[Congressional Record (Bound Edition), Volume 161 (2015), Part 15]
[House]
[Pages 20344-20389]
[From the U.S. Government Publishing Office, www.gpo.gov]




    MILITARY CONSTRUCTION AND VETERANS AFFAIRS AND RELATED AGENCIES 
                        APPROPRIATIONS ACT, 2016

  Mr. BRADY of Texas. Mr. Speaker, pursuant to House Resolution 566, as 
the designee of the gentleman from Kentucky (Mr. Rogers), I call up the 
bill (H.R. 2029) making appropriations for military construction, the 
Department of Veterans Affairs, and related agencies for the fiscal 
year ending September 30, 2016, and for other purposes, with the Senate 
amendment thereto, and ask for its immediate consideration.
  The Clerk read the title of the bill.
  The SPEAKER pro tempore (Mr. Hultgren). The Clerk will designate the 
Senate amendment.
  Senate amendment:

       Strike all after the enacting clause and insert the 
     following:
     That the following sums are appropriated, out of any money in 
     the Treasury not otherwise appropriated, for military 
     construction, the Department of Veterans Affairs, and related 
     agencies for the fiscal year ending September 30, 2016, and 
     for other purposes, namely:

                                TITLE I

                         DEPARTMENT OF DEFENSE

                      Military Construction, Army

       For acquisition, construction, installation, and equipment 
     of temporary or permanent public works, military 
     installations, facilities, and real property for the Army as 
     currently authorized by law, including personnel in the Army 
     Corps of Engineers and other personal services necessary for 
     the purposes of this appropriation, and for construction and 
     operation of facilities in support of the functions of the 
     Commander in Chief, $663,245,000, to remain available until 
     September 30, 2020:  Provided, That, of this amount, not to 
     exceed $109,245,000 shall be available for study, planning, 
     design, architect and engineer services, and host nation 
     support, as authorized by law, unless the Secretary of the 
     Army determines that additional obligations are necessary for 
     such purposes and notifies the Committees on Appropriations 
     of both Houses of Congress of the determination and the 
     reasons therefor.

              Military Construction, Navy and Marine Corps

       For acquisition, construction, installation, and equipment 
     of temporary or permanent public works, naval installations, 
     facilities, and real property for the Navy and Marine Corps 
     as currently authorized by law, including personnel in the 
     Naval Facilities Engineering Command and other personal 
     services necessary for the purposes of this appropriation, 
     $1,619,699,000, to remain available until September 30, 2020: 
      Provided, That, of this amount, not to exceed $91,649,000 
     shall be available for study, planning, design, and architect 
     and engineer services, as authorized by law, unless the 
     Secretary of the Navy determines that additional obligations 
     are necessary for such purposes and notifies the Committees 
     on Appropriations of both Houses of Congress of the 
     determination and the reasons therefor.

                    Military Construction, Air Force

       For acquisition, construction, installation, and equipment 
     of temporary or permanent public works, military 
     installations, facilities, and real property for the Air 
     Force as currently authorized by law, $1,389,185,000, to 
     remain available until September 30, 2020:  Provided, That, 
     of this amount, not to exceed $89,164,000 shall be available 
     for study, planning, design, and architect and engineer 
     services, as authorized by law, unless the Secretary of Air 
     Force determines that additional obligations are necessary 
     for such purposes and notifies the Committees on 
     Appropriations of both Houses of Congress of the 
     determination and the reasons therefor.

                  Military Construction, Defense-Wide

                     (including transfer of funds)

       For acquisition, construction, installation, and equipment 
     of temporary or permanent public works, installations, 
     facilities, and real property for activities and agencies of 
     the Department of Defense (other than the military 
     departments), as currently authorized by law, $2,290,767,000, 
     to remain available until September 30, 2020:  Provided, That 
     such amounts of this appropriation as may be determined by 
     the Secretary of Defense may be transferred to such 
     appropriations of the Department of Defense available for 
     military construction or family housing as the Secretary may 
     designate, to be merged with and to be available for the same 
     purposes, and for the same time period, as the appropriation 
     or fund to which transferred:  Provided further, That, of the 
     amount appropriated, not to exceed $160,404,000 shall be 
     available for study, planning, design, and architect and 
     engineer services, as authorized by law, unless the Secretary 
     of Defense determines that additional obligations are 
     necessary for such purposes and notifies the Committees on 
     Appropriations of both Houses of Congress of the 
     determination and the reasons therefor.

               Military Construction, Army National Guard

       For construction, acquisition, expansion, rehabilitation, 
     and conversion of facilities for the training and 
     administration of the Army National Guard, and contributions 
     therefor, as authorized by chapter 1803 of title 10, United 
     States Code, and Military Construction Authorization Acts, 
     $197,237,000, to remain available until September 30, 2020:  
     Provided, That, of the amount appropriated, not to exceed 
     $20,337,000 shall be available for study, planning, design, 
     and architect and engineer services, as authorized by law, 
     unless the Director of the Army National Guard determines 
     that additional obligations are necessary for such purposes 
     and notifies the Committees on Appropriations of both Houses 
     of Congress of the determination and the reasons therefor.

               Military Construction, Air National Guard

       For construction, acquisition, expansion, rehabilitation, 
     and conversion of facilities for the training and 
     administration of the Air National Guard, and contributions 
     therefor, as authorized by chapter 1803 of title 10, United 
     States Code, and Military Construction Authorization Acts, 
     $138,738,000, to remain available until September 30, 2020:  
     Provided, That, of the amount appropriated, not to exceed 
     $5,104,000 shall be available for study, planning, design, 
     and architect and engineer services, as authorized by law, 
     unless the Director of the Air National Guard determines that 
     additional obligations are necessary for such purposes and 
     notifies the Committees on Appropriations of both Houses of 
     Congress of the determination and the reasons therefor.

                  Military Construction, Army Reserve

       For construction, acquisition, expansion, rehabilitation, 
     and conversion of facilities for the training and 
     administration of the Army Reserve as authorized by chapter 
     1803 of title 10, United States Code, and Military 
     Construction Authorization Acts, $113,595,000, to remain 
     available until September 30, 2020:  Provided, That, of the 
     amount appropriated, not to exceed $9,318,000 shall be 
     available for study, planning, design, and architect and 
     engineer services, as authorized by law, unless the Chief of 
     the Army Reserve determines that additional obligations are 
     necessary for such purposes and notifies the Committees on 
     Appropriations of both Houses of Congress of the 
     determination and the reasons therefor.

                  Military Construction, Navy Reserve

       For construction, acquisition, expansion, rehabilitation, 
     and conversion of facilities for the training and 
     administration of the reserve components of the Navy and 
     Marine Corps as authorized by chapter 1803 of title 10, 
     United States Code, and Military Construction Authorization 
     Acts, $36,078,000, to remain available until September 30, 
     2020:  Provided, That, of the amount appropriated, not to 
     exceed $2,208,000 shall be available for study, planning, 
     design, and architect and engineer services, as authorized by 
     law, unless the Secretary of the Navy determines that 
     additional obligations are necessary for such purposes and 
     notifies the Committees on Appropriations of both Houses of 
     Congress of the determination and the reasons therefor.

                Military Construction, Air Force Reserve

       For construction, acquisition, expansion, rehabilitation, 
     and conversion of facilities for the training and 
     administration of the Air Force Reserve as authorized by 
     chapter 1803 of title 10, United States Code, and Military 
     Construction Authorization Acts, $65,021,000, to remain 
     available until September 30, 2020:  Provided, That, of the 
     amount appropriated, not to exceed $13,400,000 shall be 
     available for study, planning, design, and architect and 
     engineer services, as authorized by law, unless the Chief of 
     the Air Force Reserve determines that additional obligations 
     are necessary for such purposes and

[[Page 20345]]

     notifies the Committees on Appropriations of both Houses of 
     Congress of the determination and the reasons therefor.

                   North Atlantic Treaty Organization

                      Security Investment Program

       For the United States share of the cost of the North 
     Atlantic Treaty Organization Security Investment Program for 
     the acquisition and construction of military facilities and 
     installations (including international military headquarters) 
     and for related expenses for the collective defense of the 
     North Atlantic Treaty Area as authorized by section 2806 of 
     title 10, United States Code, and Military Construction 
     Authorization Acts, $120,000,000, to remain available until 
     expended.

                   Family Housing Construction, Army

       For expenses of family housing for the Army for 
     construction, including acquisition, replacement, addition, 
     expansion, extension, and alteration, as authorized by law, 
     $99,695,000, to remain available until September 30, 2020.

             Family Housing Operation and Maintenance, Army

       For expenses of family housing for the Army for operation 
     and maintenance, including debt payment, leasing, minor 
     construction, principal and interest charges, and insurance 
     premiums, as authorized by law, $393,511,000.

           Family Housing Construction, Navy and Marine Corps

       For expenses of family housing for the Navy and Marine 
     Corps for construction, including acquisition, replacement, 
     addition, expansion, extension, and alteration, as authorized 
     by law, $16,541,000, to remain available until September 30, 
     2020.

    Family Housing Operation and Maintenance, Navy and Marine Corps

       For expenses of family housing for the Navy and Marine 
     Corps for operation and maintenance, including debt payment, 
     leasing, minor construction, principal and interest charges, 
     and insurance premiums, as authorized by law, $353,036,000.

                 Family Housing Construction, Air Force

       For expenses of family housing for the Air Force for 
     construction, including acquisition, replacement, addition, 
     expansion, extension, and alteration, as authorized by law, 
     $160,498,000, to remain available until September 30, 2020.

          Family Housing Operation and Maintenance, Air Force

       For expenses of family housing for the Air Force for 
     operation and maintenance, including debt payment, leasing, 
     minor construction, principal and interest charges, and 
     insurance premiums, as authorized by law, $331,232,000.

         Family Housing Operation and Maintenance, Defense-Wide

       For expenses of family housing for the activities and 
     agencies of the Department of Defense (other than the 
     military departments) for operation and maintenance, leasing, 
     and minor construction, as authorized by law, $58,668,000.

               Department of Defense Base Closure Account

       For deposit into the Department of Defense Base Closure 
     Account 1990, established by section 2906(a) of the Defense 
     Base Closure and Realignment Act of 1990 (10 U.S.C. 2687 
     note), $251,334,000, to remain available until expended.

                       Administrative Provisions

       Sec. 101.  None of the funds made available in this title 
     shall be expended for payments under a cost-plus-a-fixed-fee 
     contract for construction, where cost estimates exceed 
     $25,000, to be performed within the United States, except 
     Alaska, without the specific approval in writing of the 
     Secretary of Defense setting forth the reasons therefor.
       Sec. 102.  Funds made available in this title for 
     construction shall be available for hire of passenger motor 
     vehicles.
       Sec. 103.  Funds made available in this title for 
     construction may be used for advances to the Federal Highway 
     Administration, Department of Transportation, for the 
     construction of access roads as authorized by section 210 of 
     title 23, United States Code, when projects authorized 
     therein are certified as important to the national defense by 
     the Secretary of Defense.
       Sec. 104.  None of the funds made available in this title 
     may be used to begin construction of new bases in the United 
     States for which specific appropriations have not been made.
       Sec. 105.  None of the funds made available in this title 
     shall be used for purchase of land or land easements in 
     excess of 100 percent of the value as determined by the Army 
     Corps of Engineers or the Naval Facilities Engineering 
     Command, except: (1) where there is a determination of value 
     by a Federal court; (2) purchases negotiated by the Attorney 
     General or the designee of the Attorney General; (3) where 
     the estimated value is less than $25,000; or (4) as otherwise 
     determined by the Secretary of Defense to be in the public 
     interest.
       Sec. 106.  None of the funds made available in this title 
     shall be used to: (1) acquire land; (2) provide for site 
     preparation; or (3) install utilities for any family housing, 
     except housing for which funds have been made available in 
     annual Acts making appropriations for military construction.
       Sec. 107.  None of the funds made available in this title 
     for minor construction may be used to transfer or relocate 
     any activity from one base or installation to another, 
     without prior notification to the Committees on 
     Appropriations of both Houses of Congress.
       Sec. 108.  None of the funds made available in this title 
     may be used for the procurement of steel for any construction 
     project or activity for which American steel producers, 
     fabricators, and manufacturers have been denied the 
     opportunity to compete for such steel procurement.
       Sec. 109.  None of the funds available to the Department of 
     Defense for military construction or family housing during 
     the current fiscal year may be used to pay real property 
     taxes in any foreign nation.
       Sec. 110.  None of the funds made available in this title 
     may be used to initiate a new installation overseas without 
     prior notification to the Committees on Appropriations of 
     both Houses of Congress.
       Sec. 111.  None of the funds made available in this title 
     may be obligated for architect and engineer contracts 
     estimated by the Government to exceed $500,000 for projects 
     to be accomplished in Japan, in any North Atlantic Treaty 
     Organization member country, or in countries bordering the 
     Arabian Gulf, unless such contracts are awarded to United 
     States firms or United States firms in joint venture with 
     host nation firms.
       Sec. 112.  None of the funds made available in this title 
     for military construction in the United States territories 
     and possessions in the Pacific and on Kwajalein Atoll, or in 
     countries bordering the Arabian Gulf, may be used to award 
     any contract estimated by the Government to exceed $1,000,000 
     to a foreign contractor:  Provided, That this section shall 
     not be applicable to contract awards for which the lowest 
     responsive and responsible bid of a United States contractor 
     exceeds the lowest responsive and responsible bid of a 
     foreign contractor by greater than 20 percent:  Provided 
     further, That this section shall not apply to contract awards 
     for military construction on Kwajalein Atoll for which the 
     lowest responsive and responsible bid is submitted by a 
     Marshallese contractor.
       Sec. 113.  The Secretary of Defense shall inform the 
     appropriate committees of both Houses of Congress, including 
     the Committees on Appropriations, of plans and scope of any 
     proposed military exercise involving United States personnel 
     30 days prior to its occurring, if amounts expended for 
     construction, either temporary or permanent, are anticipated 
     to exceed $100,000.
       Sec. 114.  Not more than 20 percent of the funds made 
     available in this title which are limited for obligation 
     during the current fiscal year shall be obligated during the 
     last 2 months of the fiscal year.
       Sec. 115.  Funds appropriated to the Department of Defense 
     for construction in prior years shall be available for 
     construction authorized for each such military department by 
     the authorizations enacted into law during the current 
     session of Congress.
       Sec. 116.  For military construction or family housing 
     projects that are being completed with funds otherwise 
     expired or lapsed for obligation, expired or lapsed funds may 
     be used to pay the cost of associated supervision, 
     inspection, overhead, engineering and design on those 
     projects and on subsequent claims, if any.
       Sec. 117.  Notwithstanding any other provision of law, any 
     funds made available to a military department or defense 
     agency for the construction of military projects may be 
     obligated for a military construction project or contract, or 
     for any portion of such a project or contract, at any time 
     before the end of the fourth fiscal year after the fiscal 
     year for which funds for such project were made available, if 
     the funds obligated for such project: (1) are obligated from 
     funds available for military construction projects; and (2) 
     do not exceed the amount appropriated for such project, plus 
     any amount by which the cost of such project is increased 
     pursuant to law.

                     (including transfer of funds)

       Sec. 118.  Subject to 30 days prior notification, or 14 
     days for a notification provided in an electronic medium 
     pursuant to sections 480 and 2883 of title 10, United States 
     Code, to the Committees on Appropriations of both Houses of 
     Congress, such additional amounts as may be determined by the 
     Secretary of Defense may be transferred to: (1) the 
     Department of Defense Family Housing Improvement Fund from 
     amounts appropriated for construction in ``Family Housing'' 
     accounts, to be merged with and to be available for the same 
     purposes and for the same period of time as amounts 
     appropriated directly to the Fund; or (2) the Department of 
     Defense Military Unaccompanied Housing Improvement Fund from 
     amounts appropriated for construction of military 
     unaccompanied housing in ``Military Construction'' accounts, 
     to be merged with and to be available for the same purposes 
     and for the same period of time as amounts appropriated 
     directly to the Fund:  Provided, That appropriations made 
     available to the Funds shall be available to cover the costs, 
     as defined in section 502(5) of the Congressional Budget Act 
     of 1974, of direct loans or loan guarantees issued by the 
     Department of Defense pursuant to the provisions of 
     subchapter IV of chapter 169 of title 10, United States Code, 
     pertaining to alternative means of acquiring and improving 
     military family housing, military unaccompanied housing, and 
     supporting facilities.

                     (including transfer of funds)

       Sec. 119.  In addition to any other transfer authority 
     available to the Department of Defense, amounts may be 
     transferred from the accounts established by sections 
     2906(a)(1) and 2906A(a)(1) of the Defense Base Closure and 
     Realignment Act of 1990 (10 U.S.C. 2687 note), to

[[Page 20346]]

     the fund established by section 1013(d) of the Demonstration 
     Cities and Metropolitan Development Act of 1966 (42 U.S.C. 
     3374) to pay for expenses associated with the Homeowners 
     Assistance Program incurred under 42 U.S.C. 3374(a)(1)(A). 
     Any amounts transferred shall be merged with and be available 
     for the same purposes and for the same time period as the 
     fund to which transferred.
       Sec. 120.  Notwithstanding any other provision of law, 
     funds made available in this title for operation and 
     maintenance of family housing shall be the exclusive source 
     of funds for repair and maintenance of all family housing 
     units, including general or flag officer quarters:  Provided, 
     That not more than $35,000 per unit may be spent annually for 
     the maintenance and repair of any general or flag officer 
     quarters without 30 days prior notification, or 14 days for a 
     notification provided in an electronic medium pursuant to 
     sections 480 and 2883 of title 10, United States Code, to the 
     Committees on Appropriations of both Houses of Congress, 
     except that an after-the-fact notification shall be submitted 
     if the limitation is exceeded solely due to costs associated 
     with environmental remediation that could not be reasonably 
     anticipated at the time of the budget submission:  Provided 
     further,  That the Under Secretary of Defense (Comptroller) 
     is to report annually to the Committees on Appropriations of 
     both Houses of Congress all operation and maintenance 
     expenditures for each individual general or flag officer 
     quarters for the prior fiscal year.
       Sec. 121.  Amounts contained in the Ford Island Improvement 
     Account established by subsection (h) of section 2814 of 
     title 10, United States Code, are appropriated and shall be 
     available until expended for the purposes specified in 
     subsection (i)(1) of such section or until transferred 
     pursuant to subsection (i)(3) of such section.

                     (including transfer of funds)

       Sec. 122.  During the 5-year period after appropriations 
     available in this Act to the Department of Defense for 
     military construction and family housing operation and 
     maintenance and construction have expired for obligation, 
     upon a determination that such appropriations will not be 
     necessary for the liquidation of obligations or for making 
     authorized adjustments to such appropriations for obligations 
     incurred during the period of availability of such 
     appropriations, unobligated balances of such appropriations 
     may be transferred into the appropriation ``Foreign Currency 
     Fluctuations, Construction, Defense'', to be merged with and 
     to be available for the same time period and for the same 
     purposes as the appropriation to which transferred.
       Sec. 123.  Amounts appropriated or otherwise made available 
     in an account funded under the headings in this title may be 
     transferred among projects and activities within the account 
     in accordance with the reprogramming guidelines for military 
     construction and family housing construction contained in 
     Department of Defense Financial Management Regulation 
     7000.14-R, Volume 3, Chapter 7, of February 2009, as in 
     effect on the date of enactment of this Act.
       Sec. 124.  None of the funds made available in this title 
     may be obligated or expended for planning and design and 
     construction of projects at Arlington National Cemetery.
       Sec. 125.  For an additional amount for ``Military 
     Construction, Army'', $34,500,000, to remain available until 
     September 30, 2020:  Provided, That such funds may only be 
     obligated to carry out construction projects, in priority 
     order, identified in the Department of the Army's Unfunded 
     Priority List for Fiscal Year 2016 submitted to Congress:  
     Provided further, That such funding is subject to 
     authorization prior to obligation and expenditure of funds to 
     carry out construction:  Provided further, That, not later 
     than 30 days after enactment of this Act, the Secretary of 
     the Army shall submit to the Committees on Appropriations of 
     both Houses of Congress an expenditure plan for funds 
     provided under this section.
       Sec. 126.  For an additional amount for ``Military 
     Construction, Navy and Marine Corps'', $34,320,000, to remain 
     available until September 30, 2020:  Provided, That such 
     funds may only be obligated to carry out construction 
     projects, in priority order, identified in the Department of 
     the Navy's Unfunded Priority List for fiscal year 2016:  
     Provided further, That such funding is subject to 
     authorization prior to obligation and expenditure of funds to 
     carry out construction:  Provided further, That, not later 
     than 30 days after enactment of this Act, the Secretary of 
     the Navy shall submit to the Committees on Appropriations of 
     both Houses of Congress an expenditure plan for funds 
     provided under this section.
       Sec. 127.  For an additional amount for ``Military 
     Construction, Army National Guard'', $51,300,000, to remain 
     available until September 30, 2020:  Provided, That such 
     funds may only be obligated to carry out construction 
     projects, in priority order, identified in the Department of 
     the Army's Unfunded Priority List for Fiscal Year 2016 
     submitted to Congress:  Provided further, That such funding 
     is subject to authorization prior to obligation and 
     expenditure of funds to carry out construction:  Provided 
     further, That, not later than 30 days after enactment of this 
     Act, the Secretary of the Army shall submit to the Committees 
     on Appropriations of both Houses of Congress an expenditure 
     plan for funds provided under this section.
       Sec. 128.  For an additional amount for ``Military 
     Construction, Army Reserve'', $34,200,000, to remain 
     available until September 30, 2020:  Provided, That such 
     funds may only be obligated to carry out construction 
     projects, in priority order, identified in the Department of 
     the Army's Unfunded Priority List for Fiscal Year 2016 
     submitted to Congress:  Provided further, That such funding 
     is subject to authorization prior to obligation and 
     expenditure of funds to carry out construction:  Provided 
     further, That, not later than 30 days after enactment of this 
     Act, the Secretary of the Army shall submit to the Committees 
     on Appropriations of both Houses of Congress an expenditure 
     plan for funds provided under this section.

                         (rescissions of funds)

       Sec. 129.  Of the unobligated balances available from prior 
     Appropriations Acts (other than appropriations that were 
     designated by the Congress as an emergency requirement or as 
     being for Overseas Contingency Operations/Global War on 
     Terrorism pursuant to a concurrent resolution on the budget 
     or the Balanced Budget and Emergency Deficit Control Act of 
     1985) the following funds are hereby rescinded from the 
     following accounts and programs in the specified amounts:
       ``Military Construction, Army'', $45,000,000;
       ``Military Construction, Air Force'', $46,400,000; and
       ``Military Construction, Defense-Wide'', $80,500,000.

                         (rescission of funds)

       Sec. 130.  Of the unobligated balances made available in 
     prior appropriations Acts for the fund established in section 
     1013(d) of the Demonstration Cities and Metropolitan 
     Development Act of 1966 (42 U.S.C. 3374), $65,000,000 are 
     hereby rescinded.
       Sec. 131.  Notwithstanding any other provision of law, none 
     of the funds appropriated or otherwise made available by this 
     or any other Act may be used to consolidate or relocate any 
     element of a United States Air Force Rapid Engineer 
     Deployable Heavy Operational Repair Squadron Engineer (RED 
     HORSE) outside of the United States until the Secretary of 
     the Air Force (1) completes an analysis and comparison of the 
     cost and infrastructure investment required to consolidate or 
     relocate a RED HORSE squadron outside of the United States 
     versus within the United States; (2) provides to the 
     Committees on Appropriations of both Houses of Congress 
     (``the Committees'') a report detailing the findings of the 
     cost analysis; and (3) certifies in writing to the Committees 
     that the preferred site for the consolidation or relocation 
     yields the greatest savings for the Air Force:  Provided, 
     That the term ``United States'' in this section does not 
     include any territory or possession of the United States.
       Sec. 132.  For an additional amount for ``Military 
     Construction, Air Force'', $21,000,000, to remain available 
     until September 30, 2020:  Provided, That such funds may only 
     be obligated to carry out construction projects, in priority 
     order, identified in the Department of the Air Force's 
     Unfunded Priority List for Fiscal Year 2016 submitted to 
     Congress:  Provided further, That such funding is subject to 
     authorization prior to obligation and expenditure of funds to 
     carry out construction:  Provided further, That not later 
     than 30 days after enactment of this Act, the Secretary of 
     the Air Force shall submit to the Committees on 
     Appropriations of both Houses of Congress an expenditure plan 
     for funds provided under this section.
       Sec. 133.  For an additional amount for ``Military 
     Construction, Air National Guard'', $6,100,000, to remain 
     available until September 30, 2020:  Provided, That such 
     funds may only be obligated to carry out construction 
     projects, in priority order, identified in the Department of 
     the Air Force's Unfunded Priority List for Fiscal Year 2016 
     submitted to Congress:  Provided further, That such funding 
     is subject to authorization prior to obligation and 
     expenditure of funds to carry out construction:  Provided 
     further, That not later than 30 days after enactment of this 
     Act, the Secretary of the Air Force shall submit to the 
     Committees on Appropriations of both Houses of Congress an 
     expenditure plan for funds provided under this section.
       Sec. 134.  For an additional amount for ``Military 
     Construction, Air Force Reserve'', $10,400,000, to remain 
     available until September 30, 2020:  Provided, That such 
     funds may only be obligated to carry out construction 
     projects, in priority order, identified in the Department of 
     the Air Force's Unfunded Priority List for Fiscal Year 2016 
     submitted to Congress:  Provided further, That such funding 
     is subject to authorization prior to obligation and 
     expenditure of funds to carry out construction:  Provided 
     further, That not later than 30 days after enactment of this 
     Act, the Secretary of the Air Force shall submit to the 
     Committees on Appropriations of both Houses of Congress an 
     expenditure plan for funds provided under this section.

                                TITLE II

                     DEPARTMENT OF VETERANS AFFAIRS

                    Veterans Benefits Administration

                       compensation and pensions

                     (including transfer of funds)

       For the payment of compensation benefits to or on behalf of 
     veterans and a pilot program for disability examinations as 
     authorized by section 107 and chapters 11, 13, 18, 51, 53, 
     55, and 61 of title 38, United States Code; pension benefits 
     to or on behalf of veterans as authorized by chapters 15, 51, 
     53, 55, and 61 of title 38, United States Code; and burial 
     benefits, the Reinstated Entitlement Program for Survivors, 
     emergency and other officers' retirement pay, adjusted-
     service credits and certificates, payment of premiums due on 
     commercial life insurance policies guaranteed under the 
     provisions of title IV of the Servicemembers Civil Relief Act 
     (50 U.S.C.

[[Page 20347]]

     App. 541 et seq.) and for other benefits as authorized by 
     sections 107, 1312, 1977, and 2106, and chapters 23, 51, 53, 
     55, and 61 of title 38, United States Code, $166,271,436,000, 
     to remain available until expended, of which $87,146,761,000 
     shall become available on October 1, 2016:  Provided, That 
     not to exceed $15,562,000 of the amount appropriated for 
     fiscal year 2016 and $16,021,000 of the amount made available 
     for fiscal year 2017 under this heading shall be reimbursed 
     to ``General Operating Expenses, Veterans Benefits 
     Administration'', and ``Information Technology Systems'' for 
     necessary expenses in implementing the provisions of chapters 
     51, 53, and 55 of title 38, United States Code, the funding 
     source for which is specifically provided as the 
     ``Compensation and Pensions'' appropriation:  Provided 
     further, That such sums as may be earned on an actual 
     qualifying patient basis, shall be reimbursed to ``Medical 
     Care Collections Fund'' to augment the funding of individual 
     medical facilities for nursing home care provided to 
     pensioners as authorized.

                         readjustment benefits

       For the payment of readjustment and rehabilitation benefits 
     to or on behalf of veterans as authorized by chapters 21, 30, 
     31, 33, 34, 35, 36, 39, 41, 51, 53, 55, and 61 of title 38, 
     United States Code, $32,088,826,000, to remain available 
     until expended, of which $16,743,904,000 shall become 
     available on October 1, 2016:  Provided, That expenses for 
     rehabilitation program services and assistance which the 
     Secretary is authorized to provide under subsection (a) of 
     section 3104 of title 38, United States Code, other than 
     under paragraphs (1), (2), (5), and (11) of that subsection, 
     shall be charged to this account.

                   veterans insurance and indemnities

       For military and naval insurance, national service life 
     insurance, servicemen's indemnities, service-disabled 
     veterans insurance, and veterans mortgage life insurance as 
     authorized by chapters 19 and 21, title 38, United States 
     Code, $169,080,000, to remain available until expended, of 
     which $91,920,000 shall become available on October 1, 2016.

                 veterans housing benefit program fund

       For the cost of direct and guaranteed loans, such sums as 
     may be necessary to carry out the program, as authorized by 
     subchapters I through III of chapter 37 of title 38, United 
     States Code:  Provided, That such costs, including the cost 
     of modifying such loans, shall be as defined in section 502 
     of the Congressional Budget Act of 1974:  Provided further, 
     That, during fiscal year 2016, within the resources 
     available, not to exceed $500,000 in gross obligations for 
     direct loans are authorized for specially adapted housing 
     loans.
       In addition, for administrative expenses to carry out the 
     direct and guaranteed loan programs, $164,558,000.

            vocational rehabilitation loans program account

       For the cost of direct loans, $31,000, as authorized by 
     chapter 31 of title 38, United States Code:  Provided, That 
     such costs, including the cost of modifying such loans, shall 
     be as defined in section 502 of the Congressional Budget Act 
     of 1974:  Provided further, That funds made available under 
     this heading are available to subsidize gross obligations for 
     the principal amount of direct loans not to exceed 
     $2,952,381.
       In addition, for administrative expenses necessary to carry 
     out the direct loan program, $367,000, which may be paid to 
     the appropriation for ``General Operating Expenses, Veterans 
     Benefits Administration''.

          native american veteran housing loan program account

       For administrative expenses to carry out the direct loan 
     program authorized by subchapter V of chapter 37 of title 38, 
     United States Code, $1,134,000.

                     Veterans Health Administration

                            medical services

       For necessary expenses for furnishing, as authorized by 
     law, inpatient and outpatient care and treatment to 
     beneficiaries of the Department of Veterans Affairs and 
     veterans described in section 1705(a) of title 38, United 
     States Code, including care and treatment in facilities not 
     under the jurisdiction of the Department, and including 
     medical supplies and equipment, bioengineering services, food 
     services, and salaries and expenses of healthcare employees 
     hired under title 38, United States Code, aid to State homes 
     as authorized by section 1741 of title 38, United States 
     Code, assistance and support services for caregivers as 
     authorized by section 1720G of title 38, United States Code, 
     loan repayments authorized by section 604 of the Caregivers 
     and Veterans Omnibus Health Services Act of 2010 (Public Law 
     111-163; 124 Stat. 1174; 38 U.S.C. 7681 note), and hospital 
     care and medical services authorized by section 1787 of title 
     38, United States Code; $3,104,197,000, which shall be in 
     addition to funds previously appropriated under this heading 
     that become available on October 1, 2015; and, in addition, 
     $51,673,000,000, plus reimbursements, shall become available 
     on October 1, 2016, and shall remain available until 
     September 30, 2017:  Provided, That, of the amount made 
     available on October 1, 2016, under this heading, 
     $1,400,000,000 shall remain available until September 30, 
     2018:  Provided further, That, notwithstanding any other 
     provision of law, the Secretary of Veterans Affairs shall 
     establish a priority for the provision of medical treatment 
     for veterans who have service-connected disabilities, lower 
     income, or have special needs:  Provided further, That, 
     notwithstanding any other provision of law, the Secretary of 
     Veterans Affairs shall give priority funding for the 
     provision of basic medical benefits to veterans in enrollment 
     priority groups 1 through 6:  Provided further, That, 
     notwithstanding any other provision of law, the Secretary of 
     Veterans Affairs may authorize the dispensing of prescription 
     drugs from Veterans Health Administration facilities to 
     enrolled veterans with privately written prescriptions based 
     on requirements established by the Secretary:  Provided 
     further, That the implementation of the program described in 
     the previous proviso shall incur no additional cost to the 
     Department of Veterans Affairs:  Provided further, That, of 
     the amount made available on October 1, 2016, under this 
     heading, not less than $900,000,000 shall be available for 
     highly effective Hepatitis C Virus (HCV) clinical treatments 
     including clinical treatments with modern medications that 
     have significantly higher cure rates than older medications, 
     are easier to prescribe, and have fewer and milder side 
     effects:  Provided further, That the Secretary of Veterans 
     Affairs shall ensure that amounts appropriated to the 
     Department of Veterans Affairs for medical supplies and 
     equipment are allocated to ensure the provision of gender 
     appropriate prosthetics.

                     medical support and compliance

       For necessary expenses in the administration of the 
     medical, hospital, nursing home, domiciliary, construction, 
     supply, and research activities, as authorized by law; 
     administrative expenses in support of capital policy 
     activities; and administrative and legal expenses of the 
     Department for collecting and recovering amounts owed the 
     Department as authorized under chapter 17 of title 38, United 
     States Code, and the Federal Medical Care Recovery Act (42 
     U.S.C. 2651 et seq.), $6,524,000,000, plus reimbursements, 
     shall become available on October 1, 2016, and shall remain 
     available until September 30, 2017:  Provided, That, of the 
     amount made available on October 1, 2016, under this heading, 
     $100,000,000 shall remain available until September 30, 2018.

                           medical facilities

       For necessary expenses for the maintenance and operation of 
     hospitals, nursing homes, domiciliary facilities, and other 
     necessary facilities of the Veterans Health Administration; 
     for administrative expenses in support of planning, design, 
     project management, real property acquisition and 
     disposition, construction, and renovation of any facility 
     under the jurisdiction or for the use of the Department; for 
     oversight, engineering, and architectural activities not 
     charged to project costs; for repairing, altering, improving, 
     or providing facilities in the several hospitals and homes 
     under the jurisdiction of the Department, not otherwise 
     provided for, either by contract or by the hire of temporary 
     employees and purchase of materials; for leases of 
     facilities; and for laundry services, $5,074,000,000, plus 
     reimbursements, shall become available on October 1, 2016, 
     and shall remain available until September 30, 2017:  
     Provided, That, of the amount made available on October 1, 
     2016, under this heading, $250,000,000 shall remain available 
     until September 30, 2018.

                    medical and prosthetic research

       For necessary expenses in carrying out programs of medical 
     and prosthetic research and development as authorized by 
     chapter 73 of title 38, United States Code, $621,813,000, 
     plus reimbursements, shall remain available until September 
     30, 2017:  Provided, That such sums are allocated to ensure 
     the provision of gender appropriate prosthetics and to 
     conduct research related to toxic exposure.

                    National Cemetery Administration

       For necessary expenses of the National Cemetery 
     Administration for operations and maintenance, not otherwise 
     provided for, including uniforms or allowances therefor; 
     cemeterial expenses as authorized by law; purchase of one 
     passenger motor vehicle for use in cemeterial operations; 
     hire of passenger motor vehicles; and repair, alteration or 
     improvement of facilities under the jurisdiction of the 
     National Cemetery Administration, $266,220,000, of which not 
     to exceed $26,600,000 shall remain available until September 
     30, 2017.

                      Departmental Administration

                         general administration

                     (including transfer of funds)

       For necessary operating expenses of the Department of 
     Veterans Affairs, not otherwise provided for, including 
     administrative expenses in support of Department-Wide capital 
     planning, management and policy activities, uniforms, or 
     allowances therefor; not to exceed $25,000 for official 
     reception and representation expenses; hire of passenger 
     motor vehicles; and reimbursement of the General Services 
     Administration for security guard services, $311,591,000, of 
     which not to exceed $10,000,000 shall remain available until 
     September 30, 2017:  Provided, That funds provided under this 
     heading may be transferred to ``General Operating Expenses, 
     Veterans Benefits Administration''.

                       board of veterans appeals

       For necessary operating expenses of the Board of Veterans 
     Appeals, $107,884,000, of which not to exceed $10,788,000 
     shall remain available until September 30, 2017.

      general operating expenses, veterans benefits administration

       For necessary operating expenses of the Veterans Benefits 
     Administration, not otherwise provided for, including hire of 
     passenger motor vehicles, reimbursement of the General 
     Services Administration for security guard services, and

[[Page 20348]]

     reimbursement of the Department of Defense for the cost of 
     overseas employee mail, $2,697,734,000:  Provided, That 
     expenses for services and assistance authorized under 
     paragraphs (1), (2), (5), and (11) of section 3104(a) of 
     title 38, United States Code, that the Secretary of Veterans 
     Affairs determines are necessary to enable entitled veterans: 
     (1) to the maximum extent feasible, to become employable and 
     to obtain and maintain suitable employment; or (2) to achieve 
     maximum independence in daily living, shall be charged to 
     this account:  Provided further, That, of the funds made 
     available under this heading, not to exceed $160,000,000 
     shall remain available until September 30, 2017.

                     information technology systems

       For necessary expenses for information technology systems 
     and telecommunications support, including developmental 
     information systems and operational information systems; for 
     pay and associated costs; and for the capital asset 
     acquisition of information technology systems, including 
     management and related contractual costs of said 
     acquisitions, including contractual costs associated with 
     operations authorized by section 3109 of title 5, United 
     States Code, $4,106,363,000, plus reimbursements:  Provided, 
     That $1,115,757,000 shall be for pay and associated costs, of 
     which not to exceed $34,800,000 shall remain available until 
     September 30, 2017:  Provided further, That $2,512,863,000 
     shall be for operations and maintenance, of which not to 
     exceed $175,000,000 shall remain available until September 
     30, 2017:  Provided further, That $477,743,000 shall be for 
     information technology systems development, modernization, 
     and enhancement, and shall remain available until September 
     30, 2017:  Provided further, That amounts made available for 
     information technology systems development, modernization, 
     and enhancement may not be obligated or expended until the 
     Secretary of Veterans Affairs or the Chief Information 
     Officer of the Department of Veterans Affairs submits to the 
     Committees on Appropriations of both Houses of Congress a 
     certification of the amounts, in parts or in full, to be 
     obligated and expended for each development project:  
     Provided further, That amounts made available for salaries 
     and expenses, operations and maintenance, and information 
     technology systems development, modernization, and 
     enhancement may be transferred among the three subaccounts 
     after the Secretary of Veterans Affairs requests from the 
     Committees on Appropriations of both Houses of Congress the 
     authority to make the transfer and an approval is issued:  
     Provided further, That amounts made available for the 
     ``Information Technology Systems'' account for development, 
     modernization, and enhancement may be transferred among 
     projects or to newly defined projects:  Provided further, 
     That no project may be increased or decreased by more than 
     $1,000,000 of cost prior to submitting a request to the 
     Committees on Appropriations of both Houses of Congress to 
     make the transfer and an approval is issued, or absent a 
     response, a period of 30 days has elapsed:  Provided further, 
     That funds under this heading may be used by the Interagency 
     Program Office through the Department of Veterans Affairs to 
     develop a standard data reference terminology model:  
     Provided further, That, of the funds made available for 
     information technology systems development, modernization, 
     and enhancement for VistA Evolution, not more than 25 percent 
     may be obligated or expended until the Secretary of Veterans 
     Affairs submits to the Committees on Appropriations of both 
     Houses of Congress, and such Committees approve, a report 
     that describes: (1) the status of and changes to the VistA 
     Evolution program plan dated March 24, 2014 (hereinafter 
     referred to as the ``Plan''), the VistA 4 product roadmap 
     dated February 26, 2015 (``Roadmap''), and the VistA 4 
     Incremental Life Cycle Cost Estimate, dated October 26, 2014; 
     (2) any changes to the scope or functionality of projects 
     within the VistA Evolution program as established in the 
     Plan; (3) actual program costs incurred to date; (4) progress 
     in meeting the schedule milestones that have been established 
     in the Plan; (5) a Project Management Accountability System 
     (PMAS) Dashboard Progress report that identifies each VistA 
     Evolution project being tracked through PMAS, what 
     functionality it is intended to provide, and what evaluation 
     scores it has received throughout development; (6) the 
     definition being used for interoperability between the 
     electronic health record systems of the Department of Defense 
     and the Department of Veterans Affairs, the metrics to 
     measure the extent of interoperability, the milestones and 
     timeline associated with achieving interoperability, and the 
     baseline measurements associated with interoperability; (7) 
     progress toward developing and implementing all components 
     and levels of interoperability, including semantic 
     interoperability; (8) the change management tools in place to 
     facilitate the implementation of VistA Evolution and 
     interoperability; and (9) any changes to the governance 
     structure for the VistA Evolution program and its chain of 
     decisionmaking authority:  Provided further, That the funds 
     made available under this heading for information technology 
     systems development, modernization, and enhancement, shall be 
     for the projects, and in the amounts, specified under this 
     heading in the report accompanying this Act.

                      office of inspector general

       For necessary expenses of the Office of Inspector General, 
     to include information technology, in carrying out the 
     provisions of the Inspector General Act of 1978 (5 U.S.C. 
     App.), $126,766,000, of which $12,676,000 shall remain 
     available until September 30, 2017.

                      construction, major projects

       For constructing, altering, extending, and improving any of 
     the facilities, including parking projects, under the 
     jurisdiction or for the use of the Department of Veterans 
     Affairs, or for any of the purposes set forth in sections 
     316, 2404, 2406 and chapter 81 of title 38, United States 
     Code, not otherwise provided for, including planning, 
     architectural and engineering services, construction 
     management services, maintenance or guarantee period services 
     costs associated with equipment guarantees provided under the 
     project, services of claims analysts, offsite utility and 
     storm drainage system construction costs, and site 
     acquisition, where the estimated cost of a project is more 
     than the amount set forth in section 8104(a)(3)(A) of title 
     38, United States Code, or where funds for a project were 
     made available in a previous major project appropriation, 
     $1,027,064,000, of which $967,064,000 shall remain available 
     until September 30, 2020, and of which $60,000,000 shall 
     remain available until expended:  Provided, That except for 
     advance planning activities, including needs assessments 
     which may or may not lead to capital investments, and other 
     capital asset management related activities, including 
     portfolio development and management activities, and 
     investment strategy studies funded through the advance 
     planning fund and the planning and design activities funded 
     through the design fund, including needs assessments which 
     may or may not lead to capital investments, and salaries and 
     associated costs of the resident engineers who oversee those 
     capital investments funded through this account, and funds 
     provided for the purchase of land for the National Cemetery 
     Administration through the land acquisition line item, none 
     of the funds made available under this heading shall be used 
     for any project which has not been approved by the Congress 
     in the budgetary process:  Provided further, That funds made 
     available under this heading for fiscal year 2016, for each 
     approved project shall be obligated: (1) by the awarding of a 
     construction documents contract by September 30, 2016; and 
     (2) by the awarding of a construction contract by September 
     30, 2017:  Provided further, That the Secretary of Veterans 
     Affairs shall promptly submit to the Committees on 
     Appropriations of both Houses of Congress a written report on 
     any approved major construction project for which obligations 
     are not incurred within the time limitations established 
     above:  Provided further, That, of the amount made available 
     on October 1, 2016, under this heading, $490,700,000 for 
     Veterans Health Administration major construction projects 
     shall not be available until the Secretary of Veterans 
     Affairs:
       (1) Enters into an agreement with the U.S. Army Corps of 
     Engineers, to serve as the design and construction agent for 
     Veterans Health Administration projects with a Total 
     Estimated Cost of $250,000,000 or above.
       (2) That such an agreement will designate the U.S. Army 
     Corps of Engineers as the design and construction agent to 
     serve as--
       (A) the overall construction project manager, with a 
     dedicated project delivery team including engineers, medical 
     facility designers, and professional project managers;
       (B) the facility design manager, with a dedicated design 
     manager and technical support;
       (C) the design agent, with standardized and rigorous 
     facility designs;
       (D) the architect/engineer designer; and
       (E) the overall construction agent, with a dedicated 
     construction and technical team during pre-construction, 
     construction, and commissioning phases.
       (3) Certifies in writing that such an agreement is in 
     effect and will prevent subsequent major construction project 
     cost overruns, provides a copy of the agreement entered into 
     (and any required supplementary information) to the 
     Committees on Appropriations of both Houses of Congress, and 
     a period of 60 days has elapsed.

                      construction, minor projects

       For constructing, altering, extending, and improving any of 
     the facilities, including parking projects, under the 
     jurisdiction or for the use of the Department of Veterans 
     Affairs, including planning and assessments of needs which 
     may lead to capital investments, architectural and 
     engineering services, maintenance or guarantee period 
     services costs associated with equipment guarantees provided 
     under the project, services of claims analysts, offsite 
     utility and storm drainage system construction costs, and 
     site acquisition, or for any of the purposes set forth in 
     sections 316, 2404, 2406 and chapter 81 of title 38, United 
     States Code, not otherwise provided for, where the estimated 
     cost of a project is equal to or less than the amount set 
     forth in section 8104(a)(3)(A) of title 38, United States 
     Code, $378,080,000, to remain available until September 30, 
     2020, along with unobligated balances of previous 
     ``Construction, Minor Projects'' appropriations which are 
     hereby made available for any project where the estimated 
     cost is equal to or less than the amount set forth in such 
     section:  Provided, That funds made available under this 
     heading shall be for: (1) repairs to any of the nonmedical 
     facilities under the jurisdiction or for the use of the 
     Department which are necessary because of loss or damage 
     caused by any natural disaster or catastrophe; and (2) 
     temporary measures necessary to prevent or to minimize 
     further loss by such causes.

       grants for construction of state extended care facilities

       For grants to assist States to acquire or construct State 
     nursing home and domiciliary facilities and to remodel, 
     modify, or alter existing hospital, nursing home, and 
     domiciliary facilities in State homes, for furnishing care to 
     veterans as authorized by sections 8131 through

[[Page 20349]]

     8137 of title 38, United States Code, $100,000,000, to remain 
     available until expended.

             grants for construction of veterans cemeteries

       For grants to assist States and tribal organizations in 
     establishing, expanding, or improving veterans cemeteries as 
     authorized by section 2408 of title 38, United States Code, 
     $46,000,000, to remain available until expended.

                       Administrative Provisions

                     (including transfer of funds)

       Sec. 201.  Any appropriation for fiscal year 2016 for 
     ``Compensation and Pensions'', ``Readjustment Benefits'', and 
     ``Veterans Insurance and Indemnities'' may be transferred as 
     necessary to any other of the mentioned appropriations:  
     Provided, That, before a transfer may take place, the 
     Secretary of Veterans Affairs shall request from the 
     Committees on Appropriations of both Houses of Congress the 
     authority to make the transfer and such Committees issue an 
     approval, or absent a response, a period of 30 days has 
     elapsed.

