H. R. 3221—239 
‘‘(C) in the case of any taxable year beginning in 2008, 
the real property tax deduction.’’. 
(b) DEFINITION.—Section 63(c) is amended by adding at the 
end the following new paragraph: 
‘‘(7) REAL PROPERTY TAX DEDUCTION.—For purposes of para-
graph (1), the real property tax deduction is the lesser of— 
‘‘(A) the amount allowable as a deduction under this 
chapter for State and local taxes described in section 
164(a)(1), or 
‘‘(B) $500 ($1,000 in the case of a joint return). 
Any taxes taken into account under section 62(a) shall not 
be taken into account under this paragraph.’’. 
(c) EFFECTIVE DATE.—The amendments made by this section 
shall apply to taxable years beginning after December 31, 2007. 
Subtitle C—General Provisions 
SEC. 3021. TEMPORARY LIBERALIZATION OF TAX-EXEMPT HOUSING 
BOND RULES. 
(a) TEMPORARY INCREASE IN VOLUME CAP.— 
(1) IN GENERAL.—Subsection (d) of section 146 is amended 
by adding at the end the following new paragraph: 
‘‘(5) INCREASE
AND
SET
ASIDE
FOR
HOUSING
BONDS
FOR 
2008.— 
‘‘(A) INCREASE FOR 2008.—In the case of calendar year 
2008, the State ceiling for each State shall be increased 
by an amount equal to $11,000,000,000 multiplied by a 
fraction— 
‘‘(i) the numerator of which is the State ceiling 
applicable to the State for calendar year 2008, deter-
mined without regard to this paragraph, and 
‘‘(ii) the denominator of which is the sum of the 
State ceilings determined under clause (i) for all States. 
‘‘(B) SET ASIDE.— 
‘‘(i) IN GENERAL.—Any amount of the State ceiling 
for any State which is attributable to an increase under 
this paragraph shall be allocated solely for one or 
more qualified housing issues. 
‘‘(ii) QUALIFIED HOUSING ISSUE.—For purposes of 
this paragraph, the term ‘qualified housing issue’ 
means— 
‘‘(I) an issue described in section 142(a)(7) 
(relating to qualified residential rental projects), 
or 
‘‘(II) a qualified mortgage issue (determined 
by substituting ‘12-month period’ for ‘42-month 
period’ 
each 
place 
it 
appears 
in 
section 
143(a)(2)(D)(i)).’’. 
(2) CARRYFORWARD OF UNUSED LIMITATIONS.—Subsection 
(f) of section 146 is amended by adding at the end the following 
new paragraph: 
‘‘(6) SPECIAL RULES FOR INCREASED VOLUME CAP UNDER 
SUBSECTION (d)(5).—No amount which is attributable to the 
increase under subsection (d)(5) may be used— 
‘‘(A) for any issue other than a qualified housing issue 
(as defined in subsection (d)(5)), or
H. R. 3221—240 
‘‘(B) to issue any bond after calendar year 2010.’’. 
(b) TEMPORARY RULE FOR USE OF QUALIFIED MORTGAGE BONDS 
PROCEEDS FOR SUBPRIME REFINANCING LOANS.— 
(1) IN GENERAL.—Section 143(k) (relating to other defini-
tions and special rules) is amended by adding at the end 
the following new paragraph: 
‘‘(12) SPECIAL RULES FOR SUBPRIME REFINANCINGS.— 
‘‘(A) IN GENERAL.—Notwithstanding the requirements 
of subsection (i)(1), the proceeds of a qualified mortgage 
issue may be used to refinance a mortgage on a residence 
which was originally financed by the mortgagor through 
a qualified subprime loan. 
‘‘(B) SPECIAL
RULES.—In applying subparagraph (A) 
to any refinancing— 
‘‘(i) subsection (a)(2)(D)(i) shall be applied by sub-
stituting ‘12-month period’ for ‘42-month period’ each 
place it appears, 
‘‘(ii) subsection (d) (relating to 3-year requirement) 
shall not apply, and 
‘‘(iii) subsection (e) (relating to purchase price 
requirement) shall be applied by using the market 
value of the residence at the time of refinancing in 
lieu of the acquisition cost. 
‘‘(C) QUALIFIED SUBPRIME LOAN.—The term ‘qualified 
subprime loan’ means an adjustable rate single-family resi-
dential mortgage loan made after December 31, 2001, and 
before January 1, 2008, that the bond issuer determines 
would be reasonably likely to cause financial hardship to 
the borrower if not refinanced. 
‘‘(D) TERMINATION.—This paragraph shall not apply 
to any bonds issued after December 31, 2010.’’. 
(c) EFFECTIVE DATE.—The amendments made by this section 
shall apply to bonds issued after the date of the enactment of 
this Act. 
SEC. 3022. REPEAL OF ALTERNATIVE MINIMUM TAX LIMITATIONS ON 
TAX-EXEMPT HOUSING BONDS, LOW-INCOME HOUSING 
TAX CREDIT, AND REHABILITATION CREDIT. 
(a) TAX-EXEMPT
INTEREST
ON
CERTAIN
HOUSING
BONDS 
EXEMPTED FROM ALTERNATIVE MINIMUM TAX.— 
(1) IN
GENERAL.—Subparagraph (C) of section 57(a)(5) 
(relating to specified private activity bonds) is amended by 
redesignating clauses (iii) and (iv) as clauses (iv) and (v), respec-
tively, and by inserting after clause (ii) the following new 
clause: 
‘‘(iii) EXCEPTION FOR CERTAIN HOUSING BONDS.— 
For purposes of clause (i), the term ‘private activity 
bond’ shall not include any bond issued after the date 
of the enactment of this clause if such bond is— 
‘‘(I) an exempt facility bond issued as part 
of an issue 95 percent or more of the net proceeds 
of which are to be used to provide qualified residen-
tial rental projects (as defined in section 142(d)), 
‘‘(II) a qualified mortgage bond (as defined 
in section 143(a)), or 
‘‘(III) a qualified veterans’ mortgage bond (as 
defined in section 143(b)).
H. R. 3221—241 
The preceding sentence shall not apply to any 
refunding bond unless such preceding sentence applied 
to the refunded bond (or in the case of a series of 
refundings, the original bond).’’. 
(2) NO ADJUSTMENT TO ADJUSTED CURRENT EARNINGS.— 
Subparagraph (B) of section 56(g)(4) is amended by adding 
at the end the following new clause: 
‘‘(iii) TAX EXEMPT INTEREST ON CERTAIN HOUSING 
BONDS.—Clause (i) shall not apply in the case of any 
interest on a bond to which section 57(a)(5)(C)(iii) 
applies.’’. 
