[House Report 119-600]
[From the U.S. Government Publishing Office]


119th Congress }                                       { Report
                       HOUSE OF REPRESENTATIVES
   2d Session  }                                       { 119-600
======================================================================
 
                 SUPPORTING EARLY-CHILDHOOD EDUCATORS' 
                            DEDUCTIONS ACT

                                _______
                                

 April 9, 2026.--Committed to the Committee of the Whole House on the 
                               State of 
                  the Union and ordered to be printed

                                _______
                                

Mr. Smith of Missouri, from the Committee on Ways and Means, submitted 
                             the following

                              R E P O R T

                        [To accompany H.R. 5334]

    The Committee on Ways and Means, to whom was referred the 
bill (H.R. 5334) to amend the Internal Revenue Code of 1986 to 
allow early childhood educators to take the educator expense 
deduction, and for other purposes, having considered the same, 
reports favorably thereon with an amendment and recommends that 
the bill as amended do pass.

                                CONTENTS

                                                                   Page
 I. SUMMARY AND BACKGROUND............................................2
          A. Purpose and Summary.................................     2
          B. Background and Need for Legislation.................     2
          C. Legislative History.................................     3
          D. Designated Hearing..................................     3
II. EXPLANATION OF THE BILL...........................................3
III.VOTE OF THE COMMITTEE.............................................4

IV. BUDGET EFFECTS OF THE BILL........................................5
          A. Committee Estimate of Budgetary Effects.............     5
          B. Statement Regarding New Budget Authority and Tax 
              Expenditures Budget Authority......................     5
          C. Cost Estimate Prepared by the Congressional Budget 
              Office.............................................     6
 V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE........6
          A. Committee Oversight Findings and Recommendations....     6
          B. Statement of General Performance Goals and 
              Objectives.........................................     6
          C. Applicability of House Rule XXI, Clause 5(b)........     6
          D. Information Relating to Unfunded Mandates...........     6
          E. Congressional Earmarks, Limited Tax Benefits, and 
              Limited Tariff Benefits............................     6
          F. Duplication of Federal Programs.....................     7
          G. Tax Complexity Analysis.............................     7
VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED.............7

    The amendment is as follows:
    Strike all after the enacting clause and insert the 
following:

SECTION 1. SHORT TITLE.

  This Act may be cited as the ``Supporting Early-childhood Educators' 
Deductions Act'' or the ``SEED Act''.

SEC. 2. EDUCATOR EXPENSE DEDUCTION TO INCLUDE EARLY CHILDHOOD 
                    EDUCATORS.

  (a) In General.--Section 62(d)(1) of the Internal Revenue Code of 
1986 is amended--
          (1) in subparagraph (A), by striking ``a kindergarten through 
        grade 12 teacher'' and inserting ``an early childhood or 
        kindergarten through grade 12 teacher'', and
          (2) in subparagraph (B), to read as follows:
                  ``(B) School.--The term `school' means--
                          ``(i) in the case of early childhood 
                        education, any school or childcare facility 
                        which--
                                  ``(I) provides educational or 
                                childcare services for more than 2 
                                individuals (other than individuals who 
                                reside at the school or facility) who 
                                have not attained age 6, and
                                  ``(II) operates at the public expense 
                                or receives a fee, payment, or grant 
                                for providing such services for any of 
                                the individuals (regardless of whether 
                                such school or facility is operated for 
                                profit), and
                          ``(ii) in the case of elementary education or 
                        secondary education (kindergarten through grade 
                        12), any school which provides such education, 
                        as determined under State law.''.
  (b) Conforming Amendment.--Section 62(a)(2)(D) of such Code is 
amended by striking ``Certain expenses of elementary and secondary 
school teachers'' in the heading and inserting ``Certain expenses of 
early childhood, elementary, and secondary school teachers''.
  (c) Effective Date.--The amendments made by this section shall apply 
to expenses paid or incurred in taxable years beginning after December 
31, 2025.

