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[House Report 114-16]
[From the U.S. Government Publishing Office]

114th Congress   }                                       {       Report
                        HOUSE OF REPRESENTATIVES
 1st Session     }                                       {       114-16

======================================================================

 
      PERMANENT S CORPORATION CHARITABLE CONTRIBUTION ACT OF 2015

                                _______
                                

February 9, 2015.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

                                _______
                                

Mr. Ryan of Wisconsin, from the Committee on Ways and Means, submitted 
                             the following

                              R E P O R T

                             together with

                            DISSENTING VIEWS

                        [To accompany H.R. 630]

      [Including cost estimate of the Congressional Budget Office]

    The Committee on Ways and Means, to whom was referred the 
bill (H.R. 630) to amend the Internal Revenue Code of 1986 to 
make permanent certain rules regarding basis adjustments to 
stock of S corporations making charitable contributions of 
property, having considered the same, report favorably thereon 
with an amendment and recommend 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.................................     2
 II. EXPLANATION OF THE BILL..........................................3
          A. Permanent Rule Regarding Basis Adjustment to Stock 
              of S Corporations Making Charitable Contributions 
              of Property (sec. 1367 of the Code)................     3
III. VOTES OF THE COMMITTEE...........................................4
 IV. BUDGET EFFECTS OF THE BILL.......................................4
          A. Committee Estimate of Budgetary Effects.............     4
          B. Statement Regarding New Budget Authority and Tax 
              Expenditures Budget Authority......................     5
          C. Cost Estimate Prepared by the Congressional Budget 
              Office.............................................     5
  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. Information Relating to Unfunded Mandates...........     6
          D. Applicability of House Rule XXI 5(b)................     7
          E. Tax Complexity Analysis.............................     7
          F. Congressional Earmarks, Limited Tax Benefits, and 
              Limited Tariff Benefits............................     7
          G. Duplication of Federal Programs.....................     7
          H. Disclosure of Directed Rule Makings.................     7
 VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED............8
VII. DISSENTING VIEWS.................................................9

    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 ``Permanent S Corporation Charitable 
Contribution Act of 2015''.

SEC. 2. PERMANENT RULE REGARDING BASIS ADJUSTMENT TO STOCK OF S 
                    CORPORATIONS MAKING CHARITABLE CONTRIBUTIONS OF 
                    PROPERTY.

  (a) In General.--Section 1367(a)(2) of the Internal Revenue Code of 
1986 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.

                       I. SUMMARY AND BACKGROUND

                         A. Purpose and Summary

    H.R. 630, reported by the Committee on Ways and Means, 
provides that a shareholder's basis in his S corporation stock 
is decreased by the adjusted basis of any charitable 
contributions made by the S corporation, rather than the fair 
market value. An identical, temporary provision expired for 
taxable years beginning after December 31, 2014.

                 B. Background and Need for Legislation

    While the Committee continues actively to pursue 
comprehensive tax reform as a critical means of promoting 
economic growth and job creation, the Committee also believes 
that it is important to provide small businesses permanent, 
immediate tax relief in order to help encourage economic growth 
and job creation. By providing small businesses with a 
permanent rule for adjusting the shareholders' basis in stock 
of an S corporation making charitable contributions, H.R. 630 
corrects a disparity between the treatment of charitable 
contributions made by S corporations and partnerships, which 
can result in a future tax liability for shareholders of an S 
corporation that donates appreciated property. H.R. 630 will 
level the playing field between S corporations and other types 
of businesses and provide S corporations with greater certainty 
so they can plan for charitable giving that is in the best 
interest of the company, its shareholders, and the charitable 
organizations receiving such donations.

                         C. Legislative History

Background

    H.R. 630 was introduced on January 30, 2015, and was 
referred to the Committee on Ways and Means.

Committee action

    The Committee on Ways and Means marked up H.R. 630, the 
Permanent S Corporation Charitable Contribution Act of 2015, on 
February 4, 2015, and ordered the bill, as amended, favorably 
reported (with a quorum being present).