(b) ALLOWANCE
OF LOW-INCOME HOUSING CREDIT AGAINST 
ALTERNATIVE MINIMUM TAX.—Subparagraph (B) of section 38(c)(4) 
(relating to specified credits) is amended by redesignating clauses 
(ii) through (iv) as clauses (iii) through (v) and inserting after 
clause (i) the following new clause: 
‘‘(ii) the credit determined under section 42 to the 
extent attributable to buildings placed in service after 
December 31, 2007,’’. 
(c) ALLOWANCE
OF REHABILITATION CREDIT AGAINST ALTER-
NATIVE MINIMUM TAX.—Subparagraph (B) of section 38(c)(4), as 
amended by subsection (b), is amended by striking ‘‘and’’ at the 
end of clause (iv), by redesignating clause (v) as clause (vi), and 
by inserting after clause (iv) the following new clause: 
‘‘(v) the credit determined under section 47 to the 
extent attributable to qualified rehabilitation expendi-
tures properly taken into account for periods after 
December 31, 2007, and’’. 
(d) EFFECTIVE DATE.— 
(1) HOUSING BONDS.—The amendments made by subsection 
(a) shall apply to bonds issued after the date of the enactment 
of this Act. 
(2) LOW INCOME HOUSING CREDIT.—The amendments made 
by subsection (b) shall apply to credits determined under section 
42 of the Internal Revenue Code of 1986 to the extent attrib-
utable to buildings placed in service after December 31, 2007. 
(3) REHABILITATION
CREDIT.—The amendments made by 
subsection (c) shall apply to credits determined under section 
47 of the Internal Revenue Code of 1986 to the extent attrib-
utable to qualified rehabilitation expenditures properly taken 
into account for periods after December 31, 2007. 
SEC. 3023. BONDS GUARANTEED BY FEDERAL HOME LOAN BANKS 
ELIGIBLE FOR TREATMENT AS TAX-EXEMPT BONDS. 
(a) IN
GENERAL.—Subparagraph (A) of section 149(b)(3) 
(relating to exceptions for certain insurance programs) is amended 
by striking ‘‘or’’ at the end of clause (ii), by striking the period 
at the end of clause (iii) and inserting ‘‘, or’’ and by adding at 
the end the following new clause: 
‘‘(iv) subject to subparagraph (E), any guarantee 
by a Federal home loan bank made in connection with 
the original issuance of a bond during the period begin-
ning on the date of the enactment of this clause and 
ending on December 31, 2010 (or a renewal or exten-
sion of a guarantee so made).’’.
H. R. 3221—242 
(b) SAFETY AND SOUNDNESS REQUIREMENTS.—Paragraph (3) of 
section 149(b) is amended by adding at the end the following new 
subparagraph: 
‘‘(E) SAFETY AND SOUNDNESS REQUIREMENTS FOR FED-
ERAL HOME LOAN BANKS.—Clause (iv) of subparagraph (A) 
shall not apply to any guarantee by a Federal home loan 
bank unless such bank meets safety and soundness collat-
eral requirements for such guarantees which are at least 
as stringent as such requirements which apply under regu-
lations applicable to such guarantees by Federal home 
loan banks as in effect on April 9, 2008.’’. 
(c) EFFECTIVE DATE.—The amendments made by this section 
shall apply to guarantees made after the date of the enactment 
of this Act. 
SEC. 3024. MODIFICATION OF RULES PERTAINING TO FIRPTA NONFOR-
EIGN AFFIDAVITS. 
(a) IN GENERAL.—Subsection (b) of section 1445 (relating to 
exemptions) is amended by adding at the end the following: 
‘‘(9) ALTERNATIVE PROCEDURE FOR FURNISHING NONFOREIGN 
AFFIDAVIT.—For purposes of paragraphs (2) and (7)— 
‘‘(A) IN GENERAL.—Paragraph (2) shall be treated as 
applying to a transaction if, in connection with a disposition 
of a United States real property interest— 
‘‘(i) the affidavit specified in paragraph (2) is fur-
nished to a qualified substitute, and 
‘‘(ii) the qualified substitute furnishes a statement 
to the transferee stating, under penalty of perjury, 
that the qualified substitute has such affidavit in his 
possession. 
‘‘(B) REGULATIONS.—The Secretary shall prescribe such 
regulations as may be necessary or appropriate to carry 
out this paragraph.’’. 
(b) QUALIFIED SUBSTITUTE.—Subsection (f) of section 1445 
(relating to definitions) is amended by adding at the end the fol-
lowing new paragraph: 
‘‘(6) QUALIFIED SUBSTITUTE.—The term ‘qualified substitute’ 
means, with respect to a disposition of a United States real 
property interest— 
‘‘(A) the person (including any attorney or title com-
pany) responsible for closing the transaction, other than 
the transferor’s agent, and 
‘‘(B) the transferee’s agent.’’. 
(c) EXEMPTION NOT TO APPLY IF KNOWLEDGE OR NOTICE THAT 
AFFIDAVIT OR STATEMENT IS FALSE.— 
(1) IN GENERAL.—Paragraph (7) of section 1445(b) (relating 
to special rules for paragraphs (2) and (3)) is amended to 
read as follows: 
‘‘(7) SPECIAL RULES FOR PARAGRAPHS (2), (3), AND (9).—Para-
graph (2), (3), or (9) (as the case may be) shall not apply 
to any disposition— 
‘‘(A) if— 
‘‘(i) the transferee or qualified substitute has actual 
knowledge that the affidavit referred to in such para-
graph, or the statement referred to in paragraph 
(9)(A)(ii), is false, or
H. R. 3221—243 
‘‘(ii) the transferee or qualified substitute receives 
a notice (as described in subsection (d)) from a trans-
feror’s agent, transferee’s agent, or qualified substitute 
that such affidavit or statement is false, or 
‘‘(B) if the Secretary by regulations requires the trans-
feree or qualified substitute to furnish a copy of such affi-
davit or statement to the Secretary and the transferee 
or qualified substitute fails to furnish a copy of such affi-
davit or statement to the Secretary at such time and in 
such manner as required by such regulations.’’. 
