1923 
(2) with full recognition of the constitutional 
right of the House of Representatives to change those 
rules at any time, in the same manner, and to the 
same extent as in the case of any other rule of the 
House of Representatives. 
SEC. 1003. ESTIMATES. 
Section 251(a)(7)(B) of the Balanced Budget and 
Emergency Deficit Control Act of 1985 (2 U.S.C. 
901(a)(7)(B)) is amended in the first sentence by striking 
‘‘the CBO estimate of that legislation, an OMB estimate 
of the amount of discretionary new budget authority and 
outlays’’ and inserting ‘‘both the CBO and OMB estimates 
of the amount of discretionary new budget authority’’. 
TITLE XI—IRAQ LOAN 
AUTHORITY 
SEC. 1101. IRAQ LOAN AUTHORITY. 
(a) AUTHORITY.—During fiscal year 2016, direct 
loans under section 23 of the Arms Export Control Act may 
be made available for Iraq, gross obligations for the prin-
cipal amounts of which shall not exceed $2,700,000,000: 
Provided, That funds appropriated under the heading ‘‘For-
eign Military Financing Program’’ in title VIII of the De-
partment of State, Foreign Operations and Related Pro-
grams Appropriations Act, 2016 that are designated by the 
Congress for Overseas Contingency Operations/Global War
1924 
on Terrorism pursuant to section 251(b)(2)(A) of the Bal-
anced Budget and Emergency Deficit Control Act of 1985, 
may be made available for the costs, as defined in section 
502 of the Congressional Budget Act of 1974, of direct loans, 
except that such funds may not be derived from amounts 
specifically designated by such Acts for countries other than 
Iraq: Provided further, That such costs, including the cost 
of modifying such loans, shall be as defined in section 502 
of the Congressional Budget Act of 1974, and may include 
the costs of selling, reducing, or cancelling any amounts 
owed to the United States or any agency of the United 
States by Iraq: Provided further, That the Government of 
the United States may charge fees for such loans, which 
shall be collected from borrowers in accordance with section 
502(7) of the Congressional Budget Act of 1974: Provided 
further, That no funds made available to Iraq by the De-
partment of State, Foreign Operations, and Related Pro-
grams Appropriations Act, 2016 or previous appropria-
tions Acts may be used for payment of any fees associated 
with such loans: Provided further, That applicable provi-
sions of section 3 of the Arms Export Control Act relating 
to restrictions on transfers, re-transfers and end-use shall 
apply to defense articles and services purchased with such 
loans: Provided further, That, in consultation with the Gov-
ernment of Iraq, special emphasis shall be placed on assist-
1925 
ance to covered groups (as defined in section 1223(e)(2)(D) 
of Public Law 114–92) with the loans made available pur-
suant to this paragraph: Provided further, That such loans 
shall be repaid in not more than 12 years, including a grace 
period of up to 1 year on repayment of principal. 
(b) CONSULTATION AND NOTIFICATION.—Funds made 
available pursuant to this section shall be subject to prior 
consultation with the appropriate congressional committees, 
and subject to the regular notification procedures of the 
Committees on Appropriations. 
(c) COMMITTEES.—For the purposes of this section, the 
terms ‘‘appropriate congressional committees’’ and ‘‘Com-
mittees on Appropriations’’ have the same meaning as used 
in the Department of State, Foreign Operations and Re-
lated Programs Appropriations Act, 2016. 
(d) BUDGETARY EFFECTS.—Section 1001 of title X of 
this division shall not apply to this section. 
DIVISION P—TAX-RELATED 
PROVISIONS 
SEC. 1. TABLE OF CONTENTS. 
The table of contents for this division is as follows: 
Sec. 1. Table of contents. 
TITLE I—HIGH COST EMPLOYER-SPONSORED HEALTH COVERAGE 
EXCISE TAX PROVISIONS 
Sec. 101. Delay of excise tax on high cost employer-sponsored health coverage. 
Sec. 102. Deductibility of excise tax on high cost employer-sponsored health cov-
erage. 
Sec. 103. Study on suitable benchmarks for age and gender adjustment of excise 
tax on high cost employer-sponsored health coverage.
1926 
TITLE II—ANNUAL FEE ON HEALTH INSURANCE PROVIDERS 
Sec. 201. Moratorium on annual fee on health insurance providers. 
TITLE III—MISCELLANEOUS PROVISIONS 
Sec. 301. Extension and phaseout of credits for wind facilities. 
Sec. 302. Extension of election to treat qualified facilities as energy property. 
Sec. 303. Extension and phaseout of solar energy credit. 
Sec. 304. Extension and phaseout of credits with respect to qualified solar electric 
property and qualified solar water heating property. 
Sec. 305. Treatment of transportation costs of independent refiners. 
TITLE I—HIGH COST EMPLOYER- 
SPONSORED 
HEALTH 
COV-
ERAGE EXCISE TAX PROVI-
SIONS 
SEC. 101. DELAY OF EXCISE TAX ON HIGH COST EMPLOYER- 
SPONSORED HEALTH COVERAGE. 
(a) IN GENERAL.—Sections 9001(c) and 10901(c) of 
the Patient Protection and Affordable Care Act, as amended 
by section 1401(b) of the Health Care and Education Rec-
onciliation Act of 2010, are each amended by striking 
‘‘2017’’ and inserting ‘‘2019’’. 
(b) CONFORMING AMENDMENT.—Clause (v) of section 
4980I(b)(3)(C) of the Internal Revenue Code of 1986 is 
amended— 
(1) by striking ‘‘as in effect’’ and inserting ‘‘as 
determined for’’, and 
(2) by striking ‘‘as so in effect’’ and inserting 
‘‘as so determined’’.
1927 
SEC. 102. DEDUCTIBILITY OF EXCISE TAX ON HIGH COST 
EMPLOYER-SPONSORED HEALTH COVERAGE. 
Paragraph (10) of section 4980I(f) of the Internal Rev-
enue Code of 1986 is amended to read as follows: 
‘‘(10) 
DEDUCTIBILITY
OF
TAX.—Section 
275(a)(6) shall not apply to the tax imposed by sub-
section (a).’’. 
SEC. 103. STUDY ON SUITABLE BENCHMARKS FOR AGE AND 
GENDER ADJUSTMENT OF EXCISE TAX ON 
HIGH COST EMPLOYER-SPONSORED HEALTH 
COVERAGE. 
Not later than 18 months after the date of the enact-
ment of this Act, the Comptroller General of the United 
States, in consultation with the National Association of In-
surance Commissioners, shall report to the Committee on 
Finance of the Senate and the Committee on Ways and 
Means of the House of Representatives on— 
(1) the suitability of the use (in effect under sec-
tion 4980I(b)(3)(C)(iii)(II) of the Internal Revenue 
Code of 1986 as of the date of the enactment of this 
Act) of the premium cost of the Blue Cross/Blue 
Shield standard benefit option under the Federal Em-
ployees Health Benefits Plan as a benchmark for the 
age and gender adjustment of the applicable dollar 
limit with respect to the excise tax on high cost em-
1928 
ployer-sponsored health coverage under section 4980I 
of the Internal Revenue Code of 1986; and 
(2) recommendations regarding any more suit-
able benchmarks for such age and gender adjustment. 
TITLE II—ANNUAL FEE ON 
HEALTH INSURANCE PROVIDERS 
SEC. 201. MORATORIUM ON ANNUAL FEE ON HEALTH IN-
SURANCE PROVIDERS. 
