serting ‘‘except that, in the hands of such dis-
tributee— 
‘‘(A) the basis of such property shall be 
the fair market value of the property at the 
time of the distribution in any case in which 
gain or loss is recognized by the liquidating cor-
poration with respect to such property, and 
‘‘(B) the basis of any property described in 
section 362(e)(1)(B) shall be the fair market 
value of the property at the time of the dis-
tribution in any case in which such distributee’s 
aggregate adjusted basis of such property would 
(but for this subparagraph) exceed the fair 
market value of such property immediately 
after such liquidation.’’. 
(2) Clause (ii) of section 362(e)(2)(C) is 
amended to read as follows: 
‘‘(ii) ELECTION.—Any election under 
clause (i) shall be made at such time and 
in such form and manner as the Secretary 
may prescribe, and, once made, shall be ir-
revocable.’’. 
(ee) AMENDMENT RELATED TO SECTION 840 OF THE 
ACT.—Subsection (d) of section 121 is amended—
(1) by redesignating the paragraph (10) relat-
ing to property acquired from a decedent as para-
graph (11) and by moving such paragraph to the 
end of such subsection, and 
(2) by amending the paragraph (10) relating to 
property acquired in like-kind exchange to read as 
follows: 
‘‘(10) PROPERTY ACQUIRED IN LIKE-KIND EX-
CHANGE.—If a taxpayer acquires property in an ex-
change with respect to which gain is not recognized 
(in whole or in part) to the taxpayer under sub-
section (a) or (b) of section 1031, subsection (a) 
shall not apply to the sale or exchange of such prop-
erty by such taxpayer (or by any person whose basis 
in such property is determined, in whole or in part, 
by reference to the basis in the hands of such tax-
payer) during the 5-year period beginning with the 
date of such acquisition.’’. 
(ff) AMENDMENT RELATED TO SECTION 849 OF THE 
ACT.—Subsection (a) of section 849 of the American Jobs 
Creation Act of 2004 is amended by inserting ‘‘, and in 
the case of property treated as tax-exempt use property 
other than by reason of a lease, to property acquired after 
March 12, 2004’’ before the period at the end.
(gg) AMENDMENTS RELATED TO SECTION 853 OF 
THE ACT.— 
(1) Subparagraph (C) of section 4081(a)(2) is 
amended by striking ‘‘for use in commercial avia-
tion’’ and inserting ‘‘for use in commercial aviation 
by a person registered for such use under section 
4101’’. 
(2) So much of paragraph (2) of section 
4081(d) as precedes subparagraph (A) is amended 
to read as follows: 
‘‘(2) AVIATION FUELS.—The rates of tax speci-
fied in clauses (ii) and (iv) of subsection (a)(2)(A) 
shall be 4.3 cents per gallon—’’. 
(hh) AMENDMENT RELATED TO SECTION 884 OF 
THE ACT.—Subparagraph (B) of section 170(f)(12) is 
amended by adding at the end the following new clauses: 
‘‘(v) Whether the donee organization 
provided any goods or services in consider-
ation, in whole or in part, for the qualified 
vehicle. 
‘‘(vi) A description and good faith es-
timate of the value of any goods or services 
referred to in clause (v) or, if such goods 
or services consist solely of intangible reli-
gious benefits (as defined in paragraph 
(8)(B)), a statement to that effect.’’. 
(ii) AMENDMENTS RELATED TO SECTION 885 OF 
THE ACT.— 
(1) Paragraph (2) of section 26(b) is amended 
by striking ‘‘and’’ at the end of subparagraph (R), 
by striking the period at the end of subparagraph 
(S) and inserting ‘‘, and’’, and by adding at the end 
the following new subparagraph: 
‘‘(T) 
subsections 
(a)(1)(B)(i) 
and 
(b)(4)(A) of section 409A (relating to interest 
and additional tax with respect to certain de-
ferred compensation).’’. 
(2) Clause (ii) of section 409A(a)(4)(C) is 
amended by striking ‘‘first’’. 
(3)(A) Notwithstanding section 885(d)(1) of the 
American Jobs Creation Act of 2004, subsection (b) 
of section 409A of the Internal Revenue Code of 
1986 shall take effect on January 1, 2005. 
(B) Not later than 90 days after the date of the 
enactment of this Act, the Secretary of the Treasury 
shall issue guidance under which a nonqualified de-
ferred compensation plan which is in violation of the 
requirements of section 409A(b) of such Code shall 
be treated as not having violated such requirements
if such plan comes into conformance with such re-
quirements during such limited period as the Sec-
retary may specify in such guidance. 