Committee hearings

    The need for permanent rules regarding basis adjustments to 
stock of S corporations making charitable contributions of 
property was discussed at no fewer than four hearings during 
the 112th and 113th Congresses:
            Full Committee hearing on Fundamental Tax 
        Reform (January 20, 2011);
            Full Committee hearing on the Treatment of 
        Closely-Held Businesses in the Context of Tax Reform 
        (March 7, 2012);
            Full Committee hearing on the Small 
        Business and Pass-Through Entity Tax Reform Discussion 
        Draft (May 15, 2013); and
            Full Committee hearing on the Benefits of 
        Permanent Tax Policy for America's Job Creators (April 
        8, 2014).

                      II. EXPLANATION OF THE BILL

A. Permanent Rule Regarding Basis Adjustment to Stock of S Corporations 
  Making Charitable Contributions of Property (sec. 1367 of the Code)

                              PRESENT LAW

    Under present law, if an S corporation makes a charitable 
contribution of money or other property, each shareholder takes 
into account the shareholder's pro rata share of the 
contribution in determining its own income tax liability.\1\ A 
shareholder of an S corporation reduces the basis in the stock 
of the S corporation by the shareholder's pro rata share of the 
S corporation's charitable contributions.\2\
---------------------------------------------------------------------------
    \1\Sec. 1366(a)(1)(A).
    \2\Sec. 1367(a)(2)(B). See also the last sentence of section 
1366(a)(1) referencing sec. 702(a)(4).
---------------------------------------------------------------------------
    In the case of contributions made in taxable years 
beginning before January 1, 2015, the amount of a shareholder's 
basis reduction in the stock of an S corporation on account of 
a charitable contribution made by the corporation is the 
shareholder's pro rata share of the adjusted basis of the 
contributed property. For contributions made in taxable years 
beginning after December 31, 2014, the amount of the reduction 
is the shareholder's pro rata share of the fair market value of 
the contributed property.

                           REASONS FOR CHANGE

    The Committee believes that the provision regarding basis 
adjustments to S corporation stock should be made permanent to 
prevent S corporation shareholders from losing the tax benefit 
of the deduction for charitable contributions of appreciated 
property when the shareholders sell their stock. Under the 
provision, S corporation shareholders will be treated in the 
same manner as other persons owning an interest in a business 
making charitable contributions, including partnerships and 
limited liability companies. The Committee also believes that 
this provision will encourage charitable giving.

                        EXPLANATION OF PROVISION

    The provision makes permanent the basis reduction rule 
applicable for contributions made in taxable years beginning 
before January 1, 2015.

                             EFFECTIVE DATE

    The provision applies to charitable contributions made in 
taxable years beginning after December 31, 2014.

                      III. VOTES OF THE COMMITTEE

    In compliance with clause 3(b) of rule XIII of the Rules of 
the House of Representatives, the following statement is made 
concerning the vote of the Committee on Ways and Means in its 
consideration of H.R. 630, the Permanent S Corporation 
Charitable Contribution Act of 2015, on February 4, 2015.
    The bill, H.R. 630, was ordered favorably reported as 
amended by a roll call vote of 24 yeas to 14 nays (with a 
quorum being present). The vote was as follows:

----------------------------------------------------------------------------------------------------------------
        Representative             Yea       Nay     Present     Representative      Yea       Nay      Present
----------------------------------------------------------------------------------------------------------------
Mr. Ryan......................        X   ........  .........  Mr. Levin........  ........         X   .........
Mr. Johnson...................        X   ........  .........  Mr. Rangel.......  ........         X   .........
Mr. Brady.....................        X   ........  .........  Mr. McDermott....  ........         X   .........
Mr. Nunes.....................        X   ........  .........  Mr. Lewis........  ........         X   .........
Mr. Tiberi....................        X   ........  .........  Mr. Neal.........  ........         X   .........
Mr. Reichert..................        X   ........  .........  Mr. Becerra......  ........         X   .........
Mr. Boustany..................        X   ........  .........  Mr. Doggett......  ........         X   .........
Mr. Roskam....................        X   ........  .........  Mr. Thompson.....  ........         X   .........
Mr. Price.....................        X   ........  .........  Mr. Larson.......  ........         X   .........
Mr. Buchanan..................        X   ........  .........  Mr. Blumenauer...  ........  .........  .........
Mr. Smith (NE)................        X   ........  .........  Mr. Kind.........  ........         X   .........
Mr. Schock....................        X   ........  .........  Mr. Pascrell.....  ........         X   .........
Ms. Jenkins...................        X   ........  .........  Mr. Crowley......  ........         X   .........
Mr. Paulsen...................        X   ........  .........  Mr. Davis........  ........         X   .........
Mr. Marchant..................        X   ........  .........  Ms. Sanchez......  ........         X   .........
Ms. Black.....................        X   ........  .........
Mr. Reed......................        X   ........  .........
Mr. Young.....................        X   ........  .........
Mr. Kelly.....................        X   ........  .........
Mr. Renacci...................        X   ........  .........
Mr. Meehan....................        X   ........  .........
Ms. Noem......................        X   ........  .........
Mr. Holding...................        X   ........  .........
Mr. Smith (MO)................        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. 630, as 
reported.
    The bill, as reported, is estimated to have the following 
effect on Federal budget receipts for fiscal years 2015-2025:

