGY TAX EXTENDERS

     SEC. 151. EXTENSION AND MODIFICATION 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, 2015''.
       (b) Updated Energy Star Requirements for Windows, Doors, 
     Skylights, and Roofing.--

[[Page 7840]]

       (1) In general.--Paragraph (1) of section 25C(c) is amended 
     by striking ``which meets'' and all that follows through 
     ``requirements)''.
       (2) Energy efficient building envelope component.--
     Subsection (c) of section 25C is amended by redesignating 
     paragraphs (2) and (3) as paragraphs (3) and (4), 
     respectively, and by inserting after paragraph (1) the 
     following new paragraph:
       ``(2) Energy efficient building envelope component.--The 
     term `energy efficient building envelope component' means a 
     building envelope component which meets--
       ``(A) applicable Energy Star program requirements, in the 
     case of a roof or roof products,
       ``(B) version 6.0 Energy Star program requirements, in the 
     case of an exterior window, a skylight, or an exterior door, 
     and
       ``(C) the prescriptive criteria for such component 
     established by the 2009 International Energy Conservation 
     Code, as such Code (including supplements) is in effect on 
     the date of the enactment of the American Recovery and 
     Reinvestment Tax Act of 2009, in the case of any other 
     component.''.
       (3) Conforming amendment.--Subparagraph (D) of section 
     25C(c)(3), as so redesignated, is amended to read as follows:
       ``(D) any roof or roof products which are installed on a 
     dwelling unit and are specifically and primarily designed to 
     reduce the heat gain of such dwelling unit.''.
       (c) Separate Standards for Tankless and Storage Water 
     Heaters.--
       (1) In general.--Subparagraph (D) of section 25C(d)(3) is 
     amended by striking ``which has either'' and all that follows 
     and inserting ``which has either--
       ``(i) in the case of a storage water heater, an energy 
     factor of at least 0.80 or a thermal efficiency of at least 
     90 percent, and
       ``(ii) in the case of any other water heater, an energy 
     factor of at least 0.90 or a thermal efficiency of at least 
     90 percent, and''.
       (2) Storage water heaters.--Paragraph (3) of section 25C(d) 
     is amended by adding at the end the following flush sentence:
     ``For purposes of subparagraph (D)(i), the term `storage 
     water heater' means a water heater that has a water storage 
     capacity of more than 20 gallons but not more than 55 
     gallons.''.
       (d) Modification of Testing Standards for Biomass Stoves.--
     Subparagraph (E) of section 25C(d)(3) is amended by inserting 
     before the period the following: ``, when tested using the 
     higher heating value of the fuel and in accordance with the 
     Canadian Standards Administration B415.1 test protocol''.
       (e) Separate Standard for Oil Hot Water Boilers.--Paragraph 
     (4) of section 25C(d) is amended by striking ``95'' and 
     inserting ``95 (90 in the case of an oil hot water boiler)''.
       (f) Effective Date.--The amendments made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 152. EXTENSION OF CREDIT FOR 2-WHEELED PLUG-IN ELECTRIC 
                   VEHICLES.

       (a) In General.--Subparagraph (E) of section 30D(g)(3) is 
     amended by striking ``January 1, 2014'' and inserting 
     ``January 1, 2014 (January 1, 2016, in the case of a vehicle 
     that has 2 wheels).''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to vehicles acquired after December 31, 2013.

     SEC. 153. 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, 2016''.
       (b) Effective Date.--The amendment made by this subsection 
     shall apply to qualified second generation biofuel production 
     after December 31, 2013.

     SEC. 154. 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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to fuel sold or used after December 31, 2013.

     SEC. 155. EXTENSION AND MODIFICATION 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 ``10-year period''.
       (b) Application to New Leases or Subleases.--Paragraph (10) 
     of section 45(d) is amended by inserting before the period 
     the following: ``, and any new lease or sublease of such a 
     facility''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to coal produced after December 31, 2013.

     SEC. 156. 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, 2016'':
       (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, 2016''.
       (c) Effective Dates.--The amendments made by this section 
     shall take effect on January 1, 2014.

     SEC. 157. 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, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to homes acquired after December 31, 2013.

     SEC. 158. 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, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

     SEC. 159. EXTENSION AND MODIFICATION 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, 2015''.
       (b) Allocations to Indian Tribal Governments.--Paragraph 
     (4) of section 179D(d) is amended by striking ``or local'' 
     and inserting ``local, or Indian tribal''.
       (c) Allocations to Certain Nonprofit Organizations.--
       (1) In general.--Paragraph (4) of section 179D(d), as 
     amended by subsection (b), is amended by inserting ``, or by 
     an organization that is described in section 501(c)(3) and 
     exempt from tax under section 501(a)'' after ``political 
     subdivision thereof''.
       (2) Clerical amendment.--The heading of paragraph (4) of 
     section 179D(d) is amended by inserting ``and property held 
     by certain non-profits'' after ``public property''.
       (d) Updated ASHRAE Standards for 2015.--
       (1) In general.--Paragraph (1) of section 179D(c) is 
     amended by striking ``Standard 90.1-2001'' each place it 
     appears and inserting ``Standard 90.1-2007''.
       (2) Conforming amendments.--
       (A) Paragraph (2) of section 179D(c) is amended to read as 
     follows:
       ``(2) Standard 90.1-2007.--The term `Standard 90.1-2007' 
     means Standard 90.1-2007 of the American Society of Heating, 
     Refrigerating, and Air Conditioning Engineers and the 
     Illuminating Engineering Society of North America (as in 
     effect on the day before the date of the adoption of Standard 
     90.1-2010 of such Societies).''.
       (B) Subsection (f) of section 179D is amended by striking 
     ``Standard 90.1-2001'' each place it appears in paragraphs 
     (1) and (2)(C)(i) and inserting ``Standard 90.1-2007''.
       (C) Paragraph (1) of section 179D(f) is amended--
       (i) by striking ``Table 9.3.1.1'' and inserting ``Table 
     9.5.1'', and
       (ii) by striking ``Table 9.3.1.2'' and inserting ``Table 
     9.6.1''.
       (3) Effective date.--The amendments made by this paragraph 
     shall apply to property placed in service after December 31, 
     2014.
       (e) Effective Date.--Except as provided in subsection 
     (d)(3), the amendments made by this section shall apply to 
     property placed in service after December 31, 2013.

     SEC. 160. 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, 
     2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to dispositions after December 31, 2013.

     SEC. 161. 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, 2015''.
       (2) Subparagraph (B) of section 6427(e)(6) is amended by 
     striking ``December 31, 2013'' and inserting ``December 31, 
     2015''.
       (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, 2015''.
       (2) Outlay payments for alternative fuels.--Subparagraph 
     (C) of section 6427(e)(6) is amended by striking ``December 
     31, 2013'' and inserting ``December 31, 2015''.
       (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--

[[Page 7841]]

       (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 fuels 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.

                Subtitle B--Provisions Expiring in 2014

                      PART I--ENERGY TAX EXTENDERS

     SEC. 171. EXTENSION OF CREDIT FOR NEW QUALIFIED FUEL CELL 
                   MOTOR VEHICLES.

       (a) In General.--Paragraph (1) of section 30B(k) is amended 
     by striking ``December 31, 2014'' and inserting ``December 
     31, 2015''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property purchased after December 31, 2014.

     SEC. 172. 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, 2015.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2013.

 PART II--EXTENDERS RELATING TO MULTIEMPLOYER DEFINED BENEFIT PENSION 
                                 PLANS

     SEC. 181. 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. 182. EXTENSION OF FUNDING IMPROVEMENT AND REHABILITATION 
                   PLAN 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.

                     Subtitle C--Revenue Provisions

     SEC. 191. PENALTY FOR FAILURE TO MEET DUE DILIGENCE 
                   REQUIREMENTS FOR THE CHILD TAX CREDIT.

       (a) In General.--Section 6695 is amended by adding at the 
     end the following new subsection:
       ``(h) Failure to Be Diligent in Determining Eligibility for 
     Child Tax Credit.--Any person who is a tax return preparer 
     with respect to any return or claim for refund who fails to 
     comply with due diligence requirements imposed by the 
     Secretary by regulations with respect to determining 
     eligibility for, or the amount of, the credit allowable by 
     section 24 shall pay a penalty of $500 for each such 
     failure.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 192. 100 PERCENT CONTINUOUS LEVY ON PAYMENT TO MEDICARE 
                   PROVIDERS AND SUPPLIERS.

       (a) In General.--Paragraph (3) of section 6331(h) is 
     amended by striking the period at the end and inserting ``, 
     or to a Medicare provider or supplier under title XVIII of 
     the Social Security Act.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to payments made on or after the date which is 
     180 days after the date of the enactment of this Act.