                       I. SUMMARY AND BACKGROUND


                         A. Purpose and Summary

    The bill, H.R. 5334 as amended, the ``Supporting Early-
childhood Educators' Deductions Act'' or the ``SEED Act,'' was 
ordered reported by the Committee on Ways and Means on March 
25, 2026.
    Certain individuals referred to as ``eligible educators'' 
are allowed a limited above-the-line deduction for specified 
expenses paid in connection with their work. A broader group of 
educators is also allowed an itemized deduction, not limited to 
prescribed dollar amount, for a broader category of expenses 
paid in connection with their work. Educators who are allowed 
these deductions are educators of children in kindergarten 
through grade 12. Neither the above-the-line deduction nor the 
itemized deduction is allowed to early childhood educators. The 
bill allows the deductions to early childhood educators.

                 B. Background and Need for Legislation

    A top priority of the Ways and Means Committee has been 
listening to the concerns of American workers and families and 
developing policy solutions to help. Pre-school educators are 
currently not afforded the same benefits under the tax code as 
their K-12 educator counterparts. Under current law, pre-school 
educators must cover regular classroom expenses, such as school 
supplies, out of their own pockets, whereas K-12 educators can 
deduct much of these expenses. This legislation builds on the 
bipartisan legislative history of helping early childhood 
educators afford to carry out their essential careers in caring 
for the nation's youngest students.

                         C. Legislative History


Background

    H.R. 5334 was introduced on September 11, 2025, and was 
referred to the Committee on Ways and Means.

Committee Hearings

    On January 22, 2025, the Committee held a Full Committee 
Member Day Hearing on matters within the Committee's 
jurisdiction.

Committee Action

    The Committee on Ways and Means marked up H.R. 5334, on 
March 25, 2026, and ordered the bill, as amended, favorably 
reported (with a quorum being present).

                         D. Designated Hearing

    Pursuant to clause 3(c)(6) of rule XIII, the following 
hearings were used to develop and consider H.R. 5334:
    On January 22, 2025, the Committee held a Full Committee 
Member Day Hearing on matters within the Committee's 
jurisdiction.

                      II. EXPLANATION OF THE BILL


                              Present Law

    An eligible educator is allowed a deduction in determining 
adjusted gross income (referred to below as an ``above-the-
line'' deduction) for ordinary and necessary expenses paid or 
incurred (i) by reason of the educator's participation 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.\1\
---------------------------------------------------------------------------
    \1\Sec. 62(a)(2)(D).
---------------------------------------------------------------------------
    The above-the-line deduction for education expenses is 
limited to $350 in 2026.\2\
---------------------------------------------------------------------------
    \2\Sec. 62(a)(2)(D), (d)(3); Rev. Proc. 2025-32, 2025-45 I.R.B. 
695.
---------------------------------------------------------------------------
    For purposes of the above-the-line deduction for education 
expenses, an eligible educator is, for any taxable year, an 
individual who is a kindergarten through grade 12 teacher, 
instructor, counselor, principal, or aide in a school for at 
least 900 hours during a school year. For this purpose, a 
school is any school that provides elementary or secondary 
(kindergarten through grade 12) education, as determined under 
State law.\3\
---------------------------------------------------------------------------
    \3\Sec. 62(d)(1).
---------------------------------------------------------------------------
    An itemized deduction, not limited to a prescribed dollar 
amount, is allowed for ``educator expenses.''\4\ This itemized 
deduction for educator expenses is allowed to a broader class 
of individuals for a broader class of education expenses. This 
itemized deduction is allowed for interscholastic sports 
administrators and coaches as well as for teachers, 
instructors, counselors, principals, and aides. This itemized 
deduction is allowed both for expenses for which the above-the-
line deduction is allowed and also for expenses paid or 
incurred (i) for nonathletic supplies for courses of 
instruction in health or physical education or (ii) in 
connection with books, supplies, equipment, and supplementary 
materials used as part of instructional activity, whether or 
not in the classroom.
---------------------------------------------------------------------------
    \4\Secs. 67(b)(13), (g), 162(a).
---------------------------------------------------------------------------
    An eligible educator who claims the maximum amount of the 
above-the-line deduction and who has additional expenses that 
are considered educator expenses may, if the individual elects 
to itemize deductions, claim an itemized deduction for these 
additional expenses.

