I 

114TH CONGRESS 

2D SESSION H. R. 6439 

To amend the Internal Revenue Code of 1986 to make technical corrections, 

and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

DECEMBER 6, 2016 

Mr. BRADY of Texas (for himself and Mr. NEAL) introduced the following bill; 

which was referred to the Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to make 

technical corrections, and for other purposes. 

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; TABLE OF CONTENTS; ETC. 

4 (a) SHORT TITLE.—This Act may be cited as the 

5 ‘‘Tax Technical Corrections Act of 2016’’. 

6 (b) AMENDMENT OF INTERNAL REVENUE CODE OF

7 1986.—Except as otherwise expressly provided, whenever 

8 in this Act an amendment or repeal is expressed in terms 

9 of an amendment to, or repeal of, a section or other provi10 sion, the reference shall be considered to be made to a 


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1 section or other provision of the Internal Revenue Code 

2 of 1986. 

3 (c) TABLE OF CONTENTS.—The table of contents for 

4 this Act is as follows: 

Sec. 1. Short title; table of contents; etc. 

TITLE I—TAX TECHNICAL CORRECTIONS 

Sec. 101. Amendments relating to Protecting Americans from Tax Hikes Act 

of 2015. 

Sec. 102. Amendment relating to Consolidated Appropriations Act, 2016. 

Sec. 103. Amendments relating to Fixing America’s Surface Transportation 

Act. 

Sec. 104. Amendments relating to Surface Transportation and Veterans Health 

Care Choice Improvement Act of 2015. 

Sec. 105. Amendments relating to Stephen Beck, Jr., ABLE Act of 2014. 

Sec. 106. Amendment relating to American Taxpayer Relief Act of 2012. 

Sec. 107. Amendment relating to United States-Korea Free Trade Agreement 

Implementation Act. 

Sec. 108. Amendment relating to SAFETEA–LU. 

Sec. 109. Amendment relating to the American Jobs Creation Act of 2004. 

TITLE II—TECHNICAL CORRECTIONS RELATED TO PARTNERSHIP 

AUDIT RULES 

Sec. 201. Scope of adjustments subject to partnership audit rules. 

Sec. 202. Determination of imputed underpayments. 

Sec. 203. Alternative procedure to filing amended returns for purposes of modifying imputed underpayment. 

Sec. 204. Treatment of passthrough partners in tiered structures. 

Sec. 205. Treatment of failure of partnership to pay imputed underpayment. 

Sec. 206. Other technical corrections related to partnership audit rules. 

Sec. 207. Effective date. 

TITLE III—OTHER CORRECTIONS 

Sec. 301. Amendments relating to the Bipartisan Budget Act of 2015. 

Sec. 302. Amendments relating to the Energy Policy Act of 2005. 

TITLE IV—CLERICAL CORRECTIONS AND DEADWOOD 

Sec. 401. Clerical corrections and deadwood-related provisions. 


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1 TITLE I—TAX TECHNICAL 

2 CORRECTIONS 

3 SEC. 101. AMENDMENTS RELATING TO PROTECTING AMER4 ICANS FROM TAX HIKES ACT OF 2015. 

5 (a) AMENDMENT RELATING TO SECTION 105.—Sec6 tion 132(f)(6)(A) is amended by striking the second sen7 tence. 

8 (b) AMENDMENTS RELATING TO SECTION 121.— 

9 Section 41(c) is amended— 

10 (1) by striking paragraph (4), 

11 (2) by redesignating paragraphs (5), (6), and 

12 (7) as paragraphs (4), (5), and (6), respectively, and 

13 (3) by striking the last sentence of paragraph 

14 (4)(C) (as so redesignated). 

15 (c) AMENDMENTS RELATING TO SECTION 143.— 

16 (1) Section 168(k)(2)(B)(i)(III) is amended by 

17 inserting ‘‘binding’’ before ‘‘contract’’. 

18 (2) Section 168(k)(5)(B)(ii) is amended— 

19 (A) by inserting ‘‘crop or’’ after ‘‘more 

20 than one’’, and 

21 (B) by inserting ‘‘a marketable crop or 

22 yield of’’ after ‘‘begins bearing’’. 

23 (3) Section 168(k)(5)(F) is amended— 


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1 (A) by striking ‘‘(or is grafted to a plant 

2 that has already been planted before such 

3 date)’’, 

4 (B) by inserting ‘‘or grafted’’ after ‘‘which 

5 is planted’’, and 

6 (C) by striking ‘‘(or so grafted)’’ in clauses 

7 (i) and (ii) and inserting ‘‘or grafted’’. 

8 (4) Section 168(k)(6) is amended to read as fol9 lows: 

10 ‘‘(6) PHASE-DOWN.—In the case of qualified 

11 property placed in service by the taxpayer after De12 cember 31, 2017 (December 31, 2018, in the case 

13 of property described in subparagraph (B) or (C) of 

14 paragraph (2)), paragraph (1)(A) shall be applied by 

15 substituting for ‘50 percent’— 

16 ‘‘(A) ‘40 percent’ in the case of— 

17 ‘‘(i) property placed in service in 2018 

18 (other than property described in subpara19 graph (B) or (C) of paragraph (2)), and 

20 ‘‘(ii) property described in subpara21 graph (B) or (C) of paragraph (2) which 

22 is placed in service in 2019, and 

23 ‘‘(B) ‘30 percent’ in the case of— 


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1 ‘‘(i) property placed in service in 2019 

2 (other than property described in subpara3 graph (B) or (C) of paragraph (2)), and 

4 ‘‘(ii) property described in subpara5 graph (B) or (C) of paragraph (2) which 

6 is placed in service in 2020.’’. 

7 (5) Section 168(k)(7) is amended by striking 

8 ‘‘paragraphs (1) and (2)(F)’’ and inserting ‘‘para9 graphs (1), (2)(F), and (4)’’. 

10 (d) AMENDMENTS RELATING TO SECTION 167.— 

11 (1) Section 168(j)(3) is amended by striking 

12 ‘‘property to which paragraph (1) applies’’ and in13 serting ‘‘qualified Indian reservation property’’. 

14 (2) Section 168(j)(8) is amended by striking 

15 ‘‘this subsection’’ and inserting ‘‘paragraph (1)’’. 

16 (e) AMENDMENTS RELATING TO SECTION 202.— 

17 (1) Section 6722(c)(3)(A) is amended— 

18 (A) by striking ‘‘any information return’’ 

19 in clause (iii) and inserting ‘‘such payee state20 ment’’, and 

21 (B) by striking ‘‘filed’’ in the flush matter 

22 at the end and inserting ‘‘furnished’’. 

23 (2) Section 202(e) of the Protecting Americans 

24 from Tax Hikes Act of 2015 is amended by striking 

25 ‘‘provided’’ and inserting ‘‘furnished’’. 


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1 (f) AMENDMENTS RELATING TO SECTION 203.— 

2 (1) Section 6109(i)(1)(A)(i) is amended by 

3 striking ‘‘community-based certified acceptance 

4 agent’’ and inserting ‘‘community-based certifying 

5 acceptance agent’’. 

6 (2) Section 6109(i)(1)(B) is amended by strik7 ing ‘‘Internal Revenue Service’’ and inserting ‘‘Inter8 nal Revenue Service, a community-based certifying 

9 acceptance agent approved by the Secretary,’’. 

10 (3) Section 6109(i)(3) is amended— 

11 (A) in subparagraph (A)— 

12 (i) by inserting ‘‘ending after the 

13 issuance of such number’’ before the period 

14 at the end of the first sentence, and 

15 (ii) by striking ‘‘on the last day of 

16 such third consecutive taxable year’’ and 

17 inserting ‘‘on the day after the due date 

18 for the return of tax for such third con19 secutive taxable year’’, and 

20 (B) by striking subparagraph (B)(ii) and 

21 inserting the following: 

22 ‘‘(ii) if the individual does not file a 

23 return of tax (or is not included as a de24 pendent on the return of tax of another 

25 taxpayer) for 3 consecutive taxable years 


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1 at least one of which ends after December 

2 18, 2015, the due date for the return of 

3 tax for such third consecutive taxable 

4 year.’’. 

5 (4) Section 203(c) of the Protecting Americans 

6 from Tax Hikes Act of 2015 is amended— 

7 (A) by striking ‘‘section 6109(i)(1)(A)(i)’’ 

8 and inserting ‘‘section 6109(i)(1)’’, 

9 (B) by striking ‘‘community-based certified 

10 acceptance agents’’ and inserting ‘‘community11 based certifying acceptance agents’’, and 

12 (C) by striking ‘‘CERTIFIED’’ in the head13 ing thereof and inserting ‘‘CERTIFYING’’. 

14 (5) Section 203(f) of the Protecting Americans 

15 from Tax Hikes Act of 2015 is amended by striking 

16 ‘‘The amendments’’ and inserting ‘‘Except to the ex17 tent provided in section 6109(i)(3) of the Internal 

18 Revenue Code of 1986, the amendments’’. 

19 (g) AMENDMENTS RELATING TO SECTION 204.— 

20 Section 204(b) of the Protecting Americans from Tax 

21 Hikes Act of 2015 is amended— 

22 (1) by striking paragraph (2), and 

23 (2) by striking so much as precedes ‘‘amend24 ment made by this section’’ and inserting the fol25 lowing: ‘‘(b) EFFECTIVE DATE.—The’’. 


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1 (h) AMENDMENTS RELATING TO SECTION 205.— 

2 (1) Section 24(e)(2) is amended by striking 

3 ‘‘identifying number’’ and inserting ‘‘taxpayer identi4 fication number’’. 

5 (2) Section 205(c) of the Protecting Americans 

6 from Tax Hikes Act of 2015 is amended— 

7 (A) by striking paragraph (2), and 

8 (B) by striking so much as precedes ‘‘shall 

9 apply to any return of tax’’ and inserting the 

10 following: ‘‘(c) EFFECTIVE DATE.—The amend11 ments made by this section’’. 

12 (i) AMENDMENTS RELATING TO SECTION 206.—Sec13 tion 206(b) of the Protecting Americans from Tax Hikes 

14 Act of 2015 is amended— 

15 (1) by striking ‘‘Except as provided in para16 graph (2), the amendment’’ in paragraph (1) and in17 serting ‘‘The amendment’’, and 

18 (2) by striking paragraph (2) and redesignating 

19 paragraph (3) as paragraph (2). 

20 (j) AMENDMENT RELATING TO SECTION 209.—Sec21 tion 209(d)(2) of the Protecting Americans from Tax 

22 Hikes Act of 2015 is amended by striking ‘‘amendment 

23 made by subsection (b)’’ and inserting ‘‘amendments made 

24 by subsections (b) and (c)’’. 


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1 (k) AMENDMENTS RELATED TO SECTIONS 102, 206, 

2 207, 208, AND 211.— 

3 (1) Section 25A(b)(1) is amended— 

4 (A) in subparagraph (A) by striking 

5 ‘‘$1,000’’ and inserting ‘‘$2,000’’, and 

6 (B) in subparagraph (B)— 

7 (i) by striking ‘‘50 percent’’ and in8 serting ‘‘25 percent’’, 

9 (ii) by striking ‘‘$1,000’’ and insert10 ing ‘‘$2,000’’, and 

11 (iii) by striking ‘‘the applicable limit’’ 

12 and inserting ‘‘$4,000’’. 

13 (2) Subparagraphs (A) and (C) of section 

14 25A(b)(2) are amended by striking ‘‘2’’ in the head15 ing and text of each subparagraph and inserting 

16 ‘‘4’’. 

17 (3) Section 25A(b)(4) is amended to read as 

18 follows: 

19 ‘‘(4) RESTRICTIONS ON TAXPAYERS WHO IM20 PROPERLY CLAIMED AMERICAN OPPORTUNITY TAX

21 CREDIT IN PRIOR YEARS.— 

22 ‘‘(A) TAXPAYERS MAKING PRIOR FRAUDU23 LENT OR RECKLESS CLAIMS.— 

24 ‘‘(i) IN GENERAL.—No American Op25 portunity Tax Credit shall be allowed 


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1 under this section for any taxable year in 

2 the disallowance period. 

3 ‘‘(ii) DISALLOWANCE PERIOD.—For 

4 purposes of subparagraph (A), the dis5 allowance period is— 

6 ‘‘(I) the period of 10 taxable 

7 years after the most recent taxable 

8 year for which there was a final deter9 mination that the taxpayer’s claim of 

10 the American Opportunity Tax Credit 

11 under this section was due to fraud, 

12 and 

13 ‘‘(II) the period of 2 taxable 

14 years after the most recent taxable 

15 year for which there was a final deter16 mination that the taxpayer’s claim of 

17 the American Opportunity Tax Credit 

18 under this section was due to reckless 

19 or intentional disregard of rules and 

20 regulations (but not due to fraud). 

21 ‘‘(B) TAXPAYERS MAKING IMPROPER

22 PRIOR CLAIMS.—In the case of a taxpayer who 

23 is denied the American Opportunity Tax Credit 

24 under this section for any taxable year as a re25 sult of the deficiency procedures under subVerDate Sep 11 2014 00:19 Dec 07, 2016 Jkt 069200 PO 00000 Frm 00010 Fmt 6652 Sfmt 6201 E:\BILLS\H6439.IH H6439

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1 chapter B of chapter 63, no American Oppor2 tunity Tax Credit shall be allowed under this 

3 section for any subsequent taxable year unless 

4 the taxpayer provides such information as the 

5 Secretary may require to demonstrate eligibility 

6 for such credit.’’. 

7 (4) Section 25A(d) is amended to read as fol8 lows: 

9 ‘‘(d) LIMITATIONS BASED ON MODIFIED ADJUSTED

10 GROSS INCOME.— 

11 ‘‘(1) AMERICAN OPPORTUNITY TAX CREDIT.— 

12 The American Opportunity Tax Credit (determined 

13 without regard to this paragraph) shall be reduced 

14 (but not below zero) by the amount which bears the 

15 same ratio to such credit (as so determined) as— 

16 ‘‘(A) the excess of— 

17 ‘‘(i) the taxpayer’s modified adjusted 

18 gross income for such taxable year, over 

19 ‘‘(ii) $80,000 ($160,000 in the case of 

20 a joint return), bears to 

21 ‘‘(B) $10,000 ($20,000 in the case of a 

22 joint return). 

23 ‘‘(2) LIFETIME LEARNING CREDIT.—The Life24 time Learning Credit (determined without regard to 

25 this paragraph) shall be reduced (but not below 


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1 zero) by the amount which bears the same ratio to 

2 such credit (as so determined) as— 

3 ‘‘(A) the excess of— 

4 ‘‘(i) the taxpayer’s modified adjusted 

5 gross income for such taxable year, over 

6 ‘‘(ii) $40,000 ($80,000 in the case of 

7 a joint return), bears to 

8 ‘‘(B) $10,000 ($20,000 in the case of a 

9 joint return). 

10 ‘‘(3) MODIFIED ADJUSTED GROSS INCOME.— 

11 For purposes of this subsection, the term ‘modified 

12 adjusted gross income’ means the adjusted gross in13 come of the taxpayer for the taxable year increased 

14 by any amount excluded from gross income under 

15 section 911, 931, or 933.’’. 

16 (5) Section 25A(f)(1) is amended by adding at 

17 the end the following new subparagraph: 

18 ‘‘(D) REQUIRED COURSE MATERIALS

19 TAKEN INTO ACCOUNT FOR AMERICAN OPPOR20 TUNITY TAX CREDIT.—For purposes of deter21 mining the American Opportunity Tax Credit, 

22 subparagraph (A) shall be applied by sub23 stituting ‘tuition, fees, and course materials’ for 

24 ‘tuition and fees’.’’. 

25 (6) Section 25A(g)(1) is amended— 


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1 (A) by striking ‘‘No credit’’ and inserting 

2 the following: 

3 ‘‘(A) IN GENERAL.—No credit’’, and 

4 (B) by adding at the end the following new 

5 subparagraph: 

6 ‘‘(B) ADDITIONAL IDENTIFICATION RE7 QUIREMENTS WITH RESPECT TO AMERICAN OP8 PORTUNITY TAX CREDIT.— 

9 ‘‘(i) STUDENT.—The requirements of 

10 subparagraph (A) shall not be treated as 

11 met with respect to the American Oppor12 tunity Tax Credit unless the individual’s 

13 taxpayer identification number was issued 

14 on or before the due date for filing the re15 turn of tax for the taxable year. 

16 ‘‘(ii) TAXPAYER.—No American Op17 portunity Tax Credit shall be allowed 

18 under this section if the taxpayer identi19 fication number of the taxpayer was issued 

20 after the due date for filing the return for 

21 the taxable year. 

22 ‘‘(iii) INSTITUTION.—No American 

23 Opportunity Tax Credit shall be allowed 

24 under this section unless the taxpayer in25 cludes the employer identification number 


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1 of any institution to which qualified tuition 

2 and related expenses were paid with re3 spect to the individual.’’. 

4 (7) Section 25A(h) is amended to read as fol5 lows: 

6 ‘‘(h) INFLATION ADJUSTMENT.— 

7 ‘‘(1) IN GENERAL.—In the case of a taxable 

8 year beginning after 2001, the $40,000 and $80,000 

9 amounts in subsection (d)(2) shall each be increased 

10 by an amount equal to— 

11 ‘‘(A) such dollar amount, multiplied by 

12 ‘‘(B) the cost-of-living adjustment deter13 mined under section 1(f)(3) for the calendar 

14 year in which the taxable year begins, deter15 mined by substituting ‘calendar year 2000’ for 

16 ‘calendar year 1992’ in subparagraph (B) 

17 thereof. 

18 ‘‘(2) ROUNDING.—If any amount as adjusted 

19 under paragraph (1) is not a multiple of $1,000, 

20 such amount shall be rounded to the next lowest 

21 multiple of $1,000.’’. 

22 (8) Section 25A(i) is amended to read as fol23 lows: 

24 ‘‘(i) PORTION OF AMERICAN OPPORTUNITY TAX

25 CREDIT MADE REFUNDABLE.—Forty percent of so much 


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1 of the credit allowed under subsection (a) as is attrib2 utable to the American Opportunity Tax Credit (deter3 mined after application of subsection (d) and without re4 gard to this paragraph and section 26(a)) shall be treated 

5 as a credit allowable under subpart C (and not allowed 

6 under subsection (a)). The preceding sentence shall not 

7 apply to any taxpayer for any taxable year if such tax8 payer is a child to whom subsection (g) of section 1 applies 

9 for such taxable year.’’. 

10 (9) The heading of section 25A is amended by 

11 striking ‘‘HOPE’’ and inserting ‘‘AMERICAN OP12 PORTUNITY’’. 

13 (10) The item relating to section 25A in the 

14 table of contents for subpart A of part IV of sub15 chapter A of chapter 1 is amended to read as fol16 lows: 

‘‘Sec. 25A. American Opportunity and Lifetime Learning credits.’’. 

17 (11) The heading of section 25A(b) is amended 

18 by striking ‘‘HOPE SCHOLARSHIP CREDIT’’ and in19 serting ‘‘AMERICAN OPPORTUNITY TAX CREDIT’’. 

20 (12) The heading of section 25A(b)(2) is 

21 amended by striking ‘‘HOPE SCHOLARSHIP CREDIT’’ 

22 and inserting ‘‘AMERICAN OPPORTUNITY TAX CRED23 IT’’. 


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1 (13) The heading of section 25A(c)(2)(A) is 

2 amended by striking ‘‘HOPE SCHOLARSHIP’’ and in3 serting ‘‘AMERICAN OPPORTUNITY TAX CREDIT’’. 

4 (14) Section 25A, as amended by the preceding 

5 provisions of this Act, is amended by striking ‘‘Hope 

6 Scholarship Credit’’ each place it appears in the text 

7 and inserting ‘‘American Opportunity Tax Credit’’. 

8 (15) The heading of section 529(c)(3)(B)(v) is 

9 amended by striking ‘‘HOPE’’ and inserting ‘‘AMER10 ICAN OPPORTUNITY’’. 

11 (16) The heading of section 530(d)(2)(C) is 

12 amended by striking ‘‘HOPE’’ and inserting ‘‘AMER13 ICAN OPPORTUNITY’’. 