                     (including transfer of funds)

       Sec. 202.  Amounts made available for the Department of 
     Veterans Affairs for fiscal year 2016, in this Act or any 
     other Act, under the ``Medical Services'', ``Medical support 
     and compliance'', and ``Medical Facilities'' accounts may be 
     transferred among the accounts:  Provided, That any transfers 
     between the ``Medical Services'' and ``Medical Support and 
     Compliance'' accounts of 1 percent or less of the total 
     amount appropriated to the account in this or any other Act 
     may take place subject to notification from the Secretary of 
     Veterans Affairs to the Committees on Appropriations of both 
     Houses of Congress of the amount and purpose of the transfer: 
      Provided further, That any transfers between the ``Medical 
     Services'' and ``Medical Support and Compliance'' accounts in 
     excess of 1 percent, or exceeding the cumulative 1 percent 
     for the fiscal year, may take place only after the Secretary 
     requests from the Committees on Appropriations of both Houses 
     of Congress the authority to make the transfer and an 
     approval is issued:  Provided further, That any transfers to 
     or from the ``Medical Facilities'' account may take place 
     only after the Secretary requests from the Committees on 
     Appropriations of both Houses of Congress the authority to 
     make the transfer and an approval is issued.
       Sec. 203.  Appropriations available in this title for 
     salaries and expenses shall be available for services 
     authorized by section 3109 of title 5, United States Code; 
     hire of passenger motor vehicles; lease of a facility or land 
     or both; and uniforms or allowances therefore, as authorized 
     by sections 5901 through 5902 of title 5, United States Code.
       Sec. 204.  No appropriations in this title (except the 
     appropriations for ``Construction, Major Projects'', and 
     ``Construction, Minor Projects'') shall be available for the 
     purchase of any site for or toward the construction of any 
     new hospital or home.
       Sec. 205.  No appropriations in this title shall be 
     available for hospitalization or examination of any persons 
     (except beneficiaries entitled to such hospitalization or 
     examination under the laws providing such benefits to 
     veterans, and persons receiving such treatment under sections 
     7901 through 7904 of title 5, United States Code, or the 
     Robert T. Stafford Disaster Relief and Emergency Assistance 
     Act (42 U.S.C. 5121 et seq.)), unless reimbursement of the 
     cost of such hospitalization or examination is made to the 
     ``Medical Services'' account at such rates as may be fixed by 
     the Secretary of Veterans Affairs.
       Sec. 206.  Appropriations available in this title for 
     ``Compensation and pensions'', ``Readjustment benefits'', and 
     ``Veterans insurance and indemnities'' shall be available for 
     payment of prior year accrued obligations required to be 
     recorded by law against the corresponding prior year accounts 
     within the last quarter of fiscal year 2015.
       Sec. 207.  Appropriations available in this title shall be 
     available to pay prior year obligations of corresponding 
     prior year appropriations accounts resulting from sections 
     3328(a), 3334, and 3712(a) of title 31, United States Code, 
     except that if such obligations are from trust fund accounts 
     they shall be payable only from ``Compensation and 
     Pensions''.

                     (including transfer of funds)

       Sec. 208.  Notwithstanding any other provision of law, 
     during fiscal year 2016, the Secretary of Veterans Affairs 
     shall, from the National Service Life Insurance Fund under 
     section 1920 of title 38, United States Code, the Veterans' 
     Special Life Insurance Fund under section 1923 of title 38, 
     United States Code, and the United States Government Life 
     Insurance Fund under section 1955 of title 38, United States 
     Code, reimburse the ``General operating expenses, Veterans 
     Benefits Administration'' and ``Information Technology 
     Systems'' accounts for the cost of administration of the 
     insurance programs financed through those accounts:  
     Provided, That reimbursement shall be made only from the 
     surplus earnings accumulated in such an insurance program 
     during fiscal year 2016 that are available for dividends in 
     that program after claims have been paid and actuarially 
     determined reserves have been set aside:  Provided further, 
     That, if the cost of administration of such an insurance 
     program exceeds the amount of surplus earnings accumulated in 
     that program, reimbursement shall be made only to the extent 
     of such surplus earnings:  Provided further, That the 
     Secretary shall determine the cost of administration for 
     fiscal year 2016 which is properly allocable to the provision 
     of each such insurance program and to the provision of any 
     total disability income insurance included in that insurance 
     program.
       Sec. 209.  Amounts deducted from enhanced-use lease 
     proceeds to reimburse an account for expenses incurred by 
     that account during a prior fiscal year for providing 
     enhanced-use lease services, may be obligated during the 
     fiscal year in which the proceeds are received.

                     (including transfer of funds)

       Sec. 210.  Funds available in this title or funds for 
     salaries and other administrative expenses shall also be 
     available to reimburse the Office of Resolution Management of 
     the Department of Veterans Affairs and the Office of 
     Employment Discrimination Complaint Adjudication under 
     section 319 of title 38, United States Code, for all services 
     provided at rates which will recover actual costs but not to 
     exceed $43,700,000 for the Office of Resolution Management 
     and $3,400,000 for the Office of Employment Discrimination 
     Complaint Adjudication:  Provided, That payments may be made 
     in advance for services to be furnished based on estimated 
     costs:  Provided further, That amounts received shall be 
     credited to the ``General Administration'' and ``Information 
     Technology Systems'' accounts for use by the office that 
     provided the service.

                          (transfer of funds)

       Sec. 211.  Of the amounts made available to the Department 
     of Veterans Affairs for fiscal year 2016 for the Office of 
     Rural Health under the heading ``Medical Services'', 
     including any advance appropriation for fiscal year 2016 
     provided in prior appropriation Acts, up to $20,000,000 may 
     be transferred to and merged with funds appropriated under 
     the heading ``Grants for Construction of State Extended Care 
     Facilities''.
       Sec. 212.  No funds of the Department of Veterans Affairs 
     shall be available for hospital care, nursing home care, or 
     medical services provided to any person under chapter 17 of 
     title 38, United States Code, for a non-service-connected 
     disability described in section 1729(a)(2) of such title, 
     unless that person has disclosed to the Secretary of Veterans 
     Affairs, in such form as the Secretary may require, current, 
     accurate third-party reimbursement information for purposes 
     of section 1729 of such title:  Provided, That the Secretary 
     may recover, in the same manner as any other debt due the 
     United States, the reasonable charges for such care or 
     services from any person who does not make such disclosure as 
     required:  Provided further, That any amounts so recovered 
     for care or services provided in a prior fiscal year may be 
     obligated by the Secretary during the fiscal year in which 
     amounts are received.

                     (including transfer of funds)

       Sec. 213.  Notwithstanding any other provision of law, 
     proceeds or revenues derived from enhanced-use leasing 
     activities (including disposal) may be deposited into the 
     ``Construction, Major Projects'' and ``Construction, Minor 
     Projects'' accounts and be used for construction (including 
     site acquisition and disposition), alterations, and 
     improvements of any medical facility under the jurisdiction 
     or for the use of the Department of Veterans Affairs. Such 
     sums as realized are in addition to the amount provided for 
     in ``Construction, Major Projects'' and ``Construction, Minor 
     Projects''.
       Sec. 214.  Amounts made available under ``Medical 
     Services'' are available--
       (1) for furnishing recreational facilities, supplies, and 
     equipment; and
       (2) for funeral expenses, burial expenses, and other 
     expenses incidental to funerals and burials for beneficiaries 
     receiving care in the Department.

                     (including transfer of funds)

       Sec. 215.  Such sums as may be deposited to the Medical 
     Care Collections Fund pursuant to section 1729A of title 38, 
     United States Code, may be transferred to ``Medical 
     Services'', to remain available until expended for the 
     purposes of that account:  Provided, That, for fiscal year 
     2016, up to $27,000,000 deposited in the Department of 
     Veterans Affairs Medical Care Collections Fund shall be 
     transferred to ``Information Technology Systems'', to remain 
     available until expended, for development of the Medical Care 
     Collections Fund electronic data exchange provider and payer 
     system.
       Sec. 216.  The Secretary of Veterans Affairs may enter into 
     agreements with Indian tribes and tribal organizations which 
     are party to the Alaska Native Health Compact with the Indian 
     Health Service, and Indian tribes and tribal organizations 
     serving rural Alaska which have entered into contracts with 
     the Indian Health Service under the Indian Self Determination 
     and Educational Assistance Act, to provide healthcare, 
     including behavioral health and dental care. The Secretary 
     shall require participating veterans and facilities to comply 
     with all appropriate rules and regulations, as established by 
     the Secretary. The term ``rural Alaska'' shall mean those 
     lands sited within the external boundaries of the Alaska 
     Native regions specified in sections 7(a)(1)-(4) and (7)-(12) 
     of the Alaska Native Claims Settlement Act, as amended (43 
     U.S.C. 1606), and those lands within the Alaska Native 
     regions specified in sections 7(a)(5) and 7(a)(6) of the 
     Alaska Native Claims Settlement Act, as amended (43 U.S.C. 
     1606), which are not within the boundaries of the 
     municipality of Anchorage, the Fairbanks North Star Borough, 
     the Kenai Peninsula Borough or the Matanuska Susitna Borough.

                     (including transfer of funds)

       Sec. 217.  Such sums as may be deposited to the Department 
     of Veterans Affairs Capital

[[Page 20350]]

     Asset Fund pursuant to section 8118 of title 38, United 
     States Code, may be transferred to the ``Construction, Major 
     Projects'' and ``Construction, Minor Projects'' accounts, to 
     remain available until expended for the purposes of these 
     accounts.
       Sec. 218.  None of the funds made available in this title 
     may be used to implement any policy prohibiting the Directors 
     of the Veterans Integrated Services Networks from conducting 
     outreach or marketing to enroll new veterans within their 
     respective Networks.
       Sec. 219.  The Secretary of Veterans Affairs shall submit 
     to the Committees on Appropriations of both Houses of 
     Congress a quarterly report on the financial status of the 
     Veterans Health Administration.

                     (including transfer of funds)

       Sec. 220.  Amounts made available under the ``Medical 
     Services'', ``Medical Support and Compliance'', ``Medical 
     Facilities'', ``General Operating Expenses, Veterans Benefits 
     Administration'', ``General Administration'', and ``National 
     Cemetery Administration'' accounts for fiscal year 2016 may 
     be transferred to or from the ``Information Technology 
     Systems'' account:  Provided, That, before a transfer may 
     take place, the Secretary of Veterans Affairs shall request 
     from the Committees on Appropriations of both Houses of 
     Congress the authority to make the transfer and an approval 
     is issued.
       Sec. 221.  None of the funds appropriated or otherwise made 
     available by this Act or any other Act for the Department of 
     Veterans Affairs may be used in a manner that is inconsistent 
     with: (1) section 842 of the Transportation, Treasury, 
     Housing and Urban Development, the Judiciary, the District of 
     Columbia, and Independent Agencies Appropriations Act, 2006 
     (Public Law 109-115; 119 Stat. 2506); or (2) section 
     8110(a)(5) of title 38, United States Code.
       Sec. 222.  Of the amounts made available to the Department 
     of Veterans Affairs for fiscal year 2016, in this Act or any 
     other Act, under the ``Medical Facilities'' account for 
     nonrecurring maintenance, not more than 20 percent of the 
     funds made available shall be obligated during the last 2 
     months of that fiscal year:  Provided, That the Secretary may 
     waive this requirement after providing written notice to the 
     Committees on Appropriations of both Houses of Congress.

                     (including transfer of funds)

       Sec. 223.  Of the amounts appropriated to the Department of 
     Veterans Affairs for fiscal year 2016 for ``Medical 
     Services'', ``Medical Support and Compliance'', ``Medical 
     Facilities'', ``Construction, Minor Projects'', and 
     ``Information Technology Systems'', up to $266,303,000, plus 
     reimbursements, may be transferred to the Joint Department of 
     Defense-Department of Veterans Affairs Medical Facility 
     Demonstration Fund, established by section 1704 of the 
     National Defense Authorization Act for Fiscal Year 2010 
     (Public Law 111-84; 123 Stat. 3571) and may be used for 
     operation of the facilities designated as combined Federal 
     medical facilities as described by section 706 of the Duncan 
     Hunter National Defense Authorization Act for Fiscal Year 
     2009 (Public Law 110-417; 122 Stat. 4500):  Provided, That 
     additional funds may be transferred from accounts designated 
     in this section to the Joint Department of Defense-Department 
     of Veterans Affairs Medical Facility Demonstration Fund upon 
     written notification by the Secretary of Veterans Affairs to 
     the Committees on Appropriations of both Houses of Congress:  
     Provided further, That section 223 of Title II of Division I 
     of Public Law 113-235 is repealed.

                     (including transfer of funds)

       Sec. 224.  Of the amounts appropriated to the Department of 
     Veterans Affairs which become available on October 1, 2016, 
     for ``Medical Services'', ``Medical Support and Compliance'', 
     and ``Medical Facilities'', up to $265,675,000, plus 
     reimbursements, may be transferred to the Joint Department of 
     Defense-Department of Veterans Affairs Medical Facility 
     Demonstration Fund, established by section 1704 of the 
     National Defense Authorization Act for Fiscal Year 2010 
     (Public Law 111-84; 123 Stat. 3571) and may be used for 
     operation of the facilities designated as combined Federal 
     medical facilities as described by section 706 of the Duncan 
     Hunter National Defense Authorization Act for Fiscal Year 
     2009 (Public Law 110-417; 122 Stat. 4500):  Provided, That 
     additional funds may be transferred from accounts designated 
     in this section to the Joint Department of Defense-Department 
     of Veterans Affairs Medical Facility Demonstration Fund upon 
     written notification by the Secretary of Veterans Affairs to 
     the Committees on Appropriations of both Houses of Congress.

                     (including transfer of funds)

       Sec. 225.  Such sums as may be deposited to the Medical 
     Care Collections Fund pursuant to section 1729A of title 38, 
     United States Code, for healthcare provided at facilities 
     designated as combined Federal medical facilities as 
     described by section 706 of the Duncan Hunter National 
     Defense Authorization Act for Fiscal Year 2009 (Public Law 
     110-417; 122 Stat. 4500) shall also be available: (1) for 
     transfer to the Joint Department of Defense-Department of 
     Veterans Affairs Medical Facility Demonstration Fund, 
     established by section 1704 of the National Defense 
     Authorization Act for Fiscal Year 2010 (Public Law 111-84; 
     123 Stat. 3571); and (2) for operations of the facilities 
     designated as combined Federal medical facilities as 
     described by section 706 of the Duncan Hunter National 
     Defense Authorization Act for Fiscal Year 2009 (Public Law 
     110-417; 122 Stat. 4500).

                          (transfer of funds)

       Sec. 226.  Of the amounts available in this title for 
     ``Medical Services'', ``Medical Support and Compliance'', and 
     ``Medical Facilities'', a minimum of $15,000,000 shall be 
     transferred to the DOD-VA Health Care Sharing Incentive Fund, 
     as authorized by section 8111(d) of title 38, United States 
     Code, to remain available until expended, for any purpose 
     authorized by section 8111 of title 38, United States Code.

                    (including rescissions of funds)

       Sec. 227. (a) Of the funds appropriated in division I of 
     Public Law 113-235, the following amounts which become 
     available on October 1, 2015, are hereby rescinded from the 
     following accounts in the amounts specified:
       (1) ``Department of Veterans Affairs, Medical Services'', 
     $1,400,000,000.
       (2) ``Department of Veterans Affairs, Medical Support and 
     Compliance'', $150,000,000.
       (3) ``Department of Veterans Affairs, Medical Facilities'', 
     $250,000,000.
       (b) In addition to amounts provided elsewhere in this Act, 
     an additional amount is appropriated to the following 
     accounts in the amounts specified to remain available until 
     September 30, 2017:
       (1) ``Department of Veterans Affairs, Medical Services'', 
     $1,400,000,000.
       (2) ``Department of Veterans Affairs, Medical Support and 
     Compliance'', $100,000,000.
       (3) ``Department of Veterans Affairs, Medical Facilities'', 
     $250,000,000.
       Sec. 228.  The Secretary of the Department of Veterans 
     Affairs shall notify the Committees on Appropriations of both 
     Houses of Congress of all bid savings in major construction 
     projects that total at least $5,000,000, or 5 percent of the 
     programmed amount of the project, whichever is less:  
     Provided, That such notification shall occur within 14 days 
     of a contract identifying the programmed amount:  Provided 
     further, That the Secretary shall notify the Committees on 
     Appropriations of both Houses of Congress 14 days prior to 
     the obligation of such bid savings and shall describe the 
     anticipated use of such savings.
       Sec. 229.  The scope of work for a project included in 
     ``Construction, Major Projects'' may not be increased above 
     the scope specified for that project in the original 
     justification data provided to the Congress as part of the 
     request for appropriations.
       Sec. 230.  The Secretary of Veterans Affairs shall submit 
     to the Committees on Appropriations of both Houses of 
     Congress a quarterly report that contains the following 
     information from each Veterans Benefits Administration 
     Regional Office: (1) the average time to complete a 
     disability compensation claim; (2) the number of claims 
     pending more than 125 days; (3) error rates; (4) the number 
     of claims personnel; (5) any corrective action taken within 
     the quarter to address poor performance; (6) training 
     programs undertaken; and (7) the number and results of 
     Quality Review Team audits:  Provided, That each quarterly 
     report shall be submitted no later than 30 days after the end 
     of the respective quarter.
       Sec. 231.  Of the funds provided to the Department of 
     Veterans Affairs for fiscal year 2016 for ``Medical 
     Services'' and ``Medical Support and Compliance'', a maximum 
     of $5,000,000 may be obligated from the ``Medical Services'' 
     account and a maximum of $154,596,000 may be obligated from 
     the ``Medical Support and Compliance'' account for the VistA 
     Evolution and electronic health record interoperability 
     projects:  Provided, That funds in addition to these amounts 
     may be obligated for the VistA Evolution and electronic 
     health record interoperability projects upon written 
     notification by the Secretary of Veterans Affairs to the 
     Committees on Appropriations of both Houses of Congress.
       Sec. 232.  The Secretary of Veterans Affairs shall provide 
     written notification to the Committees on Appropriations of 
     both Houses of Congress 15 days prior to organizational 
     changes which result in the transfer of 25 or more full-time 
     equivalents from one organizational unit of the Department of 
     Veterans Affairs to another.
       Sec. 233.  The Secretary of Veterans Affairs shall provide 
     on a quarterly basis to the Committees on Appropriations of 
     both Houses of Congress notification of any single national 
     outreach and awareness marketing campaign in which 
     obligations exceed $2,000,000.
       Sec. 234.  Not more than $4,400,000 of the funds provided 
     in this Act under the heading ``Department of Veterans 
     Affairs--Departmental Administration--General 
     Administration'' may be used for the Office of Congressional 
     and Legislative Affairs.
       Sec. 235.  None of the funds available to the Department of 
     Veterans Affairs, in this or any other Act, may be used to 
     replace the current system by which the Veterans Integrated 
     Service Networks select and contract for diabetes monitoring 
     supplies and equipment.

                         (rescissions of funds)

       Sec. 236.  Of the discretionary funds made available in 
     title II of division I of Public Law 113-235 for the 
     Department of Veterans Affairs for fiscal year 2016, 
     $198,000,000 are rescinded from ``Medical Services'', 
     $42,000,000 are rescinded from ``Medical Support and 
     Compliance'', and $15,000,000 are rescinded from ``Medical 
     Facilities''.

                         (rescissions of funds)

       Sec. 237. (a) There is hereby rescinded an aggregate amount 
     of $55,000,000 from the total budget authority provided for 
     fiscal year 2016 for discretionary accounts of the Department 
     of Veterans Affairs in--
       (1) this Act; or
       (2) any advance appropriation for fiscal year 2016 in prior 
     appropriation Acts.

[[Page 20351]]

       (b) The Secretary shall submit to the Committees on 
     Appropriations of both Houses of Congress a report specifying 
     the account and amount of each rescission not later than 30 
     days following enactment of this Act.

                         (rescission of funds)

       Sec. 238.  Of the unobligated balances available within the 
     ``DOD-VA Health Care Sharing Incentive Fund'', $50,000,000 
     are hereby rescinded.

                         (rescissions of funds)

       Sec. 239.  Of the discretionary funds made available in 
     title II of division I of Public Law 113-235 for the 
     Department of Veterans Affairs for fiscal year 2015, 
     $1,052,000 are rescinded from ``General Administration'', and 
     $5,000,000 are rescinded from ``Construction, Minor 
     Projects''.

                         (rescissions of funds)

       Sec. 240. (a) There is hereby rescinded an aggregate amount 
     of $90,293,000 from prior year unobligated balances available 
     within discretionary accounts of the Department of Veterans 
     Affairs;
       (b) No funds may be rescinded from amounts provided under 
     the following headings:
       (1) ``Medical Services'';
       (2) ``Medical and Prosthetic Research'';
       (3) ``National Cemetery Administration'';
       (4) ``Board of Veterans Appeals'';
       (5) ``General Operating Expenses, Veterans Benefits 
     Administration'';
       (6) ``Office of Inspector General'';
       (7) ``Grants for Construction of State Extended Care 
     Facilities''; and
       (8) ``Grants for Construction of Veterans Cemeteries''.
       (c) No amounts may be rescinded from amounts that were 
     designated by the Congress as an emergency requirement 
     pursuant to the Concurrent Resolution on the Budget or the 
     Balanced Budget and Emergency Deficit Control Act of 1985, as 
     amended.
       (d) The Secretary shall submit to the Committees on 
     Appropriations of both Houses of Congress a report specifying 
     the account and amount of each rescission not later than 30 
     days following enactment of this Act.
       Sec. 241.  Section 2302(a)(2)(A)(viii) of title 5, United 
     States Code, is amended by inserting ``or under title 38'' 
     after ``of this title''.
       Sec. 242.  The Department of Veterans Affairs is authorized 
     to administer financial assistance grants and enter into 
     cooperative agreements with organizations, utilizing a 
     competitive selection process, to train and employ homeless 
     and at-risk veterans in natural resource conservation 
     management.
       Sec. 243.  Section 312 of title 38, United States Code, is 
     amended by adding at the end the following new subsection:
       ``(c)(1) Whenever the Inspector General, in carrying out 
     the duties and responsibilities established under the 
     Inspector General Act of 1978 (5 U.S.C. App.), issues a work 
     product that makes a recommendation or otherwise suggests 
     corrective action, the Inspector General shall--
       ``(A) submit the work product to--
       ``(i) the Secretary;
       ``(ii) the Committee on Veterans' Affairs, the Committee on 
     Homeland Security and Governmental Affairs, and the Committee 
     on Appropriations of the Senate;
       ``(iii) the Committee on Veterans' Affairs, the Committee 
     on Oversight and Government Reform, and the Committee on 
     Appropriations of the House of Representatives;
       ``(iv) if the work product was initiated upon request by an 
     individual or entity other than the Inspector General, that 
     individual or entity; and
       ``(v) any Member of Congress upon request; and
       ``(B) the Inspector General shall submit all final work 
     products to--
       ``(i) if the work product was initiated upon request by an 
     individual or entity other than the Inspector General, that 
     individual or entity; and
       ``(ii) any Member of Congress upon request; and
       ``(C) not later than 3 days after the work product is 
     submitted in final form to the Secretary, post the work 
     product on the Internet website of the Inspector General.
       ``(2) Nothing in this subsection shall be construed to 
     authorize the public disclosure of information that is 
     specifically prohibited from disclosure by any other 
     provision of law.''.
       Sec. 244.  None of the funds provided in this Act may be 
     used to pay the salary of any individual who (a) was the 
     Executive Director of the Office of Acquisition, Logistics 
     and Construction, and (b) who retired from Federal service in 
     the midst of an investigation, initiated by the Department of 
     Veterans Affairs, into delays and cost overruns associated 
     with the design and construction of the new medical center in 
     Aurora, Colorado.
       Sec. 245.  Of the amounts appropriated or otherwise made 
     available to the Department of Veterans Affairs for the 
     ``Medical Services'' account for fiscal year 2016 in this Act 
     of any other Act, not less than $10,000,000 shall be used to 
     hire additional caregiver support coordinators to support the 
     programs of assistance and support for caregivers of veterans 
     under section 1720G of title 38, United States Code.
       Sec. 246.  None of the funds appropriated or otherwise made 
     available to the Department of Veterans Affairs in this Act 
     may be used in a manner that would--
       (1) interfere with the ability of a veteran to participate 
     in a State-approved medicinal marijuana program;
       (2) deny any services from the Department to a veteran who 
     is participating in such a program; or
       (3) limit or interfere with the ability of a health care 
     provider of the Department to make appropriate 
     recommendations, fill out forms, or take steps to comply with 
     such a program.
       Sec. 247.  The Comptroller General of the United States 
     shall conduct random, periodic audits of medical facilities 
     of the Department of Veterans Affairs and the Veterans 
     Integrated Service Networks to assess whether such facilities 
     and Networks are complying with all standards imposed by law 
     or by the Secretary of Veterans Affairs with respect to the 
     timely access of veterans to hospital care, medical services, 
     and other health care from the Department.
       Sec. 248.  None of the amounts appropriated or otherwise 
     made available by this title may be used to transfer any 
     amount from the Filipino Veterans Equity Compensation Fund to 
     any other account in the Treasury of the United States.
       Sec. 249.  None of the amounts appropriated or otherwise 
     made available by title II may be used to carry out the Home 
     Marketing Incentive Program of the Department of Veterans 
     Affairs or to carry out the Appraisal Value Offer Program of 
     the Department with respect to an employee of the Department 
     in a senior executive position (as defined in section 713(g) 
     of title 38, United States Code).
       Sec. 250. (a) Not later than one year after the date of the 
     enactment of this Act, the Comptroller General of the United 
     States shall submit to the congressional veterans committees 
     a report evaluating the implementation by the Department of 
     Veterans Affairs of section 101 of the Veterans Access, 
     Choice, and Accountability Act of 2014 (Public Law 113-146; 
     38 U.S.C. 1701 note).
       (b) The report required by subsection (a) shall include, 
     with respect to the implementation of such section 101, an 
     evaluation of the following:
       (1) The effect of such implementation on the reduction in 
     the use of purchased care by the Department, including delays 
     or denials of care and interruptions in courses and 
     continuity of care.
       (2) The ability of health care providers to meet the demand 
     for primary, specialty, and behavioral health care under such 
     section 101 that cannot reasonably be provided in medical 
     facilities of the Department.
       (3) The efforts of the Department to recruit health care 
     providers to provide health care under such section 101.
       (4) The accuracy of the information provided to veterans 
     through call centers regarding the receipt of health care 
     under such section 101.
       (5) The timeliness of referrals of veterans by the 
     Department to health care providers under such section 101.
       (6) Unique issues and difficulties in the implementation of 
     section 101 with respect to veterans residing in rural areas, 
     the States of Alaska and Hawaii and states lacking a full 
     service VA Hospital.
       (7) With respect to rural areas: (A) an identification of 
     the average wait times for veterans in rural areas to receive 
     health care under such section 101, measured from when the 
     veteran first calls the Department or contracted call center 
     to request an appointment; (B) an assessment of utilization 
     rates for health care provided under such section 101 in 
     rural areas; (C) an assessment of the accessibility of 
     veterans in rural areas to primary and specialty care at 
     medical centers of the Department and from non-Department 
     health care providers under such section 101; (D) an 
     assessment of the status of any pilot programs created by the 
     Department to provide care under such section 101; (E) an 
     identification of the number of health care providers 
     providing health care under such section 101 to veterans in 
     rural areas, broken out by primary care providers, specialty 
     and subspecialty providers, and behavioral health providers 
     in each Veterans Integrated Service Network.
       (8) Recommendations for such improvements to the provision 
     of health care under such section 101 as the Comptroller 
     General considers appropriate.
       (c) In this section, the term ``congressional veterans 
     committees'' means the Veterans Affairs Committees of the 
     United States Senate and the House of Representatives and the 
     Subcommittee on Military Construction, Veterans Affairs and 
     Related Agencies of the Committees on Appropriations of the 
     United States Senate and the House of Representatives.
       Sec. 251.  Not later than February 1, 2016, the Secretary 
     of Veterans Affairs shall submit to the Committee on 
     Veterans' Affairs of the Senate and the Committee on 
     Veterans' Affairs of the House of Representatives a report 
     that supplements the report required under section 4002(c) of 
     the Surface Transportation and Veterans Health Care Choice 
     Improvement Act of 2015 (Public Law 114-41) and that contains 
     the following:
       (1) A description of the changes in access, if any, of 
     veterans in Alaska to purchased care from the Department of 
     Veterans Affairs that have resulted from implementation of 
     section 101 of the Veterans Access, Choice, and 
     Accountability Act of 2014 (Public Law 113-146), including 
     denials of care and interruptions in the course and 
     continuity of care.
       (2) An assessment of the performance of the Department in 
     providing health care under such section 101 in Alaska, 
     including--
       (A) the performance of call center service provided to 
     veterans;
       (B) the accuracy of call center information provided to 
     veterans and health care providers;
       (C) whether health care providers are agreeing to provide 
     health care under such section 101 in each of the major 
     communities in Alaska;

[[Page 20352]]

       (D) gaps in the availability of health care providers, 
     disaggregated by primary, specialty, subspecialty, and 
     behavioral health care;
       (E) impediments to the provision of health care under such 
     section 101; and
       (F) plans to mitigate those impediments.
       (3) An assessment of the status of health care provider 
     vacancies at the VA Alaska Healthcare System as of the date 
     of submittal of the report under this section, including 
     impediments to filling those vacancies and plans to mitigate 
     those impediments.
       (4) A description of the manner in which the Department 
     plans to serve the primary, specialty, and behavioral health 
     care needs of veterans in Alaska if the plan and 
     recommendations set forth in the report submitted under such 
     section 4002(c) are implemented, including a description of 
     specific strategies to be employed by the Department to 
     address gaps in the provision of health care to veterans and 
     the supply and demand of health care providers for veterans, 
     including the roles of tribal health providers and community 
     providers in addressing those gaps.
       Sec. 252.  None of the amounts appropriated or otherwise 
     made available by this title may be used--
       (1) to carry out the memorandum of the Veterans Benefits 
     Administration known as ``Fast Letter 13-10'', issued on May 
     20, 2013; or
       (2) to create or maintain any patient record-keeping system 
     other than those currently approved by the Department of 
     Veterans Affairs Central Office in Washington, District of 
     Columbia.
       Sec. 253. (a) Not later than 180 days after the date of the 
     enactment of this Act, the Comptroller General of the United 
     States shall submit to Congress a report on the recruitment 
     and retention of health care providers by the Department of 
     Veterans Affairs.
       (b) The report required by subsection (a) shall include the 
     following:
       (1) An identification of the ratio of veterans to health 
     care providers of the Department, disaggregated by State.
       (2) An analysis of the workload of primary and specialty 
     care providers of the Department, disaggregated by State.
       (3) An assessment of initiatives carried out by the 
     Veterans Health Administration to recruit and retain health 
     care providers of the Department.
       (4) An assessment of the extent to which the Veterans 
     Health Administration oversees health care providers of the 
     Department.
       (5) Such recommendations for improving the recruitment and 
     retention of health care providers of the Department as the 
     Comptroller General considers appropriate.
       Sec. 254. (a) Not later than 180 days after the date of the 
     enactment of this Act, the Secretary of Veterans Affairs 
     shall submit to Congress a report on the implementation by 
     the Department of Veterans Affairs of section 101 of the 
     Veterans Access, Choice, and Accountability Act of 2014 
     (Public Law 113-146; 38 U.S.C. 1701 note) in rural areas.
       (b) The report required by subsection (a) shall include the 
     following:
       (1) An identification of average wait times for veterans in 
     rural areas to receive health care under such section 101, 
     measured from when the veteran first calls the Department to 
     schedule an appointment.
       (2) An assessment of utilization rates for health care 
     provided under such section 101 in rural areas.
       (3) An assessment of the accessibility of veterans in rural 
     areas to primary and specialty care at medical centers of the 
     Department and from non-Department health care providers 
     under such section 101.
       (4) An identification of the number of health care 
     providers providing health care under such section 101 in 
     each Veterans Integrated Service Network.
       (5) An assessment of the status of any pilot programs 
     created by the Department to provide care under such section 
     101 in rural areas.
       Sec. 255.  Report on Use of Social Security Numbers by 
     Department of Veterans Affairs. (a) Report Required.--Not 
     later than 120 days after the date of the enactment of this 
     Act, the Secretary of Veterans Affairs shall submit to the 
     appropriate committees of Congress a report on the use of 
     social security numbers by the Department of Veterans Affairs 
     and the plans of the Secretary to discontinue the unnecessary 
     use.
       (b) Contents.--The report required by subsection (a) shall 
     include the following:
       (1) A list of documents and records of the Department of 
     Veterans Affairs that contain social security numbers.
       (2) A list of all government and non-government entities 
     and the numbers of their employees that have access to the 
     social security numbers of veterans that are stored by the 
     Department.
       (3) A description of how the Department, other governmental 
     entities, and persons use social security numbers they obtain 
     from the Department, including a description of any 
     information sharing arrangements that the Secretary may have 
     with the heads of other governmental entities.
       (4) The number of data breaches of Department of Veterans 
     Affairs information systems that involved social security 
     numbers that occurred during the five-year period ending on 
     the date of the enactment of this Act that the Secretary 
     discovered or that were reported to the Secretary, a 
     description and status of the investigations conducted by the 
     Secretary regarding such breaches, and a description of the 
     plans of the Secretary to remediate such breaches.
       (5) The plans of the Secretary, including a timeline, to 
     discontinue the unnecessary use by the Department of social 
     security numbers.
       (c) Appropriate Committees of Congress Defined.--In this 
     section, the term ``appropriate committees of Congress'' 
     means--
       (1) the Committee on Veterans' Affairs and the Committee on 
     Appropriations of the Senate; and
       (2) the Committee on Veterans' Affairs and the Committee on 
     Appropriations of the House of Representatives.
       Sec. 256. (a) Not later than 30 days after the date of the 
     enactment of this Act, the Secretary of Veterans Affairs 
     shall submit to the appropriate committees of Congress a 
     report that includes, with respect to the South Texas 
     Veterans Health Care System of the Department of Veterans 
     Affairs, the following:
       (1) A description of the nature and scope of any 
     foreseeable increase in wait times for medical appointments.
       (2) An assessment of whether a shortage of health care 
     providers is the primary cause of any such increase in wait 
     times.
       (3) An identification of any other causes of any such 
     increase in wait times.
       (4) A description of any action taken by the Department to 
     correct any such increase in wait times.
       (5) An assessment of any issues relating to access to care.
       (6) A plan for how the Secretary will remedy any such 
     increase in wait times, including a detailed description of 
     steps to be taken and a timeline for completion.
       (b) In this section, the term ``appropriate committees of 
     Congress'' means--
       (1) the Committee on Appropriations and the Committee on 
     Veterans' Affairs of the Senate; and
       (2) the Committee on Appropriations and the Committee on 
     Veterans' Affairs of the House of Representatives.
       Sec. 257. (a) Not later than 30 days after the date of the 
     enactment of this Act, the Secretary of Veterans Affairs 
     shall, in consultation with the Secretary of Defense, enter 
     into a contract with an independent third party described in 
     subsection (b) to carry out a study on the impact of 
     participation in combat during service in the Armed Forces on 
     suicides and other mental health issues among members of the 
     Armed Forces and veterans.
       (b) An independent third party described in this subsection 
     is an independent third party that has appropriate 
     credentials to access information in the possession of the 
     Department of Defense and the Department of Veterans Affairs 
     that is necessary to carry out the study required under 
     subsection (a).
       Sec. 258. (a) The amount appropriated or otherwise made 
     available by this title under the heading ``medical and 
     prosthetic research'' under the heading ``Veterans Health 
     Administration'' is hereby increased by $8,922,462.
       (b) The amount appropriated or otherwise made available by 
     this title for fiscal year 2016 under the heading ``medical 
     services'' under the heading ``Veterans Health 
     Administration'' is hereby reduced by $8,922,462.
       Sec. 259.  Of the amounts appropriated or otherwise made 
     available by this title for ``medical services'', not more 
     than $5,000,000 shall be available to the Secretary of 
     Veterans Affairs to carry out a pilot program to assess the 
     feasibility and advisability of awarding grants to veterans 
     service agencies, veterans service organizations, and 
     nongovernmental organizations to provide furniture, household 
     items, and other assistance to formerly homeless veterans who 
     are moving into permanent housing to facilitate the 
     settlement of such veterans in such housing.
       Sec. 260.  Department of Veterans Affairs Action Plan To 
     Improve Vocational Rehabilitation and Education. (a) In 
     General.--Not later than 270 days after the date of the 
     enactment of this Act, the Secretary of Veterans Affairs 
     shall develop and publish an action plan for improving the 
     services and assistance provided under chapter 31 of title 
     38, United States Code.
       (b) Elements.--The plan required by subsection (a) shall 
     include each of the following:
       (1) A comprehensive analysis of, and recommendations and a 
     proposed implementation plan for remedying workload 
     management challenges at regional offices of the Department 
     of Veterans Affairs, including steps to reduce counselor 
     caseloads of veterans participating in a rehabilitation 
     program under such chapter, particularly for counselors who 
     are assisting veterans with traumatic brain injury and post-
     traumatic stress disorder and counselors with educational and 
     vocational counseling workloads.
       (2) A comprehensive analysis of the reasons for the 
     disproportionately low percentage of veterans with service-
     connected disabilities who served in the Armed Forces after 
     September 11, 2001, who opt to participate in a 
     rehabilitation program under such chapter relative to the 
     percentage of such veterans who use their entitlement to 
     educational assistance under chapter 33 of title 38, United 
     States Code, including an analysis of barriers to timely 
     enrollment in rehabilitation programs under chapter 31 of 
     such title and of any barriers to a veteran enrolling in the 
     program of that veteran's choice.
       (3) Recommendations and a proposed implementation plan for 
     encouraging more veterans with service-connected disabilities 
     who served in the Armed Forces after September 11, 2001, to 
     participate in rehabilitation programs under chapter 31 of 
     such title.

[[Page 20353]]

       (4) A national staff training program for vocational 
     rehabilitation counselors of the Department that includes the 
     provision of--
       (A) training to assist counselors in understanding the very 
     profound disorientation experienced by veterans with service-
     connected disabilities whose lives and life-plans have been 
     upended and out of their control because of such 
     disabilities;
       (B) training to assist counselors in working in partnership 
     with veterans on individual rehabilitation plans; and
       (C) training on post-traumatic stress disorder and other 
     mental health conditions and on moderate to severe traumatic 
     brain injury that is designed to improve the ability of such 
     counselors to assist veterans with these conditions, 
     including by providing information on the broad spectrum of 
     such conditions and the effect of such conditions on an 
     individual's abilities and functional limitations.

                               TITLE III

                            RELATED AGENCIES

                  American Battle Monuments Commission

                         salaries and expenses

       For necessary expenses, not otherwise provided for, of the 
     American Battle Monuments Commission, including the 
     acquisition of land or interest in land in foreign countries; 
     purchases and repair of uniforms for caretakers of national 
     cemeteries and monuments outside of the United States and its 
     territories and possessions; rent of office and garage space 
     in foreign countries; purchase (one-for-one replacement basis 
     only) and hire of passenger motor vehicles; not to exceed 
     $7,500 for official reception and representation expenses; 
     and insurance of official motor vehicles in foreign 
     countries, when required by law of such countries, 
     $75,100,000, to remain available until expended.

                 foreign currency fluctuations account

       For necessary expenses, not otherwise provided for, of the 
     American Battle Monuments Commission, such sums as may be 
     necessary, to remain available until expended, for purposes 
     authorized by section 2109 of title 36, United States Code.

           United States Court of Appeals for Veterans Claims

                         salaries and expenses

       For necessary expenses for the operation of the United 
     States Court of Appeals for Veterans Claims as authorized by 
     sections 7251 through 7298 of title 38, United States Code, 
     $32,141,000:  Provided, That $2,500,000 shall be available 
     for the purpose of providing financial assistance as 
     described, and in accordance with the process and reporting 
     procedures set forth, under this heading in Public Law 102-
     229.

                      Department of Defense--Civil

                       Cemeterial Expenses, Army

                         salaries and expenses

       For necessary expenses for maintenance, operation, and 
     improvement of Arlington National Cemetery and Soldiers' and 
     Airmen's Home National Cemetery, including the purchase or 
     lease of passenger motor vehicles for replacement on a one-
     for-one basis only, and not to exceed $1,000 for official 
     reception and representation expenses, $70,800,000, of which 
     not to exceed $28,000,000 shall remain available until 
     September 30, 2018. In addition, such sums as may be 
     necessary for parking maintenance, repairs and replacement, 
     to be derived from the ``Lease of Department of Defense Real 
     Property for Defense Agencies'' account.

                      Armed Forces Retirement Home

                               trust fund

       For expenses necessary for the Armed Forces Retirement Home 
     to operate and maintain the Armed Forces Retirement Home--
     Washington, District of Columbia, and the Armed Forces 
     Retirement Home--Gulfport, Mississippi, to be paid from funds 
     available in the Armed Forces Retirement Home Trust Fund, 
     $64,300,000, of which $1,000,000 shall remain available until 
     expended for construction and renovation of the physical 
     plants at the Armed Forces Retirement Home--Washington, 
     District of Columbia, and the Armed Forces Retirement Home--
     Gulfport, Mississippi.

                       Administrative Provisions

       Sec. 301.  Funds appropriated in this Act under the heading 
     ``Department of Defense--Civil, Cemeterial Expenses, Army'', 
     may be provided to Arlington County, Virginia, for the 
     relocation of the federally owned water main at Arlington 
     National Cemetery, making additional land available for 
     ground burials.
       Sec. 302.  Amounts deposited during the current fiscal year 
     to the special account established under 10 U.S.C. 4727 are 
     appropriated and shall be available until expended to support 
     activities at the Army National Military Cemeteries.
       Sec. 303.  For an additional amount for ``Department of 
     Defense--Civil Cemeterial Expenses, Army'' in this title, 
     $30,000,000:  Provided, That notwithstanding any other 
     provision of law, such funds may be transferred to the 
     Federal Highway Administration, Department of Transportation, 
     for construction of access roads adjacent to Arlington 
     National Cemetery to support land acquisition for the 
     expansion of the cemetery.

                                TITLE IV

                           GENERAL PROVISIONS

       Sec. 401.  No part of any appropriation contained in this 
     Act shall remain available for obligation beyond the current 
     fiscal year unless expressly so provided herein.
       Sec. 402.  None of the funds made available in this Act may 
     be used for any program, project, or activity, when it is 
     made known to the Federal entity or official to which the 
     funds are made available that the program, project, or 
     activity is not in compliance with any Federal law relating 
     to risk assessment, the protection of private property 
     rights, or unfunded mandates.
       Sec. 403.  Such sums as may be necessary for fiscal year 
     2016 for pay raises for programs funded by this Act shall be 
     absorbed within the levels appropriated in this Act.
       Sec. 404.  No part of any funds appropriated in this Act 
     shall be used by an agency of the executive branch, other 
     than for normal and recognized executive-legislative 
     relationships, for publicity or propaganda purposes, and for 
     the preparation, distribution, or use of any kit, pamphlet, 
     booklet, publication, radio, television, or film presentation 
     designed to support or defeat legislation pending before 
     Congress, except in presentation to Congress itself.
       Sec. 405.  All departments and agencies funded under this 
     Act are encouraged, within the limits of the existing 
     statutory authorities and funding, to expand their use of 
     ``E-Commerce'' technologies and procedures in the conduct of 
     their business practices and public service activities.
       Sec. 406.  Unless stated otherwise, all reports and 
     notifications required by this Act shall be submitted to the 
     Subcommittee on Military Construction and Veterans Affairs, 
     and Related Agencies of the Committee on Appropriations of 
     the House of Representatives and the Subcommittee on Military 
     Construction and Veterans Affairs, and Related Agencies of 
     the Committee on Appropriations of the Senate.
       Sec. 407.  None of the funds made available in this Act may 
     be transferred to any department, agency, or instrumentality 
     of the United States Government except pursuant to a transfer 
     made by, or transfer authority provided in, this or any other 
     appropriations Act.
       Sec. 408. (a) Any agency receiving funds made available in 
     this Act, shall, subject to subsections (b) and (c), post on 
     the public Web site of that agency any report required to be 
     submitted by the Congress in this or any other Act, upon the 
     determination by the head of the agency that it shall serve 
     the national interest.
       (b) Subsection (a) shall not apply to a report if--
       (1) the public posting of the report compromises national 
     security; or
       (2) the report contains confidential or proprietary 
     information.
       (c) The head of the agency posting such report shall do so 
     only after such report has been made available to the 
     requesting Committee or Committees of Congress for no less 
     than 45 days.
       Sec. 409. (a) None of the funds made available in this Act 
     may be used to maintain or establish a computer network 
     unless such network blocks the viewing, downloading, and 
     exchanging of pornography.
       (b) Nothing in subsection (a) shall limit the use of funds 
     necessary for any Federal, State, tribal, or local law 
     enforcement agency or any other entity carrying out criminal 
     investigations, prosecution, or adjudication activities.
       Sec. 410. (a) In General.--None of the funds appropriated 
     or otherwise made available to the Department of Defense in 
     this Act may be used to construct, renovate, or expand any 
     facility in the United States, its territories, or 
     possessions to house any individual detained at United States 
     Naval Station, Guantanamo Bay, Cuba, for the purposes of 
     detention or imprisonment in the custody or under the control 
     of the Department of Defense.
       (b) The prohibition in subsection (a) shall not apply to 
     any modification of facilities at United States Naval 
     Station, Guantanamo Bay, Cuba.
       (c) An individual described in this subsection is any 
     individual who, as of June 24, 2009, is located at United 
     States Naval Station, Guantanamo Bay, Cuba, and who--
       (1) is not a citizen of the United States or a member of 
     the Armed Forces of the United States; and
       (2) is--
       (A) in the custody or under the effective control of the 
     Department of Defense; or
       (B) otherwise under detention at United States Naval 
     Station, Guantanamo Bay, Cuba.
        This Act may be cited as the ``Military Construction, 
     Veterans Affairs, and Related Agencies Appropriations Act, 
     2016''.


                  Motion Offered by Mr. Brady of Texas

  Mr. BRADY of Texas. Mr. Speaker, I have a motion at the desk.
  The SPEAKER pro tempore. The Clerk will designate the motion.
  The text of the motion is as follows:

  Mr. Brady of Texas moves that the House concur in the Senate 
amendment to H.R. 2029 with the amendments specified in section 3 of 
House Resolution 566.

  The text of House amendment No. 2 to the Senate amendment to the text 
is as follows:

       At the end of House amendment #1, insert the following:

      DIVISION Q--PROTECTING AMERICANS FROM TAX HIKES ACT OF 2015

     SECTION 1. SHORT TITLE, ETC.

       (a) Short Title.--This division may be cited as the 
     ``Protecting Americans from Tax Hikes Act of 2015''.
       (b) Amendment of 1986 Code.--Except as otherwise expressly 
     provided, whenever in this division 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

[[Page 20354]]

     section or other provision of the Internal Revenue Code of 
     1986.
       (c) Table of Contents.--The table of contents for this 
     division is as follows:

      DIVISION Q--PROTECTING AMERICANS FROM TAX HIKES ACT OF 2015

Sec. 1. Short title, etc.