(2) LIABILITY.— 
(A) NOTICE.—Paragraph (1) of section 1445(d) (relating 
to notice of false affidavit; foreign corporations) is amended 
to read as follows: 
‘‘(1) NOTICE OF FALSE AFFIDAVIT; FOREIGN CORPORATIONS.— 
If— 
‘‘(A) the transferor furnishes the transferee or qualified 
substitute an affidavit described in paragraph (2) of sub-
section (b) or a domestic corporation furnishes the trans-
feree an affidavit described in paragraph (3) of subsection 
(b), and 
‘‘(B) in the case of— 
‘‘(i) any transferor’s agent— 
‘‘(I) such agent has actual knowledge that such 
affidavit is false, or 
‘‘(II) in the case of an affidavit described in 
subsection (b)(2) furnished by a corporation, such 
corporation is a foreign corporation, or 
‘‘(ii) any transferee’s agent or qualified substitute, 
such agent or substitute has actual knowledge that 
such affidavit is false, 
such agent or qualified substitute shall so notify the trans-
feree at such time and in such manner as the Secretary 
shall require by regulations.’’. 
(B) FAILURE
TO
FURNISH
NOTICE.—Paragraph (2) of 
section 1445(d) (relating to failure to furnish notice) is 
amended to read as follows: 
‘‘(2) FAILURE TO FURNISH NOTICE.— 
‘‘(A) IN
GENERAL.—If any transferor’s agent, trans-
feree’s agent, or qualified substitute is required by para-
graph (1) to furnish notice, but fails to furnish such notice 
at such time or times and in such manner as may be 
required by regulations, such agent or substitute shall have 
the same duty to deduct and withhold that the transferee 
would have had if such agent or substitute had complied 
with paragraph (1). 
‘‘(B) LIABILITY
LIMITED
TO
AMOUNT
OF
COMPENSA-
TION.—An agent’s or substitute’s liability under subpara-
graph (A) shall be limited to the amount of compensation 
the agent or substitute derives from the transaction.’’. 
(C) CONFORMING AMENDMENT.—The heading for sec-
tion 1445(d) is amended by striking ‘‘OR TRANSFEREE’S 
AGENTS’’ and inserting ‘‘, TRANSFEREE’S AGENTS, OR QUALI-
FIED SUBSTITUTES’’. 
(d) EFFECTIVE DATE.—The amendments made by this section 
shall apply to dispositions of United States real property interests 
after the date of the enactment of this Act.
H. R. 3221—244 
SEC. 3025. MODIFICATION OF DEFINITION OF TAX-EXEMPT USE PROP-
ERTY FOR PURPOSES OF THE REHABILITATION CREDIT. 
(a) IN GENERAL.—Subclause (I) of section 47(c)(2)(B)(v) is 
amended by striking ‘‘section 168(h)’’ and inserting ‘‘section 168(h), 
except that ‘50 percent’ shall be substituted for ‘35 percent’ in 
paragraph (1)(B)(iii) thereof’’. 
(b) EFFECTIVE DATE.—The amendments made by this section 
shall apply to expenditures properly taken into account for periods 
after December 31, 2007. 
SEC. 3026. EXTENSION OF SPECIAL RULE FOR MORTGAGE REVENUE 
BONDS FOR RESIDENCES LOCATED IN DISASTER AREAS. 
(a) IN GENERAL.—Paragraph (11) of section 143(k) is amended— 
(1) by striking ‘‘December 31, 1996’’ and inserting ‘‘May 
1, 2008’’, and 
(2) by striking ‘‘January 1, 1999’’ and inserting ‘‘January 
1, 2010’’. 
(b) EFFECTIVE DATE.—The amendments made by this section 
shall apply to bonds issued after May 1, 2008. 
SEC. 3027. TRANSFER OF FUNDS APPROPRIATED TO CARRY OUT 2008 
RECOVERY REBATES FOR INDIVIDUALS. 
Of the funds made available by section 101(e)(1)(A) of the 
Economic Stimulus Act of 2008 (Public Law 110-185), the Secretary 
of the Treasury may transfer funds among the accounts specified 
in such section to carry out section 6428 of the Internal Revenue 
Code of 1986. The Secretary shall provide advance notification 
of any such transfer to the Committees on Appropriations of the 
House of Representatives and the Senate, and any transfer greater 
than $5,000,000 shall be subject to the approval of such Committees. 
TITLE II—REFORMS RELATED TO REAL 
ESTATE INVESTMENT TRUSTS 
Subtitle A—Foreign Currency and Other 
Qualified Activities 
SEC. 3031. REVISIONS TO REIT INCOME TESTS. 
(a) FOREIGN CURRENCY GAINS NOT GROSS INCOME IN APPLYING 
REIT INCOME TESTS.—Section 856 (defining real estate investment 
trust) is amended by adding at the end the following new subsection: 
‘‘(n) RULES REGARDING FOREIGN CURRENCY TRANSACTIONS.— 
‘‘(1) IN GENERAL.—For purposes of this part— 
‘‘(A) passive foreign exchange gain for any taxable year 
shall not constitute gross income for purposes of subsection 
(c)(2), and 
‘‘(B) real estate foreign exchange gain for any taxable 
year shall not constitute gross income for purposes of sub-
section (c)(3). 
‘‘(2) REAL ESTATE FOREIGN EXCHANGE GAIN.—For purposes 
of this subsection, the term ‘real estate foreign exchange gain’ 
means— 
‘‘(A) foreign currency gain (as defined in section 
988(b)(1)) which is attributable to—
H. R. 3221—245 
‘‘(i) any item of income or gain described in sub-
section (c)(3), 
‘‘(ii) the acquisition or ownership of obligations 
secured by mortgages on real property or on interests 
in real property (other than foreign currency gain 
attributable to any item of income or gain described 
in clause (i)), or 
‘‘(iii) becoming or being the obligor under obliga-
tions secured by mortgages on real property or on 
interests in real property (other than foreign currency 
gain attributable to any item of income or gain 
described in clause (i)), 
‘‘(B) section 987 gain attributable to a qualified busi-
ness unit (as defined by section 989) of the real estate 
investment trust, but only if such qualified business unit 
meets the requirements under— 
‘‘(i) subsection (c)(3) for the taxable year, and 
‘‘(ii) subsection (c)(4)(A) at the close of each quarter 
that the real estate investment trust has directly or 
indirectly held the qualified business unit, and 
‘‘(C) any other foreign currency gain as determined 
by the Secretary. 
‘‘(3) PASSIVE FOREIGN EXCHANGE GAIN.—For purposes of 
this subsection, the term ‘passive foreign exchange gain’ 
means— 
‘‘(A) real estate foreign exchange gain, 
‘‘(B) foreign currency gain (as defined in section 
988(b)(1)) which is not described in subparagraph (A) and 
which is attributable to— 
‘‘(i) any item of income or gain described in sub-
section (c)(2), 
‘‘(ii) the acquisition or ownership of obligations 
(other than foreign currency gain attributable to any 
item of income or gain described in clause (i)), or 
‘‘(iii) becoming or being the obligor under obliga-
tions (other than foreign currency gain attributable 
to any item of income or gain described in clause 
(i)), and 
‘‘(C) any other foreign currency gain as determined 
by the Secretary. 