     SEC. 193. EXCLUSION FROM GROSS INCOME OF CERTAIN CLEAN COAL 
                   POWER GRANTS TO NON-CORPORATE TAXPAYERS.

       (a) General Rule.--In the case of an eligible taxpayer 
     other than a corporation, gross income for purposes of the 
     Internal Revenue Code of 1986 shall not include any amount 
     received under section 402 of the Energy Policy Act of 2005.
       (b) Reduction in Basis.--The basis of any property subject 
     to the allowance for depreciation under the Internal Revenue 
     Code of 1986 which is acquired with any amount to which 
     subsection (a) applies during the 12-month period beginning 
     on the day such amount is received shall be reduced by an 
     amount equal to such amount. The excess (if any) of such 
     amount over the amount of the reduction under the preceding 
     sentence shall be applied to the reduction (as of the last 
     day of the period specified in the preceding sentence) of the 
     basis of any other property held by the taxpayer. The 
     particular properties to which the reductions required by 
     this subsection are allocated shall be determined by the 
     Secretary of the Treasury (or the Secretary's delegate) under 
     regulations similar to the regulations under section 
     362(c)(2) of such Code.
       (c) Limitation to Amounts Which Would Be Contributions to 
     Capital.--Subsection (a) shall not apply to any amount unless 
     such amount, if received by a corporation, would be excluded 
     from gross income under section 118 of the Internal Revenue 
     Code of 1986.
       (d) Eligible Taxpayer.--For purposes of this section, with 
     respect to any amount received under section 402 of the 
     Energy Policy Act of 2005, the term ``eligible taxpayer'' 
     means a taxpayer that makes a payment to the Secretary of the 
     Treasury (or the Secretary's delegate) equal to 1.18 percent 
     of the amount so received. Such payment shall be made at such 
     time and in such manner as such Secretary (or the Secretary's 
     delegate) shall prescribe. In the case of a partnership, such 
     Secretary (or the Secretary's delegate) shall prescribe 
     regulations to determine the allocation of such payment 
     amount among the partners.
       (e) Effective Date.--This section shall apply to amounts 
     received under section 402 of the Energy Policy Act of 2005 
     in taxable years beginning after December 31, 2011.

     SEC. 194. REFORM OF RULES RELATING TO QUALIFIED TAX 
                   COLLECTION CONTRACTS.

       (a) Requirement to Collect Certain Inactive Tax Receivables 
     Under Qualified Tax Collection Contracts.--Section 6306 is 
     amended by redesignating subsections (c) through (f) as 
     subsections (d) through (g), respectively, and by inserting 
     after subsection (b) the following new subsection:
       ``(c) Collection of Inactive Tax Receivables.--
       ``(1) In general.--Notwithstanding any other provision of 
     law, the Secretary shall enter into one or more qualified tax 
     collection contracts for the collection of all outstanding 
     inactive tax receivables.
       ``(2) Inactive tax receivables.--For purposes of this 
     section--
       ``(A) In general.--The term `inactive tax receivable' means 
     any tax receivable if--
       ``(i) at any time after assessment, the Internal Revenue 
     Service removes such receivable from the active inventory for 
     lack of resources or inability to locate the taxpayer,
       ``(ii) more than \1/3\ of the period of the applicable 
     statute of limitation has lapsed and such receivable has not 
     been assigned for collection to any employee of the Internal 
     Revenue Service, or
       ``(iii) in the case of a receivable which has been assigned 
     for collection, more than 365 days have passed without 
     interaction with the taxpayer or a third party for purposes 
     of furthering the collection of such receivable.
       ``(B) Tax receivable.--The term `tax receivable' means any 
     outstanding assessment which the Internal Revenue Service 
     includes in potentially collectible inventory.''.
       (b) Certain Tax Receivables Not Eligible for Collection 
     Under Qualified Tax Collection Contracts.--Section 6306, as 
     amended by subsection (a), is amended by redesignating 
     subsections (d) through (g) as subsections (e) through (h), 
     respectively, and by inserting after subsection (c) the 
     following new subsection:
       ``(d) Certain Tax Receivables Not Eligible for Collection 
     Under Qualified Tax Collections Contracts.--A tax receivable 
     shall not be eligible for collection pursuant to a qualified 
     tax collection contract if such receivable--

[[Page 7842]]

       ``(1) is subject to a pending or active offer-in-compromise 
     or installment agreement,
       ``(2) is classified as an innocent spouse case,
       ``(3) involves a taxpayer identified by the Secretary as 
     being--
       ``(A) deceased,
       ``(B) under the age of 18,
       ``(C) in a designated combat zone, or
       ``(D) a victim of tax-related identity theft,
       ``(4) is currently under examination, litigation, criminal 
     investigation, or levy, or
       ``(5) is currently subject to a proper exercise of a right 
     of appeal under this title.''.
       (c) Contracting Priority.--Section 6306, as amended by the 
     preceding provisions of this section, is amended by 
     redesignating subsection (h) as subsection (i) and by 
     inserting after subsection (g) the following new subsection:
       ``(h) Contracting Priority.--In contracting for the 
     services of any person under this section, the Secretary 
     shall utilize private collection contractors and debt 
     collection centers on the schedule required under section 
     3711(g) of title 31, United States Code, including the 
     technology and communications infrastructure established 
     therein, to the extent such private collection contractors 
     and debt collection centers are appropriate to carry out the 
     purposes of this section.''.
       (d) Disclosure of Return Information.--Section 6103(k) is 
     amended by adding at the end the following new paragraph:
       ``(11) Qualified tax collection contractors.--Persons 
     providing services pursuant to a qualified tax collection 
     contract under section 6306 may, if speaking to a person who 
     has identified himself or herself as having the name of the 
     taxpayer to which a tax receivable (within the meaning of 
     such section) relates, identify themselves as contractors of 
     the Internal Revenue Service and disclose the business name 
     of the contractor, and the nature, subject, and reason for 
     the contact. Disclosures under this paragraph shall be made 
     only in such situations and under such conditions as have 
     been approved by the Secretary.''.
       (e) Taxpayers Affected by Federally Declared Disasters.--
     Section 6306, as amended by the preceding provisions of this 
     section, is amended by redesignating subsection (i) as 
     subsection (j) and by inserting after subsection (h) the 
     following new subsection:
       ``(i) Taxpayers in Presidentially Declared Disaster 
     Areas.--The Secretary may prescribe procedures under which a 
     taxpayer determined to be affected by a Federally declared 
     disaster (as defined by section 165(h)(3)(C)) may request--
       ``(1) relief from immediate collection measures by 
     contractors under this section, and
       ``(2) a return of the inactive tax receivable to the 
     inventory of the Internal Revenue Service to be collected by 
     an employee thereof.''.
       (f) Report to Congress.--
       (1) In general.--Section 6306, as amended by the preceding 
     provisions of this section, is amended by redesignating 
     subsection (j) as subsection (k) and by inserting after 
     subsection (i) the following new subsection:
       ``(j) Report to Congress.--Not later than 90 days after the 
     last day of each fiscal year (beginning with the first such 
     fiscal year ending after the date of the enactment of this 
     subsection), the Secretary shall submit to the Committee on 
     Ways and Means of the House of Representatives and the 
     Committee on Finance of the Senate a report with respect to 
     qualified tax collection contracts under this section which 
     shall include--
       ``(1) annually, with respect to such fiscal year--
       ``(A) the total number and amount of tax receivables 
     provided to each contractor for collection under this 
     section,
       ``(B) the total amounts collected (and amounts of 
     installment agreements entered into under subsection 
     (b)(1)(B)) with respect to each contractor and the collection 
     costs incurred (directly and indirectly) by the Internal 
     Revenue Service with respect to such amounts,
       ``(C) the impact of such contracts on the total number and 
     amount of unpaid assessments, and on the number and amount of 
     assessments collected by Internal Revenue Service personnel 
     after initial contact by a contractor,
       ``(D) the amount of fees retained by the Secretary under 
     subsection (e) and a description of the use of such funds, 
     and
       ``(E) a disclosure safeguard report in a form similar to 
     that required under section 6103(p)(5), and
       ``(2) biannually (beginning with the second report 
     submitted under this subsection)--
       ``(A) an independent evaluation of contractor performance, 
     and
       ``(B) a measurement plan that includes a comparison of the 
     best practices used by the private collectors to the 
     collection techniques used by the Internal Revenue Service 
     and mechanisms to identify and capture information on 
     successful collection techniques used by the contractors that 
     could be adopted by the Internal Revenue Service.''.
       (2) Repeal of existing reporting requirements with respect 
     to qualified tax collection contracts.--Section 881 of the 
     American Jobs Creation Act of 2004 is amended by striking 
     subsection (e).
       (g) Effective Dates.--
       (1) In general.--The amendments made by subsections (a) and 
     (b) shall apply to tax receivables identified by the 
     Secretary after the date of the enactment of this Act.
       (2) Contracting priority.--The Secretary shall begin 
     entering into contracts and agreements as described in the 
     amendment made by subsection (c) within 3 months after the 
     date of the enactment of this Act.
       (3) Disclosures.--The amendment made by subsection (d) 
     shall apply to disclosures made after the date of the 
     enactment of this Act.
       (4) Procedures; report to congress.--The amendments made by 
     subsections (e) and (f) shall take effect on the date of the 
     enactment of this Act.

