such individual is not an eligible indi-
vidual, and 
‘‘(II) the tax imposed by this 
chapter for any taxable year on the 
individual shall be increased by 10 
percent of the amount which is so in-
cludible. 
‘‘(ii) EXCEPTION FOR DISABILITY OR 
DEATH.—Subclauses (I) and (II) of clause 
(i) shall not apply if the individual ceased 
to be an eligible individual by reason of the 
death of the individual or the individual 
becoming disabled (within the meaning of 
section 72(m)(7)). 
‘‘(iii) TESTING
PERIOD.—The term 
‘testing period’ means the period beginning 
with the month in which the qualified HSA 
funding distribution is contributed to a 
health savings account and ending on the 
last day of the 12th month following such 
month. 
‘‘(E) APPLICATION OF SECTION 72.—Not-
withstanding section 72, in determining the ex-
tent to which an amount is treated as otherwise 
includible in gross income for purposes of sub-
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paragraph (A), the aggregate amount distrib-
uted from an individual retirement plan shall be 
treated as includible in gross income to the ex-
tent that such amount does not exceed the ag-
gregate amount which would have been so in-
cludible if all amounts from all individual retire-
ment plans were distributed. Proper adjust-
ments shall be made in applying section 72 to 
other distributions in such taxable year and 
subsequent taxable years.’’. 
(b) COORDINATION WITH LIMITATION
ON CON-
TRIBUTIONS TO HSAS.—Section 223(b)(4) (relating to co-
ordination with other contributions) is amended by strik-
ing ‘‘and’’ at the end of subparagraph (A), by striking 
the period at the end of subparagraph (B) and inserting 
‘‘, and’’, and by inserting after subparagraph (B) the fol-
lowing new subparagraph: 
‘‘(C) the aggregate amount contributed to 
health savings accounts of such individual for 
such taxable year under section 408(d)(9) (and 
such amount shall not be allowed as a deduc-
tion under subsection (a)).’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2006. 
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TITLE IV—OTHER PROVISIONS 
SEC. 401. DEDUCTION ALLOWABLE WITH RESPECT TO IN-
COME ATTRIBUTABLE TO DOMESTIC PRO-
DUCTION ACTIVITIES IN PUERTO RICO. 
(a) IN GENERAL.—Subsection (d) of section 199 (re-
lating to definitions and special rules) is amended by re-
designating paragraph (8) as paragraph (9) and by insert-
ing after paragraph (7) the following new paragraph: 
‘‘(8) TREATMENT
OF
ACTIVITIES
IN
PUERTO 
RICO.— 
‘‘(A) IN
GENERAL.—In the case of any 
taxpayer with gross receipts for any taxable 
year from sources within the Commonwealth of 
Puerto Rico, if all of such receipts are taxable 
under section 1 or 11 for such taxable year, 
then for purposes of determining the domestic 
production gross receipts of such taxpayer for 
such taxable year under subsection (c)(4), the 
term ‘United States’ shall include the Common-
wealth of Puerto Rico. 
‘‘(B) SPECIAL RULE FOR APPLYING WAGE 
LIMITATION.—In the case of any taxpayer de-
scribed in subparagraph (A), for purposes of 
applying the limitation under subsection (b) for 
any taxable year, the determination of W–2 
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wages of such taxpayer shall be made without 
regard 
to 
any 
exclusion 
under 
section 
3401(a)(8) for remuneration paid for services 
performed in Puerto Rico. 
‘‘(C) TERMINATION.—This paragraph shall 
apply only with respect to the first 2 taxable 
years of the taxpayer beginning after December 
31, 2005, and before January 1, 2008.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
subsection (a) shall apply to taxable years beginning after 
December 31, 2005. 
SEC. 402. CREDIT FOR PRIOR YEAR MINIMUM TAX LIABIL-
ITY MADE REFUNDABLE AFTER PERIOD OF 
YEARS. 