‘‘(4) EXCEPTION FOR INCOME FROM SUBSTANTIAL AND REG-
ULAR TRADING.—Notwithstanding this subsection or any other 
provision of this part, any section 988 gain derived by a corpora-
tion, trust, or association from dealing, or engaging in substan-
tial and regular trading, in securities (as defined in section 
475(c)(2)) shall constitute gross income which does not qualify 
under paragraph (2) or (3) of subsection (c). This paragraph 
shall not apply to income which does not constitute gross income 
by reason of subsection (c)(5)(G).’’. 
(b) ADDITION TO REIT HEDGING RULE.—Subparagraph (G) of 
section 856(c)(5) is amended to read as follows: 
‘‘(G) TREATMENT OF CERTAIN HEDGING INSTRUMENTS.— 
Except to the extent as determined by the Secretary— 
‘‘(i) any income of a real estate investment trust 
from a hedging transaction (as defined in clause (ii) 
or (iii) of section 1221(b)(2)(A)) which is clearly identi-
fied pursuant to section 1221(a)(7), including gain from
H. R. 3221—246 
the sale or disposition of such a transaction, shall 
not constitute gross income under paragraphs (2) and 
(3) to the extent that the transaction hedges any 
indebtedness incurred or to be incurred by the trust 
to acquire or carry real estate assets, and 
‘‘(ii) any income of a real estate investment trust 
from a transaction entered into by the trust primarily 
to manage risk of currency fluctuations with respect 
to any item of income or gain described in paragraph 
(2) or (3) (or any property which generates such income 
or gain), including gain from the termination of such 
a transaction, shall not constitute gross income under 
paragraphs (2) and (3), but only if such transaction 
is clearly identified as such before the close of the 
day on which it was acquired, originated, or entered 
into (or such other time as the Secretary may pre-
scribe).’’. 
(c) AUTHORITY
TO EXCLUDE ITEMS
OF INCOME FROM REIT 
INCOME TESTS.—Section 856(c)(5) is amended by adding at the 
end the following new subparagraph: 
‘‘(J) SECRETARIAL AUTHORITY TO EXCLUDE OTHER ITEMS 
OF INCOME.—To the extent necessary to carry out the pur-
poses of this part, the Secretary is authorized to determine, 
solely for purposes of this part, whether any item of income 
or gain which— 
‘‘(i) does not otherwise qualify under paragraph 
(2) or (3) may be considered as not constituting gross 
income for purposes of paragraphs (2) or (3), or 
‘‘(ii) otherwise constitutes gross income not quali-
fying under paragraph (2) or (3) may be considered 
as gross income which qualifies under paragraph (2) 
or (3).’’. 
SEC. 3032. REVISIONS TO REIT ASSET TESTS. 
(a) CLARIFICATION OF VALUATION TEST.—The first sentence in 
the matter following section 856(c)(4)(B)(iii)(III) is amended by 
inserting ‘‘(including a discrepancy caused solely by the change 
in the foreign currency exchange rate used to value a foreign 
asset)’’ after ‘‘such requirements’’. 
(b) CLARIFICATION OF PERMISSIBLE ASSET CATEGORY.—Section 
856(c)(5), as amended by section 3031(c), is amended by adding 
at the end the following new subparagraph: 
‘‘(K) CASH.—If the real estate investment trust or its 
qualified business unit (as defined in section 989) uses 
any foreign currency as its functional currency (as defined 
in section 985(b)), the term ‘cash’ includes such foreign 
currency but only to the extent such foreign currency— 
‘‘(i) is held for use in the normal course of the 
activities of the trust or qualified business unit which 
give rise to items of income or gain described in para-
graph (2) or (3) of subsection (c) or are directly related 
to acquiring or holding assets described in subsection 
(c)(4), and 
‘‘(ii) is not held in connection with an activity 
described in subsection (n)(4).’’.
H. R. 3221—247 
SEC. 3033. CONFORMING FOREIGN CURRENCY REVISIONS. 
(a) NET INCOME FROM FORECLOSURE PROPERTY.—Clause (i) 
of section 857(b)(4)(B) is amended to read as follows: 
‘‘(i) gain (including any foreign currency gain, as 
defined in section 988(b)(1)) from the sale or other 
disposition of foreclosure property described in section 
1221(a)(1) and the gross income for the taxable year 
derived from foreclosure property (as defined in section 
856(e)), but only to the extent such gross income is 
not described in (or, in the case of foreign currency 
gain, not attributable to gross income described in) 
section 856(c)(3) other than subparagraph (F) thereof, 
over’’. 
(b) NET INCOME FROM PROHIBITED TRANSACTIONS.—Clause (i) 
of section 857(b)(6)(B) is amended to read as follows: 
‘‘(i) the term ‘net income derived from prohibited 
transactions’ means the excess of the gain (including 
any foreign currency gain, as defined in section 
988(b)(1)) from prohibited transactions over the deduc-
tions (including any foreign currency loss, as defined 
in section 988(b)(2)) allowed by this chapter which 
are directly connected with prohibited transactions;’’. 
Subtitle B—Taxable REIT Subsidiaries 
SEC. 3041. CONFORMING TAXABLE REIT SUBSIDIARY ASSET TEST. 
Section 856(c)(4)(B)(ii) is amended— 
(1) by striking ‘‘20 percent’’ and inserting ‘‘25 percent’’, 
and 
(2) by striking ‘‘REIT subsidiaries’’ and all that follows, 
and inserting ‘‘REIT subsidiaries,’’. 
Subtitle C—Dealer Sales 
SEC. 3051. HOLDING PERIOD UNDER SAFE HARBOR. 
(a) IN GENERAL.—Section 857(b)(6) (relating to income from 
prohibited transactions) is amended— 
(1) by striking ‘‘4 years’’ in subparagraphs (C)(i), (C)(iv), 
and (D)(i) and inserting ‘‘2 years’’, 
(2) by striking ‘‘4-year period’’ in subparagraphs (C)(ii), 
(D)(ii), and (D)(iii) and inserting ‘‘2-year period’’, and 
(3) by striking ‘‘real estate asset’’and all that follows 
through ‘‘if’’ in the matter preceding clause (i) of subparagraphs 
(C) and (D), respectively, and inserting ‘‘real estate asset (as 
defined in section 856(c)(5)(B)) and which is described in section 
1221(a)(1) if’’. 
