College for All Act

To amend the Higher Education Act to improve higher education programs, and for other purposes. 1. Short title This Act may be cited as the College for All Act I Federal-State Partnership to Eliminate Tuition 101. Grant program to eliminate tuition and required fees at public institutions of higher education (a) Program authorized (1) Grants authorized From amounts appropriated under subsection (f), the Secretary of Education (referred to in this section as the Secretary (2) Matching funds requirement Each State that receives a grant under this section shall provide matching funds for a fiscal year in an amount that is equal to one half the amount received under this section for the fiscal year toward the cost of reducing the cost of attendance at public institutions of higher education in the State. (b) Determination of allotment (1) Initial allotment For fiscal year 2016, the Secretary shall allot to each eligible State that submits an application under this section an amount that is equal to 67 percent of the total revenue received by the State’s public system of higher education in the form of tuition and related fees for fiscal year 2016. For each of fiscal years 2017 through 2019, the Secretary shall allot to each eligible State that submits an application under this section— (A) an amount equal to the allotment the State received for fiscal year 2016, plus (B) if the State provides additional funds toward the cost of reducing the cost of attendance at public institutions of higher education in the State for any of such fiscal years that is more than the matching funds requirement under subsection (a)(2), an amount equal to such additional funding provided by the State, which amount provided by the Secretary may be used for the activities described in subsection (e)(2). (2) Subsequent allotments Beginning in fiscal year 2020, the Secretary shall determine the median allotment per full-time equivalent student made to all eligible States under this section for fiscal year 2019 and incrementally reduce allotments made to States under this section such that by fiscal year 2025, no State receives an allotment under this section per full-time equivalent student that exceeds the median allotment per full-time equivalent student made under this section for fiscal year 2019. (c) State eligibility requirements In order to be eligible to receive an allotment under this section for a fiscal year, a State shall— (1) ensure that public institutions of higher education in the State maintain per-pupil expenditures on instruction at levels that meet or exceed the expenditures for the previous fiscal year; (2) ensure that tuition and required fees for in-State undergraduate students in the State’s public higher education system are eliminated; (3) maintain State operating expenditures for public institutions of higher education, excluding the amount of funds provided for a fiscal year under this section, at a level that meets or exceeds the level of such support for fiscal year 2015; (4) maintain State expenditures on need-based financial aid programs for enrollment in public institutions of higher education in the State at a level that meets or exceeds the level of such support for fiscal year 2015; (5) ensure public institutions of higher education in the State maintain funding for institutional need-based student financial aid in an amount that is equal to or exceeds the level of such funding for the previous fiscal year; (6) provide an assurance that not later than 5 years after the date of enactment of this Act, not less than 75 percent of instruction at public institutions of higher education in the State is provided by tenured or tenure-track faculty; (7) require that public institutions of higher education in the State provide, for each student enrolled at the institution who receives for the maximum Federal Pell Grant award under subpart 1 of part A of title IV of the Higher Education Act of 1965 ( 20 U.S.C. 1070a et seq. (A) the cost of attendance at such institution (as determined in accordance with section 472 of the Higher Education Act of 1965 ( 20 U.S.C. 1087ll (B) the sum of— (i) the amount of the maximum Federal Pell Grant award; and (ii) the student’s expected family contribution; and (8) ensure that public institutions of higher education in the State not adopt policies to reduce enrollment. (d) Submission and contents of application For each fiscal year for which a State desires a grant under this section, the State agency with jurisdiction over higher education, or another agency designated by the Governor or chief executive of the State to administer the program under this section, shall submit an application to the Secretary at such time, in such manner, and containing such information as the Secretary may require. (e) Use of funds (1) In general A State that receives a grant under this section shall use the grant funds and the matching funds required under this section to eliminate tuition and required fees for students at public institutions of higher education in the State. (2) Additional funding Once tuition and required fees have been eliminated pursuant to paragraph (1), a State that receives a grant under this section shall use any remaining grant funds and matching funds required under this section to increase the quality of instruction and student support services