                           Reasons for Change

    The Committee believes that it is appropriate for early 
childhood educators to be allowed the same expense deductions 
as are allowed to kindergarten through grade 12 educators.

                        Explanation of Provision

    The bill broadens the present law definition of an eligible 
educator. Under the bill an eligible educator includes, in 
addition to the individuals within the present law definition, 
an early childhood teacher, instructor, counselor, principal, 
or aide in a school for at least 900 hours during a school 
year.
    The bill broadens the present law definition of school. 
Under the bill, a school includes both elementary and secondary 
schools that are within the present law definition and also, in 
the case of early childhood education, a school or childcare 
facility that (1) provides educational or childcare services 
for more than two individuals (other than individuals who 
reside at the school or facility) who are below age six, and 
(2) operates at the public expense or receives a fee, payment, 
or grant for providing its services (regardless of whether the 
school or facility is operated for profit).
    The bill makes a conforming amendment to the heading of 
Internal Revenue Code section 62(a)(2)(D) so that the heading 
reads, ``CERTAIN EXPENSES OF EARLY CHILDHOOD, ELEMENTARY, AND 
SECONDARY SCHOOL TEACHERS.''

                             Effective Date

    The bill is effective for expenses paid or incurred in 
taxable years beginning after December 31, 2025.

                       III. VOTE OF THE COMMITTEE

    In compliance with the Rules of the House of 
Representatives, the following statement is made concerning the 
vote of the Committee on Ways and Means during the markup 
consideration of H.R. 5334, the ``Supporting Early-childhood 
Educators' Deductions Act of 2025'' or the ``SEED Act,'' on 
March 25, 2026.
    H.R. 5334 was ordered favorably reported to the House of 
Representatives as amended by a roll call vote of 43 yeas to 0 
nays (with a quorum being present). The vote was as follows:

----------------------------------------------------------------------------------------------------------------
        Representative             Yea       Nay      Present    Representative      Yea       Nay      Present
----------------------------------------------------------------------------------------------------------------
Mr. Smith (MO)................        X   .........  .........  Mr. Neal........        X   .........  .........
Mr. Buchanan..................        X   .........  .........  Mr. Doggett.....        X   .........  .........
Mr. Smith (NE)................        X   .........  .........  Mr. Thompson....        X   .........  .........
Mr. Kelly.....................        X   .........  .........  Mr. Larson......        X   .........  .........
Mr. Schweikert................        X   .........  .........  Mr. Davis.......        X   .........  .........
Mr. LaHood....................        X   .........  .........  Ms. Sanchez.....        X   .........  .........
Mr. Arrington.................        X   .........  .........  Ms. Sewell......        X   .........  .........
Mr. Estes.....................        X   .........  .........  Ms. DelBene.....        X   .........  .........
Mr. Smucker...................        X   .........  .........  Ms. Chu.........        X   .........  .........
Mr. Hern......................        X   .........  .........  Ms. Moore (WI)..        X   .........  .........
Mrs. Miller (WV)..............        X   .........  .........  Mr. Boyle.......        X   .........  .........
Dr. Murphy....................        X   .........  .........  Mr. Beyer.......  ........  .........  .........
 Mr. Kustoff..................        X   .........  .........  Mr. Evans.......        X   .........  .........
Mr. Fitzpatrick...............        X   .........  .........  Mr. Schneider...        X   .........  .........
Mr. Steube....................        X   .........  .........  Mr. Panetta.....        X   .........  .........
Ms. Tenney....................        X   .........  .........  Mr. Gomez.......  ........  .........  .........
 Mrs. Fischbach...............        X   .........  .........  Mr. Horsford....        X   .........  .........
Mr. Moore (UT)................        X   .........  .........  Ms. Plaskett....        X   .........  .........
Ms. Van Duyne.................        X   .........  .........  Mr. Suozzi......        X   .........  .........
Mr. Feenstra..................        X   .........  .........
Ms. Malliotakis...............        X   .........  .........
Mr. Carey.....................        X   .........  .........
Mr. Yakym.....................        X   .........  .........
Mr. Miller (OH)...............        X   .........  .........
Mr. Bean......................        X   .........  .........
Mr. Moran.....................        X   .........  .........
----------------------------------------------------------------------------------------------------------------

