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(a) In general.—Section 856(c)(4)(B)(ii) is amended by striking “20 percent” and inserting “25 percent”.
(b) Effective date.—The amendment made by this section shall apply to taxable years beginning after December 31, …
For purposes of applying section 304(b) of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (division EE of Public Law 116–260), section 301 of such Act shall be applied by substituting the date of the …
(a) In general.—Part IV of subchapter O of chapter 1 is amended by redesignating section 1062 as section 1063 and by inserting after section 1061 the following new section:
“SEC. 1062. Gain from the sale or exchange of …
(a) Transfer tax.—Section 5811(a) is amended to read as follows:
“(a) Rate.—There shall be levied, collected, and paid on firearms transferred a tax at the rate of—
“(1) $200 for each firearm transferred in the case of a …
(a) In general.—Part III of subchapter B of chapter 1, as amended by the preceding provisions of this Act, is amended by inserting after section 139K the following new section:
“SEC. 139L. Interest on loans secured by …
(a) Election to treat costs as expenses.—Section 181(a)(1) is amended by striking “qualified film or television production, and any qualified live theatrical production,” and inserting “qualified film or television …
(a) In general.—Section 6041(a) is amended by striking “$600” and inserting “$2,000”.
(b) Inflation adjustment.—Section 6041 is amended by adding at the end the following new subsection:
“(h) Inflation adjustment.—In the …
(a) Reinstatement of exception for de minimis payments as in effect prior to enactment of American Rescue Plan Act of 2021.—
(1) IN GENERAL.—Section 6050W(e) is amended to read as follows:
“(e) Exception for de minimis …
(a) Phased increase in exclusion for gain from qualified small business stock.—
(1) IN GENERAL.—Section 1202(a)(1) is amended to read as follows:
“(1) IN GENERAL.— In the case of a taxpayer other than a corporation, …
SEC. 70421. Permanent renewal and enhancement of opportunity zones.
(a) Decennial designations.—
(1) DETERMINATION PERIOD.—Section 1400Z-1(c)(2)(B) is amended by striking “beginning on the date of the enactment of the …
(a) In general.—Section 460(e) is amended—
(1) in paragraph (1)—
(A) by striking “home construction contract” both places it appears and inserting “residential construction contract”, and
(B) by inserting “(determined by …
(a) In general.—Section 170(n)(1) of the Internal Revenue Code of 1986 is amended by striking “$10,000” and inserting “$50,000”.
(b) Effective date.—The amendments made by this section shall apply to taxable years …
(a) In general.—For purposes of subchapter F of chapter 1 of the Internal Revenue Code of 1986, any activity substantially related to participation or investment in fisheries in the Bering Sea and Aleutian Islands …
(a) In general.—Paragraph (1) of section 7652(f) is amended to read as follows:
“(1) $13.25, or”.
(b) Effective date.—The amendment made by this section shall apply to distilled spirits brought into the United States …
(a) In general.—Section 170(b)(2)(A) is amended to read as follows:
“(A) IN GENERAL.—Any charitable contribution otherwise allowable (without regard to this subparagraph) as a deduction under this section for any taxable …
(a) In general.—
(1) IN GENERAL.—Paragraph (1) of section 170(b) is amended by adding at the end the following new subparagraph:
“(I) 0.5-PERCENT FLOOR.—Any charitable contribution otherwise allowable (without regard to …
(a) In general.—Section 170(p) is amended—
(1) by striking “$300 ($600” and inserting “$1,000 ($2,000”, and
(2) by striking “beginning in 2021”.
(b) Effective date.—The amendments made by this section shall apply to …
(a) In general.—Section 45D(f)(1)(H) is amended by striking “for for each of calendar years 2020 through 2025” and inserting “ for each calendar year after 2019”.
(b) Carryover of unused limitation.—Section 45D(f)(3) is …
(a) Permanent State housing credit ceiling increase for low-income housing credit.—
(1) IN GENERAL.—Section 42(h)(3)(I) is amended—
(A) by striking “2018, 2019, 2020, and 2021,” and inserting “beginning after December …
(a) Decennial designations.—
(1) DETERMINATION PERIOD.—Section 1400Z-1(c)(2)(B) is amended by striking “beginning on the date of the enactment of the Tax Cuts and Jobs Act” and inserting “beginning on the decennial …
SEC. 70411. Tax credit for contributions of individuals to scholarship granting organizations.
(a) Allowance of credit for contributions of individuals to scholarship granting organizations.—
(1) IN GENERAL.—Subpart A of …
(a) In general.—Section 4960(c)(2) is amended to read as follows:
“(2) COVERED EMPLOYEE.—For purposes of this section, the term ‘covered employee’ means any employee of an applicable tax-exempt organization (or any …
(a) In general.—Section 4968 is amended to read as follows:
“SEC. 4968. Excise tax based on investment income of private colleges and universities.
“(a) Tax imposed.—There is hereby imposed on each applicable educational …
(a) In general.—Section 529(e)(3) is amended by adding at the end the following new subparagraph:
“(C) CERTAIN POSTSECONDARY CREDENTIALING EXPENSES.—The term ‘qualified higher education expenses’ includes qualified …
(a) In general.—
(1) IN GENERAL.—Section 529(c)(7) is amended to read as follows:
“(7) TREATMENT OF ELEMENTARY AND SECONDARY TUITION.—Any reference in this section to the term ‘qualified higher education expense’ shall …
(a) In general.—Section 127(c)(1)(B) is amended by striking “in the case of payments made before January 1, 2026,”.