by carrying out the following: (A) Expanding academic course offerings to students. (B) Increasing the number and percentage of full-time instructional faculty. (C) Providing all faculty with professional supports to help students succeed, such as professional development opportunities, office space, and shared governance in the institution. (D) Compensating part-time faculty for work done outside of the classroom relating to instruction, such as holding office hours. (E) Strengthening and ensuring all students have access to student support services such as academic advising, counseling, and tutoring. (F) Any other additional activities that improve instructional quality and academic outcomes for students as approved by the Secretary through a peer review process. (3) Prohibition A State that receives a grant under this section may not use grant funds or matching funds required under this section— (A) for the construction of non-academic facilities, such as student centers or stadiums; (B) for merit-based student financial aid; or (C) to pay the salaries or benefits of school administrators. (f) Authorization and appropriation There are authorized to be appropriated to carry out this section $47,000,000,000 for fiscal year 2016, and such sums as may be necessary for each of the fiscal years 2017 through 2025. II Student loans 201. Restoration of certain interest rate provisions Section 455(b) of the Higher Education Act of 1965 ( 20 U.S.C. 1087e(b) (1) in paragraph (8)— (A) in the heading, by striking on or after July 1, 2013 on or after July 1, 2013, and before July 1, 2015 (B) by striking on or after July 1, 2013 on or after July 1, 2013, and before July 1, 2015 (2) by redesignating paragraphs (9) and (10) as paragraphs (10) and (11), respectively; and (3) by inserting the following after paragraph (8): (9) Interest rate provisions for new loans on or after July 1, 2015 (A) Rates for FDSL and FDUSL Notwithstanding the preceding paragraphs of this subsection, for Federal Direct Stafford Loans and Federal Direct Unsubsidized Stafford Loans for which the first disbursement is made on or after July 1, 2015, the applicable rate of interest shall, during any 12-month period beginning on July 1 and ending on June 30, be determined on the preceding June 1 and be equal to— (i) the bond equivalent rate of 91-day Treasury bills auctioned at the final auction held prior to such June 1; plus (ii) 2.3 percent, except that such rate shall not exceed 8.25 percent. (B) In school and grace period rules Notwithstanding the preceding paragraphs of this subsection, with respect to any Federal Direct Stafford Loan or Federal Direct Unsubsidized Stafford Loan for which the first disbursement is made on or after July 1, 2015, the applicable rate of interest for interest which accrues— (i) prior to the beginning of the repayment period of the loan; or (ii) during the period in which principal need not be paid (whether or not such principal is in fact paid) by reason of a provision described in subsection (f), shall be determined under subparagraph (A) by substituting 1.7 percent 2.3 percent (C) PLUS loans Notwithstanding the preceding paragraphs of this subsection, with respect to Federal Direct PLUS Loan for which the first disbursement is made on or after July 1, 2015, the applicable rate of interest shall be determined under subparagraph (A)— (i) by substituting 3.1 percent 2.3 percent (ii) by substituting 9.0 percent 8.25 percent (D) Consolidation loans Notwithstanding the preceding paragraphs of this subsection, any Federal Direct Consolidation loan for which the application is received on or after July 1, 2015, shall bear interest at an annual rate on the unpaid principal balance of the loan that is equal to the lesser of— (i) the weighted average of the interest rates on the loans consolidated, rounded to the nearest higher 1/8 (ii) 8.25 percent. . 202. Borrower modification of interest rates under title IV Section 455(b) of the Higher Education Act of 1965 ( 20 U.S.C. 1087e(b) (12) Borrower modification of interest rate (A) Modification Notwithstanding any other provision of law, the borrower of a Federal Stafford Loan under section 428, a Federal Direct Stafford Loan, a Federal Unsubsidized Stafford Loan under section 428H, a Federal Direct Unsubsidized Stafford Loan, a Federal PLUS Loan under section 428B, a Federal Direct PLUS Loan, a Federal Consolidation Loan under section 428C, or a Federal Direct Consolidation Loan may elect to modify the interest rate of the loan to be equal to— (i) in the case of a Federal Direct Stafford Loan, a Federal Direct Unsubsidized Stafford Loan, a Federal Direct PLUS Loan, or a Federal Direct Consolidation Loan, the interest rate that would be applicable to such loan if such loan were first disbursed (or in the case of a Federal Direct Consolidation Loan, first applied for) on the date on which such borrower elects to modify the interest rate of such loan; and (ii) in the case of a Federal Stafford Loan, a Federal Unsubsidized Stafford Loan, a Federal PLUS Loan, or a Federal Consolidation Loan, the weighted average of the interest rates applicable to loans under part B on the date the loan was first disbursed (or in the case of a Federal Consolidation Loan, first applied for). (B) Fixed rate Except as provided in subparagraph (C), an interest rate elected under subparagraph (A) for a loan shall be fixed for the life of the loan. (C) Continuing authority to modify A borrower may elect to modify the interest rate of a loan in accordance with subparagraph (A) at any time during the life of the loan. . III Federal Work-Study Programs 301. Authorization of appropriations Section 441(b) of the Higher Education Act of 1965 ( 42 U.S.C. 2751(b) (b) Authorization of appropriations There are authorized to be appropriated to carry out this part— (1) $975,000,000 for fiscal year 2016; (2) $1,500,000,000 for fiscal year 2017; (3) $2,000,000,000 for fiscal year 2018; (4) $2,500,000,000 for fiscal year 2019; and (5) $3,000,000,000 for fiscal year 2020. . 