                     IV. BUDGET EFFECTS OF THE BILL


               A. Committee Estimate of Budgetary Effects

    In compliance with clause 3(d) of rule XIII of the Rules of 
the House of Representatives, the following statement is made 
concerning the effects on the budget of the bill, H.R. 5334 as 
reported.
    The staff of the Joint Committee on Taxation estimates that 
the bill as amended has the following effect on Federal fiscal 
year budget receipts:

                                                                      FISCAL YEARS
                                                                  [Millions of dollars]
--------------------------------------------------------------------------------------------------------------------------------------------------------
              2026                  2027      2028      2029      2030      2031      2032      2033      2034      2035      2036    2026- 31  2026- 36
--------------------------------------------------------------------------------------------------------------------------------------------------------
-6..............................      -60       -62       -63       -63       -61       -61       -63       -69       -69       -70      -315      -648
--------------------------------------------------------------------------------------------------------------------------------------------------------
NOTE: Details may not add to totals due to rounding. The date of enactment is assumed to be April 30, 2026.

B. Statement Regarding New Budget Authority and Tax Expenditures Budget 
                               Authority

    In compliance with clause 3(c)(2) of rule XIII of the Rules 
of the House of Representatives, the Committee states that the 
bill involves no new or increased budget authority.

            C. Cost Estimate Prepared by the Congressional 
                             Budget Office

    In The Congressional Budget Act of 1974, as amended 
stipulates that revenue estimates provided by the staff of the 
Joint Committee on Taxation (``JCT'') will be the official 
estimates for all tax legislation considered by Congress. As 
such CBO incorporates these estimates into its cost estimates 
of the effects of the legislation. The estimates for the 
revenue provisions of H.R. 5334, the ``Supporting Early-
childhood Educators' Deductions Act of 2025'' or the ``SEED 
Act,'' as reported were provided by JCT (see Part IV, A).

     V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE


          A. Committee Oversight Findings and Recommendations

    With respect to clause 3(c)(1) of rule XIII of the Rules of 
the House of Representatives, the Committee made findings and 
recommendations that are reflected in this report.

        B. Statement of General Performance Goals and Objectives

    With respect to clause 3(c)(4) of rule XIII of the Rules of 
the House of Representatives, the Committee advises that the 
bill does not authorize funding, so no statement of general 
performance goals and objectives is required.

            C. Applicability of House Rule XXI, Clause 5(b)

    Rule XXI 5(b) of the Rules of the House of Representatives 
provides, in part, that ``A bill or joint resolution, 
amendment, or conference report carrying a Federal income tax 
rate increase may not be considered as passed or agreed to 
unless so determined by a vote of not less than three-fifths of 
the Members voting, a quorum being present.'' The Committee has 
carefully reviewed the bill, and states that the bill does not 
provide such a Federal income tax rate increase.

              D. Information Relating to Unfunded Mandates

    This information is provided in accordance with section 423 
of the Unfunded Mandates Reform Act of 1995 (Pub. L. No. 104-
4).
    The Committee has determined that the bill does not contain 
Federal mandates on the private sector. The Committee has 
determined that the bill does not impose a Federal 
intergovernmental mandate on State, local, or tribal 
governments.

  E. Congressional Earmarks, Limited Tax Benefits, and Limited Tariff 
                                Benefits

    With respect to clause 9 of rule XXI of the Rules of the 
House of Representatives, the Committee has carefully reviewed 
the provisions of the bill, and states that the provisions of 
the bill do not contain any congressional earmarks, limited tax 
benefits, or limited tariff benefits within the meaning of the 
rule.

                   F. Duplication of Federal Programs

    In compliance with clause 3(c)(5) of rule XIII of the Rules 
of the House of Representatives, the Committee states that no 
provision of the bill establishes or reauthorizes: (1) a 
program of the Federal Government known to be duplicative of 
another Federal program; (2) a program included in any report 
from the Government Accountability Office to Congress pursuant 
to section 21 of Public Law 111-139; or (3) a program related 
to a program identified in the most recent Catalog of Federal 
Domestic Assistance, published pursuant to the Federal Program 
Information Act (Pub. L. No. 95-220, as amended by Pub. L. No. 
98-169).