                           TITLE I--EXTENDERS

                    Subtitle A--Permanent Extensions

            Part 1--Tax Relief for Families and Individuals

Sec. 101. Enhanced child tax credit made permanent.
Sec. 102. Enhanced American opportunity tax credit made permanent.
Sec. 103. Enhanced earned income tax credit made permanent.
Sec. 104. Extension and modification of deduction for certain expenses 
              of elementary and secondary school teachers.
Sec. 105. Extension of parity for exclusion from income for employer-
              provided mass transit and parking benefits.
Sec. 106. Extension of deduction of State and local general sales 
              taxes.

                Part 2--Incentives for Charitable Giving

Sec. 111. Extension and modification of special rule for contributions 
              of capital gain real property made for conservation 
              purposes.
Sec. 112. Extension of tax-free distributions from individual 
              retirement plans for charitable purposes.
Sec. 113. Extension and modification of charitable deduction for 
              contributions of food inventory.
Sec. 114. Extension of modification of tax treatment of certain 
              payments to controlling exempt organizations.
Sec. 115. Extension of basis adjustment to stock of S corporations 
              making charitable contributions of property.

    Part 3--Incentives for Growth, Jobs, Investment, and Innovation

Sec. 121. Extension and modification of research credit.
Sec. 122. Extension and modification of employer wage credit for 
              employees who are active duty members of the uniformed 
              services.
Sec. 123. Extension of 15-year straight-line cost recovery for 
              qualified leasehold improvements, qualified restaurant 
              buildings and improvements, and qualified retail 
              improvements.
Sec. 124. Extension and modification of increased expensing limitations 
              and treatment of certain real property as section 179 
              property.
Sec. 125. Extension of treatment of certain dividends of regulated 
              investment companies.
Sec. 126. Extension of exclusion of 100 percent of gain on certain 
              small business stock.
Sec. 127. Extension of reduction in S-corporation recognition period 
              for built-in gains tax.
Sec. 128. Extension of subpart F exception for active financing income.

             Part 4--Incentives for Real Estate Investment

Sec. 131. Extension of minimum low-income housing tax credit rate for 
              non-Federally subsidized buildings.
Sec. 132. Extension of military housing allowance exclusion for 
              determining whether a tenant in certain counties is low-
              income.
Sec. 133. Extension of RIC qualified investment entity treatment under 
              FIRPTA.

                  Subtitle B--Extensions Through 2019

Sec. 141. Extension of new markets tax credit.
Sec. 142. Extension and modification of work opportunity tax credit.
Sec. 143. Extension and modification of bonus depreciation.
Sec. 144. Extension of look-thru treatment of payments between related 
              controlled foreign corporations under foreign personal 
              holding company rules.

                  Subtitle C--Extensions Through 2016

            Part 1--Tax Relief for Families and Individuals

Sec. 151. Extension and modification of exclusion from gross income of 
              discharge of qualified principal residence indebtedness.
Sec. 152. Extension of mortgage insurance premiums treated as qualified 
              residence interest.
Sec. 153. Extension of above-the-line deduction for qualified tuition 
              and related expenses.

    Part 2--Incentives for Growth, Jobs, Investment, and Innovation

Sec. 161. Extension of Indian employment tax credit.
Sec. 162. Extension and modification of railroad track maintenance 
              credit.
Sec. 163. Extension of mine rescue team training credit.
Sec. 164. Extension of qualified zone academy bonds.
Sec. 165. Extension of classification of certain race horses as 3-year 
              property.
Sec. 166. Extension of 7-year recovery period for motorsports 
              entertainment complexes.
Sec. 167. Extension and modification of accelerated depreciation for 
              business property on an Indian reservation.
Sec. 168. Extension of election to expense mine safety equipment.
Sec. 169. Extension of special expensing rules for certain film and 
              television productions; special expensing for live 
              theatrical productions.
Sec. 170. Extension of deduction allowable with respect to income 
              attributable to domestic production activities in Puerto 
              Rico.
Sec. 171. Extension and modification of empowerment zone tax 
              incentives.
Sec. 172. Extension of temporary increase in limit on cover over of rum 
              excise taxes to Puerto Rico and the Virgin Islands.
Sec. 173. Extension of American Samoa economic development credit.
Sec. 174. Moratorium on medical device excise tax.

       Part 3--Incentives for Energy Production and Conservation

Sec. 181. Extension and modification of credit for nonbusiness energy 
              property.
Sec. 182. Extension of credit for alternative fuel vehicle refueling 
              property.
Sec. 183. Extension of credit for 2-wheeled plug-in electric vehicles.
Sec. 184. Extension of second generation biofuel producer credit.
Sec. 185. Extension of biodiesel and renewable diesel incentives.
Sec. 186. Extension and modification of production credit for Indian 
              coal facilities.
Sec. 187. Extension of credits with respect to facilities producing 
              energy from certain renewable resources.
Sec. 188. Extension of credit for energy-efficient new homes.
Sec. 189. Extension of special allowance for second generation biofuel 
              plant property.
Sec. 190. Extension of energy efficient commercial buildings deduction.
Sec. 191. Extension of special rule for sales or dispositions to 
              implement FERC or State electric restructuring policy for 
              qualified electric utilities.
Sec. 192. Extension of excise tax credits relating to alternative 
              fuels.
Sec. 193. Extension of credit for new qualified fuel cell motor 
              vehicles.

                      TITLE II--PROGRAM INTEGRITY

Sec. 201. Modification of filing dates of returns and statements 
              relating to employee wage information and nonemployee 
              compensation to improve compliance.
Sec. 202. Safe harbor for de minimis errors on information returns and 
              payee statements.
Sec. 203. Requirements for the issuance of ITINs.
Sec. 204. Prevention of retroactive claims of earned income credit 
              after issuance of social security number.
Sec. 205. Prevention of retroactive claims of child tax credit.
Sec. 206. Prevention of retroactive claims of American opportunity tax 
              credit.
Sec. 207. Procedures to reduce improper claims.
Sec. 208. Restrictions on taxpayers who improperly claimed credits in 
              prior year.
Sec. 209. Treatment of credits for purposes of certain penalties.
Sec. 210. Increase the penalty applicable to paid tax preparers who 
              engage in willful or reckless conduct.
Sec. 211. Employer identification number required for American 
              opportunity tax credit.
Sec. 212. Higher education information reporting only to include 
              qualified tuition and related expenses actually paid.

                  TITLE III--MISCELLANEOUS PROVISIONS

                     Subtitle A--Family Tax Relief

Sec. 301. Exclusion for amounts received under the Work Colleges 
              Program.
Sec. 302. Improvements to section 529 accounts.
Sec. 303. Elimination of residency requirement for qualified ABLE 
              programs.
Sec. 304. Exclusion for wrongfully incarcerated individuals.
Sec. 305. Clarification of special rule for certain governmental plans.
Sec. 306. Rollovers permitted from other retirement plans into simple 
              retirement accounts.
Sec. 307. Technical amendment relating to rollover of certain airline 
              payment amounts.

[[Page 20355]]

Sec. 308. Treatment of early retirement distributions for nuclear 
              materials couriers, United States Capitol Police, Supreme 
              Court Police, and diplomatic security special agents.
Sec. 309. Prevention of extension of tax collection period for members 
              of the Armed Forces who are hospitalized as a result of 
              combat zone injuries.

               Subtitle B--Real Estate Investment Trusts

Sec. 311. Restriction on tax-free spinoffs involving REITs.
Sec. 312. Reduction in percentage limitation on assets of REIT which 
              may be taxable REIT subsidiaries.
Sec. 313. Prohibited transaction safe harbors.
Sec. 314. Repeal of preferential dividend rule for publicly offered 
              REITs.
Sec. 315. Authority for alternative remedies to address certain REIT 
              distribution failures.
Sec. 316. Limitations on designation of dividends by REITs.
Sec. 317. Debt instruments of publicly offered REITs and mortgages 
              treated as real estate assets.
Sec. 318. Asset and income test clarification regarding ancillary 
              personal property.
Sec. 319. Hedging provisions.
Sec. 320. Modification of REIT earnings and profits calculation to 
              avoid duplicate taxation.
Sec. 321. Treatment of certain services provided by taxable REIT 
              subsidiaries.
Sec. 322. Exception from FIRPTA for certain stock of REITs.
Sec. 323. Exception for interests held by foreign retirement or pension 
              funds.
Sec. 324. Increase in rate of withholding of tax on dispositions of 
              United States real property interests.
Sec. 325. Interests in RICs and REITs not excluded from definition of 
              United States real property interests.
Sec. 326. Dividends derived from RICs and REITs ineligible for 
              deduction for United States source portion of dividends 
              from certain foreign corporations.

                   Subtitle C--Additional Provisions

Sec. 331. Deductibility of charitable contributions to agricultural 
              research organizations.
Sec. 332. Removal of bond requirements and extending filing periods for 
              certain taxpayers with limited excise tax liability.
Sec. 333. Modifications to alternative tax for certain small insurance 
              companies.
Sec. 334. Treatment of timber gains.
Sec. 335. Modification of definition of hard cider.
Sec. 336. Church plan clarification.

                     Subtitle D--Revenue Provisions

Sec. 341. Updated ASHRAE standards for energy efficient commercial 
              buildings deduction.
Sec. 342. Excise tax credit equivalency for liquified petroleum gas and 
              liquified natural gas.
Sec. 343. Exclusion from gross income of certain clean coal power 
              grants to non-corporate taxpayers.
Sec. 344. Clarification of valuation rule for early termination of 
              certain charitable remainder unitrusts.
Sec. 345. Prevention of transfer of certain losses from tax indifferent 
              parties.
Sec. 346. Treatment of certain persons as employers with respect to 
              motion picture projects.

                      TITLE IV--TAX ADMINISTRATION

              Subtitle A--Internal Revenue Service Reforms

Sec. 401. Duty to ensure that Internal Revenue Service employees are 
              familiar with and act in accord with certain taxpayer 
              rights.
Sec. 402. IRS employees prohibited from using personal email accounts 
              for official business.
Sec. 403. Release of information regarding the status of certain 
              investigations.
Sec. 404. Administrative appeal relating to adverse determinations of 
              tax-exempt status of certain organizations.
Sec. 405. Organizations required to notify Secretary of intent to 
              operate under 501(c)(4).
Sec. 406. Declaratory judgments for 501(c)(4) and other exempt 
              organizations.
Sec. 407. Termination of employment of Internal Revenue Service 
              employees for taking official actions for political 
              purposes.
Sec. 408. Gift tax not to apply to contributions to certain exempt 
              organizations.
Sec. 409. Extend Internal Revenue Service authority to require 
              truncated Social Security numbers on Form W-2.
Sec. 410. Clarification of enrolled agent credentials.
Sec. 411. Partnership audit rules.

                  Subtitle B--United States Tax Court

           Part 1--Taxpayer Access to United States Tax Court

Sec. 421. Filing period for interest abatement cases.
Sec. 422. Small tax case election for interest abatement cases.
Sec. 423. Venue for appeal of spousal relief and collection cases.
Sec. 424. Suspension of running of period for filing petition of 
              spousal relief and collection cases.
Sec. 425. Application of Federal rules of evidence.

             Part 2--United States Tax Court Administration

Sec. 431. Judicial conduct and disability procedures.
Sec. 432. Administration, judicial conference, and fees.

       Part 3--Clarification Relating to United States Tax Court

Sec. 441. Clarification relating to United States Tax Court.

                   TITLE V--TRADE-RELATED PROVISIONS

Sec. 501. Modification of effective date of provisions relating to 
              tariff classification of recreational performance 
              outerwear.
Sec. 502. Agreement by Asia-Pacific Economic Cooperation members to 
              reduce rates of duty on certain environmental goods.

                      TITLE VI--BUDGETARY EFFECTS

Sec. 601. Budgetary effects.

                           TITLE I--EXTENDERS

                    Subtitle A--Permanent Extensions

            PART 1--TAX RELIEF FOR FAMILIES AND INDIVIDUALS

     SEC. 101. ENHANCED CHILD TAX CREDIT MADE PERMANENT.

       (a) In General.--Section 24(d)(1)(B)(i) is amended by 
     striking ``$10,000'' and inserting ``$3,000''.
       (b) Conforming Amendment.--Section 24(d) is amended by 
     striking paragraphs (3) and (4).
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after the date of the 
     enactment of this Act.

     SEC. 102. ENHANCED AMERICAN OPPORTUNITY TAX CREDIT MADE 
                   PERMANENT.

       (a) In General.--Section 25A(i) is amended by striking 
     ``and before 2018''.
       (b) Treatment of Possessions.--Section 1004(c)(1) of 
     division B of the American Recovery and Reinvestment Tax Act 
     of 2009 by striking ``and before 2018'' each place it 
     appears.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after the date of the 
     enactment of this Act.

     SEC. 103. ENHANCED EARNED INCOME TAX CREDIT MADE PERMANENT.

       (a) Increase in Credit Percentage for 3 or More Qualifying 
     Children Made Permanent.--Section 32(b)(1) is amended to read 
     as follows:
       ``(1) Percentages.--The credit percentage and the phaseout 
     percentage shall be determined as follows:


------------------------------------------------------------------------
  ``In the case of  an eligible      The credit         The phaseout
        individual with:           percentage is:      percentage is:
------------------------------------------------------------------------
1 qualifying child..............               34                  15.98
2 qualifying children...........               40                  21.06
3 or more qualifying children...               45                  21.06
No qualifying children..........             7.65                7.65''.
------------------------------------------------------------------------

       (b) Reduction of Marriage Penalty Made Permanent.--
       (1) In general.--Section 32(b)(2)(B) is amended to read as 
     follows:
       ``(B) Joint returns.--
       ``(i) In general.--In the case of a joint return filed by 
     an eligible individual and such individual's spouse, the 
     phaseout amount determined under subparagraph (A) shall be 
     increased by $5,000.
       ``(ii) Inflation adjustment.--In the case of any taxable 
     year beginning after 2015, the

[[Page 20356]]

     $5,000 amount in clause (i) shall be increased by an amount 
     equal to--

       ``(I) such dollar amount, multiplied by
       ``(II) the cost of living adjustment determined under 
     section 1(f)(3) for the calendar year in which the taxable 
     year begins determined by substituting `calendar year 2008' 
     for `calendar year 1992' in subparagraph (B) thereof.

       ``(iii) Rounding.--Subparagraph (A) of subsection (j)(2) 
     shall apply after taking into account any increase under 
     clause (ii).''.
       (c) Conforming Amendment.--Section 32(b) is amended by 
     striking paragraph (3).
       (d) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 104. EXTENSION AND MODIFICATION OF DEDUCTION FOR CERTAIN 
                   EXPENSES OF ELEMENTARY AND SECONDARY SCHOOL 
                   TEACHERS.

       (a) Deduction Made Permanent.--Section 62(a)(2)(D) is 
     amended by striking ``In the case of taxable years beginning 
     during 2002, 2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 
     2011, 2012, 2013, or 2014, the deductions'' and inserting 
     ``The deductions''.
       (b) Inflation Adjustment.--Section 62(d) is amended by 
     adding at the end the following new paragraph:
       ``(3) Inflation adjustment.--In the case of any taxable 
     year beginning after 2015, the $250 amount in subsection 
     (a)(2)(D) shall be increased by an amount equal to--
       ``(A) such dollar amount, multiplied by
       ``(B) the cost-of-living adjustment determined under 
     section 1(f)(3) for the calendar year in which the taxable 
     year begins, determined by substituting `calendar year 2014' 
     for `calendar year 1992' in subparagraph (B) thereof.
     Any increase determined under the preceding sentence shall be 
     rounded to the nearest multiple of $50.''.
       (c) Professional Development Expenses.--Section 62(a)(2)(D) 
     is amended--
       (1) by striking ``educator in connection'' and all that 
     follows and inserting ``educator--'', and
       (2) by inserting at the end the following:
       ``(i) by reason of the participation of the educator in 
     professional development courses related to the curriculum in 
     which the educator provides instruction or to the students 
     for which the educator provides instruction, and
       ``(ii) in connection with books, supplies (other than 
     nonathletic supplies for courses of instruction in health or 
     physical education), computer equipment (including related 
     software and services) and other equipment, and supplementary 
     materials used by the eligible educator in the classroom.''.
       (d) Effective Dates.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to taxable years beginning after December 31, 2014.
       (2) Modifications.--The amendments made by subsections (b) 
     and (c) shall apply to taxable years beginning after December 
     31, 2015.

     SEC. 105. EXTENSION OF PARITY FOR EXCLUSION FROM INCOME FOR 
                   EMPLOYER-PROVIDED MASS TRANSIT AND PARKING 
                   BENEFITS.

       (a) Mass Transit and Parking Parity.--Section 132(f)(2) is 
     amended--
       (1) by striking ``$100'' in subparagraph (A) and inserting 
     ``$175'', and
       (2) by striking the last sentence.
       (b) Effective Date.--The amendments made by this section 
     shall apply to months after December 31, 2014.

     SEC. 106. EXTENSION OF DEDUCTION OF STATE AND LOCAL GENERAL 
                   SALES TAXES.

       (a) In General.--Section 164(b)(5) is amended by striking 
     subparagraph (I).
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

                PART 2--INCENTIVES FOR CHARITABLE GIVING

     SEC. 111. EXTENSION AND MODIFICATION OF SPECIAL RULE FOR 
                   CONTRIBUTIONS OF CAPITAL GAIN REAL PROPERTY 
                   MADE FOR CONSERVATION PURPOSES.

       (a) Made Permanent.--
       (1) Individuals.--Section 170(b)(1)(E) is amended by 
     striking clause (vi).
       (2) Corporations.--Section 170(b)(2)(B) is amended by 
     striking clause (iii).
       (b) Contributions of Capital Gain Real Property Made for 
     Conservation Purposes by Native Corporations.--
       (1) In general.--Section 170(b)(2) is amended by 
     redesignating subparagraph (C) as subparagraph (D), and by 
     inserting after subparagraph (B) the following new 
     subparagraph:
       ``(C) Qualified conservation contributions by certain 
     native corporations.--
       ``(i) In general.--Any qualified conservation contribution 
     (as defined in subsection (h)(1)) which--

       ``(I) is made by a Native Corporation, and
       ``(II) is a contribution of property which was land 
     conveyed under the Alaska Native Claims Settlement Act,

     shall be allowed to the extent that the aggregate amount of 
     such contributions does not exceed the excess of the 
     taxpayer's taxable income over the amount of charitable 
     contributions allowable under subparagraph (A).
       ``(ii) Carryover.--If the aggregate amount of contributions 
     described in clause (i) exceeds the limitation of clause (i), 
     such excess shall be treated (in a manner consistent with the 
     rules of subsection (d)(2)) as a charitable contribution to 
     which clause (i) applies in each of the 15 succeeding taxable 
     years in order of time.
       ``(iii) Native corporation.--For purposes of this 
     subparagraph, the term `Native Corporation' has the meaning 
     given such term by section 3(m) of the Alaska Native Claims 
     Settlement Act.''.
       (2) Conforming amendments.--
       (A) Section 170(b)(2)(A) is amended by striking 
     ``subparagraph (B) applies'' and inserting ``subparagraph (B) 
     or (C) applies''.
       (B) Section 170(b)(2)(B)(ii) is amended by striking ``15 
     succeeding years'' and inserting ``15 succeeding taxable 
     years''.
       (3) Valid existing rights preserved.--Nothing in this 
     subsection (or any amendment made by this subsection) shall 
     be construed to modify the existing property rights validly 
     conveyed to Native Corporations (within the meaning of 
     section 3(m) of the Alaska Native Claims Settlement Act) 
     under such Act.
       (c) Effective Dates.--
       (1) Extension.--The amendments made by subsection (a) shall 
     apply to contributions made in taxable years beginning after 
     December 31, 2014.
       (2) Modification.--The amendments made by subsection (b) 
     shall apply to contributions made in taxable years beginning 
     after December 31, 2015.

     SEC. 112. EXTENSION OF TAX-FREE DISTRIBUTIONS FROM INDIVIDUAL 
                   RETIREMENT PLANS FOR CHARITABLE PURPOSES.

       (a) In General.--Section 408(d)(8) 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, 2014.

     SEC. 113. EXTENSION AND MODIFICATION OF CHARITABLE DEDUCTION 
                   FOR CONTRIBUTIONS OF FOOD INVENTORY.

       (a) Permanent Extension.--Section 170(e)(3)(C) is amended 
     by striking clause (iv).
       (b) Modifications.--Section 170(e)(3)(C), as amended by 
     subsection (a), is amended by striking clause (ii), by 
     redesignating clause (iii) as clause (vi), and by inserting 
     after clause (i) the following new clauses:
       ``(ii) Limitation.--The aggregate amount of such 
     contributions for any taxable year which may be taken into 
     account under this section shall not exceed--

       ``(I) in the case of any taxpayer other than a C 
     corporation, 15 percent of the taxpayer's aggregate net 
     income for such taxable year from all trades or businesses 
     from which such contributions were made for such year, 
     computed without regard to this section, and
       ``(II) in the case of a C corporation, 15 percent of 
     taxable income (as defined in subsection (b)(2)(D)).

       ``(iii) Rules related to limitation.--

       ``(I) Carryover.--If such aggregate amount exceeds the 
     limitation imposed under clause (ii), such excess shall be 
     treated (in a manner consistent with the rules of subsection 
     (d)) as a charitable contribution described in clause (i) in 
     each of the 5 succeeding taxable years in order of time.
       ``(II) Coordination with overall corporate limitation.--In 
     the case of any charitable contribution which is allowable 
     after the application of clause (ii)(II), subsection 
     (b)(2)(A) shall not apply to such contribution, but the 
     limitation imposed by such subsection shall be reduced (but 
     not below zero) by the aggregate amount of such 
     contributions. For purposes of subsection (b)(2)(B), such 
     contributions shall be treated as allowable under subsection 
     (b)(2)(A).

       ``(iv) Determination of basis for certain taxpayers.--If a 
     taxpayer--

       ``(I) does not account for inventories under section 471, 
     and
       ``(II) is not required to capitalize indirect costs under 
     section 263A,

     the taxpayer may elect, solely for purposes of subparagraph 
     (B), to treat the basis of any apparently wholesome food as 
     being equal to 25 percent of the fair market value of such 
     food.
       ``(v) Determination of fair market value.--In the case of 
     any such contribution of apparently wholesome food which 
     cannot or will not be sold solely by reason of internal 
     standards of the taxpayer, lack of market, or similar 
     circumstances, or by reason of being produced by the taxpayer 
     exclusively for the purposes of transferring the food to an 
     organization described in subparagraph (A), the fair market 
     value of such contribution shall be determined--

       ``(I) without regard to such internal standards, such lack 
     of market, such circumstances, or such exclusive purpose, and
       ``(II) by taking into account the price at which the same 
     or substantially the same food items (as to both type and 
     quality) are sold by the taxpayer at the time of the 
     contribution (or, if not so sold at such time, in the recent 
     past).''

       (c) Effective Dates.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to contributions made after December 31, 2014.
       (2) Modifications.--The amendments made by subsection (b) 
     shall apply to taxable years beginning after December 31, 
     2015.

[[Page 20357]]



     SEC. 114. EXTENSION OF MODIFICATION OF TAX TREATMENT OF 
                   CERTAIN PAYMENTS TO CONTROLLING EXEMPT 
                   ORGANIZATIONS.

       (a) In General.--Section 512(b)(13)(E) 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, 2014.

     SEC. 115. EXTENSION OF BASIS ADJUSTMENT TO STOCK OF S 
                   CORPORATIONS MAKING CHARITABLE CONTRIBUTIONS OF 
                   PROPERTY.

       (a) In General.--Section 1367(a)(2) 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, 2014.

    PART 3--INCENTIVES FOR GROWTH, JOBS, INVESTMENT, AND INNOVATION

     SEC. 121. EXTENSION AND MODIFICATION OF RESEARCH CREDIT.

       (a) Made Permanent.--
       (1) In general.--Section 41 is amended by striking 
     subsection (h).
       (2) Conforming amendment.--Section 45C(b)(1) is amended by 
     striking subparagraph (D).
       (b) Credit Allowed Against Alternative Minimum Tax in Case 
     of Eligible Small Business.--Section 38(c)(4)(B) is amended 
     by redesignating clauses (ii) through (ix) as clauses (iii) 
     through (x), respectively, and by inserting after clause (i) 
     the following new clause:
       ``(ii) the credit determined under section 41 for the 
     taxable year 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)),''.
       (c) Treatment of Research Credit for Certain Startup 
     Companies.--
       (1) In general.--Section 41, as amended by subsection (a), 
     is amended by adding at the end the following new subsection:
       ``(h) 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(h) 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(h)(4)(A)(ii) an amount equal to the 
     payroll tax credit portion determined under section 41(h)(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).''.
       (d) Effective Dates.--
       (1) Extension.--The amendments made by subsection (a) shall 
     apply to shall apply to amounts paid or incurred after 
     December 31, 2014.
       (2) Credit allowed against alternative minimum tax in case 
     of eligible small business.--The amendments made by 
     subsection (b) shall apply to credits determined for taxable 
     years beginning after December 31, 2015.
       (3) Treatment of research credit for certain startup 
     companies.--The amendments made by subsection (c) shall apply 
     to taxable years beginning after December 31, 2015.

     SEC. 122. EXTENSION AND MODIFICATION OF EMPLOYER WAGE CREDIT 
                   FOR EMPLOYEES WHO ARE ACTIVE DUTY MEMBERS OF 
                   THE UNIFORMED SERVICES.

       (a) In General.--Section 45P is amended by striking 
     subsection (f).
       (b) Applicability to All Employers.--
       (1) In general.--Section 45P(a) is amended by striking ``, 
     in the case of an eligible small business employer''.
       (2) Conforming amendment.--Section 45P(b)(3) 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) Effective Date.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to payments made after December 31, 2014.
       (2) Modification.--The amendments made by subsection (b) 
     shall apply to taxable years beginning after December 31, 
     2015.

[[Page 20358]]



     SEC. 123. EXTENSION OF 15-YEAR STRAIGHT-LINE COST RECOVERY 
                   FOR QUALIFIED LEASEHOLD IMPROVEMENTS, QUALIFIED 
                   RESTAURANT BUILDINGS AND IMPROVEMENTS, AND 
                   QUALIFIED RETAIL IMPROVEMENTS.

       (a) Qualified Leasehold Improvement Property and Qualified 
     Restaurant Property.--Clauses (iv) and (v) of section 
     168(e)(3)(E) are each amended by striking ``placed in service 
     before January 1, 2015''.
       (b) Qualified Retail Improvement Property.--Section 
     168(e)(3)(E)(ix) is amended by striking ``placed in service 
     after December 31, 2008, and before January 1, 2015''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to property placed in service after December 31, 
     2014.

     SEC. 124. EXTENSION AND MODIFICATION OF INCREASED EXPENSING 
                   LIMITATIONS AND TREATMENT OF CERTAIN REAL 
                   PROPERTY AS SECTION 179 PROPERTY.

       (a) Made Permanent.--
       (1) Dollar limitation.--Section 179(b)(1) is amended by 
     striking ``shall not exceed--'' and all that follows and 
     inserting ``shall not exceed $500,000.''.
       (2) Reduction in limitation.--Section 179(b)(2) is amended 
     by striking ``exceeds--'' and all that follows and inserting 
     ``exceeds $2,000,000.''.
       (b) Computer Software.--Section 179(d)(1)(A)(ii) is amended 
     by striking ``, to which section 167 applies, and which is 
     placed in service in a taxable year beginning after 2002 and 
     before 2015'' and inserting ``and to which section 167 
     applies''.
       (c) Special Rules for Treatment of Qualified Real 
     Property.--
       (1) Extension for 2015.--Section 179(f) is amended--
       (A) by striking ``2015'' in paragraph (1) and inserting 
     ``2016'',
       (B) by striking ``2014'' each place it appears in paragraph 
     (4) and inserting ``2015'', and
       (C) by striking ``and 2013'' in the heading of paragraph 
     (4)(C) and inserting ``2013, and 2014''.
       (2) Made permanent.--Section 179(f), as amended by 
     paragraph (1), is amended--
       (A) by striking ``beginning after 2009 and before 2016'' in 
     paragraph (1), and
       (B) by striking paragraphs (3) and (4).
       (d) Election.--Section 179(c)(2) is amended--
       (1) by striking ``may not be revoked'' and all that follows 
     through ``and before 2015'', and
       (2) by striking ``irrevocable'' in the heading thereof.
       (e) Air Conditioning and Heating Units.--Section 179(d)(1) 
     is amended by striking ``and shall not include air 
     conditioning or heating units''.
       (f) Inflation Adjustment.--Section 179(b) 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 2015, the dollar amounts in paragraphs (1) 
     and (2) shall each be increased by an amount equal to--
       ``(i) such dollar amount, multiplied by
       ``(ii) the cost-of-living adjustment determined under 
     section 1(f)(3) for the calendar year in which the taxable 
     year begins, determined by substituting `calendar year 2014' 
     for `calendar year 1992' in subparagraph (B) thereof.
       ``(B) Rounding.--The amount of any increase under 
     subparagraph (A) shall be rounded to the nearest multiple of 
     $10,000.''.
       (g) Effective Dates.--
       (1) Extension.--Except as provided in paragraph (2), the 
     amendments made by this section shall apply to taxable years 
     beginning after December 31, 2014.
       (2) Modifications.--The amendments made by subsections 
     (c)(2) and (e) shall apply to taxable years beginning after 
     December 31, 2015.

     SEC. 125. EXTENSION OF TREATMENT OF CERTAIN DIVIDENDS OF 
                   REGULATED INVESTMENT COMPANIES.

       (a) In General.--Section 871(k) is amended by striking 
     clause (v) of paragraph (1)(C) and clause (v) of paragraph 
     (2)(C).
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 126. EXTENSION OF EXCLUSION OF 100 PERCENT OF GAIN ON 
                   CERTAIN SMALL BUSINESS STOCK.

       (a) In General.--Section 1202(a)(4) is amended--
       (1) by striking ``and before January 1, 2015'', and
       (2) by striking ``, 2011, 2012, 2013, and 2014'' in the 
     heading thereof and inserting ``and thereafter''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to stock acquired after December 31, 2014.

     SEC. 127. EXTENSION OF REDUCTION IN S-CORPORATION RECOGNITION 
                   PERIOD FOR BUILT-IN GAINS TAX.

       (a) In General.--Section 1374(d)(7) is amended to read as 
     follows:
       ``(7) Recognition period.--
       ``(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) Installment sales.--If an S corporation sells an 
     asset and reports the income from the sale using the 
     installment method under section 453, the treatment of all 
     payments received shall be governed by the provisions of this 
     paragraph applicable to the taxable year in which such sale 
     was made.''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 128. EXTENSION OF SUBPART F EXCEPTION FOR ACTIVE 
                   FINANCING INCOME.

       (a) Insurance Businesses.--Section 953(e) is amended by 
     striking paragraph (10) and by redesignating paragraph (11) 
     as paragraph (10).
       (b) Banking, Financing, or Similar Businesses.--Section 
     954(h) is amended by striking paragraph (9).
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years of foreign corporations 
     beginning after December 31, 2014, and to taxable years of 
     United States shareholders with or within which any such 
     taxable year of such foreign corporation ends.

             PART 4--INCENTIVES FOR REAL ESTATE INVESTMENT

     SEC. 131. EXTENSION OF MINIMUM LOW-INCOME HOUSING TAX CREDIT 
                   RATE FOR NON-FEDERALLY SUBSIDIZED BUILDINGS.

       (a) In General.--Section 42(b)(2) is amended by striking 
     ``with respect to housing credit dollar amount allocations 
     made before January 1, 2015''.
       (b) Clerical Amendment.--The heading for section 42(b)(2) 
     is amended by striking ``Temporary minimum'' and inserting 
     ``Minimum''.
       (c) Effective Dates.--The amendments made by this section 
     shall take effect on January 1, 2015.

     SEC. 132. EXTENSION OF MILITARY HOUSING ALLOWANCE EXCLUSION 
                   FOR DETERMINING WHETHER A TENANT IN CERTAIN 
                   COUNTIES IS LOW-INCOME.

       (a) In General.--Section 3005(b) of the Housing Assistance 
     Tax Act of 2008 is amended by striking ``and before January 
     1, 2015'' 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. 133. EXTENSION OF RIC QUALIFIED INVESTMENT ENTITY 
                   TREATMENT UNDER FIRPTA.

       (a) In General.--Section 897(h)(4)(A) is amended--
       (1) by striking clause (ii), and
       (2) by striking all that precedes ``regulated investment 
     company which'' and inserting the following:
       ``(A) Qualified investment entity.--The term `qualified 
     investment entity' means--
       ``(i) any real estate investment trust, and
       ``(ii) any''.
       (b) Effective Date.--
       (1) In general.--The amendments made by this section shall 
     take effect on January 1, 2015. Notwithstanding the preceding 
     sentence, such amendments 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, 2014, 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.

                  Subtitle B--Extensions Through 2019

     SEC. 141. EXTENSION OF NEW MARKETS TAX CREDIT.

       (a) In General.--Section 45D(f)(1)(G) is amended by 
     striking ``for 2010, 2011, 2012, 2013, and 2014'' and 
     inserting ``for each of calendar years 2010 through 2019''.
       (b) Carryover of Unused Limitation.--Section 45D(f)(3) is 
     amended by striking ``2019'' and inserting ``2024''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to calendar years beginning after December 31, 
     2014.

     SEC. 142. EXTENSION AND MODIFICATION OF WORK OPPORTUNITY TAX 
                   CREDIT.

       (a) In General.--Section 51(c)(4) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2019''.
       (b) Credit for Hiring Long-term Unemployment Recipients.--
       (1) In general.--Section 51(d)(1) 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.--Section 
     51(d) 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--

[[Page 20359]]

       ``(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 Dates.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to individuals who begin work for the employer after 
     December 31, 2014.
       (2) Modification.--The amendments made by subsection (b) 
     shall apply to individuals who begin work for the employer 
     after December 31, 2015.

     SEC. 143. EXTENSION AND MODIFICATION OF BONUS DEPRECIATION.

       (a) Extended for 2015.--
       (1) In general.--Section 168(k)(2) is amended--
       (A) by striking ``January 1, 2016'' in subparagraph (A)(iv) 
     and inserting ``January 1, 2017'', and
       (B) by striking ``January 1, 2015'' each place it appears 
     and inserting ``January 1, 2016''.
       (2) Special rule for federal long-term contracts.--Section 
     460(c)(6)(B)(ii) is amended by striking ``January 1, 2015 
     (January 1, 2016'' and inserting ``January 1, 2016 (January 
     1, 2017''.
       (3) Extension of election to accelerate amt credit in lieu 
     of bonus depreciation.--
       (A) In general.--Section 168(k)(4)(D)(iii)(II) is amended 
     by striking ``January 1, 2015'' and inserting ``January 1, 
     2016''.
       (B) Round 5 extension property.--Section 168(k)(4) is 
     amended by adding at the end the following new subparagraph:
       ``(L) Special rules for round 5 extension property.--
       ``(i) In general.--In the case of round 5 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 5 extension property.

       ``(ii) Election.--

       ``(I) A taxpayer who has an election in effect under this 
     paragraph for round 4 extension property shall be treated as 
     having an election in effect for round 5 extension property 
     unless the taxpayer elects to not have this paragraph apply 
     to round 5 extension property.
       ``(II) A taxpayer who does not have an election in effect 
     under this paragraph for round 4 extension property may elect 
     to have this paragraph apply to round 5 extension property.

       ``(iii) Round 5 extension property.--For purposes of this 
     subparagraph, the term `round 5 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 143(a)(1) of the Protecting Americans from Tax 
     Hikes Act of 2015 (and the application of such extension to 
     this paragraph pursuant to the amendment made by section 
     143(a)(3) of such Act).''.
       (4) Conforming amendments.--
       (A) The heading for section 168(k) is amended by striking 
     ``January 1, 2015'' and inserting ``January 1, 2016''.
       (B) The heading for section 168(k)(2)(B)(ii) is amended by 
     striking ``pre-january 1, 2015'' and inserting ``pre-january 
     1, 2016''.
       (5) Effective date.--
       (A) In general.--Except as provided in subparagraph (B), 
     the amendments made by this subsection shall apply to 
     property placed in service after December 31, 2014, in 
     taxable years ending after such date.
       (B) Election to accelerate amt credit.--The amendments made 
     by paragraph (3) shall apply to taxable years ending after 
     December 31, 2014.
       (b) Extended and Modified for 2016 Through 2019.--
       (1) In general.--Section 168(k)(2), as amended by 
     subsection (a), is amended to read as follows:
       ``(2) Qualified property.--For purposes of this 
     subsection--
       ``(A) In general.--The term `qualified property' means 
     property--
       ``(i)(I) to which this section applies which has a recovery 
     period of 20 years or less,
       ``(II) which is computer software (as defined in section 
     167(f)(1)(B)) for which a deduction is allowable under 
     section 167(a) without regard to this subsection,
       ``(III) which is water utility property, or
       ``(IV) which is qualified improvement property,
       ``(ii) the original use of which commences with the 
     taxpayer, and
       ``(iii) which is placed in service by the taxpayer before 
     January 1, 2020.
       ``(B) Certain property having longer production periods 
     treated as qualified property.--
       ``(i) In general.--The term `qualified property' includes 
     any property if such property--

       ``(I) meets the requirements of clauses (i) and (ii) of 
     subparagraph (A),
       ``(II) is placed in service by the taxpayer before January 
     1, 2021,
       ``(III) is acquired by the taxpayer (or acquired pursuant 
     to a written contract entered into) before January 1, 2020,
       ``(IV) has a recovery period of at least 10 years or is 
     transportation property,
       ``(V) is subject to section 263A, and
       ``(VI) meets the requirements of clause (iii) of section 
     263A(f)(1)(B) (determined as if such clause also applies to 
     property which has a long useful life (within the meaning of 
     section 263A(f))).

       ``(ii) Only pre-january 1, 2020 basis eligible for 
     additional allowance.--In the case of property which is 
     qualified property solely by reason of clause (i), paragraph 
     (1) shall apply only to the extent of the adjusted basis 
     thereof attributable to manufacture, construction, or 
     production before January 1, 2020.
       ``(iii) Transportation property.--For purposes of this 
     subparagraph, the term `transportation property' means 
     tangible personal property used in the trade or business of 
     transporting persons or property.
       ``(iv) Application of subparagraph.--This subparagraph 
     shall not apply to any property which is described in 
     subparagraph (C).
       ``(C) Certain aircraft.--The term `qualified property' 
     includes property--
       ``(i) which meets the requirements of subparagraph (A)(ii) 
     and subclauses (II) and (III) of subparagraph (B)(i),
       ``(ii) which is an aircraft which is not a transportation 
     property (as defined in subparagraph (B)(iii)) other than for 
     agricultural or firefighting purposes,
       ``(iii) which is purchased and on which such purchaser, at 
     the time of the contract for purchase, has made a 
     nonrefundable deposit of the lesser of--

       ``(I) 10 percent of the cost, or
       ``(II) $100,000, and

       ``(iv) which has--

       ``(I) an estimated production period exceeding 4 months, 
     and
       ``(II) a cost exceeding $200,000.

       ``(D) Exception for alternative depreciation property.--The 
     term `qualified property' shall not include any property to 
     which the alternative depreciation system under subsection 
     (g) applies, determined--
       ``(i) without regard to paragraph (7) of subsection (g) 
     (relating to election to have system apply), and
       ``(ii) after application of section 280F(b) (relating to 
     listed property with limited business use).
       ``(E) Special rules.--
       ``(i) Self-constructed property.--In the case of a taxpayer 
     manufacturing, constructing, or producing property for the 
     taxpayer's own use, the requirements of subclause (III) of 
     subparagraph (B)(i) shall be treated as met if the taxpayer 
     begins manufacturing, constructing, or producing the property 
     before January 1, 2020.
       ``(ii) Sale-leasebacks.--For purposes of clause (iii) and 
     subparagraph (A)(ii), if property is--

       ``(I) originally placed in service by a person, and
       ``(II) sold and leased back by such person within 3 months 
     after the date such property was originally placed in 
     service,

     such property shall be treated as originally placed in 
     service not earlier than the date on which such property is 
     used under the leaseback referred to in subclause (II).
       ``(iii) Syndication.--For purposes of subparagraph (A)(ii), 
     if--

       ``(I) property is originally placed in service by the 
     lessor of such property,
       ``(II) such property is sold by such lessor or any 
     subsequent purchaser within 3 months after the date such 
     property was originally placed in service (or, in the case of 
     multiple units of property subject to the same lease, within 
     3 months after the date the final unit is placed in service, 
     so long as the period between the time the first unit is 
     placed in service and the time the last unit is placed in 
     service does not exceed 12 months), and
       ``(III) the user of such property after the last sale 
     during such 3-month period remains the same as when such 
     property was originally placed in service,

     such property shall be treated as originally placed in 
     service not earlier than the date of such last sale.
       ``(F) Coordination with section 280f.--For purposes of 
     section 280F--
       ``(i) Automobiles.--In the case of a passenger automobile 
     (as defined in section 280F(d)(5)) which is qualified 
     property, the Secretary shall increase the limitation under 
     section 280F(a)(1)(A)(i) by $8,000.
       ``(ii) Listed property.--The deduction allowable under 
     paragraph (1) shall be taken into account in computing any 
     recapture amount under section 280F(b)(2).
       ``(iii) Phase down.--In the case of a passenger automobile 
     placed in service by the taxpayer after December 31, 2017, 
     clause (i) shall be applied by substituting for `$8,000'--

       ``(I) in the case of an automobile placed in service during 
     2018, $6,400, and
       ``(II) in the case of an automobile placed in service 
     during 2019, $4,800.

       ``(G) Deduction allowed in computing minimum tax.--For 
     purposes of determining alternative minimum taxable income 
     under section 55, the deduction under section 167 for 
     qualified property shall be determined without regard to any 
     adjustment under section 56.''.

[[Page 20360]]

       (2) Qualified improvement property.--Section 168(k)(3) is 
     amended to read as follows:
       ``(3) Qualified improvement property.--For purposes of this 
     subsection--
       ``(A) In general.--The term `qualified improvement 
     property' means any improvement to an interior portion of a 
     building which is nonresidential real property if such 
     improvement is placed in service after the date such building 
     was first placed in service.
       ``(B) Certain improvements not included.--Such term shall 
     not include any improvement for which the expenditure is 
     attributable to--
       ``(i) the enlargement of the building,
       ``(ii) any elevator or escalator, or
       ``(iii) the internal structural framework of the 
     building.''.
       (3) Expansion of election to accelerate amt credits in lieu 
     of bonus depreciation.--Section 168(k)(4), as amended by 
     subsection (a), is amended to read as follows:
       ``(4) Election to accelerate amt credits in lieu of bonus 
     depreciation.--
       ``(A) In general.--If a corporation elects to have this 
     paragraph apply for any taxable year--
       ``(i) paragraphs (1) and (2)(F) shall not apply to any 
     qualified property placed in service during such taxable 
     year,
       ``(ii) the applicable depreciation method used under this 
     section with respect to such property shall be the straight 
     line method, and
       ``(iii) the limitation imposed by section 53(c) for such 
     taxable year shall be increased by the bonus depreciation 
     amount which is determined for such taxable year under 
     subparagraph (B).
       ``(B) Bonus depreciation amount.--For purposes of this 
     paragraph--
       ``(i) In general.--The bonus depreciation amount for any 
     taxable year is an amount equal to 20 percent of the excess 
     (if any) of--

       ``(I) the aggregate amount of depreciation which would be 
     allowed under this section for qualified property placed in 
     service by the taxpayer during such taxable year if paragraph 
     (1) applied to all such property (and, in the case of any 
     such property which is a passenger automobile (as defined in 
     section 280F(d)(5)), if paragraph (2)(F) applied to such 
     automobile), over
       ``(II) the aggregate amount of depreciation which would be 
     allowed under this section for qualified property placed in 
     service by the taxpayer during such taxable year if 
     paragraphs (1) and (2)(F) did not apply to any such property.

     The aggregate amounts determined under subclauses (I) and 
     (II) shall be determined without regard to any election made 
     under subparagraph (A) or subsection (b)(2)(D), (b)(3)(D), or 
     (g)(7).
       ``(ii) Limitation.--The bonus depreciation amount for any 
     taxable year shall not exceed the lesser of--

       ``(I) 50 percent of the minimum tax credit under section 
     53(b) for the first taxable year ending after December 31, 
     2015, or
       ``(II) the minimum tax credit under section 53(b) for such 
     taxable year determined by taking into account only the 
     adjusted net minimum tax for taxable years ending before 
     January 1, 2016 (determined by treating credits as allowed on 
     a first-in, first-out basis).

       ``(iii) Aggregation rule.--All corporations which are 
     treated as a single employer under section 52(a) shall be 
     treated--

       ``(I) as 1 taxpayer for purposes of this paragraph, and
       ``(II) as having elected the application of this paragraph 
     if any such corporation so elects.

       ``(C) Credit refundable.--For purposes of section 6401(b), 
     the aggregate increase in the credits allowable under part IV 
     of subchapter A for any taxable year resulting from the 
     application of this paragraph shall be treated as allowed 
     under subpart C of such part (and not any other subpart).
       ``(D) Other rules.--
       ``(i) Election.--Any election under this paragraph may be 
     revoked only with the consent of the Secretary.
       ``(ii) Partnerships with electing partners.--In the case of 
     a corporation which is a partner in a partnership and which 
     makes an election under subparagraph (A) for the taxable 
     year, for purposes of determining such corporation's 
     distributive share of partnership items under section 702 for 
     such taxable year--

       ``(I) paragraphs (1) and (2)(F) shall not apply to any 
     qualified property placed in service during such taxable 
     year, and
       ``(II) the applicable depreciation method used under this 
     section with respect to such property shall be the straight 
     line method.