302. Federal Work-Study allocation of funds Section 442 of the Higher Education Act of 1965 ( 42 U.S.C. 2752 (1) by striking subsection (a) and inserting the following: (a) Revision to the federal work study allocation The Secretary shall allocate funds under this section solely on the basis of the self-help need determination described under subsection (c). ; (2) in subsection (c)— (A) in paragraph (2), by striking To determine the self-help need of an institution's eligible undergraduate students, Until such time as the Secretary establishes a revised method to determine the self-help need of an institution's eligible undergraduate students, in accordance with paragraph (5), (B) in paragraph (3), by striking To determine the self-help need of an institution's eligible graduate and professional students, Until such time as the Secretary establishes a revised method to determine the self-help need of an institution's eligible graduate and professional students, in accordance with paragraph (5), (C) by adding at the end the following: (5) Not later than 1 year after the date of enactment of the College for All Act ; and (3) by adding at the end the following: (f) Funds To expand job location development programs Notwithstanding any other provision of this part, to promote career readiness and improve the employment skills of Federal Pell Grant-eligible students, the Secretary is authorized to enter into agreements with eligible institutions under which such institution may not use more than 20 percent or $150,000 of its allotment under this section, whichever amount is less, to expand job location development programs, which can be coordinated with State and local workforce development boards. . IV Offering Necessary Eligibility for Timely Institutional Matriculation and Enrollment 401. FAFSA pilot program Part G of title IV of the Higher Education Act of 1965 ( 20 U.S.C. 1088 et seq. 483A. FAFSA pilot program (a) Purposes The purposes of this section are— (1) to streamline the annual process by which students apply for Federal financial assistance; (2) to reduce the need for students to re-apply for such assistance each year; (3) to lower the cost of student borrowing by maintaining important student loan protections, such as the in-school interest subsidy; (4) to strengthen the middle class and reduce income inequality by targeting financial aid to low- and middle-income students; and (5) to ensure that the financial aid application uses income data from prior tax years readily available to students and families to facilitate the widespread and increased use of automated processes, such as at the IRS-Data Retrieval Tool (IRS–DRT), with the goal of reducing errors and easing the time and rigor of the application process. (b) Pilot program authorized The Secretary is authorized to establish a pilot program and select 5 eligible States— (1) in which a student who attends an institution of higher education in the eligible State may submit a single Free Application for Federal Student Aid, as described in section 483 and modified under subsection (d) (referred to in this section as the FAFSA (2) that shall each receive a grant in accordance with subsection (e). (c) Eligible States The Secretary shall select 5 eligible States that are determined by the Secretary to have a strong record of increasing college access and affordability, especially for low-income students, to participate in the pilot program described in subsection (b). The selection of eligible States shall be based on the extent to which the State has— (1) invested, and continues to invest, significantly in public higher education, resulting in a comparatively lower net price for low-income students; (2) allocated State financial aid primarily on the basis of need; and (3) agreed, as a condition of the State's application for the pilot program under this section, to provide all in-State students (as determined by the State) with an offer for State financial aid that— (A) is valid for not less than 2 years and not more than 4 years, as determined by the State; and (B) shall be subject to change only upon certain conditions, such as significant changes in a student's financial circumstances. (d) Single FAFSA submission The Secretary shall implement, in consultation with the 5 selected eligible States, a pilot program to streamline the process of application to determine the need and eligibility of a student for financial assistance under this title that incorporates the following: (1) An option for students that are enrolled in an institution of higher education in a selected eligible State to submit a single FAFSA at the beginning of the student's postsecondary degree program and receive