                       G. Tax Complexity Analysis

    Section 4022(b) of the Internal Revenue Service Reform and 
Restructuring Act of 1998 (the ``IRS Reform Act'') requires the 
staff of the Joint Committee on Taxation (in consultation with 
the Internal Revenue Service and the Treasury Department) to 
provide a tax complexity analysis. The complexity analysis is 
required for all legislation reported by the Senate Committee 
on Finance, the House Committee on Ways and Means, or any 
committee of conference if the legislation includes a provision 
that directly or indirectly amends the Internal Revenue Code 
and has widespread applicability to individuals or small 
businesses.
    The staff of the Joint Committee on Taxation has determined 
that there are no provisions that are of widespread 
applicability to individuals or small businesses.

             VI. CHANGES IN EXISTING LAW MADE BY THE BILL, 
                              AS REPORTED

    In compliance with clause 3(e) of rule XIII of the Rules of 
the House of Representatives, changes in existing law made by 
the bill, as reported, are shown as follows.

         Changes in Existing Law Made by the Bill, as Reported

  In compliance with clause 3(e) of rule XIII of the Rules of 
the House of Representatives, changes in existing law made by 
the bill, as reported, are shown as follows (existing law 
proposed to be omitted is enclosed in black brackets, new 
matter is printed in italics, and existing law in which no 
change is proposed is shown in roman):

                     INTERNAL REVENUE CODE OF 1986




           *       *       *       *       *       *       *
Subtitle A--Income Taxes

           *       *       *       *       *       *       *


CHAPTER 1--NORMAL TAXES AND SURTAXES

           *       *       *       *       *       *       *


Subchapter B--COMPUTATION OF TAXABLE INCOME

           *       *       *       *       *       *       *


  PART I--DEFINITION OF GROSS INCOME, ADJUSTED GROSS INCOME, TAXABLE 
INCOME, ETC.

           *       *       *       *       *       *       *



SEC. 62. ADJUSTED GROSS INCOME DEFINED.