14 (17) Section 6211(b)(4)(A), as amended by this 

15 Act, is amended by striking ‘‘subsection (i)(5)’’ and 

16 inserting ‘‘subsection (i)’’. 

17 (18) Section 6213(g)(2)(Q) is amended to read 

18 as follows: 

19 ‘‘(Q) an omission of information required 

20 by section 25A(b)(4)(B) or an entry on the re21 turn claiming the American Opportunity Tax 

22 Credit for a taxable year for which such credit 

23 is disallowed under section 25A(b)(4)(A).’’. 

24 (19) Section 207(b)(1) of the Protecting Ameri25 cans from Tax Hikes Act of 2015 is amended by 


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1 striking ‘‘the American opportunity tax credit under 

2 section 25A(i) of such Code’’ and inserting ‘‘the 

3 American Opportunity Tax Credit under section 25A 

4 of such Code’’. 

5 (l) AMENDMENT RELATING TO SECTION 311.— 

6 (1) The last sentence of section 355(h)(2)(B) is 

7 amended by striking ‘‘80 percent’’ both places it ap8 pears and inserting ‘‘at least 80 percent’’. 

9 (2) Section 355(h)(2) is amended— 

10 (A) by striking ‘‘SPINOFFS’’ in the heading 

11 of such paragraph and inserting ‘‘DISTRIBU12 TIONS’’, and 

13 (B) by striking ‘‘SPINOFFS’’ in the head14 ings of subparagraphs (A) and (B) and insert15 ing ‘‘DISTRIBUTIONS’’. 

16 (m) AMENDMENT RELATING TO SECTION 318.— 

17 (1) Section 856(c)(9)(A) is amended— 

18 (A) by striking ‘‘Personal property’’ and 

19 inserting the following: 

20 ‘‘(i) IN GENERAL.—Personal prop21 erty’’, and 

22 (B) by adding at the end the following new 

23 clause: 

24 ‘‘(ii) TREATMENT OF GAIN ON DIS25 POSITION.—If— 


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1 ‘‘(I) personal property is leased 

2 under, or in connection with, a lease 

3 of real property, for a period of not 

4 less than 1 year, and rents attrib5 utable to such personal property are 

6 treated as rents from real property 

7 under subsection (d)(1)(C), 

8 ‘‘(II) any portion of such per9 sonal property and any portion of 

10 such real property are sold, or other11 wise disposed of, in a single disposi12 tion (or contemporaneously in sepa13 rate dispositions), and 

14 ‘‘(III) the fair market value of 

15 the personal property so sold or con16 temporaneously disposed of (deter17 mined at the time of disposition) does 

18 not exceed 15 percent of the total fair 

19 market value of all of the personal 

20 and real property so sold or contem21 poraneously disposed of (determined 

22 at the time of disposition), 

23 any gain from such dispositions shall be 

24 treated for purposes of paragraphs (2)(H) 


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1 and (3)(H) as gain from the disposition of 

2 a real estate asset.’’. 

3 (2) Section 856(c)(9)(B) is amended to read as 

4 follows: 

5 ‘‘(B) CERTAIN PERSONAL PROPERTY

6 MORTGAGED IN CONNECTION WITH REAL PROP7 ERTY.— 

8 ‘‘(i) IN GENERAL.—In the case of an 

9 obligation secured by a mortgage on both 

10 real property and personal property, if the 

11 fair market value of such personal property 

12 does not exceed 15 percent of the total fair 

13 market value of all such property, such ob14 ligation shall be treated— 

15 ‘‘(I) for purposes of paragraph 

16 (3)(B), as an obligation described 

17 therein, 

18 ‘‘(II) for purposes of paragraph 

19 (4)(A), as a real estate asset, and 

20 ‘‘(III) for purposes of paragraphs 

21 (2)(D) and (3)(C), as a mortgage on 

22 real property. 

23 ‘‘(ii) DETERMINATION OF FAIR MAR24 KET VALUE.— 


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1 ‘‘(I) IN GENERAL.—Except as 

2 provided in subclause (II), the fair 

3 market value of all such property shall 

4 be determined for purposes of clause 

5 (i) in the same manner as the fair 

6 market value of real property is deter7 mined for purposes of apportioning in8 terest income between real property 

9 and personal property under para10 graph (3)(B). 

11 ‘‘(II) GAIN ON DISPOSITION.— 

12 For purposes of applying clause 

13 (i)(III), fair market value shall be de14 termined at the time of sale or other 

15 disposition.’’. 

16 (n) AMENDMENTS RELATING TO SECTION 322.— 

17 (1) Section 897(k)(2) is amended— 

18 (A) by striking so much of subparagraph 

19 (B) as precedes ‘‘amounts realized by the quali20 fied shareholder’’ and inserting the following: 

21 ‘‘(B) EXCEPTION.—In the case of a quali22 fied shareholder with one or more applicable in23 vestors— 

24 ‘‘(i) subparagraph (A)(i) shall not 

25 apply to the applicable percentage of the 


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1 stock of the real estate investment trust 

2 held by the qualified shareholder, and 

3 ‘‘(ii) the applicable percentage of the’’, 

4 and 

5 (B) by adding at the end the following new 

6 subparagraph: 

7 ‘‘(F) APPLICABLE PERCENTAGE.—For 

8 purposes of subparagraph (B), the term ‘appli9 cable percentage’ means the percentage of the 

10 value of the interests (other than interests held 

11 solely as a creditor) in the qualified shareholder 

12 held by applicable investors.’’. 

13 (2) Section 897(k)(2)(D) is amended by strik14 ing ‘‘paragraph’’ and inserting ‘‘subsection’’. 

15 (3) Section 897(k)(2)(E) is amended by strik16 ing ‘‘and (C) and paragraph (4)’’ and inserting ‘‘and 

17 (D)’’. 

18 (4) Section 897(k)(3)(B)(i) is amended by 

19 striking so much as precedes ‘‘for a reduced rate of 

20 withholding’’ and inserting the following: 

21 ‘‘(i) which— 

22 ‘‘(I) is eligible for benefits under 

23 the comprehensive income tax treaty 

24 described in subparagraph (A)(i)(I), 

25 but only if the dividends article of 


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1 such treaty imposes conditions on the 

2 benefits allowable in the case of divi3 dends paid by a real estate investment 

4 trust, and 

5 ‘‘(II) is eligible under such trea6 ty’’. 

7 (5) Section 897(k)(3)(B)(ii) is amended— 

8 (A) by adding ‘‘and’’ at the end of sub9 clause (II), and 

10 (B) by striking ‘‘United States corpora11 tion’’ in subclause (III) and inserting ‘‘domestic 

12 corporation’’. 

13 (6) Section 322 of the Protecting Americans 

14 from Tax Hikes Act of 2015 is amended by striking 

15 subsections (b)(2) and (c)(3), and the Internal Rev16 enue Code of 1986 shall be applied as if such sub17 sections, and amendments made thereby, had never 

18 been enacted. 

19 (7) Section 322(c)(2) of such Act is amended 

20 by striking ‘‘take effect on’’ and inserting the fol21 lowing: ‘‘apply with respect to testing periods (as de22 fined in section 897(h)(4)(D) of the Internal Rev23 enue Code of 1986) ending on or after’’. 

24 (o) AMENDMENTS RELATED TO SECTION 323.— 


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1 (1) So much of subsection (l) of section 897 as 

2 precedes paragraph (2) thereof is amended to read 

3 as follows: 

4 ‘‘(l) EXCEPTION FOR QUALIFIED FOREIGN PENSION

5 FUNDS.— 

6 ‘‘(1) IN GENERAL.—For purposes of this sec7 tion, a qualified foreign pension fund shall not be 

8 treated as a nonresident alien individual or a foreign 

9 corporation. For purposes of the preceding sentence, 

10 an entity all the interests of which are held by a 

11 qualified foreign pension fund shall be treated as 

12 such a fund.’’. 

13 (2) Subparagraph (B) of section 897(l)(2) is 

14 amended to read as follows: 

15 ‘‘(B) which is established— 

16 ‘‘(i) by such country (or one or more 

17 political subdivisions thereof) to provide re18 tirement or pension benefits to participants 

19 or beneficiaries that are current or former 

20 employees (including self-employed individ21 uals) or persons designated by such em22 ployees, as a result of services rendered by 

23 such employees to their employers, or 

24 ‘‘(ii) by one or more employers to pro25 vide retirement or pension benefits to parVerDate Sep 11 2014 00:19 Dec 07, 2016 Jkt 069200 PO 00000 Frm 00023 Fmt 6652 Sfmt 6201 E:\BILLS\H6439.IH H6439

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1 ticipants or beneficiaries that are current 

2 or former employees (including self-em3 ployed individuals) or persons designated 

4 by such employees in consideration for 

5 services rendered by such employees to 

6 such employers,’’. 

7 (3) Section 897(l)(2)(D) is amended by striking 

8 ‘‘provides annual information reporting about its 

9 beneficiaries to the relevant tax authorities’’ and in10 serting ‘‘with respect to which annual information 

11 about its beneficiaries is provided, or is otherwise 

12 available, to the relevant tax authorities’’. 

13 (4) Section 897(l)(2)(E) is amended— 

14 (A) by striking ‘‘such entity’’ in clause (i) 

15 and inserting ‘‘such entity or arrangement’’, 

16 and 

17 (B) by striking ‘‘or such income is taxed at 

18 a reduced rate’’ in clause (ii) and inserting ‘‘, 

19 or such income is excluded from the gross in20 come of such entity or arrangement or is taxed 

21 at a reduced rate’’. 

22 (p) AMENDMENTS RELATING TO SECTION 333.— 

23 (1) Section 831(b)(2) is amended by redesig24 nating subparagraph (D) as subparagraph (E) and 


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1 by inserting after subparagraph (C) the following 

2 new subparagraph: 

3 ‘‘(D) LOOK-THROUGH OF REINSURANCE

4 AND FRONTING ARRANGEMENTS.—In the case 

5 of reinsurance or any fronting, intermediary, or 

6 similar arrangement, the term ‘policyholder’ 

7 means each policyholder of the underlying di8 rect written insurance with respect to such rein9 surance or arrangement.’’. 

10 (2)(A) Subclause (II) of section 831(b)(2)(B)(i) 

11 is amended by striking ‘‘specified assets’’ and insert12 ing ‘‘relevant specified assets’’. 

13 (B) Section 831(b)(2)(B)(ii) is amended by re14 designating subclauses (II), (III), and (IV) as sub15 clauses (III), (IV), and (V), respectively, and by in16 serting after subclause (I) the following new sub17 clause: 

18 ‘‘(II) RELEVANT SPECIFIED AS19 SETS.—The term ‘relevant specified 

20 assets’ means, with respect to any 

21 specified holder with respect to any 

22 insurance company, the aggregate 

23 amount of the specified assets, with 

24 respect to such insurance company, 

25 any interest in which is held (directly 


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1 or indirectly) by any spouse or speci2 fied relation of such specified holder. 

3 Such term shall not include any speci4 fied asset solely by reason of an inter5 est in such asset which was acquired 

6 by such spouse or specified relation by 

7 bequest, devise, or inheritance from a 

8 decedent during the taxable year of 

9 the insurance company or the pre10 ceding taxable year. For purposes of 

11 this subclause, the term ‘specified re12 lation’ means any individual with re13 spect to whom the specified holder 

14 bears a relationship described in sub15 clause (I).’’. 

16 (q) EFFECTIVE DATE.—The amendments made by 

17 this section shall take effect as if included in the provision 

18 of the Protecting Americans from Tax Hikes Act of 2015 

19 to which they relate. 

20 SEC. 102. AMENDMENT RELATING TO CONSOLIDATED AP21 PROPRIATIONS ACT, 2016. 

22 (a) AMENDMENT RELATING TO SECTION 305 OF DI23 VISION P.—Section 199(c)(3)(C)(i) is amended— 


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1 (1) by inserting ‘‘who elects the application of 

2 this clause for any taxable year,’’ after ‘‘In the case 

3 of any taxpayer’’, 

4 (2) by striking ‘‘and who’’ and inserting ‘‘, and 

5 who’’, 

6 (3) by striking ‘‘the taxable year’’ and inserting 

7 ‘‘such taxable year’’, and 

8 (4) by striking ‘‘under subsection (d)(9)(B)’’ 

9 and inserting ‘‘(as defined in subsection (d)(9)(B))’’. 

10 (b) EFFECTIVE DATE.—The amendment made by 

11 this section shall take effect as if included in section 305 

12 of division P of the Consolidated Appropriations Act, 

13 2016. 

14 SEC. 103. AMENDMENTS RELATING TO FIXING AMERICA’S 

15 SURFACE TRANSPORTATION ACT. 

16 (a) AMENDMENTS RELATING TO SECTION 32101.— 

17 (1) Section 7345(e)(1) is amended— 

18 (A) by striking ‘‘or the Tax Court’’ and in19 serting ‘‘, or against the Commissioner in the 

20 Tax Court,’’, and 

21 (B) by adding at the end the following: 

22 ‘‘For purposes of the preceding sentence, the 

23 court first acquiring jurisdiction over such an 

24 action shall have sole jurisdiction.’’. 


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1 (2) Section 7345(f) is amended by striking 

2 ‘‘subsection (a)’’ and inserting ‘‘subsection 

3 (b)(1)(B)’’. 

4 (b) EFFECTIVE DATE.—The amendments made by 

5 this section shall take effect as if included in section 

6 32101 of the Fixing America’s Surface Transportation 

7 Act. 

8 SEC. 104. AMENDMENTS RELATING TO SURFACE TRANS9 PORTATION AND VETERANS HEALTH CARE 

10 CHOICE IMPROVEMENT ACT OF 2015. 

11 (a) AMENDMENT RELATING TO SECTION 2004.— 

12 Section 6662(k) is amended to read as follows: 

13 ‘‘(k) INCONSISTENT ESTATE BASIS REPORTING.— 

14 For purposes of this section, there is an ‘inconsistent es15 tate basis’ if the adjusted basis of property (to which sec16 tion 1014(f) applies) claimed on a return exceeds the 

17 amount that would have been so claimed if the basis of 

18 such property had been properly determined under such 

19 section.’’. 

20 (b) AMENDMENTS RELATING TO SECTION 2008.— 

21 Section 9503(e)(2) is amended— 

22 (1) by striking ‘‘per gallon’’ in subparagraph 

23 (C) and inserting ‘‘per energy equivalent of a gallon 

24 of diesel (as defined in section 4041(a)(2)(D))’’, and 


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1 (2) by striking ‘‘per gallon’’ in subparagraph 

2 (D) and inserting ‘‘per energy equivalent of a gallon 

3 of gasoline (as defined in section 4041(a)(2)(C))’’. 

4 (c) EFFECTIVE DATE.—The amendments made by 

5 this section shall take effect as if included in the provision 

6 of the Surface Transportation and Veterans Health Care 

7 Choice Improvement Act of 2015 to which they relate. 

8 SEC. 105. AMENDMENTS RELATING TO STEPHEN BECK, JR., 

9 ABLE ACT OF 2014. 

10 (a) AMENDMENTS RELATING TO SECTION 208.— 

11 Section 208(h) of the Stephen Beck, Jr., ABLE Act of 

12 2014 is amended— 

13 (1) by striking so much as precedes ‘‘made by 

14 this section’’ and inserting the following: 

15 ‘‘(h) EFFECTIVE DATE.— 

16 ‘‘(1) IN GENERAL.—Except as provided in para17 graph (2), the amendments’’, 

18 (2) by inserting ‘‘, and statements required to 

19 be furnished,’’ after ‘‘returns required to be filed’’, 

20 and 

21 (3) by adding at the end the following new 

22 paragraph: 

23 ‘‘(2) SUBSECTION (c).—The amendment made 

24 by subsection (c) shall apply to returns or claims for 

25 refund filed after December 31, 2014.’’. 


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1 (b) EFFECTIVE DATE.—The amendments made by 

2 this section shall take effect as if included in section 208 

3 of the Stephen Beck, Jr., ABLE Act of 2014. 

4 SEC. 106. AMENDMENT RELATING TO AMERICAN TAXPAYER 

5 RELIEF ACT OF 2012. 

6 (a) AMENDMENT RELATING TO SECTION 104.—Sec7 tion 6211(b)(4)(A) is amended by striking ‘‘subsection 

8 (i)(6)’’ and inserting ‘‘subsection (i)(5)’’. 

9 (b) EFFECTIVE DATE.—The amendment made by 

10 this section shall take effect as if included in section 104 

11 of the American Taxpayer Relief Act of 2012. 

12 SEC. 107. AMENDMENT RELATING TO UNITED STATES13 KOREA FREE TRADE AGREEMENT IMPLE14 MENTATION ACT. 

15 (a) AMENDMENT RELATING TO SECTION 501.—Sec16 tion 501(b) of the United States-Korea Free Trade Agree17 ment Implementation Act is amended by striking ‘‘returns 

18 required to be filed’’ and inserting ‘‘documents prepared’’. 

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

20 this section shall take effect as if included in section 501 

21 of the United States-Korea Free Trade Agreement Imple22 mentation Act. 

23 SEC. 108. AMENDMENT RELATING TO SAFETEA–LU. 

24 (a) AMENDMENT RELATING TO SECTION 11125.— 

25 Section 5681(b) is amended by striking ‘‘who has paid the 


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1 special tax (or who is exempt from payment of such special 

2 tax by reason of the provisions of section 5113(a))’’ and 

3 inserting ‘‘who meets the requirements of section 5121(a) 

4 and section 5124 (or who is exempt from such require5 ments by reason of section 5121(b))’’. 

6 (b) EFFECTIVE DATE.—The amendment made by 

7 this section shall take effect as if included in section 

8 11125 of the Safe, Accountable, Flexible, Efficient Trans9 portation Equity Act: A Legacy for Users. 

10 SEC. 109. AMENDMENT RELATING TO THE AMERICAN JOBS 

11 CREATION ACT OF 2004. 

12 (a) AMENDMENT RELATING TO SECTION 319.—Sec13 tion 501(c)(12)(E) is amended by striking ‘‘means the 

14 Federal Energy Regulatory Commission’’ and all that fol15 lows and inserting: ‘‘means— 

16 ‘‘(i) the Federal Energy Regulatory 

17 Commission, and 

18 ‘‘(ii) in the case of any utility with re19 spect to which all of the electricity gen20 erated, transmitted, or distributed by such 

21 utility is generated, transmitted, distrib22 uted, and consumed in the same State, the 

23 State agency of such State with the au24 thority to regulate electric utilities.’’. 


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1 (b) EFFECTIVE DATE.—The amendment made by 

2 this section shall take effect as if included in section 319 

3 of the American Jobs Creation Act of 2004. 

4 TITLE II—TECHNICAL CORREC5 TIONS RELATED TO PART6 NERSHIP AUDIT RULES 

7 SEC. 201. SCOPE OF ADJUSTMENTS SUBJECT TO PARTNER8 SHIP AUDIT RULES. 

9 (a) IN GENERAL.—Section 6241(2) is amended to 

10 read as follows: 

11 ‘‘(2) PARTNERSHIP ADJUSTMENT.— 

12 ‘‘(A) IN GENERAL.—The term ‘partnership 

13 adjustment’ means any adjustment to a part14 nership-related item. 

15 ‘‘(B) PARTNERSHIP-RELATED ITEM.—The 

16 term ‘partnership-related item’ means— 

17 ‘‘(i) any item or amount with respect 

18 to the partnership (without regard to 

19 whether or not such item or amount ap20 pears on the partnership’s return and in21 cluding any item or amount relating to any 

22 transaction with, basis in, or liability of, 

23 the partnership) which is relevant (deter24 mined without regard to this subchapter) 


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1 in determining the tax liability of any per2 son under chapter 1, and 

3 ‘‘(ii) any partner’s distributive share 

4 of any item or amount described in clause 

5 (i).’’. 