(4) Subsection (f) of section 885 of the Amer-
ican Jobs Creation Act of 2004 is amended by strik-
ing ‘‘December 31, 2004’’ the first place it appears 
and inserting ‘‘January 1, 2005’’. 
(jj) AMENDMENTS RELATED TO SECTION 898 OF 
THE ACT.— 
(1) Paragraph (3) of section 361(b) is amended 
by inserting ‘‘(reduced by the amount of the liabil-
ities assumed (within the meaning of section 
357(c)))’’ before the period at the end. 
(2) Paragraph (1) of section 357(d) is amended 
by inserting ‘‘section 361(b)(3),’’ after ‘‘section 
358(h),’’. 
(kk) AMENDMENT RELATED TO SECTION 899 OF 
THE ACT.—Subparagraph (A) of section 351(g)(3) is 
amended by adding at the end the following: ‘‘If there is 
not a real and meaningful likelihood that dividends beyond 
any limitation or preference will actually be paid, the pos-
sibility of such payments will be disregarded in deter-
mining whether stock is limited and preferred as to divi-
dends.’’.
(ll) AMENDMENT RELATED TO SECTION 902 OF THE 
ACT.—Paragraph (1) of section 709(b) is amended by 
striking ‘‘taxpayer’’ both places it appears and inserting 
‘‘partnership’’. 
(mm) AMENDMENT RELATED TO SECTION 909 OF 
THE ACT.—Clause (ii) of section 451(i)(4)(B) is amended 
by striking ‘‘the close of the period applicable under sub-
section (a)(2)(B) as extended under paragraph (2)’’ and 
inserting ‘‘December 31, 2006’’. 
(nn) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in the provisions 
of the American Jobs Creation Act of 2004 to which they 
relate. 
SEC. 3. AMENDMENTS RELATED TO THE WORKING FAMI-
LIES TAX RELIEF ACT OF 2004. 
(a) AMENDMENT RELATED TO SECTION 201 OF THE 
ACT.—Paragraph (2) of section 152(e) is amended to read 
as follows: 
‘‘(2) REQUIREMENTS.—For purposes of para-
graph (1), the requirements described in this para-
graph are met if— 
‘‘(A) a decree of divorce or separate main-
tenance or written separation agreement be-
tween the parents applicable to the taxable year 
beginning in such calendar year provides that
the noncustodial parent shall be entitled to any 
deduction allowable under section 151 for such 
child, and in the case of such a decree or agree-
ment executed before January 1, 1985, the 
noncustodial parent provides at least $600 for 
the support of such child during such calendar 
year, or 
‘‘(B) the custodial parent signs a written 
declaration (in such manner and form as the 
Secretary may prescribe) that such parent will 
not claim such child as a dependent for such 
taxable year. 
For purposes of subparagraph (A), amounts ex-
pended for the support of a child or children shall 
be treated as received from the noncustodial parent 
to the extent that such parent provided amounts for 
such support.’’. 
(b) AMENDMENT RELATED TO SECTION 203 OF THE 
ACT.—Subparagraph (B) of section 21(b)(1) is amended 
by inserting ‘‘(as defined in section 152, determined with-
out regard to subsections (b)(1), (b)(2), and (d)(1)(B))’’ 
after ‘‘dependent of the taxpayer’’. 
(c) AMENDMENT RELATED TO SECTION 207 OF THE 
ACT.—Subparagraph (A) of section 223(d)(2) is amended
by inserting ‘‘, determined without regard to subsections 
(b)(1), (b)(2), and (d)(1)(B) thereof’’ after ‘‘section 152’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in the provisions 
of the Working Families Tax Relief Act of 2004 to which 
they relate. 
SEC. 4. AMENDMENTS RELATED TO THE JOBS AND 
GROWTH TAX RELIEF RECONCILIATION ACT 
OF 2003. 
(a) AMENDMENTS RELATED TO SECTION 201 OF 
THE ACT.— 
(1) Clause (ii) of section 168(k)(4)(B) is 
amended to read as follows: 
‘‘(ii) which is— 
‘‘(I) acquired by the taxpayer 
after May 5, 2003, and before Janu-
ary 1, 2005, but only if no written 
binding contract for the acquisition 
was in effect before May 6, 2003, or 
‘‘(II) acquired by the taxpayer 
pursuant to a written binding contract 
which was entered into after May 5, 
2003, and before January 1, 2005, 
and’’.
(2) Subparagraph (D) of section 1400L(b)(2) is 
amended by striking ‘‘September 11, 2004’’ and in-
serting ‘‘January 1, 2005’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 201 
of the Jobs and Growth Tax Relief and Reconciliation Act 
of 2003. 