  (a) General rule.--For purposes of this subtitle, the term 
``adjusted gross income'' means, in the case of an individual, 
gross income minus the following deductions:
          (1) Trade and business deductions.--The deductions 
        allowed by this chapter (other than by part VII of this 
        subchapter) which are attributable to a trade or 
        business carried on by the taxpayer, if such trade or 
        business does not consist of the performance of 
        services by the taxpayer as an employee.
          (2) Certain trade and business deductions of 
        employees.--
                  (A) Reimbursed expenses of employees.--The 
                deductions allowed by part VI (section 161 and 
                following) which consist of expenses paid or 
                incurred by the taxpayer, in connection with 
                the performance by him of services as an 
                employee, under a reimbursement or other 
                expense allowance arrangement with his 
                employer. The fact that the reimbursement may 
                be provided by a third party shall not be 
                determinative of whether or not the preceding 
                sentence applies.
                  (B) Certain expenses of performing artists.--
                The deductions allowed by section 162 which 
                consist of expenses paid or incurred by a 
                qualified performing artist in connection with 
                the performances by him of services in the 
                performing arts as an employee.
                  (C) Certain expenses of officials.--The 
                deductions allowed by section 162 which consist 
                of expenses paid or incurred with respect to 
                services performed by an official as an 
                employee of a State or a political subdivision 
                thereof in a position compensated in whole or 
                in part on a fee basis.
                  (D)  [Certain expenses of elementary and 
                secondary school teachers] Certain expenses of 
                early childhood, elementary, and secondary 
                school teachers.--The deductions allowed by 
                section 162 which consist of expenses, not in 
                excess of $250, paid or incurred by an eligible 
                educator--
                          (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.
                  (E) Certain expenses of members of reserve 
                components of the Armed Forces of the United 
                States.--The deductions allowed by section 162 
                which consist of expenses, determined at a rate 
                not in excess of the rates for travel expenses 
                (including per diem in lieu of subsistence) 
                authorized for employees of agencies under 
                subchapter I of chapter 57 of title 5, United 
                States Code, paid or incurred by the taxpayer 
                in connection with the performance of services 
                by such taxpayer as a member of a reserve 
                component of the Armed Forces of the United 
                States for any period during which such 
                individual is more than 100 miles away from 
                home in connection with such services.
          (3) Losses from sale or exchange of property.--The 
        deductions allowed by part VI (sec. 161 and following) 
        as losses from the sale or exchange of property.
          (4) Deductions attributable to rents and royalties.--
        The deductions allowed by part VI (sec. 161 and 
        following), by section 212 (relating to expenses for 
        production of income), and by section 611 (relating to 
        depletion) which are attributable to property held for 
        the production of rents or royalties.
          (5) Certain deductions of life tenants and income 
        beneficiaries of property.--In the case of a life 
        tenant of property, or an income beneficiary of 
        property held in trust, or an heir, legatee, or devisee 
        of an estate, the deduction for depreciation allowed by 
        section 167 and the deduction allowed by section 611.
          (6) Pension, profit-sharing, and annuity plans of 
        self-employed individuals.--In the case of an 
        individual who is an employee within the meaning of 
        section 401(c)(1), the deduction allowed by section 
        404.
          (7) Retirement savings.--The deduction allowed by 
        section 219 (relating to deduction of certain 
        retirement savings).
          (9) Penalties forfeited because of premature 
        withdrawal of funds from time savings accounts or 
        deposits.--The deductions allowed by section 165 for 
        losses incurred in any transaction entered into for 
        profit, though not connected with a trade or business, 
        to the extent that such losses include amounts 
        forfeited to a bank, mutual savings bank, savings and 
        loan association, building and loan association, 
        cooperative bank or homestead association as a penalty 
        for premature withdrawal of funds from a time savings 
        account, certificate of deposit, or similar class of 
        deposit.
          (11) Reforestation expenses.--The deduction allowed 
        by section 194.
          (12) Certain required repayments of supplemental 
        unemployment compensation benefits.--The deduction 
        allowed by section 165 for the repayment to a trust 
        described in paragraph (9) or (17) of section 501(c) of 
        supplemental unemployment compensation benefits 
        received from such trust if such repayment is required 
        because of the receipt of trade readjustment allowances 
        under section 231 or 232 of the Trade Act of 1974 (19 
        U.S.C. 2291 and 2292).
          (13) Jury duty pay remitted to employer.--Any 
        deduction allowable under this chapter by reason of an 
        individual remitting any portion of any jury pay to 
        such individual's employer in exchange for payment by 