6 (b) COORDINATION WITH OTHER CHAPTERS.—Sec7 tion 6241 is amended by adding at the end the following 

8 new paragraph: 

9 ‘‘(9) COORDINATION WITH OTHER CHAPTERS.— 

10 This subchapter shall not apply with respect to any 

11 tax imposed (or any amount required to be deducted 

12 or withheld) under chapter 2, 2A, 3, or 4, except 

13 that any partnership adjustment determined under 

14 this subchapter for purposes of chapter 1 shall be 

15 taken into account for purposes of determining any 

16 such tax to the extent that such adjustment is rel17 evant to such determination.’’. 

18 (c) CONFORMING AMENDMENTS.— 

19 (1) Section 6211(c) is amended to read as fol20 lows: 

21 ‘‘(c) COORDINATION WITH SUBCHAPTER C.—In de22 termining the amount of any deficiency for purposes of 

23 this subchapter, adjustments to partnership-related items 

24 shall be made only as provided in subchapter C.’’. 


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1 (2) Section 6221(a) is amended to read as fol2 lows: 

3 ‘‘(a) IN GENERAL.—Any adjustment to a partner4 ship-related item shall be determined, and any tax attrib5 utable thereto shall be assessed and collected, and the ap6 plicability of any penalty, addition to tax, or additional 

7 amount which relates to an adjustment to any such item 

8 shall be determined, at the partnership level, except to the 

9 extent otherwise provided in this subchapter.’’. 

10 (3) Section 6222(a) is amended to read as fol11 lows: 

12 ‘‘(a) IN GENERAL.—A partner shall, on the partner’s 

13 return, treat any partnership-related item in a manner 

14 which is consistent with the treatment of such item on 

15 the partnership return.’’. 

16 (4) Section 6226(a)(2) is amended by striking 

17 ‘‘any adjustment to income, gain, loss, deduction, or 

18 credit’’ and inserting ‘‘any adjustment to a partner19 ship-related item’’. 

20 (5) Section 6227(a) is amended by striking 

21 ‘‘items of income, gain, loss, deduction, or credit of 

22 the partnership’’ and inserting ‘‘partnership-related 

23 items’’. 

24 (6) Section 6231(a)(1) is amended by striking 

25 ‘‘any item of income, gain, loss, deduction, or credit 


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1 of a partnership for a partnership taxable year’’ and 

2 inserting ‘‘any partnership-related item for any part3 nership taxable year’’. 

4 (7) Section 6234(c) is amended by striking ‘‘all 

5 items of income, gain, loss, deduction, or credit of 

6 the partnership’’ and inserting ‘‘all partnership-re7 lated items’’. 

8 SEC. 202. DETERMINATION OF IMPUTED UNDERPAYMENTS. 

9 (a) IN GENERAL.—Section 6225(b) is amended to 

10 read as follows: 

11 ‘‘(b) DETERMINATION OF IMPUTED UNDERPAY12 MENTS.—For purposes of this subchapter— 

13 ‘‘(1) IN GENERAL.—Except as otherwise pro14 vided in this section, any imputed underpayment 

15 with respect to any reviewed year shall be deter16 mined by the Secretary by— 

17 ‘‘(A) appropriately netting all partnership 

18 adjustments with respect to such reviewed year, 

19 and 

20 ‘‘(B) applying the highest rate of tax in ef21 fect for the reviewed year under section 1 or 

22 11. 

23 ‘‘(2) ADJUSTMENTS TO DISTRIBUTIVE SHARES

24 OF PARTNERS NOT NETTED.—In the case of any ad25 justment which reallocates the distributive share of 


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1 any item from one partner to another, such adjust2 ment shall be taken into account by disregarding so 

3 much of such adjustment as results in a decrease in 

4 the amount of the imputed underpayment. 

5 ‘‘(3) ADJUSTMENTS SEPARATELY NETTED BY

6 CATEGORY.—For purposes of paragraph (1)(A), 

7 partnership adjustments for any reviewed year shall 

8 first be separately determined (and netted as appro9 priate) within each category of items that are re10 quired to be taken into account separately under 

11 section 702(a) or other provision of this title. 

12 ‘‘(4) LIMITATION ON ADJUSTMENTS THAT MAY

13 BE TAKEN INTO ACCOUNT.—If any adjustment 

14 would (but for this paragraph)— 

15 ‘‘(A) result in a decrease in the amount of 

16 the imputed underpayment, and 

17 ‘‘(B) could be subject to any additional 

18 limitation under the provisions of this title (or 

19 not allowed, in whole or in part, against ordi20 nary income) if such adjustment were taken 

21 into account by any person, 

22 such adjustment shall not be taken into account 

23 under paragraph (1)(A) except to the extent other24 wise provided by the Secretary.’’. 

25 (b) CONFORMING AMENDMENTS.— 


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1 (1) Section 6225(a) is amended to read as fol2 lows: 

3 ‘‘(a) IN GENERAL.—In the case of any adjustments 

4 by the Secretary to any partnership-related items with re5 spect to any reviewed year of a partnership— 

6 ‘‘(1) if such adjustments result in an imputed 

7 underpayment, the partnership shall pay an amount 

8 equal to such imputed underpayment in the adjust9 ment year as provided in section 6232, and 

10 ‘‘(2) if such adjustments do not result in an im11 puted underpayment, such adjustments shall be 

12 taken into account by the partnership in the adjust13 ment year.’’. 

14 (2) Section 6225(c) is amended by adding at 

15 the end the following new paragraph: 

16 ‘‘(9) MODIFICATION OF ADJUSTMENTS NOT RE17 SULTING IN AN IMPUTED UNDERPAYMENT.—The 

18 Secretary shall establish procedures under which the 

19 adjustments described in subsection (a)(2) may be 

20 modified in such manner as the Secretary deter21 mines appropriate.’’. 


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1 SEC. 203. ALTERNATIVE PROCEDURE TO FILING AMENDED 

2 RETURNS FOR PURPOSES OF MODIFYING IM3 PUTED UNDERPAYMENT. 

4 (a) IN GENERAL.—Section 6225(c)(2) is amended to 

5 read as follows: 

6 ‘‘(2) PROCEDURES FOR PARTNERS TO TAKE AD7 JUSTMENTS INTO ACCOUNT.— 

8 ‘‘(A) AMENDED RETURNS OF PARTNERS.— 

9 Such procedures shall provide that if— 

10 ‘‘(i) one or more partners file returns 

11 for the taxable year of the partners which 

12 includes the end of the reviewed year of 

13 the partnership (and for any taxable year 

14 with respect to which any tax attribute is 

15 affected by reason of any adjustment re16 ferred to in clause (ii)), 

17 ‘‘(ii) such returns take into account 

18 all adjustments under subsection (a) prop19 erly allocable to such partners (and the ef20 fect of such adjustments on any tax at21 tributes), and 

22 ‘‘(iii) payment of any tax due is in23 cluded with such returns, 

24 then the imputed underpayment amount shall 

25 be determined without regard to the portion of 

26 the adjustments so taken into account. 


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1 ‘‘(B) ALTERNATIVE PROCEDURE TO FIL2 ING AMENDED RETURNS.—Such procedures 

3 shall provide that, with respect to any partner 

4 referred to in subparagraph (A), the require5 ments of subparagraph (A) shall be treated as 

6 satisfied with respect to adjustments properly 

7 allocable to such partner if, in lieu of filing the 

8 returns described in such subparagraph— 

9 ‘‘(i) the amounts described in sub10 paragraph (A)(iii) are paid by the partner, 

11 ‘‘(ii) the adjustments to the tax at12 tributes of such partner referred to in sub13 paragraph (A)(ii) are binding with respect 

14 to all subsequent taxable years of the part15 ner, and 

16 ‘‘(iii) such partner provides, in the 

17 form and manner specified by the Sec18 retary (including, if the Secretary so speci19 fies, in the same form as on an amended 

20 return), such information as the Secretary 

21 may require to carry out this subpara22 graph. 

23 ‘‘(C) REALLOCATION OF DISTRIBUTIVE

24 SHARE.—In the case of any adjustment which 

25 reallocates the distributive share of any item 


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1 from one partner to another, this paragraph 

2 shall apply with respect to any such partner 

3 only if the requirements of subparagraph (A) or 

4 (B) are satisfied with respect to all partners af5 fected by such adjustment. 

6 ‘‘(D) APPLICATION OF STATUTE OF LIMI7 TATIONS.—Sections 6501 and 6511 shall not 

8 apply with respect to any return filed for pur9 poses of subparagraph (A)(i) or any amount 

10 paid under subparagraph (A)(iii) or (B)(i), but 

11 only with respect to adjustments referred to in 

12 subparagraph (A)(ii). 

13 ‘‘(E) APPLICATION TO TIERED PARTNER14 SHIPS.—In the case of any partnership any 

15 partner of which is a partnership, except as 

16 otherwise provided by the Secretary, subpara17 graph (B) shall apply with respect to any part18 ner in the chain of ownership of such partner19 ships. For purposes of applying the preceding 

20 sentence, an S corporation and its shareholders 

21 shall be treated in the same manner as a part22 nership and its partners.’’. 

23 (b) CONFORMING AMENDMENT.—Section 6201(a)(1) 

24 is amended by inserting ‘‘(or payments under section 

25 6225(c)(2)(B)(i))’’ after ‘‘returns or lists’’. 


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1 SEC. 204. TREATMENT OF PASSTHROUGH PARTNERS IN 

2 TIERED STRUCTURES. 

3 (a) IN GENERAL.—Section 6226(b) is amended by 

4 adding at the end the following new paragraph: 

5 ‘‘(4) TREATMENT OF PARTNERSHIPS IN TIERED

6 STRUCTURES.— 

7 ‘‘(A) IN GENERAL.—If a partner which re8 ceives a statement under subsection (a)(2) is a 

9 partnership or an S corporation, such partner 

10 shall, with respect to the partner’s share of the 

11 adjustment— 

12 ‘‘(i) file with the Secretary a partner13 ship adjustment tracking report which in14 cludes such information as the Secretary 

15 may require, and 

16 ‘‘(ii) either— 

17 ‘‘(I) pay the imputed under18 payment under rules similar to the 

19 rules of section 6225 (other than 

20 paragraphs (2)(A), (6), (7), and (9) of 

21 subsection (c) thereof), or 

22 ‘‘(II) furnish statements under 

23 rules similar to the rules of subsection 

24 (a)(2). 

25 ‘‘(B) DUE DATE.—For purposes of sub26 paragraph (A), with respect to a partner’s 


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1 share of the adjustment, the partnership adjust2 ment tracking report shall be filed, and the im3 puted underpayment shall be paid or state4 ments shall be furnished, not later than the due 

5 date for the return for the taxable year of the 

6 audited partnership which includes the date the 

7 final determination was made with respect to 

8 such partnership. 

9 ‘‘(C) PARTNERSHIP PAYMENT OF TAX NOT

10 PERMITTED IF ELECTED OUT OF SUB11 CHAPTER.—In the case of a partnership which 

12 has elected the application of section 6221(b) 

13 with respect to the taxable year of the partner14 ship which includes the end of the reviewed year 

15 of the audited partnership, this paragraph shall 

16 apply notwithstanding such election, except that 

17 subparagraph (A) shall be applied without re18 gard to clause (ii)(I) thereof. 

19 ‘‘(D) AUDITED PARTNERSHIP.—For pur20 poses of this paragraph, the term ‘audited part21 nership’ means, with respect to any partner de22 scribed in subparagraph (A), the partnership in 

23 the chain of ownership originally electing the 

24 application of this section.’’. 

25 (b) CONFORMING AMENDMENTS.— 


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1 (1) Section 6226(b)(1) is amended by striking 

2 ‘‘Each partner’s’’ and inserting ‘‘Except as provided 

3 in paragraph (4), each partner’s’’. 

4 (2) Section 6226(c)(2) is amended by inserting 

5 ‘‘or which is described in subsection 

6 (b)(4)(A)(ii)(I),’’ after ‘‘is elected,’’. 

7 SEC. 205. TREATMENT OF FAILURE OF PARTNERSHIP TO 

8 PAY IMPUTED UNDERPAYMENT. 

9 Section 6232 is amended by adding at the end the 

10 following new subsection: 

11 ‘‘(f) FAILURE TO PAY IMPUTED UNDERPAYMENT.— 

12 ‘‘(1) IN GENERAL.—If any amount of any im13 puted underpayment to which section 6225 applies 

14 or which is described in section 6226(b)(4)(A)(ii)(I) 

15 (or any interest or penalties with respect to any such 

16 amount) has not been paid by the date which is 10 

17 days after the date on which the Secretary provides 

18 notice and demand for such payment— 

19 ‘‘(A) section 6621(a)(2)(B) shall be ap20 plied by substituting ‘5 percentage points’ for ‘3 

21 percentage points’ with respect to such amount, 

22 and 

23 ‘‘(B) the Secretary may assess upon each 

24 partner of the partnership (determined as of 

25 the close of the adjustment year) a tax equal to 


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1 such partner’s proportionate share of such 

2 amount (including any such interest or pen3 alties, determined after application of subpara4 graph (A)). 

5 ‘‘(2) PROPORTIONATE SHARE.—For purposes of 

6 paragraph (1), a partner’s proportionate share is 

7 such percentage as the Secretary may determine on 

8 the basis of such partner’s distributive share of 

9 items under section 702. The Secretary shall make 

10 determinations under the preceding sentence such 

11 that the aggregate proportionate shares so deter12 mined total 100 percent. 

13 ‘‘(3) COORDINATION WITH PARTNERSHIP LI14 ABILITY.—The liability of the partnership for any 

15 amount with respect to which a partner is made lia16 ble under paragraph (1) shall be reduced upon pay17 ment by the partner of such amount. Paragraph 

18 (1)(B) shall not apply with respect to any amount 

19 after the date on which such amount is paid by the 

20 partnership. 

21 ‘‘(4) S CORPORATIONS.—For purposes of this 

22 subsection, an S corporation and its shareholders 

23 shall be treated in the same manner as a partner24 ship and its partners. 


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1 ‘‘(5) RULES RELATED TO ASSESSMENT AND

2 COLLECTION.— 

3 ‘‘(A) DEFICIENCY PROCEDURES NOT AP4 PLICABLE.—Subchapter B shall not apply to 

5 any assessment or collection under this para6 graph. 

7 ‘‘(B) LIMITATION ON ASSESSMENT.—Ex8 cept as otherwise provided in this chapter, no 

9 assessment may be made with respect to any 

10 partner with respect to an amount under para11 graph (1) (and no levy or proceeding in any 

12 court for the collection of such amount may 

13 begin) after the date which is 2 years after the 

14 date on which the Secretary provides notice and 

15 demand to the partnership with respect to such 

16 amount.’’. 

17 SEC. 206. OTHER TECHNICAL CORRECTIONS RELATED TO 

18 PARTNERSHIP AUDIT RULES. 

19 (a) LIMITATION ON AMENDMENT OF STATEMENTS

20 FURNISHED TO PARTNERS NOT APPLICABLE TO PART21 NERSHIPS ELECTING OUT OF PARTNERSHIP AUDIT

22 RULES.—Section 6031(b) is amended by striking the last 

23 sentence and inserting the following: ‘‘Information re24 quired to be furnished by the partnership under this sub25 section may not be amended after the due date of the reVerDate Sep 11 2014 00:19 Dec 07, 2016 Jkt 069200 PO 00000 Frm 00045 Fmt 6652 Sfmt 6201 E:\BILLS\H6439.IH H6439

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1 turn under subsection (a) to which such information re2 lates, except— 

3 ‘‘(1) in the case of a partnership which has 

4 elected the application of section 6221(b) for the 

5 taxable year, 

6 ‘‘(2) as provided in the procedures under sec7 tion 6225(c), 

8 ‘‘(3) with respect to statements under section 

9 6226, or 

10 ‘‘(4) as otherwise provided by the Secretary.’’. 

11 (b) ADMINISTRATIVE ADJUSTMENT REQUEST AND

12 PARTNERSHIP ADJUSTMENT TRACKING REPORT NOT

13 TREATED AS AMENDED RETURN FOR PURPOSES OF

14 MODIFICATION OF IMPUTED UNDERPAYMENTS.—Section 

15 6225(c)(2), as amended by the preceding provisions of this 

16 Act, is amended by adding at the end the following new 

17 subparagraph: 

18 ‘‘(F) ADJUSTMENTS NOT TREATED AS

19 AMENDED RETURN.—An administrative adjust20 ment request under section 6227 and a partner21 ship adjustment tracking report under section 

22 6226(b)(4)(A) shall not be treated as a return 

23 for purposes of this paragraph.’’. 

24 (c) CLARIFICATION OF FINAL DETERMINATION

25 WITH RESPECT TO PARTNERSHIP ADJUSTMENT.— 


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1 (1) IN GENERAL.—Section 6226(a)(2) is 

2 amended by striking ‘‘in the notice of final partner3 ship adjustment’’ and inserting ‘‘by reference to the 

4 final determination with respect to such adjust5 ment’’. 

6 (2) FINAL DETERMINATION.—Section 6225(d) 

7 is amended by adding at the end the following new 

8 paragraph: 

9 ‘‘(3) FINAL DETERMINATION.—The final deter10 mination is made with respect to an adjustment on 

11 the date on which— 

12 ‘‘(A) in the case of an adjustment pursu13 ant to the decision of a court in a proceeding 

14 brought under section 6234, such decision be15 comes final, 

16 ‘‘(B) in the case of an administrative ad17 justment request under section 6227, such ad18 ministrative adjustment request is filed, or 

19 ‘‘(C) in any other case, 90 days after the 

20 date on which the notice of the final partner21 ship adjustment is mailed under section 6231.’’. 

22 (3) CONFORMING AMENDMENTS.— 

23 (A) Section 6225(d)(2) is amended by 

24 striking ‘‘in which—’’ and all that follows and 


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1 inserting ‘‘in which the final determination is 

2 made with respect to the adjustment.’’. 

3 (B) Section 6227(b) is amended by strik4 ing ‘‘is made’’ both places it appears and in5 serting ‘‘is filed’’. 

6 (d) CLARIFICATION OF ASSESSMENT AUTHORITY.— 

7 Section 6226(a) is amended by inserting ‘‘(and no assess8 ment of tax, levy, or proceeding in any court for the collec9 tion of such underpayment shall be made against such 

10 partnership)’’ after ‘‘section 6225 shall not apply with re11 spect to such underpayment’’. 

12 (e) TREATMENT OF PARTNERSHIP ADJUSTMENTS

13 THAT RESULT IN DECREASE IN TAX IN CASE OF ELEC14 TION TO PUSH OUT ADJUSTMENTS.—Section 6226(b) is 

15 amended— 

16 (1) by striking ‘‘increased’’ in paragraph (1) 

17 and inserting ‘‘adjusted’’, 

18 (2) by striking ‘‘adjustment amounts’’ each 

19 place it appears in paragraphs (1) and (2) and in20 serting ‘‘correction amounts’’, 

21 (3) by striking ‘‘increase’’ each place it appears 

22 in subparagraphs (A) and (B) of paragraph (2) and 

23 inserting ‘‘increase or decrease’’, 

24 (4) by striking ‘‘plus’’ at the end of paragraph 

25 (2)(A) and inserting ‘‘and’’, and 


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1 (5) by striking ‘‘ADJUSTMENT AMOUNTS’’ in 

2 the heading of paragraph (2) and inserting ‘‘COR3 RECTION AMOUNTS’’. 

4 (f) TIME LIMITATION FOR NOTICE OF PROPOSED

5 ADJUSTMENT.— 

6 (1) IN GENERAL.—Section 6231 is amended by 

7 redesignating subsections (b) and (c) as subsections 

8 (c) and (d), respectively, and by inserting after sub9 section (a) the following new subsection: 

10 ‘‘(b) TIMING OF NOTICES.— 

11 ‘‘(1) NOTICE OF PROPOSED PARTNERSHIP AD12 JUSTMENT.—Any notice of a proposed partnership 

13 adjustment shall not be mailed later than the date 

14 determined under section 6235 (determined without 

15 regard to paragraphs (2) and (3) of subsection (a) 

16 thereof). 