a determination of financial assistance under this title that shall, on a contingent basis, be valid for not less than 2 years and not more than 4 years, as determined by the State. (2) The determination of financial assistance under paragraph (1) shall be made in accordance with part F, except that relevant calculations shall be made using a multi-year average, of 2 or 3 years, from the most recent tax years for which data are available. A student may use previously submitted student and parent taxpayer data to prepopulate the electronic version of the FAFSA, as described in section 483(f). (3) As a condition of the continued receipt of financial assistance under this section, the Secretary may require a student who submits the single FAFSA to respond to a short number of questions (which may be determined by the Secretary), on an annual basis, to determine if there is a change in the financial status of the student (such as whether the student or the student's parent has experienced a substantial increase in annual income) in order to ensure that the student continues to receive the appropriate amount of financial assistance under this title. (4) Notwithstanding paragraph (1), a requirement that students who experience significant changes in their financial circumstances, as determined by the Secretary, will be required to resubmit the FAFSA in order to receive a new determination of financial assistance under this title. (5) An income verification process— (A) which the Secretary, through the establishment of a memorandum of understanding with the Secretary of the Treasury, will develop to share the income tax data of a random sample of students who have received Federal assistance under this title, including Federal Pell Grants under section 401 and loans made under part D; (B) to ensure that students who have not resubmitted a FAFSA in accordance with paragraph (3) did not have a significant change in financial circumstances that would have required them to do so; (C) that shall be carried out in a way so as to ensure that no personally identifiable information is made public through the income verification process; and (D) that will be carried out only with the consent of students, whose consent will be requested as part of the annual response required under paragraph (3). (6) An option for students to request professional judgment or resubmit their FAFSA each year, to receive a new determination of eligibility for financial assistance under this title. (e) Grant amount Each eligible State selected under this section shall receive a grant to increase public awareness of, and promote the use of, the single FAFSA that may be submitted under the pilot program to be used as the application to determine the need and eligibility of the student for financial assistance under this title during the official length of the student's proposed postsecondary degree program. (f) Supplement not supplant Grants provided under this section shall be used to supplement, and not supplant, State funds that are used to improve college access and affordability. (g) Evaluation Not later than 3 years after the date of enactment of the College for All Act . 402. Prior, prior year Section 480(a)(1) of the Higher Education Act of 1965 ( 20 U.S.C. 1087vv(a)(1) (B) Notwithstanding section 478(a) and beginning not later than 180 days after the date of enactment of the College for All Act . V Offset 501. Short title This title may be cited as the Inclusive Prosperity Act of 2015 502. Transaction tax (a) In general Chapter 36 C Tax on Trading Transactions Sec. 4475. Tax on trading transactions. 4475. Tax on trading transactions (a) Imposition of tax There is hereby imposed a tax on the transfer of ownership in each covered transaction with respect to any security. (b) Rate of tax The tax imposed under subsection (a) with respect to any covered transaction shall be the applicable percentage of the specified base amount with respect to such covered transaction. The applicable percentage shall be— (1) 0.5 percent in the case of a security described in subparagraph (A) or (B) of subsection (e)(1), (2) 0.10 percent in the case of a security described in subparagraph (C) of subsection (e)(1), and (3) 0.005 percent in the case of a security described in subparagraph (D), (E), or (F) of subsection (e)(1). (c) Specified base amount For purposes of this section, the term specified base amount (1) except as provided in paragraph (2), the fair market value of the security (determined as of the time of the covered transaction), and (2) in the case of any payment described in subsection (h), the amount of such payment. (d) Covered transaction For purposes of this section, the term covered transaction (1) except as provided in paragraph (2), any purchase of a security if— (A) such purchase occurs or is cleared on a facility located in the United States, or (B) the purchaser or seller is a United States person, and (2) any transaction with respect to a security described in subparagraph (D), (E), or (F) of subsection (e)(1), if— (A) such security is traded or cleared on a facility located in the United States, or (B) any party with rights under such security is a United States person. (e) Security and other definitions For purposes of this section— (1) In general The term security (A) any share of stock in a corporation, (B) any partnership or