       ``(iii) Certain partnerships.--In the case of a partnership 
     in which more than 50 percent of the capital and profits 
     interests are owned (directly or indirectly) at all times 
     during the taxable year by 1 corporation (or by corporations 
     treated as 1 taxpayer under subparagraph (B)(iii)), each 
     partner shall compute its bonus depreciation amount under 
     clause (i) of subparagraph (B) by taking into account its 
     distributive share of the amounts determined by the 
     partnership under subclauses (I) and (II) of such clause for 
     the taxable year of the partnership ending with or within the 
     taxable year of the partner.''.
       (4) Special rules for certain plants bearing fruits and 
     nuts.--Section 168(k) is amended--
       (A) by striking paragraph (5), and
       (B) by inserting after paragraph (4) the following new 
     paragraph:
       ``(5) Special rules for certain plants bearing fruits and 
     nuts.--
       ``(A) In general.--In the case of any specified plant which 
     is planted before January 1, 2020, or is grafted before such 
     date to a plant that has already been planted, by the 
     taxpayer in the ordinary course of the taxpayer's farming 
     business (as defined in section 263A(e)(4)) during a taxable 
     year for which the taxpayer has elected the application of 
     this paragraph--
       ``(i) a depreciation deduction equal to 50 percent of the 
     adjusted basis of such specified plant shall be allowed under 
     section 167(a) for the taxable year in which such specified 
     plant is so planted or grafted, and
       ``(ii) the adjusted basis of such specified plant shall be 
     reduced by the amount of such deduction.
       ``(B) Specified plant.--For purposes of this paragraph, the 
     term `specified plant' means--
       ``(i) any tree or vine which bears fruits or nuts, and
       ``(ii) any other plant which will have more than one yield 
     of fruits or nuts and which generally has a pre-productive 
     period of more than 2 years from the time of planting or 
     grafting to the time at which such plant begins bearing 
     fruits or nuts.
     Such term shall not include any property which is planted or 
     grafted outside of the United States.
       ``(C) Election revocable only with consent.--An election 
     under this paragraph may be revoked only with the consent of 
     the Secretary.
       ``(D) Additional depreciation may be claimed only once.--If 
     this paragraph applies to any specified plant, such specified 
     plant shall not be treated as qualified property in the 
     taxable year in which placed in service.
       ``(E) Deduction allowed in computing minimum tax.--Rules 
     similar to the rules of paragraph (2)(G) shall apply for 
     purposes of this paragraph.
       ``(F) Phase down.--In the case of a specified plant which 
     is planted after December 31, 2017 (or is grafted to a plant 
     that has already been planted before such date), subparagraph 
     (A)(i) shall be applied by substituting for `50 percent'--
       ``(i) in the case of a plant which is planted (or so 
     grafted) in 2018, `40 percent', and
       ``(ii) in the case of a plant which is planted (or so 
     grafted) during 2019, `30 percent'.''.
       (5) Phase down of bonus depreciation.--Section 168(k) is 
     amended by adding at the end the following new paragraph:
       ``(6) Phase down.--In the case of qualified property placed 
     in service by the taxpayer after December 31, 2017, paragraph 
     (1)(A) shall be applied by substituting for `50 percent'--
       ``(A) in the case of property placed in service in 2018 (or 
     in the case of property placed in service in 2019 and 
     described in paragraph (2)(B) or (C) (determined by 
     substituting `2019' for `2020' in paragraphs (2)(B)(i)(III) 
     and (ii) and paragraph (2)(E)(i)), `40 percent',
       ``(B) in the case of property placed in service in 2019 (or 
     in the case of property placed in service in 2020 and 
     described in paragraph (2)(B) or (C), `30 percent'.''.
       (6) Conforming amendments.--
       (A) Section 168(e)(6) is amended--
       (i) by redesignating subparagraphs (A) and (B) as 
     subparagraphs (D) and (E), respectively,
       (ii) by striking all that precedes subparagraph (D) (as so 
     redesignated) and inserting the following:
       ``(6) Qualified leasehold improvement property.--For 
     purposes of this subsection--
       ``(A) In general.--The term `qualified leasehold 
     improvement property' means any improvement to an interior 
     portion of a building which is nonresidential real property 
     if--
       ``(i) such improvement is made under or pursuant to a lease 
     (as defined in subsection (h)(7))--

       ``(I) by the lessee (or any sublessee) of such portion, or
       ``(II) by the lessor of such portion,

       ``(ii) such portion is to be occupied exclusively by the 
     lessee (or any sublessee) of such portion, and
       ``(iii) such improvement is placed in service more than 3 
     years after the date the building was first placed in 
     service.
       ``(B) Certain improvements not included.--Such term shall 
     not include any improvement for which the expenditure is 
     attributable to--
       ``(i) the enlargement of the building,
       ``(ii) any elevator or escalator,
       ``(iii) any structural component benefitting a common area, 
     or
       ``(iv) the internal structural framework of the building.
       ``(C) Definitions and special rules.--For purposes of this 
     paragraph--
       ``(i) Commitment to lease treated as lease.--A commitment 
     to enter into a lease shall be treated as a lease, and the 
     parties to such commitment shall be treated as lessor and 
     lessee, respectively.

[[Page 20361]]

       ``(ii) Related persons.--A lease between related persons 
     shall not be considered a lease. For purposes of the 
     preceding sentence, the term `related persons' means--

       ``(I) members of an affiliated group (as defined in section 
     1504), and
       ``(II) persons having a relationship described in 
     subsection (b) of section 267; except that, for purposes of 
     this clause, the phrase `80 percent or more' shall be 
     substituted for the phrase `more than 50 percent' each place 
     it appears in such subsection.'', and

       (iii) by striking ``subparagraph (A)'' in subparagraph (E) 
     (as so redesignated) and inserting ``subparagraph (D)''.
       (B) Section 168(e)(7)(B) is amended by striking ``qualified 
     leasehold improvement property'' and inserting ``qualified 
     improvement property''.
       (C) Section 168(e)(8) is amended by striking subparagraph 
     (D).
       (D) Section 168(k), as amended by the preceding provisions 
     of this section, is amended by adding at the end the 
     following new paragraph:
       ``(7) Election out.--If a taxpayer makes an election under 
     this paragraph with respect to any class of property for any 
     taxable year, paragraphs (1) and (2)(F) shall not apply to 
     any qualified property in such class placed in service during 
     such taxable year. An election under this paragraph may be 
     revoked only with the consent of the Secretary.''.
       (E) Section 168(l)(3) is amended--
       (i) by striking ``section 168(k)'' in subparagraph (A) and 
     inserting ``subsection (k)'', and
       (ii) by striking ``section 168(k)(2)(D)(i)'' in 
     subparagraph (B) and inserting ``subsection (k)(2)(D)''.
       (F) Section 168(l)(4) is amended by striking ``subparagraph 
     (E) of section 168(k)(2)'' and all that follows and inserting 
     ``subsection (k)(2)(E) shall apply.''.
       (G) Section 168(l)(5) is amended by striking ``section 
     168(k)(2)(G)'' and inserting ``subsection (k)(2)(G)''.
       (H) Section 263A(c) is amended by adding at the end the 
     following new paragraph:
       ``(7) Coordination with section 168(k)(5).--This section 
     shall not apply to any amount allowed as a deduction by 
     reason of section 168(k)(5) (relating to special rules for 
     certain plants bearing fruits and nuts).''.
       (I) Section 460(c)(6)(B)(ii), as amended by subsection (a), 
     is amended to read as follows:
       ``(ii) is placed in service before January 1, 2020 (January 
     1, 2021 in the case of property described in section 
     168(k)(2)(B)).''.
       (J) Section 168(k), as amended by subsection (a), is 
     amended by striking ``and Before January 1, 2016'' in the 
     heading thereof and inserting ``and Before January 1, 2020''.
       (7) Effective dates.--
       (A) In general.--Except as otherwise provided in this 
     paragraph, the amendments made by this subsection shall apply 
     to property placed in service after December 31, 2015, in 
     taxable years ending after such date.
       (B) Expansion of election to accelerate amt credits in lieu 
     of bonus depreciation.--The amendments made by paragraph (3) 
     shall apply to taxable years ending after December 31, 2015, 
     except that in the case of any taxable year beginning before 
     January 1, 2016, and ending after December 31, 2015, the 
     limitation under section 168(k)(4)(B)(ii) of the Internal 
     Revenue Code of 1986 (as amended by this section) shall be 
     the sum of--
       (i) the product of--

       (I) the maximum increase amount (within the meaning of 
     section 168(k)(4)(C)(iii) of such Code, as in effect before 
     the amendments made by this subsection), multiplied by
       (II) a fraction the numerator of which is the number of 
     days in the taxable year before January 1, 2016, and the 
     denominator of which is the number of days in the taxable 
     year, plus

       (ii) the product of--

       (I) such limitation (determined without regard to this 
     subparagraph), multiplied by
       (II) a fraction the numerator of which is the number of 
     days in the taxable year after December 31, 2015, and the 
     denominator of which is the number of days in the taxable 
     year.

       (C) Special rules for certain plants bearing fruits and 
     nuts.--The amendments made by paragraph (4) (other than 
     subparagraph (A) thereof) shall apply to specified plants (as 
     defined in section 168(k)(5)(B) of the Internal Revenue Code 
     of 1986, as amended by this subsection) planted or grafted 
     after December 31, 2015.

     SEC. 144. 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)(C) is amended by 
     striking ``January 1, 2015'' and inserting ``January 1, 
     2020''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years of foreign corporations 
     beginning after December 31, 2014, and to taxable years of 
     United States shareholders with or within which such taxable 
     years of foreign corporations end.

                  Subtitle C--Extensions Through 2016

            PART 1--TAX RELIEF FOR FAMILIES AND INDIVIDUALS

     SEC. 151. EXTENSION AND MODIFICATION OF EXCLUSION FROM GROSS 
                   INCOME OF DISCHARGE OF QUALIFIED PRINCIPAL 
                   RESIDENCE INDEBTEDNESS.

       (a) Extension.--Section 108(a)(1)(E) is amended by striking 
     ``January 1, 2015'' and inserting ``January 1, 2017''.
       (b) Modification.--Section 108(a)(1)(E), as amended by 
     subsection (a), is amended by striking ``discharged before'' 
     and all that follows and inserting ``discharged--
       ``(i) before January 1, 2017, or
       ``(ii) subject to an arrangement that is entered into and 
     evidenced in writing before January 1, 2017.''.
       (c) Effective Dates.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to discharges of indebtedness after December 31, 2014.
       (2) Modification.--The amendment made by subsection (b) 
     shall apply to discharges of indebtedness after December 31, 
     2015.

     SEC. 152. 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, 2014'' and inserting 
     ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to amounts paid or accrued after December 31, 
     2014.

     SEC. 153. EXTENSION OF ABOVE-THE-LINE DEDUCTION FOR QUALIFIED 
                   TUITION AND RELATED EXPENSES.

       (a) In General.--Section 222(e) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

    PART 2--INCENTIVES FOR GROWTH, JOBS, INVESTMENT, AND INNOVATION

     SEC. 161. EXTENSION OF INDIAN EMPLOYMENT TAX CREDIT.

       (a) In General.--Section 45A(f) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 162. EXTENSION AND MODIFICATION OF RAILROAD TRACK 
                   MAINTENANCE CREDIT.

       (a) Extension.--Section 45G(f) is amended by striking 
     ``January 1, 2015'' and inserting ``January 1, 2017''.
       (b) Modification.--Section 45G(d) is amended by striking 
     ``January 1, 2005,'' and inserting ``January 1, 2015,''.
       (c) Effective Dates.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to expenditures paid or incurred in taxable years 
     beginning after December 31, 2014.
       (2) Modification.--The amendment made by subsection (b) 
     shall apply to expenditures paid or incurred in taxable years 
     beginning after December 31, 2015.

     SEC. 163. EXTENSION OF MINE RESCUE TEAM TRAINING CREDIT.

       (a) In General.--Section 45N(e) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 164. EXTENSION OF QUALIFIED ZONE ACADEMY BONDS.

       (a) Extension.--Section 54E(c)(1) is amended by striking 
     ``and 2014'' and inserting ``2014, 2015, and 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to obligations issued after December 31, 2014.

     SEC. 165. EXTENSION OF CLASSIFICATION OF CERTAIN RACE HORSES 
                   AS 3-YEAR PROPERTY.

       (a) In General.--Section 168(e)(3)(A)(i) is amended--
       (1) by striking ``January 1, 2015'' in subclause (I) and 
     inserting ``January 1, 2017'', and
       (2) by striking ``December 31, 2014'' in subclause (II) and 
     inserting ``December 31, 2016''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to property placed in service after December 31, 
     2014.

     SEC. 166. EXTENSION OF 7-YEAR RECOVERY PERIOD FOR MOTORSPORTS 
                   ENTERTAINMENT COMPLEXES.

       (a) In General.--Section 168(i)(15)(D) is amended by 
     striking ``December 31, 2014'' and inserting ``December 31, 
     2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2014.

     SEC. 167. EXTENSION AND MODIFICATION OF ACCELERATED 
                   DEPRECIATION FOR BUSINESS PROPERTY ON AN INDIAN 
                   RESERVATION.

       (a) In General.--Section 168(j)(8) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Election to Have Special Rules Not Apply.--Section 
     168(j) is amended by redesignating paragraph (8), as amended 
     by subsection (a), as paragraph (9), and by inserting after 
     paragraph (7) the following new paragraph:
       ``(8) Election out.--If a taxpayer makes an election under 
     this paragraph with respect to any class of property for any 
     taxable year, this subsection shall not apply to all property 
     in such class placed in service during

[[Page 20362]]

     such taxable year. Such election, once made, shall be 
     irrevocable.''.
       (c) Effective Dates.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to property placed in service after December 31, 2014.
       (2) Modification.--The amendments made by subsection (b) 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 168. EXTENSION OF ELECTION TO EXPENSE MINE SAFETY 
                   EQUIPMENT.

       (a) In General.--Section 179E(g) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2014.

     SEC. 169. EXTENSION OF SPECIAL EXPENSING RULES FOR CERTAIN 
                   FILM AND TELEVISION PRODUCTIONS; SPECIAL 
                   EXPENSING FOR LIVE THEATRICAL PRODUCTIONS.

       (a) In General.--Section 181(f) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (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--
       ``(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) Seasonal productions.--
       ``(i) In general.--In the case of a live staged production 
     not described in subparagraph (B) which is produced or 
     presented by a taxable entity for not more than 10 weeks of 
     the taxable year, subparagraph (A) shall be applied by 
     substituting `6,500' for `3,000'.
       ``(ii) Short taxable years.--For purposes of clause (i), in 
     the case of any taxable year of less than 12 months, the 
     number of weeks for which a production is produced or 
     presented shall be annualized by multiplying the number of 
     weeks the production is produced or presented during such 
     taxable year by 12 and dividing the result by the number of 
     months in such taxable year.
       ``(E) 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 Date.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to productions commencing after December 31, 2014.
       (2) Modifications.--
       (A) In general.--The amendments made by subsections (b) and 
     (c) shall apply to productions commencing after December 31, 
     2015.
       (B) Commencement.--For purposes of subparagraph (A), 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. 170. EXTENSION OF DEDUCTION ALLOWABLE WITH RESPECT TO 
                   INCOME ATTRIBUTABLE TO DOMESTIC PRODUCTION 
                   ACTIVITIES IN PUERTO RICO.

       (a) In General.--Section 199(d)(8)(C) is amended--
       (1) by striking ``first 9 taxable years'' and inserting 
     ``first 11 taxable years'', and
       (2) by striking ``January 1, 2015'' and inserting ``January 
     1, 2017''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 171. EXTENSION AND MODIFICATION OF EMPOWERMENT ZONE TAX 
                   INCENTIVES.

       (a) In General.--
       (1) Extension.--Section 1391(d)(1)(A)(i) is amended by 
     striking ``December 31, 2014'' and inserting ``December 31, 
     2016''.
       (2) 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.
       (b) Modification.--Section 1394(b)(3)(B)(i) is amended--
       (1) by striking ``References'' and inserting the following:

       ``(I) In general.--Except as provided in subclause (II), 
     references'', and

       (2) by adding at the end the following new subclause:

       ``(II) Special rule for employee residence test.--For 
     purposes of subsection (b)(6) and (c)(5) of section 1397C, an 
     employee shall be treated as a resident of an empowerment 
     zone if such employee is a resident of an empowerment zone, 
     an enterprise community, or a qualified low-income community 
     within an applicable nominating jurisdiction.''.

       (c) Definitions.--
       (1) Qualified low-income community.--Section 1394(b)(3) 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) Qualified low-income community.--For purposes of 
     subparagraph (B)--
       ``(i) In general.--The term `qualified low-income 
     community' means any population census tract if--

       ``(I) the poverty rate for such tract is at least 20 
     percent, or
       ``(II) the median family income for such tract does not 
     exceed 80 percent of statewide median family income (or, in 
     the case of a tract located within a metropolitan area, 
     metropolitan area median family income if greater).

     Subclause (II) shall be applied using possessionwide median 
     family income in the case of census tracts located within a 
     possession of the United States.
       ``(ii) Targeted populations.--The Secretary shall prescribe 
     regulations under which 1 or more targeted populations 
     (within the meaning of section 103(20) of the Riegle 
     Community Development and Regulatory Improvement Act of 1994) 
     may be treated as qualified low-income communities.
       ``(iii) Areas not within census tracts.--In the case of an 
     area which is not tracted for population census tracts, the 
     equivalent county divisions (as defined by the Bureau of the 
     Census for purposes of defining poverty areas) shall be used 
     for purposes of determining poverty rates and median family 
     income.
       ``(iv) Modification of income requirement for census tracts 
     within high migration rural counties.--

       ``(I) In general.--In the case of a population census tract 
     located within a high migration rural county, clause (i)(II) 
     shall be applied to areas not located within a metropolitan 
     area by substituting `85 percent' for `80 percent'.
       ``(II) High migration rural county.--For purposes of this 
     clause, the term `high migration rural county' means any 
     county which, during the 20-year period ending with the year 
     in which the most recent census was conducted, has a net out-
     migration of inhabitants from the county of at least 10 
     percent of the population of the county at the beginning of 
     such period.''.

       (2) Applicable nominating jurisdiction.--Section 
     1394(b)(3)(D), as redesignated by paragraph (1), is amended 
     by adding at the end the following new clause:
       ``(iii) Applicable nominating jurisdiction.--The term 
     `applicable nominating jurisdiction' means, with respect to 
     any empowerment zone or enterprise community,

[[Page 20363]]

     any local government that nominated such community for 
     designation under section 1391.''.
       (d) Conforming Amendments.--
       (1) Section 1394(b)(3)(B)(iii) is amended by striking ``or 
     an enterprise community'' and inserting ``, an enterprise 
     community, or a qualified low-income community within an 
     applicable nominating jurisdiction''.
       (2) Section 1394(b)(3)(D), as redesignated by subsection 
     (c)(1), is amended by striking ``Definitions'' and inserting 
     ``Other definitions''.
       (e) Effective Dates.--
       (1) Extensions.--The amendment made by subsection (a) shall 
     apply to taxable years beginning after December 31, 2014.
       (2) Modifications.--The amendments made by subsections (b), 
     (c), and (d) shall apply to bonds issued after December 31, 
     2015.

     SEC. 172. EXTENSION OF TEMPORARY INCREASE IN LIMIT ON COVER 
                   OVER OF RUM EXCISE TAXES TO PUERTO RICO AND THE 
                   VIRGIN ISLANDS.

       (a) In General.--Section 7652(f)(1) is amended by striking 
     ``January 1, 2015'' and inserting ``January 1, 2017''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to distilled spirits brought into the United 
     States after December 31, 2014.

     SEC. 173. EXTENSION OF AMERICAN SAMOA ECONOMIC DEVELOPMENT 
                   CREDIT.

       (a) In General.--Section 119(d) of division A of the Tax 
     Relief and Health Care Act of 2006 is amended--
       (1) by striking ``January 1, 2015'' each place it appears 
     and inserting ``January 1, 2017'',
       (2) by striking ``first 9 taxable years'' in paragraph (1) 
     and inserting ``first 11 taxable years'', and
       (3) by striking ``first 3 taxable years'' in paragraph (2) 
     and inserting ``first 5 taxable years''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 174. MORATORIUM ON MEDICAL DEVICE EXCISE TAX.

       (a) In General.--Section 4191 is amended by adding at the 
     end the following new subsection:
       ``(c) Moratorium.--The tax imposed under subsection (a) 
     shall not apply to sales during the period beginning on 
     January 1, 2016, and ending on December 31, 2017.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to sales after December 31, 2015.

       PART 3--INCENTIVES FOR ENERGY PRODUCTION AND CONSERVATION

     SEC. 181. EXTENSION AND MODIFICATION OF CREDIT FOR 
                   NONBUSINESS ENERGY PROPERTY.

       (a) Extension.--Section 25C(g)(2) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Updated Energy Star Requirements.--
       (1) In general.--Section 25C(c)(1) is amended by striking 
     ``which meets'' and all that follows through 
     ``requirements)''.
       (2) Energy efficient building envelope component.--Section 
     25C(c) 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.''.
       (c) Effective Dates.--
       (1) Extension.--The amendment made by subsection (a) shall 
     apply to property placed in service after December 31, 2014.
       (2) Modification.--The amendments made by subsection (b) 
     shall apply to property placed in service after December 31, 
     2015.

     SEC. 182. EXTENSION OF CREDIT FOR ALTERNATIVE FUEL VEHICLE 
                   REFUELING PROPERTY.

       (a) In General.--Section 30C(g) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2014.

     SEC. 183. EXTENSION OF CREDIT FOR 2-WHEELED PLUG-IN ELECTRIC 
                   VEHICLES.

       (a) In General.--Section 30D(g)(3)(E) is amended by 
     striking ``acquired'' and all that follows and inserting the 
     following: ``acquired--
       ``(i) after December 31, 2011, and before January 1, 2014, 
     or
       ``(ii) in the case of a vehicle that has 2 wheels, after 
     December 31, 2014, and before January 1, 2017.''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to vehicles acquired after December 31, 2014.

     SEC. 184. EXTENSION OF SECOND GENERATION BIOFUEL PRODUCER 
                   CREDIT.

       (a) In General.--Section 40(b)(6)(J)(i) is amended by 
     striking ``January 1, 2015'' and inserting ``January 1, 
     2017''.
       (b) Effective Date.--The amendment made by this subsection 
     shall apply to qualified second generation biofuel production 
     after December 31, 2014.

     SEC. 185. EXTENSION OF BIODIESEL AND RENEWABLE DIESEL 
                   INCENTIVES.

       (a) Income Tax Credit.--
       (1) In general.--Subsection (g) of section 40A is amended 
     by striking ``December 31, 2014'' and inserting ``December 
     31, 2016''.
       (2) Effective date.--The amendment made by this subsection 
     shall apply to fuel sold or used after December 31, 2014.
       (b) Excise Tax Incentives.--
       (1) In general.--Section 6426(c)(6) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (2) Payments.--Section 6427(e)(6)(B) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (3) Effective date.--The amendments made by this subsection 
     shall apply to fuel sold or used after December 31, 2014.
       (4) Special rule for 2015.--Notwithstanding any other 
     provision of law, in the case of any biodiesel mixture credit 
     properly determined under section 6426(c) of the Internal 
     Revenue Code of 1986 for the period beginning on January 1, 
     2015, and ending on December 31, 2015, such credit shall be 
     allowed, and any refund or payment attributable to such 
     credit (including any payment under section 6427(e) of such 
     Code) shall be made, only in such manner as the Secretary of 
     the Treasury (or the Secretary's delegate) shall provide. 
     Such Secretary shall issue guidance within 30 days after the 
     date of the enactment of this Act providing for a one-time 
     submission of claims covering periods described in the 
     preceding sentence. Such guidance shall provide for a 180-day 
     period for the submission of such claims (in such manner as 
     prescribed by such Secretary) to begin not later than 30 days 
     after such guidance is issued. Such claims shall be paid by 
     such Secretary not later than 60 days after receipt. If such 
     Secretary has not paid pursuant to a claim filed under this 
     subsection within 60 days after the date of the filing of 
     such claim, the claim shall be paid with interest from such 
     date determined by using the overpayment rate and method 
     under section 6621 of such Code.

     SEC. 186. EXTENSION AND MODIFICATION OF PRODUCTION CREDIT FOR 
                   INDIAN COAL FACILITIES.

       (a) In General.--Section 45(e)(10)(A) is amended by 
     striking ``9-year period'' each place it appears and 
     inserting ``11-year period''.
       (b) Repeal of Limitation Based on Date Facility Is Placed 
     in Service.--Section 45(d)(10) is amended to read as follows:
       ``(10) Indian coal production facility.--The term `Indian 
     coal production facility' means a facility that produces 
     Indian coal.''.
       (c) Treatment of Sales to Related Parties.--Section 
     45(e)(10)(A)(ii)(I) is amended by inserting ``(either 
     directly by the taxpayer or after sale or transfer to one or 
     more related persons)'' after ``unrelated person''.
       (d) Credit Allowed Against Alternative Minimum Tax.--
       (1) In general.--Section 38(c)(4)(B), as amended by the 
     preceding provisions of this Act, is amended by redesignating 
     clauses (v) through (x) as clauses (vi) through (xi), 
     respectively, and by inserting after clause (iv) the 
     following new clause:
       ``(v) the credit determined under section 45 to the extent 
     that such credit is attributable to section 45(e)(10) 
     (relating to Indian coal production facilities),''.
       (2) Conforming amendment.--Section 45(e)(10) is amended by 
     striking subparagraph (D).
       (e) Effective Dates.--
       (1) Extension.--The amendments made by subsection (a) shall 
     apply to coal produced after December 31, 2014.
       (2) Modifications.--The amendments made by subsections (b) 
     and (c) shall apply to coal produced and sold after December 
     31, 2015, in taxable years ending after such date.
       (3) Credit allowed against alternative minimum tax.--The 
     amendments made by subsection (d) shall apply to credits 
     determined for taxable years beginning after December 31, 
     2015.

     SEC. 187. 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, 2015'' each place 
     it appears and inserting ``January 1, 2017'':
       (1) Paragraph (2)(A).
       (2) Paragraph (3)(A).
       (3) Paragraph (4)(B).
       (4) Paragraph (6).
       (5) Paragraph (7).
       (6) Paragraph (9).
       (7) Paragraph (11)(B).
       (b) Extension of Election to Treat Qualified Facilities as 
     Energy Property.--Section 48(a)(5)(C)(ii) is amended by 
     striking ``January 1, 2015'' and inserting ``January 1, 
     2017''.
       (c) Effective Dates.--The amendments made by this section 
     shall take effect on January 1, 2015.

[[Page 20364]]



     SEC. 188. EXTENSION OF CREDIT FOR ENERGY-EFFICIENT NEW HOMES.

       (a) In General.--Section 45L(g) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to homes acquired after December 31, 2014.

     SEC. 189. EXTENSION OF SPECIAL ALLOWANCE FOR SECOND 
                   GENERATION BIOFUEL PLANT PROPERTY.

       (a) In General.--Section 168(l)(2)(D) is amended by 
     striking ``January 1, 2015'' and inserting ``January 1, 
     2017''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property placed in service after December 31, 
     2014.

     SEC. 190. EXTENSION OF ENERGY EFFICIENT COMMERCIAL BUILDINGS 
                   DEDUCTION.

       (a) In General.--Section 179D(h) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by subsection (a) 
     shall apply to property placed in service after December 31, 
     2014.

     SEC. 191. EXTENSION OF SPECIAL RULE FOR SALES OR DISPOSITIONS 
                   TO IMPLEMENT FERC OR STATE ELECTRIC 
                   RESTRUCTURING POLICY FOR QUALIFIED ELECTRIC 
                   UTILITIES.

       (a) In General.--Section 451(i)(3) is amended by striking 
     ``January 1, 2015'' and inserting ``January 1, 2017''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to dispositions after December 31, 2014.

     SEC. 192. EXTENSION OF EXCISE TAX CREDITS RELATING TO 
                   ALTERNATIVE FUELS.

       (a) 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, 2014'' and inserting 
     ``December 31, 2016''.
       (2) Outlay payments for alternative fuels.--Section 
     6427(e)(6)(C) is amended by striking ``December 31, 2014'' 
     and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to fuel sold or used after December 31, 2014.
       (c) Special Rule for 2015.--Notwithstanding any other 
     provision of law, in the case of any alternative fuel credit 
     properly determined under section 6426(d) of the Internal 
     Revenue Code of 1986 for the period beginning on January 1, 
     2015, and ending on December 31, 2015, such credit shall be 
     allowed, and any refund or payment attributable to such 
     credit (including any payment under section 6427(e) of such 
     Code) shall be made, only in such manner as the Secretary of 
     the Treasury (or the Secretary's delegate) shall provide. 
     Such Secretary shall issue guidance within 30 days after the 
     date of the enactment of this Act providing for a one-time 
     submission of claims covering periods described in the 
     preceding sentence. Such guidance shall provide for a 180-day 
     period for the submission of such claims (in such manner as 
     prescribed by such Secretary) to begin not later than 30 days 
     after such guidance is issued. Such claims shall be paid by 
     such Secretary not later than 60 days after receipt. If such 
     Secretary has not paid pursuant to a claim filed under this 
     subsection within 60 days after the date of the filing of 
     such claim, the claim shall be paid with interest from such 
     date determined by using the overpayment rate and method 
     under section 6621 of such Code.

     SEC. 193. EXTENSION OF CREDIT FOR NEW QUALIFIED FUEL CELL 
                   MOTOR VEHICLES.

       (a) In General.--Section 30B(k)(1) is amended by striking 
     ``December 31, 2014'' and inserting ``December 31, 2016''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to property purchased after December 31, 2014.

                      TITLE II--PROGRAM INTEGRITY

     SEC. 201. MODIFICATION OF FILING DATES OF RETURNS AND 
                   STATEMENTS RELATING TO EMPLOYEE WAGE 
                   INFORMATION AND NONEMPLOYEE COMPENSATION TO 
                   IMPROVE COMPLIANCE.

       (a) In General.--Section 6071 is amended by redesignating 
     subsection (c) as subsection (d), and by inserting after 
     subsection (b) the following new subsection:
       ``(c) Returns and Statements Relating to Employee Wage 
     Information and Nonemployee Compensation.--Forms W-2 and W-3 
     and any returns or statements required by the Secretary to 
     report nonemployee compensation shall be filed on or before 
     January 31 of the year following the calendar year to which 
     such returns relate.''.
       (b) Date for Certain Refunds.--Section 6402 is amended by 
     adding at the end the following new subsection:
       ``(m) Earliest Date for Certain Refunds.--No credit or 
     refund of an overpayment for a taxable year shall be made to 
     a taxpayer before the 15th day of the second month following 
     the close of such taxable year if a credit is allowed to such 
     taxpayer under section 24 (by reason of subsection (d) 
     thereof) or 32 for such taxable year.''.
       (c) Conforming Amendment.--Section 6071(b) is amended by 
     striking ``subparts B and C of part III of this subchapter'' 
     and inserting ``subpart B of part III of this subchapter 
     (other than returns and statements required to be filed with 
     respect to nonemployee compensation)''.
       (d) Effective Dates.--
       (1) In general.--Except as provided in paragraph (2), the 
     amendments made by this section shall apply to returns and 
     statements relating to calendar years beginning after the 
     date of the enactment of this Act.
       (2) Date for certain refunds.--The amendment made by 
     subsection (b) shall apply to credits or refunds made after 
     December 31, 2016.

     SEC. 202. SAFE HARBOR FOR DE MINIMIS ERRORS ON INFORMATION 
                   RETURNS AND PAYEE STATEMENTS.

       (a) In General.--Section 6721(c) is amended by adding at 
     the end the following new paragraph:
       ``(3) Safe harbor for certain de minimis errors.--
       ``(A) In general.--If, with respect to an information 
     return filed with the Secretary--
       ``(i) there are 1 or more failures described in subsection 
     (a)(2)(B) relating to an incorrect dollar amount,
       ``(ii) no single amount in error differs from the correct 
     amount by more than $100, and
       ``(iii) no single amount reported for tax withheld on any 
     information return differs from the correct amount by more 
     than $25,
     then no correction shall be required and, for purposes of 
     this section, such return shall be treated as having been 
     filed with all of the correct required information.
       ``(B) Exception.--Subparagraph (A) shall not apply with 
     respect to any incorrect dollar amount to the extent that 
     such error relates to an amount with respect to which an 
     election is made under section 6722(c)(3)(B).
       ``(C) Regulatory authority.--The Secretary may issue 
     regulations to prevent the abuse of the safe harbor under 
     this paragraph, including regulations providing that this 
     paragraph shall not apply to the extent necessary to prevent 
     any such abuse.''.
       (b) Failure To Furnish Correct Payee Statement.--Section 
     6722(c) is amended by adding at the end the following new 
     paragraph:
       ``(3) Safe harbor for certain de minimis errors.--
       ``(A) In general.--If, with respect to any payee 
     statement--
       ``(i) there are 1 or more failures described in subsection 
     (a)(2)(B) relating to an incorrect dollar amount,
       ``(ii) no single amount in error differs from the correct 
     amount by more than $100, and
       ``(iii) no single amount reported for tax withheld on any 
     information return differs from the correct amount by more 
     than $25,
     then no correction shall be required and, for purposes of 
     this section, such statement shall be treated as having been 
     filed with all of the correct required information.
       ``(B) Exception.--Subparagraph (A) shall not apply to any 
     payee statement if the person to whom such statement is 
     required to be furnished makes an election (at such time and 
     in such manner as the Secretary may prescribe) that 
     subparagraph (A) not apply with respect to such statement.
       ``(C) Regulatory authority.--The Secretary may issue 
     regulations to prevent the abuse of the safe harbor under 
     this paragraph, including regulations providing that this 
     paragraph shall not apply to the extent necessary to prevent 
     any such abuse.''.
       (c) Application to Broker Reporting of Basis.--Section 
     6045(g)(2)(B) is amended by adding at the end the following 
     new clause:
       ``(iii) Treatment of uncorrected de minimis errors.--Except 
     as otherwise provided by the Secretary, the customer's 
     adjusted basis shall be determined by treating any incorrect 
     dollar amount which is not required to be corrected by reason 
     of section 6721(c)(3) or section 6722(c)(3) as the correct 
     amount.''.
       (d) Conforming Amendments.--
       (1) Section 6721(c) is amended by striking ``Exception for 
     De Minimis Failures to Include All Required Information'' in 
     the heading and inserting ``Exceptions for Certain De Minimis 
     Failures''.
       (2) Section 6721(c)(1) is amended by striking ``In 
     general'' in the heading and inserting ``Exception for de 
     minimis failure to include all required information''.
       (e) Effective Date.--The amendments made by this section 
     shall apply to returns required to be filed, and payee 
     statements required to be provided, after December 31, 2016.

     SEC. 203. REQUIREMENTS FOR THE ISSUANCE OF ITINS.

       (a) In General.--Section 6109 is amended by adding at the 
     end the following new subsection:
       ``(i) Special Rules Relating to the Issuance of ITINs.--
       ``(1) In general.--The Secretary is authorized to issue an 
     individual taxpayer identification number to an individual 
     only if the applicant submits an application, using such form 
     as the Secretary may require and including the required 
     documentation--
       ``(A) in the case of an applicant not described in 
     subparagraph (B)--
       ``(i) in person to an employee of the Internal Revenue 
     Service or a community-based certified acceptance agent 
     approved by the Secretary, or
       ``(ii) by mail, pursuant to rules prescribed by the 
     Secretary, or
       ``(B) in the case of an applicant who resides outside of 
     the United States, by mail or in

[[Page 20365]]

     person to an employee of the Internal Revenue Service or a 
     designee of the Secretary at a United States diplomatic 
     mission or consular post.
       ``(2) Required documentation.--For purposes of this 
     subsection--
       ``(A) In general.--The term `required documentation' 
     includes such documentation as the Secretary may require that 
     proves the individual's identity, foreign status, and 
     residency.
       ``(B) Validity of documents.--The Secretary may accept only 
     original documents or certified copies meeting the 
     requirements of the Secretary.
       ``(3) Term of itin.--
       ``(A) In general.--An individual taxpayer identification 
     number issued after December 31, 2012, shall remain in effect 
     unless the individual to whom such number is issued does not 
     file a return of tax (or is not included as a dependent on 
     the return of tax of another taxpayer) for 3 consecutive 
     taxable years. In the case of an individual described in the 
     preceding sentence, such number shall expire on the last day 
     of such third consecutive taxable year.
       ``(B) Special rule for existing itins.--In the case of an 
     individual with respect to whom an individual taxpayer 
     identification number was issued before January 1, 2013, such 
     number shall remain in effect until the earlier of--
       ``(i) the applicable date, or
       ``(ii) if the individual does not file a return of tax (or 
     is not included as a dependent on the return of tax of 
     another taxpayer) for 3 consecutive taxable years, the 
     earlier of--

       ``(I) the last day of such third consecutive taxable year, 
     or
       ``(II) the last day of the taxable year that includes the 
     date of the enactment of this subsection.

       ``(C) Applicable date.--For purposes of subparagraph (B), 
     the term `applicable date' means--
       ``(i) January 1, 2017, in the case of an individual 
     taxpayer identification number issued before January 1, 2008,
       ``(ii) January 1, 2018, in the case of an individual 
     taxpayer identification number issued in 2008,
       ``(iii) January 1, 2019, in the case of an individual 
     taxpayer identification number issued in 2009 or 2010, and
       ``(iv) January 1, 2020, in the case of an individual 
     taxpayer identification number issued in 2011 or 2012.
       ``(4) Distinguishing itins issued solely for purposes of 
     treaty benefits.--The Secretary shall implement a system that 
     ensures that individual taxpayer identification numbers 
     issued solely for purposes of claiming tax treaty benefits 
     are used only for such purposes, by distinguishing such 
     numbers from other individual taxpayer identification numbers 
     issued.''.
       (b) Audit by TIGTA.--Not later than 2 years after the date 
     of the enactment of this Act, and every 2 years thereafter, 
     the Treasury Inspector General for Tax Administration shall 
     conduct an audit of the program of the Internal Revenue 
     Service for the issuance of individual taxpayer 
     identification numbers pursuant to section 6109(i) of the 
     Internal Revenue Code of 1986 (as added by this section) and 
     report the results of such audit to the Committee on Finance 
     of the Senate and the Committee on the Ways and Means of the 
     House of Representatives.
       (c) Community-based Certified Acceptance Agents.--The 
     Secretary of the Treasury, or the Secretary's delegate, shall 
     maintain a program for training and approving community-based 
     certified acceptance agents for purposes of section 
     6109(i)(1)(A)(i) of the Internal Revenue Code of 1986 (as 
     added by this section). Persons eligible to be acceptance 
     agents under such program include--
       (1) financial institutions (as defined in section 265(b)(5) 
     of such Code and the regulations thereunder),
       (2) colleges and universities which are described in 
     section 501(c)(3) of such Code and exempt from taxation under 
     section 501(a) of such Code,
       (3) Federal agencies (as defined in section 6402(h) of such 
     Code),
       (4) State and local governments, including agencies 
     responsible for vital records,
       (5) community-based organizations which are described in 
     subsection (c)(3) or (d) of section 501 of such Code and 
     exempt from taxation under section 501(a) of such Code,
       (6) persons that provide assistance to taxpayers in the 
     preparation of their tax returns, and
       (7) other persons or categories of persons as authorized by 
     regulations or other guidance of the Secretary of the 
     Treasury.
       (d) ITIN Study.--
       (1) In general.--The Secretary of the Treasury, or the 
     Secretary's delegate, shall conduct a study on the 
     effectiveness of the application process for individual 
     taxpayer identification numbers before the implementation of 
     the amendments made by this section, the effects of the 
     amendments made by this section on such application process, 
     the comparative effectiveness of an in-person review process 
     for application versus other methods of reducing fraud in the 
     ITIN program and improper payments to ITIN holders as a 
     result, and possible administrative and legislative 
     recommendations to improve such process.
       (2) Specific requirements.--Such study shall include an 
     evaluation of the following:
       (A) Possible administrative and legislative recommendations 
     to reduce fraud and improper payments through the use of 
     individual taxpayer identification numbers (hereinafter 
     referred to as ``ITINs'').
       (B) If data supports an in-person initial review of ITIN 
     applications to reduce fraud and improper payments, the 
     administrative and legislative steps needed to implement such 
     an in-person initial review of ITIN applications, in 
     conjunction with an expansion of the community-based 
     certified acceptance agent program under subsection (c), with 
     a goal of transitioning to such a program by 2020.
       (C) Strategies for more efficient processing of ITIN 
     applications.
       (D) The acceptance agent program as in existence on the 
     date of the enactment of this Act and ways to expand the 
     geographic availability of agents through the community-based 
     certified acceptance agent program under subsection (c).
       (E) Strategies for the Internal Revenue Service to work 
     with other Federal agencies, State and local governments, and 
     other organizations and persons described in subsection (c) 
     to encourage participation in the community-based certified 
     acceptance agent program under subsection (c) to facilitate 
     in-person initial review of ITIN applications.
       (F) Typical characteristics (derived from Form W-7 and 
     other sources) of mail applications for ITINs as compared 
     with typical characteristics of in-person applications.
       (G) Typical characteristics (derived from 17 Form W-7 and 
     other sources) of ITIN applications before the Internal 
     Revenue Service revised its application procedures in 2012 as 
     compared with typical characteristics of ITIN applications 
     made after such revisions went into effect.
       (3) Report.--The Secretary, or the Secretary's delegate, 
     shall submit to the Committee on Finance of the Senate and 
     the Committee on Ways and Means of the House of 
     Representatives a report detailing the study under paragraph 
     (1) and its findings not later than 1 year after the date of 
     the enactment of this Act.
       (4) Administrative steps.--The Secretary of the Treasury 
     shall implement any administrative steps identified by the 
     report under paragraph (3) not later than 180 days after 
     submitting such report.
       (e) Mathematical or Clerical Error Authority.--Paragraph 
     (2) of section 6213(g) of the Internal Revenue Code of 1986 
     is amended by striking ``and'' at the end of subparagraph 
     (M), by striking the period at the end of subparagraph (N) 
     and inserting ``, and'', and by inserting after subparagraph 
     (N) the following new subparagraph:
       ``(O) the inclusion on a return of an individual taxpayer 
     identification number issued under section 6109(i) which has 
     expired, been revoked by the Secretary, or is otherwise 
     invalid.''.
       (f) Effective Date.--The amendments made by this section 
     shall apply to applications for individual taxpayer 
     identification numbers made after the date of the enactment 
     of this Act.

     SEC. 204. PREVENTION OF RETROACTIVE CLAIMS OF EARNED INCOME 
                   CREDIT AFTER ISSUANCE OF SOCIAL SECURITY 
                   NUMBER.

       (a) In General.--Section 32(m) is amended by inserting ``on 
     or before the due date for filing the return for the taxable 
     year'' before the period at the end.
       (b) Effective Date.--
       (1) In general.--Except as provided in paragraph (2), the 
     amendment made by this section shall apply to any return of 
     tax, and any amendment or supplement to any return of tax, 
     which is filed after the date of the enactment of this Act.
       (2) Exception for timely-filed 2015 returns.--The amendment 
     made by this section shall not apply to any return of tax 
     (other than an amendment or supplement to any return of tax) 
     for any taxable year which includes the date of the enactment 
     of this Act if such return is filed on or before the due date 
     for such return of tax.

     SEC. 205. PREVENTION OF RETROACTIVE CLAIMS OF CHILD TAX 
                   CREDIT.

       (a) Qualifying Child Identification Requirement.--Section 
     24(e) is amended by inserting ``and such taxpayer 
     identification number was issued on or before the due date 
     for filing such return'' before the period at the end.
       (b) Taxpayer Identification Requirement.--Section 24(e), as 
     amended by subsection (a) is amended--
       (1) by striking ``Identification Requirement.--No credit 
     shall be allowed'' and inserting the following: 
     ``Identification Requirements.--
       ``(1) Qualifying child identification requirement.--No 
     credit shall be allowed'', and
       (2) by adding at the end the following new paragraph:
       ``(2) Taxpayer identification requirement.--No credit shall 
     be allowed under this section if the identifying number of 
     the taxpayer was issued after the due date for filing the 
     return for the taxable year.''.
       (c) Effective Date.--
       (1) In general.--The amendments made by this section shall 
     apply to any return of tax,

[[Page 20366]]

     and any amendment or supplement to any return of tax, which 
     is filed after the date of the enactment of this Act.
       (2) Exception for timely-filed 2015 returns.--The 
     amendments made by this section shall not apply to any return 
     of tax (other than an amendment or supplement to any return 
     of tax) for any taxable year which includes the date of the 
     enactment of this Act if such return is filed on or before 
     the due date for such return of tax.

     SEC. 206. PREVENTION OF RETROACTIVE CLAIMS OF AMERICAN 
                   OPPORTUNITY TAX CREDIT.

       (a) In General.--Section 25A(i) is amended--
       (1) by striking paragraph (6), and
       (2) by inserting after paragraph (5) the following new 
     paragraph:
       ``(6) Identification numbers.--
       ``(A) Student.--The requirements of subsection (g)(1) shall 
     not be treated as met with respect to the Hope Scholarship 
     Credit unless the individual's taxpayer identification number 
     was issued on or before the due date for filing the return of 
     tax for the taxable year.
       ``(B) Taxpayer.--No Hope Scholarship Credit shall be 
     allowed under this section if the identifying number of the 
     taxpayer was issued after the due date for filing the return 
     for the taxable year.''.
       (b) Effective Dates.--
       (1) In general.--Except as provided in paragraph (2), the 
     amendment made by subsection (a)(2) shall apply to any return 
     of tax, and any amendment or supplement to any return of tax, 
     which is filed after the date of the enactment of this Act.
       (2) Exception for timely-filed 2015 returns.--The amendment 
     made by subsection (a)(2) shall not apply to any return of 
     tax (other than an amendment or supplement to any return of 
     tax) for any taxable year which includes the date of the 
     enactment of this Act if such return is filed on or before 
     the due date for such return of tax.
       (3) Repeal of deadwood.--The amendment made by subsection 
     (a)(1) shall take effect on the date of the enactment of this 
     Act.

     SEC. 207. PROCEDURES TO REDUCE IMPROPER CLAIMS.

       (a) Due Diligence Requirements.--Section 6695(g) is 
     amended--
       (1) by striking ``section 32''and inserting ``section 24, 
     25A(a)(1), or 32'', and
       (2) in the heading by inserting ``Child Tax Credit; 
     American Opportunity Tax Credit; and'' before ``Earned Income 
     Credit''.
       (b) Return Preparer Due Diligence Study.--
       (1) In general.--The Secretary of the Treasury, or his 
     delegate, shall conduct a study of the effectiveness of tax 
     return preparer due diligence requirements for claiming the 
     earned income tax credit under section 32 of the Internal 
     Revenue Code of 1986, the child tax credit under section 24 
     of such Code, and the American opportunity tax credit under 
     section 25A(i) of such Code.
       (2) Requirements.--Such study shall include an evaluation 
     of the following:
       (A) The effectiveness of the questions currently asked as 
     part of the due-diligence requirement with respect to 
     minimizing error and fraud.
       (B) Whether all such questions are necessary and support 
     improved compliance.
       (C) The comparative effectiveness of such questions 
     relative to other means of determining (i) eligibility for 
     these tax credits and (ii) the correct amount of tax credit.
       (D) Whether due diligence of this type should apply to 
     other methods of tax filing and whether such requirements 
     should vary based on the methods to increase effectiveness.
       (E) The effectiveness of the preparer penalty under section 
     6695(g) in enforcing the due diligence requirements.
       (3) Report.--The Secretary, or his delegate, shall submit 
     to the Committee on Ways and Means of the House of 
     Representatives and the Committee on Finance of the Senate a 
     report detailing the study and its findings--
       (A) in the case of the portion of the study that relates to 
     the earned income tax credit, not later than 1 year after the 
     date of enactment of this Act, and
       (B) in the case of the portions of the study that relate to 
     the child tax credit and the American opportunity tax credit, 
     not later than 2 years after the date of the enactment of 
     this Act.
       (c) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 208. RESTRICTIONS ON TAXPAYERS WHO IMPROPERLY CLAIMED 
                   CREDITS IN PRIOR YEAR.