Subsection (j) of section 9010 of the Patient Protection 
and Affordable Care Act is amended to read as follows: 
‘‘(j) EFFECTIVE DATE.—This section shall apply to 
calendar years— 
‘‘(1) beginning after December 31, 2013, and 
ending before January 1, 2017, and 
‘‘(2) beginning after December 31, 2017.’’. 
TITLE III—MISCELLANEOUS 
PROVISIONS 
SEC. 301. EXTENSION AND PHASEOUT OF CREDITS FOR 
WIND FACILITIES. 
(a) IN GENERAL.— 
(1) EXTENSION.—Paragraph (1) of section 45(d) 
of the Internal Revenue Code of 1986 is amended by 
striking ‘‘January 1, 2015’’ and inserting ‘‘January 
1, 2020’’.
1930 
any facility which is described in paragraph (1) of section 
45(d))’’ before ‘‘, and’’. 
(b) PHASEOUT FOR WIND FACILITIES.—Paragraph 
(5) of section 48(a) is amended by adding at the end the 
following new subparagraph: 
‘‘(E) PHASEOUT OF CREDIT FOR WIND FA-
CILITIES.—In the case of any facility using wind 
to produce electricity, the amount of the credit 
determined under this section (determined after 
the application of paragraphs (1) and (2) and 
without regard to this subparagraph) shall be re-
duced by— 
‘‘(i) in the case of any facility the con-
struction of which begins after December 31, 
2016, and before January 1, 2018, 20 per-
cent, 
‘‘(ii) in the case of any facility the 
construction of which begins after December 
31, 2017, and before January 1, 2019, 40 
percent, and 
‘‘(iii) in the case of any facility the 
construction of which begins after December 
31, 2018, and before January 1, 2020, 60 
percent.’’.
1931 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall take effect on January 1, 2015. 
SEC. 303. EXTENSION AND PHASEOUT OF SOLAR ENERGY 
CREDIT. 
(a) 
EXTENSION.—Subclause 
(II) 
of 
section 
48(a)(2)(A)(i) of the Internal Revenue Code of 1986 is 
amended by striking ‘‘periods ending before January 1, 
2017’’ and inserting ‘‘property the construction of which 
begins before January 1, 2022’’. 
(b) PHASEOUT FOR SOLAR ENERGY PROPERTY.—Sub-
section (a) of section 48 of such Code is amended by adding 
at the end the following new paragraph: 
‘‘(6) PHASEOUT
FOR
SOLAR
ENERGY
PROP-
ERTY.— 
‘‘(A) IN
GENERAL.—Subject to subpara-
graph (B), in the case of any energy property de-
scribed in paragraph (3)(A)(i) the construction 
of which begins before January 1, 2022, the en-
ergy percentage determined under paragraph (2) 
shall be equal to— 
‘‘(i) in the case of any property the 
construction of which begins after December 
31, 2019, and before January 1, 2021, 26 
percent, and
1932 
‘‘(ii) in the case of any property the 
construction of which begins after December 
31, 2020, and before January 1, 2022, 22 
percent. 
‘‘(B) PLACED IN SERVICE DEADLINE.—In 
the case of any property energy property de-
scribed in paragraph (3)(A)(i) the construction 
of which begins before January 1, 2022, and 
which is not placed in service before January 1, 
2024, the energy percentage determined under 
paragraph (2) shall be equal to 10 percent.’’. 
(c) CONFORMING AMENDMENT.—Subparagraph (A) of 
section 48(a)(2) of such Code is amended by striking ‘‘The 
energy percentage’’ and inserting ‘‘Except as provided in 
paragraph (6), the energy percentage’’. 
(d) EFFECTIVE DATE.—The amendments made by this 
section shall take effect on the date of the enactment of this 
Act. 
SEC. 304. EXTENSION AND PHASEOUT OF CREDITS WITH 
RESPECT TO QUALIFIED SOLAR ELECTRIC 
PROPERTY AND QUALIFIED SOLAR WATER 
HEATING PROPERTY. 
(a) IN GENERAL.—Section 25D of the Internal Rev-
enue Code of 1986 is amended—
1933 
(1) in paragraphs (1) and (2) of subsection (a), 
by striking ‘‘30 percent’’ each place it appears and 
inserting ‘‘the applicable percentage’’, 
(2) in subsection (g), by inserting ‘‘(December 
31, 2021, in the case of any qualified solar electric 
property expenditures and qualified solar water heat-
ing property expenditures)’’ before the period at the 
end, 
(3) by redesignating subsection (g), as amended 
by paragraph (2), as subsection (h), and 
(4) by inserting after subsection (f) the following 
new subsection: 
‘‘(g) APPLICABLE PERCENTAGE.—For purposes of 
paragraphs (1) and (2) of subsection (a), the applicable per-
centage shall be— 
‘‘(1) in the case of property placed in service 
after December 31, 2016, and before January 1, 2020, 
30 percent, 
‘‘(2) in the case of property placed in service 
after December 31, 2019, and before January 1, 2021, 
26 percent, and 
‘‘(3) in the case of property placed in service 
after December 31, 2020, and before January 1, 2022, 
22 percent.’’.
1934 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall take effect on January 1, 2017. 
SEC. 305. TREATMENT OF TRANSPORTATION COSTS OF 
INDEPENDENT REFINERS. 
(a) IN GENERAL.—Paragraph (3) of section 199(c) of 
the Internal Revenue Code of 1986 is amended by adding 
at the end the following new subparagraph: 
‘‘(C) TRANSPORTATION
COSTS
OF
INDE-
PENDENT REFINERS.— 
‘‘(i) IN GENERAL.—In the case of any 
taxpayer who is in the trade or business of 
refining crude oil and who is not a major 
integrated oil company (as defined in sec-
tion 167(h)(5)(B), determined without re-
gard to clause (iii) thereof) for the taxable 
year, in computing oil related qualified pro-
duction activities income under subsection 
(d)(9)(B), the amount allocated to domestic 
production gross receipts under paragraph 
(1)(B) for costs related to the transportation 
of oil shall be 25 percent of the amount 
properly allocable under such paragraph 
(determined without regard to this subpara-
graph).
1935 
‘‘(ii) TERMINATION.—Clause (i) shall 
not apply to any taxable year beginning 
after December 31, 2021.’’. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2015. 
Ω2æAt the end of House amendment numbered 1, insert 
the following: 
DIVISION 
Q—PROTECTING 
AMERICANS FROM TAX HIKES 
ACT OF 2015 
SECTION 1. SHORT TITLE, ETC. 
(a) SHORT TITLE.—This division may be cited as the 
‘‘Protecting Americans from Tax Hikes Act of 2015’’. 
(b) AMENDMENT OF 1986 CODE.—Except as otherwise 
expressly provided, whenever in this division an amend-
ment or repeal is expressed in terms of an amendment to, 
or repeal of, a section or other provision, the reference shall 
be considered to be made to a section or other provision 
of the Internal Revenue Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents for 
this division is as follows: 
DIVISION Q—PROTECTING AMERICANS FROM TAX HIKES ACT OF 
2015 
Sec. 1. Short title, etc.
1936 
TITLE I—EXTENDERS 
Subtitle A—Permanent Extensions 
PART 1—TAX RELIEF FOR FAMILIES AND INDIVIDUALS 
Sec. 101. Enhanced child tax credit made permanent. 
Sec. 102. Enhanced American opportunity tax credit made permanent. 
Sec. 103. Enhanced earned income tax credit made permanent. 
Sec. 104. Extension and modification of deduction for certain expenses of elemen-
tary and secondary school teachers. 
Sec. 105. Extension of parity for exclusion from income for employer-provided 
mass transit and parking benefits. 
Sec. 106. Extension of deduction of State and local general sales taxes. 