                                                  FISCAL YEARS
                                              [Millions of dollars]
----------------------------------------------------------------------------------------------------------------
  2015     2016     2017     2018     2019     2020    2021    2022    2023    2024    2025    2015-20   2015-25
----------------------------------------------------------------------------------------------------------------
   -23      -49      -53      -55      -57      -59      -61     -64     -68     -71     -75      -296     -635
----------------------------------------------------------------------------------------------------------------
NOTE: Details do not add to totals due to rounding.

    Pursuant to clause 8 of rule XIII of the Rules of the House 
of Representatives, the following statement is made by the 
Joint Committee on Taxation with respect to the provisions of 
the bill amending the Internal Revenue Code of 1986: the gross 
budgetary effect (before incorporating macroeconomic effects) 
in any fiscal year is less than 0.25 percent of the current 
projected gross domestic product of the United States for that 
fiscal year; therefore, the bill is not ``major legislation'' 
for purposes of requiring that the estimate include the 
budgetary effects of changes in economic output, employment, 
capital stock and other macroeconomic variables.

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. The 
Committee states further that the bill involves no new or 
increased tax expenditures.

      C. Cost Estimate Prepared by the Congressional Budget Office

    In compliance with clause 3(c)(3) of rule XIII of the Rules 
of the House of Representatives, requiring a cost estimate 
prepared by the CBO, the following statement by CBO is 
provided.

                                     U.S. Congress,
                               Congressional Budget Office,
                                  Washington, DC, February 5, 2015.
Hon. Paul Ryan,
Chairman, Committee on Ways and Means,
House of Representatives, Washington, DC.
    Dear Mr. Chairman: The Congressional Budget Office has 
prepared the enclosed cost estimate for H.R. 630, the Permanent 
S Corporation Charitable Contribution Act of 2015.
    If you wish further details on this estimate, we will be 
pleased to provide them. The CBO staff contact is Nate Frentz.
            Sincerely,
                                              Douglas W. Elmendorf.
    Enclosure.

H.R. 630--Permanent S Corporation Charitable Contribution Act of 2015

    H.R. 630 would amend the Internal Revenue Code to make 
permanent a rule that expired at the end of 2014 that defines 
how a shareholder in an S corporation adjusts the basis of that 
S corporation stock to account for that corporation's 
contributions of property to charity. This legislation would 
permanently provide that a shareholder reduces S corporation 
stock basis by an amount equal to the shareholder's pro rata 
share of the adjusted basis of the contributed property, 
instead of the pro rata share of the fair market value of the 
contributed property.
    The staff of the Joint Committee on Taxation (JCT) 
estimates that enacting H.R. 630 would reduce revenues, thus 
increasing federal deficits, by $635 million over the 2015-2025 
period.
    The Statutory Pay-As-You-Go Act of 2010 establishes budget-
reporting and enforcement procedures for legislation affecting 
direct spending and revenues. Enacting H.R. 630 would result in 
revenue losses in each year beginning in 2015. The estimated 
increases in the deficit are shown in the following table.
    JCT has determined that the bill contains no 
intergovernmental or private-sector mandates as defined in the 
Unfunded Mandates Reform Act.
    The CBO staff contact for this estimate is Nathaniel 
Frentz. The estimate was approved by David Weiner, Assistant 
Director for Tax Analysis.