beneficial ownership interest in a partnership or trust, (C) any note, bond, debenture, or other evidence of indebtedness, other than a State or local bond the interest of which is excluded from gross income under section 103(a), (D) any evidence of an interest in, or a derivative financial instrument with respect to, any security or securities described in subparagraph (A), (B), or (C), (E) any derivative financial instrument with respect to any currency or commodity including notional principal contracts, and (F) any other derivative financial instrument any payment with respect to which is calculated by reference to any specified index. (2) Derivative financial instrument The term derivative financial instrument (3) Specified index The term specified index (A) a fixed rate, price, or amount, or (B) a variable rate, price, or amount, which is based on any current objectively determinable information which is not within the control of any of the parties to the contract or instrument and is not unique to any of the parties’ circumstances. (4) Treatment of exchanges (A) In general An exchange shall be treated as the sale of the property transferred and a purchase of the property received by each party to the exchange. (B) Certain deemed exchanges In the case of a distribution treated as an exchange for stock under section 302 or 331, the corporation making such distribution shall be treated as having purchased such stock for purposes of this section. (f) Exceptions (1) Exception for initial issues No tax shall be imposed under subsection (a) on any covered transaction with respect to the initial issuance of any security described in subparagraph (A), (B), or (C) of subsection (e)(1). (2) Exception for certain traded short-term indebtedness A note, bond, debenture, or other evidence of indebtedness which— (A) is traded on a trading facility located in the United States, and (B) has a fixed maturity of not more than 60 days, shall not be treated as described in subsection (e)(1)(C). (3) Exception for securities lending arrangements No tax shall be imposed under subsection (a) on any covered transaction with respect to which gain or loss is not recognized by reason of section 1058. (g) By whom paid (1) In general The tax imposed by this section shall be paid by— (A) in the case of a transaction which occurs or is cleared on a facility located in the United States, such facility, and (B) in the case of a purchase not described in subparagraph (A) which is executed by a broker (as defined in section 6045(c)(1)), the broker. (2) Special rules for direct, etc., transactions In the case of any transaction to which paragraph (1) does not apply, the tax imposed by this section shall be paid by— (A) in the case of a transaction described in subsection (d)(1)— (i) the purchaser if the purchaser is a United States person, and (ii) the seller if the purchaser is not a United States person, and (B) in the case of a transaction described in subsection (d)(2)— (i) the payor if the payor is a United States person, and (ii) the payee if the payor is not a United States person. (h) Certain payments treated as separate transactions Except as otherwise provided by the Secretary, any payment with respect to a security described in subparagraph (D), (E), or (F) of subsection (e)(1) shall be treated as a separate transaction for purposes of this section, including— (1) any net initial payment, net final or terminating payment, or net periodical payment with respect to a notional principal contract (or similar financial instrument), (2) any payment with respect to any forward contract (or similar financial instrument), and (3) any premium paid with respect to any option (or similar financial instrument). (i) Administration The Secretary shall carry out this section in consultation with the Securities and Exchange Commission and the Commodity Futures Trading Commission. (j) Guidance; regulations The Secretary shall— (1) provide guidance regarding such information reporting concerning covered transactions as the Secretary deems appropriate, including reporting by the payor of the tax in cases where the payor is not the purchaser, and (2) prescribe such regulations as are necessary or appropriate to prevent avoidance of the purposes of this section, including the use of non-United States persons in such transactions. (k) Whistleblowers See section 7623 for provisions relating to whistleblowers. . (b) Penalty for failure To include covered transaction information with return Part I of subchapter B of chapter 68 6707B. Penalty for failure to include covered transaction information with return (a) Imposition of penalty Any person who fails to include on any return or statement any information with respect to a covered transaction which is required pursuant to section 4475(j)(1) to be included with such return or statement shall pay a penalty in the amount determined under subsection (b). (b) Amount of penalty Except as otherwise provided in this subsection, the amount of the penalty under subsection (a) with respect to any covered transaction shall be determined by the Secretary. (c) Covered transaction For purposes of this section, the term covered transaction (d) Authority To rescind penalty (1) In general The Commissioner of Internal Revenue may rescind all or any portion of any penalty imposed by this section with respect to any