(b) Inflation adjustment.—Section 127 is amended—
(1) by redesignating subsection (d) as subsection (e), …
(a) Allowance of credit for contributions of individuals to scholarship granting organizations.—
(1) IN GENERAL.—Subpart A of part IV of subchapter A of chapter 1 is amended by inserting after section 25E the following …
SEC. 70401. Enhancement of employer-provided child care credit.
(a) Increase of amount of qualified child care expenditures taken into account.—Section 45F(a)(1) is amended by striking “25 percent” and inserting “40 …
(a) In general.—Paragraph (2) of section 21(a) is amended to read as follows:
“(2) APPLICABLE PERCENTAGE DEFINED.—For purposes of paragraph (1), the term ‘applicable percentage’ means 50 percent—
“(A) reduced (but not …
(a) In general.—Section 129(a)(2)(A) is amended by striking “$5,000 ($2,500” and inserting “$7,500 ($3,750”.
(b) Effective date.—The amendment made by this section shall apply to taxable years beginning after December …
(a) In general.—Section 23(d)(3) is amended—
(1) in subparagraph (A), by inserting “or Indian tribal government” after “a State”, and
(2) in subparagraph (B), by inserting “or Indian tribal government” after “such …
(a) In general.—Section 23(a) is amended by adding at the end the following new paragraph:
“(4) PORTION OF CREDIT REFUNDABLE.—So much of the credit allowed under paragraph (1) as does not exceed $5,000 shall be treated …
(a) Increase of amount of qualified child care expenditures taken into account.—Section 45F(a)(1) is amended by striking “25 percent” and inserting “40 percent (50 percent in the case of an eligible small business)”.
(b) …
PART I—Foreign tax credit
SEC. 70311. Modifications related to foreign tax credit limitation.
(a) Rules for allocation of certain deductions to foreign source net CFC tested income for purposes of foreign tax credit …
SUBCHAPTER A—PERMANENT U.S. BUSINESS TAX REFORM AND BOOSTING DOMESTIC INVESTMENT
SEC. 70301. Full expensing for certain business property.
(a) Made permanent.—
(1) IN GENERAL.—Section 168(k)(2)(A) is amended by adding …
SEC. 70351. Permanent extension of look-thru rule for related controlled foreign corporations.
(a) In general.—Section 954(c)(6)(C) is amended by striking “and before January 1, 2026,”.
(b) Effective date.—The amendment …
(a) In general.—Subsection (a) of section 951 is amended to read as follows:
“(a) Amounts included.—
“(1) IN GENERAL.—If a foreign corporation is a controlled foreign corporation at any time during a taxable year of the …
(a) In general.—Section 958(b) is amended—
(1) by inserting after paragraph (3) the following:
“(4) Subparagraphs (A), (B), and (C) of section 318(a)(3) shall not be applied so as to consider a United States person as …
(a) In general.—Section 898(c) is amended by striking paragraph (2) and redesignating paragraph (3) as paragraph (2).
(b) Effective date.—The amendments made by this section shall apply to taxable years of specified …
(a) In general.—Section 954(c)(6)(C) is amended by striking “and before January 1, 2026,”.
(b) Effective date.—The amendment made by this section shall apply to taxable years of foreign corporations beginning after …
SEC. 70341. Coordination of business interest limitation with interest capitalization provisions.
(a) In general.—Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by …
SEC. 70342. Definition of adjusted taxable income for business interest limitation.
(a) In general.—Subparagraph (A) of section 163(j)(8) is amended—
(1) by striking “and” at the end of clause (iv), and
(2) by adding at …
(a) In general.—Section 163(j) is amended by redesignating paragraphs (10) and (11) as paragraphs (11) and (12) and by inserting after paragraph (9) the following:
“(10) COORDINATION WITH INTEREST CAPITALIZATION …
SEC. 70331. Extension and modification of base erosion minimum tax amount.
(a) In general.—Section 59A(b) is amended—
(1) by striking “10 percent” in paragraph (1) and inserting “10.5 percent”, and
(2) by striking …
(a) In general.—Section 59A(b) is amended—
(1) by striking “10 percent” in paragraph (1) and inserting “10.5 percent”, and
(2) by striking paragraph (2) and by redesignating paragraphs (3) and (4) as paragraphs (2) and …
SEC. 70321. Modification of deduction for foreign-derived deduction eligible income and net CFC tested income.
(a) In general.—Section 250(a) is amended—
(1) by striking “37.5 percent” in paragraph (1)(A) and inserting …
(a) Taxation of net CFC tested income.—
(1) IN GENERAL.—Section 951A(a) is amended by striking “global intangible low-taxed income” and inserting “net CFC tested income”.
(2) REPEAL OF TAX-FREE DEEMED RETURN ON FOREIGN …
(a) Sales or other dispositions of certain property.—
(1) IN GENERAL.—Section 250(b)(3)(A)(i) is amended—
(A) by striking “and” at the end of subclause (V),
(B) by striking “over” at the end of subclause (VI) and …
(a) In general.—Section 250(a) is amended—
(1) by striking “37.5 percent” in paragraph (1)(A) and inserting “33.34 percent”,
(2) by striking “50 percent” in paragraph (1)(B) and inserting “40 percent”, and
(3) by …
SEC. 70311. Modifications related to foreign tax credit limitation.
(a) Rules for allocation of certain deductions to foreign source net CFC tested income for purposes of foreign tax credit limitation.—Section 904(b) is …