     SEC. 195. SPECIAL COMPLIANCE PERSONNEL PROGRAM.

       (a) In General.--Subsection (e) of section 6306, as 
     redesignated by section 194, is amended by striking ``for 
     collection enforcement activities of the Internal Revenue 
     Service'' in paragraph (2) and inserting ``to fund the 
     special compliance personnel program account under section 
     6307''.
       (b) Special Compliance Personnel Program Account.--
     Subchapter A of chapter 64 is amended by adding at the end 
     the following new section:

     ``SEC. 6307. SPECIAL COMPLIANCE PERSONNEL PROGRAM ACCOUNT.

       ``(a) Establishment of a Special Compliance Personnel 
     Program Account.--The Secretary shall establish an account 
     within the Department for carrying out a program consisting 
     of the hiring, training, and employment of special compliance 
     personnel, and shall transfer to such account from time to 
     time amounts retained by the Secretary under section 
     6306(e)(2).
       ``(b) Restrictions.--The program described in subsection 
     (a) shall be subject to the following restrictions:
       ``(1) No funds shall be transferred to such account except 
     as described in subsection (a).
       ``(2) No other funds from any other source shall be 
     expended for special compliance personnel employed under such 
     program, and no funds from such account shall be expended for 
     the hiring of any personnel other than special compliance 
     personnel.
       ``(3) Notwithstanding any other authority, the Secretary is 
     prohibited from spending funds out of such account for any 
     purpose other than for costs under such program associated 
     with the employment of special compliance personnel and the 
     retraining and reassignment of current noncollections 
     personnel as special compliance personnel, and to reimburse 
     the Internal Revenue Service or other government agencies for 
     the cost of administering qualified tax collection contracts 
     under section 6306.
       ``(c) Reporting.--Not later than March of each year, the 
     Commissioner of Internal Revenue shall submit a report to the 
     Committees on Finance and Appropriations of the Senate and 
     the Committees on Ways and Means and Appropriations of the 
     House of Representatives consisting of the following:
       ``(1) For the preceding fiscal year, all funds received in 
     the account established under subsection (a), administrative 
     and program costs for the program described in such 
     subsection, the number of special compliance personnel hired 
     and employed under the program, and the amount of revenue 
     actually collected by such personnel.
       ``(2) For the current fiscal year, all actual and estimated 
     funds received or to be received in the account, all actual 
     and estimated administrative and program costs, the number of 
     all actual and estimated special compliance personnel hired 
     and employed under the program, and the actual and estimated 
     revenue actually collected or to be collected by such 
     personnel.
       ``(3) For the following fiscal year, an estimate of all 
     funds to be received in the account, all estimated 
     administrative and program costs, the estimated number of 
     special compliance personnel hired and employed under the 
     program, and the estimated revenue to be collected by such 
     personnel.
       ``(d) Definitions.--For purposes of this section--
       ``(1) Special compliance personnel.--The term `special 
     compliance personnel' means individuals employed by the 
     Internal Revenue Service as field function collection 
     officers or in a similar position, or employed to collect 
     taxes using the automated collection system or an equivalent 
     replacement system.
       ``(2) Program costs.--The term `program costs' means--
       ``(A) total salaries (including locality pay and bonuses), 
     benefits, and employment taxes for special compliance 
     personnel employed or trained under the program described in 
     subsection (a), and
       ``(B) direct overhead costs, salaries, benefits, and 
     employment taxes relating to support staff, rental payments, 
     office equipment and furniture, travel, data processing 
     services, vehicle costs, utilities, telecommunications, 
     postage, printing and reproduction, supplies and materials, 
     lands and structures, insurance claims, and indemnities for 
     special compliance personnel hired and employed under this 
     section.

     For purposes of subparagraph (B), the cost of management and 
     supervision of special compliance personnel shall be taken 
     into account as direct overhead costs to the extent

[[Page 7843]]

     such costs, when included in total program costs under this 
     paragraph, do not represent more than 10 percent of such 
     total costs.''.
       (c) Clerical Amendment.--The table of sections for 
     subchapter A of chapter 64 is amended by inserting after the 
     item relating to section 6306 the following new item:

``Sec. 6307. Special compliance personnel program account.''.
       (d) Effective Date.--The amendment made by subsection (a) 
     shall apply to amounts collected and retained by the 
     Secretary after the date of the enactment of this Act.

     SEC. 196. EXCLUSION OF DIVIDENDS FROM CONTROLLED FOREIGN 
                   CORPORATIONS FROM THE DEFINITION OF PERSONAL 
                   HOLDING COMPANY INCOME FOR PURPOSES OF THE 
                   PERSONAL HOLDING COMPANY RULES.

       (a) In General.--Paragraph (1) of section 543(a) is amended 
     by redesignating subparagraphs (C) and (D) as subparagraphs 
     (D) and (E), respectively, and by inserting after 
     subparagraph (B) the following new subparagraph:
       ``(C) dividends received by a United States shareholder (as 
     defined in section 951(b)) from a controlled foreign 
     corporation (as defined in section 957(a)),''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years ending on or after the date of 
     the enactment of this Act.

     SEC. 197. INFLATION ADJUSTMENT FOR CERTAIN CIVIL PENALTIES 
                   UNDER THE INTERNAL REVENUE CODE OF 1986.