PART 2—INCENTIVES FOR CHARITABLE GIVING 
Sec. 111. Extension and modification of special rule for contributions of capital 
gain real property made for conservation purposes. 
Sec. 112. Extension of tax-free distributions from individual retirement plans for 
charitable purposes. 
Sec. 113. Extension and modification of charitable deduction for contributions of 
food inventory. 
Sec. 114. Extension of modification of tax treatment of certain payments to con-
trolling exempt organizations. 
Sec. 115. Extension of basis adjustment to stock of S corporations making chari-
table contributions of property. 
PART 3—INCENTIVES FOR GROWTH, JOBS, INVESTMENT, AND INNOVATION 
Sec. 121. Extension and modification of research credit. 
Sec. 122. Extension and modification of employer wage credit for employees who 
are active duty members of the uniformed services. 
Sec. 123. Extension of 15-year straight-line cost recovery for qualified leasehold 
improvements, qualified restaurant buildings and improvements, 
and qualified retail improvements. 
Sec. 124. Extension and modification of increased expensing limitations and 
treatment of certain real property as section 179 property. 
Sec. 125. Extension of treatment of certain dividends of regulated investment 
companies. 
Sec. 126. Extension of exclusion of 100 percent of gain on certain small business 
stock. 
Sec. 127. Extension of reduction in S-corporation recognition period for built-in 
gains tax. 
Sec. 128. Extension of subpart F exception for active financing income. 
PART 4—INCENTIVES FOR REAL ESTATE INVESTMENT 
Sec. 131. Extension of minimum low-income housing tax credit rate for non-Fed-
erally subsidized buildings. 
Sec. 132. Extension of military housing allowance exclusion for determining 
whether a tenant in certain counties is low-income. 
Sec. 133. Extension of RIC qualified investment entity treatment under FIRPTA. 
Subtitle B—Extensions Through 2019 
Sec. 141. Extension of new markets tax credit. 
Sec. 142. Extension and modification of work opportunity tax credit.
1937 
Sec. 143. Extension and modification of bonus depreciation. 
Sec. 144. Extension of look-thru treatment of payments between related controlled 
foreign corporations under foreign personal holding company 
rules. 
Subtitle C—Extensions Through 2016 
PART 1—TAX RELIEF FOR FAMILIES AND INDIVIDUALS 
Sec. 151. Extension and modification of exclusion from gross income of discharge 
of qualified principal residence indebtedness. 
Sec. 152. Extension of mortgage insurance premiums treated as qualified resi-
dence interest. 
Sec. 153. Extension of above-the-line deduction for qualified tuition and related 
expenses. 
PART 2—INCENTIVES FOR GROWTH, JOBS, INVESTMENT, AND INNOVATION 
Sec. 161. Extension of Indian employment tax credit. 
Sec. 162. Extension and modification of railroad track maintenance credit. 
Sec. 163. Extension of mine rescue team training credit. 
Sec. 164. Extension of qualified zone academy bonds. 
Sec. 165. Extension of classification of certain race horses as 3-year property. 
Sec. 166. Extension of 7-year recovery period for motorsports entertainment com-
plexes. 
Sec. 167. Extension and modification of accelerated depreciation for business 
property on an Indian reservation. 
Sec. 168. Extension of election to expense mine safety equipment. 
Sec. 169. Extension of special expensing rules for certain film and television pro-
ductions; special expensing for live theatrical productions. 
Sec. 170. Extension of deduction allowable with respect to income attributable to 
domestic production activities in Puerto Rico. 
Sec. 171. Extension and modification of empowerment zone tax incentives. 
Sec. 172. Extension of temporary increase in limit on cover over of rum excise 
taxes to Puerto Rico and the Virgin Islands. 
Sec. 173. Extension of American Samoa economic development credit. 
Sec. 174. Moratorium on medical device excise tax. 
PART 3—INCENTIVES FOR ENERGY PRODUCTION AND CONSERVATION 
Sec. 181. Extension and modification of credit for nonbusiness energy property. 
Sec. 182. Extension of credit for alternative fuel vehicle refueling property. 
Sec. 183. Extension of credit for 2-wheeled plug-in electric vehicles. 
Sec. 184. Extension of second generation biofuel producer credit. 
Sec. 185. Extension of biodiesel and renewable diesel incentives. 
Sec. 186. Extension and modification of production credit for Indian coal facili-
ties. 
Sec. 187. Extension of credits with respect to facilities producing energy from cer-
tain renewable resources. 
Sec. 188. Extension of credit for energy-efficient new homes. 
Sec. 189. Extension of special allowance for second generation biofuel plant prop-
erty. 
Sec. 190. Extension of energy efficient commercial buildings deduction. 
Sec. 191. Extension of special rule for sales or dispositions to implement FERC 
or State electric restructuring policy for qualified electric utili-
ties. 
Sec. 192. Extension of excise tax credits relating to alternative fuels.
1938 
Sec. 193. Extension of credit for new qualified fuel cell motor vehicles. 
TITLE II—PROGRAM INTEGRITY 
Sec. 201. Modification of filing dates of returns and statements relating to em-
ployee wage information and nonemployee compensation to im-
prove compliance. 
Sec. 202. Safe harbor for de minimis errors on information returns and payee 
statements. 
Sec. 203. Requirements for the issuance of ITINs. 
Sec. 204. Prevention of retroactive claims of earned income credit after issuance 
of social security number. 
Sec. 205. Prevention of retroactive claims of child tax credit. 
Sec. 206. Prevention of retroactive claims of American opportunity tax credit. 
Sec. 207. Procedures to reduce improper claims. 
Sec. 208. Restrictions on taxpayers who improperly claimed credits in prior year. 
Sec. 209. Treatment of credits for purposes of certain penalties. 
Sec. 210. Increase the penalty applicable to paid tax preparers who engage in 
willful or reckless conduct. 
Sec. 211. Employer identification number required for American opportunity tax 
credit. 
Sec. 212. Higher education information reporting only to include qualified tui-
tion and related expenses actually paid. 
TITLE III—MISCELLANEOUS PROVISIONS 
Subtitle A—Family Tax Relief 
Sec. 301. Exclusion for amounts received under the Work Colleges Program. 
Sec. 302. Improvements to section 529 accounts. 
Sec. 303. Elimination of residency requirement for qualified ABLE programs. 
Sec. 304. Exclusion for wrongfully incarcerated individuals. 
Sec. 305. Clarification of special rule for certain governmental plans. 
Sec. 306. Rollovers permitted from other retirement plans into simple retirement 
accounts. 
Sec. 307. Technical amendment relating to rollover of certain airline payment 
amounts. 
Sec. 308. Treatment of early retirement distributions for nuclear materials couri-
ers, United States Capitol Police, Supreme Court Police, and 
diplomatic security special agents. 
Sec. 309. Prevention of extension of tax collection period for members of the 
Armed Forces who are hospitalized as a result of combat zone 
injuries. 
Subtitle B—Real Estate Investment Trusts 
Sec. 311. Restriction on tax-free spinoffs involving REITs. 
Sec. 312. Reduction in percentage limitation on assets of REIT which may be 
taxable REIT subsidiaries. 
Sec. 313. Prohibited transaction safe harbors. 
Sec. 314. Repeal of preferential dividend rule for publicly offered REITs. 
Sec. 315. Authority for alternative remedies to address certain REIT distribution 
failures. 
Sec. 316. Limitations on designation of dividends by REITs. 
Sec. 317. Debt instruments of publicly offered REITs and mortgages treated as 
real estate assets.
1939 
Sec. 318. Asset and income test clarification regarding ancillary personal prop-
erty. 
Sec. 319. Hedging provisions. 