17 ‘‘(2) NOTICE OF FINAL PARTNERSHIP ADJUST18 MENT.— 

19 ‘‘(A) IN GENERAL.—Except to the extent 

20 that the partnership elects to waive the applica21 tion of this subparagraph, any notice of a final 

22 partnership adjustment shall not be mailed ear23 lier than 270 days after the date on which the 

24 notice of the proposed partnership adjustment 

25 is mailed. 


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1 ‘‘(B) STATUTE OF LIMITATIONS ON AD2 JUSTMENT.—For the period of limitations on 

3 making adjustments, see section 6235.’’. 

4 (2) CONFORMING AMENDMENT.—Section 

5 6231(a) is amended by striking ‘‘Any notice of a 

6 final partnership adjustment’’ and all that follows 

7 through ‘‘Such notices’’ and inserting ‘‘Any notice of 

8 a final partnership adjustment’’. 

9 (g) DEPOSIT TO SUSPEND INTEREST ON IMPUTED

10 UNDERPAYMENT.—Section 6233 is amended by adding at 

11 the end the following new subsection: 

12 ‘‘(c) DEPOSIT TO SUSPEND INTEREST.—For rules 

13 allowing deposits to suspend running of interest on poten14 tial underpayments, see section 6603.’’. 

15 (h) TREATMENT OF SPECIAL ENFORCEMENT MAT16 TERS.—Section 6241, as amended by the preceding provi17 sions of this Act, is amended by adding at the end the 

18 following new paragraph: 

19 ‘‘(10) TREATMENT OF SPECIAL ENFORCEMENT

20 MATTERS.— 

21 ‘‘(A) IN GENERAL.—In the case of part22 nership-related items which involve special en23 forcement matters, the Secretary may prescribe 

24 regulations pursuant to which— 


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1 ‘‘(i) this subchapter (or any portion 

2 thereof) does not apply to such items, and 

3 ‘‘(ii) such items are subject to such 

4 special rules (including rules related to as5 sessment and collection) as the Secretary 

6 determines to be necessary for the effective 

7 and efficient enforcement of this title. 

8 ‘‘(B) SPECIAL ENFORCEMENT MATTERS.— 

9 For purposes of subparagraph (A), the term 

10 ‘special enforcement matters’ means— 

11 ‘‘(i) failure to comply with the re12 quirements of section 6226(b)(4)(A)(ii), 

13 ‘‘(ii) assessments under section 6851 

14 (relating to termination assessments of in15 come tax) or section 6861 (relating to 

16 jeopardy assessments of income, estate, 

17 gift, and certain excise taxes), 

18 ‘‘(iii) criminal investigations, 

19 ‘‘(iv) indirect methods of proof of in20 come, 

21 ‘‘(v) foreign partnerships, and 

22 ‘‘(vi) other matters that the Secretary 

23 determines by regulation present special 

24 enforcement considerations.’’. 


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1 (i) PENALTIES RELATED TO ADMINISTRATIVE AD2 JUSTMENT REQUESTS AND PARTNERSHIP ADJUSTMENT

3 TRACKING REPORTS.— 

4 (1) FAILURE TO PAY.—Section 6651 is amend5 ed by redesignating subsection (i) as subsection (j) 

6 and by inserting after subsection (h) the following 

7 new subsection: 

8 ‘‘(i) APPLICATION TO IMPUTED UNDERPAYMENT.— 

9 For purposes of this section, any failure to comply with 

10 section 6226(b)(4)(A)(ii) shall be treated as a failure to 

11 pay the amount described in subclause (I) thereof and 

12 such amount shall be treated for purposes of this section 

13 as an amount shown as tax on a return specified in sub14 section (a)(1).’’. 

15 (2) FAILURE TO FILE PARTNERSHIP ADJUST16 MENT TRACKING REPORT.—Section 6698(a) is 

17 amended— 

18 (A) in the matter preceding paragraph (1) 

19 by inserting ‘‘, or a partnership adjustment 

20 tracking report under section 6226(b)(4)(A),’’ 

21 after ‘‘under section 6031’’, 

22 (B) in paragraph (1) by inserting ‘‘, or 

23 such report,’’ after ‘‘such return’’, and 

24 (C) in paragraph (2)— 


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1 (i) by inserting ‘‘or a report’’ after ‘‘a 

2 return’’, and 

3 (ii) by inserting ‘‘or 6226(b)(4)(A), 

4 respectively’’ before the comma at the end. 

5 (3) TAX RETURN PREPARER RELATED PEN6 ALTIES.—Section 6696(e)(1) is amended by insert7 ing ‘‘, any administrative adjustment request under 

8 section 6227, and any partnership adjustment track9 ing report under section 6226(b)(4)(A)’’ before the 

10 period at the end. 

11 (4) FRIVOLOUS TAX SUBMISSIONS.—Section 

12 6702 is amended by adding at the end the following 

13 new subsection: 

14 ‘‘(f) PARTNERSHIP ADJUSTMENTS.—An administra15 tive adjustment request under section 6227 and a partner16 ship adjustment tracking report under section 

17 6226(b)(4)(A) shall be treated as a return for purposes 

18 of this section.’’. 

19 (j) ADJUSTED SCHEDULE K–1 TREATED AS PAYEE

20 STATEMENT.—Section 6724(d)(2) is amended by striking 

21 ‘‘or’’ at the end of subparagraph (HH), by striking the 

22 period at the end of subparagraph (II) and inserting ‘‘, 

23 or’’, and by inserting after subparagraph (II) the following 

24 new subparagraph: 


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1 ‘‘(JJ) section 6226(a)(2) (relating to state2 ments relating to alternative to payment of im3 puted underpayment by partnership) or under 

4 any other provision of this title which provides 

5 for the application of rules similar to such sec6 tion.’’. 

7 (k) CLERICAL CORRECTIONS.— 

8 (1) Section 6232(d)(1)(A) is amended by strik9 ing ‘‘a item’’ and inserting ‘‘an item’’. 

10 (2) Section 6232(e) is amended by striking 

11 ‘‘thereof’’. 

12 (3) Section 6235(a) is amended by striking 

13 ‘‘subpart’’ and inserting ‘‘subchapter’’. 

14 (4) Section 6235(a)(3) is amended by striking 

15 ‘‘section 6225(c)(7)’’ and inserting ‘‘section 

16 6225(c)(7))’’. 

17 (5) Section 6241(5) is amended by striking 

18 ‘‘sections 6234’’ and inserting ‘‘section 6234’’. 

19 (6) The heading of the first part of subchapter 

20 C of chapter 63 is amended to read as follows: 

21 ‘‘PART I—IN GENERAL’’. 

22 (7) The heading of the second part of sub23 chapter C of chapter 63 is amended to read as fol24 lows: 


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1 ‘‘PART II—PARTNERSHIP ADJUSTMENTS’’. 

2 (8) The heading of the third part of subchapter 

3 C of chapter 63 is amended to read as follows: 

4 ‘‘PART III—PROCEDURE’’. 

5 (9) The heading of the fourth part of sub6 chapter C of chapter 63 is amended to read as fol7 lows: 

8 ‘‘PART IV—DEFINITIONS AND SPECIAL RULES’’. 

9 SEC. 207. EFFECTIVE DATE. 

10 The amendments made by this title shall take effect 

11 as if included in section 1101 of the Bipartisan Budget 

12 Act of 2015. 

13 TITLE III—OTHER CORRECTIONS 

14 SEC. 301. AMENDMENTS RELATING TO THE BIPARTISAN 

15 BUDGET ACT OF 2015. 

16 (a) AMENDMENTS RELATING TO SECTION 1101.— 

17 (1) Section 6011(e) is amended by adding at 

18 the end the following new paragraph: 

19 ‘‘(5) SPECIAL RULES FOR PARTNERSHIPS.— 

20 ‘‘(A) PARTNERSHIPS PERMITTED TO BE

21 REQUIRED TO FILE ON MAGNETIC MEDIA.—In 

22 the case of a partnership, paragraph (2)(A) 

23 shall be applied by substituting for ‘250’ the 

24 following amount: 


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1 ‘‘(i) In the case of returns and state2 ments relating to calendar year 2018, 

3 ‘200’. 

4 ‘‘(ii) In the case of returns and state5 ments relating to calendar year 2019, 

6 ‘150’. 

7 ‘‘(iii) In the case of returns and state8 ments relating to calendar year 2020, 

9 ‘100’. 

10 ‘‘(iv) In the case of returns and state11 ments relating to calendar year 2021, ‘50’. 

12 ‘‘(v) In the case of returns and state13 ments relating to calendar years after 

14 2021, ‘20’. 

15 ‘‘(B) PARTNERSHIPS REQUIRED TO FILE

16 ON MAGNETIC MEDIA.—Notwithstanding sub17 paragraph (A) and paragraph (2)(A), the Sec18 retary shall require partnerships having more 

19 than 100 partners to file returns on magnetic 

20 media.’’. 

21 (2) Section 6011(e)(2) is amended by striking 

22 the last sentence. 

23 (b) EFFECTIVE DATE.—The amendments made by 

24 this section shall take effect as if included in section 1101 

25 of the Bipartisan Budget Act of 2015. 


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1 SEC. 302. AMENDMENTS RELATING TO THE ENERGY POL2 ICY ACT OF 2005. 

3 (a) AMENDMENTS RELATING TO SECTION 1253.— 

4 (1) Subclause (II) of section 168(e)(3)(B)(vi) is 

5 amended by striking ‘‘is a qualifying small power 

6 production facility’’ and all that follows and insert7 ing ‘‘has a power production capacity of not greater 

8 than 80 megawatts, or’’. 

9 (2) The last sentence of section 168(e)(3)(B) is 

10 amended by striking ‘‘clause (vi)(I)’’ and all that fol11 lows and inserting ‘‘subclause (I) or (II) of clause 

12 (vi) by reason of being public utility property.’’. 

13 (b) EFFECTIVE DATE.—The amendments made by 

14 this section shall apply to property placed in service after 

15 the date of the enactment of this Act. 

16 TITLE IV—CLERICAL 

17 CORRECTIONS AND DEADWOOD 

18 SEC. 401. CLERICAL CORRECTIONS AND DEADWOOD-RE19 LATED PROVISIONS. 

20 (a) CLERICAL CORRECTIONS.— 

21 (1) The table of subchapters for chapter 1 is 

22 amended by moving the item relating to subchapter 

23 R before the item relating to subchapter S. 

24 (2)(A) Sections 22(c)(3)(A)(i)(III), 

25 104(b)(2)(D), 140(a)(3), and 149(b)(3)(A)(i) are 

26 each amended by striking ‘‘Veterans’ AdministraVerDate Sep 11 2014 00:19 Dec 07, 2016 Jkt 069200 PO 00000 Frm 00057 Fmt 6652 Sfmt 6201 E:\BILLS\H6439.IH H6439

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1 tion’’ and inserting ‘‘Department of Veterans Af2 fairs’’. 

3 (B) The heading of section 4980H(c)(2)(F) is 

4 amended by striking ‘‘VETERANS ADMINISTRATION’’ 

5 and inserting ‘‘DEPARTMENT OF VETERANS AF6 FAIRS’’. 

7 (C) Section 6050H(h)(3)(B)(i) is amended by 

8 striking ‘‘Veterans Administration’’ and inserting 

9 ‘‘Department of Veterans Affairs’’. 

10 (3) Section 24(d) is amended by redesignating 

11 paragraph (5) as paragraph (3). 

12 (4) Section 25C(b)(2) is amended by striking 

13 ‘‘subsection (c)(2)(B)’’ and inserting ‘‘subsection 

14 (c)(3)(B)’’. 

15 (5) Section 25C(d)(3) is amended— 

16 (A) by striking the period at the end of 

17 subparagraph (B) and inserting a comma, and 

18 (B) by striking the period at the end of 

19 subparagraph (D) and inserting ‘‘, and’’. 

20 (6) Section 25C(g)(2) is amended by striking 

21 ‘‘2016..’’ and inserting ‘‘2016.’’. 

22 (7) The table of sections for subpart D of part 

23 IV of subchapter A of chapter 1 is amended— 


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1 (A) by striking the item relating to section 

2 41 which relates to the employee stock owner3 ship credit, and 

4 (B) by moving the item relating to section 

5 45K after the item relating to section 45J. 

6 (8) Section 38(b)(34) is amended by adding a 

7 comma at the end. 

8 (9) The heading of section 40(g)(2) is amended 

9 by striking ‘‘AGGREGRATION’’ and inserting ‘‘AG10 GREGATION’’. 

11 (10) The heading of section 42(e)(2)(B) is 

12 amended by striking ‘‘ETC,’’ and inserting ‘‘ETC.,’’. 

13 (11)(A) Section 42(d)(4)(C)(i) is amended by 

14 striking ‘‘as defined in paragraph (5)(C)’’ and in15 serting ‘‘as defined in paragraph (5)(B)(ii)’’. 

16 (B) Section 42(f)(5)(B)(ii)(I) is amended by 

17 striking ‘‘(d)(6)(C)’’ and inserting ‘‘(d)(6)(B)’’. 

18 (C) Section 42(k)(2)(B) is amended— 

19 (i) by striking ‘‘(d)(6)(B)’’ and inserting 

20 ‘‘(d)(6)(C)’’, and 

21 (ii) by striking ‘‘building..’’ in clause (ii) 

22 and inserting ‘‘building.’’. 

23 (D) Section 42(m)(1)(B)(ii)(III) is amended by 

24 striking ‘‘as defined in subsection (d)(5)(C)’’ and in25 serting ‘‘as defined in subsection (d)(5)(B)(ii)’’. 


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1 (12) Section 42(h)(5)(C)(ii) is amended by 

2 striking ‘‘; and’’ and inserting ‘‘, and’’. 

3 (13) Section 42(i)(3)(D)(ii)(I) is amended by 

4 striking the period at the end. 

5 (14) Section 45(c)(6) is amended by striking 

6 ‘‘section 2(27)’’ and inserting ‘‘section 1004(27)’’. 

7 (15) Section 45(c)(7)(A)(i)(II) is amended by 

8 striking ‘‘for purpose’’ and inserting ‘‘for the pur9 pose’’. 

10 (16) Section 45(c)(7)(A)(i)(III) is amended by 

11 striking the period at the end and inserting ‘‘, or’’. 

12 (17) Section 45C(b)(2)(A)(ii)(II) is amended by 

13 striking ‘‘; and’’ and inserting ‘‘, and’’. 

14 (18) Section 45D(f)(1)(F) is amended by add15 ing ‘‘, and’’ at the end. 

16 (19) Section 45H(d) is amended by striking 

17 ‘‘purposes this’’ and inserting ‘‘purposes of this’’. 

18 (20) Section 48(a)(1) is amended by striking 

19 ‘‘(3)(B), and (4)(B)’’ and inserting ‘‘and (3)(B)’’. 

20 (21) Section 48(a)(6)(B) is amended by strik21 ing ‘‘property energy property’’ and inserting ‘‘en22 ergy property’’. 

23 (22) Section 48(c)(2)(B) is amended by striking 

24 ‘‘equal $200’’ and inserting ‘‘equal to $200’’. 

25 (23) Section 48(d)(3) is amended— 


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1 (A) by striking ‘‘shall’’ in the matter that 

2 precedes subparagraph (A), and 

3 (B) by inserting ‘‘shall’’ before ‘‘not’’ in 

4 subparagraph (A). 

5 (24) Section 49(a)(1)(D)(iii) is amended by 

6 striking ‘‘share-holder’’ in the last sentence and in7 serting ‘‘shareholder’’. 

8 (25) Section 50(b)(2)(A) is amended by strik9 ing the period at the end and inserting a semicolon. 

10 (26) Section 51(c)(4) is amended by adding a 

11 period at the end. 

12 (27) Section 51(d)(3)(A)(ii)(II) is amended by 

13 adding a comma at the end. 

14 (28) Section 51(d)(8) is amended by striking 

15 ‘‘FOOD STAMP RECIPIENT’’ in the heading thereof 

16 and inserting ‘‘SUPPLEMENTAL NUTRITION ASSIST17 ANCE PROGRAM BENEFITS RECIPIENT’’. 

18 (29) Section 51(i)(1)(A) is amended by striking 

19 ‘‘entity,’’ and inserting ‘‘entity’’. 

20 (30) The item relating to section 54C in the 

21 table of sections for subpart I of part IV of sub22 chapter A of chapter 1 is amended to read as fol23 lows: 

‘‘Sec. 54C. New clean renewable energy bonds.’’. 

24 (31) Section 58(a)(2)(A) is amended by striking 

25 ‘‘461(j)’’ and inserting ‘‘461(k)’’. 


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1 (32) Section 62(a)(20) is amended by inserting 

2 a comma after ‘‘United States Code’’. 

3 (33) Section 62(e)(1) is amended by striking 

4 ‘‘(2 U.S.C. 1202)’’ and inserting ‘‘(42 U.S.C. 

5 2000e–16b)’’. 

6 (34) Section 68(b)(2) is amended by striking 

7 ‘‘shall be shall be’’ and inserting ‘‘shall be’’. 

8 (35) The heading of section 82 is amended by 

9 striking ‘‘FOR EXPENSES OF MOVING’’ and insert10 ing ‘‘OF MOVING EXPENSES’’. 

11 (36) The heading of section 84 is amended by 

12 striking ‘‘POLITICAL ORGANIZATION’’ and insert13 ing ‘‘POLITICAL ORGANIZATIONS’’. 

14 (37) Section 105(h)(7)(B) is amended by strik15 ing ‘‘subparagraph (A)’’ and inserting ‘‘subpara16 graph (A))’’. 

17 (38) Section 125(e)(2) is amended by striking 

18 ‘‘subparagraphs’’ and inserting ‘‘subparagraph’’. 

19 (39) Section 132(c)(4) is amended by striking 

20 ‘‘peforming’’ and inserting ‘‘performing’’. 

21 (40) Section 134(b)(6) is amended by striking 

22 ‘‘an combat’’ and inserting ‘‘a combat’’. 

23 (41) Section 139(c)(2) is amended by striking 

24 ‘‘federally’’ and inserting ‘‘a federally’’. 


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1 (42) Section 139E(c)(1) is amended by striking 

2 ‘‘(43 U.S.C. 1601, et seq.)’’ and inserting ‘‘(43 

3 U.S.C. 1601 et seq.)’’. 

4 (43) Section 139E(c)(3) is amended by striking 

5 ‘‘2013’’ and inserting ‘‘2014’’. 

6 (44) The item relating to section 143 in the 

7 table of sections for subpart A of part IV of sub8 chapter B of chapter 1 is amended to read as fol9 lows: 

‘‘Sec. 143. Mortgage revenue bonds; qualified mortgage bond and qualified veterans’ mortgage bond.’’. 

10 (45) Section 141(e)(2) is amended by striking 

11 ‘‘, and’’ and inserting a period. 

12 (46) Section 142(d)(2)(C) is amended by insert13 ing ‘‘section’’ before ‘‘42(i)(3)(D)’’. 

14 (47) Section 148(f)(4)(C)(xiv) is amended by 

15 striking ‘‘subpargraph’’ and inserting ‘‘subpara16 graph’’. 

17 (48) Section 163(e)(5)(C)(ii) is amended by in18 serting ‘‘in’’ before ‘‘subsection (i)(1)(B)’’. 

19 (49) Section 168(d)(3)(B)(i) is amended by in20 serting a comma after ‘‘real property’’. 

21 (50) Section 168(e)(3)(C)(i) is amended by 

22 striking ‘‘and’’. 

23 (51) Section 169(d)(5)(B) is amended by in24 serting ‘‘a’’ before ‘‘facility’’. 


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1 (52) Section 170(b)(1)(A)(ix) is amended by in2 serting ‘‘National’’ before ‘‘Agricultural’’. 

3 (53) Section 172(d)(5) is amended by striking 

4 ‘‘section 243’’ and inserting ‘‘sections 243’’. 

5 (54) Section 179D(d)(1)(B) is amended by 

6 striking ‘‘which’’ and inserting ‘‘such that’’. 

7 (55) Section 199 is amended by striking so 

8 much of subsection (a) as precedes ‘‘There shall be 

9 allowed’’ and inserting ‘‘(a) ALLOWANCE OF DEDUC10 TION.—’’. 