       (a) Failure to File Tax Return or Pay Tax.--Section 6651 is 
     amended by adding at the end the following new subsection:
       ``(i) Adjustment for Inflation.--
       ``(1) In general.--In the case of any return required to be 
     filed in a calendar year beginning after 2014, the $135 
     dollar amount under subsection (a) shall be increased by such 
     dollar amount multiplied by the cost-of-living adjustment 
     determined under section 1(f)(3) determined by substituting 
     `calendar year 2013' for `calendar year 1992' in subparagraph 
     (B) thereof.
       ``(2) Rounding.--If any amount adjusted under paragraph (1) 
     is not a multiple of $5, such amount shall be rounded to the 
     next lowest multiple of $5.''.
       (b) Failure to File Certain Information Returns, 
     Registration Statements, etc.--
       (1) In general.--Section 6652(c) is amended by adding at 
     the end the following new paragraph:
       ``(6) Adjustment for inflation.--
       ``(A) In general.--In the case of any failure relating to a 
     return required to be filed in a calendar year beginning 
     after 2014, each of the dollar amounts under paragraphs (1), 
     (2), and (3) shall be increased by such dollar amount 
     multiplied by the cost-of-living adjustment determined under 
     section 1(f)(3) determined by substituting `calendar year 
     2013' for `calendar year 1992' in subparagraph (B) thereof.
       ``(B) Rounding.--If any amount adjusted under subparagraph 
     (A)--
       ``(i) is not less than $5,000 and is not a multiple of 
     $500, such amount shall be rounded to the next lowest 
     multiple of $500, and
       ``(ii) is not described in clause (i) and is not a multiple 
     of $5, such amount shall be rounded to the next lowest 
     multiple of $5.''.
       (2) Conforming amendments.--
       (A) The last sentence of section 6652(c)(1)(A) is amended 
     by striking ``the first sentence of this subparagraph shall 
     be applied by substituting `$100' for `$20' and'' and 
     inserting ``in applying the first sentence of this 
     subparagraph, the amount of the penalty for each day during 
     which a failure continues shall be $100 in lieu of the amount 
     otherwise specified, and''.
       (B) Clause (ii) of section 6652(c)(2)(C) is amended by 
     striking ``the first sentence of paragraph (1)(A)'' and all 
     that follows and inserting ``in applying the first sentence 
     of paragraph (1)(A), the amount of the penalty for each day 
     during which a failure continues shall be $100 in lieu of the 
     amount otherwise specified, and in lieu of applying the 
     second sentence of paragraph (1)(A), the maximum penalty 
     under paragraph (1)(A) shall not exceed $50,000, and''.
       (c) Other Assessable Penalties With Respect to the 
     Preparation of Tax Returns for Other Persons.--Section 6695 
     is amended by adding at the end the following new subsection:
       ``(h) Adjustment for Inflation.--
       ``(1) In general.--In the case of any failure relating to a 
     return or claim for refund filed in a calendar year beginning 
     after 2014, each of the dollar amounts under subsections (a), 
     (b), (c), (d), (e), (f), and (g) shall be increased by such 
     dollar amount multiplied by the cost-of-living adjustment 
     determined under section 1(f)(3) determined by substituting 
     `calendar year 2013' for `calendar year 1992' in subparagraph 
     (B) thereof.
       ``(2) Rounding.--If any amount adjusted under subparagraph 
     (A)--
       ``(A) is not less than $5,000 and is not a multiple of 
     $500, such amount shall be rounded to the next lowest 
     multiple of $500, and
       ``(B) is not described in clause (i) and is not a multiple 
     of $5, such amount shall be rounded to the next lowest 
     multiple of $5.''.
       (d) Failure to File Partnership Return.--Section 6698 is 
     amended by adding at the end the following new subsection:
       ``(e) Adjustment for Inflation.--
       ``(1) In general.--In the case of any return required to be 
     filed in a calendar year beginning after 2014, the $195 
     dollar amount under subsection (b)(1) shall be increased by 
     such dollar amount multiplied by the cost-of-living 
     adjustment determined under section 1(f)(3) determined by 
     substituting `calendar year 2013' for `calendar year 1992' in 
     subparagraph (B) thereof.
       ``(2) Rounding.--If any amount adjusted under paragraph (1) 
     is not a multiple of $5, such amount shall be rounded to the 
     next lowest multiple of $5.''.
       (e) Failure to File S Corporation Return.--Section 6699 is 
     amended by adding at the end the following new subsection:
       ``(e) Adjustment for Inflation.--
       ``(1) In general.--In the case of any return required to be 
     filed in a calendar year beginning after 2014, the $195 
     dollar amount under subsection (b)(1) shall be increased by 
     such dollar amount multiplied by the cost-of-living 
     adjustment determined under section 1(f)(3) determined by 
     substituting `calendar year 2013' for `calendar year 1992' in 
     subparagraph (B) thereof.
       ``(2) Rounding.--If any amount adjusted under paragraph (1) 
     is not a multiple of $5, such amount shall be rounded to the 
     next lowest multiple of $5.''.
       (f) Failure to File Correct Information Returns.--Paragraph 
     (1) of section 6721(f) is amended by striking ``For each 
     fifth calendar year beginning after 2012'' and inserting ``In 
     the case of any failure relating to a return required to be 
     filed in a calendar year beginning after 2014''.
       (g) Failure to Furnish Correct Payee Statements.--Paragraph 
     (1) of section 6722(f) is amended by striking ``For each 
     fifth calendar year beginning after 2012'' and inserting ``In 
     the case of any failure relating to a statement required to 
     be furnished in a calendar year beginning after 2014''.
       (h) Effective Date.--The amendments made by this section 
     shall apply to returns required to be filed after December 
     31, 2014.

                  TITLE II--TAX TECHNICAL CORRECTIONS

     SEC. 201. SHORT TITLE.

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

     SEC. 202. 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. 203. AMENDMENTS RELATING TO AMERICAN TAXPAYER RELIEF ACT 
                   OF 2012.

       (a) 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''.
       (b) Amendments Relating to Section 104.--
       (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''.
       (c) 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. 204. 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.

[[Page 7844]]

       (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 a regulated 
     investment company which, before the date of the enactment of 
     this Act, elected under paragraph (8) of section 852(b) of 
     the Internal Revenue Code of 1986 (as in effect on the date 
     of such election) for any taxable year ending before such 
     date of enactment to treat any loss as arising in the 
     following taxable year, the amendments made by paragraphs (1) 
     and (2) of subsection (c) shall not apply with respect to 
     such election.

     SEC. 205. 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 Amendment Relating to Section 302.--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) 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. 206. 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''.
       (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. 207. 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. 208. 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

[[Page 7845]]

     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 the 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. 209. 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.''.
       (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 for pre-2012 stock.--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 Amendment Relating to Section 108.--Paragraph 
     (2) of section 45(b) is amended by striking ``$3 amount'' and 
     inserting ``$2 amount''.
       (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. 210. 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

[[Page 7846]]

     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) Amendment relating to section 306.--Paragraph (5) of 
     section 168(b) is amended by striking ``(2)(C)'' and 
     inserting ``(2)(D)''.
       (2) 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''.
       (3) 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).
       (4) 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. 211. 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. 212. 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. 213. 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 TIN 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. 214. 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 
     ``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. 215. 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. 216. 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. 217. 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. 218. 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. 219. MODIFICATION OF TREATMENT OF CERTAIN HEALTH 
                   ORGANIZATIONS.

       (a) In General.--Paragraph (5) of section 833(c) is 
     amended--
       (1) by striking ``this section'' and inserting ``paragraphs 
     (2) and (3) of subsection (a)'', and
       (2) by inserting ``and for activities that improve health 
     care quality'' after ``clinical services''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2009.

     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 ``under 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''.

[[Page 7847]]

       (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) Subsection (b) of section 858 is amended by striking 
     ``857(b)(8)'' and inserting ``857(b)(9)''.
       (m) Subparagraph (A) of section 1012(c)(2) is amended by 
     striking ``section 1012'' and inserting ``this section''.
       (n) The heading for section 1394(f) is amended by striking 
     ``Designated Under Section 1391(g)''.
       (o) 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''.
       (p) Subsections (e)(3)(B) and (f)(7)(B) of section 4943 are 
     each amended by striking ``January 1, 1970'' and inserting 
     ``January 1, 1971''.
       (q) Paragraph (2) of section 4982(f) is amended by adding a 
     comma at the end.
       (r) Paragraph (3) of section 6011(e) is amended by striking 
     ``shall require than'' and inserting ``shall require that''.
       (s) Subsection (b) of section 6072 is amended by striking 
     ``6011(e)(2)'' and inserting ``6011(c)(2)''.
       (t) Subsection (d) of section 6104 is amended by 
     redesignating the second paragraph (6) (relating to 
     disclosure of reports by Internal Revenue Service) and third 
     paragraph (6) (relating to application to nonexempt 
     charitable trusts and nonexempt private foundations) as 
     paragraphs (7) and (8), respectively.
       (u) Subsection (c) of section 6662A is amended by striking 
     ``section 6664(d)(2)(A)'' and inserting ``section 
     6664(d)(3)(A)''.
       (v) Subparagraph (FF) of section 6724(d)(2) is amended by 
     striking ``section 6050W(c)'' and inserting ``section 
     6050W(f)''.
       (w) Section 9802 is amended by redesignating the second 
     subsection (f) (relating to genetic information of a fetus or 
     embryo) as subsection (g).
       (x) 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 
     208(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) is 
     amended by striking subparagraph (P), as amended by section 
     213(a)(2).
       (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).
       (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 the 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) by striking clause (iii) of subsection (e)(2)(B) and 
     inserting:
       ``(iii) Modified alternative minimum taxable income.--The 
     term `modified alternative minimum taxable income' means 
     alternative minimum taxable income (as defined in section 
     55(b)(2)) but determined without regard to the alternative 
     tax net operating loss deduction (as defined in section 
     56(d)).'', and
       (ii) 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 (e) 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) 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

[[Page 7848]]

     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 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).
       (B) 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.''.
       (C) Section 1033(h)(3) is amended by striking ``section 
     165(h)(3)(C)'' and inserting ``section 165(i))(5)''.
       (D) Section 6306(i), as added by this Act, 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 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
       (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 
     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), as amended by this Act, 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) 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:
       ``(I) 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 by striking 
     paragraph (2) and by striking ``In general.--'', by 
     redesignating subparagraphs (A) and (B) of paragraph (1) as 
     paragraphs (1) and (2), and by moving paragraphs (1) and (2) 
     (as so redesignated) 2 ems to the left.
       (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:
       ``(ii) Applicable amount.--For purposes of clause (i), the 
     applicable amount is $1,000.''.
       (C) Clause (ii) of section 219(g)(2)(A) is amended by 
     striking ``for a taxable year beginning after December 31, 
     2006''.
       (D) 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.''.
       (E) 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).