(b) RETENTION
OF
EXISTING
LAW.—Section 857(b)(6) is 
amended— 
(1) by striking subparagraph (G) and redesignating sub-
paragraphs (H) and (I) as subparagraphs (G) and (H), respec-
tively, and 
(2) in subparagraph (G), as so redesignated, by adding 
at the end the following: ‘‘For purposes of the preceding sen-
tence, the reference to subparagraph (D) shall be a reference
H. R. 3221—248 
to such subparagraph as in effect on the day before the enact-
ment of the Housing Assistance Tax Act of 2008, as modified 
by subparagraph (G) as so in effect.’’. 
SEC. 3052. DETERMINING VALUE OF SALES UNDER SAFE HARBOR. 
Section 857(b)(6) is amended— 
(1) by striking the semicolon at the end of subparagraph 
(C)(iii) and inserting ‘‘, or (III) the fair market value of property 
(other than sales of foreclosure property or sales to which 
section 1033 applies) sold during the taxable year does not 
exceed 10 percent of the fair market value of all of the assets 
of the trust as of the beginning of the taxable year;’’, and 
(2) by adding ‘‘or’’ at the end of subclause (II) of subpara-
graph (D)(iv) and by adding at the end of such subparagraph 
the following new subclause: 
‘‘(III) the fair market value of property (other than 
sales of foreclosure property or sales to which section 
1033 applies) sold during the taxable year does not 
exceed 10 percent of the fair market value of all of 
the assets of the trust as of the beginning of the 
taxable year,’’. 
Subtitle D—Health Care REITs 
SEC. 3061. CONFORMITY FOR HEALTH CARE FACILITIES. 
(a) RELATED PARTY RENTALS.—Subparagraph (B) of section 
856(d)(8) (relating to special rule for taxable REIT subsidiaries) 
is amended to read as follows: 
‘‘(B) EXCEPTION FOR CERTAIN LODGING FACILITIES AND 
HEALTH
CARE
PROPERTY.—The 
requirements 
of 
this 
subparagraph are met with respect to an interest in real 
property which is a qualified lodging facility (as defined 
in paragraph (9)(D)) or a qualified health care property 
(as defined in subsection (e)(6)(D)(i)) leased by the trust 
to a taxable REIT subsidiary of the trust if the property 
is operated on behalf of such subsidiary by a person who 
is an eligible independent contractor. For purposes of this 
section, a taxable REIT subsidiary is not considered to 
be operating or managing a qualified health care property 
or qualified lodging facility solely because it— 
‘‘(i) directly or indirectly possesses a license, 
permit, or similar instrument enabling it to do so, 
or 
‘‘(ii) employs individuals working at such facility 
or property located outside the United States, but only 
if an eligible independent contractor is responsible for 
the daily supervision and direction of such individuals 
on behalf of the taxable REIT subsidiary pursuant 
to a management agreement or similar service con-
tract.’’. 
(b) ELIGIBLE INDEPENDENT CONTRACTOR.—Subparagraphs (A) 
and (B) of section 856(d)(9) (relating to eligible independent con-
tractor) are amended to read as follows: 
‘‘(A) IN GENERAL.—The term ‘eligible independent con-
tractor’ means, with respect to any qualified lodging facility 
or qualified health care property (as defined in subsection
H. R. 3221—252 
amount allocated to such limitation for all pre-
ceding taxable years. 
‘‘(iii) BUSINESS
CREDIT
INCREASE
AMOUNT.—For 
purposes of this paragraph, the term ‘business credit 
increase amount’ means the amount equal to the por-
tion of the credit allowable under section 38 (deter-
mined without regard to subsection (c) thereof) for 
the first taxable year ending after March 31, 2008, 
which is allocable to business credit carryforwards to 
such taxable year which are— 
‘‘(I) from taxable years beginning before 
January 1, 2006, and 
‘‘(II) properly allocable (determined under the 
rules of section 38(d)) to the research credit deter-
mined under section 41(a). 
‘‘(iv) AMT CREDIT
INCREASE
AMOUNT.—For pur-
poses of this paragraph, the term ‘AMT credit increase 
amount’ means the amount equal to the portion of 
the minimum tax credit under section 53(b) for the 
first taxable year ending after March 31, 2008, deter-
mined by taking into account only the adjusted min-
imum tax for taxable years beginning before January 
1, 2006. For purposes of the preceding sentence, credits 
shall be treated as allowed on a first-in, first-out basis. 
‘‘(F) CREDIT
REFUNDABLE.—For purposes of section 
6401(b), the aggregate increase in the credits allowable 
under part IV of subchapter A for any taxable year 
resulting from the application of this paragraph shall be 
treated as allowed under subpart C of such part (and 
not any other subpart). 
‘‘(G) OTHER RULES.— 
‘‘(i) ELECTION.—Any election under this paragraph 
(including any allocation under subparagraph (E)) may 
be revoked only with the consent of the Secretary. 
‘‘(ii) PARTNERSHIPS WITH ELECTING PARTNERS.—In 
the case of a corporation making an election under 
subparagraph (A) and which is a partner in a partner-
ship, for purposes of determining such corporation’s 
distributive share of partnership items under section 
702— 
‘‘(I) paragraph (1) shall not apply to any 
eligible qualified property, and 
‘‘(II) the applicable depreciation method used 
under this section with respect to such property 
shall be the straight line method. 
‘‘(iii) SPECIAL
RULE
FOR
PASSENGER
AIRCRAFT.— 
In the case of any passenger aircraft, the written 
binding 
contract 
limitation 
under 
paragraph 
(2)(A)(iii)(I) shall not apply for purposes of subpara-
graphs (C)(i)(I) and (D).’’. 
(b) APPLICATION TO CERTAIN AUTOMOTIVE PARTNERSHIPS.— 
(1) IN GENERAL.—If an applicable partnership elects the 
application of this subsection— 
(A) the partnership shall be treated as having made 
a payment against the tax imposed by chapter 1 of the 
Internal Revenue Code of 1986 for any applicable taxable
H. R. 3221—253 
year of the partnership in the amount determined under 
paragraph (3), 
(B) in the case of any eligible qualified property placed 
in service by the partnership during any applicable taxable 
year— 
(i) section 168(k) of such Code shall not apply 
in determining the amount of the deduction allowable 
with respect to such property under section 168 of 
such Code, 
(ii) the applicable depreciation method used with 
respect to such property shall be the straight line 
method, and 
(C) the amount of the credit determined under section 
41 of such Code for any applicable taxable year with respect 
to the partnership shall be reduced by the amount of the 
deemed payment under subparagraph (A) for the taxable 
year. 