11 (56) Section 219(f)(1) is amended by striking 

12 ‘‘term compensation includes’’ in the last sentence 

13 and inserting ‘‘term ‘compensation’ includes’’. 

14 (57) Section 219(g)(8) is amended by striking 

15 ‘‘shall each be’’ and inserting ‘‘shall be’’. 

16 (58) Section 223(d)(2)(A) is amended by strik17 ing ‘‘section 213(d)’’ and inserting ‘‘section 

18 213(d))’’. 

19 (59) The item relating to section 280H in the 

20 table of sections for part IX of subchapter B of 

21 chapter 1 is amended to read as follows: 

‘‘Sec. 280H. Limitation on certain amounts paid to employee-owners by personal service corporations electing alternative taxable years.’’. 

22 (60) Subparagraphs (F) and (G) of section 

23 263(a)(1) are each amended by striking the semi24 colon at the end and inserting a comma. 


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1 (61) Section 263(a)(1) is amended by redesig2 nating subparagraphs (I) through (L) as subpara3 graphs (H) through (K), respectively. 

4 (62) Section 280C(a) is amended by striking 

5 ‘‘and 1396(a),’’ and inserting ‘‘1396(a),’’. 

6 (63) Section 280F(d)(4)(A)(iv) is amended by 

7 striking ‘‘ ‘and’ ’’ at the end and inserting ‘‘and’’. 

8 (64) The heading of section 331 is amended by 

9 striking ‘‘SHAREHOLDERS’’ and inserting 

10 ‘‘SHAREHOLDER’’. 

11 (65) Section 338(h)(3)(A)(iii) is amended by 

12 striking ‘‘paragaraph’’ and inserting ‘‘paragraph’’. 

13 (66) The second sentence of section 

14 355(h)(2)(B) is amended by striking ‘‘of assets’’. 

15 (67) The heading of subpart C of part III of 

16 subchapter C of chapter 1 is amended by striking 

17 ‘‘Corporation’’ and inserting ‘‘Corporations’’. 

18 (68) Section 362(a) is amended by striking the 

19 comma after ‘‘acquired’’. 

20 (69) Section 368(a)(2)(F)(vii) is amended by 

21 striking ‘‘(15 U.S.C. 80a-2(36))’’ and inserting ‘‘(15 

22 U.S.C. 80a–2(a)(36))’’. 

23 (70) Section 401(a)(2) is amended by striking 

24 ‘‘determination).;’’ and inserting ‘‘determination));’’. 


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1 (71) Section 401(a)(15) is amended by striking 

2 ‘‘a trust’’ and inserting ‘‘A trust’’. 

3 (72) Section 401(a)(32)(A) is amended by 

4 striking ‘‘section section’’ both places it appears and 

5 inserting ‘‘section’’. 

6 (73) Section 401(c)(2)(A)(iii) is amended by 

7 striking ‘‘sections 3121(d)(3)(A), (C), or (D), with8 out regard to paragraph (2) of section 1402(c)’’ and 

9 inserting ‘‘subparagraph (A), (C), or (D) of section 

10 3121(d)(3), without regard to section 1402(c)(2)’’. 

11 (74) Section 402(i) is amended by striking 

12 ‘‘subparagraph (A) of subsection (d)(4)’’ and insert13 ing ‘‘subsection (e)(4)(D)(i)’’. 

14 (75) Section 404A(c)(4)(B) is amended by 

15 striking ‘‘and’’ at the end. 

16 (76) Section 408(a)(1) is amended by inserting 

17 ‘‘or’’ after ‘‘subsection (d)(3)’’. 

18 (77) Section 408(m)(3)(B) is amended by strik19 ing ‘‘section 7’’ and inserting ‘‘section 5’’. 

20 (78) Section 408A(d)(3)(B) is amended by add21 ing a period at the end. 

22 (79) Section 408A(e)(2)(B) is amended by 

23 striking ‘‘the subparagraph (A)’’ and inserting ‘‘sub24 paragraph (A)’’. 


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1 (80) Section 409(n)(1)(A)(i) is amended by 

2 striking ‘‘securities,,,’’ and inserting ‘‘securities,’’. 

3 (81) Section 409A(b)(3)(B)(i) is amended by 

4 striking the semicolon at the end and inserting a 

5 comma. 

6 (82) The item relating to section 413 in the 

7 table of sections for subpart B of part I of sub8 chapter D of chapter 1 is amended to read as fol9 lows: 

‘‘Sec. 413. Collectively bargained plans, etc.’’. 

10 (83) Section 411(a)(4)(A) is amended by strik11 ing the comma at the end and inserting a semicolon. 

12 (84) Section 411(b)(5)(B)(iv) is amended by 

13 striking ‘‘similar amount’’ and inserting ‘‘similar ac14 count’’. 

15 (85) Section 412(c)(1)(A) is amended by add16 ing a period at the end. 

17 (86) Section 412(c)(4)(B) is amended by insert18 ing ‘‘section’’ before ‘‘433(d)’’. 

19 (87) Section 412(c)(7)(B)(iii) is amended by 

20 striking the comma after ‘‘subchapter D’’. 

21 (88) Section 414(l)(2)(G) is amended by strik22 ing ‘‘BANKS’’ in the heading thereof and inserting 

23 ‘‘DEPOSITORY INSTITUTIONS’’. 

24 (89) Section 414(u)(6) is amended by striking 

25 ‘‘section 403(b)’’ and inserting ‘‘section 403(b))’’. 


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1 (90) Section 414(x)(1) is amended by striking 

2 ‘‘are’’ and inserting ‘‘is’’. 

3 (91) Section 414(y)(1)(C)(i) is amended by 

4 striking ‘‘of such Code’’. 

5 (92) Section 414(y)(2) is amended by striking 

6 ‘‘subparagraph’’ and inserting ‘‘subparagraphs’’. 

7 (93) Section 418E is amended by striking ‘‘sub8 section 432(b)(2)’’ each place it appears and insert9 ing ‘‘section 432(b)(2)’’. 

10 (94) Section 418E(d)(1), as amended by the 

11 preceding paragraph, is amended— 

12 (A) by striking ‘‘section 432(b)(2),,’’ and 

13 inserting ‘‘section 432(b)(2),’’, and 

14 (B) by striking ‘‘section 432(b)(2),)’’ and 

15 inserting ‘‘section 432(b)(2))’’. 

16 (95) Section 418E(e)(1)(A) is amended to read 

17 as follows: 

18 ‘‘(A) notify the Secretary and the parties 

19 described in section 101(f)(1) of the Employee 

20 Retirement Income Security Act of 1974 of that 

21 determination, and’’. 

22 (96) Section 419A(c)(6)(B) is amended by 

23 striking ‘‘(42 U.S.C. 300gg-91(d)(3))’’ and inserting 

24 ‘‘(42 U.S.C. 300gg–91(d)(3)))’’. 


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1 (97) Section 420(c)(1)(A) is amended by strik2 ing ‘‘subsection (e)(1)(D)’’ and inserting ‘‘subsection 

3 (e)(1)(E)’’. 

4 (98) Section 424(g) is amended by striking 

5 ‘‘section 422(a)(2)’’ and inserting ‘‘sections 

6 422(a)(2)’’. 

7 (99) Section 430(c)(7)(E)(v)(II) is amended by 

8 inserting ‘‘the’’ after ‘‘title I of’’. 

9 (100) Section 430(h)(2)(F) is amended by 

10 striking ‘‘section 417(e)(3)(D)(i)’’ and inserting 

11 ‘‘section 417(e)(3)(D)’’. 

12 (101) Section 431(d)(2)(B)(i) is amended by 

13 striking ‘‘this Act’’ and inserting ‘‘the Pension Pro14 tection Act of 2006’’. 

15 (102) Section 432(b)(3)(A)(i) is amended by 

16 striking ‘‘paragraph (5),,’’ and inserting ‘‘paragraph 

17 (5),’’. 

18 (103) Section 432(b)(3)(B) is amended by re19 designating the clause (iv) relating to projections of 

20 critical and declining status as clause (v). 

21 (104) Section 432(b)(3)(D)(iv) is amended by 

22 inserting a comma after ‘‘Labor’’. 

23 (105) Section 432(e)(8)(C)(iii) is amended by 

24 striking ‘‘the Secretary shall’’ and inserting ‘‘The 

25 Secretary shall’’. 


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1 (106) Section 432(g)(1) is amended by striking 

2 ‘‘subsection (e)(9))’’ and inserting ‘‘subsection 

3 (e)(9)’’. 

4 (107) Section 433(c)(5)(C)(ii)(II) is amended 

5 by inserting ‘‘of such Act’’ after ‘‘title IV’’. 

6 (108) The item relating to section 436 in the 

7 table of sections for subpart B of part III of sub8 chapter D of chapter 1 is amended to read as fol9 lows: 

‘‘Sec. 436. Funding-based limits on benefits and benefit accruals under singleemployer plans.’’. 

10 (109) Section 447(h)(2)(A) is amended by 

11 striking ‘‘employes’’ and inserting ‘‘employees’’. 

12 (110) Section 447(i)(5)(B) is amended by re13 designating clause (iv) as clause (iii). 

14 (111) The heading of section 453B is amended 

15 by striking ‘‘LOSS DISPOSITION’’ and inserting 

16 ‘‘LOSS ON DISPOSITION’’. 

17 (112) Section 457(f)(4)(C)(i) is amended— 

18 (A) by striking ‘‘section 9101’’ and insert19 ing ‘‘section 8101’’, and 

20 (B) by striking ‘‘7801),’’ and inserting 

21 ‘‘7801)),’’. 

22 (113) Section 457A(d)(4) is amended— 

23 (A) by striking ‘‘case a foreign’’ and in24 serting ‘‘case of a foreign’’, and 


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1 (B) by striking ‘‘had been’’ and inserting 

2 ‘‘been’’. 

3 (114) Section 458(b)(9) is amended by striking 

4 ‘‘REPURCHASED’’ in the heading thereof and insert5 ing ‘‘REPURCHASE’’. 

6 (115) Section 458(c)(1) is amended by striking 

7 ‘‘regulations prescribed’’ and inserting ‘‘regulations 

8 prescribe’’. 

9 (116) Section 460(b)(2)(A) is amended by in10 serting a comma after ‘‘first’’. 

11 (117)(A) Section 461 is amended by redesig12 nating the second subsection (j) (relating to farming 

13 syndicate defined) as subsection (k). 

14 (B) Section 461(i)(4) is amended by striking 

15 ‘‘subsection (j)’’ and inserting ‘‘subsection (k)’’. 

16 (118) The heading of section 464 is amended 

17 by inserting ‘‘EXPENSES’’ after ‘‘FARMING’’. 

18 (119) Section 464(d)(2)(B)(iii) is amended by 

19 striking ‘‘subsection (c)(2)(E)’’ and inserting ‘‘sec20 tion 461(k)(2)(E)’’. 

21 (120) Section 470(d)(2)(B) is amended by 

22 striking ‘‘clause (ii)’’ and inserting ‘‘subparagraph 

23 (A)(ii)’’. 


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1 (121) The item relating to part VIII in the 

2 table of parts for subchapter F of chapter 1 is 

3 amended to read as follows: 

‘‘PART VIII. CERTAIN SAVINGS ENTITIES’’. 

4 (122) Section 501(c)(14)(B)(iv) is amended by 

5 adding a period at the end. 

6 (123) Section 501(c)(19)(B) is amended by 

7 striking ‘‘widows,,’’ and inserting ‘‘widows,’’. 

8 (124) Section 501(f)(3)(B) is amended by strik9 ing ‘‘section 115(a)’’ and inserting ‘‘section 115’’. 

10 (125) The item relating to section 511 in the 

11 table of sections for part III of subchapter F of 

12 chapter 1 is amended to read as follows: 

‘‘Sec. 511. Imposition of tax on unrelated business income of charitable, etc., 

organizations.’’. 

13 (126) Section 512(b)(19)(H)(iii) is amended by 

14 striking ‘‘clause (i)(II)’’ and inserting ‘‘clause (i)’’. 

15 (127) Section 529(c)(6) is amended by striking 

16 ‘‘an Coverdell’’ and inserting ‘‘a Coverdell’’. 

17 (128) Section 529(e)(3)(A) is amended— 

18 (A) by striking the semicolon at the end of 

19 clause (i) and inserting a comma, and 

20 (B) by adding ‘‘, and’’ at the end of clause 

21 (ii). 

22 (129) Section 529A(d)(4) is amended by strik23 ing ‘‘Achieving a Better Life Experience Act of 


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1 2014’’ and inserting ‘‘Stephen Beck, Jr., ABLE Act 

2 of 2014’’. 

3 (130) Section 529A(e)(4) is amended by strik4 ing ‘‘subparagraph section’’ and inserting ‘‘section’’. 

5 (131) Section 530(d)(9)(B) is amended by 

6 striking ‘‘by the’’ and inserting ‘‘by’’. 

7 (132) Section 542(c)(5) is amended by striking 

8 the comma at the end and inserting a semicolon. 

9 (133) Section 542(c)(7) is amended by striking 

10 ‘‘A small’’ and inserting ‘‘a small’’. 

11 (134) Section 543(a)(2)(B)(ii) is amended by 

12 striking ‘‘section 563(d)’’ and inserting ‘‘section 

13 563(c)’’. 

14 (135) Section 543(d)(5)(A)(ii) is amended by 

15 striking ‘‘section 563(d)’’ and inserting ‘‘section 

16 563(c)’’. 

17 (136) Section 613A(c)(7)(B) is amended by 

18 striking ‘‘taxpayers’’ and inserting ‘‘taxpayer’s’’. 

19 (137) Section 642(c)(1) is amended by striking 

20 ‘‘other then’’ and inserting ‘‘other than’’. 

21 (138) The item relating to section 661 in the 

22 table of sections for subpart C of part I of sub23 chapter J of chapter 1 is amended to read as fol24 lows: 

‘‘Sec. 661. Deduction for estates and trusts accumulating income or distributing corpus.’’. 


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1 (139) Section 706(b)(5) is amended by striking 

2 ‘‘section 584(h)’’ and inserting ‘‘section 584(i)’’. 

3 (140) Section 751(c) is amended by striking 

4 ‘‘and, sections’’ both places it appears and inserting 

5 ‘‘and sections’’. 

6 (141) Section 807(e)(7)(A)(i) is amended by 

7 striking ‘‘subparagraph (C)’’ and inserting ‘‘sub8 paragraph (B)’’. 

9 (142) Section 810(c)(2)(B) is amended by 

10 striking ‘‘corporations),’’ and inserting ‘‘corpora11 tions)’’. 

12 (143) Section 810(d)(1) is amended by striking 

13 ‘‘paragraphs (2) and (3) of section 804) or’’ and in14 serting ‘‘paragraph (2) of section 804) for’’. 

15 (144) Section 810(f) is amended by striking 

16 ‘‘section 805(b)(5)’’ and inserting ‘‘section 

17 805(b)(4)’’. 

18 (145) Section 831(c) is amended by striking 

19 ‘‘section 816(a)).’’ and inserting ‘‘section 816(a).’’. 

20 (146) Section 832(b)(7)(E)(ii)(II) is amended 

21 by striking the comma at the end and inserting a pe22 riod. 

23 (147) Section 852(a)(1)(B) is amended by 

24 striking ‘‘265,’’ and inserting ‘‘265 and’’. 


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1 (148) Section 852(b)(2)(D) is amended by 

2 striking ‘‘the deduction’’ and inserting ‘‘The deduc3 tion’’. 

4 (149) Subparagraphs (A) and (B) of section 

5 856(c)(7) are each amended by striking ‘‘paragraph 

6 (4)(B)(iii)’’ and inserting ‘‘paragraph (4)(B)(iv)’’. 

7 (150) Paragraphs (1), (3), (4), and (5) of sec8 tion 856(m) are each amended by striking ‘‘sub9 section (c)(4)(B)(iii)’’ and inserting ‘‘subsection 

10 (c)(4)(B)(iv)’’. 

11 (151) Section 857(b)(6)(J) is amended by strik12 ing ‘‘section 856(c)(8)’’ and inserting ‘‘section 

13 856(c)(10)’’. 

14 (152) Section 860(f)(2)(A)(ii) is amended by 

15 striking ‘‘decreased’’ and inserting ‘‘decrease’’. 

16 (153) Section 860(i) is amended by striking 

17 ‘‘willfull’’ and inserting ‘‘willful’’. 

18 (154) Section 860G(a)(3)(A)(iii)(III) is amend19 ed by striking the period at the end and inserting 

20 a comma. 

21 (155) Section 864(d)(8) is amended by striking 

22 ‘‘section 956(b)(3)’’ and inserting ‘‘section 

23 956(c)(3)’’. 

24 (156) Section 877(d)(4)(B)(i) is amended by 

25 striking ‘‘in 957’’ and inserting ‘‘in section 957’’. 


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1 (157) Section 877A(g)(6) is amended by strik2 ing ‘‘220(e)(4)’’ and inserting ‘‘220(f)(4)’’. 

3 (158) Section 897(a)(1)(A) is amended by 

4 striking ‘‘section 871(B)(1)’’ and inserting ‘‘section 

5 871(b)(1)’’. 

6 (159) The heading of section 897(k)(2) is 

7 amended by striking ‘‘USRPI’’ and inserting 

8 ‘‘UNITED STATES REAL PROPERTY INTEREST’’. 

9 (160) Section 904(d)(2)(B)(ii) is amended by 

10 striking ‘‘subparagraph (E)(iii) or paragraph (3)(I)’’ 

11 and inserting ‘‘subparagraph (E)(ii) or paragraph 

12 (3)(H)’’. 

13 (161) Section 907(c)(3)(C) is amended by strik14 ing the period after ‘‘partnerships’’ and inserting a 

15 comma. 

16 (162) Section 907(f)(1) is amended by striking 

17 ‘‘year,’’ and inserting ‘‘years,’’. 

18 (163) Section 911(d)(8)(B)(i) is amended by 

19 striking ‘‘(50 U.S.C. App. 1 et seq.)’’ and inserting 

20 ‘‘(50 U.S.C. 4301 et seq.)’’. 

21 (164) Section 912(1)(B) is amended by striking 

22 ‘‘(50 U.S.C., sec. 403e)’’ and inserting ‘‘(50 U.S.C. 

23 3505)’’. 


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1 (165) Section 936(h)(5)(C)(i)(III)(a) is amend2 ed by striking ‘‘corporations’’ and inserting ‘‘cor3 poration’s’’. 

4 (166) Section 954(b)(5) is amended by striking 

5 ‘‘income,,’’ and inserting ‘‘income,’’. 

6 (167) Section 954(b)(6) is amended by striking 

7 the comma after ‘‘paragraph (2)’’. 

8 (168) Section 956(c)(2)(E) is amended by 

9 striking ‘‘section 953(a)(1)’’ and inserting ‘‘section 

10 953(e)(2)’’. 

11 (169) Section 956(e) is amended by striking 

12 ‘‘provisons’’ and inserting ‘‘provisions’’. 

13 (170) Section 957(b) is amended by striking 

14 ‘‘section 953(a)(1)’’ and inserting ‘‘section 

15 953(e)(2)’’. 

16 (171) Section 960(b)(3) is amended by striking 

17 ‘‘Reconcilation’’ and inserting ‘‘Reconciliation’’. 

18 (172) The heading of section 993 is amended 

19 by inserting ‘‘AND SPECIAL RULES’’ after ‘‘DEFI20 NITIONS’’. 

21 (173) Section 1016(a)(3)(D) is amended by in22 serting ‘‘as in effect prior to its repeal by the Tax 

23 Reform Act of 1986’’ before ‘‘(or the corresponding 

24 provisions of prior income tax laws)’’. 


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1 (174) Section 1033(h)(2) is amended by insert2 ing ‘‘is’’ before ‘‘located’’. 

3 (175) Section 1035(a)(1) is amended by strik4 ing ‘‘; or’’ and inserting a semicolon. 

5 (176) Section 1059(d)(3) is amended by strik6 ing ‘‘; except that’’ and all that follows and inserting 

7 ‘‘and there shall not be taken into account any day 

8 which is more than 2 years after the date on which 

9 such share becomes ex-dividend.’’. 