       (a) Restrictions.--
       (1) Child tax credit.--Section 24 is amended by adding at 
     the end the following new subsection:
       ``(g) Restrictions on Taxpayers Who Improperly Claimed 
     Credit in Prior Year.--
       ``(1) Taxpayers making prior fraudulent or reckless 
     claims.--
       ``(A) In general.--No credit shall be allowed under this 
     section for any taxable year in the disallowance period.
       ``(B) Disallowance period.--For purposes of subparagraph 
     (A), the disallowance period is--
       ``(i) the period of 10 taxable years after the most recent 
     taxable year for which there was a final determination that 
     the taxpayer's claim of credit under this section was due to 
     fraud, and
       ``(ii) the period of 2 taxable years after the most recent 
     taxable year for which there was a final determination that 
     the taxpayer's claim of credit under this section was due to 
     reckless or intentional disregard of rules and regulations 
     (but not due to fraud).
       ``(2) Taxpayers making improper prior claims.--In the case 
     of a taxpayer who is denied credit under this section for any 
     taxable year as a result of the deficiency procedures under 
     subchapter B of chapter 63, no credit shall be allowed under 
     this section for any subsequent taxable year unless the 
     taxpayer provides such information as the Secretary may 
     require to demonstrate eligibility for such credit.''.
       (2) American opportunity tax credit.--Section 25A(i), as 
     amended by the preceding provisions of this Act, is amended 
     by adding at the end the following new paragraph:
       ``(7) Restrictions on taxpayers who improperly claimed 
     credit in prior year.--
       ``(A) Taxpayers making prior fraudulent or reckless 
     claims.--
       ``(i) In general.--No credit shall be allowed under this 
     section for any taxable year in the disallowance period.
       ``(ii) Disallowance period.--For purposes of clause (i), 
     the disallowance period is--

       ``(I) the period of 10 taxable years after the most recent 
     taxable year for which there was a final determination that 
     the taxpayer's claim of credit under this section was due to 
     fraud, and
       ``(II) the period of 2 taxable years after the most recent 
     taxable year for which there was a final determination that 
     the taxpayer's claim of credit under this section was due to 
     reckless or intentional disregard of rules and regulations 
     (but not due to fraud).

       ``(B) Taxpayers making improper prior claims.--In the case 
     of a taxpayer who is denied credit under this section for any 
     taxable year as a result of the deficiency procedures under 
     subchapter B of chapter 63, no credit shall be allowed under 
     this section for any subsequent taxable year unless the 
     taxpayer provides such information as the Secretary may 
     require to demonstrate eligibility for such credit.''.
       (b) Math Error Authority.--
       (1) Earned income tax credit.--Section 6213(g)(2)(K) is 
     amended by inserting before the comma at the end the 
     following: ``or an entry on the return claiming the credit 
     under section 32 for a taxable year for which the credit is 
     disallowed under subsection (k)(1) thereof''.
       (2) American opportunity tax credit and child tax credit.--
     Section 6213(g)(2), as amended by the preceding provisions of 
     this Act, is amended by striking ``and'' at the end of 
     subparagraph (N), by striking the period at the end of 
     subparagraph (O), and by inserting after subparagraph (O) the 
     following new subparagraphs:
       ``(P) an omission of information required by section 
     24(h)(2) or an entry on the return claiming the credit under 
     section 24 for a taxable year for which the credit is 
     disallowed under subsection (h)(1) thereof, and
       ``(Q) an omission of information required by section 
     25A(i)(8)(B) or an entry on the return claiming the credit 
     determined under section 25A(i) for a taxable year for which 
     the credit is disallowed under paragraph (8)(A) thereof.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 209. TREATMENT OF CREDITS FOR PURPOSES OF CERTAIN 
                   PENALTIES.

       (a) Application of Underpayment Penalties.--Section 6664(a) 
     is amended by adding at the end the following: ``A rule 
     similar to the rule of section 6211(b)(4) shall apply for 
     purposes of this subsection.''.
       (b) Penalty for Erroneous Claim of Credit Made Applicable 
     to Earned Income Credit.--Section 6676(a) is amended by 
     striking ``(other than a claim for a refund or credit 
     relating to the earned income credit under section 32)''.
       (c) Reasonable Cause Exception for Erroneous Claim for 
     Refund or Credit.--
       (1) In general.--Section 6676(a) is amended by striking 
     ``has a reasonable basis'' and inserting ``is due to 
     reasonable cause''.
       (2) Noneconomic substance transactions.--Section 6676(c) is 
     amended by striking ``having a reasonable basis'' and 
     inserting ``due to reasonable cause''.
       (d) Effective Dates.--
       (1) Underpayment penalties.--The amendment made by 
     subsection (a) shall apply to--
       (A) returns filed after the date of the enactment of this 
     Act, and
       (B) returns filed on or before such date if the period 
     specified in section 6501 of the Internal Revenue Code of 
     1986 for assessment of the taxes with respect to which such 
     return relates has not expired as of such date.
       (2) Penalty for erroneous claim of credit.--The amendment 
     made by subsection (b) shall apply to claims filed after the 
     date of the enactment of this Act.

     SEC. 210. INCREASE THE PENALTY APPLICABLE TO PAID TAX 
                   PREPARERS WHO ENGAGE IN WILLFUL OR RECKLESS 
                   CONDUCT.

       (a) In General.--Section 6694(b)(1)(B) is amended by 
     striking ``50 percent'' and inserting ``75 percent''.

[[Page 20367]]

       (b) Effective Date.--The amendment made by this section 
     shall apply to returns prepared for taxable years ending 
     after the date of the enactment of this Act.

     SEC. 211. EMPLOYER IDENTIFICATION NUMBER REQUIRED FOR 
                   AMERICAN OPPORTUNITY TAX CREDIT.

       (a) In General.--Section 25A(i)(6), as added by this Act, 
     is amended by adding at the end the following new 
     subparagraph:
       ``(C) Institution.--No Hope Scholarship Credit shall be 
     allowed under this section unless the taxpayer includes the 
     employer identification number of any institution to which 
     qualified tuition and related expenses were paid with respect 
     to the individual.''.
       (b) Information Reporting.--Section 6050S(b)(2) is amended 
     by striking ``and'' at the end of subparagraph (B), by 
     redesignating subparagraph (C) as subparagraph (D), and by 
     inserting after subparagraph (B) the following new 
     subparagraph:
       ``(C) the employer identification number of the 
     institution, and''.
       (c) Effective Date.--
       (1) Subsection (a).--The amendments made by subsection (a) 
     shall apply to taxable years beginning after December 31, 
     2015.
       (2) Subsection (b).--The amendments made by subsection (b) 
     shall apply to expenses paid after December 31, 2015, for 
     education furnished in academic periods beginning after such 
     date.

     SEC. 212. HIGHER EDUCATION INFORMATION REPORTING ONLY TO 
                   INCLUDE QUALIFIED TUITION AND RELATED EXPENSES 
                   ACTUALLY PAID.

       (a) In General.--Section 6050S(b)(2)(B)(i) is amended by 
     striking ``or the aggregate amount billed''.
       (b) Effective Date.--The amendments made by subsection (b) 
     shall apply to expenses paid after December 31, 2015, for 
     education furnished in academic periods beginning after such 
     date.

                  TITLE III--MISCELLANEOUS PROVISIONS

                     Subtitle A--Family Tax Relief

     SEC. 301. EXCLUSION FOR AMOUNTS RECEIVED UNDER THE WORK 
                   COLLEGES PROGRAM.

       (a) In General.--Paragraph (2) of section 117(c) is amended 
     by striking ``or'' at the end of subparagraph (A), by 
     striking the period at the end of subparagraph (B) and 
     inserting ``, or'', and by adding at the end the following 
     new subparagraph:
       ``(C) a comprehensive student work-learning-service program 
     (as defined in section 448(e) of the Higher Education Act of 
     1965) operated by a work college (as defined in such 
     section).''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to amounts received in taxable years beginning 
     after the date of the enactment of this Act.

     SEC. 302. IMPROVEMENTS TO SECTION 529 ACCOUNTS.

       (a) Computer Technology and Equipment Permanently Allowed 
     as a Qualified Higher Education Expense for Section 529 
     Accounts.--
       (1) In general.--Section 529(e)(3)(A)(iii) is amended to 
     read as follows:
       ``(iii) expenses for the purchase of computer or peripheral 
     equipment (as defined in section 168(i)(2)(B)), computer 
     software (as defined in section 197(e)(3)(B)), or Internet 
     access and related services, if such equipment, software, or 
     services are to be used primarily by the beneficiary during 
     any of the years the beneficiary is enrolled at an eligible 
     educational institution.''.
       (2) Effective date.--The amendment made by this subsection 
     shall apply to taxable years beginning after December 31, 
     2014.
       (b) Elimination of Distribution Aggregation Requirements.--
       (1) In general.--Section 529(c)(3) is amended by striking 
     subparagraph (D).
       (2) Effective date.--The amendment made by this subsection 
     shall apply to distributions after December 31, 2014.
       (c) Recontribution of Refunded Amounts.--
       (1) In general.--Section 529(c)(3), as amended by 
     subsection (b), is amended by adding at the end the following 
     new subparagraph:
       ``(D) Special rule for contributions of refunded amounts.--
     In the case of a beneficiary who receives a refund of any 
     qualified higher education expenses from an eligible 
     educational institution, subparagraph (A) shall not apply to 
     that portion of any distribution for the taxable year which 
     is recontributed to a qualified tuition program of which such 
     individual is a beneficiary, but only to the extent such 
     recontribution is made not later than 60 days after the date 
     of such refund and does not exceed the refunded amount.''.
       (2) Effective date.--
       (A) In general.--The amendment made by this subsection 
     shall apply with respect to refunds of qualified higher 
     education expenses after December 31, 2014.
       (B) Transition rule.--In the case of a refund of qualified 
     higher education expenses received after December 31, 2014, 
     and before the date of the enactment of this Act, section 
     529(c)(3)(D) of the Internal Revenue Code of 1986 (as added 
     by this subsection) shall be applied by substituting ``not 
     later than 60 days after the date of the enactment of this 
     subparagraph'' for ``not later than 60 days after the date of 
     such refund''.

     SEC. 303. ELIMINATION OF RESIDENCY REQUIREMENT FOR QUALIFIED 
                   ABLE PROGRAMS.

       (a) In General.--Section 529A(b)(1) is amended by striking 
     subparagraph (C), by inserting ``and'' at the end of 
     subparagraph (B), and by redesignating subparagraph (D) as 
     subparagraph (C).
       (b) Conforming Amendments.--
       (1) The second sentence of section 529A(d)(3) is amended by 
     striking ``and State of residence''.
       (2) Section 529A(e) is amended by striking paragraph (7).
       (c) Technical Amendments.--
       (1) Section 529A(d)(4) is amended by striking ``section 4'' 
     and inserting ``section 103''.
       (2) Section 529A(c)(1)(C)(i) is amended by striking 
     ``family member'' and inserting ``member of the family''.
       (d) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2014.

     SEC. 304. EXCLUSION FOR WRONGFULLY INCARCERATED INDIVIDUALS.

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

     ``SEC. 139F. CERTAIN AMOUNTS RECEIVED BY WRONGFULLY 
                   INCARCERATED INDIVIDUALS.

       ``(a) Exclusion From Gross Income.--In the case of any 
     wrongfully incarcerated individual, gross income shall not 
     include any civil damages, restitution, or other monetary 
     award (including compensatory or statutory damages and 
     restitution imposed in a criminal matter) relating to the 
     incarceration of such individual for the covered offense for 
     which such individual was convicted.
       ``(b) Wrongfully Incarcerated Individual.--For purposes of 
     this section, the term `wrongfully incarcerated individual' 
     means an individual--
       ``(1) who was convicted of a covered offense,
       ``(2) who served all or part of a sentence of imprisonment 
     relating to that covered offense, and
       ``(3)(A) who was pardoned, granted clemency, or granted 
     amnesty for that covered offense because that individual was 
     innocent of that covered offense, or
       ``(B)(i) for whom the judgment of conviction for that 
     covered offense was reversed or vacated, and
       ``(ii) for whom the indictment, information, or other 
     accusatory instrument for that covered offense was dismissed 
     or who was found not guilty at a new trial after the judgment 
     of conviction for that covered offense was reversed or 
     vacated.
       ``(c) Covered Offense.--For purposes of this section, the 
     term `covered offense' means any criminal offense under 
     Federal or State law, and includes any criminal offense 
     arising from the same course of conduct as that criminal 
     offense.''.
       (b) Conforming Amendment.--The table of sections for part 
     III of subchapter B of chapter 1 is amended by inserting 
     after the item relating to section 139E the following new 
     item:

``Sec. 139F. Certain amounts received by wrongfully incarcerated 
              individuals.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning before, on, or after 
     the date of the enactment of this Act.
       (d) Waiver of Limitations.--If the credit or refund of any 
     overpayment of tax resulting from the application of this Act 
     to a period before the date of enactment of this Act is 
     prevented as of such date by the operation of any law or rule 
     of law (including res judicata), such credit or refund may 
     nevertheless be allowed or made if the claim therefor is 
     filed before the close of the 1-year period beginning on the 
     date of the enactment of this Act.

     SEC. 305. CLARIFICATION OF SPECIAL RULE FOR CERTAIN 
                   GOVERNMENTAL PLANS.

       (a) In General.--Paragraph (1) of section 105(j) is 
     amended--
       (1) by striking ``the taxpayer'' and inserting ``a 
     qualified taxpayer'', and
       (2) by striking ``deceased plan participant's beneficiary'' 
     and inserting ``deceased employee's beneficiary (other than 
     an individual described in paragraph (3)(B))''.
       (b) Qualified Taxpayer.--Subsection (j) of section 105 is 
     amended by adding at the end the following new paragraph:
       ``(3) Qualified taxpayer.--For purposes of paragraph (1), 
     with respect to an accident or health plan described in 
     paragraph (2), the term `qualified taxpayer' means a taxpayer 
     who is--
       ``(A) an employee, or
       ``(B) the spouse, dependent (as defined for purposes of 
     subsection (b)), or child (as defined for purposes of such 
     subsection) of an employee.''.
       (c) Application to Political Subdivisions of States.--
     Paragraph (2) of section 105(j) is amended--
       (1) by inserting ``or established by or on behalf of a 
     State or political subdivision thereof'' after ``public 
     retirement system'', and
       (2) by inserting ``or 501(c)(9)'' after ``section 115'' in 
     subparagraph (B).
       (d) Effective Date.--The amendments made by this section 
     shall apply to payments after the date of the enactment of 
     this Act.

[[Page 20368]]



     SEC. 306. ROLLOVERS PERMITTED FROM OTHER RETIREMENT PLANS 
                   INTO SIMPLE RETIREMENT ACCOUNTS.

       (a) In General.--Section 408(p)(1)(B) is amended by 
     inserting ``except in the case of a rollover contribution 
     described in subsection (d)(3)(G) or a rollover contribution 
     otherwise described in subsection (d)(3) or in section 
     402(c), 403(a)(4), 403(b)(8), or 457(e)(16), which is made 
     after the 2-year period described in section 72(t)(6),'' 
     before ``with respect to which the only contributions 
     allowed''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to contributions made after the date of the 
     enactment of this Act.

     SEC. 307. TECHNICAL AMENDMENT RELATING TO ROLLOVER OF CERTAIN 
                   AIRLINE PAYMENT AMOUNTS.

       (a) In General.--Section 1106(a) of the FAA Modernization 
     and Reform Act of 2012 (26 U.S.C. 408 note) is amended by 
     adding at the end the following new paragraph:
       ``(6) Special rule for certain airline payment amounts.--In 
     the case of any amount which became an airline payment amount 
     by reason of the amendments made by section 1(b) of Public 
     Law 113-243 (26 U.S.C. 408 note), paragraph (1) shall be 
     applied by substituting `(or, if later, within the period 
     beginning on December 18, 2014, and ending on the date which 
     is 180 days after the date of enactment of the Protecting 
     Americans from Tax Hikes Act of 2015)' for `(or, if later, 
     within 180 days of the date of the enactment of this 
     Act)'.''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect as if included in Public Law 113-243 (26 
     U.S.C. 408 note).

     SEC. 308. TREATMENT OF EARLY RETIREMENT DISTRIBUTIONS FOR 
                   NUCLEAR MATERIALS COURIERS, UNITED STATES 
                   CAPITOL POLICE, SUPREME COURT POLICE, AND 
                   DIPLOMATIC SECURITY SPECIAL AGENTS.

       (a) In General.--Section 72(t)(10)(B)(ii), as added by 
     Public Law 114-26, is amended by striking ``or any'' and 
     inserting ``any'' and by inserting before the period at the 
     end the following: ``, any nuclear materials courier 
     described in section 8331(27) or 8401(33) of such title, any 
     member of the United States Capitol Police, any member of the 
     Supreme Court Police, or any diplomatic security special 
     agent of the Department of State''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to distributions after December 31, 2015.

     SEC. 309. PREVENTION OF EXTENSION OF TAX COLLECTION PERIOD 
                   FOR MEMBERS OF THE ARMED FORCES WHO ARE 
                   HOSPITALIZED AS A RESULT OF COMBAT ZONE 
                   INJURIES.

       (a) In General.--Section 7508(e) is amended by adding at 
     the end the following new paragraph:
       ``(3) Collection period after assessment not extended as a 
     result of hospitalization.--With respect to any period of 
     continuous qualified hospitalization described in subsection 
     (a) and the next 180 days thereafter, subsection (a) shall 
     not apply in the application of section 6502.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxes assessed before, on, or after the date 
     of the enactment of this Act.

               Subtitle B--Real Estate Investment Trusts

     SEC. 311. RESTRICTION ON TAX-FREE SPINOFFS INVOLVING REITS.

       (a) In General.--Section 355 is amended by adding at the 
     end the following new subsection:
       ``(h) Restriction on Distributions Involving Real Estate 
     Investment Trusts.--
       ``(1) In general.--This section (and so much of section 356 
     as relates to this section) shall not apply to any 
     distribution if either the distributing corporation or 
     controlled corporation is a real estate investment trust.
       ``(2) Exceptions for certain spinoffs.--
       ``(A) Spinoffs of a real estate investment trust by another 
     real estate investment trust.--Paragraph (1) shall not apply 
     to any distribution if, immediately after the distribution, 
     the distributing corporation and the controlled corporation 
     are both real estate investment trusts.
       ``(B) Spinoffs of certain taxable reit subsidiaries.--
     Paragraph (1) shall not apply to any distribution if--
       ``(i) the distributing corporation has been a real estate 
     investment trust at all times during the 3-year period ending 
     on the date of such distribution,
       ``(ii) the controlled corporation has been a taxable REIT 
     subsidiary (as defined in section 856(l)) of the distributing 
     corporation at all times during such period, and
       ``(iii) the distributing corporation had control (as 
     defined in section 368(c) applied by taking into account 
     stock owned directly or indirectly, including through one or 
     more corporations or partnerships, by the distributing 
     corporation) of the controlled corporation at all times 
     during such period.
     A controlled corporation will be treated as meeting the 
     requirements of clauses (ii) and (iii) if the stock of such 
     corporation was distributed by a taxable REIT subsidiary in a 
     transaction to which this section (or so much of section 356 
     as relates to this section) applies and the assets of such 
     corporation consist solely of the stock or assets of assets 
     held by one or more taxable REIT subsidiaries of the 
     distributing corporation meeting the requirements of clauses 
     (ii) and (iii). For purposes of clause (iii), control of a 
     partnership means ownership of 80 percent of the profits 
     interest and 80 percent of the capital interests.''.
       (b) Prevention of REIT Election Following Tax-free Spin 
     Off.--Section 856(c) is amended by redesignating paragraph 
     (8) as paragraph (9) and by inserting after paragraph (7) the 
     following new paragraph:
       ``(8) Election after tax-free reorganization.--If a 
     corporation was a distributing corporation or a controlled 
     corporation (other than a controlled corporation with respect 
     to a distribution described in section 355(h)(2)(A)) with 
     respect to any distribution to which section 355 (or so much 
     of section 356 as relates to section 355) applied, such 
     corporation (and any successor corporation) shall not be 
     eligible to make any election under paragraph (1) for any 
     taxable year beginning before the end of the 10-year period 
     beginning on the date of such distribution.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to distributions on or after December 7, 2015, 
     but shall not apply to any distribution pursuant to a 
     transaction described in a ruling request initially submitted 
     to the Internal Revenue Service on or before such date, which 
     request has not been withdrawn and with respect to which a 
     ruling has not been issued or denied in its entirety as of 
     such date.

     SEC. 312. REDUCTION IN PERCENTAGE LIMITATION ON ASSETS OF 
                   REIT WHICH MAY BE TAXABLE REIT SUBSIDIARIES.

       (a) In General.--Section 856(c)(4)(B)(ii) is amended by 
     striking ``25 percent'' and inserting ``20 percent''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to taxable years beginning after December 31, 
     2017.

     SEC. 313. PROHIBITED TRANSACTION SAFE HARBORS.

       (a) Alternative 3-Year Averaging Test for Percentage of 
     Assets That Can Be Sold Annually.--
       (1) In general.--Clause (iii) of section 857(b)(6)(C) is 
     amended by inserting before the semicolon at the end the 
     following: ``, or (IV) the trust satisfies the requirements 
     of subclause (II) applied by substituting `20 percent' for 
     `10 percent' and the 3-year average adjusted bases percentage 
     for the taxable year (as defined in subparagraph (G)) does 
     not exceed 10 percent, or (V) the trust satisfies the 
     requirements of subclause (III) applied by substituting `20 
     percent' for `10 percent' and the 3-year average fair market 
     value percentage for the taxable year (as defined in 
     subparagraph (H)) does not exceed 10 percent''.
       (2) 3-year average adjusted bases and fair market value 
     percentages.--Paragraph (6) of section 857(b) is amended by 
     redesignating subparagraphs (G) and (H) as subparagraphs (I) 
     and (J), respectively, and by inserting after subparagraph 
     (F) the following new subparagraphs:
       ``(G) 3-year average adjusted bases percentage.--The term 
     `3-year average adjusted bases percentage' means, with 
     respect to any taxable year, the ratio (expressed as a 
     percentage) of--
       ``(i) the aggregate adjusted bases (as determined for 
     purposes of computing earnings and profits) of property 
     (other than sales of foreclosure property or sales to which 
     section 1033 applies) sold during the 3 taxable year period 
     ending with such taxable year, divided by
       ``(ii) the sum of the aggregate adjusted bases (as so 
     determined) of all of the assets of the trust as of the 
     beginning of each of the 3 taxable years which are part of 
     the period referred to in clause (i).
       ``(H) 3-year average fair market value percentage.--The 
     term `3-year average fair market value percentage' means, 
     with respect to any taxable year, the ratio (expressed as a 
     percentage) of--
       ``(i) the fair market value of property (other than sales 
     of foreclosure property or sales to which section 1033 
     applies) sold during the 3 taxable year period ending with 
     such taxable year, divided by
       ``(ii) the sum of the fair market value of all of the 
     assets of the trust as of the beginning of each of the 3 
     taxable years which are part of the period referred to in 
     clause (i).''.
       (3) Conforming amendments.--Clause (iv) of section 
     857(b)(6)(D) is amended by adding ``or'' at the end of 
     subclause (III) and by adding at the end the following new 
     subclauses:

       ``(IV) the trust satisfies the requirements of subclause 
     (II) applied by substituting `20 percent' for `10 percent' 
     and the 3-year average adjusted bases percentage for the 
     taxable year (as defined in subparagraph (G)) does not exceed 
     10 percent, or
       ``(V) the trust satisfies the requirements of subclause 
     (III) applied by substituting `20 percent' for `10 percent' 
     and the 3-year average fair market value percentage for the 
     taxable year (as defined in subparagraph (H)) does not exceed 
     10 percent,''.

       (b) Application of Safe Harbors Independent of 
     Determination Whether Real Estate Asset Is Inventory 
     Property.--
       (1) In general.--Subparagraphs (C) and (D) of section 
     857(b)(6) are each amended by striking ``and which is 
     described in section 1221(a)(1)'' in the matter preceding 
     clause (i).

[[Page 20369]]

       (2) No inference from safe harbors.--Subparagraph (F) of 
     section 857(b)(6) is amended to read as follows:
       ``(F) No inference with respect to treatment as inventory 
     property.--The determination of whether property is described 
     in section 1221(a)(1) shall be made without regard to this 
     paragraph.''.
       (c) Effective Dates.--
       (1) In general.--The amendments made by subsection (a) 
     shall apply to taxable years beginning after the date of the 
     enactment of this Act.
       (2) Application of safe harbors.--
       (A) In general.--Except as provided in subparagraph (B), 
     the amendments made by subsection (b) shall take effect as if 
     included in section 3051 of the Housing Assistance Tax Act of 
     2008.
       (B) Retroactive application of no inference not applicable 
     to certain timber property previously treated as not 
     inventory property.--The amendment made by subsection (b)(2) 
     shall not apply to any sale of property to which section 
     857(b)(6)(G) of the Internal Revenue Code of 1986 (as in 
     effect on the day before the date of the enactment of this 
     Act) applies.

     SEC. 314. REPEAL OF PREFERENTIAL DIVIDEND RULE FOR PUBLICLY 
                   OFFERED REITS.

       (a) In General.--Section 562(c) is amended by inserting 
     ``or a publicly offered REIT'' after ``a publicly offered 
     regulated investment company (as defined in section 
     67(c)(2)(B))''.
       (b) Publicly Offered REIT.--Section 562(c), as amended by 
     subsection (a), is amended--
       (1) by striking ``Except in the case of'' and inserting the 
     following:
       ``(1) In general.--Except in the case of'', and
       (2) by adding at the end the following new paragraph:
       ``(2) Publicly offered reit.--For purposes of this 
     subsection, the term `publicly offered REIT' means a real 
     estate investment trust which is required to file annual and 
     periodic reports with the Securities and Exchange Commission 
     under the Securities Exchange Act of 1934.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to distributions in taxable years beginning after 
     December 31, 2014.

     SEC. 315. AUTHORITY FOR ALTERNATIVE REMEDIES TO ADDRESS 
                   CERTAIN REIT DISTRIBUTION FAILURES.

       (a) In General.--Subsection (e) of section 562 is amended--
       (1) by striking ``In the case of a real estate investment 
     trust'' and inserting the following:
       ``(1) Determination of earnings and profits for purposes of 
     dividends paid deduction.--In the case of a real estate 
     investment trust'', and
       (2) by adding at the end the following new paragraph:
       ``(2) Authority to provide alternative remedies for certain 
     failures.--In the case of a failure of a distribution by a 
     real estate investment trust to comply with the requirements 
     of subsection (c), the Secretary may provide an appropriate 
     remedy to cure such failure in lieu of not considering the 
     distribution to be a dividend for purposes of computing the 
     dividends paid deduction if--
       ``(A) the Secretary determines that such failure is 
     inadvertent or is due to reasonable cause and not due to 
     willful neglect, or
       ``(B) such failure is of a type of failure which the 
     Secretary has identified for purposes of this paragraph as 
     being described in subparagraph (A).''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to distributions in taxable years beginning after 
     December 31, 2015.

     SEC. 316. LIMITATIONS ON DESIGNATION OF DIVIDENDS BY REITS.

       (a) In General.--Section 857 is amended by redesignating 
     subsection (g) as subsection (h) and by inserting after 
     subsection (f) the following new subsection:
       ``(g) Limitations on Designation of Dividends.--
       ``(1) Overall limitation.--The aggregate amount of 
     dividends designated by a real estate investment trust under 
     subsections (b)(3)(C) and (c)(2)(A) with respect to any 
     taxable year may not exceed the dividends paid by such trust 
     with respect to such year. For purposes of the preceding 
     sentence, dividends paid after the close of the taxable year 
     described in section 858 shall be treated as paid with 
     respect to such year.
       ``(2) Proportionality.--The Secretary may prescribe 
     regulations or other guidance requiring the proportionality 
     of the designation of particular types of dividends among 
     shares or beneficial interests of a real estate investment 
     trust.''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to distributions in taxable years beginning after 
     December 31, 2015.

     SEC. 317. DEBT INSTRUMENTS OF PUBLICLY OFFERED REITS AND 
                   MORTGAGES TREATED AS REAL ESTATE ASSETS.

       (a) Debt Instruments of Publicly Offered REITs Treated as 
     Real Estate Assets.--
       (1) In general.--Subparagraph (B) of section 856(c)(5) is 
     amended--
       (A) by striking ``and shares'' and inserting ``, shares'', 
     and
       (B) by inserting ``, and debt instruments issued by 
     publicly offered REITs'' before the period at the end of the 
     first sentence.
       (2) Income from nonqualified debt instruments of publicly 
     offered reits not qualified for purposes of satisfying the 75 
     percent gross income test.--Subparagraph (H) of section 
     856(c)(3) is amended by inserting ``(other than a 
     nonqualified publicly offered REIT debt instrument)'' after 
     ``real estate asset''.
       (3) 25 percent asset limitation on holding of nonqualified 
     debt instruments of publicly offered reits.--Subparagraph (B) 
     of section 856(c)(4) is amended by redesignating clause (iii) 
     as clause (iv) and by inserting after clause (ii) the 
     following new clause:
       ``(iii) not more than 25 percent of the value of its total 
     assets is represented by nonqualified publicly offered REIT 
     debt instruments, and''.
       (4) Definitions related to debt instruments of publicly 
     offered reits.--Paragraph (5) of section 856(c) is amended by 
     adding at the end the following new subparagraph:
       ``(L) Definitions related to debt instruments of publicly 
     offered reits.--
       ``(i) Publicly offered reit.--The term `publicly offered 
     REIT' has the meaning given such term by section 562(c)(2).
       ``(ii) Nonqualified publicly offered reit debt 
     instrument.--The term `nonqualified publicly offered REIT 
     debt instrument' means any real estate asset which would 
     cease to be a real estate asset if subparagraph (B) were 
     applied without regard to the reference to `debt instruments 
     issued by publicly offered REITs'.''.
       (b) Interests in Mortgages on Interests in Real Property 
     Treated as Real Estate Assets.--Subparagraph (B) of section 
     856(c)(5) is amended by inserting ``or on interests in real 
     property'' after ``interests in mortgages on real property''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 318. ASSET AND INCOME TEST CLARIFICATION REGARDING 
                   ANCILLARY PERSONAL PROPERTY.

       (a) In General.--Subsection (c) of section 856, as amended 
     by the preceding provisions of this Act, is amended by 
     redesignating paragraph (9) as paragraph (10) and by 
     inserting after paragraph (8) the following new paragraph:
       ``(9) Special rules for certain personal property which is 
     ancillary to real property.--
       ``(A) Certain personal property leased in connection with 
     real property.--Personal property shall be treated as a real 
     estate asset for purposes of paragraph (4)(A) to the extent 
     that rents attributable to such personal property are treated 
     as rents from real property under subsection (d)(1)(C).
       ``(B) Certain personal property mortgaged in connection 
     with real property.--In the case of an obligation secured by 
     a mortgage on both real property and personal property, if 
     the fair market value of such personal property does not 
     exceed 15 percent of the total fair market value of all such 
     property, such obligation shall be treated--
       ``(i) for purposes of paragraph (3)(B), as an obligation 
     described therein, and
       ``(ii) for purposes of paragraph (4)(A), as a real estate 
     asset.
     For purposes of the preceding sentence, the fair market value 
     of all such property shall be determined in the same manner 
     as the fair market value of real property is determined for 
     purposes of apportioning interest income between real 
     property and personal property under paragraph (3)(B).''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 319. HEDGING PROVISIONS.

       (a) Modification to Permit the Termination of a Hedging 
     Transaction Using an Additional Hedging Instrument.--
     Subparagraph (G) of section 856(c)(5) is amended by striking 
     ``and'' at the end of clause (i), by striking the period at 
     the end of clause (ii) and inserting ``, and'', and by adding 
     at the end the following new clause:
       ``(iii) if--

       ``(I) a real estate investment trust enters into one or 
     more positions described in clause (i) with respect to 
     indebtedness described in clause (i) or one or more positions 
     described in clause (ii) with respect to property which 
     generates income or gain described in paragraph (2) or (3),
       ``(II) any portion of such indebtedness is extinguished or 
     any portion of such property is disposed of, and
       ``(III) in connection with such extinguishment or 
     disposition, such trust enters into one or more transactions 
     which would be hedging transactions described in clause (ii) 
     or (iii) of section 1221(b)(2)(A) with respect to any 
     position referred to in subclause (I) if such position were 
     ordinary property,

     any income of such trust from any position referred to in 
     subclause (I) and from any transaction referred to in 
     subclause (III) (including gain from the termination of any 
     such position or transaction) shall not constitute gross 
     income under paragraphs (2) and (3) to the extent that such 
     transaction hedges such position.''.

[[Page 20370]]

       (b) Identification Requirements.--
       (1) In general.--Subparagraph (G) of section 856(c)(5), as 
     amended by subsection (a), 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) clauses (i), (ii), and (iii) shall not apply with 
     respect to any transaction unless such transaction satisfies 
     the identification requirement described in section 
     1221(a)(7) (determined after taking into account any curative 
     provisions provided under the regulations referred to 
     therein).''.
       (2) Conforming amendments.--Subparagraph (G) of section 
     856(c)(5) is amended--
       (A) by striking ``which is clearly identified pursuant to 
     section 1221(a)(7)'' in clause (i), and
       (B) by striking ``, but only if such transaction is clearly 
     identified as such before the close of the day on which it 
     was acquired, originated, or entered into (or such other time 
     as the Secretary may prescribe)'' in clause (ii).
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 320. MODIFICATION OF REIT EARNINGS AND PROFITS 
                   CALCULATION TO AVOID DUPLICATE TAXATION.

       (a) Earnings and Profits Not Increased by Amounts Allowed 
     in Computing Taxable Income in Prior Years.--Section 857(d) 
     is amended--
       (1) by amending paragraph (1) to read as follows:
       ``(1) In general.--The earnings and profits of a real 
     estate investment trust for any taxable year (but not its 
     accumulated earnings) shall not be reduced by any amount 
     which--
       ``(A) is not allowable in computing its taxable income for 
     such taxable year, and
       ``(B) was not allowable in computing its taxable income for 
     any prior taxable year.'', and
       (2) by adding at the end the following new paragraphs:
       ``(4) Real estate investment trust.--For purposes of this 
     subsection, the term `real estate investment trust' includes 
     a domestic corporation, trust, or association which is a real 
     estate investment trust determined without regard to the 
     requirements of subsection (a).
       ``(5) Special rules for determining earnings and profits 
     for purposes of the deduction for dividends paid.--For 
     special rules for determining the earnings and profits of a 
     real estate investment trust for purposes of the deduction 
     for dividends paid, see section 562(e)(1).''.
       (b) Exception for Purposes of Determining Dividends Paid 
     Deduction.--Section 562(e)(1), as amended by the preceding 
     provisions of this Act, is amended by striking ``deduction, 
     the earnings'' and all that follows and inserting the 
     following: ``deduction--
       ``(A) the earnings and profits of such trust for any 
     taxable year (but not its accumulated earnings) shall be 
     increased by the amount of gain (if any) on the sale or 
     exchange of real property which is taken into account in 
     determining the taxable income of such trust for such taxable 
     year (and not otherwise taken into account in determining 
     such earnings and profits), and
       ``(B) section 857(d)(1) shall be applied without regard to 
     subparagraph (B) thereof.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 321. TREATMENT OF CERTAIN SERVICES PROVIDED BY TAXABLE 
                   REIT SUBSIDIARIES.

       (a) Taxable REIT Subsidiaries Treated in Same Manner as 
     Independent Contractors for Certain Purposes.--
       (1) Marketing and development expenses under rental 
     property safe harbor.--Clause (v) of section 857(b)(6)(C) is 
     amended by inserting ``or a taxable REIT subsidiary'' before 
     the period at the end.
       (2) Marketing expenses under timber safe harbor.--Clause 
     (v) of section 857(b)(6)(D) is amended by striking ``, in the 
     case of a sale on or before the termination date,''.
       (3) Foreclosure property grace period.--Subparagraph (C) of 
     section 856(e)(4) is amended by inserting ``or through a 
     taxable REIT subsidiary'' after ``receive any income''.
       (b) Tax on Redetermined TRS Service Income.--
       (1) In general.--Subparagraph (A) of section 857(b)(7) is 
     amended by striking ``and excess interest'' and inserting 
     ``excess interest, and redetermined TRS service income''.
       (2) Redetermined trs service income.--Paragraph (7) of 
     section 857(b) is amended by redesignating subparagraphs (E) 
     and (F) as subparagraphs (F) and (G), respectively, and 
     inserting after subparagraph (D) the following new 
     subparagraph:
       ``(E) Redetermined trs service income.--
       ``(i) In general.--The term `redetermined TRS service 
     income' means gross income of a taxable REIT subsidiary of a 
     real estate investment trust attributable to services 
     provided to, or on behalf of, such trust (less deductions 
     properly allocable thereto) to the extent the amount of such 
     income (less such deductions) would (but for subparagraph 
     (F)) be increased on distribution, apportionment, or 
     allocation under section 482.
       ``(ii) Coordination with redetermined rents.--Clause (i) 
     shall not apply with respect to gross income attributable to 
     services furnished or rendered to a tenant of the real estate 
     investment trust (or to deductions properly allocable 
     thereto).''.
       (3) Conforming amendments.--Subparagraphs (B)(i) and (C) of 
     section 857(b)(7) are each amended by striking ``subparagraph 
     (E)'' and inserting ``subparagraph (F)''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 322. EXCEPTION FROM FIRPTA FOR CERTAIN STOCK OF REITS.

       (a) Modifications of Ownership Rules.--
       (1) In general.--Section 897 is amended by adding at the 
     end the following new subsection:
       ``(k) Special Rules Relating to Real Estate Investment 
     Trusts.--
       ``(1) Increase in percentage ownership for exceptions for 
     persons holding publicly traded stock.--
       ``(A) Dispositions.--In the case of any disposition of 
     stock in a real estate investment trust, paragraphs (3) and 
     (6)(C) of subsection (c) shall each be applied by 
     substituting `more than 10 percent' for `more than 5 
     percent'.
       ``(B) Distributions.--In the case of any distribution from 
     a real estate investment trust, subsection (h)(1) shall be 
     applied by substituting `10 percent' for `5 percent'.
       ``(2) Stock held by qualified shareholders not treated as 
     usrpi.--
       ``(A) In general.--Except as provided in subparagraph (B)--
       ``(i) stock of a real estate investment trust which is held 
     directly (or indirectly through 1 or more partnerships) by a 
     qualified shareholder shall not be treated as a United States 
     real property interest, and
       ``(ii) notwithstanding subsection (h)(1), any distribution 
     to a qualified shareholder shall not be treated as gain 
     recognized from the sale or exchange of a United States real 
     property interest to the extent the stock of the real estate 
     investment trust held by such qualified shareholder is not 
     treated as a United States real property interest under 
     clause (i).
       ``(B) Exception.--In the case of a qualified shareholder 
     with 1 or more applicable investors--
       ``(i) subparagraph (A)(i) shall not apply to so much of the 
     stock of a real estate investment trust held by a qualified 
     shareholder as bears the same ratio to the value of the 
     interests (other than interests held solely as a creditor) 
     held by such applicable investors in the qualified 
     shareholder bears to value of all interests (other than 
     interests held solely as a creditor) in the qualified 
     shareholder, and
       ``(ii) a percentage equal to the ratio determined under 
     clause (i) of the amounts realized by the qualified 
     shareholder with respect to any disposition of stock in the 
     real estate investment trust or with respect to any 
     distribution from the real estate investment trust 
     attributable to gain from sales or exchanges of a United 
     States real property interest shall be treated as amounts 
     realized from the disposition of United States real property 
     interests.
       ``(C) Special rule for certain distributions treated as 
     sale or exchange.--If a distribution by a real estate 
     investment trust is treated as a sale or exchange of stock 
     under section 301(c)(3), 302, or 331 with respect to a 
     qualified shareholder--
       ``(i) in the case of an applicable investor, subparagraph 
     (B) shall apply with respect to such distribution, and
       ``(ii) in the case of any other person, such distribution 
     shall be treated under section 857(b)(3)(F) as a dividend 
     from a real estate investment trust notwithstanding any other 
     provision of this title.
       ``(D) Applicable investor.--For purposes of this paragraph, 
     the term `applicable investor' means, with respect to any 
     qualified shareholder holding stock in a real estate 
     investment trust, a person (other than a qualified 
     shareholder) which--
       ``(i) holds an interest (other than an interest solely as a 
     creditor) in such qualified shareholder, and
       ``(ii) holds more than 10 percent of the stock of such real 
     estate investment trust (whether or not by reason of the 
     person's ownership interest in the qualified shareholder).
       ``(E) Constructive ownership rules.--For purposes of 
     subparagraphs (B)(i) and (C) and paragraph (4), the 
     constructive ownership rules under subsection (c)(6)(C) shall 
     apply.
       ``(3) Qualified shareholder.--For purposes of this 
     subsection--
       ``(A) In general.--The term `qualified shareholder' means a 
     foreign person which--
       ``(i)(I) is eligible for benefits of a comprehensive income 
     tax treaty with the United States which includes an exchange 
     of information program and the principal class of interests 
     of which is listed and regularly traded on 1 or more 
     recognized stock exchanges (as defined in such comprehensive 
     income tax treaty), or
       ``(II) is a foreign partnership that is created or 
     organized under foreign law as a limited partnership in a 
     jurisdiction that has an agreement for the exchange of 
     information with respect to taxes with the United States

[[Page 20371]]

     and has a class of limited partnership units which is 
     regularly traded on the New York Stock Exchange or Nasdaq 
     Stock Market and such class of limited partnership units 
     value is greater than 50 percent of the value of all the 
     partnership units,
       ``(ii) is a qualified collective investment vehicle, and
       ``(iii) maintains records on the identity of each person 
     who, at any time during the foreign person's taxable year, 
     holds directly 5 percent or more of the class of interest 
     described in subclause (I) or (II) of clause (i), as the case 
     may be.
       ``(B) Qualified collective investment vehicle.--For 
     purposes of this subsection, the term `qualified collective 
     investment vehicle' means a foreign person--
       ``(i) which, under the comprehensive income tax treaty 
     described in subparagraph (A)(i), is eligible for a reduced 
     rate of withholding with respect to ordinary dividends paid 
     by a real estate investment trust even if such person holds 
     more than 10 percent of the stock of such real estate 
     investment trust,
       ``(ii) which--

       ``(I) is a publicly traded partnership (as defined in 
     section 7704(b)) to which subsection (a) of section 7704 does 
     not apply,
       ``(II) is a withholding foreign partnership for purposes of 
     chapters 3, 4, and 61,
       ``(III) if such foreign partnership were a United States 
     corporation, would be a United States real property holding 
     corporation (determined without regard to paragraph (1)) at 
     any time during the 5-year period ending on the date of 
     disposition of, or distribution with respect to, such 
     partnership's interests in a real estate investment trust, or

       ``(iii) which is designated as a qualified collective 
     investment vehicle by the Secretary and is either--

       ``(I) fiscally transparent within the meaning of section 
     894, or
       ``(II) required to include dividends in its gross income, 
     but entitled to a deduction for distributions to persons 
     holding interests (other than interests solely as a creditor) 
     in such foreign person.

       ``(4) Partnership allocations.--
       ``(A) In general.--For the purposes of this subsection, in 
     the case of an applicable investor who is a nonresident alien 
     individual or a foreign corporation and is a partner in a 
     partnership that is a qualified shareholder, if such 
     partner's proportionate share of USRPI gain for the taxable 
     year exceeds such partner's distributive share of USRPI gain 
     for the taxable year, then
       ``(i) such partner's distributive share of the amount of 
     gain taken into account under subsection (a)(1) by the 
     partner for the taxable year (determined without regard to 
     this paragraph) shall be increased by the amount of such 
     excess, and
       ``(ii) such partner's distributive share of items of income 
     or gain for the taxable year that are not treated as gain 
     taken into account under subsection (a)(1) (determined 
     without regard to this paragraph) shall be decreased (but not 
     below zero) by the amount of such excess.
       ``(B) USRPI gain.--For the purposes of this paragraph, the 
     term `USRPI gain' means the excess (if any) of--
       ``(i) the sum of--

       ``(I) any gain recognized from the disposition of a United 
     States real property interest, and
       ``(II) any distribution by a real estate investment trust 
     that is treated as gain recognized from the sale or exchange 
     of a United States real property interest, over

       ``(ii) any loss recognized from the disposition of a United 
     States real property interest.
       ``(C) Proportionate share of usrpi gain.--For purposes of 
     this paragraph, an applicable investor's proportionate share 
     of USRPI gain shall be determined on the basis of such 
     investor's share of partnership items of income or gain 
     (excluding gain allocated under section 704(c)), whichever 
     results in the largest proportionate share. If the investor's 
     share of partnership items of income or gain (excluding gain 
     allocated under section 704(c)) may vary during the period 
     such investor is a partner in the partnership, such share 
     shall be the highest share such investor may receive.''.
       (2) Conforming amendments.--
       (A) Section 897(c)(1)(A) is amended by inserting ``or 
     subsection (k)'' after ``subparagraph (B)'' in the matter 
     preceding clause (i).
       (B) Section 857(b)(3)(F) is amended by inserting ``or 
     subparagraph (A)(ii) or (C) of section 897(k)(2)'' after 
     ``897(h)(1)''.
       (b) Determination of Domestic Control.--
       (1) Special ownership rules.--
       (A) In general.--Section 897(h)(4) is amended by adding at 
     the end the following new subparagraph:
       ``(E) Special ownership rules.--For purposes of determining 
     the holder of stock under subparagraphs (B) and (C)--
       ``(i) in the case of any class of stock of the qualified 
     investment entity which is regularly traded on an established 
     securities market in the United States, a person holding less 
     than 5 percent of such class of stock at all times during the 
     testing period shall be treated as a United States person 
     unless the qualified investment entity has actual knowledge 
     that such person is not a United States person,
       ``(ii) any stock in the qualified investment entity held by 
     another qualified investment entity--

       ``(I) any class of stock of which is regularly traded on an 
     established securities market, or
       ``(II) which is a regulated investment company which issues 
     redeemable securities (within the meaning of section 2 of the 
     Investment Company Act of 1940),

     shall be treated as held by a foreign person, except that if 
     such other qualified investment entity is domestically 
     controlled (determined after application of this 
     subparagraph), such stock shall be treated as held by a 
     United States person, and
       ``(iii) any stock in the qualified investment entity held 
     by any other qualified investment entity not described in 
     subclause (I) or (II) of clause (ii) shall only be treated as 
     held by a United States person in proportion to the stock of 
     such other qualified investment entity which is (or is 
     treated under clause (ii) or (iii) as) held by a United 
     States person.''.
       (B) Conforming amendment.--The heading for paragraph (4) of 
     section 897(h) is amended by inserting ``and special rules'' 
     after ``Definitions''.
       (2) Technical amendment.--Clause (ii) of section 
     897(h)(4)(A) is amended by inserting ``and for purposes of 
     determining whether a real estate investment trust is a 
     domestically controlled qualified investment entity under 
     this subsection'' after ``real estate investment trust''.
       (c) Effective Dates.--
       (1) In general.--The amendments made by subsection (a) 
     shall take effect on the date of enactment and shall apply 
     to--
       (A) any disposition on and after the date of the enactment 
     of this Act, and
       (B) any distribution by a real estate investment trust on 
     or after the date of the enactment of this Act which is 
     treated as a deduction for a taxable year of such trust 
     ending after such date.
       (2) Determination of domestic control.--The amendments made 
     by subsection (b)(1) shall take effect on the date of the 
     enactment of this Act.
       (3) Technical amendment.--The amendment made by subsection 
     (b)(2) shall take effect on January 1, 2015.