(2) TREATMENT OF DEEMED PAYMENT.— 
(A) IN GENERAL.—Notwithstanding any other provision 
of the Internal Revenue Code of 1986, the Secretary of 
the Treasury or his delegate shall not use the payment 
of tax described in paragraph (1) as an offset or credit 
against any tax liability of the applicable partnership or 
any partner but shall refund such payment to the 
applicable partnership. 
(B) NO
INTEREST.—The payment described in para-
graph (1) shall not be taken into account in determining 
any amount of interest under such Code. 
(3) AMOUNT OF DEEMED PAYMENT.—The amount determined 
under this paragraph for any applicable taxable year shall 
be the least of the following: 
(A) The amount which would be determined for the 
taxable year under section 168(k)(4)(C)(i) of the Internal 
Revenue Code of 1986 (as added by the amendments made 
by this section) if an election under section 168(k)(4) of 
such Code were in effect with respect to the partnership. 
(B) The amount of the credit determined under section 
41 of such Code for the taxable year with respect to the 
partnership. 
(C) $30,000,000, reduced by the amount of any pay-
ment under this subsection for any preceding taxable year. 
(4) DEFINITIONS.—For purposes of this subsection— 
(A) APPLICABLE PARTNERSHIP.—The term ‘‘applicable 
partnership’’ means a domestic partnership that— 
(i) was formed effective on August 3, 2007, and 
(ii) will produce in excess of 675,000 automobiles 
during the period beginning on January 1, 2008, and 
ending on June 30, 2008. 
(B) APPLICABLE TAXABLE YEAR.—The term ‘‘applicable 
taxable year’’ means any taxable year during which eligible 
qualified property is placed in service. 
(C) ELIGIBLE QUALIFIED PROPERTY.—The term ‘‘eligible 
qualified property’’ has the meaning given such term by 
section 168(k)(4)(D) of the Internal Revenue Code of 1986 
(as added by the amendments made by this section). 
(c) CONFORMING AMENDMENT.—Section 1324(b)(2) of title 31, 
United States Code, as amended by this Act, is amended—
H. R. 3221—254 
(1) by inserting ‘‘168(k)(4)(F),’’ after ‘‘36,’’, and 
(2) by inserting ‘‘, or due under section 3081(b)(2) of the 
Housing Assistance Tax Act of 2008’’ before the period at the 
end. 
(d) EFFECTIVE DATE.—The amendments made by this section 
shall apply to taxable years ending after March 31, 2008. 
SEC. 3082. CERTAIN GO ZONE INCENTIVES. 
(a) USE OF AMENDED INCOME TAX RETURNS TO TAKE INTO 
ACCOUNT RECEIPT OF CERTAIN HURRICANE-RELATED CASUALTY LOSS 
GRANTS
BY
DISALLOWING
PREVIOUSLY
TAKEN
CASUALTY
LOSS 
DEDUCTIONS.— 
(1) IN GENERAL.—Notwithstanding any other provision of 
the Internal Revenue Code of 1986, if a taxpayer claims a 
deduction for any taxable year with respect to a casualty loss 
to a principal residence (within the meaning of section 121 
of such Code) resulting from Hurricane Katrina, Hurricane 
Rita, or Hurricane Wilma and in a subsequent taxable year 
receives a grant under Public Law 109–148, 109–234, or 110– 
116 as reimbursement for such loss, such taxpayer may elect 
to file an amended income tax return for the taxable year 
in which such deduction was allowed (and for any taxable 
year to which such deduction is carried) and reduce (but not 
below zero) the amount of such deduction by the amount of 
such reimbursement. 
(2) TIME OF FILING AMENDED RETURN.—Paragraph (1) shall 
apply with respect to any grant only if any amended income 
tax returns with respect to such grant are filed not later than 
the later of— 
(A) the due date for filing the tax return for the taxable 
year in which the taxpayer receives such grant, or 
(B) the date which is 1 year after the date of the 
enactment of this Act. 
(3) WAIVER
OF
PENALTIES
AND
INTEREST.—Any under-
payment of tax resulting from the reduction under paragraph 
(1) of the amount otherwise allowable as a deduction shall 
not be subject to any penalty or interest under such Code 
if such tax is paid not later than 1 year after the filing of 
the amended return to which such reduction relates. 
(b) WAIVER OF DEADLINE ON CONSTRUCTION OF GO ZONE PROP-
ERTY ELIGIBLE FOR BONUS DEPRECIATION.— 
(1) IN GENERAL.—Subparagraph (B) of section 1400N(d)(3) 
is amended to read as follows: 
‘‘(B) without regard to ‘and before January 1, 2009’ 
in clause (i) thereof, and’’. 
(2) EFFECTIVE DATE.—The amendment made by this sub-
section shall apply to property placed in service after December 
31, 2007. 
(c) INCLUSION OF CERTAIN COUNTIES IN GULF OPPORTUNITY 
ZONE FOR PURPOSES OF TAX-EXEMPT BOND FINANCING.— 
(1) IN
GENERAL.—Subsection (a) of section 1400N is 
amended by adding at the end the following new paragraph: 
‘‘(8) INCLUSION OF CERTAIN COUNTIES.—For purposes of this 
subsection, the Gulf Opportunity Zone includes Colbert County, 
Alabama and Dallas County, Alabama.’’.
H. R. 3221—255 
(2) EFFECTIVE DATE.—The amendment made by this sub-
section shall take effect as if included in the provisions of 
the Gulf Opportunity Zone Act of 2005 to which it relates. 
SEC. 3083. INCREASE IN STATUTORY LIMIT ON THE PUBLIC DEBT. 
Subsection (b) of section 3101 of title 31, United States Code, 
is amended by striking out the dollar limitation contained in such 
subsection and inserting in lieu thereof $10,615,000,000,000. 
Subtitle B—Revenue Offsets 
SEC. 3091. RETURNS RELATING TO PAYMENTS MADE IN SETTLEMENT 
OF PAYMENT CARD AND THIRD PARTY NETWORK TRANS-
ACTIONS. 
(a) IN GENERAL.—Subpart B of part III of subchapter A of 
chapter 61 is amended by adding at the end the following new 
section: 
‘‘SEC. 6050W. RETURNS RELATING TO PAYMENTS MADE IN SETTLE-
MENT OF PAYMENT CARD AND THIRD PARTY NETWORK 
TRANSACTIONS. 
‘‘(a) IN GENERAL.—Each payment settlement entity shall make 
a return for each calendar year setting forth— 
‘‘(1) the name, address, and TIN of each participating payee 
to whom one or more payments in settlement of reportable 
payment transactions are made, and 
‘‘(2) the gross amount of the reportable payment trans-
actions with respect to each such participating payee. 