10 (177) Section 1092(a)(2)(B) is amended by 

11 striking ‘‘with respect other’’ in the last sentence 

12 and inserting ‘‘with respect to other’’. 

13 (178) Section 1092(c)(4)(E) is amended by 

14 striking ‘‘(other than subparagraph (B) thereof)’’. 

15 (179) The item relating to section 1222 in the 

16 table of sections for part III of subchapter P of 

17 chapter 1 is amended to read as follows: 

‘‘Sec. 1222. Other terms relating to capital gains and losses.’’. 

18 (180) The item relating to section 1252 in the 

19 table of sections for part IV of subchapter P of 

20 chapter 1 is amended to read as follows: 

‘‘Sec. 1252. Gain from disposition of farm land.’’. 

21 (181) Section 1250(d)(3) is amended by strik22 ing ‘‘paragraph (9)’’ and inserting ‘‘paragraph (6)’’. 

23 (182) Section 1255(b)(2) is amended by strik24 ing ‘‘170(e),’’ and inserting ‘‘170(e)’’. 


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1 (183)(A) Subparagraphs (B) and (C) of section 

2 1256(e)(3) are each amended by striking ‘‘section 

3 464(e)(2)’’ and inserting ‘‘section 461(k)(4)’’. 

4 (B) Section 1258(d)(5)(C) is amended by strik5 ing ‘‘section 464(e)(2)’’ and inserting ‘‘section 

6 461(k)(4)’’. 

7 (184) Section 1257(c)(1) is amended— 

8 (A) by striking ‘‘section 1201(4)’’ and in9 serting ‘‘section 1201(a)(7)’’, and 

10 (B) by striking ‘‘16 U.S.C. 3801(4)’’ and 

11 inserting ‘‘16 U.S.C. 3801(7)’’. 

12 (185) Section 1257(c)(2) is amended— 

13 (A) by striking ‘‘section 1201(6)’’ and in14 serting ‘‘section 1201(a)(10)’’, and 

15 (B) by striking ‘‘16 U.S.C. 3801(6)’’ and 

16 inserting ‘‘16 U.S.C. 3801(10)’’. 

17 (186) Section 1274(b)(3)(B)(i) is amended by 

18 striking ‘‘section 6662(d)(2)(C)(iii)’’ and inserting 

19 ‘‘section 6662(d)(2)(C)(ii)’’. 

20 (187) Section 1276(a)(4) is amended by strik21 ing ‘‘871(a),,’’ and inserting ‘‘871(a),’’. 

22 (188) Section 1278(b)(1) is amended by strik23 ing ‘‘871(a),,’’ and inserting ‘‘871(a),’’. 

24 (189) Section 1286(f) is amended by striking 

25 ‘‘and 305(e),’’ and inserting ‘‘and section 305(e),’’. 


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1 (190) Section 1291(e) is amended by striking 

2 ‘‘subsections (c) and (d) (e),’’ and inserting ‘‘sub3 sections (c), (d), and (e)’’. 

4 (191) Section 1298(b)(5)(B) is amended by 

5 striking ‘‘section 951(f)’’ and inserting ‘‘section 

6 951(c)’’. 

7 (192) Section 1298(d)(2)(A) is amended by 

8 striking ‘‘section 1296(a)(2)’’ and inserting ‘‘section 

9 1297(a)(2)’’. 

10 (193) Section 1298(e)(2)(B)(ii) is amended by 

11 striking ‘‘provisons’’ and inserting ‘‘provisions’’. 

12 (194) Section 1355(f)(3) is amended by strik13 ing ‘‘of which’’ and inserting ‘‘on which’’. 

14 (195) Section 1358(b)(1) is amended by strik15 ing ‘‘section 1352(a)(2)’’ and inserting ‘‘section 

16 1352(2)’’. 

17 (196) Section 1358(c)(2) is amended by strik18 ing ‘‘an person’s’’ and inserting ‘‘a person’s’’. 

19 (197) Sections 1361(f)(2), 1362(d)(3)(C)(v), 

20 and 4975(d)(16)(A) are each amended by striking 

21 ‘‘1813(w)(1)),’’ and inserting ‘‘1813(w)(1))),’’. 

22 (198) Section 1362(f) is amended by striking 

23 ‘‘may be during’’ and inserting ‘‘may be, during’’. 


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1 (199) Section 1366(e) is amended by striking 

2 ‘‘section 704(e)(3)’’ and inserting ‘‘section 

3 704(e)(2)’’. 

4 (200) Section 1368(f)(2) is amended by strik5 ing ‘‘in included’’ and inserting ‘‘is included’’. 

6 (201) Section 1391(g)(3)(E)(ii) is amended by 

7 striking ‘‘Interior’’ and inserting ‘‘the Interior’’. 

8 (202) Section 1394(b)(3)(B)(i)(II) is amended 

9 by striking ‘‘subsection’’ and inserting ‘‘sub10 sections’’. 

11 (203) Section 1397C(d)(5)(B) is amended by 

12 striking ‘‘subparagraphs (A) or (B)’’ and inserting 

13 ‘‘subparagraph (A) or (B)’’. 

14 (204) Section 1402(a)(1) is amended— 

15 (A) by striking ‘‘section 1233(2)’’ and in16 serting ‘‘section 1233(a)(2)’’, and 

17 (B) by striking ‘‘16 U.S.C. 3833(2)’’ and 

18 inserting ‘‘16 U.S.C. 3833(a)(2)’’. 

19 (205) Section 1402(b) is amended by striking 

20 ‘‘3211,.’’ and inserting ‘‘3211.’’. 

21 (206) The heading of section 1446 is amended 

22 by striking ‘‘WITHHOLDING TAX’’ in the heading 

23 and inserting ‘‘WITHHOLDING OF TAX’’. 


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1 (207) Section 2031(c)(1) is amended by strik2 ing all that follows subparagraph (A) and inserting 

3 the following: 

4 ‘‘(B) $500,000.’’. 

5 (208) Section 2031(c)(2) is amended by strik6 ing ‘‘paragraph (5)).’’ and inserting ‘‘paragraph 

7 (5))).’’. 

8 (209) Section 2055(e)(3)(G) is amended by 

9 striking ‘‘subparagraph (J)’’ and inserting ‘‘sub10 paragraph (J))’’. 

11 (210) Section 2106(a)(4) is amended by insert12 ing ‘‘section’’ before ‘‘2058(a)’’. 

13 (211) Section 2522(c)(1) is amended by strik14 ing ‘‘to of for’’ and inserting ‘‘to or for’’. 

15 (212) Section 2523(g)(1) is amended by strik16 ing ‘‘noncharitable beneficiary’’ and inserting ‘‘bene17 ficiary who is not a charitable beneficiary’’. 

18 (213) Section 2523(g)(2) is amended by strik19 ing ‘‘noncharitable’’ and inserting ‘‘charitable’’. 

20 (214) Section 3101(a) is amended by adding a 

21 period at the end. 

22 (215) Section 3111(e)(5)(B) is amended by in23 serting ‘‘the’’ before ‘‘meaning’’. 


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1 (216) Section 3121(b)(5)(B)(i)(V) is amended 

2 by striking ‘‘section 105(e)(2)’’ and inserting ‘‘sec3 tion 104(e)(2)’’. 

4 (217) Section 3121(b)(5)(H)(i) is amended by 

5 striking ‘‘1997’’ and inserting ‘‘1997,’’. 

6 (218) Section 3304(a)(4)(G)(ii) is amended by 

7 striking ‘‘section 6402(f)(4)(B)’’ and inserting ‘‘sec8 tion 6402(f)(4)(C)’’. 

9 (219) Section 3306(b)(5)(F) is amended by 

10 striking the semicolon at the end and inserting a 

11 comma. 

12 (220) Section 3306(c)(19) is amended by strik13 ing ‘‘Service’’ and inserting ‘‘service’’. 

14 (221) Section 3306(u) is amended by striking 

15 ‘‘25 U.S.C. 450b(e)’’ and inserting ‘‘25 U.S.C. 

16 5304(e)’’. 

17 (222) Section 3306(v) is amended by striking 

18 ‘‘this part’’ and inserting ‘‘this section’’. 

19 (223) Section 3309(d) is amended by striking 

20 ‘‘25 U.S.C. 450b(e)’’ and inserting ‘‘25 U.S.C. 

21 5304(e)’’. 

22 (224)(A) Paragraphs (1), (2), (3), (4)(B), (5), 

23 (6), (8)(A)(ii), (8)(B), (8)(D), (9), (10)(B), (11), 

24 (12)(A), (12)(B), (12)(C), (13), (14), and (15) of 


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1 section 3401(a) are each amended by striking ‘‘; or’’ 

2 at the end and inserting a comma. 

3 (B) Paragraphs (4)(A), (8)(A)(i), (8)(C), 

4 (10)(A), (12)(D), and (22) of section 3401(a) are 

5 each amended by striking ‘‘; or’’ at the end and in6 serting ‘‘, or’’. 

7 (C) Section 3401(a)(12)(E) is amended by 

8 striking ‘‘, or’’ at the end and inserting a comma. 

9 (D) Paragraphs (16)(A), (16)(B), (17), (18), 

10 (19), (20), and (21) of section 3401(a) are each 

11 amended by striking the semicolon at the end and 

12 inserting a comma. 

13 (225) Section 3509(d)(1)(C) is amended by 

14 striking ‘‘sections’’ and inserting ‘‘section’’. 

15 (226) Section 4051(a)(3) is amended by strik16 ing ‘‘Secretary.’’ and inserting ‘‘Secretary).’’. 

17 (227) Section 4104(a)(1) is amended by strik18 ing ‘‘section’’ and inserting ‘‘sections’’. 

19 (228) Section 4221(a) is amended by striking 

20 ‘‘section 4051,’’ and inserting ‘‘section 4051’’. 

21 (229) The item relating to part III in the table 

22 of parts for subchapter C of chapter 33 is amended 

23 by striking ‘‘relating’’ and inserting ‘‘applicable’’. 


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1 (230) Section 4612(e)(2)(B)(ii)(I) is amended 

2 by striking ‘‘tranferred’’ and inserting ‘‘trans3 ferred’’. 

4 (231) Section 4958(f)(1)(D) is amended by 

5 striking the period at the end and inserting a 

6 comma. 

7 (232) Section 4971(c)(3) is amended by strik8 ing ‘‘applicable and’’ and inserting ‘‘applicable, 

9 and’’. 

10 (233) Section 4971(f) is amended by striking 

11 ‘‘applicable for’’ and inserting ‘‘applicable, for’’. 

12 (234) Section 4971(g)(4)(C)(ii) is amended by 

13 striking ‘‘section 432(i)(9)’’ and inserting ‘‘section 

14 432(j)(9)’’. 

15 (235) Section 4975(d)(3) is amended by strik16 ing ‘‘an leveraged’’ and inserting ‘‘a leveraged’’. 

17 (236) Section 4975(d)(17) is amended by strik18 ing ‘‘Any’’ and inserting ‘‘any’’. 

19 (237) Section 4975(d)(21) is amended by strik20 ing ‘‘person person’’ and inserting ‘‘person’’. 

21 (238) Section 4975(f)(8)(C)(iv)(II) is amended 

22 by inserting ‘‘subsection’’ before ‘‘(d)(17)(A)(ii)’’. 

23 (239) Section 4975(f)(8)(F)(i)(I) is amended by 

24 striking ‘‘adviser,’’ and inserting ‘‘adviser’’. 


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1 (240) Section 4975(f)(8)(F)(i)(V) is amended 

2 by inserting ‘‘of’’ before ‘‘the manner’’. 

3 (241) Section 4980B(f)(1) is amended by strik4 ing ‘‘section 2162 of the Public Health Service Act’’ 

5 and inserting ‘‘section 1928(h)(6) of the Social Se6 curity Act (42 U.S.C. 1396s(h)(6))’’. 

7 (242) Section 4980B(f)(5)(C)(iii) is amended 

8 by striking ‘‘section 2701(c)(2)’’ and inserting ‘‘sec9 tion 2704(c)(2)’’. 

10 (243) Section 4980I(b)(3)(C)(iv) is amended by 

11 striking the comma at the end and inserting a pe12 riod. 

13 (244) Section 4980I(b)(3)(C)(v) is amended by 

14 striking ‘‘for for’’ and inserting ‘‘for’’. 

15 (245) Section 5054(a)(3)(B) is amended by 

16 striking ‘‘sections’’ and inserting ‘‘section’’. 

17 (246) Section 5066(d) is amended by striking 

18 ‘‘section 5001(a)(5)’’ and inserting ‘‘section 

19 5001(a)(4)’’. 

20 (247) The item relating to subpart C in the 

21 table of subparts for part II of subchapter A of 

22 chapter 51 is amended to read as follows: 

‘‘SUBPART C. RECORDKEEPING AND REGISTRATION BY DEALERS’’. 


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1 (248) The item relating to section 5178 in the 

2 table of sections for subchapter B of chapter 51 is 

3 amended to read as follows: 

‘‘Sec. 5178. Premises of distilled spirits plants.’’. 

4 (249) Section 5182 is amended by striking 

5 ‘‘section 5112’’ and inserting ‘‘section 5121’’. 

6 (250) Section 5273(e)(2) is amended by strik7 ing ‘‘section 5001(a)(6)’’ and inserting ‘‘section 

8 5001(a)(5)’’. 

9 (251) Section 5314(a)(2) is amended by strik10 ing ‘‘section 5001(a)(10)’’ and inserting ‘‘section 

11 5001(a)(9)’’. 

12 (252) Section 5392(f) is amended by striking 

13 ‘‘section 17(a)(5)’’ and inserting ‘‘section 

14 117(a)(5)’’. 

15 (253) Section 5512 is amended by striking 

16 ‘‘section 5001(a)(7)’’ and inserting ‘‘section 

17 5001(a)(6)’’. 

18 (254) Section 5601(a)(15) is amended by strik19 ing ‘‘Withdraws,’’ and inserting ‘‘withdraws,’’. 

20 (255) The heading of section 5603 is amended 

21 by inserting a comma after ‘‘RETURNS’’. 

22 (256) Section 5701(e) is amended by striking 

23 ‘‘manufacturered’’ and inserting ‘‘manufactured’’. 


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1 (257) The item relating to section 5847 in the 

2 table of sections for part I of subchapter B of chap3 ter 53 is amended to read as follows: 

‘‘Sec. 5847. Effect on other laws.’’. 

4 (258) Section 5847 is amended by striking 

5 ‘‘section 414 of the Mutual Security Act of 1954’’ 

6 and inserting ‘‘section 38 of the Arms Export Con7 trol Act (22 U.S.C. 2778)’’. 

8 (259) The item relating to section 5852 in the 

9 table of sections for part II of subchapter B of chap10 ter 53 is amended to read as follows: 

‘‘Sec. 5852. General transfer and making tax exemption.’’. 

11 (260) The item relating to section 5853 in the 

12 table of sections for part II of subchapter B of chap13 ter 53 is amended to read as follows: 

‘‘Sec. 5853. Transfer and making tax exemption available to certain governmental entities.’’. 

14 (261) Section 6012(a)(6) is amended by strik15 ing ‘‘and’’ at the end. 

16 (262) Section 6012(a)(7) is amended by strik17 ing the period at the end and inserting ‘‘; and’’. 

18 (263) Section 6012(a)(8) is amended by strik19 ing ‘‘section 63(c)(2)(D).’’ and inserting ‘‘section 

20 63(c)(2)(C);’’. 

21 (264) Section 6033(b)(15) is amended by strik22 ing the period at the end and inserting ‘‘, and’’. 


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1 (265) Section 6039(d)(2) is amended to read as 

2 follows: 

3 ‘‘(2) the term ‘employee stock purchase plan’, 

4 see section 423(b).’’. 

5 (266) The table of sections for subpart B of 

6 part III of subchapter A of chapter 61 is amended 

7 by inserting after the item relating to section 6041 

8 the following new item: 

‘‘Sec. 6041A. Returns regarding payments of remuneration for services and direct sales.’’. 

9 (267) The item relating to section 6050I in the 

10 table of sections for subpart B of part III of sub11 chapter A of chapter 61 is amended to read as fol12 lows: 

‘‘Sec. 6050I. Returns relating to cash received in trade or business, etc.’’. 

13 (268) The item relating to section 6050W in 

14 the table of sections for subpart B of part III of 

15 subchapter A of chapter 61 is amended to read as 

16 follows: 

‘‘Sec. 6050W. Returns relating to payments made in settlement of payment 

card and third party network transactions.’’. 

17 (269) Section 6050H(h)(3)(B)(i) is amended by 

18 striking ‘‘Rural Housing Administration’’ and insert19 ing ‘‘Rural Housing Service’’. 

20 (270) Section 6058(e) is amended by striking 

21 paragraph (1) and by redesignating paragraphs (2) 

22 and (3) as paragraphs (1) and (2), respectively. 


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1 (271) Section 6059(b)(3)(B) is amended— 

2 (A) by striking ‘‘the requirements’’ and in3 serting ‘‘that the requirements’’, and 

4 (B) by striking the period at the end and 

5 inserting a comma. 

6 (272) Section 6091(b)(2)(B)(ii) is amended by 

7 striking ‘‘and’’ at the end. 

8 (273) Section 6103(l)(7) is amended by striking 

9 ‘‘OF 1977’’ in the heading thereof. 

10 (274) Section 6103(l)(10)(A) is amended by 

11 striking ‘‘request made under subsection (f)(5)’’ and 

12 inserting ‘‘notice submitted under subsection 

13 (f)(5)(C)’’. 

14 (275) Section 6103(l)(10) is amended by strik15 ing so much of subparagraph (B) as precedes ‘‘Any’’ 

16 and inserting the following: 

17 ‘‘(B) RESTRICTION ON USE OF DISCLOSED

18 INFORMATION.—(i)’’. 

19 (276) Section 6103(l)(16)(A) is amended by 

20 striking ‘‘subsection 6103(b)(6)’’ and inserting ‘‘sec21 tion 6103(b)(6)’’. 

22 (277) Section 6103(p)(3)(A) is amended by 

23 striking ‘‘subsections’’ and inserting ‘‘subsection’’. 


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1 (278) Section 6103(p)(3)(C)(ii) is amended by 

2 striking the comma at the end and inserting a pe3 riod. 

4 (279) Section 6103(p)(4) is amended by strik5 ing ‘‘7(a)(ii)’’ in the flush matter before subpara6 graph (A) and inserting ‘‘(7)(A)(ii)’’. 

7 (280) Section 6103(p)(4)(F)(ii) is amended— 

8 (A) by striking ‘‘subsections’’ and inserting 

9 ‘‘subsection’’, and 

10 (B) by striking ‘‘subsection (l)(21),,,’’ and 

11 inserting ‘‘subsection (l)(21),’’. 

12 (281) Section 6103(p)(4) is amended by strik13 ing ‘‘subsection (l)(21),,’’ both places it appears in 

14 the flush matter at the end and inserting ‘‘sub15 section (l)(21),’’. 

16 (282) Section 6109(f) is amended by striking 

17 ‘‘OF 1977’’ in the heading thereof. 

18 (283) Section 6213(g)(2)(O) is amended by 

19 adding a comma at the end. 

20 (284) Section 6213(g)(2)(P) is amended— 

21 (A) by striking ‘‘section 24(h)(2)’’ and in22 serting ‘‘section 24(g)(2)’’, and 

23 (B) by striking ‘‘subsection (h)(1)’’ and in24 serting ‘‘subsection (g)(1)’’. 


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1 (285) Section 6302(e)(2)(A) is amended by 

2 striking ‘‘sections’’ and inserting ‘‘section’’. 

3 (286) Section 6311(d)(3)(D) is amended— 

4 (A) by striking ‘‘section 103(f)’’ and in5 serting ‘‘section 103(g)’’, and 

6 (B) by striking ‘‘1602(f)’’ and inserting 

7 ‘‘1602(g)’’. 

8 (287) Section 6330(d)(2) is amended by strik9 ing ‘‘, and’’ at the end and inserting a period. 