SEC. 5. AMENDMENT RELATED TO THE VICTIMS OF TER-
RORISM TAX RELIEF ACT OF 2001. 
(a) AMENDMENT RELATED TO SECTION 201 OF THE 
ACT.—Paragraph (17) of section 6103(l) is amended by 
striking ‘‘subsection (f), (i)(7), or (p)’’ and inserting ‘‘sub-
section (f), (i)(8), or (p)’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 201 
of the Victims of Terrorism Tax Relief Act of 2001. 
SEC. 6. AMENDMENT RELATED TO THE TRANSPORTATION 
EQUITY ACT FOR THE 21ST CENTURY. 
(a) AMENDMENT RELATED TO SECTION 9005 OF 
THE ACT.—The last sentence of paragraph (2) of section 
9504(b) is amended by striking ‘‘subparagraph (B)’’ and 
inserting ‘‘subparagraph (C)’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 9005 
of the Transportation Equity Act for the 21st Century.
SEC. 7. AMENDMENTS RELATED TO THE TAXPAYER RELIEF 
ACT OF 1997. 
(a) AMENDMENTS RELATED TO SECTION 1055 OF 
THE ACT.— 
(1) The last sentence of section 6411(a) is 
amended by striking ‘‘6611(f)(3)(B)’’ and inserting 
‘‘6611(f)(4)(B)’’. 
(2) Paragraph (4) of section 6601(d) is amend-
ed by striking ‘‘6611(f)(3)(A)’’ and inserting 
‘‘6611(f)(4)(A)’’. 
(b) AMENDMENT RELATED TO SECTION 1144 OF 
THE ACT.—Subparagraph (B) of section 6038B(a)(1) is 
amended by inserting ‘‘or’’ at the end. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in the provisions 
of the Taxpayer Relief Act of 1997 to which they relate. 
SEC. 8. CLERICAL CORRECTIONS. 
(a) Subparagraph (C) of section 2(b)(2) is amended 
by striking ‘‘subparagraph (C)’’ and inserting ‘‘subpara-
graph (B)’’. 
(b) Subparagraph (E) of section 26(b)(2) is amended 
by striking ‘‘section 530(d)(3)’’ and inserting ‘‘section 
530(d)(4)’’. 
(c)(1) Subclause (II) of section 38(c)(2)(A)(ii) is 
amended by striking ‘‘or the New York Liberty Zone busi-
ness employee credit or the specified credits’’ and inserting
‘‘, the New York Liberty Zone business employee credit, 
and the specified credits’’. 
(2) Subclause (II) of section 38(c)(3)(A)(ii) is 
amended by striking ‘‘or the specified credits’’ and insert-
ing ‘‘and the specified credits’’. 
(3) Subparagraph (B) of section 38(c)(4) is amend-
ed— 
(A) by striking ‘‘includes’’ and inserting 
‘‘means’’, and 
(B) by inserting ‘‘and’’ at the end of clause (i). 
(d)(1) Subparagraph (A) of section 39(a)(1) is 
amended by striking ‘‘each of the 1 taxable years’’ and 
by inserting ‘‘the taxable year’’. 
(2) Subparagraph (B) of section 39(a)(3) is amended 
to read as follows: 
‘‘(B) paragraph (1) shall be applied by 
substituting ‘each of the 5 taxable years’ for 
‘the taxable year’ in subparagraph (A) thereof, 
and’’. 
(e) Paragraph (5) of section 43(c) is amended to read 
as follows: 
‘‘(5) ALASKA NATURAL GAS.—For purposes of 
paragraph (1)(D)— 
‘‘(A) IN GENERAL.—The term ‘Alaska nat-
ural gas’ means natural gas entering the Alaska
natural gas pipeline (as defined in section 
168(i)(16) (determined without regard to sub-
paragraph (B) thereof)) which is produced from 
a well— 
‘‘(i) located in the area of the State of 
Alaska lying north of 64 degrees North 
latitude, determined by excluding the area 
of the Alaska National Wildlife Refuge (in-
cluding the continental shelf thereof within 
the meaning of section 638(1)), and 
‘‘(ii) pursuant to the applicable State 
and Federal pollution prevention, control, 
and permit requirements from such area 
(including the continental shelf thereof 
within the meaning of section 638(1)). 
‘‘(B) NATURAL GAS.—The term ‘natural 
gas’ has the meaning given such term by sec-
tion 613A(e)(2).’’. 