(a) IN GENERAL.—Section 53 (relating to credit for 
prior year minimum tax liability) is amended by adding 
at the end the following new subsection: 
‘‘(e) SPECIAL RULE FOR INDIVIDUALS WITH LONG- 
TERM UNUSED CREDITS.— 
‘‘(1) IN GENERAL.—If an individual has a long- 
term unused minimum tax credit for any taxable 
year beginning before January 1, 2013, the amount 
determined under subsection (c) for such taxable 
year shall not be less than the AMT refundable cred-
it amount for such taxable year. 
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‘‘(2) AMT REFUNDABLE CREDIT AMOUNT.—For 
purposes of paragraph (1)— 
‘‘(A) IN GENERAL.—The term ‘AMT re-
fundable credit amount’ means, with respect to 
any taxable year, the amount equal to the 
greater of— 
‘‘(i) the lesser of— 
‘‘(I) $5,000, or 
‘‘(II) the amount of long-term 
unused minimum tax credit for such 
taxable year, or 
‘‘(ii) 20 percent of the amount of such 
credit. 
‘‘(B) PHASEOUT
OF
AMT
REFUNDABLE 
CREDIT AMOUNT.— 
‘‘(i) IN GENERAL.—In the case of an 
individual whose adjusted gross income for 
any taxable year exceeds the threshold 
amount (within the meaning of section 
151(d)(3)(C)), the AMT refundable credit 
amount determined under subparagraph 
(A) for such taxable year shall be reduced 
by the applicable percentage (within the 
meaning of section 151(d)(3)(B)). 
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‘‘(ii) ADJUSTED GROSS INCOME.—For 
purposes of clause (i), adjusted gross in-
come shall be determined without regard to 
sections 911, 931, and 933. 
‘‘(3) LONG-TERM UNUSED MINIMUM TAX CRED-
IT.— 
‘‘(A) IN GENERAL.—For purposes of this 
subsection, the term ‘long-term unused min-
imum tax credit’ means, with respect to any 
taxable year, the portion of the minimum tax 
credit determined under subsection (b) attrib-
utable to the adjusted net minimum tax for tax-
able years before the 3rd taxable year imme-
diately preceding such taxable year. 
‘‘(B) 
FIRST-IN, 
FIRST-OUT
ORDERING 
RULE.—For purposes of subparagraph (A), 
credits shall be treated as allowed under sub-
section (a) on a first-in, first-out basis. 
‘‘(4) CREDIT REFUNDABLE.—For purposes of 
this title (other than this section), the credit allowed 
by reason of this subsection shall be treated as if it 
were allowed under subpart C.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Section 6211(b)(4)(A) is amended by strik-
ing ‘‘and 34’’ and inserting ‘‘34, and 53(e)’’. 
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(2) Paragraph (2) of section 1324(b) of title 
31, United States Code, is amended by inserting ‘‘or 
53(e)’’ after ‘‘section 35’’. 
(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. 403. RETURNS REQUIRED IN CONNECTION WITH CER-
TAIN OPTIONS. 
(a) IN GENERAL.—So much of section 6039(a) as fol-
lows paragraph (2) is amended to read as follows: 
‘‘shall, for such calendar year, make a return at such time 
and in such manner, and setting forth such information, 
as the Secretary may by regulations prescribe.’’. 
(b) STATEMENTS TO PERSONS WITH RESPECT TO 
WHOM INFORMATION IS FURNISHED.—Section 6039 is 
amended by redesignating subsections (b) and (c) as sub-
section (c) and (d), respectively, and by inserting after 
subsection (a) the following new subsection: 
‘‘(b) STATEMENTS TO BE FURNISHED TO PERSONS 
WITH
RESPECT
TO
WHOM
INFORMATION
IS
RE-
PORTED.—Every corporation making a return under sub-
section (a) shall furnish to each person whose name is set 
forth in such return a written statement setting forth such 
information as the Secretary may by regulations prescribe. 