10 (288) Section 6334(a)(10)(A) is amended by 

11 striking ‘‘V,,’’ and inserting ‘‘V,’’. 

12 (289) Section 6342(a) is amended by striking 

13 ‘‘subsection (c)(2)’’ and inserting ‘‘subsection 

14 (d)(2)’’. 

15 (290) Section 6402(a) is amended by striking 

16 ‘‘(f) refund’’ and inserting ‘‘(f), refund’’. 

17 (291) Section 6402(c) is amended by striking 

18 ‘‘of of’’ and inserting ‘‘of’’. 

19 (292) Section 6402(d)(2) is amended by strik20 ing ‘‘section 402(a)(26) of the Social Security Act’’ 

21 and inserting ‘‘section 408(a)(3) of the Social Secu22 rity Act (42 U.S.C. 608(a)(3))’’. 

23 (293) Section 6404(g)(2)(E) is amended by 

24 striking ‘‘section 6664(d)(2)(A)’’ and inserting ‘‘sec25 tion 6664(d)(3)(A)’’. 


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1 (294) Section 6420(i)(4) is amended by striking 

2 ‘‘State and’’ and inserting ‘‘State (and’’. 

3 (295) Section 6421(c) is amended by striking 

4 ‘‘(4) (5)’’ and inserting ‘‘(4), (5)’’. 

5 (296) Section 6421(j)(3) is amended by striking 

6 ‘‘State and’’ and inserting ‘‘State (and’’. 

7 (297) Section 6422 is amended— 

8 (A) by striking paragraph (7), 

9 (B) by redesignating paragraphs (8) 

10 through (12) as paragraphs (7) through (11), 

11 respectively, and 

12 (C) by striking ‘‘for credit’’ in paragraph 

13 (10) as so redesignated and inserting ‘‘For 

14 credit’’. 

15 (298) Section 6425(c)(1)(A) is amended by 

16 striking ‘‘The sum’’ and inserting ‘‘the sum’’. 

17 (299) Section 6426(b)(2)(A)(ii) is amended by 

18 striking ‘‘cents..’’ and inserting ‘‘cents.’’. 

19 (300) Section 6501(m) is amended by striking 

20 ‘‘any election’’ and all that follows through ‘‘(or 

21 any’’ and inserting the following: ‘‘any election 

22 under section 30B(h)(9), 30C(e)(4), 30D(e)(4), 

23 35(g)(11), 40(f), 43, 45B, 45C(d)(4), 45H(g), or 

24 51(j) (or any’’. 


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1 (301) Section 6503(a)(1) is amended by strik2 ing ‘‘section 6230(a)).’’ and inserting ‘‘section 

3 6230(a))’’. 

4 (302) Section 6612(c) is amended— 

5 (A) by inserting ‘‘sections’’ before 

6 ‘‘2014(e)’’, and 

7 (B) by striking ‘‘and 6420’’ and inserting 

8 ‘‘6420’’. 

9 (303) The item relating to section 6651 in the 

10 table of sections for part I of subchapter A of chap11 ter 68 is amended to read as follows: 

‘‘Sec. 6651. Failure to file tax return or to pay tax.’’. 

12 (304) Each of the following sections are amend13 ed by inserting ‘‘an amount equal to’’ after ‘‘in14 creased by’’ and by inserting ‘‘for the calendar year’’ 

15 after ‘‘section 1(f)(3)’’: 

16 (A) Section 6651(i). 

17 (B) Section 6652(c)(7)(A). 

18 (C) Section 6695(h)(1). 

19 (D) Section 6698(e)(1). 

20 (E) Section 6699(e)(1). 

21 (F) Section 6721(f)(1). 

22 (G) Section 6722(f)(1). 

23 (305) Section 6654(a) is amended by striking 

24 ‘‘chapter 1 the tax’’ and inserting ‘‘chapter 1, the 

25 tax’’. 


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1 (306) Section 6654(f)(3) is amended by strik2 ing ‘‘taxes’’ and inserting ‘‘tax’’. 

3 (307) Section 6662(d)(3) is amended by strik4 ing ‘‘section 6664(d)(2)’’ and inserting ‘‘section 

5 6664(d)(3)’’. 

6 (308) Section 6662 is amended by moving sub7 section (i) before subsection (j). 

8 (309) The heading of section 6676(c) is amend9 ed by striking ‘‘REASONABLE BASIS’’ and inserting 

10 ‘‘REASONABLE CAUSE’’. 

11 (310) The item relating to section 6684 in the 

12 table of sections for part I of subchapter B of chap13 ter 68 is amended to read as follows: 

‘‘Sec. 6684. Assessable penalties with respect to liability for tax under chapter 

42.’’. 

14 (311) The item relating to section 6686 in the 

15 table of sections for part I of subchapter B of chap16 ter 68 is amended to read as follows: 

‘‘Sec. 6686. Failure to file returns or supply information by DISC or former 

FSC.’’. 

17 (312) Section 6679(a)(1) is amended by strik18 ing ‘‘section 6046 and 6046A’’ and inserting ‘‘sec19 tion 6046 or 6046A’’. 

20 (313) Section 6695(h)(2) is amended by strik21 ing ‘‘subparagraph (A)’’ and inserting ‘‘paragraph 

22 (1)’’. 


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1 (314) Section 6695(h)(2)(B) is amended by 

2 striking ‘‘clause (i)’’ and inserting ‘‘subparagraph 

3 (A)’’. 

4 (315) Section 6696(a) is amended by striking 

5 ‘‘section 6694,’’ and inserting ‘‘sections 6694,’’. 

6 (316) Section 6696(d)(1) is amended by strik7 ing ‘‘section 6695,’’ and inserting ‘‘6695,’’. 

8 (317) Section 6698(b)(2) is amended by adding 

9 a period at the end. 

10 (318) Section 6700(a) is amended by striking 

11 ‘‘the $1,000’’ and inserting ‘‘$1,000’’. 

12 (319) Section 6724(d)(1)(B)(xx) is amended by 

13 striking ‘‘or’’ at the end. 

14 (320) Section 6724(d)(1)(B)(xxi) is amended 

15 by striking ‘‘and’’ at the end. 

16 (321) Section 6724(d)(1) is amended by strik17 ing ‘‘Such term also includes’’ and inserting the fol18 lowing: 

19 ‘‘Such term also includes’’. 

20 (322) Section 6724(d)(2)(F) is amended by 

21 striking the period at the end and inserting a 

22 comma. 

23 (323) Section 6724(d)(2)(M) is amended by 

24 striking ‘‘(h)(2) relating’’ and inserting ‘‘(h)(2) (re25 lating’’. 


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1 (324) Section 6724(d)(2)(DD) is amended by 

2 adding a comma at the end. 

3 (325) Section 6863(a) is amended by striking 

4 ‘‘6852,,’’ and inserting ‘‘6852,’’. 

5 (326) Section 6901(a)(1)(B) is amended by 

6 striking ‘‘Code in’’ and inserting ‘‘Code, in’’. 

7 (327) Section 7275(b)(2) is amended by strik8 ing ‘‘taxes, shall’’ and inserting ‘‘taxes,’’. 

9 (328) Section 7421(b)(2) is amended by strik10 ing ‘‘Code in’’ and inserting ‘‘Code, in’’. 

11 (329)(A) Subsections (e) and (i) of section 

12 7422 and sections 3121(b)(5)(E), 6110(j)(1)(B), 

13 7428(a), and 7430(c)(6) are each amended by strik14 ing ‘‘United States Claims Court’’ and inserting 

15 ‘‘United States Court of Federal Claims’’. 

16 (B) Subsections (a), (b), and (c)(1)(C)(iii) of 

17 section 7428 are each amended by striking ‘‘Claims 

18 Court’’ and inserting ‘‘Court of Federal Claims’’. 

19 (C) The heading of section 4961(c)(1) is 

20 amended by striking ‘‘UNITED STATES CLAIMS

21 COURT’’ and inserting ‘‘UNITED STATES COURT OF

22 FEDERAL CLAIMS’’. 

23 (D) Section 6672(c)(2) is amended by striking 

24 ‘‘Court of Claims’’ and inserting ‘‘Court of Federal 

25 Claims’’. 


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1 (330) The item relating to section 7448 in the 

2 table of sections for part I of subchapter C of chap3 ter 76 is amended to read as follows: 

‘‘Sec. 7448. Annuities to surviving spouses and dependent children of judges 

and special trial judges.’’. 

4 (331) Section 7448(j)(1)(A) is amended by 

5 striking ‘‘Code,),’’ and inserting ‘‘Code),’’. 

6 (332) Section 7448(m) is amended by striking 

7 ‘‘Code,’’ and inserting ‘‘Code),’’. 

8 (333) Section 7454(b) is amended by striking 

9 ‘‘4955),,’’ and inserting ‘‘4955),’’. 

10 (334) Section 7654(d)(1) is amended by strik11 ing ‘‘50 App. U.S.C. 501 et seq.’’ and inserting ‘‘50 

12 U.S.C. 3901 et seq.’’. 

13 (335) Section 7701(a)(36)(B) is amended by 

14 striking ‘‘an ‘tax’’ and inserting ‘‘a ‘tax’’. 

15 (336) Section 7701(e)(5)(B) is amended by 

16 striking ‘‘Reconcilation’’ and inserting ‘‘Reconcili17 ation’’. 

18 (337) Section 7801(a)(2)(B) is amended— 

19 (A) by striking ‘‘this Act’’ and inserting 

20 ‘‘the Homeland Security Act of 2002’’, and 

21 (B) by striking ‘‘effective date of the 

22 Homeland Security Act of 2002’’ and inserting 

23 ‘‘effective date of such Act’’. 


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1 (338) Section 7809(c)(1) is amended by strik2 ing ‘‘Work’’ and inserting ‘‘work’’. 

3 (339) Section 7851(a)(1)(A) is amended by 

4 striking ‘‘, 4’’. 

5 (340) Section 7851(a)(1)(B) is amended by 

6 striking ‘‘Chapters 3 and 5’’ and inserting ‘‘Chapter 

7 3’’. 

8 (341) Section 7871(c)(3)(D)(ii)(II) is amended 

9 by striking ‘‘calender’’ and inserting ‘‘calendar’’. 

10 (342) Section 9003(b)(2) is amended by strik11 ing ‘‘section 9006(d)’’ and inserting ‘‘section 

12 9006(c)’’. 

13 (343) Section 9011(b)(1) is amended by strik14 ing ‘‘contrue’’ and inserting ‘‘construe’’. 

15 (344) Section 9502(d)(2) is amended by strik16 ing ‘‘farms,’’ and inserting ‘‘farms),’’. 

17 (345) Section 9503(c)(5) is amended by strik18 ing ‘‘and before October 1, 2011,’’. 

19 (346) Section 9508(c)(1) is amended by strik20 ing ‘‘the Public’’ and inserting ‘‘Public’’. 

21 (347) Section 9701(a)(4) is amended by strik22 ing ‘‘section 9713A’’ and inserting ‘‘section 9712’’. 

23 (348) Section 9704(d)(2)(B) is amended by 

24 striking ‘‘1232)),’’ and inserting ‘‘1232),’’. 


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1 (349) Section 9704(h) is amended by striking 

2 ‘‘Secretary’’ and inserting ‘‘Commissioner’’. 

3 (350) Section 9705(b)(1) is amended by strik4 ing ‘‘1232(h)’’ and inserting ‘‘1232’’. 

5 (351) Section 9705(b)(2) is amended by strik6 ing ‘‘Acts’’ and inserting ‘‘Act’’. 

7 (352) Section 9711(c)(4)(B) is amended by 

8 striking ‘‘paragraph (4)(C)’’ and inserting ‘‘para9 graph (3)(C)’’. 

10 (353) Section 9712(a)(4)(A) is amended by in11 serting ‘‘section 402 of’’ after ‘‘subsections (h) and 

12 (i) of’’. 

13 (354) Section 9812(a)(3)(B)(i) is amended by 

14 striking the comma at the end and inserting a pe15 riod. 

16 (355) Section 302 of division P of the Consoli17 dated Appropriations Act, 2016 is amended— 

18 (A) in subsection (a), by inserting ‘‘of the 

19 Internal Revenue Code of 1986’’ after ‘‘section 

20 48(a)(5)(C)’’, and 

21 (B) in subsection (b), by inserting ‘‘of such 

22 Code’’ after ‘‘section 48(a)’’. 

23 (356) Section 32103(a) of the Fixing America’s 

24 Surface Transportation Act is amended by striking 

25 ‘‘section 52106’’ and inserting ‘‘section 32102’’. 


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1 (b) GENERAL DEADWOOD-RELATED PROVISIONS.— 

2 (1) Section 25A(c)(1) is amended by striking 

3 ‘‘($5,000 in the case of taxable years beginning be4 fore January 1, 2003)’’. 

5 (2) Section 26(b)(2) is amended by striking 

6 subparagraph (P). 

7 (3) Section 32(l) is amended by striking ‘‘, and 

8 any payment made to such individual (or such 

9 spouse) by an employer under section 3507,’’. 

10 (4)(A) Section 38(c)(5) is amended— 

11 (i) by striking all that precedes subpara12 graph (C) thereof and inserting the following: 

13 ‘‘(5) RULES RELATED TO ELIGIBLE SMALL

14 BUSINESSES.—’’, 

15 (ii) by redesignating subparagraphs (C) 

16 and (D) as subparagraphs (A) and (B), respec17 tively, and 

18 (iii) by amending subparagraph (B) (as so 

19 redesignated) to read as follows: 

20 ‘‘(B) TREATMENT OF PARTNERS AND S

21 CORPORATION SHAREHOLDERS.—For purposes 

22 of paragraph (4)(B)(ii), any credit determined 

23 under section 41 with respect to a partnership 

24 or S corporation shall not be treated as a speci25 fied credit by any partner or shareholder unless 


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1 such partner or shareholder meets the gross re2 ceipts test under subparagraph (A) for the tax3 able year in which such credit is treated as a 

4 current year business credit.’’. 

5 (B) Section 38(c)(2)(A)(ii)(II) is amended by 

6 striking ‘‘the eligible small business credits,’’. 

7 (C) Section 38(c)(4)(A)(ii)(II) is amended by 

8 striking ‘‘the eligible small business credits and’’. 

9 (D) Section 38(c)(4)(B)(ii) is amended by strik10 ing ‘‘(as defined in paragraph (5)(C), after applica11 tion of rules similar to the rules of paragraph 

12 (5)(D))’’ and inserting ‘‘(as defined in paragraph 

13 (5)(A) after application of the rules of paragraph 

14 (5)(B))’’. 

15 (5) Section 56(d)(1)(A)(ii)(I) is amended by in16 serting ‘‘(as in effect before its repeal by the Tax In17 crease Prevention Act of 2014)’’ after ‘‘section 

18 172(b)(1)(H)’’. 

19 (6)(A) Section 139(c)(2) is amended by striking 

20 ‘‘section 165(h)(3)(C)(i)’’ and inserting ‘‘section 

21 165(i)(5)(A)’’. 

22 (B) Section 7508A(a) is amended by striking 

23 ‘‘section 165(h)(3)(C)(i)’’ and inserting ‘‘section 

24 165(i)(5)(A)’’. 


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1 (7) Section 140(a) is amended by striking para2 graph (2) and by redesignating paragraphs (3) 

3 through (6) as paragraphs (2) through (5), respec4 tively. 

5 (8) Section 163(d)(4) is amended by striking 

6 subparagraph (E). 

7 (9) Section 168 is amended by striking sub8 section (n). 

9 (10) Section 172(b)(1)(D)(iv) is amended by 

10 striking ‘‘subsection (h)’’ and inserting ‘‘subsection 

11 (g)’’. 

12 (11) Section 246A(b)(1) is amended by striking 

13 ‘‘without regard to section 243(d)(4)’’. 

14 (12) Section 409 is amended by striking sub15 section (m). 

16 (13) Section 411(a)(3)(F)(i) is amended by 

17 striking ‘‘under section 418D or’’. 

18 (14) Section 413(b)(6) is amended by striking 

19 ‘‘and the last sentence of section 4971(a)’’ in the 

20 last sentence. 

21 (15) Section 415(g) is amended by striking 

22 ‘‘subsection (f)(3)’’ and inserting ‘‘subsection 

23 (f)(2)’’. 

24 (16)(A) Section 419(e)(3)(A) is amended by 

25 striking ‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 


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1 (B) Section 419A(g)(1) is amended by striking 

2 ‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 

3 (C) Section 419A(g)(2) is amended by striking 

4 ‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 

5 (D) Section 505 is amended— 

6 (i) in the heading thereof, by striking 

7 ‘‘PARAGRAPH (9), (17), OR (20)’’ and insert8 ing ‘‘PARAGRAPH (9) OR (17)’’, 

9 (ii) in the heading of subsection (a), by 

10 striking ‘‘PARAGRAPH (9) OR (20) OF SECTION

11 501(c)’’ and inserting ‘‘SECTION 501(c)(9)’’, 

12 (iii) in subsection (a)(1), by striking ‘‘para13 graph (9) or (20) of subsection (c) of section 

14 501’’ and inserting ‘‘section 501(c)(9)’’, and 

15 (iv) in subsection (c)(1), by striking ‘‘para16 graph (9), (17), or (20)’’ and inserting ‘‘para17 graph (9) or (17)’’. 

18 (E) Subparagraphs (A), (C), and (D) of section 

19 512(a)(3) are each amended in the text thereof by 

20 striking ‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 

21 (F) Subparagraphs (B)(ii) and (E) of section 

22 512(a)(3) are each amended in the text thereof by 

23 striking ‘‘, (17), or (20)’’ and inserting ‘‘or (17)’’. 


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1 (G) The heading of section 512(a)(3) is amend2 ed by striking ‘‘(17), OR (20)’’ and inserting ‘‘OR

3 (17)’’. 

4 (H) The heading of section 512(a)(3)(E) is 

5 amended by striking ‘‘, (17), OR (20)’’ and inserting 

6 ‘‘OR (17)’’. 

7 (I) The item relating to section 505 in the table 

8 of sections for part I of subchapter F of chapter 1 

9 is amended to read as follows: 

‘‘Sec. 505. Additional requirements for organizations described in paragraph 

(9) or (17) of section 501(c).’’. 

10 (17) Section 501(p)(4) is amended by striking 

11 ‘‘, 556(b)(2)’’. 

12 (18) Section 530(b)(3) is amended— 

13 (A) by striking ‘‘(as defined in section 

14 170(e)(6)(F)(i))’’ in subparagraph (A)(iii), and 

15 (B) by adding at the end the following new 

16 subparagraph: 

17 ‘‘(C) COMPUTER TECHNOLOGY OR EQUIP18 MENT.—The term ‘computer technology or 

19 equipment’ means computer software (as de20 fined by section 197(e)(3)(B)), computer or pe21 ripheral equipment (as defined by section 

22 168(i)(2)(B)), and fiber optic cable related to 

23 computer use.’’. 


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1 (19) Section 593(b)(2)(D)(iv) is amended by 

2 striking ‘‘(determined without regard to section 

3 596)’’. 

4 (20) Section 597(c)(1) is amended by striking 

5 ‘‘or section 21A of the Federal Home Loan Bank 

6 Act’’. 

7 (21) Section 664(g)(3)(E) is amended by strik8 ing ‘‘limitations under sections 415(c) and (e)’’ and 

9 inserting ‘‘limitation under section 415(c)’’. 

10 (22) Section 810(b) is amended by striking 

11 paragraph (4). 

12 (23) Section 856(m) is amended by striking 

13 paragraph (6). 

14 (24) Section 871(a)(3) is amended by striking 

15 the last sentence thereof. 

16 (25) Section 992(d) is amended by striking 

17 paragraph (6) and by redesignating paragraph (7) 

18 as paragraph (6). 

19 (26) Section 1245(a)(3)(C) is amended by 

20 striking ‘‘, 185’’. 

21 (27)(A) Section 1252(a)(1) is amended by 

22 striking ‘‘during a taxable year beginning’’. 

