There is a similar provision with respect to an employer who, because of an acquisition, disposition or similar transaction, fails to be an eligible employer because such employer employs more than 100 employees. The proposal would be effective as if included in the Small Business Job Protection Act of 1996. The proposal would be effective as if included in the Small Business Job Protection Act of 1996. The proposal would clarify that the AGI phaseout only applies in the year that the credit is generated and is not reapplied to further reduce any carry-forward amounts. The proposal would be effective as if included in the Small Business Job Protection Act of 1996.
Any amount so included in the gross income of a member is treated as a dividend received.
The proposal would be effective on the date of enactment. Unused credits may be carried back one year and carried forward 20 years. Section 196 allows a deduction to the extent that certain portions of the GBC expire unused after the end of the carry forward period. Section 196 does not allow a deduction to the extent that the portion of the GBC that expires unused after the end of the carry forward period relates to the employer social security credit. The proposal would allow a deduction to the extent that the portion of the GBC relating to the employer social security credit expires unused after the end of the carry forward period.