Such return shall be made at such time and in such form and 
manner as the Secretary may require by regulations. 
‘‘(b) PAYMENT SETTLEMENT ENTITY.—For purposes of this sec-
tion— 
‘‘(1) IN GENERAL.—The term ‘payment settlement entity’ 
means— 
‘‘(A) in the case of a payment card transaction, the 
merchant acquiring entity, and 
‘‘(B) in the case of a third party network transaction, 
the third party settlement organization. 
‘‘(2) MERCHANT ACQUIRING ENTITY.—The term ‘merchant 
acquiring entity’ means the bank or other organization which 
has the contractual obligation to make payment to participating 
payees in settlement of payment card transactions. 
‘‘(3) THIRD PARTY SETTLEMENT ORGANIZATION.—The term 
‘third party settlement organization’ means the central 
organization which has the contractual obligation to make pay-
ment to participating payees of third party network trans-
actions. 
‘‘(4) SPECIAL RULES RELATED TO INTERMEDIARIES.—For pur-
poses of this section— 
‘‘(A) AGGREGATED PAYEES.—In any case where report-
able payment transactions of more than one participating 
payee are settled through an intermediary— 
‘‘(i) such intermediary shall be treated as the 
participating payee for purposes of determining the 
reporting obligations of the payment settlement entity 
with respect to such transactions, and
H. R. 3221—256 
‘‘(ii) such intermediary shall be treated as the pay-
ment settlement entity with respect to the settlement 
of such transactions with the participating payees. 
‘‘(B) ELECTRONIC PAYMENT FACILITATORS.—In any case 
where an electronic payment facilitator or other third party 
makes payments in settlement of reportable payment trans-
actions on behalf of the payment settlement entity, the 
return under subsection (a) shall be made by such electronic 
payment facilitator or other third party in lieu of the pay-
ment settlement entity. 
‘‘(c) REPORTABLE PAYMENT TRANSACTION.—For purposes of this 
section— 
‘‘(1) IN
GENERAL.—The term ‘reportable payment trans-
action’ means any payment card transaction and any third 
party network transaction. 
‘‘(2) PAYMENT CARD TRANSACTION.—The term ‘payment card 
transaction’ means any transaction in which a payment card 
is accepted as payment. 
‘‘(3) THIRD PARTY NETWORK TRANSACTION.—The term ‘third 
party network transaction’ means any transaction which is 
settled through a third party payment network. 
‘‘(d) OTHER DEFINITIONS.—For purposes of this section— 
‘‘(1) PARTICIPATING PAYEE.— 
‘‘(A) IN
GENERAL.—The term ‘participating payee’ 
means— 
‘‘(i) in the case of a payment card transaction, 
any person who accepts a payment card as payment, 
and 
‘‘(ii) in the case of a third party network trans-
action, any person who accepts payment from a third 
party settlement organization in settlement of such 
transaction. 
‘‘(B) EXCLUSION OF FOREIGN PERSONS.—Except as pro-
vided by the Secretary in regulations or other guidance, 
such term shall not include any person with a foreign 
address. 
‘‘(C) INCLUSION OF GOVERNMENTAL UNITS.—The term 
‘person’ includes any governmental unit (and any agency 
or instrumentality thereof). 
‘‘(2) PAYMENT CARD.—The term ‘payment card’ means any 
card which is issued pursuant to an agreement or arrangement 
which provides for— 
‘‘(A) one or more issuers of such cards, 
‘‘(B) a network of persons unrelated to each other, 
and to the issuer, who agree to accept such cards as pay-
ment, and 
‘‘(C) standards and mechanisms for settling the trans-
actions between the merchant acquiring entities and the 
persons who agree to accept such cards as payment. 
The acceptance as payment of any account number or other 
indicia associated with a payment card shall be treated for 
purposes of this section in the same manner as accepting such 
payment card as payment. 
‘‘(3) THIRD
PARTY
PAYMENT
NETWORK.—The term ‘third 
party payment network’ means any agreement or arrange-
ment—
H. R. 3221—257 
‘‘(A) which involves the establishment of accounts with 
a central organization by a substantial number of persons 
who— 
‘‘(i) are unrelated to such organization, 
‘‘(ii) provide goods or services, and 
‘‘(iii) have agreed to settle transactions for the 
provision of such goods or services pursuant to such 
agreement or arrangement, 
‘‘(B) which provides for standards and mechanisms 
for settling such transactions, and 
‘‘(C) which guarantees persons providing goods or serv-
ices pursuant to such agreement or arrangement that such 
persons will be paid for providing such goods or services. 
Such term shall not include any agreement or arrangement 
which provides for the issuance of payment cards. 
‘‘(e) EXCEPTION FOR DE MINIMIS PAYMENTS BY THIRD PARTY 
SETTLEMENT ORGANIZATIONS.—A third party settlement organiza-
tion shall be required to report any information under subsection 
(a) with respect to third party network transactions of any partici-
pating payee only if— 
‘‘(1) the amount which would otherwise be reported under 
subsection (a)(2) with respect to such transactions exceeds 
$20,000, and 
‘‘(2) the aggregate number of such transactions exceeds 
200. 
‘‘(f) STATEMENTS TO BE FURNISHED TO PERSONS WITH RESPECT 
TO WHOM INFORMATION IS REQUIRED.—Every person required to 
make a return under subsection (a) shall furnish to each person 
with respect to whom such a return is required a written statement 
showing— 
‘‘(1) the name, address, and phone number of the informa-
tion contact of the person required to make such return, and 
‘‘(2) the gross amount of the reportable payment trans-
actions with respect to the person required to be shown on 
the return. 
The written statement required under the preceding sentence shall 
be furnished to the person on or before January 31 of the year 
following the calendar year for which the return under subsection 
(a) was required to be made. Such statement may be furnished 
electronically, and if so, the email address of the person required 
to make such return may be shown in lieu of the phone number. 
‘‘(g) REGULATIONS.—The Secretary may prescribe such regula-
tions or other guidance as may be necessary or appropriate to 
carry out this section, including rules to prevent the reporting 
of the same transaction more than once.’’. 
(b) PENALTY FOR FAILURE TO FILE.— 
(1) RETURN.—Subparagraph (B) of section 6724(d)(1) is 
amended— 
(A) by striking ‘‘or’’ at the end of clause (xx), 
(B) by redesignating the clause (xix) that follows clause 
(xx) as clause (xxi), 
(C) by striking ‘‘and’’ at the end of clause (xxi), as 
redesignated by subparagraph (B) and inserting ‘‘or’’, and 
(D) by adding at the end the following: 
‘‘(xxii) section 6050W (relating to returns to pay-
ments made in settlement of payment card trans-
actions), and’’.