Sec. 320. Modification of REIT earnings and profits calculation to avoid dupli-
cate taxation. 
Sec. 321. Treatment of certain services provided by taxable REIT subsidiaries. 
Sec. 322. Exception from FIRPTA for certain stock of REITs. 
Sec. 323. Exception for interests held by foreign retirement or pension funds. 
Sec. 324. Increase in rate of withholding of tax on dispositions of United States 
real property interests. 
Sec. 325. Interests in RICs and REITs not excluded from definition of United 
States real property interests. 
Sec. 326. Dividends derived from RICs and REITs ineligible for deduction for 
United States source portion of dividends from certain foreign 
corporations. 
Subtitle C—Additional Provisions 
Sec. 331. Deductibility of charitable contributions to agricultural research organi-
zations. 
Sec. 332. Removal of bond requirements and extending filing periods for certain 
taxpayers with limited excise tax liability. 
Sec. 333. Modifications to alternative tax for certain small insurance companies. 
Sec. 334. Treatment of timber gains. 
Sec. 335. Modification of definition of hard cider. 
Sec. 336. Church plan clarification. 
Subtitle D—Revenue Provisions 
Sec. 341. Updated ASHRAE standards for energy efficient commercial buildings 
deduction. 
Sec. 342. Excise tax credit equivalency for liquified petroleum gas and liquified 
natural gas. 
Sec. 343. Exclusion from gross income of certain clean coal power grants to non- 
corporate taxpayers. 
Sec. 344. Clarification of valuation rule for early termination of certain chari-
table remainder unitrusts. 
Sec. 345. Prevention of transfer of certain losses from tax indifferent parties. 
Sec. 346. Treatment of certain persons as employers with respect to motion pic-
ture projects. 
TITLE IV—TAX ADMINISTRATION 
Subtitle A—Internal Revenue Service Reforms 
Sec. 401. Duty to ensure that Internal Revenue Service employees are familiar 
with and act in accord with certain taxpayer rights. 
Sec. 402. IRS employees prohibited from using personal email accounts for offi-
cial business. 
Sec. 403. Release of information regarding the status of certain investigations. 
Sec. 404. Administrative appeal relating to adverse determinations of tax-exempt 
status of certain organizations. 
Sec. 405. Organizations required to notify Secretary of intent to operate under 
501(c)(4). 
Sec. 406. Declaratory judgments for 501(c)(4) and other exempt organizations. 
Sec. 407. Termination of employment of Internal Revenue Service employees for 
taking official actions for political purposes.
1940 
Sec. 408. Gift tax not to apply to contributions to certain exempt organizations. 
Sec. 409. Extend Internal Revenue Service authority to require truncated Social 
Security numbers on Form W–2. 
Sec. 410. Clarification of enrolled agent credentials. 
Sec. 411. Partnership audit rules. 
Subtitle B—United States Tax Court 
PART 1—TAXPAYER ACCESS TO UNITED STATES TAX COURT 
Sec. 421. Filing period for interest abatement cases. 
Sec. 422. Small tax case election for interest abatement cases. 
Sec. 423. Venue for appeal of spousal relief and collection cases. 
Sec. 424. Suspension of running of period for filing petition of spousal relief and 
collection cases. 
Sec. 425. Application of Federal rules of evidence. 
PART 2—UNITED STATES TAX COURT ADMINISTRATION 
Sec. 431. Judicial conduct and disability procedures. 
Sec. 432. Administration, judicial conference, and fees. 
PART 3—CLARIFICATION RELATING TO UNITED STATES TAX COURT 
Sec. 441. Clarification relating to United States Tax Court. 
TITLE V—TRADE-RELATED PROVISIONS 
Sec. 501. Modification of effective date of provisions relating to tariff classifica-
tion of recreational performance outerwear. 
Sec. 502. Agreement by Asia-Pacific Economic Cooperation members to reduce 
rates of duty on certain environmental goods. 
TITLE VI—BUDGETARY EFFECTS 
Sec. 601. Budgetary effects. 
TITLE I—EXTENDERS 
Subtitle A—Permanent Extensions 
PART 1—TAX RELIEF FOR FAMILIES AND 
INDIVIDUALS 
SEC. 101. ENHANCED CHILD TAX CREDIT MADE PERMA-
NENT. 
(a) IN GENERAL.—Section 24(d)(1)(B)(i) is amended 
by striking ‘‘$10,000’’ and inserting ‘‘$3,000’’. 
(b) CONFORMING
AMENDMENT.—Section 24(d) is 
amended by striking paragraphs (3) and (4).
1941 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after the date 
of the enactment of this Act. 
SEC. 102. ENHANCED AMERICAN OPPORTUNITY TAX CREDIT 
MADE PERMANENT. 
(a) IN GENERAL.—Section 25A(i) is amended by strik-
ing ‘‘and before 2018’’. 
(b) TREATMENT OF POSSESSIONS.—Section 1004(c)(1) 
of division B of the American Recovery and Reinvestment 
Tax Act of 2009 by striking ‘‘and before 2018’’ each place 
it appears. 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after the date 
of the enactment of this Act. 
SEC. 103. ENHANCED EARNED INCOME TAX CREDIT MADE 
PERMANENT. 
(a) INCREASE IN CREDIT PERCENTAGE FOR 3 OR 
MORE QUALIFYING CHILDREN MADE PERMANENT.—Sec-
tion 32(b)(1) is amended to read as follows: 
‘‘(1) PERCENTAGES.—The credit percentage and 
the phaseout percentage shall be determined as fol-
lows: 
‘‘In the case of 
an eligible individual with: 
The credit 
percentage is: 
The phaseout 
percentage is: 
1 qualifying child ...............................................
15.98
2 qualifying children .........................................
21.06
3 or more qualifying children ...........................
21.06
No qualifying children .......................................
7.65 
7.65’’.
1942 
(b) REDUCTION OF MARRIAGE PENALTY MADE PER-
MANENT.— 
(1) IN GENERAL.—Section 32(b)(2)(B) is amend-
ed to read as follows: 
‘‘(B) JOINT RETURNS.— 
‘‘(i) IN GENERAL.—In the case of a 
joint return filed by an eligible individual 
and such individual’s spouse, the phaseout 
amount determined under subparagraph 
(A) shall be increased by $5,000. 
‘‘(ii) INFLATION ADJUSTMENT.—In the 
case of any taxable year beginning after 
2015, the $5,000 amount in clause (i) shall 
be increased by an amount equal to— 
‘‘(I) such dollar amount, multi-
plied by 
‘‘(II) the cost of living adjustment 
determined under section 1(f)(3) for 
the calendar year in which the taxable 
year begins determined by substituting 
‘calendar year 2008’ for ‘calendar year 
1992’ in subparagraph (B) thereof. 
‘‘(iii) ROUNDING.—Subparagraph (A) 
of subsection (j)(2) shall apply after taking
1943 
into account any increase under clause 
(ii).’’. 
(c) CONFORMING
AMENDMENT.—Section 32(b) is 
amended by striking paragraph (3). 
(d) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2015. 
SEC. 104. EXTENSION AND MODIFICATION OF DEDUCTION 
FOR CERTAIN EXPENSES OF ELEMENTARY 
AND SECONDARY SCHOOL TEACHERS. 
(a) 
DEDUCTION
MADE
PERMANENT.—Section 
62(a)(2)(D) is amended by striking ‘‘In the case of taxable 
years beginning during 2002, 2003, 2004, 2005, 2006, 2007, 
2008, 2009, 2010, 2011, 2012, 2013, or 2014, the deduc-
tions’’ and inserting ‘‘The deductions’’. 