          CBO ESTIMATE OF PAY-AS-YOU-GO EFFECTS FOR H.R. 630, AS ORDERED REPORTED BY THE HOUSE COMMITTEE ON WAYS AND MEANS ON FEBRUARY 4, 2015
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                    By fiscal year, in millions of dollars--
                                                      --------------------------------------------------------------------------------------------------
                                                        2015   2016   2017   2018   2019   2020   2021   2022   2023   2024   2025  2015-2020  2015-2025
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                               NET INCREASE IN THE DEFICIT
 
Statutory Pay-As-You-Go Impact.......................     23     49     53     55     57     59     61     64     68     71     75       296       635
--------------------------------------------------------------------------------------------------------------------------------------------------------
Source: Staff of the Joint Committee on Taxation.

     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 (relating to oversight findings), 
the Committee advises that it was as a result of the 
Committee's review of the provisions of H.R. 630 that the 
Committee concluded that it is appropriate to report the bill, 
as amended, favorably to the House of Representatives with the 
recommendation that the bill do pass.

        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 contains no measure that authorizes funding, so no 
statement of general performance goals and objectives for which 
any measure authorizes funding is required.

              C. 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.

                D. Applicability of House Rule XXI 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 
involve any Federal income tax rate increases within the 
meaning of the rule.

                       E. Tax Complexity Analysis

    Section 4022(b) of the Internal Revenue Service 
Restructuring and Reform 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.
    Pursuant to clause 3(h)(1) of rule XIII of the Rules of the 
House of Representatives, the staff of the Joint Committee on 
Taxation has determined that a complexity analysis is not 
required under section 4022(b) of the IRS Reform Act because 
the bill contains no provisions that amend the Code and that 
have ``widespread applicability'' to individuals or small 
businesses, within the meaning of the rule.

  F. 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.

                   G. Duplication of Federal Programs

    In compliance with Sec. 3(g)(2) of H. Res. 5 (114th 
Congress), 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 (Public Law 95-220, as amended by Public Law 
98-169).

                 H. Disclosure of Directed Rule Makings

    In compliance with Sec. 3(i) of H. Res. 5 (114th Congress), 
the following statement is made concerning directed rule 
makings: The Committee estimates that the bill requires no 
directed rule makings within the meaning of such section.

       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 (existing law 
proposed to be omitted is enclosed in black brackets, new 
matter is printed in italic, 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 S--Tax Treatment of S Corporations and Their Shareholders

           *       *       *       *       *       *       *

PART II--TAX TREATMENT OF SHAREHOLDERS

           *       *       *       *       *       *       *

SEC. 1367. ADJUSTMENTS TO BASIS OF STOCK OF SHAREHOLDERS, ETC.