[[Page 7849]]

       (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), and 244(a),'' the 
     first place it appears 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).
       (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) 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.''.
       (53) Tax credit employee stock ownership plans.--Section 
     409 is amended by striking subsection (q).
       (54) Catch-up contributions.--Subparagraph (B) of section 
     414(v)(2) is amended to read as follows:
       ``(II)(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.''.
       (55) Employee stock purchase plans.--Section 423(a) is 
     amended by striking ``after December 31, 1963,''.
       (56) Transition rules.--
       (A)(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.1082(c)) is 
     amended by striking subparagraph (B) and by striking ``(A) In 
     general.--''
       (B)(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.1082(h)) is 
     amended by striking subparagraph (G).
       (C)(i) Paragraph (3) of section 436(j) 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.--''.
       (D)(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 (10).
       (57) 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)''.
       (58) 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''.
       (59) 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),

[[Page 7850]]

     by striking paragraph (2), and by redesignating paragraph (3) 
     as paragraph (2).
       (60) Adjustments required by changes in method of 
     accounting.--Section 481(b)(3) is amended by striking 
     subparagraph (C).
       (61) Exemption from tax on corporations, certain trusts, 
     etc.--Section 501 is amended by striking subsection (s).
       (62) 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)''.
       (63) 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.''.
       (64) 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''.
       (65) 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''.
       (66) Income taxes of members of armed forces on death.--
     Section 692(a)(1) is amended by striking ``after June 24, 
     1950''.
       (67) Special rules for computing reserves.--Paragraph (7) 
     of section 807(e) is amended by striking subparagraph (B) and 
     redesignating subparagraph (C) as subparagraph (B).
       (68) 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''.
       (69) Capitalization of certain policy acquisition 
     expenses.--Section 848 is amended by striking subsection (j).
       (70) Tax on nonresident alien individuals.--Subparagraph 
     (B) of section 871(a)(1) is amended to read as follows:
       ``(II) gains described in subsection (b) or (c) of section 
     631,''.
       (71) Limitation on credit.--Paragraph (2) of section 904(d) 
     is amended by striking subparagraph (J).
       (72) 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.''.
       (73) Basis of property acquired from decedent.--Section 
     1014 is amended--
       (A) by striking ``or section 811(j) of the Internal Revenue 
     Code of 1939 where the decedent died after October 21, 1942'' 
     in subsection (a)(2), and
       (B) by striking paragraphs (7) and (8) of subsection (b).
       (74) Adjusted basis.--Section 1016(a) is amended by 
     striking paragraph (12).
       (75) Property on which lessee has made improvements.--
     Section 1019 is amended by striking the last sentence.
       (76) Involuntary conversion.--Section 1033 is amended by 
     striking subsection (j) and by redesignating subsections (k) 
     and (l) as subsections (j) and (k), respectively.
       (77) 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.
       (78) Capital gains and losses.--Section 1222 is amended by 
     striking the last sentence.
       (79) 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.
       (80) 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''.
       (81) 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)''.
       (82) Dealers in securities.--Subsection (b) of section 1236 
     is amended by striking ``after November 19, 1951,''.
       (83) Sale of patents.--Subsection (a) of section 1249 is 
     amended by striking ``after December 31, 1962,''.
       (84) 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).
       (85) 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.''.
       (86) Amount and method of adjustment.--Section 1314 is 
     amended by striking subsection (d) and by redesignating 
     subsection (e) as subsection (d).
       (87) 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.''.
       (88) 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.''.
       (89) 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.''.
       (90) 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.
       (91) 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)''.
       (92) 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).
       (93) 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)''.
       (94) 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)''.
       (95) 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.''.
       (96)(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).

[[Page 7851]]

       (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.
       (97) 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''.
       (98) 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).
       (99) 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 the income of each employer a tax equal to 
     the percentage determined under section 3241 for any calendar 
     year of the compensation paid during such calendar year by 
     such employer for services rendered for 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.
       (100) 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).
       (101) Domestic service employment taxes.--Section 3510(b) 
     is amended by striking paragraph (4).
       (102) 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,''.
       (103) Tax on fuel used in commercial transportation on 
     inland waterways.--Section 4042(b)(2)(A) is amended to read 
     as follows:
       ``(I) The Inland Waterways Trust Fund financing rate is 20 
     cents per gallon.''.
       (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 
     213(a)(2) 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 
     at 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 at 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--

[[Page 7852]]

       (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--HIRE MORE HEROES

     SEC. 301. SHORT TITLE.

       This title may be cited as the ``Hire More Heroes Act of 
     2014''.

     SEC. 302. EMPLOYEES WITH HEALTH COVERAGE UNDER TRICARE OR THE 
                   VETERANS ADMINISTRATION MAY BE EXEMPTED FROM 
                   EMPLOYER MANDATE UNDER PATIENT PROTECTION AND 
                   AFFORDABLE CARE ACT.

       (a) In General.--Section 4980H(c)(2) is amended by adding 
     at the end the following:
       ``(F) Exemption for health coverage under tricare or the 
     veterans administration.--Solely for purposes of determining 
     whether an employer is an applicable large employer under 
     this paragraph for any month, an employer may elect not to 
     take into account for a month as an employee any individual 
     who, for such month, has medical coverage under--
       ``(i) chapter 55 of title 10, United States Code, including 
     coverage under the TRICARE program, or
       ``(ii) under a health care program under chapter 17 or 18 
     of title 38, United States Code, as determined by the 
     Secretary of Veterans Affairs, in coordination with the 
     Secretary of Health and Human Services and the Secretary.''.
       (b) Effective Date.--The amendment made by subsection (a) 
     shall apply to months beginning after December 31, 2013.

                      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).
                                 ______
                                 
  SA 3061. Mr. HATCH submitted an amendment intended to be proposed by 
him to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       At the end of part I of subtitle A of title I, insert the 
     following:

              Subpart B--Certain Provisions Made Permanent

     SEC. 111. PERMANENT EXTENSION OF DEDUCTION FOR CERTAIN 
                   EXPENSES OF ELEMENTARY AND SECONDARY SCHOOL 
                   TEACHERS.

       (a) In General.--Subparagraph (D) of section 62(a)(2), as 
     amended by this Act, is amended by striking ``In the case of 
     taxable years beginning during 2002'' and all that follows 
     through ``deductions'' and inserting ``The deductions''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 112. PERMANENT EXTENSION OF DEDUCTION OF STATE AND LOCAL 
                   GENERAL SALES TAXES.

       (a) In General.--Section 164(b)(5), as amended by this Act, 
     is amended by striking subparagraph (I).
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 113. PERMANENT EXTENSION OF ABOVE-THE-LINE DEDUCTION FOR 
                   QUALIFIED TUITION AND RELATED EXPENSES.

       (a) In General.--Section 222, as amended by this Act, is 
     amended by striking subsection (e).
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.
                                 ______
                                 
  SA 3062. Mr. HATCH submitted an amendment intended to be proposed by 
him to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       At the end of part II of subtitle A of title I, insert the 
     following:

              Subpart B--Certain Provisions Made Permanent

     SEC. 142. PERMANENT EXTENSION AND MODIFICATION OF RESEARCH 
                   CREDIT.

       (a) Simplified Credit for Qualified Research Expenses.--
     Subsection (a) of section 41 is amended to read as follows:
       ``(a) General Rule.--For purposes of section 38, the 
     research credit determined under this section for the taxable 
     year shall be an amount equal to 20 percent of so much of the 
     qualified research expenses for the taxable year as exceeds 
     50 percent of the average qualified research expenses for the 
     3 taxable years preceding the taxable year for which the 
     credit is being determined.''.
       (b) Special Rules and Termination of Base Amount 
     Calculation.--
       (1) In general.--Subsection (c) of section 41 is amended to 
     read as follows:
       ``(c) Special Rule in Case of No Qualified Research 
     Expenses in Any of 3 Preceding Taxable Years.--
       ``(1) Taxpayers to which subsection applies.--The credit 
     under this section shall be determined under this subsection, 
     and not under subsection (a), if, in any one of the 3 taxable 
     years preceding the taxable year for which the credit is 
     being determined, the taxpayer has no qualified research 
     expenses.
       ``(2) Credit rate.--The credit determined under this 
     subsection shall be equal to 10 percent of the qualified 
     research expenses for the taxable year.''.
       (2) Consistent treatment of expenses.--Subsection (b) of 
     section 41 is amended by adding at the end the following new 
     paragraph:
       ``(5) Consistent treatment of expenses required.--
       ``(A) In general.--Notwithstanding whether the period for 
     filing a claim for credit or refund has expired for any 
     taxable year in the 3-taxable-year period taken into account 
     under subsection (a), the qualified research expenses taken 
     into account for such year shall be determined on a basis 
     consistent with the determination of qualified research 
     expenses for the credit year.
       ``(B) Prevention of distortions.--The Secretary may 
     prescribe regulations to prevent distortions in calculating a 
     taxpayer's qualified research expenses caused by a change in 
     accounting methods used by such taxpayer between the credit 
     year and a year in such 3-taxable-year period.''.
       (c) Inclusion of Qualified Research Expenses of an Acquired 
     Person.--
       (1) Partial inclusion of pre-acquisition qualified research 
     expenses.--Subparagraph (A) of section 41(f)(3) is amended to 
     read as follows:
       ``(A) Acquisitions.--
       ``(i) In general.--If a person acquires the major portion 
     of a trade or business of another person (hereinafter in this 
     paragraph referred to as the `predecessor') or the major 
     portion of a separate unit of a trade or business of a 
     predecessor, then the amount of qualified research expenses 
     paid or incurred by the acquiring person during the 3 taxable 
     years preceding the taxable year in which the credit under 
     this section is determined shall be increased by--

