The bill clarifies that the AGI phaseout only applies in the year that the credit is generated and is not reapplied to further reduce any carryforward amounts. The provision is effective as if included in the Small Business Job Protection Act of 1996. 1313 of the Taxpayer Bill of Rights 2, and Sec.
Any amount so included in the gross income of a member is treated as a dividend received.
The provision is effective on the date of enactment. 6019 of the bill, Sec. 13443 of the Omnibus Budget Reconciliation Act of 1993, and Sec. 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.