(b) 
INFLATION
ADJUSTMENT.—Section 
62(d) 
is 
amended by adding at the end the following new paragraph: 
‘‘(3) INFLATION
ADJUSTMENT.—In the case of 
any taxable year beginning after 2015, the $250 
amount in subsection (a)(2)(D) shall be increased by 
an amount equal to— 
‘‘(A) such dollar amount, multiplied by 
‘‘(B) the cost-of-living adjustment deter-
mined under section 1(f)(3) for the calendar year 
in which the taxable year begins, determined by
1944 
substituting ‘calendar year 2014’ for ‘calendar 
year 1992’ in subparagraph (B) thereof. 
Any increase determined under the preceding sentence 
shall be rounded to the nearest multiple of $50.’’. 
(c) PROFESSIONAL DEVELOPMENT EXPENSES.—Sec-
tion 62(a)(2)(D) is amended— 
(1) by striking ‘‘educator in connection’’ and all 
that follows and inserting ‘‘educator—’’, and 
(2) by inserting at the end the following: 
‘‘(i) by reason of the participation of 
the educator in professional development 
courses related to the curriculum in which 
the educator provides instruction or to the 
students for which the educator provides in-
struction, and 
‘‘(ii) in connection with books, supplies 
(other than nonathletic supplies for courses 
of instruction in health or physical edu-
cation), computer equipment (including re-
lated software and services) and other 
equipment, and supplementary materials 
used by the eligible educator in the class-
room.’’. 
(d) EFFECTIVE DATES.—
1945 
(1) EXTENSION.—The amendment made by sub-
section (a) shall apply to taxable years beginning 
after December 31, 2014. 
(2) MODIFICATIONS.—The amendments made by 
subsections (b) and (c) shall apply to taxable years 
beginning after December 31, 2015. 
SEC. 105. EXTENSION OF PARITY FOR EXCLUSION FROM IN-
COME FOR EMPLOYER-PROVIDED MASS TRAN-
SIT AND PARKING BENEFITS. 
(a) MASS TRANSIT AND PARKING PARITY.—Section 
132(f)(2) is amended— 
(1) by striking ‘‘$100’’ in subparagraph (A) and 
inserting ‘‘$175’’, and 
(2) by striking the last sentence. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to months after December 31, 2014. 
SEC. 106. EXTENSION OF DEDUCTION OF STATE AND LOCAL 
GENERAL SALES TAXES. 
(a) IN GENERAL.—Section 164(b)(5) is amended by 
striking subparagraph (I). 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2014.
1946 
PART 2—INCENTIVES FOR CHARITABLE GIVING 
SEC. 111. EXTENSION AND MODIFICATION OF SPECIAL 
RULE FOR CONTRIBUTIONS OF CAPITAL GAIN 
REAL PROPERTY MADE FOR CONSERVATION 
PURPOSES. 
(a) MADE PERMANENT.— 
(1) 
INDIVIDUALS.—Section 
170(b)(1)(E) 
is 
amended by striking clause (vi). 
(2) CORPORATIONS.—Section 170(b)(2)(B) is 
amended by striking clause (iii). 
(b) CONTRIBUTIONS OF CAPITAL GAIN REAL PROP-
ERTY MADE FOR CONSERVATION PURPOSES BY NATIVE 
CORPORATIONS.— 
(1) IN GENERAL.—Section 170(b)(2) is amended 
by redesignating subparagraph (C) as subparagraph 
(D), and by inserting after subparagraph (B) the fol-
lowing new subparagraph: 
‘‘(C) QUALIFIED CONSERVATION CONTRIBU-
TIONS BY CERTAIN NATIVE CORPORATIONS.— 
‘‘(i) IN GENERAL.—Any qualified con-
servation contribution (as defined in sub-
section (h)(1)) which— 
‘‘(I) is made by a Native Corpora-
tion, and
1947 
‘‘(II) is a contribution of property 
which was land conveyed under the 
Alaska Native Claims Settlement Act, 
shall be allowed to the extent that the aggre-
gate amount of such contributions does not 
exceed the excess of the taxpayer’s taxable 
income over the amount of charitable con-
tributions allowable under subparagraph 
(A). 
‘‘(ii) CARRYOVER.—If the aggregate 
amount of contributions described in clause 
(i) exceeds the limitation of clause (i), such 
excess shall be treated (in a manner con-
sistent with the rules of subsection (d)(2)) 
as a charitable contribution to which clause 
(i) applies in each of the 15 succeeding tax-
able years in order of time. 
‘‘(iii) 
NATIVE
CORPORATION.—For 
purposes of this subparagraph, the term 
‘Native Corporation’ has the meaning given 
such term by section 3(m) of the Alaska Na-
tive Claims Settlement Act.’’. 
(2) CONFORMING AMENDMENTS.—
1948 
(A) Section 170(b)(2)(A) is amended by 
striking ‘‘subparagraph (B) applies’’ and insert-
ing ‘‘subparagraph (B) or (C) applies’’. 
(B) Section 170(b)(2)(B)(ii) is amended by 
striking ‘‘15 succeeding years’’ and inserting ‘‘15 
succeeding taxable years’’. 
(3) VALID EXISTING RIGHTS PRESERVED.—Noth-
ing in this subsection (or any amendment made by 
this subsection) shall be construed to modify the exist-
ing property rights validly conveyed to Native Cor-
porations (within the meaning of section 3(m) of the 
Alaska Native Claims Settlement Act) under such Act. 
(c) EFFECTIVE DATES.— 
(1) EXTENSION.—The amendments made by sub-
section (a) shall apply to contributions made in tax-
able years beginning after December 31, 2014. 
(2) MODIFICATION.—The amendments made by 
subsection (b) shall apply to contributions made in 
taxable years beginning after December 31, 2015. 
SEC. 112. EXTENSION OF TAX-FREE DISTRIBUTIONS FROM 
INDIVIDUAL RETIREMENT PLANS FOR CHARI-
TABLE PURPOSES. 
(a) IN GENERAL.—Section 408(d)(8) is amended by 
striking subparagraph (F).
1949 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to distributions made in taxable years 
beginning after December 31, 2014. 
SEC. 113. EXTENSION AND MODIFICATION OF CHARITABLE 
DEDUCTION FOR CONTRIBUTIONS OF FOOD 
INVENTORY. 
(a) PERMANENT EXTENSION.—Section 170(e)(3)(C) is 
amended by striking clause (iv). 
(b) MODIFICATIONS.—Section 170(e)(3)(C), as amend-
ed by subsection (a), is amended by striking clause (ii), by 
redesignating clause (iii) as clause (vi), and by inserting 
after clause (i) the following new clauses: 
‘‘(ii) 
LIMITATION.—The 
aggregate 
amount of such contributions for any tax-
able year which may be taken into account 
under this section shall not exceed— 
‘‘(I) in the case of any taxpayer 
other than a C corporation, 15 percent 
of the taxpayer’s aggregate net income 
for such taxable year from all trades or 
businesses from which such contribu-
tions were made for such year, com-
puted without regard to this section, 
and
1950 
‘‘(II) in the case of a C corpora-
tion, 15 percent of taxable income (as 
defined in subsection (b)(2)(D)). 
‘‘(iii) RULES
RELATED
TO
LIMITA-
TION.— 
‘‘(I) CARRYOVER.—If such aggre-
gate amount exceeds the limitation im-
posed under clause (ii), such excess 
shall be treated (in a manner con-
sistent with the rules of subsection (d)) 
as a charitable contribution described 
in clause (i) in each of the 5 suc-
ceeding taxable years in order of time. 
