Subtitle B—Other Provisions 
SEC. 231. 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
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. 232. 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.
‘‘(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)).
‘‘(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)’’.