IB 

Union Calendar No. 275 

116TH CONGRESS 

1ST SESSION H. R. 5377 

[Report No. 116–345] 

To amend the Internal Revenue Code of 1986 to modify the limitation 

on deduction of State and local taxes, and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

DECEMBER 10, 2019 

Mr. SUOZZI (for himself, Mr. THOMPSON of California, Mr. PASCRELL, Mr. 

KING of New York, Mr. BEYER, Mr. BRENDAN F. BOYLE of Pennsylvania, Ms. JUDY CHU of California, Mr. DANNY K. DAVIS of Illinois, Mr. 

HIGGINS of New York, Mr. LARSON of Connecticut, Mr. PANETTA, Ms. 

SA ́NCHEZ, Mr. SCHNEIDER, Mr. CASTEN of Illinois, Mr. CISNEROS, Mr. 

CORREA, Ms. CRAIG, Mr. ENGEL, Ms. ESHOO, Mr. KIM, Mr. LEVIN of 

California, Mrs. LOWEY, Mr. MALINOWSKI, Mr. MEEKS, Ms. MENG, Mr. 

MORELLE, Mr. NADLER, Mr. PHILLIPS, Ms. PORTER, Mr. RASKIN, Miss 

RICE of New York, Mr. ROSE of New York, Ms. SHERRILL, Mr. SIRES, 

Mr. TRONE, Ms. UNDERWOOD, Mrs. WATSON COLEMAN, Mr. COURTNEY, 

Mr. ESPAILLAT, and Mr. HARDER of California) introduced the following 

bill; which was referred to the Committee on Ways and Means 

DECEMBER 13, 2019 

Additional sponsors: Mr. SEAN PATRICK MALONEY of New York, Mr. 

KRISHNAMOORTHI, Mr. HUFFMAN, Mr. GONZALEZ of Texas, Mr. GOMEZ, 

Ms. WEXTON, Ms. NORTON, Ms. DELAURO, Mr. TED LIEU of California, 

Mr. BROWN of Maryland, Mr. PALLONE, Mrs. DAVIS of California, and 

Ms. SPEIER

DECEMBER 13, 2019 

Reported with an amendment, committed to the Committee of the Whole 

House on the State of the Union, and ordered to be printed 

[Strike out all after the enacting clause and insert the part printed in italic] 

[For text of introduced bill, see copy of bill as introduced on December 10, 2019] 


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A BILL 

To amend the Internal Revenue Code of 1986 to modify 

the limitation on deduction of State and local taxes, 

and for other purposes. 


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1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Restoring Tax Fairness 

5 for States and Localities Act’’. 

6 SEC. 2. ELIMINATION FOR 2019 OF MARRIAGE PENALTY IN 

7 LIMITATION ON DEDUCTION OF STATE AND 

8 LOCAL TAXES. 

9 (a) IN GENERAL.—Section 164(b) of the Internal Rev10 enue Code of 1986 is amended by adding at the end the 

11 following new paragraph: 

12 ‘‘(7) SPECIAL RULE FOR LIMITATION ON INDI13 VIDUAL DEDUCTIONS FOR 2019.—In the case of a tax14 able year beginning after December 31, 2018, and be15 fore January 1, 2020, paragraph (6) shall be applied 

16 by substituting ‘($20,000 in the case of a joint re17 turn)’ for ‘($5,000 in the case of a married individual 

18 filing a separate return)’.’’. 

19 (b) EFFECTIVE DATE.—The amendment made by this 

20 section shall apply to taxable years beginning after Decem21 ber 31, 2018. 

22 SEC. 3. ELIMINATION FOR 2020 AND 2021 OF LIMITATION ON 

23 DEDUCTION OF STATE AND LOCAL TAXES. 

24 (a) IN GENERAL.—Section 164(b)(6)(B) of the Inter25 nal Revenue Code of 1986 is amended by inserting ‘‘in the 


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1 case of a taxable year beginning before January 1, 2020, 

2 or after December 31, 2021,’’ before ‘‘the aggregate amount 

3 of taxes’’. 