H. R. 3221—258 
(2) STATEMENT.—Paragraph (2) of section 6724(d) is 
amended by striking ‘‘or’’ at the end of subparagraph (BB), 
by striking the period at the end of the subparagraph (CC) 
and inserting ‘‘, or’’, and by inserting after subparagraph (CC) 
the following: 
‘‘(DD) section 6050W(c) (relating to returns relating 
to payments made in settlement of payment card trans-
actions).’’. 
(c) APPLICATION OF BACKUP WITHHOLDING.—Paragraph (3) of 
section 3406(b) is amended by striking ‘‘or’’ at the end of subpara-
graph (D), by striking the period at the end of subparagraph (E) 
and inserting ‘‘, or’’, and by adding at the end the following new 
subparagraph: 
‘‘(F) section 6050W (relating to returns relating to pay-
ments made in settlement of payment card transactions).’’. 
(d) CLERICAL AMENDMENT.—The table of sections for subpart 
B of part III of subchapter A of chapter 61 is amended by inserting 
after the item relating to section 6050V the following: 
‘‘Sec. 6050W. Returns relating to payments made in settlement of payment card 
transactions.’’. 
(e) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as otherwise provided in this sub-
section, the amendments made by this section shall apply to 
returns for calendar years beginning after December 31, 2010. 
(2) APPLICATION OF BACKUP WITHHOLDING.— 
(A) IN GENERAL.—The amendment made by subsection 
(c) shall apply to amounts paid after December 31, 2011. 
(B) ELIGIBILITY FOR TIN MATCHING PROGRAM.—Solely 
for purposes of carrying out any TIN matching program 
established by the Secretary under section 3406(i) of the 
Internal Revenue Code of 1986— 
(i) the amendments made this section shall be 
treated as taking effect on the date of the enactment 
of this Act, and 
(ii) each person responsible for setting the stand-
ards 
and 
mechanisms 
referred 
to 
in 
section 
6050W(d)(2)(C) of such Code, as added by this section, 
for settling transactions involving payment cards shall 
be treated in the same manner as a payment settle-
ment entity. 
SEC. 3092. GAIN FROM SALE OF PRINCIPAL RESIDENCE ALLOCATED 
TO NONQUALIFIED USE NOT EXCLUDED FROM INCOME. 
(a) IN GENERAL.—Subsection (b) of section 121 of the Internal 
Revenue Code of 1986 (relating to limitations) is amended by adding 
at the end the following new paragraph: 
‘‘(4) EXCLUSION
OF
GAIN
ALLOCATED
TO
NONQUALIFIED 
USE.— 
‘‘(A) IN GENERAL.—Subsection (a) shall not apply to 
so much of the gain from the sale or exchange of property 
as is allocated to periods of nonqualified use. 
‘‘(B) GAIN ALLOCATED TO PERIODS OF NONQUALIFIED 
USE.—For purposes of subparagraph (A), gain shall be allo-
cated to periods of nonqualified use based on the ratio 
which—
H. R. 3221—259 
‘‘(i) the aggregate periods of nonqualified use 
during the period such property was owned by the 
taxpayer, bears to 
‘‘(ii) the period such property was owned by the 
taxpayer. 
‘‘(C) PERIOD OF NONQUALIFIED USE.—For purposes of 
this paragraph— 
‘‘(i) IN GENERAL.—The term ‘period of nonqualified 
use’ means any period (other than the portion of any 
period preceding January 1, 2009) during which the 
property is not used as the principal residence of the 
taxpayer or the taxpayer’s spouse or former spouse. 
‘‘(ii) EXCEPTIONS.—The term ‘period of nonqualified 
use’ does not include— 
‘‘(I) any portion of the 5-year period described 
in subsection (a) which is after the last date that 
such property is used as the principal residence 
of the taxpayer or the taxpayer’s spouse, 
‘‘(II) any period (not to exceed an aggregate 
period of 10 years) during which the taxpayer or 
the taxpayer’s spouse is serving on qualified official 
extended duty (as defined in subsection (d)(9)(C)) 
described in clause (i), (ii), or (iii) of subsection 
(d)(9)(A), and 
‘‘(III) any other period of temporary absence 
(not to exceed an aggregate period of 2 years) 
due to change of employment, health conditions, 
or such other unforeseen circumstances as may 
be specified by the Secretary. 
‘‘(D) COORDINATION WITH RECOGNITION OF GAIN ATTRIB-
UTABLE
TO
DEPRECIATION.—For purposes of this para-
graph— 
‘‘(i) subparagraph (A) shall be applied after the 
application of subsection (d)(6), and 
‘‘(ii) subparagraph (B) shall be applied without 
regard to any gain to which subsection (d)(6) applies.’’. 
(b) EFFECTIVE DATE.—The amendment made by this section 
shall apply to sales and exchanges after December 31, 2008. 
SEC. 3093. DELAY IN APPLICATION OF WORLDWIDE ALLOCATION OF 
INTEREST. 
(a) IN GENERAL.—Paragraphs (5)(D) and (6) of section 864(f) 
are each amended by striking ‘‘December 31, 2008’’ and inserting 
‘‘December 31, 2010’’. 
(b) TRANSITIONAL
RULE.—Subsection (f) of section 864 is 
amended by adding at the end the following new paragraph: 
‘‘(7) TRANSITION.—In the case of the first taxable year 
to which this subsection applies, the increase (if any) in the 
amount of the interest expense allocable to sources within 
the United States by reason of the application of this subsection 
shall be 30 percent of the amount of such increase determined 
without regard to this paragraph.’’. 
(c) EFFECTIVE DATE.—The amendments made by this section 
shall apply to taxable years beginning after December 31, 2008. 
SEC. 3094. TIME FOR PAYMENT OF CORPORATE ESTIMATED TAXES. 
(a) REPEAL OF ADJUSTMENT FOR 2012.—Subparagraph (B) of 
section 401(1) of the Tax Increase Prevention and Reconciliation
H. R. 3221—260 
Act of 2005 is amended by striking the percentage contained therein 
and inserting ‘‘100 percent’’. No other provision of law which would 
change such percentage shall have any force and effect. 
(b) MODIFICATION OF ADJUSTMENT FOR 2013.—The percentage 
under subparagraph (C) of section 401(1) of the Tax Increase 
Prevention and Reconciliation Act of 2005 in effect on the date 
of the enactment of this Act is increased by 16.75 percentage 
points. 
Speaker of the House of Representatives. 
Vice President of the United States and
President of the Senate.