The written statement required under the preceding sen-
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tence shall be furnished to such person on or before Janu-
ary 31 of the year following the calendar year for which 
the return under subsection (a) was made.’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 6724(d)(1)(B) is amended by strik-
ing ‘‘or’’ at the end of clause (xvii), by striking 
‘‘and’’ at the end of clause (xviii) and inserting ‘‘or’’, 
and by adding at the end the following new clause: 
‘‘(xix) section 6039(a) (relating to re-
turns required with respect to certain op-
tions), and’’. 
(2) Section 6724(d)(2)(B) is amended by strik-
ing ‘‘section 6039(a)’’ and inserting ‘‘section 
6039(b)’’. 
(3) The heading of section 6039 and the item 
relating to such section in the table of sections of 
subpart A of part III of subchapter A of chapter 61 
of such Code are each amended by striking ‘‘Infor-
mation’’ and inserting ‘‘Returns’’. 
(4) The heading of subsection (a) of section 
6039 is amended by striking ‘‘FURNISHING OF IN-
FORMATION’’ and inserting ‘‘REQUIREMENT OF RE-
PORTING’’. 
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(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to calendar years beginning after 
the date of the enactment of this Act. 
SEC. 404. PARTIAL EXPENSING FOR ADVANCED MINE SAFE-
TY EQUIPMENT. 
(a) IN GENERAL.—Part VI of subchapter B of chap-
ter 1 is amended by inserting after section 179D the fol-
lowing new section: 
‘‘SEC. 179E. ELECTION TO EXPENSE ADVANCED MINE SAFE-
TY EQUIPMENT. 
‘‘(a) TREATMENT AS EXPENSES.—A taxpayer may 
elect to treat 50 percent of the cost of any qualified ad-
vanced mine safety equipment property as an expense 
which is not chargeable to capital account. Any cost so 
treated shall be allowed as a deduction for the taxable year 
in which the qualified advanced mine safety equipment 
property is placed in service. 
‘‘(b) ELECTION.— 
‘‘(1) IN GENERAL.—An election under this sec-
tion for any taxable year shall be made on the tax-
payer’s return of the tax imposed by this chapter for 
the taxable year. Such election shall specify the ad-
vanced mine safety equipment property to which the 
election applies and shall be made in such manner 
as the Secretary may by regulations prescribe. 
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‘‘(2) ELECTION
IRREVOCABLE.—Any election 
made under this section may not be revoked except 
with the consent of the Secretary. 
‘‘(c) QUALIFIED ADVANCED MINE SAFETY EQUIP-
MENT PROPERTY.—For purposes of this section, the term 
‘qualified advanced mine safety equipment property’ 
means any advanced mine safety equipment property for 
use in any underground mine located in the United 
States— 
‘‘(1) the original use of which commences with 
the taxpayer, and 
‘‘(2) which is placed in service by the taxpayer 
after the date of the enactment of this section. 
‘‘(d) ADVANCED MINE SAFETY EQUIPMENT PROP-
ERTY.—For purposes of this section, the term ‘advanced 
mine safety equipment property’ means any of the fol-
lowing: 
‘‘(1) Emergency communication technology or 
device which is used to allow a miner to maintain 
constant communication with an individual who is 
not in the mine. 
‘‘(2) Electronic identification and location de-
vice which allows an individual who is not in the 
mine to track at all times the movements and loca-
tion of miners working in or at the mine. 
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‘‘(3) Emergency oxygen-generating, self-rescue 
device which provides oxygen for at least 90 min-
utes. 
‘‘(4) Pre-positioned supplies of oxygen which (in 
combination with self-rescue devices) can be used to 
provide each miner on a shift, in the event of an ac-
cident or other event which traps the miner in the 
mine or otherwise necessitates the use of such a self- 
rescue device, the ability to survive for at least 48 
hours. 