violation if rescinding the penalty would promote compliance with the requirements of this title and effective tax administration. (2) No judicial appeal Notwithstanding any other provision of law, any determination under this subsection may not be reviewed in any judicial proceeding. (3) Records If a penalty is rescinded under paragraph (1), the Commissioner shall place in the file in the Office of the Commissioner the opinion of the Commissioner with respect to the determination, including— (A) a statement of the facts and circumstances relating to the violation, (B) the reasons for the rescission, and (C) the amount of the penalty rescinded. (e) Coordination with other penalties The penalty imposed by this section shall be in addition to any other penalty imposed by this title. . (c) Clerical amendments (1) The table of sections for part I of subchapter B of chapter 68 of such Code is amended by inserting after the item relating to section 6707A the following new item: Sec. 6707B. Penalty for failure to include covered transaction information with return. . (2) The table of subchapters for chapter 36 Subchapter C. Tax on Trading Transactions . (d) Effective date The amendments made by this section shall apply to transactions after December 31, 2015. 503. Offsetting credit for financial transaction tax (a) In general Subpart A of part IV of subchapter A of chapter 1 25E. Financial transaction tax payments (a) Allowance of credit In the case of an individual, there shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the tax paid during the taxable year under section 4475. (b) Limitation based on modified adjusted gross income (1) In general Subsection (a) shall not apply to a taxpayer for the taxable year if the modified adjusted gross income of the taxpayer for the taxable year exceeds $50,000 ($75,000 in the case of a joint return and one-half of such amount in the case of a married individual filing a separate return). (2) Modified adjusted gross income For purposes of paragraph (1), the term modified adjusted gross income (A) determined without regard to sections 86, 893, 911, 931, and 933, and (B) increased by the amount of interest received or accrued by the taxpayer during the taxable year which is exempt from tax. (3) Inflation adjustment (A) In general In the case of any taxable year beginning after 2016, each dollar amount referred to in paragraph (1) shall be increased by an amount equal to— (i) such dollar amount, multiplied by (ii) the cost-of-living adjustment determined under section 1(f)(3) 2015 1992 (B) Rounding If any amount as adjusted under clause (i) is not a multiple of $50, such amount shall be rounded to the nearest multiple of $50. (c) Eligible individual (1) In general The term eligible individual (A) has attained the age of 18 as of the last day of such taxable year, and (B) is a citizen or lawful permanent resident (within the meaning of section 7701(b)(6)) as of the last day of such taxable year. (2) Certain individuals not eligible For purposes of paragraph (1), an individual described in any of the following provisions of this title for the preceding taxable year shall not be treated as an eligible individual for the taxable year: (A) An individual who is a student (as defined in section 152(f)(2)) for the taxable year or the immediately preceding taxable year. (B) An individual who is a taxpayer described in subsection (c), (d), or (e) of section 6402 for the immediately preceding taxable year. (C) A married individual who files a separate return for the taxable year. . (b) Clerical amendment The table of sections for subpart A of part IV of subchapter A of chapter 1 of such Code is amended by inserting after the item relating to section 25D the following new item: Sec. 25E. Financial transaction tax payments. . (c) Effective date The amendments made by this section shall apply to taxable years beginning after December 31, 2015.

Summary: College for All Act This bill directs the Department of Education (ED) to award grants to states to eliminate tuition and required fees at public institutions of higher education (IHEs). It also amends the Higher Education Act of 1965 to: modify provisions related to interest rates on federal student loans to revise rates applicable to new loans disbursed on or after July 1, 2015; allow student loan borrowers to modify interest rates on outstanding federal student loans to current rates; reauthorize the Federal Work Study program for FY2016-FY2020; eliminate existing base guarantees of Federal Work Study funds to IHEs and require funds to be allocated based solely on the aggregate need of the institution&rsquo;s students; authorize ED to establish a pilot program to streamline the federal financial assistance application process and reduce the need for students to apply for financial assistance each year; and require ED to use tax information from the second preceding tax year (the &ldquo;prior, prior year&rdquo;) to determine a student&rsquo;s financial aid eligibility. Inclusive Prosperity Act of 2015 To offset the cost, this bill amends the Internal Revenue Code to impose a transaction tax on certain securities transfers. An individual taxpayer whose modified adjusted gross income does not exceed $50,000 ($75,000 for married taxpayers filing joint returns) is eligible for a tax credit for the amount of tax paid on covered transactions.