‘‘(II) COORDINATION WITH OVER-
ALL CORPORATE LIMITATION.—In the 
case of any charitable contribution 
which is allowable after the application 
of clause (ii)(II), subsection (b)(2)(A) 
shall not apply to such contribution, 
but the limitation imposed by such 
subsection shall be reduced (but not 
below zero) by the aggregate amount of 
such contributions. For purposes of 
subsection (b)(2)(B), such contributions
1951 
shall be treated as allowable under sub-
section (b)(2)(A). 
‘‘(iv) DETERMINATION OF BASIS FOR 
CERTAIN TAXPAYERS.—If a taxpayer— 
‘‘(I) does not account for inven-
tories under section 471, and 
‘‘(II) is not required to capitalize 
indirect costs under section 263A, 
the taxpayer may elect, solely for purposes 
of subparagraph (B), to treat the basis of 
any apparently wholesome food as being 
equal to 25 percent of the fair market value 
of such food. 
‘‘(v) DETERMINATION OF FAIR MARKET 
VALUE.—In the case of any such contribu-
tion of apparently wholesome food which 
cannot or will not be sold solely by reason 
of internal standards of the taxpayer, lack 
of market, or similar circumstances, or by 
reason of being produced by the taxpayer 
exclusively for the purposes of transferring 
the food to an organization described in 
subparagraph (A), the fair market value of 
such contribution shall be determined—
1952 
‘‘(I) without regard to such inter-
nal standards, such lack of market, 
such circumstances, or such exclusive 
purpose, and 
‘‘(II) by taking into account the 
price at which the same or substan-
tially the same food items (as to both 
type and quality) are sold by the tax-
payer at the time of the contribution 
(or, if not so sold at such time, in the 
recent past).’’ 
(c) EFFECTIVE DATES.— 
(1) EXTENSION.—The amendment made by sub-
section (a) shall apply to contributions made after 
December 31, 2014. 
(2) MODIFICATIONS.—The amendments made by 
subsection (b) shall apply to taxable years beginning 
after December 31, 2015. 
SEC. 114. EXTENSION OF MODIFICATION OF TAX TREAT-
MENT OF CERTAIN PAYMENTS TO CONTROL-
LING EXEMPT ORGANIZATIONS. 
(a) IN GENERAL.—Section 512(b)(13)(E) is amended 
by striking clause (iv).
1953 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to payments received or accrued after 
December 31, 2014. 
SEC. 115. EXTENSION OF BASIS ADJUSTMENT TO STOCK OF 
S CORPORATIONS MAKING CHARITABLE CON-
TRIBUTIONS OF PROPERTY. 
(a) IN GENERAL.—Section 1367(a)(2) is amended by 
striking the last sentence. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to contributions made in taxable years 
beginning after December 31, 2014. 
PART 3—INCENTIVES FOR GROWTH, JOBS, 
INVESTMENT, AND INNOVATION 
SEC. 121. EXTENSION AND MODIFICATION OF RESEARCH 
CREDIT. 
(a) MADE PERMANENT.— 
(1) IN
GENERAL.—Section 41 is amended by 
striking subsection (h). 
(2) 
CONFORMING
AMENDMENT.—Section 
45C(b)(1) is amended by striking subparagraph (D). 
(b) CREDIT ALLOWED AGAINST ALTERNATIVE MIN-
IMUM TAX IN CASE OF ELIGIBLE SMALL BUSINESS.—Sec-
tion 38(c)(4)(B) is amended by redesignating clauses (ii) 
through (ix) as clauses (iii) through (x), respectively, and 
by inserting after clause (i) the following new clause:
1954 
‘‘(ii) the credit determined under sec-
tion 41 for the taxable year with respect to 
an eligible small business (as defined in 
paragraph (5)(C), after application of rules 
similar to the rules of paragraph (5)(D)),’’. 
(c) TREATMENT OF RESEARCH CREDIT FOR CERTAIN 
STARTUP COMPANIES.— 
(1) IN GENERAL.—Section 41, as amended by 
subsection (a), is amended by adding at the end the 
following new subsection: 
‘‘(h) TREATMENT OF CREDIT FOR QUALIFIED SMALL 
BUSINESSES.— 
‘‘(1) IN GENERAL.—At the election of a qualified 
small business for any taxable year, section 3111(f) 
shall apply to the payroll tax credit portion of the 
credit otherwise determined under subsection (a) for 
the taxable year and such portion shall not be treated 
(other than for purposes of section 280C) as a credit 
determined under subsection (a). 
‘‘(2) PAYROLL TAX CREDIT PORTION.—For pur-
poses of this subsection, the payroll tax credit portion 
of the credit determined under subsection (a) with re-
spect to any qualified small business for any taxable 
year is the least of—
1955 
‘‘(A) the amount specified in the election 
made under this subsection, 
‘‘(B) the credit determined under subsection 
(a) for the taxable year (determined before the 
application of this subsection), or 
‘‘(C) in the case of a qualified small busi-
ness other than a partnership or S corporation, 
the amount of the business credit carryforward 
under section 39 carried from the taxable year 
(determined before the application of this sub-
section to the taxable year). 
‘‘(3) QUALIFIED
SMALL
BUSINESS.—For pur-
poses of this subsection— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
small business’ means, with respect to any tax-
able year— 
‘‘(i) a corporation or partnership, if— 
‘‘(I) the gross receipts (as deter-
mined under the rules of section 
448(c)(3), without regard to subpara-
graph (A) thereof) of such entity for 
the 
taxable 
year 
is 
less 
than 
$5,000,000, and 
‘‘(II) such entity did not have 
gross receipts (as so determined) for
1956 
any taxable year preceding the 5-tax-
able-year period ending with such tax-
able year, and 
‘‘(ii) any person (other than a corpora-
tion or partnership) who meets the require-
ments of subclauses (I) and (II) of clause 
(i), determined— 
‘‘(I) by substituting ‘person’ for 
‘entity’ each place it appears, and 
‘‘(II) by only taking into account 
the aggregate gross receipts received by 
such person in carrying on all trades 
or businesses of such person. 
‘‘(B) LIMITATION.—Such term shall not in-
clude an organization which is exempt from tax-
ation under section 501. 
‘‘(4) ELECTION.— 
‘‘(A) IN GENERAL.—Any election under this 
subsection for any taxable year— 
‘‘(i) shall specify the amount of the 
credit to which such election applies, 
‘‘(ii) shall be made on or before the due 
date (including extensions) of— 
‘‘(I) in the case of a qualified 
small business which is a partnership,
1957 
the return required to be filed under 
section 6031, 
‘‘(II) in the case of a qualified 
small business which is an S corpora-
tion, the return required to be filed 
under section 6037, and 
‘‘(III) in the case of any other 
qualified small business, the return of 
tax for the taxable year, and 
‘‘(iii) may be revoked only with the 
consent of the Secretary. 
‘‘(B) LIMITATIONS.— 
‘‘(i) AMOUNT.—The amount specified 
in any election made under this subsection 
shall not exceed $250,000. 
‘‘(ii) NUMBER OF TAXABLE YEARS.—A 
person may not make an election under this 
subsection if such person (or any other per-
son treated as a single taxpayer with such 
person under paragraph (5)(A)) has made 
an election under this subsection for 5 or 
more preceding taxable years. 
‘‘(C) SPECIAL
RULE
FOR
PARTNERSHIPS 
AND S CORPORATIONS.—In the case of a quali-
fied small business which is a partnership or S
1958 
corporation, the election made under this sub-
section shall be made at the entity level. 
‘‘(5) AGGREGATION RULES.— 
‘‘(A) IN GENERAL.—Except as provided in 
subparagraph (B), all persons or entities treated 
as a single taxpayer under subsection (f)(1) shall 
be treated as a single taxpayer for purposes of 
this subsection. 