       ``(I) for purposes of applying this section for the taxable 
     year in which such acquisition is made, the amount determined 
     under clause (ii), and
       ``(II) for purposes of applying this section for any 
     taxable year after the taxable year in which such acquisition 
     is made, so much of the qualified research expenses paid or 
     incurred by the predecessor with respect to the acquired 
     trade or business during the portion of the measurement 
     period that is part of the 3-taxable-year period preceding 
     the taxable year for which the credit is determined as is 
     attributable to the portion of such trade or business or 
     separate unit acquired by such person.

       ``(ii) Amount determined.--The amount determined under this 
     clause is the amount equal to the product of--

       ``(I) so much of the qualified research expenses paid or 
     incurred by the predecessor with respect to the acquired 
     trade or business during the 3 taxable years before the 
     taxable year in which the acquisition is made as is 
     attributable to the portion of such trade or business or 
     separate unit acquired by the acquiring person, and
       ``(II) the number of months in the period beginning on the 
     date of the acquisition and ending on the last day of the 
     taxable year in which the acquisition is made,

     divided by 12.
       ``(iii) Special rules for coordinating taxable years.--In 
     the case of an acquiring person and a predecessor whose 
     taxable years do not begin on the same date--

       ``(I) each reference to a taxable year in clauses (i) and 
     (ii) shall refer to the appropriate taxable year of the 
     acquiring person,
       ``(II) the qualified research expenses paid or incurred by 
     the predecessor during each taxable year of the predecessor 
     any portion of which is part of the measurement period shall 
     be allocated equally among the months of such taxable year, 
     and

[[Page 7853]]

       ``(III) the amount of such qualified research expenses 
     taken into account under clauses (i) and (ii) with respect to 
     a taxable year of the acquiring person shall be equal to the 
     total of the expenses attributable under subclause (II) to 
     the months occurring during such taxable year.

       ``(iv) Measurement period.--For purposes of this 
     subparagraph, the term `measurement period' means the taxable 
     year of the acquiring person in which the acquisition is made 
     and the 3 taxable years of the acquiring person preceding 
     such taxable year.''.
       (2) Expenses of a predecessor.--Subparagraph (B) of section 
     41(f)(3) is amended to read as follows:
       ``(B) Dispositions.--If the predecessor furnished to the 
     acquiring person such information as is necessary for the 
     application of subparagraph (A), then, for purposes of 
     applying this section for any taxable year ending after such 
     disposition, the amount of qualified research expenses paid 
     or incurred by the predecessor during the 3 taxable years 
     preceding such taxable year shall be reduced--
       ``(i) in the case of the taxable year in which such 
     disposition is made, by an amount equal to the product of--

       ``(I) the amount of qualified research expenses paid or 
     incurred during such 3 taxable years with respect to the 
     acquired business, and
       ``(II) the number of days in the period beginning on the 
     date of acquisition (as determined for purposes of 
     subparagraph (A)(ii)(II)) and ending on the last day of the 
     taxable year of the predecessor in which the disposition is 
     made,

     divided by the number of days in the taxable year of the 
     predecessor, and
       ``(ii) in the case of any taxable year ending after the 
     taxable year in which such disposition is made, the amount 
     described in clause (i)(I).''.
       (d) Aggregation of Expenditures.--Paragraph (1) of section 
     41(f), as amended by the American Taxpayer Relief Act of 
     2012, is amended--
       (1) by striking ``of the qualified research expenses, basic 
     research payments, and amounts paid or incurred to energy 
     research consortiums,'' in subparagraph (A)(ii) and inserting 
     ``qualified research expenses'', and
       (2) by striking ``of the qualified research expenses, basic 
     research payments, and amounts paid or incurred to energy 
     research consortiums,'' in subparagraph (B)(ii) and inserting 
     ``qualified research expenses''.
       (e) Permanent Extension.--
       (1) Section 41 is amended by striking subsection (h), as 
     amended by this Act.
       (2) Paragraph (1) of section 45C(b) is amended by striking 
     subparagraph (D), as amended by this Act.
       (f) Conforming Amendments.--
       (1) Termination of basic research payment calculation.--
     Section 41 is amended--
       (A) by striking subsection (e),
       (B) by redesignating subsection (g) as subsection (e), and
       (C) by relocating subsection (e), as so redesignated, 
     immediately after subsection (d).
       (2) Special rules.--
       (A) Paragraph (4) of section 41(f) is amended by striking 
     ``and gross receipts''.
       (B) Subsection (f) of section 41 is amended by striking 
     paragraph (6).
       (3) Termination of certain 2014 and 2015 provisions.--
       (A) Section 41 is amended by striking subsection (i), as 
     added by this Act.
       (B) Section 3111 is amended by striking subsection (f), as 
     added by this Act.
       (C) Subparagraph (B) of section 38(c)(4), as amended by 
     this Act, is amended by striking clause (ii), as added by 
     this Act, and by redesignating clauses (iii), (iv), (v), 
     (vi), (vii), (viii), (ix), and (x) as clauses (ii), (iii), 
     (iv), (v), (vi), (vii), (viii), and (ix), respectively.
       (4) Cross-references.--
       (A) Paragraph (2) of section 45C(c) is amended by striking 
     ``base period research expenses'' and inserting ``average 
     qualified research expenses''.
       (B) Subparagraph (A) of section 54(l)(3) is amended by 
     striking ``section 41(g)'' and inserting ``section 41(e)''.
       (C) Clause (i) of section 170(e)(4)(B) is amended to read 
     as follows:
       ``(i) the contribution is to a qualified organization,''.
       (D) Paragraph (4) of section 170(e) is amended by adding at 
     the end the following new subparagraph:
       ``(E) Qualified organization.--For purposes of this 
     paragraph, the term `qualified organization' means--
       ``(i) any educational organization which--

       ``(I) is an institution of higher education (within the 
     meaning of section 3304(f)), and
       ``(II) is described in subsection (b)(1)(A)(ii), or

       ``(ii) any organization not described in clause (i) which--

       ``(I) is described in section 501(c)(3) and is exempt from 
     tax under section 501(a),
       ``(II) is organized and operated primarily to conduct 
     scientific research, and
       ``(III) is not a private foundation.''.

       (E) Section 280C is amended--
       (i) by striking ``or basic research expenses (as defined in 
     section 41(e)(2))'' in subsection (c)(1),
       (ii) by striking ``section 41(a)(1)'' in subsection 
     (c)(2)(A) and inserting ``section 41(a)'', and
       (iii) by striking ``or basic research expenses'' in 
     subsection (c)(2)(B).
       (F) Clause (i) of section 1400N(l)(7)(B) is amended by 
     striking ``section 41(g)'' and inserting ``section 41(e)''.
       (g) Technical Corrections.--Section 409 is amended--
       (1) by inserting ``, as in effect before the enactment of 
     the Tax Reform Act of 1984)'' after ``section 41(c)(1)(B)'' 
     in subsection (b)(1)(A),
       (2) by inserting ``, as in effect before the enactment of 
     the Tax Reform Act of 1984'' after ``relating to the employee 
     stock ownership credit'' in subsection (b)(4),
       (3) by inserting ``(as in effect before the enactment of 
     the Tax Reform Act of 1984)'' after ``section 41(c)(1)(B)'' 
     in subsection (i)(1)(A),
       (4) by inserting ``(as in effect before the enactment of 
     the Tax Reform Act of 1984)'' after ``section 41(c)(1)(B)'' 
     in subsection (m), and
       (5) by inserting ``(as so in effect)'' after ``section 
     48(n)(1)'' in subsection (m).
       (h) Effective Dates.--
       (1) In general.--Except as provided in paragraphs (2), (3), 
     and (4), the amendments made by this section shall apply to 
     credits determined for taxable years beginning after December 
     31, 2015.
       (2) Permanent extension.--The amendments made by subsection 
     (e) shall apply to amounts paid or incurred after December 
     31, 2015.
       (3) Termination of allowance of credit against alternative 
     minimum tax.--The amendments made by subsection (f)(3)(C) 
     shall apply to credits determined for taxable years beginning 
     after December 31, 2015, and to carrybacks of such credits.
       (4) Technical corrections.--The amendments made by 
     subsection (k) shall take effect on the date of the enactment 
     of this Act.