‘‘(5) Comprehensive atmospheric monitoring 
system which monitors the levels of carbon mon-
oxide, methane, and oxygen that are present in all 
areas of the mine and which can detect smoke in the 
case of a fire in a mine. 
‘‘(e) COORDINATION WITH SECTION 179.—No ex-
penditures shall be taken into account under subsection 
(a) with respect to the portion of the cost of any property 
specified in an election under section 179. 
‘‘(f) REPORTING.—No deduction shall be allowed 
under subsection (a) to any taxpayer for any taxable year 
unless such taxpayer files with the Secretary a report con-
taining such information with respect to the operation of 
the mines of the taxpayer as the Secretary shall require. 
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‘‘(g) TERMINATION.—This section shall not apply to 
property placed in service after December 31, 2008.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Section 263(a)(1) is amended by striking 
‘‘or’’ at the end of subparagraph (J), by striking the 
period at the end of subparagraph (K) and inserting 
‘‘, or’’, and by inserting after subparagraph (K) the 
following new subparagraph: 
‘‘(L) expenditures for which a deduction is 
allowed under section 179E.’’. 
(2) Section 312(k)(3)(B) is amended by strik-
ing ‘‘or 179D’’ each place it appears in the heading 
and text thereof and inserting ‘‘179D, or 179E’’. 
(3) Paragraphs (2)(C) and (3)(C) of section 
1245(a) are each amended by inserting ‘‘179E,’’ 
after ‘‘179D,’’. 
(4) The table of sections for part VI of sub-
chapter B of chapter 1 is amended by inserting after 
the item relating to section 179D the following new 
item: 
‘‘Sec. 179E. Election to expense advanced mine safety equipment.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to costs paid or incurred after the 
date of the enactment of this Act. 
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SEC. 405. MINE RESCUE TEAM TRAINING TAX CREDIT. 
(a) IN GENERAL.—Subpart D of part IV of sub-
chapter A of chapter 1 (relating to business related cred-
its) is amended by adding at the end the following new 
section: 
‘‘SEC. 45N. MINE RESCUE TEAM TRAINING CREDIT. 
‘‘(a) AMOUNT OF CREDIT.—For purposes of section 
38, the mine rescue team training credit determined under 
this section with respect to each qualified mine rescue 
team employee of an eligible employer for any taxable year 
is an amount equal to the lesser of— 
‘‘(1) 20 percent of the amount paid or incurred 
by the taxpayer during the taxable year with respect 
to the training program costs of such qualified mine 
rescue team employee (including wages of such em-
ployee while attending such program), or 
‘‘(2) $10,000. 
‘‘(b) QUALIFIED MINE RESCUE TEAM EMPLOYEE.— 
For purposes of this section, the term ‘qualified mine res-
cue team employee’ means with respect to any taxable year 
any full-time employee of the taxpayer who is— 
‘‘(1) a miner eligible for more than 6 months 
of such taxable year to serve as a mine rescue team 
member as a result of completing, at a minimum, an 
initial 20-hour course of instruction as prescribed by 
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the Mine Safety and Health Administration’s Office 
of Educational Policy and Development, or 
‘‘(2) a miner eligible for more than 6 months 
of such taxable year to serve as a mine rescue team 
member by virtue of receiving at least 40 hours of 
refresher training in such instruction. 
‘‘(c) ELIGIBLE EMPLOYER.—For purposes of this 
section, the term ‘eligible employer’ means any taxpayer 
which employs individuals as miners in underground mines 
in the United States. 
‘‘(d) WAGES.—For purposes of this section, the term 
‘wages’ has the meaning given to such term by subsection 
(b) of section 3306 (determined without regard to any dol-
lar limitation contained in such section). 
‘‘(e) TERMINATION.—This section shall not apply to 
taxable years beginning after December 31, 2008.’’. 