23 (B) Section 1252(a)(1)(A) is amended— 

24 (i) by striking ‘‘sections’’ and inserting 

25 ‘‘section’’, and 


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1 (ii) by striking ‘‘and 182’’ and all that fol2 lows through ‘‘for expenditures’’ and inserting 

3 ‘‘for expenditures’’. 

4 (C) Section 1252(a)(2) is amended— 

5 (i) by striking ‘‘sections’’ and inserting 

6 ‘‘section’’, and 

7 (ii) by striking ‘‘or 182’’ and all that fol8 lows and inserting a period. 

9 (28) Section 3111 is amended by striking sub10 section (d). 

11 (29) Section 3127(b)(3) is amended by striking 

12 ‘‘or 222(b)’’. 

13 (30) Section 3221 is amended by striking sub14 section (c) and by redesignating subsection (d) as 

15 subsection (c). 

16 (31) Section 4481(d) is amended to read as fol17 lows: 

18 ‘‘(d) ONE TAX LIABILITY PER PERIOD.—To the ex19 tent that the tax imposed by this section is paid with re20 spect to any highway motor vehicle for any taxable period, 

21 no further tax shall be imposed by this section for such 

22 taxable period with respect to such vehicle.’’. 

23 (32) Section 4971(d) is amended by striking 

24 the last sentence. 


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1 (33) Section 6050G(a)(2) is amended by strik2 ing ‘‘(to the extent not previously taken into account 

3 under section 72(d)(1))’’. 

4 (34) Section 6215(b) is amended by striking 

5 paragraph (5) and by redesignating paragraphs (6) 

6 and (7) as paragraphs (5) and (6), respectively. 

7 (35) Section 6601(b) is amended by striking 

8 paragraph (2) and by redesignating paragraphs (3) 

9 through (5) as paragraphs (2) through (4), respec10 tively. 

11 (36) Section 6654(d)(1)(C)(i) is amended by 

12 striking ‘‘by substituting’’ and all that follows and 

13 inserting ‘‘by substituting ‘110 percent’ for ‘100 

14 percent’.’’. 

15 (37) Section 6654(d)(1) is amended by striking 

16 subparagraph (D). 

17 (38) Part II of subchapter C of chapter 75 is 

18 amended by striking section 7326 (and by striking 

19 the item relating to such section in the table of sec20 tions for such part). 

21 (39) Section 7448(a)(5) is amended by striking 

22 ‘‘, whether or not performing judicial duties under 

23 section 7443B’’. 

24 (40) Section 7448(a)(6) is amended by striking 

25 ‘‘, and compensation received under section 7443B’’. 


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1 (41) Section 7448(d) is amended by striking 

2 ‘‘at 4 percent per annum to December 31, 1947, 

3 and 3 percent per annum thereafter’’ and inserting 

4 ‘‘at 3 percent per annum’’. 

5 (42) Section 7701(a)(19)(A) is amended by 

6 striking ‘‘either (i)’’ and all that follows through 

7 ‘‘(ii)’’. 

8 (43) Section 7701(a)(32)(A) is amended to 

9 read as follows: 

10 ‘‘(A) is subject by law to supervision and 

11 examination by State or Federal authority hav12 ing supervision over such institutions, and’’. 

13 (c) REPEAL OF CERTAIN OBSOLETE BOND PROVI14 SIONS.— 

15 (1) CERTAIN RULES WITH RESPECT TO BONDS

16 ISSUED BEFORE JULY 2, 1982.— 

17 (A) Section 1271 is amended— 

18 (i) by striking subsection (c) and by 

19 redesignating subsection (d) as subsection 

20 (c), and 

21 (ii) by striking ‘‘(and paragraph (2) of 

22 subsection (c))’’ in subsection (a)(2)(B). 

23 (B) Section 1272 is amended by striking 

24 subsection (b) and by redesignating subsections 


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1 (c) and (d) as subsections (b) and (c), respec2 tively. 

3 (C) Section 163(e)(1) is amended by strik4 ing ‘‘In the case of any debt instrument issued 

5 after July 1, 1982, the portion of the original 

6 issue discount with respect to such debt instru7 ment which is’’ and inserting ‘‘The portion of 

8 the original issue discount with respect to any 

9 debt instrument which is’’. 

10 (D) Section 163(j)(2)(C)(ii) is amended by 

11 striking ‘‘or (b)(4)’’. 

12 (E) Section 1271(a)(2)(A)(ii) is amended 

13 by striking ‘‘subsection (a)(7) or (b)(4) of sec14 tion 1272’’ and inserting ‘‘section 1272(a)(7)’’. 

15 (F) Section 1271(b)(1) is amended to read 

16 as follows: 

17 ‘‘(1) IN GENERAL.—This section shall not apply 

18 to any obligation issued by a natural person before 

19 June 9, 1997.’’. 

20 (G) Section 1272(a) is amended— 

21 (i) by striking ‘‘ON DEBT INSTRU22 MENTS ISSUED AFTER JULY 1, 1982,’’ in 

23 the heading, and 

24 (ii) by striking ‘‘issued after July 1, 

25 1982’’ in paragraph (1). 


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1 (H) Section 1278(a)(4)(B) is amended by 

2 striking ‘‘or (b)(4)’’. 

3 (I) The amendments made by this para4 graph shall apply to debt instruments issued on 

5 or after July 2, 1982. 

6 (2) CERTAIN RULES WITH RESPECT TO

7 STRIPPED BONDS PURCHASED BEFORE JULY 2, 

8 1982.— 

9 (A) Section 1286 is amended by striking 

10 subsection (c). 

11 (B) Subsections (a) and (b) of section 

12 1286 are each amended by striking ‘‘after July 

13 1, 1982,’’. 

14 (C) Section 1286(e)(5) is amended by 

15 striking the last sentence. 

16 (D) The amendments made by this para17 graph shall apply to bonds purchased on or 

18 after July 2, 1982. 

19 (3) CERTAIN RULES WITH RESPECT TO OBLIGA20 TIONS ISSUED BEFORE MARCH 2, 1984.— 

21 (A) Section 1272(a)(2) is amended by 

22 striking subparagraph (D) and by redesignating 

23 subparagraph (E) as subparagraph (D). 

24 (B) Section 163(e)(4) is amended to read 

25 as follows: 


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1 ‘‘(4) EXCEPTION.—This subsection shall not 

2 apply to any debt instrument described in section 

3 1272(a)(2)(D) (relating to loans between natural 

4 persons).’’. 

5 (C) The amendments made by this para6 graph shall apply to obligations issued on or 

7 after March 2, 1984. 

8 (d) DEADWOOD PROVISIONS INVOLVING REPEAL OF

9 ONE OR MORE SECTIONS.— 

10 (1) ENERGY EFFICIENT APPLIANCE CREDIT.— 

11 (A) IN GENERAL.—Subpart D of part IV 

12 of subchapter A of chapter 1 is amended by 

13 striking section 45M (and by striking the item 

14 relating to such section in the table of sections 

15 for such subpart). 

16 (B) CONFORMING AMENDMENT.—Section 

17 38(b), as amended by the preceding provisions 

18 of this Act, is amended by striking paragraph 

19 (24) and by redesignating paragraphs (25) 

20 through (36) as paragraphs (24) through (35), 

21 respectively. 

22 (2) QUALIFYING THERAPEUTIC DISCOVERY

23 PROJECT CREDIT.— 

24 (A) IN GENERAL.—Subpart E of part IV 

25 of subchapter A of chapter 1 is amended by 


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1 striking section 48D (and by striking the item 

2 relating to such section in the table of sections 

3 for such subpart). 

4 (B) CONFORMING AMENDMENTS.— 

5 (i) Section 49(a)(1)(C) is amended by 

6 adding ‘‘and’’ at the end of clause (iv), by 

7 striking ‘‘, and’’ at the end of clause (v) 

8 and inserting a period, and by striking 

9 clause (vi). 

10 (ii) Section 50(a)(2)(E) is amended 

11 by striking ‘‘48C(b)(2), or 48D(b)(4)’’ and 

12 inserting ‘‘or 48C(b)(2)’’. 

13 (iii) Section 280C is amended by 

14 striking the subsection (g) which relates to 

15 the qualifying therapeutic discovery project 

16 credit. 

17 (C) SAVINGS PROVISION.—In the case of 

18 the repeal of section 48D(e)(1) of the Internal 

19 Revenue Code of 1986, the amendments made 

20 by this paragraph shall not apply to expendi21 tures made in taxable years beginning before 

22 January 1, 2011. 

23 (3) DC ZONE PROVISIONS.— 

24 (A) IN GENERAL.—Chapter 1 is amended 

25 by striking subchapter W (and by striking the 


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1 item relating to such subchapter in the table of 

2 subchapters for such chapter). 

3 (B) CONFORMING AMENDMENTS.— 

4 (i) Section 23(c)(1) is amended by 

5 striking ‘‘sections 25D and 1400C’’ and 

6 inserting ‘‘section 25D’’. 

7 (ii) Section 25(e)(1)(C) is amended by 

8 striking ‘‘sections 23, 25D, and 1400C’’ 

9 and inserting ‘‘sections 23 and 25D’’. 

10 (iii) Section 45D(h) is amended by 

11 striking ‘‘sections 1202, 1400B, and 

12 1400F’’ and inserting ‘‘section 1202’’. 

13 (iv) Section 1016(a) is amended by 

14 striking paragraph (27). 

15 (v) Section 1202(a)(2)(B) is amended 

16 by inserting ‘‘(as in effect before its re17 peal)’’ after ‘‘1400B(b)’’. 

18 (vi) Section 1223(13) is amended by 

19 striking ‘‘sections 1202(a)(2), 

20 1202(c)(2)(A), 1400B(b), and 1400F(b)’’ 

21 and inserting ‘‘subsections (a)(2) and 

22 (c)(2)(A) of section 1202’’. 

23 (vii) Section 1397B(b)(1) is amended 

24 by striking subparagraph (B). 


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1 (C) SAVINGS PROVISIONS.—The amend2 ments made by this paragraph shall not apply 

3 to— 

4 (i) in the case of the repeal of section 

5 1400A of the Internal Revenue Code of 

6 1986, obligations described in section 1394 

7 of such Code (as in effect before its repeal) 

8 which were issued before January 1, 2012, 

9 (ii) in the case of the repeal of section 

10 1400B of such Code, DC Zone assets (as 

11 defined in such section, as in effect before 

12 its repeal) which were acquired by the tax13 payer before January 1, 2012, and 

14 (iii) in the case of the repeal of sec15 tion 1400C of such Code, principal resi16 dences acquired before January 1, 2012. 

17 (4) RENEWAL COMMUNITY PROVISIONS.— 

18 (A) IN GENERAL.—Chapter 1 is amended 

19 by striking subchapter X (and by striking the 

20 item relating to such subchapter in the table of 

21 subchapters for such chapter). 

22 (B) CONFORMING AMENDMENTS.— 

23 (i)(I) Section 469(i)(3) is amended by 

24 striking subparagraph (C) and by redesig25 nating subparagraphs (D), (E), and (F) as 


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1 subparagraphs (C), (D), and (E), respec2 tively. 

3 (II) Section 469(i)(3)(D), as so redes4 ignated, is amended to read as follows: 

5 ‘‘(D) ORDERING RULE.—Paragraph (1) 

6 shall be applied for any taxable year— 

7 ‘‘(i) first, to the passive activity loss, 

8 ‘‘(ii) second, to the portion of the pas9 sive activity credit to which subparagraph 

10 (B) and (C) does not apply, 

11 ‘‘(iii) third, to the portion of such 

12 credit to which subparagraph (B) applies, 

13 and 

14 ‘‘(iv) then, to the portion of such cred15 it to which subparagraph (C) applies.’’. 

16 (III) Section 469(i)(6)(B) is amend17 ed— 

18 (aa) by striking ‘‘, REHABILITA19 TION CREDIT, OR COMMERCIAL REVI20 TALIZATION DEDUCTION’’ in the head21 ing and inserting ‘‘OR REHABILITA22 TION CREDIT’’, 

23 (bb) by adding ‘‘or’’ at the end of 

24 clause (i), 


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1 (cc) by striking ‘‘, or’’ at the end 

2 of clause (ii) and inserting a comma, 

3 and 

4 (dd) by striking clause (iii). 

5 (IV) Section 1397B(b)(1), as amend6 ed by the preceding provisions of this Act, 

7 is amended by adding at the end the fol8 lowing new subparagraph: 

9 ‘‘(B) REFERENCES.—Any reference in this 

10 paragraph to section 1400F shall be treated as 

11 reference to such section before its repeal.’’. 

12 (C) SAVINGS PROVISIONS.—The amend13 ments made by this paragraph shall not apply 

14 to— 

15 (i) in the case of the repeal of section 

16 1400F of the Internal Revenue Code of 

17 1986, qualified community assets (as de18 fined in such section, as in effect before its 

19 repeal) which were acquired by the tax20 payer before January 1, 2010, 

21 (ii) in the case of the repeal section 

22 1400H of such Code, wages paid or in23 curred before January 1, 2010, 

24 (iii) in the case of the repeal of sec25 tion 1400I of such Code, qualified revitalVerDate Sep 11 2014 00:19 Dec 07, 2016 Jkt 069200 PO 00000 Frm 00117 Fmt 6652 Sfmt 6201 E:\BILLS\H6439.IH H6439

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1 ization buildings (as defined in such sec2 tion, as in effect before its repeal) which 

3 were placed in service before January 1, 

4 2010, and 

5 (iv) in the case of the repeal of section 

6 1400J of such Code, property acquired be7 fore January 1, 2010. 

8 (5) SHORT-TERM REGIONAL BENEFITS.— 

9 (A) IN GENERAL.—Chapter 1 is amended 

10 by striking subchapter Y (and by striking the 

11 item relating to such subchapter in the table of 

12 subchapters for such chapter). 

13 (B) CONFORMING AMENDMENTS.— 

14 (i) Section 38(b), as amended by the 

15 preceding provisions of this Act, is amend16 ed by striking paragraphs (26), (27), (28), 

17 and (29) and by redesignating paragraphs 

18 (30) through (35) as paragraphs (26) 

19 through (31), respectively. 

20 (ii) Section 38(c)(2)(A)(ii)(II), as 

21 amended by the preceding provisions of 

22 this Act, is amended by striking ‘‘, the 

23 New York Liberty Zone business employee 

24 credit,’’. 


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1 (iii) Section 38(c) is amended by 

2 striking paragraph (3). 

3 (iv) Section 54(c)(2) is amended by 

4 striking ‘‘section 1400N(l),’’. 

5 (v) Section 280C(a), as amended by 

6 the preceding provisions of this Act, is 

7 amended by striking ‘‘1396(a), 1400P(b), 

8 and 1400R’’ and inserting ‘‘and 1396(a)’’. 

9 (vi) Section 6033(b)(14) is amended 

10 by striking ‘‘including the amount and use 

11 of qualified contributions to which section 

12 1400S(a) applies,’’. 

13 (vii) Section 6049(d)(8)(A) is amend14 ed— 

15 (I) by striking ‘‘or 1400N(l)(6)’’, 

16 and 

17 (II) by striking ‘‘or 

18 1400N(l)(2)(D), as the case may be’’. 

19 (C) SAVINGS PROVISIONS.—The amend20 ments made by this paragraph shall not apply 

21 to— 

22 (i) in the case of the repeal of section 

23 1400L(a) of the Internal Revenue Code of 

24 1986, qualified wages (as defined in such 

25 section, as in effect before its repeal) which 


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1 were paid or incurred before January 1, 

2 2004, 

3 (ii) in the case of the repeal of sub4 sections (b) and (f) of section 1400L of 

5 such Code, qualified New York Liberty 

6 Zone property (as defined in section 

7 1400L(b) of such Code, as in effect before 

8 its repeal) placed in service before January 

9 1, 2010, 

10 (iii) in the case of the repeal of sec11 tion 1400L(c) of such Code, qualified New 

12 York Liberty Zone leasehold improvement 

13 property (as defined in such section, as in 

14 effect before its repeal) placed in service 

15 before January 1, 2007, 

16 (iv) in the case of the repeal of section 

17 1400L(d) of such Code, qualified New 

18 York Liberty bonds (as defined in such 

19 section, as in effect before its repeal) 

20 issued before January 1, 2014, 

21 (v) in the case of the repeal of section 

22 1400L(e) of such Code, advanced 

23 refundings before January 1, 2006, 

24 (vi) in the case of the repeal of section 

25 1400L(g) of such Code, property which is 


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1 compulsorily or involuntarily converted as 

2 a result of the terrorist attacks on Sep3 tember 11, 2001, 

4 (vii) in the case of the repeal of sec5 tion 1400N(a) of such Code, obligations 

6 issued before January 1, 2012, 

7 (viii) in the case of the repeal of sec8 tion 1400N(b) of such Code, advanced 

9 refundings before January 1, 2011, 

10 (ix) in the case of the repeal of section 

11 1400N(d) of such Code, property placed in 

12 service before January 1, 2012, 

13 (x) in the case of the repeal of section 

14 1400N(e) of such Code, property placed in 

15 service before January 1, 2009, 

16 (xi) in the case of the repeal of sub17 sections (f) and (g) of section 1400N of 

18 such Code, amounts paid or incurred be19 fore January 1, 2008, 

20 (xii) in the case of the repeal of sec21 tion 1400N(h) of such Code, amounts paid 

22 or incurred before January 1, 2012, 

23 (xiii) in the case of the repeal of sec24 tion 1400N(k)(1)(B) of such Code, losses 


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1 arising in taxable years beginning before 

2 January 1, 2008, 

3 (xiv) in the case of the repeal of sec4 tion 1400N(l) of such Code, bonds issued 

5 before January 1, 2007, 

6 (xv) in the case of the repeal of sec7 tion 1400Q(a) of such Code, distributions 

8 before January 1, 2007, 

9 (xvi) in the case of the repeal of sec10 tion 1400Q(b) of such Code, contributions 

11 before March 1, 2006, 

12 (xvii) in the case of the repeal of sec13 tion 1400Q(c) of such Code, loans made 

14 before January 1, 2007, 

15 (xviii) in the case of the repeal of sec16 tion 1400R of such Code, wages paid or 

17 incurred before January 1, 2006, 

18 (xix) in the case of the repeal of sec19 tion 1400S(a) of such Code, contributions 

20 paid before January 1, 2006, 

21 (xx) in the case of the repeal of sec22 tion 1400T of such Code, financing pro23 vided before January 1, 2011, and 

24 (xxi) in the case of the repeal of part 

25 III of subchapter Y of chapter 1 of such 


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1 Code, obligations issued before January 1, 

2 2011. 

3 (6) PROVISIONS RELATED TO COBRA PREMIUM

4 ASSISTANCE.— 

5 (A) IN GENERAL.—Subchapter B of chap6 ter 65 is amended by striking section 6432 

7 (and by striking the item relating to such sec8 tion in the table of sections for such sub9 chapter). 

10 (B) NOTIFICATION REQUIREMENT.—Part I 

11 of subchapter B of chapter 68 is amended by 

12 striking section 6720C (and by striking the 

13 item relating to such section in the table of sec14 tions for such part). 

15 (C) EXCLUSION FROM GROSS INCOME.— 

16 Part III of subchapter B of chapter 1 is amend17 ed by striking section 139C (and by striking the 

18 item relating to such section in the table of sec19 tions for such part). 

20 (e) GENERAL SAVINGS PROVISION WITH RESPECT

21 TO DEADWOOD PROVISIONS.—If— 

22 (1) any provision amended or repealed by the 

23 amendments made by subsection (b) or (d) applied 

24 to— 


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1 (A) any transaction occurring before the 

2 date of the enactment of this Act, 

3 (B) any property acquired before such date 

4 of enactment, or 

5 (C) any item of income, loss, deduction, or 

6 credit taken into account before such date of 

7 enactment, and 

8 (2) the treatment of such transaction, property, 

9 or item under such provision would (without regard 

10 to the amendments or repeals made by such sub11 section) affect the liability for tax for periods ending 

12 after such date of enactment, 

13 nothing in the amendments or repeals made by this section 

14 shall be construed to affect the treatment of such trans15 action, property, or item for purposes of determining li16 ability for tax for periods ending after such date of enact17 ment. 

Æ 


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