     SEC. 143. PERMANENT EXTENSION OF RAILROAD TRACK MAINTENANCE 
                   CREDIT.

       (a) In General.--Section 45G, as amended by this Act, is 
     amended by striking subsection (f).
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 144. PERMANENT 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) and (v) of section 
     168(e)(3)(E), as amended by this Act, are each amended by 
     striking ``placed in service before January 1, 2016''.
       (b) Qualified Retail Improvement Property.--Clause (ix) of 
     section 168(e)(3)(E), as amended by this Act, is amended by 
     striking ``placed in service after December 31, 2008, and 
     before January 1, 2016''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to property placed in service after December 31, 
     2015.

     SEC. 145. PERMANENT EXTENSION AND MODIFICATION OF INCREASED 
                   EXPENSING LIMITATIONS AND TREATMENT OF CERTAIN 
                   REAL PROPERTY AS SECTION 179 PROPERTY.

       (a) In General.--
       (1) Dollar limitation.--Paragraph (1) of section 179(b), as 
     amended by this Act, is amended by striking ``shall not 
     exceed--'' and all that follows and inserting ``shall not 
     exceed $500,000.''.
       (2) Reduction in limitation.--Paragraph (2) of section 
     179(b), as amended by this Act, is amended by striking 
     ``exceeds--'' and all that follows and inserting ``exceeds 
     $2,000,000.''.
       (b) Computer Software.--Clause (ii) of section 
     179(d)(1)(A), as amended by this Act, is amended by striking 
     ``, to which section 167 applies, and which is placed in 
     service in a taxable year beginning after 2002 and before 
     2016'' and inserting ``and to which section 167 applies''.
       (c) Election.--Paragraph (2) of section 179(c), as amended 
     by this Act, is amended--
       (1) by striking ``may not be revoked'' and all that follows 
     through ``and before 2016'', and
       (2) by striking ``irrevocable'' in the heading thereof.
       (d) Air Conditioning and Heating Units.--The last sentence 
     of section 179(d)(1) is amended by striking ``and shall not 
     include air conditioning or heating units''.
       (e) Qualified Real Property.--Subsection (f) of section 
     179, as amended by this Act, is amended--
       (1) by striking ``beginning after 2009 and before 2016'' in 
     paragraph (1), and
       (2) by striking paragraphs (3) and (4).
       (f) Inflation Adjustment.--Paragraph (6) of section 179(b), 
     as added by this Act, is amended--
       (1) by striking ``the $500,000 amount in paragraph (1)(B) 
     and the $2,000,000 amount in paragraph (2)(B)'' in 
     subparagraph (A) and inserting ``the dollar amounts in 
     paragraphs (1) and (2)'', and
       (2) in subparagraph (B)--
       (A) by striking ``paragraph (1)(B)'' in clause (i) and 
     inserting ``paragraph (1)'', and
       (B) by striking ``paragraph (2)(B)'' in clause (ii) and 
     inserting ``paragraph (2)''.
       (g) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

[[Page 7854]]



     SEC. 146. PERMANENT SUBPART F EXEMPTION FOR ACTIVE FINANCING 
                   INCOME.

       (a) Banking, Financing, or Similar Businesses.--Subsection 
     (h) of section 954, as amended by this Act, is amended by 
     striking paragraph (9).
       (b) Insurance Businesses.--Subsection (e) of section 953, 
     as amended by this Act, is amended by striking paragraph (10) 
     and by redesignating paragraph (11) as paragraph (10).
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years of a foreign corporation 
     beginning after December 31, 2015, and to taxable years of 
     United States shareholders with or within which such taxable 
     years of such foreign corporation end.

     SEC. 147. PERMANENT EXTENSION OF LOOK-THRU TREATMENT OF 
                   PAYMENTS BETWEEN RELATED CONTROLLED FOREIGN 
                   CORPORATIONS UNDER FOREIGN PERSONAL HOLDING 
                   COMPANY RULES.

       (a) In General.--Section 954(c)(6), as amended by this Act, 
     is amended by striking subparagraph (C).
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years of foreign corporations 
     beginning after December 31, 2015, and to taxable years of 
     United States shareholders with or within which such taxable 
     years of foreign corporations end.

     SEC. 148. PERMANENT FULL EXCLUSION APPLICABLE TO QUALIFIED 
                   SMALL BUSINESS STOCK.

       (a) In General.--Paragraph (4) of section 1202(a), as 
     amended by this Act, is amended--
       (1) by striking ``and before January 1, 2016'', and
       (2) by striking ``certain periods in 2010, 2011, 2012, 
     2013, 2014,and 2015'' in the heading and inserting ``certain 
     periods after 2009''.
       (b) Conforming Amendments.--
       (1) The heading for section 1202 is amended by striking 
     ``partial''.
       (2) The item relating to section 1202 in the table of 
     sections for part I of subchapter P of chapter 1 is amended 
     by striking ``Partial exclusion'' and inserting 
     ``Exclusion''.
       (3) Section 1223(13) is amended by striking 
     ``1202(a)(2),''.
       (c) Effective Date.--The amendments made by this section 
     apply to stock acquired after December 31, 2015.

     SEC. 149. REDUCED RECOGNITION PERIOD FOR BUILT-IN GAINS MADE 
                   PERMANENT.

       (a) In General.--Paragraph (7) of section 1374(d), as 
     amended by this Act, is amended--
       (1) by striking subparagraphs (A), (B), (C), and (D),
       (2) by redesignating subparagraph (E) as subparagraph (B), 
     and
       (3) by inserting before subparagraph (B) (as so 
     redesignated) the following new subparagraph:
       ``(A) In general.--The term `recognition period' means the 
     5-year period beginning with the 1st day of the 1st taxable 
     year for which the corporation was an S corporation. For 
     purposes of applying this section to any amount includible in 
     income by reason of distributions to shareholders pursuant to 
     section 593(e), the preceding sentence shall be applied 
     without regard to the phrase `5-year'.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 150. 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), as 
     amended by this Act, is amended to read as follows:
       ``(1) $13.25, or''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to distilled spirits brought into the United 
     States after December 31, 2015.
                                 ______
                                 
  SA 3063. Mr. HATCH submitted an amendment intended to be proposed by 
him to the bill H.R. 3474, to amend the Internal Revenue Code of 1986 
to allow employers to exempt employees with health coverage under 
TRICARE or the Veterans Administration from being taken into account 
for purposes of the employer mandate under the Patient Protection and 
Affordable Care Act; which was ordered to lie on the table; as follows:

       At the end of subtitle A of title I, insert the following:

               PART IV--CERTAIN PROVISIONS MADE PERMANENT

     SEC. 162. PERMANENT 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, as amended by this Act, 
     is amended by striking ``and before January 1, 2016'' each 
     place it appears.
       (b) Effective Date.--The amendments 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. 163. PERMANENT EXTENSION OF SPECIAL RULE FOR 
                   CONTRIBUTIONS OF CAPITAL GAIN REAL PROPERTY 
                   MADE FOR CONSERVATION PURPOSES.

       (a) In General.--Section 170(b)(1)(E), as amended by this 
     Act, is amended by striking clause (vi).
       (b) Contributions by Certain Corporate Farmers and 
     Ranchers.--Section 170(b)(2)(B), as amended by this Act, is 
     amended by striking clause (iii).
       (c) Effective Date.--The amendments made by this section 
     shall apply to contributions made in taxable years beginning 
     after December 31, 2015.

     SEC. 164. PERMANENT EXTENSION OF ENHANCED CHARITABLE 
                   DEDUCTION FOR CONTRIBUTIONS OF FOOD INVENTORY.

       (a) In General.--Section 170(e)(3)(C), as amended by this 
     Act, is amended by striking clause (iv).
       (b) Effective Date.--The amendment made by this section 
     shall apply to contributions made after December 31, 2015.

     SEC. 165. PERMANENT EXTENSION OF TAX-FREE DISTRIBUTIONS FROM 
                   INDIVIDUAL RETIREMENT PLANS FOR CHARITABLE 
                   PURPOSES.

       (a) In General.--Section 408(d)(8), as amended by this Act, 
     is amended by striking subparagraph (F).
       (b) Effective Date.--The amendment made by this section 
     shall apply to distributions made in taxable years beginning 
     after December 31, 2015.