  (a) General Rule.--
          (1) Increases in basis.--The basis of each 
        shareholder's stock in an S corporation shall be 
        increased for any period by the sum of the following 
        items determined with respect to that shareholder for 
        such period:
                  (A) the items of income described in 
                subparagraph (A) of section 1366(a)(1),
                  (B) any nonseparately computed income 
                determined under subparagraph (B) of section 
                1366(a)(1), and
                  (C) the excess of the deductions for 
                depletion over the basis of the property 
                subject to depletion.
          (2) Decreases in basis.--The basis of each 
        shareholder's stock in an S corporation shall be 
        decreased for any period (but not below zero) by the 
        sum of the following items determined with respect to 
        the shareholder for such period:
                  (A) distributions by the corporation which 
                were not includible in the income of the 
                shareholder by reason of section 1368,
                  (B) the items of loss and deduction described 
                in subparagraph (A) of section 1366(a)(1),
                  (C) any nonseparately computed loss 
                determined under subparagraph (B) of section 
                1366(a)(1),
                  (D) any expense of the corporation not 
                deductible in computing its taxable income and 
                not properly chargeable to capital account, and
                  (E) the amount of the shareholder's deduction 
                for depletion for any oil and gas property held 
                by the S corporation to the extent such 
                deduction does not exceed the proportionate 
                share of the adjusted basis of such property 
                allocated to such shareholder under section 
                613A(c)(11)(B).
        The decrease under subparagraph (B) by reason of a 
        charitable contribution (as defined in section 170(c)) 
        of property shall be the amount equal to the 
        shareholder's pro rata share of the adjusted basis of 
        such property. [The preceding sentence shall not apply 
        to contributions made in taxable years beginning after 
        December 31, 2014.]
  (b) Special Rules.--
          (1) Income items.--An amount which is required to be 
        included in the gross income of a shareholder and shown 
        on his return shall be taken into account under 
        subparagraph (A) or (B) of subsection (a)(1) only to 
        the extent such amount is included in the shareholder's 
        gross income on his return, increased or decreased by 
        any adjustment of such amount in a redetermination of 
        the shareholder's tax liability.
          (2) Adjustments in basis of indebtedness.--
                  (A) Reduction of basis.--If for any taxable 
                year the amounts specified in subparagraphs 
                (B), (C), (D), and (E) of subsection (a)(2) 
                exceed the amount which reduces the 
                shareholder's basis to zero, such excess shall 
                be applied to reduce (but not below zero) the 
                shareholder's basis in any indebtedness of the 
                S corporation to the shareholder.
                  (B) Restoration of basis.--If for any taxable 
                year beginning after December 31, 1982, there 
                is a reduction under subparagraph (A) in the 
                shareholder's basis in the indebtedness of an S 
                corporation to a shareholder, any net increase 
                (after the application of paragraphs (1) and 
                (2) of subsection (a)) for any subsequent 
                taxable year shall be applied to restore such 
                reduction in basis before any of it may be used 
                to increase the shareholder's basis in the 
                stock of the S corporation.
          (3) Coordination with sections 165(g) and 166(d).--
        This section and section 1366 shall be applied before 
        the application of sections 165(g) and 166(d) to any 
        taxable year of the shareholder or the corporation in 
        which the security or debt becomes worthless.
          (4) Adjustments in case of inherited stock.--
                  (A) In general.--If any person acquires stock 
                in an S corporation by reason of the death of a 
                decedent or by bequest, devise, or inheritance, 
                section 691 shall be applied with respect to 
                any item of income of the S corporation in the 
                same manner as if the decedent had held 
                directly his pro rata share of such item.
                  (B) Adjustments to basis.--The basis 
                determined under section 1014 of any stock in 
                an S corporation shall be reduced by the 
                portion of the value of the stock which is 
                attributable to items constituting income in 
                respect of the decedent.

           *       *       *       *       *       *       *

      
      

                         VII. DISSENTING VIEWS

    The seven bills approved by the Republicans at the markup 
would add more than $93 billion to the deficit--and if history 
is our guide, this is merely the start of the approach the 
Republicans embraced last Congress. In the 113th Congress, Ways 
and Means Committee Republicans approved $825 billion worth of 
deficit-financed, permanent tax cuts. The bills marked up by 
the Committee set us down a partisan path, when we should be 
embracing bipartisanship and working in a responsible, 
bipartisan manner on tax reform.

    Even though some of these bills were introduced 
individually with some bipartisan support, the opposition to 
these bills was based on the position that these tax provisions 
should not be made permanent by adding to the deficit without 
any revenue offset. Our nation's small businesses play a vital 
role in the economy. They are the backbone of our communities, 
creating jobs, economic growth, and harnessing the American 
entrepreneurial spirit--this is undeniable. But the approach 
that the Committee Republicans are taking with respect to this 
and other important legislation undermines that bipartisan 
support that the provisions enjoy. The American people expect a 
tax code that maintains and supports our shared priorities, and 
each time the Committee considers these bills in a piecemeal 
approach, it is taking a step in the wrong direction and away 
from comprehensive tax reform.

    We all support the small businesses in our communities and 
across the nation. The markup was not to debate the economic 
growth driven by small businesses, the role of small businesses 
donations in our country's charitable giving, or the merits of 
H.R. 630, which would make permanent the certain rules 
regarding basis adjustments to the stock of S corporations 
making charitable contributions of property.

    Finally, we also oppose the manner in which Republicans 
were proceeding--selecting seven provisions to make permanent 
at a cost of nearly $100 billion without any offset from the 
approximately 60 tax provisions that expired at the end of last 
year. This approach is both fiscally irresponsible and contrary 
to the goals of bipartisan, comprehensive tax reform.
    Expired provisions must be dealt with in a comprehensive 
manner. The Republicans did not take up other tax extenders 
that also are important to Democratic Committee Members. Left 
to an uncertain fate are provisions like the Work Opportunity 
Tax Credit, the New Markets Tax Credit, and the renewable 
energy tax credits, as well as the long-term status of the 
Earned Income Tax Credit, the Child Tax Credit, and the 
American Opportunity Tax Credit.

                                   Sander M. Levin.

                                  [all]
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