        the employer of compensation for the period such 
        individual was performing jury duty. For purposes of 
        the preceding sentence, the term ``jury pay'' means any 
        payment received by the individual for the discharge of 
        jury duty.
          (15) Moving expenses.--The deduction allowed by 
        section 217.
          (16) Archer MSAs.--The deduction allowed by section 
        220.
          (17) Interest on education loans.--The deduction 
        allowed by section 221.
          (19) Health savings accounts.--The deduction allowed 
        by section 223.
          (20) Costs involving discrimination suits, etc..--Any 
        deduction allowable under this chapter for attorney 
        fees and court costs paid by, or on behalf of, the 
        taxpayer in connection with any action involving a 
        claim of unlawful discrimination (as defined in 
        subsection (e)) or a claim of a violation of subchapter 
        III of chapter 37 of title 31, United States Code, or a 
        claim made under section 1862(b)(3)(A) of the Social 
        Security Act (42 U.S.C. 1395y(b)(3)(A)). The preceding 
        sentence shall not apply to any deduction in excess of 
        the amount includible in the taxpayer's gross income 
        for the taxable year on account of a judgment or 
        settlement (whether by suit or agreement and whether as 
        lump sum or periodic payments) resulting from such 
        claim.
          (21) Attorneys' fees relating to awards to 
        whistleblowers.--
                  (A) In general.--Any deduction allowable 
                under this chapter for attorney fees and court 
                costs paid by, or on behalf of, the taxpayer in 
                connection with any award under--
                          (i) section 7623(b), or
                          (ii) in the case of taxable years 
                        beginning after December 31, 2017, any 
                        action brought under--
                                  (I) section 21F of the 
                                Securities Exchange Act of 1934 
                                (15 U.S.C. 78u-6),
                                  (II) a State false claims 
                                act, including a State false 
                                claims act with qui tam 
                                provisions, or
                                  (III) section 23 of the 
                                Commodity Exchange Act (7 
                                U.S.C. 26).
                  (B) May not exceed award.--Subparagraph (A) 
                shall not apply to any deduction in excess of 
                the amount includible in the taxpayer's gross 
                income for the taxable year on account of such 
                award.
Nothing in this section shall permit the same item to be 
deducted more than once. Any deduction allowed by section 199A 
shall not be treated as a deduction described in any of the 
preceding paragraphs of this subsection.
  (b) Qualified performing artist.--
          (1) In general.--For purposes of subsection 
        (a)(2)(B), the term ``qualified performing artist'' 
        means, with respect to any taxable year, any individual 
        if--
                  (A) such individual performed services in the 
                performing arts as an employee during the 
                taxable year for at least 2 employers,
                  (B) the aggregate amount allowable as a 
                deduction under section 162 in connection with 
                the performance of such services exceeds 10 
                percent of such individual's gross income 
                attributable to the performance of such 
                services, and
                  (C) the adjusted gross income of such 
                individual for the taxable year (determined 
                without regard to subsection (a)(2)(B)) does 
                not exceed $16,000.
          (2) Nominal employer not taken into account.--An 
        individual shall not be treated as performing services 
        in the performing arts as an employee for any employer 
        during any taxable year unless the amount received by 
        such individual from such employer for the performance 
        of such services during the taxable year equals or 
        exceeds $200.
          (3) Special rules for married couples.--
                  (A) In general.--Except in the case of a 
                husband and wife who lived apart at all times 
                during the taxable year, if the taxpayer is 
                married at the close of the taxable year, 
                subsection (a)(2)(B) shall apply only if the 
                taxpayer and his spouse file a joint return for 
                the taxable year.
                  (B) Application of paragraph (1).--In the 
                case of a joint return--
                          (i) paragraph (1) (other than 
                        subparagraph (C) thereof) shall be 
                        applied separately with respect to each 
                        spouse, but
                          (ii) paragraph (1)(C) shall be 
                        applied with respect to their combined 
                        adjusted gross income.
                  (C) Determination of marital status.--For 
                purposes of this subsection, marital status 
                shall be determined under section 7703(a).
                  (D) Joint return.--For purposes of this 
                subsection, the term ``joint return'' means the 
                joint return of a husband and wife made under 
                section 6013.
  (c) Certain arrangements not treated as reimbursement 
arrangements.--For purposes of subsection (a)(2)(A), an 
arrangement shall in no event be treated as a reimbursement or 
other expense allowance arrangement if--
          (1) such arrangement does not require the employee to 
        substantiate the expenses covered by the arrangement to 
        the person providing the reimbursement, or