(b) CREDIT MADE PART OF GENERAL BUSINESS 
CREDIT.—Section 38(b) is amended by striking ‘‘and’’ at 
the end of paragraph (29), by striking the period at the 
end of paragraph (30) and inserting ‘‘, plus’’, and by add-
ing at the end the following new paragraph: 
‘‘(31) the mine rescue team training credit de-
termined under section 45N(a).’’. 
(c) NO DOUBLE BENEFIT.—Section 280C is amend-
ed by adding at the end the following new subsection: 
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‘‘(e) MINE RESCUE TEAM TRAINING CREDIT.—No 
deduction shall be allowed for that portion of the expenses 
otherwise allowable as a deduction for the taxable year 
which is equal to the amount of the credit determined for 
the taxable year under section 45N(a).’’. 
(d) CLERICAL AMENDMENT.—The table of sections 
for subpart D of part IV of subchapter A of chapter 1 
is amended by adding at the end the following new item: 
‘‘Sec. 45N. Mine rescue team training credit.’’. 
(e) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2005. 
SEC. 406. WHISTLEBLOWER REFORMS. 
(a) AWARDS TO WHISTLEBLOWERS.— 
(1) IN GENERAL.—Section 7623 (relating to ex-
penses of detection of underpayments and fraud, 
etc.) is amended— 
(A) by striking ‘‘The Secretary’’ and in-
serting ‘‘(a) IN GENERAL.—The Secretary’’, 
(B) by striking ‘‘and’’ at the end of para-
graph (1) and inserting ‘‘or’’, 
(C) by striking ‘‘(other than interest)’’, 
and 
(D) by adding at the end the following new 
subsection: 
‘‘(b) AWARDS TO WHISTLEBLOWERS.— 
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‘‘(1) IN GENERAL.—If the Secretary proceeds 
with any administrative or judicial action described 
in subsection (a) based on information brought to 
the Secretary’s attention by an individual, such indi-
vidual shall, subject to paragraph (2), receive as an 
award at least 15 percent but not more than 30 per-
cent of the collected proceeds (including penalties, 
interest, additions to tax, and additional amounts) 
resulting from the action (including any related ac-
tions) or from any settlement in response to such ac-
tion. The determination of the amount of such 
award by the Whistleblower Office shall depend upon 
the extent to which the individual substantially con-
tributed to such action. 
‘‘(2) AWARD IN CASE OF LESS SUBSTANTIAL 
CONTRIBUTION.— 
‘‘(A) IN GENERAL.—In the event the ac-
tion described in paragraph (1) is one which the 
Whistleblower Office determines to be based 
principally on disclosures of specific allegations 
(other than information provided by the indi-
vidual described in paragraph (1)) resulting 
from a judicial or administrative hearing, from 
a governmental report, hearing, audit, or inves-
tigation, or from the news media, the Whistle-
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blower Office may award such sums as it con-
siders appropriate, but in no case more than 10 
percent of the collected proceeds (including pen-
alties, interest, additions to tax, and additional 
amounts) resulting from the action (including 
any related actions) or from any settlement in 
response to such action, taking into account the 
significance of the individual’s information and 
the role of such individual and any legal rep-
resentative of such individual in contributing to 
such action. 
‘‘(B) NONAPPLICATION
OF
PARAGRAPH 
WHERE INDIVIDUAL IS ORIGINAL SOURCE OF 
INFORMATION.—Subparagraph (A) shall not 
apply if the information resulting in the initi-
ation of the action described in paragraph (1) 
was originally provided by the individual de-
scribed in paragraph (1). 
‘‘(3) REDUCTION IN OR DENIAL OF AWARD.— 
If the Whistleblower Office determines that the 
claim for an award under paragraph (1) or (2) is 
brought by an individual who planned and initiated 
the actions that led to the underpayment of tax or 
actions described in subsection (a)(2), then the 
Whistleblower Office may appropriately reduce such 
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