     SEC. 323. EXCEPTION FOR INTERESTS HELD BY FOREIGN RETIREMENT 
                   OR PENSION FUNDS.

       (a) In General.--Section 897, as amended by the preceding 
     provisions of this Act, is amended by adding at the end the 
     following new subsection:
       ``(l) Exception for Interests Held by Foreign Pension 
     Funds.--
       ``(1) In general.--This section shall not apply to any 
     United States real property interest held directly (or 
     indirectly through 1 or more partnerships) by, or to any 
     distribution received from a real estate investment trust 
     by--
       ``(A) a qualified foreign pension fund, or
       ``(B) any entity all of the interests of which are held by 
     a qualified foreign pension fund.
       ``(2) Qualified foreign pension fund.--For purposes of this 
     subsection, the term `qualified foreign pension fund' means 
     any trust, corporation, or other organization or 
     arrangement--
       ``(A) which is created or organized under the law of a 
     country other than the United States,
       ``(B) which is established to provide retirement or pension 
     benefits to participants or beneficiaries that are current or 
     former employees (or persons designated by such employees) of 
     one or more employers in consideration for services rendered,
       ``(C) which does not have a single participant or 
     beneficiary with a right to more than five percent of its 
     assets or income,
       ``(D) which is subject to government regulation and 
     provides annual information reporting about its beneficiaries 
     to the relevant tax authorities in the country in which it is 
     established or operates, and
       ``(E) with respect to which, under the laws of the country 
     in which it is established or operates--
       ``(i) contributions to such trust, corporation, 
     organization, or arrangement which would otherwise be subject 
     to tax under such laws are deductible or excluded from the 
     gross income of such entity or taxed at a reduced rate, or
       ``(ii) taxation of any investment income of such trust, 
     corporation, organization or arrangement is deferred or such 
     income is taxed at a reduced rate.
       ``(3) Regulations.--The Secretary shall prescribe such 
     regulations as may be necessary or appropriate to carry out 
     the purposes of this subsection.''.
       (b) Exemption From Withholding.--Section 1445(f)(3) is 
     amended by striking ``any person'' and all that follows and 
     inserting the following: ``any person other than--
       ``(A) a United States person, and
       ``(B) except as otherwise provided by the Secretary, an 
     entity with respect to which section 897 does not apply by 
     reason of subsection (l) thereof.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to dispositions and distributions after the date 
     of the enactment of this Act.

[[Page 20372]]



     SEC. 324. INCREASE IN RATE OF WITHHOLDING OF TAX ON 
                   DISPOSITIONS OF UNITED STATES REAL PROPERTY 
                   INTERESTS.

       (a) In General.--Subsections (a), (e)(3), (e)(4), and 
     (e)(5) of section 1445 are each amended by striking ``10 
     percent'' and inserting ``15 percent''.
       (b) Exception for Certain Residences.--Section 1445(c) is 
     amended by adding at the end the following new paragraph:
       ``(4) Reduced rate of withholding for residence where 
     amount realized does not exceed $1,000,000.--In the case of a 
     disposition--
       ``(A) of property which is acquired by the transferee for 
     use by the transferee as a residence,
       ``(B) with respect to which the amount realized for such 
     property does not exceed $1,000,000, and
       ``(C) to which subsection (b)(5) does not apply,
     subsection (a) shall be applied by substituting `10 percent' 
     for `15 percent'.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to dispositions after the date which is 60 days 
     after the date of the enactment of this Act.

     SEC. 325. INTERESTS IN RICS AND REITS NOT EXCLUDED FROM 
                   DEFINITION OF UNITED STATES REAL PROPERTY 
                   INTERESTS.

       (a) In General.--Section 897(c)(1)(B) is amended by 
     striking ``and'' at the end of clause (i), by striking the 
     period at the end of clause (ii)(II) and inserting ``, and'', 
     and by adding at the end the following new clause:
       ``(iii) neither such corporation nor any predecessor of 
     such corporation was a regulated investment company or a real 
     estate investment trust at any time during the shorter of the 
     periods described in subparagraph (A)(ii).''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to dispositions on or after the date of the 
     enactment of this Act.

     SEC. 326. DIVIDENDS DERIVED FROM RICS AND REITS INELIGIBLE 
                   FOR DEDUCTION FOR UNITED STATES SOURCE PORTION 
                   OF DIVIDENDS FROM CERTAIN FOREIGN CORPORATIONS.

       (a) In General.--Section 245(a) is amended by adding at the 
     end the following new paragraph:
       ``(12) Dividends derived from rics and reits ineligible for 
     deduction.--Regulated investment companies and real estate 
     investment trusts shall not be treated as domestic 
     corporations for purposes of paragraph (5)(B).''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to dividends received from regulated investment 
     companies and real estate investment trusts on or after the 
     date of the enactment of this Act.
       (c) No Inference.--Nothing contained in this section or the 
     amendments made by this section shall be construed to create 
     any inference with respect to the proper treatment under 
     section 245 of the Internal Revenue Code of 1986 of dividends 
     received from regulated investment companies or real estate 
     investment trusts before the date of the enactment of this 
     Act.

                   Subtitle C--Additional Provisions

     SEC. 331. DEDUCTIBILITY OF CHARITABLE CONTRIBUTIONS TO 
                   AGRICULTURAL RESEARCH ORGANIZATIONS.

       (a) In General.--Subparagraph (A) of section 170(b)(1) is 
     amended by striking ``or'' at the end of clause (vii), by 
     striking the comma at the end of clause (viii) and inserting 
     ``, or'', and by inserting after clause (viii) the following 
     new clause:
       ``(ix) an agricultural research organization directly 
     engaged in the continuous active conduct of agricultural 
     research (as defined in section 1404 of the Agricultural 
     Research, Extension, and Teaching Policy Act of 1977) in 
     conjunction with a land-grant college or university (as 
     defined in such section) or a non-land grant college of 
     agriculture (as defined in such section), and during the 
     calendar year in which the contribution is made such 
     organization is committed to spend such contribution for such 
     research before January 1 of the fifth calendar year which 
     begins after the date such contribution is made,''.
       (b) Expenditures To Influence Legislation.--Paragraph (4) 
     of section 501(h) is amended by redesignating subparagraphs 
     (E) and (F) as subparagraphs (F) and (G), respectively, and 
     by inserting after subparagraph (D) the following new 
     subparagraph:
       ``(E) section 170(b)(1)(A)(ix) (relating to agricultural 
     research organizations),''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to contributions made on and after the date of 
     the enactment of this Act.

     SEC. 332. REMOVAL OF BOND REQUIREMENTS AND EXTENDING FILING 
                   PERIODS FOR CERTAIN TAXPAYERS WITH LIMITED 
                   EXCISE TAX LIABILITY.

       (a) Filing Requirements.--Paragraph (4) of section 5061(d) 
     of the Internal Revenue Code of 1986 is amended--
       (1) in subparagraph (A)--
       (A) by striking ``In the case of'' and inserting the 
     following:
       ``(i) More than $1,000 and not more than $50,000 in 
     taxes.--Except as provided in clause (ii), in the case of'',
       (B) by striking ``under bond for deferred payment'', and
       (C) by adding at the end the following new clause:
       ``(ii) Not more than $1,000 in taxes.--In the case of any 
     taxpayer who reasonably expects to be liable for not more 
     than $1,000 in taxes imposed with respect to distilled 
     spirits, wines, and beer under subparts A, C, and D and 
     section 7652 for the calendar year and who was liable for not 
     more than $1,000 in such taxes in the preceding calendar 
     year, the last day for the payment of tax on withdrawals, 
     removals, and entries (and articles brought into the United 
     States from Puerto Rico) shall be the 14th day after the last 
     day of the calendar year.'', and
       (2) in subparagraph (B)--
       (A) by striking ``Subparagraph (A)'' and inserting the 
     following:
       ``(i) Exceeds $50,000 limit.--Subparagraph (A)(i)'', and
       (B) by adding at the end the following new clause:
       ``(ii) Exceeds $1,000 limit.--Subparagraph (A)(ii) shall 
     not apply to any taxpayer for any portion of the calendar 
     year following the first date on which the aggregate amount 
     of tax due under subparts A, C, and D and section 7652 from 
     such taxpayer during such calendar year exceeds $1,000, and 
     any tax under such subparts which has not been paid on such 
     date shall be due on the 14th day after the last day of the 
     calendar quarter in which such date occurs.''.
       (b) Bond Requirements.--
       (1) In general.--Section 5551 of such Code is amended--
       (A) in subsection (a), by striking ``No individual'' and 
     inserting ``Except as provided under subsection (d), no 
     individual'', and
       (B) by adding at the end the following new subsection:
       ``(d) Removal of Bond Requirements.--
       ``(1) In general.--During any period to which subparagraph 
     (A) of section 5061(d)(4) applies to a taxpayer (determined 
     after application of subparagraph (B) thereof), such taxpayer 
     shall not be required to furnish any bond covering operations 
     or withdrawals of distilled spirits or wines for 
     nonindustrial use or of beer.
       ``(2) Satisfaction of bond requirements.--Any taxpayer for 
     any period described in paragraph (1) shall be treated as if 
     sufficient bond has been furnished for purposes of covering 
     operations and withdrawals of distilled spirits or wines for 
     nonindustrial use or of beer for purposes of any requirements 
     relating to bonds under this chapter.''.
       (2) Conforming amendments.--
       (A) Bonds for distilled spirits plants.--Section 5173(a) of 
     such Code is amended--
       (i) in paragraph (1), by striking ``No person'' and 
     inserting ``Except as provided under section 5551(d), no 
     person'', and
       (ii) in paragraph (2), by striking ``No distilled spirits'' 
     and inserting ``Except as provided under section 5551(d), no 
     distilled spirits''.
       (B) Bonded wine cellars.--Section 5351 of such Code is 
     amended--
       (i) by striking ``Any person'' and inserting the following:
       ``(a) In General.--Any person'',
       (ii) by inserting ``, except as provided under section 
     5551(d),'' before ``file bond'',
       (iii) by striking ``Such premises shall'' and all that 
     follows through the period, and
       (iv) by adding at the end the following new subsection:
       ``(b) Definitions.--For purposes of this chapter--
       ``(1) Bonded wine cellar.--The term `bonded wine cellar' 
     means any premises described in subsection (a), including any 
     such premises established by a taxpayer described in section 
     5551(d).
       ``(2) Bonded winery.--At the discretion of the Secretary, 
     any bonded wine cellar that engages in production operations 
     may be designated as a `bonded winery'.''.
       (C) Bonds for breweries.--Section 5401 of such Code is 
     amended by adding at the end the following new subsection:
       ``(c) Exception From Bond Requirements for Certain 
     Breweries.--Subsection (b) shall not apply to any taxpayer 
     for any period described in section 5551(d).''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to any calendar quarters beginning more than 1 
     year after the date of the enactment of this Act.

     SEC. 333. MODIFICATIONS TO ALTERNATIVE TAX FOR CERTAIN SMALL 
                   INSURANCE COMPANIES.

       (a) Additional Requirement for Companies to Which 
     Alternative Tax Applies.--
       (1) Added requirement.--
       (A) In general.--Subparagraph (A) of section 831(b)(2) is 
     amended--
       (i) by striking ``(including interinsurers and reciprocal 
     underwriters)'', and
       (ii) by striking ``and'' at the end of clause (i), by 
     redesignating clause (ii) as clause (iii), and by inserting 
     after clause (i) the following new clause:
       ``(ii) such company meets the diversification requirements 
     of subparagraph (B), and''.
       (B) Diversification requirement.--Paragraph (2) of section 
     831(b) is amended by redesignating subparagraphs (B) as 
     subparagraph (C) and by inserting after subparagraph (A) the 
     following new subparagraph:
       ``(B) Diversification requirements.--
       ``(i) In general.--An insurance company meets the 
     requirements of this subparagraph if--

[[Page 20373]]

       ``(I) no more than 20 percent of the net written premiums 
     (or, if greater, direct written premiums) of such company for 
     the taxable year is attributable to any one policyholder, or
       ``(II) such insurance company does not meet the requirement 
     of subclause (I) and no person who holds (directly or 
     indirectly) an interest in such insurance company is a 
     specified holder who holds (directly or indirectly) aggregate 
     interests in such insurance company which constitute a 
     percentage of the entire interests in such insurance company 
     which is more than a de minimis percentage higher than the 
     percentage of interests in the specified assets with respect 
     to such insurance company held (directly or indirectly) by 
     such specified holder.

       ``(ii) Definitions.--For purposes of clause (i)(II)--

       ``(I) Specified holder.--The term `specified holder' means, 
     with respect to any insurance company, any individual who 
     holds (directly or indirectly) an interest in such insurance 
     company and who is a spouse or lineal descendant (including 
     by adoption) of an individual who holds an interest (directly 
     or indirectly) in the specified assets with respect to such 
     insurance company.
       ``(II) Specified assets.--The term `specified assets' 
     means, with respect to any insurance company, the trades or 
     businesses, rights, or assets with respect to which the net 
     written premiums (or direct written premiums) of such 
     insurance company are paid.
       ``(III) Indirect interest.--An indirect interest includes 
     any interest held through a trust, estate, partnership, or 
     corporation.
       ``(IV) De minimis.--Except as otherwise provided by the 
     Secretary in regulations or other guidance, 2 percentage 
     points or less shall be treated as de minimis.''.

       (C) Conforming amendments.--The second sentence section 
     831(b)(2)(A) is amended--
       (i) by striking ``clause (ii)'' and inserting ``clause 
     (iii)'', and
       (ii) by striking ``clause (i)'' and inserting ``clauses (i) 
     and (ii)''.
       (2) Treatment of related policyholders.--Clause (i) of 
     section 831(b)(2)(C), as redesignated by paragraph (1)(B), is 
     amended--
       (A) by striking ``For purposes of subparagraph (A), in 
     determining'' and inserting ``For purposes of this 
     paragraph--

       ``(I) in determining'',

       (B) by striking the period at the end and inserting ``, 
     and'', and
       (C) by adding at the end the following new subclause:

       ``(II) in determining the attribution of premiums to any 
     policyholder under subparagraph (B)(i), all policyholders 
     which are related (within the meaning of section 267(b) or 
     707(b)) or are members of the same controlled group shall be 
     treated as one policyholder.''.

       (3) Reporting.--Section 831 is amended by redesignating 
     subsection (d) as subsection (e) and by inserting after 
     subsection (c) the following new subsection:
       ``(d) Reporting.--Every insurance company for which an 
     election is in effect under subsection (b) for any taxable 
     year shall furnish to the Secretary at such time and in such 
     manner as the Secretary shall prescribe such information for 
     such taxable year as the Secretary shall require with respect 
     to the requirements of subsection (b)(2)(A)(ii).''.
       (b) Increase in Limitation on Premiums.--
       (1) In general.--Clause (i) of section 831(b)(2)(A) is 
     amended by striking ``$1,200,000'' and inserting 
     ``$2,200,000''.
       (2) Inflation adjustment.--Paragraph (2) of section 831(b), 
     as amended by subsection (a)(1)(B), is amended by adding at 
     the end the following new subparagraph:
       ``(D) Inflation adjustment.--In the case of any taxable 
     year beginning in a calendar year after 2015, the dollar 
     amount set forth in subparagraph (A)(i) shall 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 such calendar year by substituting 
     `calendar year 2013' for `calendar year 1992' in subparagraph 
     (B) thereof.
     If the amount as adjusted under the preceding sentence is not 
     a multiple of $50,000, such amount shall be rounded to the 
     next lowest multiple of $50,000.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2016.

     SEC. 334. TREATMENT OF TIMBER GAINS.

       (a) In General.--Section 1201(b) is amended to read as 
     follows:
       ``(b) Special Rate for Qualified Timber Gains.--
       ``(1) In general.--If, for any taxable year beginning in 
     2016, a corporation has both a net capital gain and qualified 
     timber gain--
       ``(A) subsection (a) shall apply to such corporation for 
     the taxable year without regard to whether the applicable tax 
     rate exceeds 35 percent, and
       ``(B) the tax computed under subsection (a)(2) shall be 
     equal to the sum of--
       ``(i) 23.8 percent of the least of--

       ``(I) qualified timber gain,
       ``(II) net capital gain, or
       ``(III) taxable income, plus

       ``(ii) 35 percent of the excess (if any) of taxable income 
     over the sum of the amounts for which a tax was determined 
     under subsection (a)(1) and clause (i).
       ``(2) Qualified timber gain.--For purposes of this section, 
     the term `qualified timber gain' means, with respect to any 
     taxpayer for any taxable year, the excess (if any) of--
       ``(A) the sum of the taxpayer's gains described in 
     subsections (a) and (b) of section 631 for such year, over
       ``(B) the sum of the taxpayer's losses described in such 
     subsections for such year.
     For purposes of subparagraphs (A) and (B), only timber held 
     more than 15 years shall be taken into account.''.
       (b) Conforming Amendment.--Section 55(b) is amended by 
     striking paragraph (4).
       (c) Effective Date.--The amendments made by this section 
     shall apply to taxable years beginning after December 31, 
     2015.

     SEC. 335. MODIFICATION OF DEFINITION OF HARD CIDER.

       (a) In General.--Section 5041 of the Internal Revenue Code 
     of 1986 is amended--
       (1) in paragraph (6) of subsection (b), by striking ``which 
     is a still wine'' and all that follows through ``alcohol by 
     volume'', and
       (2) by adding at the end the following new subsection:
       ``(g) Hard Cider.--For purposes of subsection (b)(6), the 
     term `hard cider' means a wine--
       ``(1) containing not more than 0.64 gram of carbon dioxide 
     per hundred milliliters of wine, except that the Secretary 
     may by regulations prescribe such tolerances to this 
     limitation as may be reasonably necessary in good commercial 
     practice,
       ``(2) which is derived primarily--
       ``(A) from apples or pears, or
       ``(B) from--
       ``(i) apple juice concentrate or pear juice concentrate, 
     and
       ``(ii) water,
       ``(3) which contains no fruit product or fruit flavoring 
     other than apple or pear, and
       ``(4) which contains at least one-half of 1 percent and 
     less than 8.5 percent alcohol by volume.''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to hard cider removed during calendar years 
     beginning after December 31, 2016.

     SEC. 336. CHURCH PLAN CLARIFICATION.

       (a) Application of Controlled Group Rules to Church 
     Plans.--
       (1) In general.--Section 414(c) is amended--
       (A) by striking ``For purposes'' and inserting the 
     following:
       ``(1) In general.--Except as provided in paragraph (2), for 
     purposes'', and
       (B) by adding at the end the following new paragraph:
       ``(2) Special rules relating to church plans.--
       ``(A) General rule.--Except as provided in subparagraphs 
     (B) and (C), for purposes of this subsection and subsection 
     (m), an organization that is otherwise eligible to 
     participate in a church plan shall not be aggregated with 
     another such organization and treated as a single employer 
     with such other organization for a plan year beginning in a 
     taxable year unless--
       ``(i) one such organization provides (directly or 
     indirectly) at least 80 percent of the operating funds for 
     the other organization during the preceding taxable year of 
     the recipient organization, and
       ``(ii) there is a degree of common management or 
     supervision between the organizations such that the 
     organization providing the operating funds is directly 
     involved in the day-to-day operations of the other 
     organization.
       ``(B) Nonqualified church-controlled organizations.--
     Notwithstanding subparagraph (A), for purposes of this 
     subsection and subsection (m), an organization that is a 
     nonqualified church-controlled organization shall be 
     aggregated with 1 or more other nonqualified church-
     controlled organizations, or with an organization that is not 
     exempt from tax under section 501, and treated as a single 
     employer with such other organization, if at least 80 percent 
     of the directors or trustees of such other organization are 
     either representatives of, or directly or indirectly 
     controlled by, such nonqualified church-controlled 
     organization. For purposes of this subparagraph, the term 
     `nonqualified church-controlled organization' means a church-
     controlled tax-exempt organization described in section 
     501(c)(3) that is not a qualified church-controlled 
     organization (as defined in section 3121(w)(3)(B)).
       ``(C) Permissive aggregation among church-related 
     organizations.--The church or convention or association of 
     churches with which an organization described in subparagraph 
     (A) is associated (within the meaning of subsection 
     (e)(3)(D)), or an organization designated by such church or 
     convention or association of churches, may elect to treat 
     such organizations as a single employer for a plan year. Such 
     election, once made, shall apply to all succeeding plan years 
     unless revoked with notice provided to the Secretary in such 
     manner as the Secretary shall prescribe.
       ``(D) Permissive disaggregation of church-related 
     organizations.--For purposes of subparagraph (A), in the case 
     of a church plan, an employer may elect to treat churches (as 
     defined in section 403(b)(12)(B)) separately from entities 
     that are not churches (as so defined), without regard to 
     whether such entities maintain separate church plans. Such 
     election, once made, shall apply

[[Page 20374]]

     to all succeeding plan years unless revoked with notice 
     provided to the Secretary in such manner as the Secretary 
     shall prescribe.''.
       (2) Clarification relating to application of anti-abuse 
     rule.--The rule of 26 CFR 1.414(c)-5(f) shall continue to 
     apply to each paragraph of section 414(c) of the Internal 
     Revenue Code of 1986, as amended by paragraph (1).
       (3) Effective date.--The amendments made by paragraph (1) 
     shall apply to years beginning before, on, or after the date 
     of the enactment of this Act.
       (b) Application of Contribution and Funding Limitations to 
     403(b) Grandfathered Defined Benefit Plans.--
       (1) In general.--Section 251(e)(5) of the Tax Equity and 
     Fiscal Responsibility Act of 1982 (Public Law 97-248), is 
     amended--
       (A) by striking ``403(b)(2)'' and inserting ``403(b)'', and
       (B) by inserting before the period at the end the 
     following: ``, and shall be subject to the applicable 
     limitations of section 415(b) of such Code as if it were a 
     defined benefit plan under section 401(a) of such Code (and 
     not to the limitations of section 415(c) of such Code).''.
       (2) Effective date.--The amendments made by this subsection 
     shall apply to years beginning before, on, or after the date 
     of the enactment of this Act.
       (c) Automatic Enrollment by Church Plans.--
       (1) In general.--This subsection shall supersede any law of 
     a State that relates to wage, salary, or payroll payment, 
     collection, deduction, garnishment, assignment, or 
     withholding which would directly or indirectly prohibit or 
     restrict the inclusion in any church plan (as defined in 
     section 414(e) of the Internal Revenue Code of 1986) of an 
     automatic contribution arrangement.
       (2) Definition of automatic contribution arrangement.--For 
     purposes of this subsection, the term ``automatic 
     contribution arrangement'' means an arrangement--
       (A) under which a participant may elect to have the plan 
     sponsor or the employer make payments as contributions under 
     the plan on behalf of the participant, or to the participant 
     directly in cash,
       (B) under which a participant is treated as having elected 
     to have the plan sponsor or the employer make such 
     contributions in an amount equal to a uniform percentage of 
     compensation provided under the plan until the participant 
     specifically elects not to have such contributions made (or 
     specifically elects to have such contributions made at a 
     different percentage), and
       (C) under which the notice and election requirements of 
     paragraph (3), and the investment requirements of paragraph 
     (4), are satisfied.
       (3) Notice requirements.--
       (A) In general.--The plan sponsor of, or plan administrator 
     or employer maintaining, an automatic contribution 
     arrangement shall, within a reasonable period before the 
     first day of each plan year, provide to each participant to 
     whom the arrangement applies for such plan year notice of the 
     participant's rights and obligations under the arrangement 
     which--
       (i) is sufficiently accurate and comprehensive to apprise 
     the participant of such rights and obligations, and
       (ii) is written in a manner calculated to be understood by 
     the average participant to whom the arrangement applies.
       (B) Election requirements.--A notice shall not be treated 
     as meeting the requirements of subparagraph (A) with respect 
     to a participant unless--
       (i) the notice includes an explanation of the participant's 
     right under the arrangement not to have elective 
     contributions made on the participant's behalf (or to elect 
     to have such contributions made at a different percentage),
       (ii) the participant has a reasonable period of time, after 
     receipt of the explanation described in clause (i) and before 
     the first elective contribution is made, to make such 
     election, and
       (iii) the notice explains how contributions made under the 
     arrangement will be invested in the absence of any investment 
     election by the participant.
       (4) Default investment.--If no affirmative investment 
     election has been made with respect to any automatic 
     contribution arrangement, contributions to such arrangement 
     shall be invested in a default investment selected with the 
     care, skill, prudence, and diligence that a prudent person 
     selecting an investment option would use.
       (5) Effective date.--This subsection shall take effect on 
     the date of the enactment of this Act.
       (d) Allow Certain Plan Transfers and Mergers.--
       (1) In general.--Section 414 is amended by adding at the 
     end the following new subsection:
       ``(z) Certain Plan Transfers and Mergers.--
       ``(1) In general.--Under rules prescribed by the Secretary, 
     except as provided in paragraph (2), no amount shall be 
     includible in gross income by reason of--
       ``(A) a transfer of all or a portion of the accrued benefit 
     of a participant or beneficiary, whether or not vested, from 
     a church plan that is a plan described in section 401(a) or 
     an annuity contract described in section 403(b) to an annuity 
     contract described in section 403(b), if such plan and 
     annuity contract are both maintained by the same church or 
     convention or association of churches,
       ``(B) a transfer of all or a portion of the accrued benefit 
     of a participant or beneficiary, whether or not vested, from 
     an annuity contract described in section 403(b) to a church 
     plan that is a plan described in section 401(a), if such plan 
     and annuity contract are both maintained by the same church 
     or convention or association of churches, or
       ``(C) a merger of a church plan that is a plan described in 
     section 401(a), or an annuity contract described in section 
     403(b), with an annuity contract described in section 403(b), 
     if such plan and annuity contract are both maintained by the 
     same church or convention or association of churches.
       ``(2) Limitation.--Paragraph (1) shall not apply to a 
     transfer or merger unless the participant's or beneficiary's 
     total accrued benefit immediately after the transfer or 
     merger is equal to or greater than the participant's or 
     beneficiary's total accrued benefit immediately before the 
     transfer or merger, and such total accrued benefit is 
     nonforfeitable after the transfer or merger.
       ``(3) Qualification.--A plan or annuity contract shall not 
     fail to be considered to be described in section 401(a) or 
     403(b) merely because such plan or annuity contract engages 
     in a transfer or merger described in this subsection.
       ``(4) Definitions.--For purposes of this subsection--
       ``(A) Church or convention or association of churches.--The 
     term `church or convention or association of churches' 
     includes an organization described in subparagraph (A) or 
     (B)(ii) of subsection (e)(3).
       ``(B) Annuity contract.--The term `annuity contract' 
     includes a custodial account described in section 403(b)(7) 
     and a retirement income account described in section 
     403(b)(9).
       ``(C) Accrued benefit.--The term `accrued benefit' means--
       ``(i) in the case of a defined benefit plan, the employee's 
     accrued benefit determined under the plan, and
       ``(ii) in the case of a plan other than a defined benefit 
     plan, the balance of the employee's account under the 
     plan.''.
       (2) Effective date.--The amendment made by this subsection 
     shall apply to transfers or mergers occurring after the date 
     of the enactment of this Act.
       (e) Investments by Church Plans in Collective Trusts.--
       (1) In general.--In the case of--
       (A) a church plan (as defined in section 414(e) of the 
     Internal Revenue Code of 1986), including a plan described in 
     section 401(a) of such Code and a retirement income account 
     described in section 403(b)(9) of such Code, and
       (B) an organization described in section 414(e)(3)(A) of 
     such Code the principal purpose or function of which is the 
     administration of such a plan or account,

     the assets of such plan, account, or organization (including 
     any assets otherwise permitted to be commingled for 
     investment purposes with the assets of such a plan, account, 
     or organization) may be invested in a group trust otherwise 
     described in Internal Revenue Service Revenue Ruling 81-100 
     (as modified by Internal Revenue Service Revenue Rulings 
     2004-67, 2011-1, and 2014-24), or any subsequent revenue 
     ruling that supersedes or modifies such revenue ruling, 
     without adversely affecting the tax status of the group 
     trust, such plan, account, or organization, or any other plan 
     or trust that invests in the group trust.
       (2) Effective date.--This subsection shall apply to 
     investments made after the date of the enactment of this Act.

                     Subtitle D--Revenue Provisions

     SEC. 341. UPDATED ASHRAE STANDARDS FOR ENERGY EFFICIENT 
                   COMMERCIAL BUILDINGS DEDUCTION.

       (a) 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''.
       (b) Conforming Amendments.--
       (1) 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).''.
       (2) 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''.
       (3) Paragraph (1) of section 179D(f) is amended--
       (A) by striking ``Table 9.3.1.1'' and inserting ``Table 
     9.5.1'', and
       (B) by striking ``Table 9.3.1.2'' and inserting ``Table 
     9.6.1''.
       (c) Effective Date.--The amendments made by this subsection 
     shall apply to property placed in service after December 31, 
     2015.

[[Page 20375]]



     SEC. 342. EXCISE TAX CREDIT EQUIVALENCY FOR LIQUIFIED 
                   PETROLEUM GAS AND LIQUIFIED NATURAL GAS.

       (a) In General.--Section 6426 is amended by adding at the 
     end the following new subsection:
       ``(j) Energy Equivalency Determinations for Liquefied 
     Petroleum Gas and Liquefied Natural Gas.--For purposes of 
     determining any credit under this section, any reference to 
     the number of gallons of an alternative fuel or the gasoline 
     gallon equivalent of such a fuel shall be treated as a 
     reference to--
       ``(1) in the case of liquefied petroleum gas, the energy 
     equivalent of a gallon of gasoline, as defined in section 
     4041(a)(2)(C), and
       ``(2) in the case of liquefied natural gas, the energy 
     equivalent of a gallon of diesel, as defined in section 
     4041(a)(2)(D).''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to fuel sold or used after December 31, 2015.

     SEC. 343. 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. 344. CLARIFICATION OF VALUATION RULE FOR EARLY 
                   TERMINATION OF CERTAIN CHARITABLE REMAINDER 
                   UNITRUSTS.

       (a) In General.--Section 664(e) is amended--
       (1) by adding at the end the following: ``In the case of 
     the early termination of a trust which is a charitable 
     remainder unitrust by reason of subsection (d)(3), the 
     valuation of interests in such trust for purposes of this 
     section shall be made under rules similar to the rules of the 
     preceding sentence.'', and
       (2) by striking ``for Purposes of Charitable Contribution'' 
     in the heading thereof and inserting ``of Interests''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to terminations of trusts occurring after the 
     date of the enactment of this Act.

     SEC. 345. PREVENTION OF TRANSFER OF CERTAIN LOSSES FROM TAX 
                   INDIFFERENT PARTIES.

       (a) In General.--Section 267(d) is amended to read as 
     follows:
       ``(d) Amount of Gain Where Loss Previously Disallowed.--
       ``(1) In general.--If--
       ``(A) in the case of a sale or exchange of property to the 
     taxpayer a loss sustained by the transferor is not allowable 
     to the transferor as a deduction by reason of subsection 
     (a)(1), and
       ``(B) the taxpayer sells or otherwise disposes of such 
     property (or of other property the basis of which in the 
     taxpayer's hands is determined directly or indirectly by 
     reference to such property) at a gain,
     then such gain shall be recognized only to the extent that it 
     exceeds so much of such loss as is properly allocable to the 
     property sold or otherwise disposed of by the taxpayer.
       ``(2) Exception for wash sales.--Paragraph (1) shall not 
     apply if the loss sustained by the transferor is not 
     allowable to the transferor as a deduction by reason of 
     section 1091 (relating to wash sales).
       ``(3) Exception for transfers from tax indifferent 
     parties.--Paragraph (1) shall not apply to the extent any 
     loss sustained by the transferor (if allowed) would not be 
     taken into account in determining a tax imposed under section 
     1 or 11 or a tax computed as provided by either of such 
     sections.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to sales and other dispositions of property 
     acquired after December 31, 2015, by the taxpayer in a sale 
     or exchange to which section 267(a)(1) of the Internal 
     Revenue Code of 1986 applied.

     SEC. 346. TREATMENT OF CERTAIN PERSONS AS EMPLOYERS WITH 
                   RESPECT TO MOTION PICTURE PROJECTS.

       (a) In General.--Chapter 25 (relating to general provisions 
     relating to employment taxes) is amended by adding at the end 
     the following new section:

     ``SEC. 3512. TREATMENT OF CERTAIN PERSONS AS EMPLOYERS WITH 
                   RESPECT TO MOTION PICTURE PROJECTS.

       ``(a) In General.--For purposes of sections 3121(a)(1) and 
     3306(b)(1), remuneration paid to a motion picture project 
     worker by a motion picture project employer during a calendar 
     year shall be treated as remuneration paid with respect to 
     employment of such worker by such employer during the 
     calendar year. The identity of such employer for such 
     purposes shall be determined as set forth in this section and 
     without regard to the usual common law rules applicable in 
     determining the employer-employee relationship.
       ``(b) Definitions.--For purposes of this section--
       ``(1) Motion picture project employer.--The term `motion 
     picture project employer' means any person if--
       ``(A) such person (directly or through affiliates)--
       ``(i) is a party to a written contract covering the 
     services of motion picture project workers with respect to 
     motion picture projects in the course of a client's trade or 
     business,
       ``(ii) is contractually obligated to pay remuneration to 
     the motion picture project workers without regard to payment 
     or reimbursement by any other person,
       ``(iii) controls the payment (within the meaning of section 
     3401(d)(1)) of remuneration to the motion picture project 
     workers and pays such remuneration from its own account or 
     accounts,
       ``(iv) is a signatory to one or more collective bargaining 
     agreements with a labor organization (as defined in 29 U.S.C. 
     152(5)) that represents motion picture project workers, and
       ``(v) has treated substantially all motion picture project 
     workers that such person pays as employees and not as 
     independent contractors during such calendar year for 
     purposes of determining employment taxes under this subtitle, 
     and
       ``(B) at least 80 percent of all remuneration (to which 
     section 3121 applies) paid by such person in such calendar 
     year is paid to motion picture project workers.
       ``(2) Motion picture project worker.--The term `motion 
     picture project worker' means any individual who provides 
     services on motion picture projects for clients who are not 
     affiliated with the motion picture project employer.
       ``(3) Motion picture project.--The term `motion picture 
     project' means the production of any property described in 
     section 168(f)(3). Such term does not include property with 
     respect to which records are required to be maintained under 
     section 2257 of title 18, United States Code.
       ``(4) Affiliate; affiliated.--A person shall be treated as 
     an affiliate of, or affiliated with, another person if such 
     persons are treated as a single employer under subsection (b) 
     or (c) of section 414.''.
       (b) Clerical Amendment.--The table of sections for such 
     chapter 25 is amended by adding at the end the following new 
     item:

``Sec. 3512. Treatment of certain persons as employers with respect to 
              motion picture projects.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to remuneration paid after December 31, 2015.
       (d) No Inference.--Nothing in the amendments made by this 
     section shall be construed to create any inference on the law 
     before the date of the enactment of this Act.

                      TITLE IV--TAX ADMINISTRATION

              Subtitle A--Internal Revenue Service Reforms

     SEC. 401. DUTY TO ENSURE THAT INTERNAL REVENUE SERVICE 
                   EMPLOYEES ARE FAMILIAR WITH AND ACT IN ACCORD 
                   WITH CERTAIN TAXPAYER RIGHTS.

       (a) In General.--Section 7803(a) is amended by 
     redesignating paragraph (3) as paragraph (4) and by inserting 
     after paragraph (2) the following new paragraph:
       ``(3) Execution of duties in accord with taxpayer rights.--
     In discharging his duties, the Commissioner shall ensure that 
     employees of the Internal Revenue Service are familiar with 
     and act in accord with taxpayer rights as afforded by other 
     provisions of this title, including--
       ``(A) the right to be informed,
       ``(B) the right to quality service,
       ``(C) the right to pay no more than the correct amount of 
     tax,
       ``(D) the right to challenge the position of the Internal 
     Revenue Service and be heard,

[[Page 20376]]

       ``(E) the right to appeal a decision of the Internal 
     Revenue Service in an independent forum,
       ``(F) the right to finality,
       ``(G) the right to privacy,
       ``(H) the right to confidentiality,
       ``(I) the right to retain representation, and
       ``(J) the right to a fair and just tax system.''.
       (b) Effective Date.--The amendments made by this section 
     shall take effect on the date of the enactment of this Act.

     SEC. 402. IRS EMPLOYEES PROHIBITED FROM USING PERSONAL EMAIL 
                   ACCOUNTS FOR OFFICIAL BUSINESS.

       No officer or employee of the Internal Revenue Service may 
     use a personal email account to conduct any official business 
     of the Government.

     SEC. 403. RELEASE OF INFORMATION REGARDING THE STATUS OF 
                   CERTAIN INVESTIGATIONS.

       (a) In General.--Section 6103(e) is amended by adding at 
     the end the following new paragraph:
       ``(11) Disclosure of information regarding status of 
     investigation of violation of this section.--In the case of a 
     person who provides to the Secretary information indicating a 
     violation of section 7213, 7213A, or 7214 with respect to any 
     return or return information of such person, the Secretary 
     may disclose to such person (or such person's designee)--
       ``(A) whether an investigation based on the person's 
     provision of such information has been initiated and whether 
     it is open or closed,
       ``(B) whether any such investigation substantiated such a 
     violation by any individual, and
       ``(C) whether any action has been taken with respect to 
     such individual (including whether a referral has been made 
     for prosecution of such individual).''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to disclosures made on or after the date of the 
     enactment of this Act.

     SEC. 404. ADMINISTRATIVE APPEAL RELATING TO ADVERSE 
                   DETERMINATIONS OF TAX-EXEMPT STATUS OF CERTAIN 
                   ORGANIZATIONS.

       (a) In General.--Section 7123 is amended by adding at the 
     end of the following:
       ``(c) Administrative Appeal Relating to Adverse 
     Determination of Tax-Exempt Status of Certain 
     Organizations.--
       ``(1) In general.--The Secretary shall prescribe procedures 
     under which an organization which claims to be described in 
     section 501(c) may request an administrative appeal 
     (including a conference relating to such appeal if requested 
     by the organization) to the Internal Revenue Service Office 
     of Appeals of an adverse determination described in paragraph 
     (2).
       ``(2) Adverse determinations.--For purposes of paragraph 
     (1), an adverse determination is described in this paragraph 
     if such determination is adverse to an organization with 
     respect to--
       ``(A) the initial qualification or continuing qualification 
     of the organization as exempt from tax under section 501(a) 
     or as an organization described in section 170(c)(2),
       ``(B) the initial classification or continuing 
     classification of the organization as a private foundation 
     under section 509(a), or
       ``(C) the initial classification or continuing 
     classification of the organization as a private operating 
     foundation under section 4942(j)(3).''.
       (b) Effective Date.--The amendment made by subsection (a) 
     shall apply to determinations made on or after May 19, 2014.

     SEC. 405. ORGANIZATIONS REQUIRED TO NOTIFY SECRETARY OF 
                   INTENT TO OPERATE UNDER 501(C)(4).

       (a) In General.--Part I of subchapter F of chapter 1 is 
     amended by adding at the end the following new section:

     ``SEC. 506. ORGANIZATIONS REQUIRED TO NOTIFY SECRETARY OF 
                   INTENT TO OPERATE UNDER 501(C)(4).

       ``(a) In General.--An organization described in section 
     501(c)(4) shall, not later than 60 days after the 
     organization is established, notify the Secretary (in such 
     manner as the Secretary shall by regulation prescribe) that 
     it is operating as such.
       ``(b) Contents of Notice.--The notice required under 
     subsection (a) shall include the following information:
       ``(1) The name, address, and taxpayer identification number 
     of the organization.
       ``(2) The date on which, and the State under the laws of 
     which, the organization was organized.
       ``(3) A statement of the purpose of the organization.
       ``(c) Acknowledgment of Receipt.--Not later than 60 days 
     after receipt of such a notice, the Secretary shall send to 
     the organization an acknowledgment of such receipt.
       ``(d) Extension for Reasonable Cause.--The Secretary may, 
     for reasonable cause, extend the 60-day period described in 
     subsection (a).
       ``(e) User Fee.--The Secretary shall impose a reasonable 
     user fee for submission of the notice under subsection (a).
       ``(f) Request for Determination.--Upon request by an 
     organization to be treated as an organization described in 
     section 501(c)(4), the Secretary may issue a determination 
     with respect to such treatment. Such request shall be treated 
     for purposes of section 6104 as an application for exemption 
     from taxation under section 501(a).''.
       (b) Supporting Information With First Return.--Section 
     6033(f) is amended--
       (1) by striking the period at the end and inserting ``, 
     and'',
       (2) by striking ``include on the return required under 
     subsection (a) the information'' and inserting the following: 
     ``include on the return required under subsection (a)--
       ``(1) the information'', and
       (3) by adding at the end the following new paragraph:
       ``(2) in the case of the first such return filed by such an 
     organization after submitting a notice to the Secretary under 
     section 506(a), such information as the Secretary shall by 
     regulation require in support of the organization's treatment 
     as an organization described in section 501(c)(4).''.
       (c) Failure To File Initial Notification.--Section 6652(c) 
     is amended by redesignating paragraphs (4), (5), and (6) as 
     paragraphs (5), (6), and (7), respectively, and by inserting 
     after paragraph (3) the following new paragraph:
       ``(4) Notices under section 506.--
       ``(A) Penalty on organization.--In the case of a failure to 
     submit a notice required under section 506(a) (relating to 
     organizations required to notify Secretary of intent to 
     operate as 501(c)(4)) on the date and in the manner 
     prescribed therefor, there shall be paid by the organization 
     failing to so submit $20 for each day during which such 
     failure continues, but the total amount imposed under this 
     subparagraph on any organization for failure to submit any 
     one notice shall not exceed $5,000.
       ``(B) Managers.--The Secretary may make written demand on 
     an organization subject to penalty under subparagraph (A) 
     specifying in such demand a reasonable future date by which 
     the notice shall be submitted for purposes of this 
     subparagraph. If such notice is not submitted on or before 
     such date, there shall be paid by the person failing to so 
     submit $20 for each day after the expiration of the time 
     specified in the written demand during which such failure 
     continues, but the total amount imposed under this 
     subparagraph on all persons for failure to submit any one 
     notice shall not exceed $5,000.''.
       (d) Clerical Amendment.--The table of sections for part I 
     of subchapter F of chapter 1 is amended by adding at the end 
     the following new item:

``Sec. 506. Organizations required to notify Secretary of intent to 
              operate under 501(c)(4).''.
       (e) Limitation.--Notwithstanding any other provision of 
     law, any fees collected pursuant to section 506(e) of the 
     Internal Revenue Code of 1986, as added by subsection (a), 
     shall not be expended by the Secretary of the Treasury or the 
     Secretary's delegate unless provided by an appropriations 
     Act.
       (f) Effective Date.--
       (1) In general.--The amendments made by this section shall 
     apply to organizations which are described in section 
     501(c)(4) of the Internal Revenue Code of 1986 and organized 
     after the date of the enactment of this Act.
       (2) Certain existing organizations.--In the case of any 
     other organization described in section 501(c)(4) of such 
     Code, the amendments made by this section shall apply to such 
     organization only if, on or before the date of the enactment 
     of this Act--
       (A) such organization has not applied for a written 
     determination of recognition as an organization described in 
     section 501(c)(4) of such Code, and
       (B) such organization has not filed at least one annual 
     return or notice required under subsection (a)(1) or (i) (as 
     the case may be) of section 6033 of such Code.
     In the case of any organization to which the amendments made 
     by this section apply by reason of the preceding sentence, 
     such organization shall submit the notice required by section 
     506(a) of such Code, as added by this Act, not later than 180 
     days after the date of the enactment of this Act.

     SEC. 406. DECLARATORY JUDGMENTS FOR 501(C)(4) AND OTHER 
                   EXEMPT ORGANIZATIONS.

       (a) In General.--Section 7428(a)(1) is amended by striking 
     ``or'' at the end of subparagraph (C) and by inserting after 
     subparagraph (D) the following new subparagraph:
       ``(E) with respect to the initial qualification or 
     continuing qualification of an organization as an 
     organization described in section 501(c) (other than 
     paragraph (3)) or 501(d) and exempt from tax under section 
     501(a), or''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to pleadings filed after the date of the 
     enactment of this Act.

     SEC. 407. TERMINATION OF EMPLOYMENT OF INTERNAL REVENUE 
                   SERVICE EMPLOYEES FOR TAKING OFFICIAL ACTIONS 
                   FOR POLITICAL PURPOSES.

       (a) In General.--Paragraph (10) of section 1203(b) of the 
     Internal Revenue Service Restructuring and Reform Act of 1998 
     is amended to read as follows:
       ``(10) performing, delaying, or failing to perform (or 
     threatening to perform, delay, or fail to perform) any 
     official action (including any audit) with respect to a 
     taxpayer for purpose of extracting personal gain or benefit 
     or for a political purpose.''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect on the date of the enactment of this Act.

[[Page 20377]]



     SEC. 408. GIFT TAX NOT TO APPLY TO CONTRIBUTIONS TO CERTAIN 
                   EXEMPT ORGANIZATIONS.

       (a) In General.--Section 2501(a) is amended by adding at 
     the end the following new paragraph:
       ``(6) Transfers to certain exempt organizations.--Paragraph 
     (1) shall not apply to the transfer of money or other 
     property to an organization described in paragraph (4), (5), 
     or (6) of section 501(c) and exempt from tax under section 
     501(a), for the use of such organization.''.
       (b) Effective Date.--The amendment made by subsection (a) 
     shall apply to gifts made after the date of the enactment of 
     this Act.
       (c) No Inference.--Nothing in the amendment made by 
     subsection (a) shall be construed to create any inference 
     with respect to whether any transfer of property (whether 
     made before, on, or after the date of the enactment of this 
     Act) to an organization described in paragraph (4), (5), or 
     (6) of section 501(c) of the Internal Revenue Code of 1986 is 
     a transfer of property by gift for purposes of chapter 12 of 
     such Code.