          (2) such arrangement provides the employee the right 
        to retain any amount in excess of the substantiated 
        expenses covered under the arrangement.
The substantiation requirements of the preceding sentence shall 
not apply to any expense to the extent that substantiation is 
not required under section 274(d) for such expense by reason of 
the regulations prescribed under the 2nd sentence thereof.
  (d) Definition; Special Rules.--
          (1) Eligible educator.--
                  (A) In general.--For purposes of subsection 
                (a)(2)(D), the term ``eligible educator'' 
                means, with respect to any taxable year, an 
                individual who is [a kindergarten through grade 
                12 teacher] an early childhood or kindergarten 
                through grade 12 teacher, instructor, 
                counselor, principal, or aide in a school for 
                at least 900 hours during a school year.
                  [(B) School.--The term ``school'' means any 
                school which provides elementary education or 
                secondary education (kindergarten through grade 
                12), as determined under State law.]
                  (B) School.--The term ``school'' means--
                          (i) in the case of early childhood 
                        education, any school or childcare 
                        facility which--
                                  (I) provides educational or 
                                childcare services for more 
                                than 2 individuals (other than 
                                individuals who reside at the 
                                school or facility) who have 
                                not attained age 6, and
                                  (II) operates at the public 
                                expense or receives a fee, 
                                payment, or grant for providing 
                                such services for any of the 
                                individuals (regardless of 
                                whether such school or facility 
                                is operated for profit), and
                          (ii) in the case of elementary 
                        education or secondary education 
                        (kindergarten through grade 12), any 
                        school which provides such education, 
                        as determined under State law.
          (2) Coordination with exclusions.--A deduction shall 
        be allowed under subsection (a)(2)(D) for expenses only 
        to the extent the amount of such expenses exceeds the 
        amount excludable under section 135, 529(c)(1), or 
        530(d)(2) for the taxable year.
          (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 2016'' in subparagraph (A)(ii) 
                thereof.
        Any increase determined under the preceding sentence 
        shall be rounded to the nearest multiple of $50.
  (e) Unlawful discrimination defined.--For purposes of 
subsection (a)(20), the term ``unlawful discrimination'' means 
an act that is unlawful under any of the following:
          (1) Section 302 of the Civil Rights Act of 1991 (42 
        U.S.C. 2000e-16b).
          (2) Section 201, 202, 203, 204, 205, 206, 207, or 208 
        of the Congressional Accountability Act of 1995 (2 
        U.S.C. 1311, 1312, 1313, 1314, 1315, 1316, or 1317).
          (3) The National Labor Relations Act (29 U.S.C. 151 
        et seq.).
          (4) The Fair Labor Standards Act of 1938 (29 U.S.C. 
        201 et seq.).
          (5) Section 4 or 15 of the Age Discrimination in 
        Employment Act of 1967 (29 U.S.C. 623 or 633a).
          (6) Section 501 or 504 of the Rehabilitation Act of 
        1973 (29 U.S.C. 791 or 794).
          (7) Section 510 of the Employee Retirement Income 
        Security Act of 1974 (29 U.S.C. 1140).
          (8) Title IX of the Education Amendments of 1972 (20 
        U.S.C. 1681 et seq.).
          (9) The Employee Polygraph Protection Act of 1988 (29 
        U.S.C. 2001 et seq.).
          (10) The Worker Adjustment and Retraining 
        Notification Act (29 U.S.C. 2102 et seq.).
          (11) Section 105 of the Family and Medical Leave Act 
        of 1993 (29 U.S.C. 2615).
          (12) Chapter 43 of title 38, United States Code 
        (relating to employment and reemployment rights of 
        members of the uniformed services).
          (13) Section 1977, 1979, or 1980 of the Revised 
        Statutes (42 U.S.C. 1981, 1983, or 1985).
          (14) Section 703, 704, or 717 of the Civil Rights Act 
        of 1964 (42 U.S.C. 2000e-2, 2000e-3, or 2000e-16).
          (15) Section 804, 805, 806, 808, or 818 of the Fair 
        Housing Act (42 U.S.C. 3604, 3605, 3606, 3608, or 
        3617).
          (16) Section 102, 202, 302, or 503 of the Americans 
        with Disabilities Act of 1990 (42 U.S.C. 12112, 12132, 
        12182, or 12203).
          (17) Any provision of Federal law (popularly known as 
        whistleblower protection provisions) prohibiting the 
        discharge of an employee, the discrimination against an 
        employee, or any other form of retaliation or reprisal 
        against an employee for asserting rights or taking 
        other actions permitted under Federal law.
          (18) Any provision of Federal, State, or local law, 
        or common law claims permitted under Federal, State, or 
        local law--
                  
                  (i) providing for the enforcement of civil 
                rights, or
                  
                  (ii) regulating any aspect of the employment 
                relationship, including claims for wages, 
                compensation, or benefits, or prohibiting the 
                discharge of an employee, the discrimination 
                against an employee, or any other form of 
                retaliation or reprisal against an employee for 
                asserting rights or taking other actions 
                permitted by law.

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