4 (b) CONFORMING AMENDMENTS.—Section 164(b)(6) of 

5 the Internal Revenue Code of 1986 is amended— 

6 (1) by striking ‘‘For purposes of subparagraph 

7 (B)’’ and inserting ‘‘For purposes of this section’’, 

8 (2) by striking ‘‘January 1, 2018’’ and inserting 

9 ‘‘January 1, 2022’’, 

10 (3) by striking ‘‘December 31, 2017, shall’’ and 

11 inserting ‘‘December 31, 2021, shall’’, and 

12 (4) by adding at the end the following: ‘‘For pur13 poses of this section, in the case of State or local taxes 

14 with respect to any real or personal property paid 

15 during a taxable year beginning in 2020 or 2021, the 

16 Secretary shall prescribe rules which treat all or a 

17 portion of such taxes as paid in a taxable year or 

18 years other than the taxable year in which actually 

19 paid as necessary or appropriate to prevent the 

20 avoidance of the limitations of this subsection.’’. 

21 (c) EFFECTIVE DATE.—The amendments made by this 

22 section shall apply to taxes paid or accrued in taxable years 

23 beginning after December 31, 2019. 


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1 SEC. 4. INCREASE IN DEDUCTION FOR CERTAIN EXPENSES 

2 OF ELEMENTARY AND SECONDARY SCHOOL 

3 TEACHERS. 

4 (a) INCREASE.—Section 62(a)(2)(D) of the Internal 

5 Revenue Code of 1986 is amended by striking ‘‘$250’’ and 

6 inserting ‘‘$500’’. 

7 (b) CONFORMING AMENDMENTS.—Section 62(d)(3) of 

8 the Internal Revenue Code of 1986 is amended— 

9 (1) by striking ‘‘2015’’ and inserting ‘‘2019’’, 

10 (2) by striking ‘‘$250’’ and inserting ‘‘$500’’, 

11 and 

12 (3) in subparagraph (B), by striking ‘‘2014’’ and 

13 inserting ‘‘2018’’. 

14 (c) EFFECTIVE DATE.—The amendments made by this 

15 section shall apply to taxable years beginning after Decem16 ber 31, 2018. 

17 SEC. 5. ABOVE-THE-LINE DEDUCTION ALLOWED FOR CER18 TAIN EXPENSES OF FIRST RESPONDERS. 

19 (a) IN GENERAL.—Section 62(a)(2) of the Internal 

20 Revenue Code of 1986 is amended by adding at the end 

21 the following new subparagraph: 

22 ‘‘(F) CERTAIN EXPENSES OF FIRST RE23 SPONDERS.—The deductions allowed by section 

24 162 which consist of expenses, not in excess of 

25 $500, paid or incurred by a first responder— 


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1 ‘‘(i) as tuition or fees for the participa2 tion of the first responder in professional 

3 development courses related to service as a 

4 first responder, or 

5 ‘‘(ii) for uniforms used by the first re6 sponder in service as a first responder.’’. 

7 (b) FIRST RESPONDER DEFINED.—Section 62(d) of 

8 the Internal Revenue Code of 1986 is amended by adding 

9 at the end the following new paragraph: 

10 ‘‘(4) FIRST RESPONDER.—For purposes of sub11 section (a)(2)(F), the term ‘first responder’ means, 

12 with respect to any taxable year, any individual who 

13 is employed as a law enforcement officer, firefighter, 

14 paramedic, or emergency medical technician for at 

15 least 1000 hours during such taxable year.’’. 

16 (c) INFLATION ADJUSTMENT.—Section 62(d)(3) of the 

17 Internal Revenue Code of 1986, as amended by section 4, 

18 is further amended by striking ‘‘the $500 amount in sub19 section (a)(2)(D)’’ and inserting ‘‘the $500 amount in each 

20 of subparagraphs (D) and (F) of subsection (a)(2)’’. 

21 (d) EFFECTIVE DATE.—The amendments made by this 

22 section shall apply to taxable years beginning after Decem23 ber 31, 2019. 


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1 SEC. 6. INCREASE OF TOP MARGINAL INDIVIDUAL INCOME 

2 TAX RATE UNDER TEMPORARY RULES. 

3 (a) IN GENERAL.—The tables contained in subpara4 graphs (A), (B), (C), (D), and (E) of section 1(j)(2) of the 