‘‘(B) SPECIAL RULES.—For purposes of this 
subsection and section 3111(f)— 
‘‘(i) each of the persons treated as a 
single taxpayer under subparagraph (A) 
may separately make the election under 
paragraph (1) for any taxable year, and 
‘‘(ii) the $250,000 amount under para-
graph (4)(B)(i) shall be allocated among all 
persons treated as a single taxpayer under 
subparagraph (A) in the same manner as 
under subparagraph (A)(ii) or (B)(ii) of 
subsection (f)(1), whichever is applicable. 
‘‘(6) REGULATIONS.—The Secretary shall pre-
scribe such regulations as may be necessary to carry 
out the purposes of this subsection, including— 
‘‘(A) regulations to prevent the avoidance of 
the purposes of the limitations and aggregation
1959 
rules under this subsection through the use of 
successor companies or other means, 
‘‘(B) regulations to minimize compliance 
and record-keeping burdens under this sub-
section, and 
‘‘(C) regulations for recapturing the benefit 
of credits determined under section 3111(f) in 
cases where there is a subsequent adjustment to 
the payroll tax credit portion of the credit deter-
mined under subsection (a), including requiring 
amended income tax returns in the cases where 
there is such an adjustment.’’. 
(2) CREDIT ALLOWED AGAINST FICA TAXES.— 
Section 3111 is amended by adding at the end the fol-
lowing new subsection: 
‘‘(f) CREDIT
FOR
RESEARCH
EXPENDITURES
OF 
QUALIFIED SMALL BUSINESSES.— 
‘‘(1) IN GENERAL.—In the case of a taxpayer 
who has made an election under section 41(h) for a 
taxable year, there shall be allowed as a credit against 
the tax imposed by subsection (a) for the first cal-
endar quarter which begins after the date on which 
the taxpayer files the return specified in section 
41(h)(4)(A)(ii) an amount equal to the payroll tax 
credit portion determined under section 41(h)(2).
1960 
‘‘(2) LIMITATION.—The credit allowed by para-
graph (1) shall not exceed the tax imposed by sub-
section (a) for any calendar quarter on the wages 
paid with respect to the employment of all individ-
uals in the employ of the employer. 
‘‘(3) CARRYOVER
OF
UNUSED
CREDIT.—If the 
amount of the credit under paragraph (1) exceeds the 
limitation of paragraph (2) for any calendar quarter, 
such excess shall be carried to the succeeding calendar 
quarter and allowed as a credit under paragraph (1) 
for such quarter. 
‘‘(4) DEDUCTION
ALLOWED
FOR
CREDITED 
AMOUNTS.—The credit allowed under paragraph (1) 
shall not be taken into account for purposes of deter-
mining the amount of any deduction allowed under 
chapter 1 for taxes imposed under subsection (a).’’. 
(d) EFFECTIVE DATES.— 
(1) EXTENSION.—The amendments made by sub-
section (a) shall apply to shall apply to amounts paid 
or incurred after December 31, 2014. 
(2) CREDIT
ALLOWED
AGAINST
ALTERNATIVE 
MINIMUM TAX IN CASE OF ELIGIBLE SMALL BUSI-
NESS.—The amendments made by subsection (b) shall 
apply to credits determined for taxable years begin-
ning after December 31, 2015.
1961 
(3) TREATMENT OF RESEARCH CREDIT FOR CER-
TAIN STARTUP COMPANIES.—The amendments made 
by subsection (c) shall apply to taxable years begin-
ning after December 31, 2015. 
SEC. 122. EXTENSION AND MODIFICATION OF EMPLOYER 
WAGE CREDIT FOR EMPLOYEES WHO ARE AC-
TIVE DUTY MEMBERS OF THE UNIFORMED 
SERVICES. 
(a) IN GENERAL.—Section 45P is amended by striking 
subsection (f). 
(b) APPLICABILITY TO ALL EMPLOYERS.— 
(1) IN GENERAL.—Section 45P(a) is amended by 
striking ‘‘, in the case of an eligible small business 
employer’’. 
(2) 
CONFORMING
AMENDMENT.—Section 
45P(b)(3) is amended to read as follows: 
‘‘(3) CONTROLLED GROUPS.—All persons treated 
as a single employer under subsection (b), (c), (m), or 
(o) of section 414 shall be treated as a single em-
ployer.’’. 
(c) EFFECTIVE DATE.— 
(1) EXTENSION.—The amendment made by sub-
section (a) shall apply to payments made after De-
cember 31, 2014.
1962 
(2) MODIFICATION.—The amendments made by 
subsection (b) shall apply to taxable years beginning 
after December 31, 2015. 
SEC. 123. EXTENSION OF 15-YEAR STRAIGHT-LINE COST RE-
COVERY FOR QUALIFIED LEASEHOLD IM-
PROVEMENTS, 
QUALIFIED 
RESTAURANT 
BUILDINGS AND IMPROVEMENTS, AND QUALI-
FIED RETAIL IMPROVEMENTS. 
(a) QUALIFIED LEASEHOLD IMPROVEMENT PROPERTY 
AND QUALIFIED RESTAURANT PROPERTY.—Clauses (iv) 
and (v) of section 168(e)(3)(E) are each amended by strik-
ing ‘‘placed in service before January 1, 2015’’. 
(b) QUALIFIED RETAIL IMPROVEMENT PROPERTY.— 
Section 168(e)(3)(E)(ix) is amended by striking ‘‘placed in 
service after December 31, 2008, and before January 1, 
2015’’. 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to property placed in service after De-
cember 31, 2014. 
SEC. 124. EXTENSION AND MODIFICATION OF INCREASED 
EXPENSING LIMITATIONS AND TREATMENT 
OF CERTAIN REAL PROPERTY AS SECTION 179 
PROPERTY. 
(a) MADE PERMANENT.—
1963 
(1) DOLLAR LIMITATION.—Section 179(b)(1) is 
amended by striking ‘‘shall not exceed—’’ and all that 
follows and inserting ‘‘shall not exceed $500,000.’’. 
(2) 
REDUCTION
IN
LIMITATION.—Section 
179(b)(2) is amended by striking ‘‘exceeds—’’ and all 
that follows and inserting ‘‘exceeds $2,000,000.’’. 
(b) COMPUTER SOFTWARE.—Section 179(d)(1)(A)(ii) 
is amended by striking ‘‘, to which section 167 applies, and 
which is placed in service in a taxable year beginning after 
2002 and before 2015’’ and inserting ‘‘and to which section 
167 applies’’. 
(c) SPECIAL RULES FOR TREATMENT OF QUALIFIED 
REAL PROPERTY.— 
(1) EXTENSION
FOR
2015.—Section 179(f) is 
amended— 
(A) by striking ‘‘2015’’ in paragraph (1) 
and inserting ‘‘2016’’, 
(B) by striking ‘‘2014’’ each place it ap-
pears in paragraph (4) and inserting ‘‘2015’’, 
and 
(C) by striking ‘‘AND 2013’’ in the heading 
of paragraph (4)(C) and inserting ‘‘2013, AND 
2014’’. 
(2) MADE
PERMANENT.—Section 179(f), as 
amended by paragraph (1), is amended—
1964 
(A) by striking ‘‘beginning after 2009 and 
before 2016’’ in paragraph (1), and 
(B) by striking paragraphs (3) and (4). 
(d) ELECTION.—Section 179(c)(2) is amended— 
(1) by striking ‘‘may not be revoked’’ and all 
that follows through ‘‘and before 2015’’, and 
(2) by striking ‘‘IRREVOCABLE’’ in the heading 
thereof. 