(f) Paragraph (2) of section 45I(a) is amended by 
striking ‘‘qualified credit oil production’’ and inserting 
‘‘qualified crude oil production’’. 
(g) Subparagraph (E) of section 50(a)(2) is amended 
by striking ‘‘section 48(a)(5)’’ and inserting ‘‘section 
48(b)’’. 
(h)(1) Subsection (a) of section 62 is amended—
(A) by redesignating paragraph (19) (relating 
to costs involving discrimination suits, etc.), as 
added by section 703 of the American Jobs Creation 
Act of 2004, as paragraph (20), and 
(B) by moving such paragraph after paragraph 
(19) (relating to health savings accounts). 
(2) Subsection (e) of section 62 is amended by strik-
ing ‘‘subsection (a)(19)’’ and inserting ‘‘subsection 
(a)(20)’’. 
(i) Paragraph (3) of section 167(f) is amended by 
striking ‘‘section 197(e)(7)’’ and inserting ‘‘section 
197(e)(6)’’. 
(j) Subparagraph (D) of section 168(i)(15) is amend-
ed by striking ‘‘This paragraph shall not apply to’’ and 
inserting ‘‘Such term shall not include’’. 
(k) Paragraph (2) of section 221(d) is amended by 
striking ‘‘this Act’’ and inserting ‘‘the Taxpayer Relief Act 
of 1997’’. 
(l) Paragraph (8) of section 318(b) is amended by 
striking ‘‘section 6038(d)(2)’’ and inserting ‘‘section 
6038(e)(2)’’. 
(m) Subparagraph (B) of section 332(d)(1) is amend-
ed by striking ‘‘distribution to which section 301 applies’’ 
and inserting ‘‘distribution of property to which section 
301 applies’’.
(n) Paragraph (1) of section 415(l) is amended by 
striking ‘‘individual medical account’’ and inserting ‘‘indi-
vidual medical benefit account’’. 
(o) The matter following clause (iv) of section 
415(n)(3)(C) is amended by striking ‘‘clauses’’ and insert-
ing ‘‘clause’’. 
(p) Paragraph (12) of section 501(c) is amended— 
(1) by striking ‘‘subparagraph (C)(iii)’’ in sub-
paragraph 
(F) 
and 
inserting 
‘‘subparagraph 
(C)(iv)’’, and 
(2) by striking ‘‘subparagraph (C)(iv)’’ in sub-
paragraph (G) and inserting ‘‘subparagraph (C)(v)’’. 
(q) Clause (ii) of section 501(c)(22)(B) is amended 
by striking ‘‘clause (ii) of paragraph (21)(B)’’ and insert-
ing ‘‘clause (ii) of paragraph (21)(D)’’. 
(r) Paragraph (1) of section 512(b) is amended by 
striking ‘‘section 512(a)(5)’’ and inserting ‘‘subsection 
(a)(5)’’. 
(s)(1) Subsection (b) of section 512 is amended— 
(A) by redesignating paragraph (18) (relating 
to the treatment of gain or loss on sale or exchange 
of certain brownfield sites), as added by section 702 
of the American Jobs Creation Act of 2004, as para-
graph (19), and
(B) by moving such paragraph to the end of 
such subsection. 
(2) Subparagraph (E) of section 514(b)(1) is amend-
ed by striking ‘‘section 512(b)(18)’’ and inserting ‘‘section 
512(b)(19)’’. 
(t)(1) Subsection (b) of section 530 is amended by 
striking paragraph (3) and by redesignating paragraphs 
(4) and (5) as paragraphs (3) and (4), respectively. 
(2) Clause (ii) of section 530(b)(2)(A) is amended by 
striking ‘‘paragraph (4)’’ and inserting ‘‘paragraph (3)’’. 
(u) Section 881(e)(1)(C) is amended by inserting ‘‘in-
terest-related dividend received by a controlled foreign cor-
poration’’ after ‘‘shall apply to any’’. 
(v) Clause (i) of section 954(c)(1)(C) is amended by 
striking ‘‘paragraph (4)(A)’’ and inserting ‘‘paragraph 
(5)(A)’’. 
(w) Subparagraph (F) of section 954(c)(1) is amend-
ed by striking ‘‘Net income from notional principal con-
tracts.’’ after ‘‘Income from notional principal con-
tracts.—’’. 
(x) Paragraph (23) of section 1016(a) is amended by 
striking ‘‘1045(b)(4)’’ and inserting ‘‘1045(b)(3)’’. 
(y) Paragraph (1) of section 1256(f) is amended by 
striking ‘‘subsection (e)(2)(C)’’ and inserting ‘‘subsection 
(e)(2)’’.