     SEC. 166. PERMANENT EXTENSION OF MODIFICATION OF TAX 
                   TREATMENT OF CERTAIN PAYMENTS TO CONTROLLING 
                   EXEMPT ORGANIZATIONS.

       (a) In General.--Section 512(b)(13)(E), as amended by this 
     Act, is amended by striking clause (iv).
       (b) Effective Date.--The amendment made by this section 
     shall apply to payments received or accrued after December 
     31, 2015.

     SEC. 167. PERMANENT EXTENSION OF BASIS ADJUSTMENT TO STOCK OF 
                   S CORPORATIONS MAKING CHARITABLE CONTRIBUTIONS 
                   OF PROPERTY.

       (a) In General.--Paragraph (2) of section 1367(a), as 
     amended by this Act, is amended by striking the last 
     sentence.
       (b) Effective Date.--The amendment made by this section 
     shall apply to contributions made in taxable years beginning 
     after December 31, 2015.
                                 ______
                                 
  SA 3064. Mr. MORAN (for himself, Ms. Heitkamp, Mr. Thune, Mr. 
Heinrich, Mr. Begich, Mr. Inhofe, Mr. Bennet, Ms. Stabenow, Mr. Enzi, 
Mr. Hoeven, Mr. Udall of New Mexico, Mr. Johnson of South Dakota, Mr. 
Udall of Colorado, Mrs. Murray, Mr. Crapo, Mr. Tester, and Mr. Walsh) 
submitted an amendment intended to be proposed by him to the bill H.R. 
3474, to amend the Internal Revenue Code of 1986 to allow employers to 
exempt employees with health coverage under TRICARE or the Veterans 
Administration from being taken into account for purposes of the 
employer mandate under the Patient Protection and Affordable Care Act; 
which was ordered to lie on the table; as follows:

       At the appropriate place, insert the following:

               TITLE __--TRIBAL GENERAL WELFARE EXCLUSION

     SEC. _01. SHORT TITLE.

       This title may be cited as the ``Tribal General Welfare 
     Exclusion Act of 2013''.

     SEC. _02. INDIAN GENERAL WELFARE BENEFITS.

       (a) In General.--Part III of subchapter B of chapter 1 is 
     amended by inserting before section 140 the following new 
     section:

     ``SEC. 139E. INDIAN GENERAL WELFARE BENEFITS.

       ``(a) In General.--Gross income does not include the value 
     of any Indian general welfare benefit.
       ``(b) Indian General Welfare Benefit.--For purposes of this 
     section, the term `Indian general welfare benefit' includes 
     any payment made or services provided to or on behalf of a 
     member of an Indian tribe (or any spouse or dependent of such 
     a member) pursuant to an Indian tribal government program, 
     but only if--
       ``(1) the program is administered under specified 
     guidelines and does not discriminate in favor of members of 
     the governing body of the tribe, and
       ``(2) the benefits provided under such program--
       ``(A) are available to any tribal member who meets such 
     guidelines,
       ``(B) are for the promotion of general welfare,
       ``(C) are not lavish or extravagant, and
       ``(D) are not compensation for services.
       ``(c) Definitions and Special Rules.--For purposes of this 
     section--
       ``(1) Indian tribal government.--For purposes of this 
     section, the term `Indian tribal government' includes any 
     agencies or instrumentalities of an Indian tribal government 
     and any Alaska Native regional or village corporation, as 
     defined in, or established pursuant to, the Alaska Native 
     Claims Settlement Act (43 U.S.C. 1601 et seq.).
       ``(2) Dependent.--The term `dependent' has the meaning 
     given such term by section 152, determined without regard to 
     subsections (b)(1), (b)(2), and (d)(1)(B).

[[Page 7855]]

       ``(3) Lavish or extravagant.--The Secretary shall, in 
     consultation with the Tribal Advisory Committee (as 
     established under section 3(a) of the Tribal General Welfare 
     Exclusion Act of 2013), establish guidelines for what 
     constitutes lavish or extravagant benefits with respect to 
     Indian tribal government programs.
       ``(4) Establishment of tribal government program.--A 
     program shall not fail to be treated as an Indian tribal 
     government program solely by reason of the program being 
     established by tribal custom or government practice.
       ``(5) Ceremonial activities.--Any items of cultural 
     significance, reimbursement of costs, or cash honorarium for 
     participation in cultural or ceremonial activities for the 
     transmission of tribal culture shall not be treated as 
     compensation for services.''.
       (b) Conforming Amendment.--The table of sections for part 
     III of subchapter B of chapter 1 is amended by inserting 
     before the item relating to section 140 the following new 
     item:

``Sec. 139E. Indian general welfare benefits.''.
       (c) Statutory Construction.--Ambiguities in section 139E of 
     the Internal Revenue Code of 1986, as added by this section, 
     shall be resolved in favor of Indian tribal governments and 
     deference shall be given to Indian tribal governments for the 
     programs administered and authorized by the tribe to benefit 
     the general welfare of the tribal community.
       (d) Effective Date.--
       (1) In general.--The amendments made by this section shall 
     apply to taxable years for which the period of limitation on 
     refund or credit under section 6511 of the Internal Revenue 
     Code of 1986 has not expired.
       (2) One-year waiver of statute of limitations.--If the 
     period of limitation on a credit or refund resulting from the 
     amendments made by subsection (a) expires before the end of 
     the 1-year period beginning on the date of the enactment of 
     this Act, refund or credit of such overpayment (to the extent 
     attributable to such amendments) may, nevertheless, be made 
     or allowed if claim therefor is filed before the close of 
     such 1-year period.

     SEC. _03. TRIBAL ADVISORY COMMITTEE.

       (a) Establishment.--The Secretary of the Treasury shall 
     establish a Tribal Advisory Committee (hereinafter in this 
     subsection referred to as the ``Committee'').
       (b) Duties.--
       (1) Implementation.--The Committee shall advise the 
     Secretary on matters relating to the taxation of Indians.
       (2) Education and training.--The Secretary shall, in 
     consultation with the Committee, establish and require--
       (A) training and education for internal revenue field 
     agents who administer and enforce internal revenue laws with 
     respect to Indian tribes on Federal Indian law and the 
     Federal Government's unique legal treaty and trust 
     relationship with Indian tribal governments, and
       (B) training of such internal revenue field agents, and 
     provision of training and technical assistance to tribal 
     financial officers, about implementation of this Act and the 
     amendments made thereby.
       (c) Membership.--
       (1) In general.--The Committee shall be composed of 7 
     members appointed as follows:
       (A) Three members appointed by the Secretary of the 
     Treasury.
       (B) One member appointed by the Chairman, and one member 
     appointed by the Ranking Member, of the Committee on Ways and 
     Means of the House of Representatives.
       (C) One member appointed by the Chairman, and one member 
     appointed by the Ranking Member, of the Committee on Finance 
     of the Senate.
       (2) Term.--
       (A) In general.--Except as provided in subparagraph (B), 
     each member's term shall be 4 years.
       (B) Initial staggering.--The first appointments made by the 
     Secretary under paragraph (1)(A) shall be for a term of 2 
     years.

     SEC. 4. OTHER RELIEF FOR INDIAN TRIBES.

       (a) Temporary Suspension of Examinations.--The Secretary of 
     the Treasury shall suspend all audits and examinations of 
     Indian tribal governments and members of Indian tribes (or 
     any spouse or dependent of such a member), to the extent such 
     an audit or examination relates to the exclusion of a payment 
     or benefit from an Indian tribal government under the general 
     welfare exclusion, until the education and training 
     prescribed by this Act is completed. The running of any 
     period of limitations under section 6501 of the Internal 
     Revenue Code of 1986 with respect to Indian tribal 
     governments and members of Indian tribes shall be suspended 
     during the period during which audits and examinations are 
     suspended under the preceding sentence.
       (b) Waiver of Penalties and Interest.--The Secretary of the 
     Treasury may waive any interest and penalties imposed under 
     such Code on any Indian tribal government or member of an 
     Indian tribe (or any spouse or dependent of such a member) to 
     the extent such interest and penalties relate to excluding a 
     payment or benefit from gross income under the general 
     welfare exclusion.
       (c) Definitions.--For purposes of this subsection--
       (1) Indian tribal government.--The term ``Indian tribal 
     government'' shall have the meaning given such term by 
     section 139E of the Internal Revenue Code of 1986, as added 
     by this Act.
       (2) Indian tribe.--The term ``Indian tribe'' shall have the 
     meaning given such term by section 45A(c)(6) of such Code.

                          ____________________