     SEC. 409. EXTEND INTERNAL REVENUE SERVICE AUTHORITY TO 
                   REQUIRE TRUNCATED SOCIAL SECURITY NUMBERS ON 
                   FORM W-2.

       (a) Wages.--Section 6051(a)(2) is amended by striking ``his 
     social security account number'' and inserting ``an 
     identifying number for the employee''.
       (b) Effective Date.--The amendment made by this section 
     shall take effect on the date of the enactment of this Act.

     SEC. 410. CLARIFICATION OF ENROLLED AGENT CREDENTIALS.

       Section 330 of title 31, United States Code, is amended--
       (1) by redesignating subsections (b), (c), and (d) as 
     subsections (c), (d), and (e), respectively, and
       (2) by inserting after subsection (a) the following new 
     subsection:
       ``(b) Any enrolled agents properly licensed to practice as 
     required under rules promulgated under subsection (a) shall 
     be allowed to use the credentials or designation of `enrolled 
     agent', `EA', or `E.A.'.''.

     SEC. 411. PARTNERSHIP AUDIT RULES.

       (a) Correction and Clarification to Modifications to 
     Imputed Underpayments.--
       (1) Section 6225(c)(4)(A)(i) is amended by striking ``in 
     the case of ordinary income,''.
       (2) Section 6225(c) is amended by redesignating paragraphs 
     (5) through (7) as paragraphs (6) through (8), respectively, 
     and by inserting after paragraph (4) the following new 
     paragraph:
       ``(5) Certain passive losses of publicly traded 
     partnerships.--
       ``(A) In general.--In the case of a publicly traded 
     partnership (as defined in section 469(k)(2)), such 
     procedures shall provide--
       ``(i) for determining the imputed underpayment without 
     regard to the portion thereof that the partnership 
     demonstrates is attributable to a net decrease in a specified 
     passive activity loss which is allocable to a specified 
     partner, and
       ``(ii) for the partnership to take such net decrease into 
     account as an adjustment in the adjustment year with respect 
     to the specified partners to which such net decrease relates.
       ``(B) Specified passive activity loss.--For purposes of 
     this paragraph, the term `specified passive activity loss' 
     means, with respect to any specified partner of such publicly 
     traded partnership, the lesser of--
       ``(i) the passive activity loss of such partner which is 
     separately determined with respect to such partnership under 
     section 469(k) with respect to such partner's taxable year in 
     which or with which the reviewed year of such partnership 
     ends, or
       ``(ii) such passive activity loss so determined with 
     respect to such partner's taxable year in which or with which 
     the adjustment year of such partnership ends.
       ``(C) Specified partner.--For purposes of this paragraph, 
     the term `specified partner' means any person if such 
     person--
       ``(i) is a partner of the publicly traded partnership 
     referred to in subparagraph (A),
       ``(ii) is described in section 469(a)(2), and
       ``(iii) has a specified passive activity loss with respect 
     to such publicly traded partnership,
     with respect to each taxable year of such person which is 
     during the period beginning with the taxable year of such 
     person in which or with which the reviewed year of such 
     publicly traded partnership ends and ending with the taxable 
     year of such person in which or with which the adjustment 
     year of such publicly traded partnership ends.''.
       (b) Correction and Clarification to Judicial Review of 
     Partnership Adjustment .--
       (1) Section 6226 is amended by adding at the end the 
     following new subsection:
       ``(d) Judicial Review.--For the time period within which a 
     partnership may file a petition for a readjustment, see 
     section 6234(a).''.
       (2) Subsections (a)(3), (b)(1), and (d) of section 6234 are 
     each amended by striking ``the Claims Court'' and inserting 
     ``the Court of Federal Claims''.
       (3) The heading for section 6234(b) is amended by striking 
     ``Claims Court'' and inserting ``Court of Federal Claims''.
       (c) Correction and Clarification to Period of Limitations 
     on Making Adjustments.--
       (1) Section 6235(a)(2) is amended by striking ``paragraph 
     (4)'' and inserting ``paragraph (7)''.
       (2) Section 6235(a)(3) is amended by striking ``270 days'' 
     and inserting ``330 days (plus the number of days of any 
     extension consented to by the Secretary under section 
     6225(c)(7)''.
       (d) Technical Amendment.--Section 6031(b) is amended by 
     striking the last sentence and inserting the following: 
     ``Except as provided in the procedures under section 6225(c), 
     with respect to statements under section 6226, or as 
     otherwise provided by the Secretary, information required to 
     be furnished by the partnership under this subsection may not 
     be amended after the due date of the return under subsection 
     (a) to which such information relates.''.
       (e) Effective Date.--The amendments made by this section 
     shall take effect as if included in section 1101 of the 
     Bipartisan Budget Act of 2015.

                  Subtitle B--United States Tax Court

           PART 1--TAXPAYER ACCESS TO UNITED STATES TAX COURT

     SEC. 421. FILING PERIOD FOR INTEREST ABATEMENT CASES.

       (a) In General.--Subsection (h) of section 6404 is 
     amended--
       (1) by striking ``Review of Denial'' in the heading and 
     inserting ``Judicial Review'', and
       (2) by striking ``if such action is brought'' and all that 
     follows in paragraph (1) and inserting ``if such action is 
     brought--
       ``(A) at any time after the earlier of--
       ``(i) the date of the mailing of the Secretary's final 
     determination not to abate such interest, or
       ``(ii) the date which is 180 days after the date of the 
     filing with the Secretary (in such form as the Secretary may 
     prescribe) of a claim for abatement under this section, and
       ``(B) not later than the date which is 180 days after the 
     date described in subparagraph (A)(i).''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to claims for abatement of interest filed with 
     the Secretary of the Treasury after the date of the enactment 
     of this Act.

     SEC. 422. SMALL TAX CASE ELECTION FOR INTEREST ABATEMENT 
                   CASES.

       (a) In General.--Subsection (f) of section 7463 is 
     amended--
       (1) by striking ``and'' at the end of paragraph (1),
       (2) by striking the period at the end of paragraph (2) and 
     inserting ``, and'', and
       (3) by adding at the end the following new paragraph:
       ``(3) a petition to the Tax Court under section 6404(h) in 
     which the amount of the abatement sought does not exceed 
     $50,000.''.
       (b) Effective Date.--The amendments made by this section 
     shall apply to cases pending as of the day after the date of 
     the enactment of this Act, and cases commenced after such 
     date of enactment.

     SEC. 423. VENUE FOR APPEAL OF SPOUSAL RELIEF AND COLLECTION 
                   CASES.

       (a) In General.--Paragraph (1) of section 7482(b) is 
     amended--
       (1) by striking ``or'' at the end of subparagraph (D),
       (2) by striking the period at the end of subparagraph (E), 
     and
       (3) by inserting after subparagraph (E) the following new 
     subparagraphs:
       ``(F) in the case of a petition under section 6015(e), the 
     legal residence of the petitioner, or
       ``(G) in the case of a petition under section 6320 or 
     6330--
       ``(i) the legal residence of the petitioner if the 
     petitioner is an individual, and
       ``(ii) the principal place of business or principal office 
     or agency if the petitioner is an entity other than an 
     individual.''.
       (b) Effective Date.--
       (1) In general.--The amendments made by this section shall 
     apply to petitions filed after the date of enactment of this 
     Act.
       (2) Effect on existing proceedings.--Nothing in this 
     section shall be construed to create any inference with 
     respect to the application of section 7482 of the Internal 
     Revenue Code of 1986 with respect to court proceedings filed 
     on or before the date of the enactment of this Act.

     SEC. 424. SUSPENSION OF RUNNING OF PERIOD FOR FILING PETITION 
                   OF SPOUSAL RELIEF AND COLLECTION CASES.

       (a) Petitions for Spousal Relief.--
       (1) In general.--Subsection (e) of section 6015 is amended 
     by adding at the end the following new paragraph:
       ``(6) Suspension of running of period for filing petition 
     in title 11 cases.--In the case of a person who is prohibited 
     by reason of a case under title 11, United States Code, from 
     filing a petition under paragraph (1)(A) with respect to a 
     final determination of relief under this section, the running 
     of the period prescribed by such paragraph for filing such a 
     petition with respect to such final determination shall be 
     suspended for the period during which the person is so 
     prohibited from filing such a petition, and for 60 days 
     thereafter.''.

[[Page 20378]]

       (2) Effective date.--The amendment made by this subsection 
     shall apply to petitions filed under section 6015(e) of the 
     Internal Revenue Code of 1986 after the date of the enactment 
     of this Act.
       (b) Collection Proceedings.--
       (1) In general.--Subsection (d) of section 6330 is 
     amended--
       (A) by striking ``appeal such determination to the Tax 
     Court'' in paragraph (1) and inserting ``petition the Tax 
     Court for review of such determination'',
       (B) by striking ``Judicial review of determination'' in the 
     heading of paragraph (1) and inserting ``Petition for review 
     by tax court'',
       (C) by redesignating paragraph (2) as paragraph (3), and
       (D) by inserting after paragraph (1) the following new 
     paragraph:
       ``(2) Suspension of running of period for filing petition 
     in title 11 cases.--In the case of a person who is prohibited 
     by reason of a case under title 11, United States Code, from 
     filing a petition under paragraph (1) with respect to a 
     determination under this section, the running of the period 
     prescribed by such subsection for filing such a petition with 
     respect to such determination shall be suspended for the 
     period during which the person is so prohibited from filing 
     such a petition, and for 30 days thereafter, and''.
       (2) Effective date.--The amendments made by this subsection 
     shall apply to petitions filed under section 6330 of the 
     Internal Revenue Code of 1986 after the date of the enactment 
     of this Act.
       (c) Conforming Amendment.--Subsection (c) of section 6320 
     is amended by striking ``(2)(B)'' and inserting ``(3)(B)''.

     SEC. 425. APPLICATION OF FEDERAL RULES OF EVIDENCE.

       (a) In General.--Section 7453 is amended by striking ``the 
     rules of evidence applicable in trials without a jury in the 
     United States District Court of the District of Columbia'' 
     and inserting ``the Federal Rules of Evidence''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to proceedings commenced after the date of the 
     enactment of this Act and, to the extent that it is just and 
     practicable, to all proceedings pending on such date.

             PART 2--UNITED STATES TAX COURT ADMINISTRATION

     SEC. 431. JUDICIAL CONDUCT AND DISABILITY PROCEDURES.

       (a) In General.--Part II of subchapter C of chapter 76 is 
     amended by adding at the end the following new section:

     ``SEC. 7466. JUDICIAL CONDUCT AND DISABILITY PROCEDURES.

       ``(a) In General.--The Tax Court shall prescribe rules, 
     consistent with the provisions of chapter 16 of title 28, 
     United States Code, establishing procedures for the filing of 
     complaints with respect to the conduct of any judge or 
     special trial judge of the Tax Court and for the 
     investigation and resolution of such complaints. In 
     investigating and taking action with respect to any such 
     complaint, the Tax Court shall have the powers granted to a 
     judicial council under such chapter.
       ``(b) Judicial Council.--The provisions of sections 354(b) 
     through 360 of title 28, United States Code, regarding 
     referral or certification to, and petition for review in the 
     Judicial Conference of the United States, and action thereon, 
     shall apply to the exercise by the Tax Court of the powers of 
     a judicial council under subsection (a). The determination 
     pursuant to section 354(b) or 355 of title 28, United States 
     Code, shall be made based on the grounds for removal of a 
     judge from office under section 7443(f), and certification 
     and transmittal by the Conference of any complaint shall be 
     made to the President for consideration under section 
     7443(f).
       ``(c) Hearings.--
       ``(1) In general.--In conducting hearings pursuant to 
     subsection (a), the Tax Court may exercise the authority 
     provided under section 1821 of title 28, United States Code, 
     to pay the fees and allowances described in that section.
       ``(2) Reimbursement for expenses.--The Tax Court shall have 
     the power provided under section 361 of such title 28 to 
     award reimbursement for the reasonable expenses described in 
     that section. Reimbursements under this paragraph shall be 
     made out of any funds appropriated for purposes of the Tax 
     Court.''.
       (b) Clerical Amendment.--The table of sections for part II 
     of subchapter C of chapter 76 is amended by adding at the end 
     the following new item:

``Sec. 7466. Judicial conduct and disability procedures.''.
       (c) Effective Date.--The amendments made by this section 
     shall apply to proceedings commenced after the date which is 
     180 days after the date of the enactment of this Act and, to 
     the extent just and practicable, all proceedings pending on 
     such date.

     SEC. 432. ADMINISTRATION, JUDICIAL CONFERENCE, AND FEES.

       (a) In General.--Part III of subchapter C of chapter 76 is 
     amended by inserting before section 7471 the following new 
     sections:

     ``SEC. 7470. ADMINISTRATION.

       ``Notwithstanding any other provision of law, the Tax Court 
     may exercise, for purposes of management, administration, and 
     expenditure of funds of the Court, the authorities provided 
     for such purposes by any provision of law (including any 
     limitation with respect to such provision of law) applicable 
     to a court of the United States (as that term is defined in 
     section 451 of title 28, United States Code), except to the 
     extent that such provision of law is inconsistent with a 
     provision of this subchapter.

     ``SEC. 7470A. JUDICIAL CONFERENCE.

       ``(a) Judicial Conference.--The chief judge may summon the 
     judges and special trial judges of the Tax Court to an annual 
     judicial conference, at such time and place as the chief 
     judge shall designate, for the purpose of considering the 
     business of the Tax Court and recommending means of improving 
     the administration of justice within the jurisdiction of the 
     Tax Court. The Tax Court shall provide by its rules for 
     representation and active participation at such conferences 
     by persons admitted to practice before the Tax Court and by 
     other persons active in the legal profession.
       ``(b) Registration Fee.--The Tax Court may impose a 
     reasonable registration fee on persons (other than judges and 
     special trial judges of the Tax Court) participating at 
     judicial conferences convened pursuant to subsection (a). 
     Amounts so received by the Tax Court shall be available to 
     the Tax Court to defray the expenses of such conferences.''.
       (b) Disposition of Fees.--Section 7473 is amended to read 
     as follows:

     ``SEC. 7473. DISPOSITION OF FEES.

       ``Except as provided in sections 7470A and 7475, all fees 
     received by the Tax Court pursuant to this title shall be 
     deposited into a special fund of the Treasury to be available 
     to offset funds appropriated for the operation and 
     maintenance of the Tax Court.''.
       (c) Clerical Amendments.--The table of sections for part 
     III of subchapter C of chapter 76 is amended by inserting 
     before the item relating to section 7471 the following new 
     items:

``Sec. 7470. Administration.
``Sec. 7470A. Judicial conference.''.

       PART 3--CLARIFICATION RELATING TO UNITED STATES TAX COURT

     SEC. 441. CLARIFICATION RELATING TO UNITED STATES TAX COURT.

       Section 7441 is amended by adding at the end the following: 
     ``The Tax Court is not an agency of, and shall be independent 
     of, the executive branch of the Government.''.

                   TITLE V--TRADE-RELATED PROVISIONS

     SEC. 501. MODIFICATION OF EFFECTIVE DATE OF PROVISIONS 
                   RELATING TO TARIFF CLASSIFICATION OF 
                   RECREATIONAL PERFORMANCE OUTERWEAR.

       Section 601(c) of the Trade Preferences Extension Act of 
     2015 (Public Law 114-27; 129 Stat. 412) is amended--
       (1) in paragraph (1), by striking ``the 180th day after the 
     date of the enactment of this Act'' and inserting ``March 31, 
     2016''; and
       (2) in paragraph (2), by striking ``such 180th day'' and 
     inserting ``March 31, 2016''.

     SEC. 502. AGREEMENT BY ASIA-PACIFIC ECONOMIC COOPERATION 
                   MEMBERS TO REDUCE RATES OF DUTY ON CERTAIN 
                   ENVIRONMENTAL GOODS.

       Section 107 of the Bipartisan Congressional Trade 
     Priorities and Accountability Act of 2015 (Public Law 114-26; 
     19 U.S.C. 4206) is amended by adding at the end the 
     following:
       ``(c) Agreement by Asia-Pacific Economic Cooperation 
     Members to Reduce Rates of Duty on Certain Environmental 
     Goods.--Notwithstanding the notification requirement 
     described in section 103(a)(2), the President may exercise 
     the proclamation authority provided for in section 
     103(a)(1)(B) to implement an agreement by members of the 
     Asia-Pacific Economic Cooperation (APEC) to reduce any rate 
     of duty on certain environmental goods included in Annex C of 
     the APEC Leaders Declaration issued on September 9, 2012, if 
     (and only if) the President, as soon as feasible after the 
     date of the enactment of this subsection, and before 
     exercising proclamation authority under section 103(a)(1)(B), 
     notifies Congress of the negotiations relating to the 
     agreement and the specific United States objectives in the 
     negotiations.''.

                      TITLE VI--BUDGETARY EFFECTS

     SEC. 601. BUDGETARY EFFECTS.

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

  The SPEAKER pro tempore. Pursuant to House Resolution 566, the 
question shall be divided among the two House amendments.
  Pursuant to section 2(a) of House Resolution 566, the portion of the 
divided question comprising the amendment specified in section 3(b) of 
House Resolution 566 shall be considered first.
  This portion shall be debatable for 1 hour equally divided and 
controlled by the Chair and ranking minority member of the Committee on 
Ways and Means.

[[Page 20379]]

  The gentleman from Texas (Mr. Brady) and the gentleman from Michigan 
(Mr. Levin) each will control 30 minutes.
  The Chair recognizes the gentleman from Texas.


                             General Leave

  Mr. BRADY of Texas. Mr. Speaker, I ask unanimous consent that all 
Members may have 5 legislative days in which to revise and extend their 
remarks on H.R. 2029.
  The SPEAKER pro tempore. Is there objection to the request of the 
gentleman from Texas?
  There was no objection.
  Mr. BRADY of Texas. Mr. Speaker, I yield myself such time as I may 
consume.
  After months of negotiations, I am honored today to talk to Americans 
about the Protecting Americans from Tax Hikes Act, also known as the 
PATH Act.
  The most important thing for the American people to know is that this 
bill prevents their taxes from increasing, helps create more jobs in 
their communities, and makes it easier for them to do their taxes. It 
also reins in the IRS and protects taxpayers from waste and fraud 
within the large tax credit programs administered by the IRS.
  Now I would like to take a moment to talk about the six specific ways 
this bill helps American taxpayers.
  First, this bill provides $629 billion of tax relief that families 
and businesses can rely on. It is financially responsible because 
preventing a tax increase is never a cost.
  Republicans have always worked to stop Washington from taking more 
money from the hardworking Americans who earned it. This is not 
Washington's money. It is the taxpayers'. We shouldn't have to raise 
taxes on some people to prevent taxes on other people from going up.
  Secondly, by making a number of temporary tax provisions permanent, 
this will deliver predictability, clarity, and certainty for individual 
taxpayers as well as people managing businesses and trying to invest 
for the future.
  As we know all too well, how our country manages its Tax Code makes 
absolutely no sense. How can families and local businesses count on tax 
relief each year as long as Congress can't decide what is permanent and 
what is not? That confusion ends with this bill.
  With this bill in place, Americans will no longer have to worry each 
December if Congress will take action to extend certain tax relief 
measures that they have come to rely upon, including allowing State and 
local sales tax deductions for families, providing small businesses tax 
relief, and offering incentives--true incentives--for innovation, 
including the research and development tax credit.
  Third, this is a progrowth bill. This permanent tax relief will make 
it easier for employees to plan ahead, hire new workers, grow their 
businesses, and invest in the community.
  Fourth, Americans who are frustrated by Washington waste will be 
pleased to know that our bill contains stronger measures to fight fraud 
and abuse in these tax credit programs. While these provisions are 
significant, they are only a down payment on Republican efforts to make 
these tax programs, which are far too prone to error, abuse, and waste 
today, more accountable.
  Fifth, our bill reins in the IRS and protects taxpayers, delivers the 
power to fire IRS employees who take politically motivated actions 
against taxpayers, requires IRS employees to respect the Taxpayer Bill 
of Rights, and prohibits IRS employees from using personal email 
accounts for official business.
  After witnessing years of abuse at the IRS, we can all agree that 
these provisions are important taxpayer victories.
  Finally, this bill serves as a path forward to progrowth tax reform 
by ensuring that we will no longer have to spend months each year 
debating temporary tax extensions. Instead, Congress can focus on 
delivering a simpler, fairer, and flatter Tax Code that is built for 
growth.
  I am proud of this legislation and grateful for all the Members of 
Congress who have helped throughout the course of these negotiations. 
This bill includes literally dozens of provisions drawn from bills and 
marked up by the Ways and Means Committee this past year. That is a 
reflection of the regular order that I am committed to extending and 
expanding next year as the committee digs in on tax reform and other 
critical measures.
  There is a lot in this bill, but those are the key principles. The 
bottom line is this legislation prevents tax increases, creates more 
job opportunities, and makes it easier for Americans to do their taxes. 
That is a great gift, an overdue gift, for the American taxpayers and 
the people who want and deserve a stronger U.S. economy.
  Mr. Speaker, I reserve the balance of my time.

                              {time}  1115

  Mr. LEVIN. Mr. Speaker, I yield myself such time as I may consume.
  This bill adds $622 billion to the deficit, the vast majority of 
which is through permanent tax provisions. For those who propose to 
have the increase in the deficit continue to drive down defense 
domestic spending, this bill will almost certainly accomplish this. By 
FY17, nondefense discretionary spending will have already fallen to its 
lowest level, as a share of the economy, since 1962. These cuts 
seriously threaten programs that assist the middle class or those who 
are striving to reach the middle class, programs like Head Start and 
Pell Grants and those in job training and those in basic health 
research.
  For those who want, as they have for years, to make tax breaks 
permanent so that they will not have to be offset in revenue-neutral 
tax reform, this bill will help them carry it out, leaving more room to 
cut taxes for the very wealthy, which they will say will pay for 
themselves.
  For those who want to continue tax cuts that were only intended for a 
specific period, like expensive bonus depreciation, the purpose of 
which is to ease recovery from the recession and to lose its 
effectiveness otherwise, this bill will help do that.
  For those who want to continue international tax proposals, often 
serving as a loophole and helping to move resources overseas, this bill 
will help do that. The active financing international tax provision, 
made permanent in this bill at a cost of $78 billion, and the extension 
of the CFC look-through provision for 5 years, at a cost of $8 billion, 
which often promotes tax savings, should be thoroughly reexamined as 
part of comprehensive tax reform--and the sooner the better.
  This bill is a piecemeal approach to tax reform. It is the opposite 
of what was done by former Ways and Means Chairman Dave Camp, who kept 
some provisions, who changed some, who ended some, like bonus 
depreciation, and who paid for his revenue-neutral comprehensive tax 
reform proposal.
  These shortcomings must be weighed against the provisions that are 
important priorities for Democrats--the child tax credit, the earned 
income tax credit, and the American opportunity tax credit. But the 
long-term negative dangers of this legislation make the price too high. 
Therefore, I oppose this legislation.
  Mr. Speaker, I reserve the balance of my time.
  Mr. BRADY of Texas. Mr. Speaker, I yield myself such time as I may 
consume.
  As chairman of the Committee on Ways and Means, I have asked that the 
nonpartisan Joint Committee on Taxation make available to the public a 
technical explanation of the Protecting Americans from Tax Hikes Act of 
2015, which the House is considering today.
  The Joint Committee on Taxation has issued that technical explanation 
as JCX-144-15, and it expresses the Ways and Means Committee's 
understanding and legislative intent behind this important legislation. 
It is available on the Joint Committee on Taxation's Web site at 
www.jct.gov.
  Mr. Speaker, I yield 2 minutes to the gentleman from Louisiana (Mr. 
Boustany), who leads the Subcommittee on Tax Policy for the Committee 
on Ways and Means.
  Mr. BOUSTANY. I thank the chairman for the fine work he and his staff 
have done in negotiating this package.

[[Page 20380]]

  Mr. Speaker, Speaker Ryan has talked about restoring confidence in 
America, which is something I think we can all agree on. Things we need 
to do to achieve that involve restoring American leadership abroad, 
protecting our American values, and, very importantly, restoring 
American prosperity. We can't do that until we reform the Tax Code. 
That is at the center of all of the efforts to restore American 
prosperity through economic growth.
  I rise in rigorous support of this bill as it stops the cycle of just 
extending these provisions without vetting them year after year and in 
the last hours of the year. It is time to stop that, and we are doing 
that. We are making some of these provisions permanent. We are creating 
certainty for American families and for American businesses at a time 
of economic uncertainty. This is real tax relief that sets the stage 
for tax reform.
  There are a number of important provisions in this. Mr. Paulsen has 
worked very hard to repeal the device tax, which stifles American 
innovation, and we are going to put this on hold for 2 years. We are 
going to stop the health insurance tax for 1 year, which is causing 
health insurance premium hikes for American families. By some 
estimates, it is $350 to $400 a year for American families, and this is 
wrong.
  The R&D tax credit is made permanent. American innovation is what we 
want to see to get growth. It also has a whole bunch of other 
provisions that help small businesses and families. We do work very 
hard to create program integrity in our EITC and child tax credit, 
something that is very much needed.
  I believe this is a very important step forward for tax reform. It 
sets the stage. We have broken that disastrous cycle of just a knee-
jerk extension of these provisions, and we have, actually, vetted a lot 
of these tax provisions to be made permanent--we have run them through 
committee; we have had hearings; we have had markups; we have taken 
them to the floor. We are trying to restore regular order.
  Ladies and gentlemen, this will be seen as a first step in restoring 
American confidence. I am confident of that. Let's pass this package 
and move on.
  Mr. LEVIN. Mr. Speaker, I yield 3 minutes to the gentleman from 
Maryland (Mr. Hoyer), the Democratic whip.
  Mr. HOYER. I thank the gentleman for yielding.
  Mr. Speaker, as for the last speaker, I heard that speech in 1981. I 
heard it in 2001. I heard it in 2003. The certainty of this bill is 
that we will explode further deficits and provide for disinvestment. 
That is the certainty of this bill, and I rise in strong opposition to 
it.
  This package will raise deficits by approximately $622 billion over 
the next 10 years. Add to that the $58 billion in unpaid-for tax 
provisions in the omnibus bill of approximately $680 billion. When you 
add interest to that, it is almost $800 billion in additional debt, Mr. 
and Mrs. America.
  I came to this floor on Tuesday and spoke in greater detail about my 
opposition to this package. I, again, want to highlight one major 
issue, and that is how enacting this legislation will set the stage for 
the next round of painful sequester cuts, otherwise known as 
disinvestment in growing our economy and jobs.
  Do my colleagues not see the tragic symmetry of this package's almost 
$800 billion in new deficits and the sequester's $813 billion in cuts 
that were imposed for the sake of deficit reduction?
  Republicans will again insist upon hundreds of billions of cuts from 
domestic discretionary investment--i.e., growing jobs and the economy--
in order to make up for the budget shortfall incurred by the extension 
of these tax credits, some of which are made permanent.
  There are, certainly, good reasons to make a number of these tax 
credits and deductions permanent, and I support making many of these 
permanent, but we ought to pay for it in the process, as your 
predecessor did, Mr. Camp. It was a tough decision he made, and it was 
dismissed out of hand because it was hard to do.
  This is easy to do. There is no courage required to vote for this 
bill. All you have to do is suspend common sense. This legislation 
flies in the face of the basic budgeting principle, which hardworking 
families all across our Nation understand and have to live with every 
month.
  Maya MacGuineas, president of the Committee for a Responsible Federal 
Budget, wrote in The Washington Post last week:
  ``How do we explain to our children that we borrowed more than $1 
trillion--counting interest--not because it was a national emergency or 
to make critical investments in the future but because we just don't 
like paying our bills?''
  Republicans would answer as they always do--that tax cuts somehow, 
magically, pay for themselves. I have been here 35 years. It has never 
happened.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. LEVIN. I yield the gentleman an additional 30 seconds.
  Mr. HOYER. Mr. Speaker, we have seen that notion disproven several 
times over, and the results of experimenting with that idea have been 
higher deficits and a ballooning debt that fuel Republican efforts to 
disinvest in our future and to dismantle Medicare, Social Security, and 
safety net programs. Let's not make the same mistake again.
  Instead, we ought to be voting on a straightforward, 2-year 
extension, and then commit ourselves to meaningful tax reform as David 
Camp did. It is tough to do, I understand that, but it is the right 
thing to do. Let us show that we have courage as well as common sense. 
Defeat this bill. Let us move on to meaningful tax reform and to 
growing our economy.
  Mr. BRADY of Texas. Mr. Speaker, I yield 2 minutes to the gentleman 
from Ohio (Mr. Tiberi), one of our key leaders on tax reform.
  Mr. TIBERI. I thank Chairman Brady and Speaker Ryan for their 
leadership.
  Mr. Speaker, to the previous gentleman, I say Mr. and Mrs. America 
would be stunned to know that, to keep current policy in place, we have 
to raise taxes to keep tax cuts, some of which have been in place for 
30 years. The R&D tax credit has been around for 30 years. The horrible 
way that we make policy here on a retroactive basis or on a ``1-year 
forward and then we will address it again'' basis is changing today.
  Tom and Judy Price, who are farmers in my district, have been 
thinking about buying a loader this year. They can now, actually, buy 
one, and they can, actually, plan for the next 10 years on how to 
operate their farm and to make investments. There is that small 
business guy who wants to expense or that person to whom R&D is so 
important, but they weren't sure what we were going to do with the R&D 
tax credit even though it has been around for decades.
  For decades, the current policy has been the R&D tax credit. Yet, 
making that current policy permanent was being argued by some on the 
other side as our having to raise taxes to pay for this current policy. 
No wonder Americans shake their heads.
  This is a good bill. This is an amazing bill. Go talk to your small 
business owners. Go talk to the accountant at the YMCA who puts 
together tax filings for people who care about the child tax credit and 
about the permanency in the child tax credit, about the New Markets tax 
credit--things that have an amazing impact on our communities, like the 
Low-Income Housing tax credit that Mr. Neal and I have worked on. 
Section 179's permanency is unbelievable. It is going to impact 
communities from coast to coast, including my district in Ohio and 
farmers as well. This is going to provide amazing certainty.
  I have been so pleased to work on a number of these issues with my 
Republican and Democrat colleagues. This, ladies and gentlemen, is a 
wonderful bridge to comprehensive tax reform.
  Mr. LEVIN. Mr. Speaker, I yield 1\1/2\ minutes to the gentleman from 
New York (Mr. Rangel).
  Mr. RANGEL. Mr. Speaker, I don't know how proud we can be as 
legislators to say, at the end of the year, instead of legislating--
having hearings,

[[Page 20381]]

listening to what this is going to do to help America, and where it is 
going to hurt--we are so proud of the fact that we are negotiating. 
Here we are talking about $680 billion of tax cuts, yet, we all know 
that, when we get home, there is nobody in the world who is going to 
think that their pockets, that their jobs, that their educations are 
going to be better.
  The world should be screaming for America to provide the leadership 
and to say that we have a system based on a Tax Code that we can depend 
on. Yes, we shouldn't have to extend these every year. We should work 
together to bring all of this together so that we know exactly what is 
going on.
  I hate to say this. People talk about the earned income tax credit. I 
fought for this. I am one of the people who goes against loopholes, and 
I guess I have really tried to get more loopholes in it in order for 
poor people to get some justice out of the tax system. The truth of the 
matter is, because of the disparity in incomes, because people work 
hard every day and they are still in poverty, we are going to use the 
Tax Code in order to say that we will give them a refundable tax 
credit.
  No. What this is going to do is to remove the ability for this great 
country of ours to have the discretionary funds to do the right thing, 
which is really conditioned in what we call the pursuit of happiness. 
We should not be using the Tax Code for social welfare, nor should we 
be using the Tax Code in order to have certain companies benefit from 
it.

                              {time}  1130

  What we should be doing is reforming the entire Tax Code so America 
would know where we are going and where we should be going.
  Mr. BRADY of Texas. Mr. Speaker, I yield 2 minutes to the gentlewoman 
from Kansas (Ms. Jenkins), a key member of our tax writing committee.
  Ms. JENKINS of Kansas. Mr. Speaker, I thank the gentleman for his 
good work on this issue.
  As I visit with folks at home in Kansas, they often express their 
frustration with Washington. Uncertainty is the enemy, whether in tax 
policy, regulatory policy, or health policy. Folks simply need to know 
what the rules will be so they can plan accordingly.
  As a former CPA who worked in the tax area and a former State 
treasurer, I have seen firsthand how uncertain tax policies that expire 
every year negatively impact our hardworking businesses and families. I 
am pleased we have secured a tax package that will bring much more 
certainty to families and businesses across the country fighting to 
create jobs in our still-struggling economy. This legislation will help 
bring us closer to the stable tax policies our economy desperately 
needs.
  This bill is another step in the right direction toward a confident 
America, built on principles and values that hard work should equal 
success. This legislation will grow our economy, put more money back in 
the folks' pockets, and rein in the IRS. With these foundations, we can 
continue to make strides towards a progrowth agenda that helps 
businesses succeed, creates more jobs, and stimulates the economy.
  Mr. LEVIN. Mr. Speaker, I yield 1 minute to the distinguished 
gentlewoman from California (Ms. Pelosi).
  Ms. PELOSI. Mr. Speaker, I thank the gentleman for yielding, and I 
thank him for his leadership on bigger paychecks for America's working 
families and in so many areas. Thank you, Mr. Levin, for your 
leadership.
  I congratulate Chairman Brady for assuming his new position. We all 
wish him success and look forward to working with him.
  The bill before us today calls for very serious discussion. We in 
this body have a very big responsibility to make decisions as 
architects of our children's future, where we are making decisions that 
strengthen the middle class and that take us to our responsibility to 
be custodians of our democracy.
  The middle class is the backbone of our democracy, and this 
legislation undermines the success of the middle class. In terms of 
children, their education, the financial security of their families, 
the pension security of their grandparents, the health of the 
environment in which they live, all of that is seriously affected by 
this legislation.
  Let's put it in perspective, because this is part of a grand scheme 
that started after President Clinton left office. In his term of 
office, because of the Budget Act of 1993 which passed with Democratic 
support, it unleashed a remarkable era of job creation, and it took us 
on a path to deficit reduction. In fact, five of his last budgets were 
even or in surplus, and that was taking us to a path of reducing not 
only the deficit--of course it would be eliminated--but the national 
debt.
  Along came tax cuts for the middle class, and in just a few years, 
all of the progress in reducing the deficit that occurred during the 
Clinton administration was reversed by the Bush tax cuts--unpaid for--
for the wealthiest. That unpaid for is really what my problem is here 
today.
  There are many provisions in this bill that we Democrats take 
ownership of and I personally take some personal pride in having worked 
on. For example, the earned income tax credit and the childcare tax 
credit, those initiatives we negotiated with President Bush to take 
them to the place that they are. They are a stimulus. They were debated 
and passed at the time as part of President Bush's stimulus package.
  When it comes to some of the initiatives like R&D, we have all been 
talking about modernizing and making permanent the research and 
development tax credit. The problem is, unpaid for.
  When we talk about 179, that is a creation of which Democrats were 
very much a part, which were the initiatives to help small businesses. 
We fully subscribe to that. But when we make them permanent--and that 
might be a good idea--and they are unpaid for, it also hurts our 
ability to do something broader in the Tax Code and take advantage of 
that opportunity.
  So low-income housing tax credits, again, I think I am second to 
none--except maybe Mr. Rangel--in this body in my advocacy for that, 
when Mr. Rostenkowski was the chairman of the committee. It is 
important that they are in this legislation, and they should be 
permanent.
  My problem with it all is why are these things--look, this is an 
engine to send jobs overseas with some of the provisions that are in 
the legislation, so it is like a Trojan horse. There are many good 
things, and then all of a sudden you find out what is in the belly of 
them.
  So the fact that they are permanent means that, for certain things 
like bonus depreciation and things like that, if they are for a short 
term, people will take advantage of them. We get the boost in our 
economy, and our Treasury from that.
  Here is what it comes down to: You go down this path of $600-plus 
billion of permanent, unpaid for tax extenders largely benefiting 
corporate America and say that doesn't have to be paid for. Oh, but, by 
the way, if you want to do $7 billion to honor the work of 9/11 first 
responders, you have to pay for every penny of it, find a way to do it 
by cuts or outlay or some other way.
  So what is the symmetry in all of this? Tax cuts for businesses to 
send jobs overseas, unpaid for and permanent; 9/11, which is an 
emergency, would you not agree? If there ever were an emergency, it 
would be 9/11. And the costs related to honoring our commitments, both 
in health and compensation to those workers, should be held up because 
we couldn't find pay-fors. Now we have, so that is good. We had to find 
the pay-fors.
  What I question very seriously is: What are the costs in the 
outyears? It is hard to determine, but they are there.
  What they are going to do is increase the deficit with such 
seriousness that our country will have to borrow from the Social 
Security trust fund to stay afloat, seriously undermining Social 
Security--and as our distinguished whip said, Social Security, 
Medicare, and the rest. It seriously affects this legislation, 
seriously affects our ability to make the discretionary investments in 
the education of our children, the promotion of growth, and the rest of 
that.

[[Page 20382]]

  So I think what it comes down to is, yes, there are some good ideas 
in here. We developed them. We support them. We don't even care if some 
of them are permanent. It is the unpaid for part of it that is 
mortgaging our children's future, that is threatening Social Security, 
and that undermines our ability to reduce the deficit and reduce the 
interest payments on the national debt.
  Again, we are walking away from what President Clinton did so 
successfully with a very difficult vote. We lost the Congress after 
that for that and other reasons. Some Members did. They said: I did the 
right thing because it took us on a path of fiscal soundness, and it 
took us on a path of economic growth. This, of course, was reversed in 
the Bush years. The $5.5 trillion of deficit reduction was--there was 
an $11 trillion reversal, one of the biggest, up until that time, of a 
reversal.
  My colleagues, I sympathize with some who say, well, I have always 
been for R&D tax credits, and others who say, well, it has to do with 
the tax stuff in my State and all that. I appreciate that, and I 
respect your judgment on it.
  There is a bigger picture here, and the bigger picture is our 
responsibility to the future. The chickens will come home to roost on 
this. We will have to pay. You know who is going to pay? Our children, 
their families, the Social Security system, and the rest.
  For that reason, I will not be supporting this, and I join our 
distinguished Whip Hoyer in urging our colleagues to vote against it as 
well. I know it sounds good. But, as I said, it is a Trojan horse, and 
we should not be fooled.
  Mr. BRADY of Texas. Mr. Speaker, I yield 2 minutes to the gentleman 
from Minnesota (Mr. Paulsen), the House leader of the efforts to stop 
the medical device tax.
  Mr. PAULSEN. Mr. Speaker and Members, the United States is the only 
country in the world that lets important parts of its Tax Code expire 
each and every year, and we are changing that here today. This 
bipartisan tax package prioritizes permanent tax relief for families 
and businesses so that they can keep more of their own money, they can 
hire new workers, and they can invest in new equipment.
  It also does include the repeal of the medical device tax that has 
been in place, and it stops it for the next 2 years, a tax that has 
cost our economy jobs and has also reduced innovation.
  What has been the result of this tax? One small business I spoke with 
said it is pretty simple. Instead of having 10 projects, I will have 6, 
which means 2 fewer engineers and 2 fewer technicians.
  Another company I spoke to says, because it is a tax on sales and not 
on profit, they testified it is a 79 percent effective tax rate that 
they have. How can anyone justify a 79 percent effective tax rate? 
Another company said they are borrowing money from the bank every 
single month just to pay the tax in the hopes and taking the risk that 
they will actually become profitable.
  Of course, a constituent I spoke to, Jim, he told the story of losing 
his job at a medical device company that he had for 21 years. He was 
laid off. He eventually was rehired, but his job paid $40,000 less, his 
vacation time was halved, and his health costs skyrocketed.
  Of course, patients are suffering also because we have fewer 
lifesaving and life-improving technologies here developed in the United 
States.
  Mr. Speaker, this tax package helps our economy, and it gets us back 
on track with a progrowth Tax Code. I will say that our local 
businesses are really excited about ending the guessing game of 6-
month, 1-year, retroactive tax policy and instead giving clarity, 
predictability, and certainty so they can invest in their people and 
they can invest in their equipment.
  I ask my colleagues to support this legislation.
  I thank the chairman for his leadership.
  Mr. LEVIN. Mr. Speaker, I yield 3 minutes to the gentleman from 
Massachusetts (Mr. Neal).
  Mr. NEAL. Mr. Speaker, the bill we have before us today is the 
universal legislator's dilemma: the possible versus the perfect.
  I rise in support of this legislation today. I stand with President 
Obama in support of this legislation today.
  I rise to prevent 18 million Americans, including 8 million children, 
from falling deeper into poverty.
  I rise to ensure that, during this special time of the year, 
nonprofits will continue their important work to improve the lives of 
millions of Americans through charitable activity.
  I rise to unleash billions of dollars in economic development to 
rebuild, to rehab, and to refurbish our neighborhoods and our 
communities.
  I rise to incentivize American innovation and the millions of jobs 
that it creates. At this bill's core is a modest progrowth jobs bill, 
one that, given the current headwinds of our economy, is sorely needed.
  I have spent the better part of my career in Congress as a champion 
of the earned income tax credit and expanding it, as a champion of the 
child tax credit and expanding it, as a champion of the low-income 
housing tax credit and expanding it and the expansion of the New 
Markets Tax Credit Program, which my DNA clearly is on.
  Taken together, these credits will go a long way to toward improving 
the lives of millions of Americans across the country in our typically 
overlooked communities.

                              {time}  1145

  This is not the easiest way to accomplish an end. We should be very 
critical of ourselves now for the backup manner in which we do these 
undertakings--voting on 12 legislative appropriations bills tomorrow 
wrapped into 1; tax policy that is done in this shape and manner.
  I will also say something else that we need to remind ourselves of: 
the breakdown of the committee structure in Congress. What has happened 
to the procedures that we all use to vet controversial legislation? 
Amendments could be offered and people could speak their minds.
  Today we are taking up issues that should have been vetted over the 
course of the last 3 years. I offer a gentle rebuke to my colleagues on 
the other side. Chairman Camp had the backbone to put out a decent 
piece of legislation. It didn't mean we were going to embrace it or 
endorse it, but it was a courageous act, and it was his own side that 
shot it down.
  In Cambridge, Massachusetts, Kendall Square has the highest 
concentration of research and development today in the world. Making 
the R&D tax credit permanent is going to enhance that opportunity. I 
have worked on the R&D credit and pushed for a more aggressive, 
predictable R&D credit through my entire years in this Congress.
  This is not perfect, what we are doing today. It is far from it. But 
it represents a compromise or, as The New York Times called it, an 
acceptable compromise that is necessary to move the country forward.
  Mr. Speaker, I urge its adoption.
  Mr. BRADY of Texas. Mr. Speaker, I yield 2 minutes to the gentleman 
from Washington (Mr. Reichert), the former leader of our Subcommittee 
on Tax Policy.
  Mr. REICHERT. Mr. Speaker, I thank the chairman for yielding and for 
his hard work on this bill.
  We are here in Washington, D.C., talking about tax reform, and we are 
throwing around tax terms like built-in gains, bonus depreciation, 
research and development, R&D, and on and on and on.
  People back home I think really, for the most part, don't get all of 
that talk, but they do understand when we are talking about reducing 
their taxes, when we are creating an environment where businesses can 
thrive, where businesses can reinvest their capital back into their 
hard work, their small businesses, create jobs, sell their products, 
and hire more people. That is what this bill is about.
  Just three quick examples of constituencies that I am hearing from in 
my district:
  One, the teachers in Washington State. They really appreciate the 
fact that there is certainty now that they

[[Page 20383]]

can deduct the amount of money they spend up to $500 on school 
equipment to help our children learn. Every year or 2 years we go 
through this exercise of deciding whether or not we are going to 
support our teachers. They have certainty. This is not about big 
businesses. These are teachers.
  Two, small businesses, S Corporations, can now with certainty have 
access to revenue. Rather than waiting 10 years, they can have it in 5. 
They can sell equipment that they had to sit on for 5 years or 7 years. 
Now they can sell that equipment and buy new equipment, creating more 
jobs and selling more products.
  Three, for Washington State especially, the permanency in sales tax 
is a big deal. The permanency in our ability in Washington State--I 
think one of seven States in this country--to deduct our sales tax from 
our Federal income tax creates certainty for every taxpaying citizen in 
Washington State. This is a big deal.
  These three small, little provisions are big deals for the average 
American across this country in Washington State and in the Eighth 
District of Washington State that I serve.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from Texas 
(Mr. Doggett), another distinguished member of our committee.
  Mr. DOGGETT. Mr. Speaker, the nonpartisan Committee for a Responsible 
Federal Budget has said that, over two decades, this very bill will add 
over $2 trillion to the national debt.
  For anyone who hides behind poor kids to justify that $2 trillion in 
debt, understand that there is no poor child in America who will get a 
dime out of this bill next year. Their tax credits do not expire now. 
We have more than another year to resolve that matter.
  No, this isn't about poor children. It is about big gifts. Indeed, in 
the holiday spirit, the biggest bow of all has been put on a special 
gift for Wall Street. The world's largest financial institutions, you 
know, the ones that brought America to its economic knees with the 
debacle over finances and then came forward and got a majority of this 
Congress--not me--to vote for a taxpayer bailout, well, they are back 
here again, and they are getting a reward.
  They are getting a tax subsidy that is made permanent. It just 
happens to be a tax subsidy that was removed from our Tax Code 
originally in a bill that Ronald Reagan signed into law. When it got 
put back in on a temporary basis, Bill Clinton sought to veto the 
provision because it was so unjustified.
  Christmas, of course, is not cheap. This bill, this gift to Wall 
Street, costs $78 billion--not paid for--borrowed from the Saudis and 
from the Chinese to give Wall Street $78 billion, with a ``B.''
  How much money is that? Well, about the same amount is included in 
the bill this will be a part of. It funds all the medical research at 
the National Institutes of Health, the Centers for Disease Control, all 
of Head Start across the country, and all of the education for the 
disabled and disadvantaged that is provided by the Federal Government. 
All of that combined is $78 billion. But you can be sure that Wall 
Street is never disabled or disadvantaged in the Capitol.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Mr. LEVIN. Mr. Speaker, I yield an additional 30 seconds to the 
gentleman.
  Mr. DOGGETT. This $78 billion tax subsidy is called the ``active 
financing exception.'' My, my, these bankers have been active here. 
They may have been very naughty to the American people. They may have 
been very naughty to the American economy. But they have been, oh, so 
nice to some Members of Congress.
  Republicans and some Democratic enablers are helping keep a provision 
in here that will only lead to shipping jobs overseas. They are 
borrowing from overseas to put this burden on the American people. This 
is the kind of provision that causes Americans to be so concerned about 
their government and a feeling that it has run away from them because 
these kinds of provisions are running away our debt and denying the 
support for Make It In America that we need.
  Mr. Speaker, I urge the rejection of this package that will do so 
much harm to our country.