5 Internal Revenue Code of 1986 are each amended by strik6 ing ‘‘37%’’ and inserting ‘‘39.6%’’ and— 

7 (1) in subparagraph (A)— 

8 (A) by striking ‘‘$600,000’’ each place such 

9 term appears and inserting ‘‘$479,000’’, and 

10 (B) by striking ‘‘$161,379’’ and inserting 

11 ‘‘$119,029’’, 

12 (2) in subparagraph (B)— 

13 (A) by striking ‘‘$500,000’’ each place such 

14 term appears and inserting ‘‘$452,400’’, and 

15 (B) by striking ‘‘$149,298’’ and inserting 

16 ‘‘$132,638’’, 

17 (3) in subparagraph (C)— 

18 (A) by striking ‘‘$500,000’’ each place such 

19 term appears and inserting ‘‘$425,800’’, and 

20 (B) by striking ‘‘$150,689.50’’ and inserting 

21 ‘‘$124,719.50’’, and 

22 (4) in subparagraph (D)— 

23 (A) by striking ‘‘$300,000’’ each place such 

24 term appears and inserting ‘‘$239,500’’, and 

25 (B) by striking ‘‘$80,689.50’’ and inserting 

26 ‘‘$59,514.50’’. 


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1 (b) CONFORMING AMENDMENTS.— 

2 (1) Section 1(j)(4)(B)(iii) of the Internal Rev3 enue Code of 1986 is amended— 

4 (A) in the matter preceding subclause (I), 

5 by striking ‘‘37 percent’’ and inserting ‘‘39.6 

6 percent’’, 

7 (B) in subclause (II), by striking ‘‘37-per8 cent bracket’’ and inserting ‘‘39.6-percent brack9 et’’, and 

10 (C) in the heading, by striking ‘‘37-PER11 CENT BRACKET’’ and inserting ‘‘39.6-PERCENT

12 BRACKET’’. 

13 (2) Section 1(j)(4)(C) of such Code is amended— 

14 (A) in clause (i)(II), by striking ‘‘para15 graph (5)(B)(i)(IV)’’ and inserting ‘‘paragraph 

16 (5)(B)(iv)’’, and 

17 (B) by amending clause (ii) to read as fol18 lows: 

19 ‘‘(ii) the amount which would (without 

20 regard to this paragraph) be taxed at a rate 

21 below 39.6 percent shall not be more than 

22 the sum of— 

23 ‘‘(I) the earned taxable income of 

24 such child, plus 


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1 ‘‘(II) the maximum dollar amount 

2 for the 35-percent rate bracket for es3 tates and trusts.’’. 

4 (3) The heading of section 1(j)(5) of such Code 

5 is amended to read as follows: ‘‘APPLICATION OF

6 ZERO PERCENT CAPITAL GAIN RATE BRACKETS’’. 

7 (4) Subparagraphs (A) and (B) of section 1(j)(5) 

8 of such Code are amended to read as follows: 

9 ‘‘(A) IN GENERAL.—Subsection (h)(1)(B)(i) 

10 shall be applied by substituting ‘below the max11 imum zero rate amount’ for ‘which would (with12 out regard to this paragraph) be taxed at a rate 

13 below 25 percent’. 

14 ‘‘(B) MAXIMUM ZERO RATE AMOUNT DE15 FINED.—For purposes of subparagraph (A), the 

16 term ‘maximum zero rate amount’ means— 

17 ‘‘(i) in the case of a joint return or 

18 surviving spouse, $77,200, 

19 ‘‘(ii) in the case of an individual who 

20 is a head of household (as defined in section 

21 2(b)), $51,700, 

22 ‘‘(iii) in the case of any other indi23 vidual (other than an estate or trust), an 

amount equal to 1 24 ⁄2 of the amount in effect 

25 for the taxable year under clause (i), and 


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1 ‘‘(iv) in the case of an estate or trust, 

2 $2,600.’’. 

3 (5) Section 1(j)(5)(C) of such Code is amended 

4 by striking ‘‘clauses (i) and (ii) of’’. 

5 (c) EFFECTIVE DATE.—The amendments made by this 

6 section shall apply to taxable years beginning after Decem7 ber 31, 2019. 

8 (d) SECTION 15 NOT TO APPLY.—Section 15 of the In9 ternal Revenue Code of 1986 shall not apply to any change 

10 in a rate of tax by reason of any amendment made by this 

11 section. 


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pamtmann on DSKBC07HB2PROD with BILLS
Union Calendar No. 275 

116TH CONGRESS 

1ST SESSION H. R. 5377 

[Report No. 116–345] 

A BILL 

To amend the Internal Revenue Code of 1986 to 

local taxes, and for other purposes. modify the limitation on deduction of State and 

DECEMBER 13, 2019 

Reported with an amendment, committed to the Comand ordered to be printed mittee of the Whole House on the State of the Union, 


pamtmann on DSKBC07HB2PROD with BILLS