(e) AIR CONDITIONING AND HEATING UNITS.—Section 
179(d)(1) is amended by striking ‘‘and shall not include 
air conditioning or heating units’’. 
(f) INFLATION
ADJUSTMENT.—Section 179(b) is 
amended by adding at the end the following new paragraph: 
‘‘(6) INFLATION ADJUSTMENT.— 
‘‘(A) IN GENERAL.—In the case of any tax-
able year beginning after 2015, the dollar 
amounts in paragraphs (1) and (2) shall each be 
increased by an amount equal to— 
‘‘(i) such dollar amount, multiplied by 
‘‘(ii) the cost-of-living adjustment de-
termined under section 1(f)(3) for the cal-
endar year in which the taxable year be-
gins, determined by substituting ‘calendar 
year 2014’ for ‘calendar year 1992’ in sub-
paragraph (B) thereof.
1966 
(2) by striking ‘‘, 2011, 2012, 2013, AND 2014’’ in 
the heading thereof and inserting ‘‘AND
THERE-
AFTER’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to stock acquired after December 31, 
2014. 
SEC. 127. EXTENSION OF REDUCTION IN S-CORPORATION 
RECOGNITION PERIOD FOR BUILT-IN GAINS 
TAX. 
(a) IN GENERAL.—Section 1374(d)(7) is amended to 
read as follows: 
‘‘(7) RECOGNITION PERIOD.— 
‘‘(A) IN GENERAL.—The term ‘recognition 
period’ means the 5-year period beginning with 
the 1st day of the 1st taxable year for which the 
corporation was an S corporation. For purposes 
of applying this section to any amount includ-
ible in income by reason of distributions to 
shareholders pursuant to section 593(e), the pre-
ceding sentence shall be applied without regard 
to the phrase ‘5-year’. 
‘‘(B) INSTALLMENT SALES.—If an S cor-
poration sells an asset and reports the income 
from the sale using the installment method under 
section 453, the treatment of all payments re-
1967 
ceived shall be governed by the provisions of this 
paragraph applicable to the taxable year in 
which such sale was made.’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2014. 
SEC. 128. EXTENSION OF SUBPART F EXCEPTION FOR AC-
TIVE FINANCING INCOME. 
(a) INSURANCE
BUSINESSES.—Section 953(e) is 
amended by striking paragraph (10) and by redesignating 
paragraph (11) as paragraph (10). 
(b) BANKING, FINANCING, OR SIMILAR BUSINESSES.— 
Section 954(h) is amended by striking paragraph (9). 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years of foreign corporations 
beginning after December 31, 2014, and to taxable years 
of United States shareholders with or within which any 
such taxable year of such foreign corporation ends.
1968 
PART 4—INCENTIVES FOR REAL ESTATE 
INVESTMENT 
SEC. 131. EXTENSION OF MINIMUM LOW-INCOME HOUSING 
TAX CREDIT RATE FOR NON-FEDERALLY SUB-
SIDIZED BUILDINGS. 
(a) IN GENERAL.—Section 42(b)(2) is amended by 
striking ‘‘with respect to housing credit dollar amount allo-
cations made before January 1, 2015’’. 
(b) CLERICAL AMENDMENT.—The heading for section 
42(b)(2) is amended by striking ‘‘TEMPORARY MINIMUM’’ 
and inserting ‘‘MINIMUM’’. 
(c) EFFECTIVE DATES.—The amendments made by 
this section shall take effect on January 1, 2015. 
SEC. 132. EXTENSION OF MILITARY HOUSING ALLOWANCE 
EXCLUSION FOR DETERMINING WHETHER A 
TENANT IN CERTAIN COUNTIES IS LOW-IN-
COME. 
(a) IN GENERAL.—Section 3005(b) of the Housing As-
sistance Tax Act of 2008 is amended by striking ‘‘and before 
January 1, 2015’’ each place it appears. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall take effect as if included in the enactment of 
section 3005 of the Housing Assistance Tax Act of 2008. 
SEC. 133. EXTENSION OF RIC QUALIFIED INVESTMENT EN-
TITY TREATMENT UNDER FIRPTA. 
(a) IN GENERAL.—Section 897(h)(4)(A) is amended—
1969 
(1) by striking clause (ii), and 
(2) by striking all that precedes ‘‘regulated in-
vestment company which’’ and inserting the fol-
lowing: 
‘‘(A) QUALIFIED INVESTMENT ENTITY.—The 
term ‘qualified investment entity’ means— 
‘‘(i) any real estate investment trust, 
and 
‘‘(ii) any’’. 
(b) EFFECTIVE DATE.— 
(1) IN
GENERAL.—The amendments made by 
this section shall take effect on January 1, 2015. Not-
withstanding the preceding sentence, such amend-
ments shall not apply with respect to the withholding 
requirement under section 1445 of the Internal Rev-
enue Code of 1986 for any payment made before the 
date of the enactment of this Act. 
(2) AMOUNTS WITHHELD ON OR BEFORE DATE 
OF ENACTMENT.—In the case of a regulated invest-
ment company— 
(A) which makes a distribution after De-
cember 31, 2014, and before the date of the enact-
ment of this Act, and 
(B) which would (but for the second sen-
tence of paragraph (1)) have been required to
1970 
withhold with respect to such distribution under 
section 1445 of such Code, 
such investment company shall not be liable to any 
person to whom such distribution was made for any 
amount so withheld and paid over to the Secretary of 
the Treasury. 
Subtitle B—Extensions Through 
2019 
SEC. 141. EXTENSION OF NEW MARKETS TAX CREDIT. 
(a) IN GENERAL.—Section 45D(f)(1)(G) is amended 
by striking ‘‘for 2010, 2011, 2012, 2013, and 2014’’ and 
inserting ‘‘for each of calendar years 2010 through 2019’’. 
(b) CARRYOVER
OF UNUSED LIMITATION.—Section 
45D(f)(3) is amended by striking ‘‘2019’’ and inserting 
‘‘2024’’. 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to calendar years beginning after De-
cember 31, 2014. 
SEC. 142. EXTENSION AND MODIFICATION OF WORK OPPOR-
TUNITY TAX CREDIT. 
(a) IN GENERAL.—Section 51(c)(4) is amended by 
striking ‘‘December 31, 2014’’ and inserting ‘‘December 31, 
2019’’. 
(b) CREDIT FOR HIRING LONG-TERM UNEMPLOYMENT 
RECIPIENTS.—
1971 
(1) IN GENERAL.—Section 51(d)(1) is amended 
by striking ‘‘or’’ at the end of subparagraph (H), by 
striking the period at the end of subparagraph (I) 
and inserting ‘‘, or’’, and by adding at the end the 
following new subparagraph: 
‘‘(J) a qualified long-term unemployment 
recipient.’’. 
(2) QUALIFIED LONG-TERM UNEMPLOYMENT RE-
CIPIENT.—Section 51(d) is amended by adding at the 
end the following new paragraph: 
‘‘(15) QUALIFIED
LONG-TERM
UNEMPLOYMENT 
RECIPIENT.—The term ‘qualified long-term unemploy-
ment recipient’ means any individual who is certified 
by the designated local agency as being in a period 
of unemployment which— 
‘‘(A) is not less than 27 consecutive weeks, 
and 
‘‘(B) includes a period in which the indi-
vidual was receiving unemployment compensa-
tion under State or Federal law.’’. 
(c) EFFECTIVE DATES.— 
(1) EXTENSION.—The amendment made by sub-
section (a) shall apply to individuals who begin work 
for the employer after December 31, 2014.