                             General Leave

  Mr. BRADY of Texas. Mr. Speaker, I ask unanimous consent that all 
Members may have 5 legislative days in which to include extraneous 
materials to the motion now under consideration.
  The SPEAKER pro tempore. Is there objection to the request of the 
gentleman from Texas?
  There was no objection.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1\1/2\ minutes to the 
gentleman from Nebraska (Mr. Smith), a big fighter for American 
agriculture who serves on the Committee on Ways and Means.
  Mr. SMITH of Nebraska. Mr. Speaker, I thank the chairman for his 
efforts on better tax policy. The U.S. Congress owes the American 
people better tax policy than we currently have.
  We currently have so many temporary provisions that so many Americans 
are wondering and trying to predict what the tax policy will be by the 
end of the year. That is not what we should be about. We should be 
about establishing permanent tax policy whenever we can.
  I appreciate the bipartisan interest in today's bill because I know a 
lot of work has gone into this. I know that constituents in Nebraska's 
Third District can appreciate what permanent tax policy can deliver, 
especially as it sets us on a trajectory to comprehensive tax reform.
  We hear from both sides that we need comprehensive tax reform. I 
agree. This is a great way to move the ball down the field. We can end 
up with better tax policy today as a result of this legislation. I urge 
my colleagues to adopt this legislation.
  Mr. LEVIN. Mr. Speaker, how much time remains on each side?
  The SPEAKER pro tempore. The gentleman from Michigan has 15\1/2\ 
minutes remaining. The gentleman from Texas has 15 minutes remaining.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from 
California (Mr. Thompson), another distinguished member of our 
committee.
  Mr. THOMPSON of California. Mr. Speaker, I stand today in support of 
many of the provisions that are in this bill. I, too, believe that we 
need to bring permanency to our tax policy.
  One of the pieces of this legislation that we are debating today is 
one that is very near and dear to my heart, something I have worked on 
since the day I got to Congress, and that is the conservation easement 
provision, which has helped all of our districts a great deal. That, 
too, needs to be made permanent.
  But I stand in opposition to the overall bill. It is not because it 
is bad policy. We all agree that a lot of the provisions in this bill 
are good public policy. We should pass them. We should make them 
permanent.
  But, sadly, this bill is fiscally reckless. We are going to pass this 
policy, and we are going to send a nearly $700 billion bill on to the 
taxpayers of this country.
  In his comments, my friend, the gentleman from Louisiana, said that, 
for every piece of legislation in here, they have had hearings, they 
have had markups, and they have taken these to the floor. He is 
absolutely correct.
  We have done everything except make sure this bill is paid for. That 
is a responsibility that all of us should take seriously. We should not 
pass tax expenditures without paying for them.
  I urge a ``no'' vote on the bill.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1 minute to the gentlewoman 
from Tennessee (Mrs. Black), a member of our committee who is a 
champion of the State and local sales tax deduction.
  Mrs. BLACK. Mr. Speaker, I rise today in strong support of the 
Protecting Americans from Tax Hikes Act, which includes a permanent 
extension of the sales tax deduction that is so critical for Tennessee. 
We are proud to be one of only nine States in the Union without an 
income tax on wages.
  Taxpayers in other States are able to deduct their State income tax 
on their Federal returns. It only makes sense that a similar deduction 
would be made available in States like mine that exercise our right not 
to pile on additional income tax on our own.

[[Page 20384]]

  As the only Member of the Committee on Ways and Means from the State 
of Tennessee, I was proud to work with Chairman Brady to ensure the 
inclusion of this much-needed provision in today's bill. I am also 
pleased that this legislation includes language to combat educational 
tax fraud.
  Specifically, this bill requires that individuals claiming the 
American Opportunity Tax Credit provide the employer identification 
number of the educational institution they are attending, in turn, 
saving our tax system an estimated $837 million in fraudulent payments.
  I urge passage of the Protecting Americans from Tax Hikes Act.
  Mr. LEVIN. Mr. Speaker, I yield 2\1/2\ minutes to the gentleman from 
Oregon (Mr. Blumenauer).
  Mr. BLUMENAUER. Mr. Speaker, I, too, have been deeply concerned about 
the long-term trends of our failing to come forward with revenue to pay 
for America's priorities. I found the Bush tax cuts a disaster.
  I have repeatedly brought before my friends in Congress proposals to 
actually fund our priorities. I look forward to doing so again, either 
stand-alone or in the context of comprehensive tax reform.
  I am prepared, however, today to support the provisions before us. 
First of all, I think the cost ought to be put in perspective because 
these items are ones that have been routinely approved year in and year 
out, not particularly paid for, and they are ones that will be approved 
again.
  My friend, the distinguished minority whip, talked about it is better 
to do just 2 years. Doing it on an ongoing basis for 2 years continues 
to have the same cost, but provides uncertainty for people who depend 
upon it.
  There are a number of provisions here that we all worked on: wind, 
solar, new markets, short line, transit parity, CIDER Act. These are 
items people deserve to have some clarity on moving forward for 
numerous provisions that ultimately would pass, but we would hold 
people in suspense until the end.
  But I want to speak to one particular item here. My good friend from 
Texas said you don't have to worry about the earned income tax credit 
or the child tax credit because they don't expire until next year.
  Well, I would respectfully suggest that, if we followed that path and 
waited until 2017, not in the context of this total package, I think we 
are putting at risk significant tax relief for working, low-income 
Americans and their families.

                              {time}  1200

  Left alone, there would be a huge price to be extracted from some in 
Congress who aren't particularly supportive of this Democratic 
priority. It would put at risk the support for these 16 million 
Americans, half of whom are children, and 164,000 Oregonians.
  I think adopting it in this package and making it permanent is a far 
superior approach to guarantee that. Then, by all means, let's roll up 
our sleeves and work on the provisions together. There is going to be 
lots to argue about, but in the meantime, I feel comfortable supporting 
those priorities--and particularly for low- and moderate-income 
Americans.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1\1/2\ minutes to the 
gentleman from New York (Mr. Reed), who has been a key leader of the 
Ways and Means Committee on manufacturing and energy.
  Mr. REED. Mr. Speaker, I thank the chairman for yielding, and I thank 
him for his hard work, as well as the folks on the other side of the 
aisle who have come together to support this legislation, as I do, 
today.
  Mr. Speaker, hardworking taxpayers across America deserve a fairer, 
simpler Tax Code, and one that allows them to keep more of their hard-
earned dollars. That is exactly why I support this legislation, as it 
is a step in the right direction along that path.
  The other important aspect of this legislation is it brings certainty 
to our manufacturers and the energy sector in regard to these 
provisions that are temporarily extended each and every year, as my 
colleagues have recognized over and over again, and now, to a large 
extent, we make permanent. That allows them to plan for tomorrow. That 
allows them to make the investments with their hard-earned dollars in 
the places they choose to put that money. And they can rely on a Tax 
Code now that is certain, simpler, and fairer on their behalf.
  We also take care of hardworking families in this bill. We also take 
care of people in our bill, the Mortgage Forgiveness Act and the 
America Gives More Act, where we talk about charitable donation of food 
inventories.
  That is the right policy for the American people. That is the right 
policy for hardworking taxpayers across America. And I am glad that we 
have on the floor today an opportunity to demonstrate to hardworking 
taxpayers that we care about them and that we are going to put their 
interests first and foremost, rather than those of Washington, D.C., 
and of the elected officials here.
  Mr. BRADY of Texas. Mr. Speaker, I yield 2 minutes to the gentleman 
from Pennsylvania (Mr. Kelly), another key member of our committee, who 
brings such local business sense to the issue of taxes.
  Mr. KELLY of Pennsylvania. I thank the chairman for yielding.
  Mr. Speaker, I rise in strong support. This is one of the things that 
I think really makes us a little bit different. It is about certainty. 
And where I am from, there is an old saying: If you don't know where 
you are going, any road will get you there. Well, people who run 
businesses actually have to know where they are going before they 
start. So this does bring some honesty to what it is that we need to 
do.
  But in a time when people talk about ``I'' and ``me''--and that is 
what I hear most of the time--I want to talk about all the other 
people: the ``we's'' that got together. This is truly a joint effort 
between a lot of staff members. It is not just Members of Congress, but 
staff members.
  So, if I could just for a second thank the committee's tax team: 
George Callas, Mark Warren, Harold Hancock, John Sandell, Aharon 
Friedman, and Jennifer Acuna. They have put in unbelievable amounts of 
time on this to get this done not for the Republican Party, but for the 
American people. How refreshing it is at this time of the year to 
actually give back and do something for others--and do it in a way that 
just makes common sense to everybody out there who has to know where it 
is that they are going.
  There is something about certainty that gives us the confidence to go 
forward and that gives us that assuredness that we can actually get 
there. This is an incredible opportunity. This is really historic.
  So I want to thank Members on both sides. I think the American people 
will sit back and say: This is the place where these guys and girls 
can't get together on anything. I would just say that is not true. This 
is truly bipartisan. It has taken an awful lot of work by an awful lot 
of people. So I want to take time to thank them for what they did. They 
are incredible people and great patriots.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from 
Wisconsin (Mr. Kind), another distinguished member of our committee.
  Mr. KIND. I thank my friend for yielding.
  Mr. Speaker, I am all for certainty. I am all for predictability. I 
am all for a lot of the policy initiatives that are contained in this 
legislation before us. But what I am not in favor of is the fact that 
this $700 billion bill is not paid for. Not a nickle of it is offset.
  When I go home to Wisconsin, I constantly hear from folks back home 
for Congress to pay our bills and to get our fiscal house in order. 
This legislation doesn't do it. It is $700 billion over the first 10 
years. It explodes to $2 trillion in the second 10 years.
  There is nothing more dangerous for the long-term success of Social 
Security and Medicaid or our children's future than these end-of-the-
year, large tax cut packages that are not paid for and that are not 
offset.
  It is a missed opportunity. We should be doing this within the 
context of comprehensive reform. I submit that

[[Page 20385]]

by going forward and making permanent many of these provisions in the 
legislation today, it takes the wind out of the sails of tax reform in 
the future.
  There has been an implicit agreement when we do comprehensive reform 
that we are going to do it in a way that builds in certainty, 
encourages investments, makes us more competitive globally, but we 
don't blow a hole in the deficit and our children's future at the same 
time. Chairman Camp recognized that with the discussion draft. He made 
hard choices to pay for the lowering of rates and the broadening of the 
base. We are ducking that responsibility here today.
  The irony is that every bipartisan deficit reduction commission that 
has been asked to try to come up with a plan to get our fiscal house in 
order has reached the same conclusion: We are going to need some 
additional revenue in the future and long-term spending reforms in 
order to accomplish it. This legislation fails on both of those fronts.
  So I would encourage my colleagues to vote ``no'' on this 
legislation. We can continue temporarily to extend many of these 
important provisions today, but let's keep the pressure on 
comprehensive reform. By doing this now, I submit that we are punting 
on the opportunity in the very short future to take on a Tax Code that 
has been long overdue for reform since 1987.
  I encourage my colleagues to vote ``no.''
  Mr. BRADY of Texas. Mr. Speaker, I yield 1\1/2\ minutes to the 
gentleman from Ohio (Mr. Renacci), a key member of our committee who 
has extensive business experience.
  Mr. RENACCI. Mr. Speaker, I want to thank the chairman and his staff 
for their hard work.
  Mr. Speaker, I rise today in support of the Protecting Americans from 
Tax Hikes Act, or the PATH Act.
  I came to Washington as a business owner and CPA to reform our broken 
Tax Code and protect hardworking American taxpayers. Many of those 
taxpayers come to my office on an annual basis, looking at many of 
these extenders and not really understanding whether they were 
permanent or not permanent, whether they had them or would have the 
opportunity to use these credits. This package here makes many of those 
credits permanent.
  The PATH Act is an important first step forward in allowing us to 
reform our broken Tax Code. This legislation will make several tax 
policies permanent, such as the R&D credit and small business 
expensing. It will provide certainty and predictability to our 
businesses and individuals. And most importantly, it will help open the 
door to economic growth.
  This legislation also removes unnecessary tax compliance burdens. The 
PATH Act includes a bill I introduced with many of my colleagues, 
including many on the Bipartisan Working Group that I formed many years 
ago. The Information Reporting Simplification Act of 2015 is in the 
bill. This bipartisan, commonsense legislation provides a safe harbor 
to eliminate the need to correct minor errors on tax forms that have de 
minimis impact on the tax liability outcome, and helps avoid the waste 
in time and dollars for businesses and individuals that would otherwise 
have to refile their tax returns.
  Mr. Speaker, the PATH Act is an important first step in fixing our 
Tax Code, and I urge my colleagues to join me in support.
  Mr. LEVIN. Mr. Speaker, I yield 2\1/2\ minutes to the gentleman from 
California (Mr. Becerra).
  Mr. BECERRA. I thank the gentleman for yielding.
  Mr. Speaker, there are pockets of Americans who might like the tax 
break here for corporations or the tax break there for wealthy folks 
who want to donate some of their IRA. But for the 320 million Americans 
in the country, and particularly for the 147 million Americans who file 
Federal tax returns, my guess is they are more concerned about their 
security and that of their children--their personal security, our 
national security, and our economic security.
  After San Bernardino, Colorado Springs, Charleston, and Newtown, 
where Americans were senselessly gunned down in our schools, at work, 
and in our places of worship, the American people want job one of this 
Congress to be security--personal, national, and economic.
  So why, 2 weeks after 32 Americans were terrorized and 14 of them 
killed in San Bernardino, would we make this massive, $600 billion tax 
break giveaway and charge it to the government credit card--because 
remember, it is not paid for--the first major legislation to come 
before this House for a vote?
  We can all agree that the FBI does important work keeping us safe, 
tracking down terrorists. We all agree that they need to do more. So 
why would we be voting for this bill, which will rob funding for 
everything from the FBI to food safety to college Pell grants?
  The cost of this bill would fund the FBI for the next 73 years--
because, remember, these tax breaks are not paid for. We have got to 
pay for them somehow. If you were to add up the cost of this tax break 
bill, it could fund the FBI for 73 years. And why would we use the 
credit card for people who can give up their IRAs, when most Americans 
can't even put enough money into one basic IRA?
  This is wrong-headed. These are not the American people's priorities. 
We can do this right. We can reform the Tax Code. But this is not the 
reform that the American people are asking us for. They are asking us, 
first and foremost, to keep our eye on the prize: our security, my 
kids' security, your kids' security, our national security, and our 
economic security.
  You give away this money to corporations, you give it away to wealthy 
folks, and guess what? Can that person who has to think about the job 
and worry whether he or she is safe at the job or their kids are safe 
at school or can you go worship safely, are they going to be able to 
send their kids to college, buy that home, and retire in security? 
Think about it.
  I urge my colleagues to vote ``no'' on this legislation.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1 minute to the gentleman 
from North Carolina (Mr. Holding), a member of the Ways and Means 
Committee who has focused on making companies competitive here and 
around the world.
  Mr. HOLDING. Mr. Speaker, the PATH Act will provide much-needed 
certainty to our Nation's families and small businesses and, most 
importantly, lay the foundation for comprehensive tax reform.
  For far too long, folks in North Carolina had to face the burden of 
trying to grow their businesses and plan for the future while being 
forced to operate under a tax system comprised of temporary tax 
provisions whose fate is unpredictable.
  With this bill, farmers in my district will be able to purchase a new 
tractor without having to gamble on whether Congress will extend the 
expensing provisions they depend on. In the Research Triangle Park, 
innovative companies will finally be able to access the R&D credit to 
further support their groundbreaking research without being concerned 
as to whether Congress will extend the credit or not.
  Mr. Speaker, importantly, it is imperative that we continue to build 
on this progress. This bill is an important first step towards 
comprehensive tax reform that simplifies the Tax Code, lowers the rate, 
and makes America competitive around the world.
  I urge my colleagues to support the PATH Act.

                              {time}  1215

  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from New 
Jersey (Mr. Pascrell), a distinguished member of our committee.
  Mr. PASCRELL. Mr. Speaker, let's cut to the chase. I support this 
legislation. It wasn't an easy decision, but I believe that Democrats 
were able to get a lot of policies into the bill that are good for the 
middle class. It is going to help 16 million Americans out of poverty.
  In New Jersey, 435,000 children and 219,000 families will lose some 
or all of their working family tax credits if we don't do this.
  This package includes a bill introduced by my friend from New York,

[[Page 20386]]

Tom Reed, and myself to help put people back to work. Our tax credit 
for businesses who hire long-term unemployed Americans--and we have 
abandoned them, let's face it--will help those families who haven't yet 
felt the effects of our economic recovery.
  Another bill the gentleman from Washington (Mr. Reichert) and I co-
authored supports our Nation's hardworking teachers. You heard him 
speak about it just several minutes ago.
  Both of these bills are part of the tax package before us today. And 
as the gentleman from Oregon (Mr. Blumenauer) said, these things pass 
routinely anyway.
  Who the heck are we kidding? The enemy of the good is the perfect. 
Over and over and again we prove that here on this floor.
  An important provision allowing public safety officers to withdraw 
from their pensions when they retire early without a tax penalty is 
included in this package.
  There are provisions that support mass transit commuters, small 
businesses, low-income housing, families paying for college, economic 
development.
  The earned income tax credit and the child tax credit are our biggest 
forces against poverty in this country, in this Nation. I can't say 
enough about the significance of making these enhanced credits 
permanent.
  But when faced with the choice between these important priorities for 
families, for teachers, for public safety officers, I simply can't, in 
good conscience, vote against them to prove a point that not everything 
is in there, including the kitchen sink. The bill is far from perfect.
  And in conclusion, let me say this. I think this has been a civil 
debate, and that is healthy for us, all of us, regardless of what 
happens in the vote.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1\1/2\ minutes to the 
gentleman from Illinois (Mr. Dold), a member of our committee who has 
focused on working families in Illinois.
  Mr. DOLD. Mr. Speaker, I thank the chairman for his leadership and 
for yielding time.
  Today we are voting on a historic bill. Frankly, as a small-business 
owner, when I came to Congress, it was largely because I felt the 
government was making it harder and harder for me to put the key in the 
door and open up my small business each and every day. They should be 
making it easier for me to open up my business, easier for me to hire 
that next individual.
  I hear from small businesses each and every day, that they need more 
certainty. If they had the certainty, they would be able to move 
forward. Instead, they sit on their hands.
  These tax policies that we are voting on today, what a difference a 
year makes. A year ago this December, we were extending these tax 
extenders, and we made it for 1 year, which was retroactive. My 
goodness gracious, retroactive tax policy. I can't imagine anything so 
asinine. This package today, this historic package, talks about making 
many of these provisions permanent.
  The R&D tax credit, if we want to talk about innovation, we want to 
talk about moving our country forward and being on the leading edge, 
this R&D tax credit is absolutely vital for small businesses that want 
to expense equipment. We make that permanent. It is absolutely vital 
that we are jump-starting our economy and growing more American jobs.
  But it is not just for the businesses in here. We are also protecting 
families. We are also helping families pay for higher education.
  We have incentives for charitable giving. Now listen. There are some 
that say the government should be the one that determines where these 
dollars go, but I would argue for putting that choice into the hands of 
the American people as to where they can put those dollars into the 
charitable organizations that they care about. Those dollars will go so 
much further.
  That is exactly the type of bipartisan legislation that the American 
people not only want, but expect, from this body.
  We also have so many other great things in this package: transit 
parity, development for affordable housing.
  I urge my colleagues to come together in a bipartisan way and 
resoundingly pass this package.
  Mr. LEVIN. Mr. Speaker, I yield 2 minutes to the gentleman from 
Illinois (Mr. Danny K. Davis), another very active member of our 
committee.
  Mr. DANNY K. DAVIS of Illinois. Mr. Speaker, I have been told that 
all that glitters is not gold. There isn't much that is absolutely 
perfect, and this extender package certainly is not.
  However, I am pleased to note that it does make the child tax credit 
permanent, the American opportunity tax credit permanent, the earned 
income tax credit permanent, extends deductions for expenses for 
elementary and secondary schoolteachers, extends deductions for State 
and local general sales tax, extends deductions for certain charitable 
giving, and extends deductions for research activities, which helps to 
create jobs.
  The new market tax credit has been beneficial to districts like mine 
all over the country, and I am indeed pleased to see it extended.
  The work opportunity tax credit is a godsend for long-term 
unemployed. I have worked on an issue called Work Colleges, and I am 
pleased to note the exemption for students who work under this 
provision.
  I am also pleased to note the elimination of residency requirements 
for disabled individuals who are eligible for the ABLE program. I am 
also pleased to note the exclusion for wrongfully incarcerated 
individuals.
  Mr. Speaker, these extensions are good. I am not sure that they are 
going to do enough. They are not paid for, and I am not sure that they 
are going to do as much for low- and moderate-income families and 
communities as I had hoped, or for job creation or for disadvantaged 
areas. I am convinced that they will do good, but I am not sure that 
they will do enough.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1 minute to the gentleman 
from Pennsylvania (Mr. Meehan), one of the members of the Ways and 
Means Committee focused on small businesses and on ending this medical 
device tax.
  Mr. MEEHAN. Mr. Speaker, I thank the chairman.
  Let me express my support for this, really, through the people that I 
represent. I try to think about: How does it make a difference in their 
lives?
  It does for the person looking for a job. And we see that jobs are 
created by small business, and this is the kind of a program which we 
have now given certainty to the entrepreneurs that will create new jobs 
and, therefore, new revenue by somebody who is back to work.
  We appreciate teachers who take money out of their own pocket. It is 
not a big dollar amount, but we say thank you for making your 
commitment to our children.
  We appreciate our communities with conservation easement that will 
allow us to preserve the beauty, particularly in areas in which open 
space continues to be an issue.
  But I think it is in the issue of health care, families struggling 
with diseases, that now we incent the kind of research and development 
to make a change; and then, ultimately, when we do have the products 
that we can bring to market, we are not taxing them and driving them 
further away from the consumer.
  For all of these reasons, it makes a difference to the people in a 
positive way, and that is why I urge my colleagues to be supportive.
  Mr. LEVIN. Mr. Speaker, I reserve the balance of my time.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1\1/2\ minutes to the 
gentleman from Illinois (Mr. Roskam), a key member, the leader of our 
Oversight Subcommittee who authored many of the IRS reforms that are in 
this bill.
  Mr. ROSKAM. Mr. Speaker, I thank Chairman Brady.
  Not long ago, the Internal Revenue Service reached out its long arm 
and decided to try and get between donors and 501(c)(4), (c)(5), and 
(c)(6) organizations. The IRS did something that was really 
provocative.
  What they said was--they created a false impression, and they sent 
letters

[[Page 20387]]

to donors that had a chilling effect and said: We know that you made 
this contribution, but we think we may have a tax liability for you 
there. You can imagine how this had a shuddering effect all throughout 
these areas. And lest people think that this is a left-right issue, it 
is not. Left and right were both under a great deal of threat here.
  So I am really pleased that in this extenders package is something 
that has had broad bipartisan support and bicameral support and support 
from both the political left and the political right, and that is to 
say that gifts to 501(c)(4), (c)(5), and (c)(6) organizations should be 
tax exempt, and the IRS ought not be manipulating and intimidating and 
so forth. So, Mr. Speaker, what this does is it makes sure that the IRS 
is boxed in and that there is no gift tax liability.
  I strongly support this package, and I thank Chairman Brady.
  Mr. LEVIN. Mr. Speaker, I reserve the balance of my time.
  Mr. BRADY of Texas. Mr. Speaker, I am pleased to yield 1 minute to 
the gentlewoman from Indiana (Mrs. Walorski), who has been a key 
proponent of tax relief for families and small businesses.
  Mrs. WALORSKI. I thank the chairman for yielding.
  Mr. Speaker, I rise in strong support of the Protecting Americans 
from Tax Hikes Act. There are many great pieces of this bill, but I 
want to highlight two in particular that will help Indiana's economy.
  For decades, the research and development tax credit has relied on 
short-term extensions, leaving innovators in complete limbo. Today, we 
are making it permanent, giving innovative industry the confidence to 
make investments here in the United States. Indiana is also home to 300 
medical device companies, employing over 20,000 people, and stands to 
benefit greatly from this certainty.
  I am also thrilled today that we are delaying the damaging medical 
device tax for 2 years. This misguided tax will cost jobs, harm 
patients, and I look forward to the day that we can fully repeal it.
  Mr. Speaker, our Tax Code is a mess; but today we have an opportunity 
to give certainty to individuals, to families, charities, and job 
creators, and we can take another step forward toward comprehensive tax 
reform.
  Mr. LEVIN. Mr. Speaker, I reserve the balance of my time.
  Mr. BRADY of Texas. Mr. Speaker, I yield 1 minute to the gentleman 
from South Carolina (Mr. Sanford), who is a strong proponent of 
progrowth tax reform.
  Mr. SANFORD. Mr. Speaker, I rise as a fiscal hawk. I rise as one who 
believes passionately in the issue of the debt and the deficit and 
government spending, but one who believes that we can't pretend our way 
to fixing those problems and that the first part of fixing a problem 
lies in actually recognizing that you have a problem. Yet the reality 
is that, for the last 30 years or so, we have pretended that which was 
permanent was impermanent, which makes, overall, this notion of tax 
reform incredibly difficult.
  Ronald Reagan once observed that the closest thing to eternal life 
was a government program. It is true with regard to tax policy as well.
  So I just applaud the committee for the way that they have moved us 
to a place where we can move to a fair tax, a flat tax, changing the 
Tax Code to make the system fairer and flatter, more equitable for all 
and then, frankly, get rid of some of the provisions that don't belong 
in this Tax Code.
  Mr. LEVIN. Mr. Speaker, I yield myself the balance of my time.
  Well, here we go again, $622 billion added to the deficit, and when 
you include interest on the deficit, far more. No hard choices. We are 
making a bad choice.
  There has been lots of talk here about certainty. What is certain 
with this bill is that it will lead to further starving what the 
Republicans call the beast: adequate domestic spending for education, 
for health, for job training, for nutrition programs.
  What is also certain is that it is going to make it easier for 
Republicans to cut taxes for the very wealthy.

                              {time}  1230

  That has always been one of the major purposes of all these bills 
making permanent unpaid-for tax cuts. It is also certain with this bill 
that we will keep loopholes that need to be closed.
  For all of these reasons, Mr. Speaker, I think the cost is much too 
high. There are some important provisions here, but their significance 
I think is really overwhelmed by the fact that we are going to add 
money to the deficit and have consequences for the long term.
  Mr. Speaker, I urge opposition to this bill.
  Mr. Speaker, I yield back the balance of my time.
  Mr. BRADY of Texas. Mr. Speaker, I yield myself such time as I may 
consume.
  Mr. Speaker, I first want to thank the Ways and Means members who 
have for years and years worked on making these important tax relief 
provisions permanent and who have continued with me to stay at the 
table to work through an agreement that finally provides tax relief 
that families and businesses can count on.
  Mr. Speaker, that wouldn't have been possible without an extremely 
talented professional staff. Our tax team, led by Mr. George Callas, 
did remarkable work in crafting this tax relief permanent measure. For 
that I say thank you.
  This is a historical day. Today we end business as usual in Congress, 
and we take an important first step to progrowth tax reform. This bill 
provides tax relief families and businesses can finally count on. It 
reins in the IRS and protects taxpayers. It includes the first 
significant antifraud provisions in the IRS tax credit program since 
the 1990s. It finally creates true, honest accounting of our Tax Code.
  It spends no more than what we spend each year as Congress lurches 
December to December trying to decide what is permanent, what is 
temporary, and what can people count on. Today we heard arguments that 
these tax savings advance terrorism, starve children, and are 
apparently responsible for the breakup of the Beatles.
  The truth of the matter is, Mr. Speaker, extending these provisions 
year by year is no less--the math is no different than simply 
acknowledging that it is going to be done and doing it permanently so 
that we can actually create tax relief our families and businesses can 
count on.
  Mr. Speaker, this is not the end of tax reform. This is a serious 
first step to progrowth tax reform that is built for growth, built for 
the growth for families' paychecks, built for the growth of our local 
businesses, and built for the growth of America.
  We have got work to do. Today we start that work. Let's get to work.
  Mr. Speaker, I yield back the balance of my time.
  Mr. KIND. Mr. Speaker, I rise today in support of a number of the 
policies included in the PATH Act, but in opposition to fully paying 
for it.
  As a member of the Ways and Means Committee, I have long supported a 
number of provisions included in the PATH Act on the floor today. A 
number of these provisions are vital for our businesses to operate; 
others are critical to helping families plan for the year ahead. I have 
worked closely with Congressman Tiberi on an enhanced Sec. 179 
expensing limitations for small businesses and with Congressman 
Reichert on the reduction of S-corporation recognition period for 
built-in gains tax. I appreciate the dedication of my partners across 
the aisle to working with me to see these proposals over the finish 
line and signed into law.
  Within the PATH Act, I am pleased that the 50,000 families in my 
district who receive the Child Tax Credit and the 40,000 who benefit 
from the Earned Income Tax Credit will be able to count on these 
benefits in the years to come. Many new provisions in this package are 
important to me and our communities, including my bill with 
Congresswoman Jenkins to improve section 529 accounts to help our 
students save for college more effectively. I am also pleased to see 
the inclusion of the provision allowing rollovers from 401(k)s to 
SIMPLE IRAs to help families better save for retirement. The creation 
of agricultural research organizations, a bill I introduced with

[[Page 20388]]

Congressman Nunes, will help universities and extensions across the 
country invest in cutting edge 21st century agricultural research. 
Finally, I am glad to see that legislation I worked on with Congressman 
Paulsen to remove bond requirements for craft beverages is included in 
the PATH Act.
  As lead Democratic sponsor on the Protect Medical Innovation Act that 
repeals the device tax, I have been, and continue to be, strongly 
supportive of repealing the medical device tax. The medical device 
industry is one of the most innovative and creative in the U.S. economy 
today. Some of the greatest cost savings we've seen in the health care 
system have come through technological breakthroughs in the medical 
device and biotechnology industries. I fought against including the 
medical device tax during debate on the ACA and remain opposed to it 
now, but I am also committed to fiscal responsibility.
  Although this legislation included a number of my bills and 
proposals, I will be voting against the bill on the floor today. 
Without offsets, these provisions will cause our deficits to explode. 
Tax cuts do not pay for themselves, as Republican CPO Director Keith 
Hall reminded us just this summer. This bill makes comprehensive tax 
reform even more difficult by narrowing the base and eliminating 
options. The United States needs comprehensive tax reform that broadens 
the tax base while lowering rates on businesses and families. The PATH 
Act narrows that base, and makes no effort to remove any wasteful 
provisions. This package, while commendable for many of its policy 
goals, will fuel unsustainable deficit growth and I must oppose the 
package on these grounds. In the future, I look forward to working on 
bipartisan tax reform that promotes both a better business climate and 
supports the middle class.
  Mr. VAN HOLLEN. Mr. Speaker, I rise in opposition to the PATH Act. 
This bill does take some good steps, but the failure to close special 
interest tax loopholes to offset permanent businesses tax provisions 
leads to a massive loss in federal revenue, and proves once again that 
Republicans are committed to using accounting gimmicks that would make 
Enron blush.
  This bill does include extension of some important enhancements to 
the EITC, Child Tax Credit, and American Opportunity Tax Credit. These 
are vital pro-work, pro-family income supports, and making the 
enhancements permanent will help tens of millions of Americans.
  But, while a permanent extension of these provisions is a positive 
first step, this bill stopped short of doing more for working families. 
The child tax credit did not get indexed, so will not rise with the 
cost of living. Each year, the credit loses value in real dollars, 
making it harder and harder for low-income families. There is also 
bipartisan agreement that the EITC for childless workers is far too 
low, and yet the EITC for childless workers was left out of the PATH 
Act. I believe not taking these steps today is a missed opportunity.
  The unpaid-for tax cuts in the PATH Act are also more proof that the 
Republicans' claims of fiscal discipline are at best gimmicks, and at 
worst out-right fabrications. Between the PATH Act and the tax 
provisions in the omnibus spending bill, federal revenue is being 
reduced by $640 billion over the next ten years.
  Since my Republican colleagues probably won't say it, I will remind 
everyone of one key fact--when Republicans passed their budget and 
claimed that it would balance in ten years, they relied on every single 
dollar of revenue that is being cut today. Let me repeat that, so it is 
very clear. Every. Single. Dollar. The Republican budget never really 
balanced in March, and it certainly does not balance now.
  Here are some things which the PATH Act does not do: it does not 
close the loophole giving a lower tax rate to hedge funds managers; it 
does not close the inversion loophole allowing companies to dodge their 
taxes just by changing their mailing address; it does not end all the 
tax subsidies for the oil and gas industry; and it does not touch the 
17% of all tax expenditures that go to the top 1% of earners. We could 
have significantly reduced the lost revenue if we closed these and 
other special interest tax loopholes, and failure to do so is another 
missed opportunity.
  So, next time Republicans come to the floor claiming that they care 
about fiscal discipline, let's all be reminded of just what happened 
today--more budget gimmickry that doesn't pass the smell test.
  Ms. ROYBAL-ALLARD. Mr. Speaker, I rise in opposition to this tax 
bill, which is unpaid for and adds more than $600 billion to the 
deficit, primarily to benefit corporations at the expense of working 
families. In the future, to address the revenue loss in this bill will 
require reduced funding for education, health care, and job training 
programs essential to improving the lives of hardworking Americans. 
This is completely unacceptable.
  While there are some positive elements in this bill, including making 
the Child Tax Credit and the Earned Income Tax Credit permanent, the 
bill does not allow the Child Tax Credit to keep pace with inflation, 
which means the tax credit will be worth less and less as the years go 
by.
  Mr. Speaker, the tax provisions in this bill don't do enough to help 
families make ends meet, and will force us to underfund programs that 
Americans need to educate their children, keep their families healthy, 
and provide for their families' future and well-being. I will vote 
against this bill because it is a bad deal for American families.
  Mr. NEAL. Mr. Speaker, the Church Plan Clarification Act addresses 
several unintended consequences resulting from the application of 
general tax and pension regulations to the unique structures of church 
pension plans. Churches and synagogues established some of the first 
pension plans in the country, several dating back to the 18th century, 
and they are designed to ensure that our clergy and laystaff have 
adequate resources during their retirement years.
  Church plans are often structured to reflect the ecclesiastical 
teachings of their denomination. The resulting diversity of plan 
structures, coupled with the complexity of the legal and regulatory 
framework that applies to church plans, has led to the need for this 
legislation. The bill would correct several technical issues that are 
critical to the functioning and operation of church plans and the 
retirement benefits they provide.
  While the corrections contained in PATH Act would be of tremendous 
help to church plans, I want to make clear that the bill does not 
affect the definition of ``church plan'' under the Internal Revenue 
Code or Employee Retirement Income Security Act of 1974, ERISA. In 
particular, no inference is intended by this legislation regarding the 
statutory requirements a pension plan must meet to be considered or 
treated as a ``church plan'' under IRC section 414(e) of the Internal 
Revenue Code and section 3(33) of ERISA, and the bill has no bearing on 
the interpretation of those sections. Rather, the Church Plan 
Clarification Act is simply about fixing the rules that govern how 
church plans operate and serve their participants.
  Mr. LARSON of Connecticut. Mr. Speaker, I rise today in support of 
the PATH Act. While this is not a perfect bill, I join with the 
President in supporting this legislation as it represents clear 
progress for the American people. This legislation will permanently 
continue critical tax breaks to aid children and working families. It 
will permanently extend key provisions like the R&D tax credit and 
Section 179 expensing that will help our small businesses and 
manufacturers grow jobs and strengthen the economy. This bipartisan 
bill moves us forward as a nation both in terms of the benefits it 
provides and the signal it sends that it is possible for Congress to 
break the gridlock that has unfortunately engulfed Washington for too 
long.
  I am particularly proud that the permanent extension of the R&D tax 
credit that I sponsored along with Chairman Kevin Brady was included in 
this legislation. The R&D tax credit is a driver of innovation and 
economic growth, and making it permanent will provide the certainty 
American companies need to make the long-term investments in our nation 
and in our workers for technologies that will keep our global economic 
edge. The R&D credit, along with a permanent extension of the Section 
179 expensing credit, will give businesses in Connecticut and across 
the country the stability they need in the tax code to move our economy 
forward.
  For children and working families, this legislation also offers a 
permanent extension of critical tax credits. The permanent extension of 
the Recovery Act enhancements of the EITC and CTC credits as well as 
the AOTC will ensure millions of working families across the country 
will continue to receive well-deserved tax breaks. Without this 
extension, by 2018, over 50 million individuals would have lost part or 
all of their credits. In Connecticut, 141,000 children in 42,000 
families would lose access to part or all of their EITC or CTC credits. 
These provisions are absolutely critical and without them, I would not 
have been able to support this agreement. I wholeheartedly agree with 
my colleagues who have argued that the CTC should be indexed for 
inflation and while it is unfortunate that indexing is not included in 
this agreement, I will continue to fight for its inclusion on bills 
moving forward.
  In addition, this bill includes other important provisions, including 
a permanent extension of a deduction for teachers who purchase supplies 
for their classrooms as well as critical charitable provisions such as 
a credit for the donation of food inventory and a provision that allows 
for tax-free distributions from IRAs for charitable purposes. It also 
incorporates other

[[Page 20389]]

bills that will help with economic development, like the New Markets 
Tax credit, the low income housing tax credit, and legislation ensuring 
tax relief for another year for homeowners who have had part of their 
mortgage debt forgiven.
  Finally, I want to thank the negotiators for including a bill that I 
co-authored with Rep. Sam Johnson--the Wrongful Convictions Tax Relief 
Act, which ensures that compensation awards received by those who were 
wrongfully accused are not subjected to federal taxes on their awards. 
I first introduced the bill with Mr. Johnson in 2007 following the 
exoneration of James Tillman in Connecticut. I was proud to co-author 
this bill with Mr. Johnson, a true American hero, which rights a 
tremendous wrong in the tax code. Individuals who have been wrongfully 
accused have already suffered enough, so the notion that they would be 
taxed on the awards they receive as a result of their wrongful 
imprisonment is unconscionable. Once again, I thank the negotiators for 
including this common-sense bill in this package.
  On the whole, this bill will provide tremendous benefits for 
children, working families, and economic growth in our country. I 
support this bill and look forward to its passage.
  The SPEAKER pro tempore. All time for debate has expired.
  Pursuant to House Resolution 566, the previous question is ordered on 
this portion of the divided question.
  The question is: Will the House concur in the Senate amendment with 
the House amendment specified in section 3(b) of House Resolution 566?
  The question was taken; and the Speaker pro tempore announced that 
the ayes appeared to have it.
  Mr. LEVIN. Mr. Speaker, on that I demand the yeas and nays.
  The yeas and nays were ordered.
  The vote was taken by electronic device, and there were--yeas 318, 
nays 109, not voting 6, as follows:

                             [Roll No. 703]

                               YEAS--318

     Abraham
     Aderholt
     Aguilar
     Allen
     Amodei
     Ashford
     Babin
     Barletta
     Barr
     Barton
     Beatty
     Benishek
     Bera
     Bilirakis
     Bishop (GA)
     Bishop (MI)
     Bishop (UT)
     Black
     Blackburn
     Blum
     Blumenauer
     Bonamici
     Bost
     Boustany
     Boyle, Brendan F.
     Brady (TX)
     Brat
     Bridenstine
     Brooks (AL)
     Brooks (IN)
     Brownley (CA)
     Buchanan
     Buck
     Bucshon
     Burgess
     Bustos
     Byrne
     Calvert
     Capuano
     Carter (GA)
     Carter (TX)
     Chabot
     Chaffetz
     Cicilline
     Clark (MA)
     Clawson (FL)
     Cleaver
     Coffman
     Cohen
     Cole
     Collins (GA)
     Comstock
     Conaway
     Connolly
     Cook
     Costa
     Costello (PA)
     Courtney
     Cramer
     Crawford
     Crenshaw
     Crowley
     Culberson
     Curbelo (FL)
     Davis, Rodney
     Delaney
     DeLauro
     DelBene
     Denham
     Dent
     DeSantis
     DesJarlais
     Diaz-Balart
     Dold
     Donovan
     Duckworth
     Duffy
     Duncan (SC)
     Duncan (TN)
     Ellmers (NC)
     Emmer (MN)
     Engel
     Esty
     Farenthold
     Fincher
     Fitzpatrick
     Fleischmann
     Fleming
     Flores
     Forbes
     Fortenberry
     Foxx
     Franks (AZ)
     Frelinghuysen
     Gabbard
     Garamendi
     Garrett
     Gibbs
     Gibson
     Gohmert
     Goodlatte
     Gosar
     Gowdy
     Graham
     Granger
     Graves (GA)
     Graves (LA)
     Graves (MO)
     Green, Al
     Green, Gene
     Griffith
     Grothman
     Guinta
     Guthrie
     Hahn
     Hanna
     Hardy
     Harper
     Harris
     Hartzler
     Heck (NV)
     Heck (WA)
     Hensarling
     Herrera Beutler
     Hice, Jody B.
     Higgins
     Hill
     Hinojosa
     Holding
     Hudson
     Huelskamp
     Huizenga (MI)
     Hultgren
     Hunter
     Hurd (TX)
     Hurt (VA)
     Issa
     Jenkins (KS)
     Jenkins (WV)
     Johnson (OH)
     Johnson, E. B.
     Johnson, Sam
     Jolly
     Jordan
     Kaptur
     Katko
     Keating
     Kelly (MS)
     Kelly (PA)
     Kilmer
     King (IA)
     King (NY)
     Kinzinger (IL)
     Kirkpatrick
     Kline
     Knight
     Kuster
     Labrador
     LaHood
     LaMalfa
     Lamborn
     Lance
     Langevin
     Larson (CT)
     Latta
     LoBiondo
     Loebsack
     Long
     Loudermilk
     Love
     Lowey
     Lucas
     Luetkemeyer
     Lujan Grisham (NM)
     Lummis
     Lynch
     MacArthur
     Maloney, Carolyn
     Maloney, Sean
     Marchant
     Marino
     Massie
     McCarthy
     McCaul
     McClintock
     McGovern
     McHenry
     McKinley
     McMorris Rodgers
     McNerney
     McSally
     Meadows
     Meehan
     Meeks
     Meng
     Messer
     Mica
     Miller (FL)
     Miller (MI)
     Moolenaar
     Mooney (WV)
     Moulton
     Mullin
     Mulvaney
     Murphy (FL)
     Murphy (PA)
     Neal
     Neugebauer
     Newhouse
     Noem
     Nolan
     Norcross
     Nugent
     Nunes
     Olson
     Palazzo
     Palmer
     Pascrell
     Paulsen
     Pearce
     Perry
     Peters
     Peterson
     Pingree
     Pittenger
     Pitts
     Poe (TX)
     Poliquin
     Pompeo
     Posey
     Price (NC)
     Price, Tom
     Quigley
     Ratcliffe
     Reed
     Reichert
     Renacci
     Ribble
     Rice (NY)
     Rice (SC)
     Rigell
     Roby
     Roe (TN)
     Rogers (AL)
     Rogers (KY)
     Rohrabacher
     Rokita
     Rooney (FL)
     Ros-Lehtinen
     Roskam
     Ross
     Rothfus
     Rouzer
     Royce
     Ruiz
     Ruppersberger
     Russell
     Ryan (OH)
     Salmon
     Sanford
     Scalise
     Schweikert
     Scott, Austin
     Scott, David
     Sensenbrenner
     Sessions
     Sherman
     Shimkus
     Shuster
     Simpson
     Sinema
     Sires
     Smith (MO)
     Smith (NE)
     Smith (NJ)
     Smith (TX)
     Stefanik
     Stewart
     Stivers
     Stutzman
     Swalwell (CA)
     Takai
     Thompson (PA)
     Thornberry
     Tiberi
     Tipton
     Titus
     Trott
     Turner
     Upton
     Valadao
     Veasey
     Vela
     Wagner
     Walberg
     Walden
     Walker
     Walorski
     Walters, Mimi
     Walz
     Weber (TX)
     Webster (FL)
     Wenstrup
     Westerman
     Westmoreland
     Whitfield
     Williams
     Wilson (SC)
     Wittman
     Womack
     Woodall
     Yoder
     Yoho
     Young (AK)
     Young (IA)
     Young (IN)
     Zeldin
     Zinke

                               NAYS--109

     Adams
     Amash
     Bass
     Becerra
     Beyer
     Brady (PA)
     Brown (FL)
     Butterfield
     Capps
     Cardenas
     Carney
     Carson (IN)
     Cartwright
     Castor (FL)
     Castro (TX)
     Chu, Judy
     Clarke (NY)
     Clay
     Clyburn
     Collins (NY)
     Conyers
     Cooper
     Cummings
     Davis (CA)
     Davis, Danny
     DeFazio
     DeGette
     DeSaulnier
     Dingell
     Doggett
     Doyle, Michael F.
     Edwards
     Ellison
     Eshoo
     Farr
     Fattah
     Foster
     Frankel (FL)
     Fudge
     Gallego
     Grayson
     Grijalva
     Gutierrez
     Hastings
     Himes
     Honda
     Hoyer
     Huffman
     Israel
     Jackson Lee
     Jeffries
     Johnson (GA)
     Jones
     Kelly (IL)
     Kind
     Larsen (WA)
     Lawrence
     Lee
     Levin
     Lewis
     Lieu, Ted
     Lipinski
     Lofgren
     Lowenthal
     Lujan, Ben Ray (NM)
     Matsui
     McCollum
     McDermott
     Moore
     Napolitano
     O'Rourke
     Pallone
     Payne
     Pelosi
     Perlmutter
     Pocan
     Polis
     Rangel
     Richmond
     Roybal-Allard
     Rush
     Sanchez, Linda T.
     Sanchez, Loretta
     Sarbanes
     Schakowsky
     Schiff
     Schrader
     Scott (VA)
     Serrano
     Sewell (AL)
     Slaughter
     Smith (WA)
     Speier
     Takano
     Thompson (CA)
     Thompson (MS)
     Tonko
     Torres
     Tsongas
     Van Hollen
     Vargas
     Velazquez
     Visclosky
     Wasserman Schultz
     Waters, Maxine
     Watson Coleman
     Welch
     Wilson (FL)
     Yarmuth

                             NOT VOTING--6

     Cuellar
     Deutch
     Joyce
     Kennedy
     Kildee
     Nadler

                              {time}  1300

  Ms. SLAUGHTER changed her vote from ``yea'' to ``nay.''
  So the first portion of the divided question was adopted.
  The result of the vote was announced as above recorded.
  A motion to reconsider was laid on the table.
  The SPEAKER pro tempore. Pursuant to clause 1(c) of rule XIX, further 
consideration of the pending motion is postponed.

                          ____________________