suant to this section to report quarterly, in 
a format specified by the Chief Executive 
Officer, on such entity’s use of such sup-
port and its progress fulfilling the objec-
tives for which such support was granted, 
and the Chief Executive Officer shall make 
these reports available to the public; 
‘‘(ii) may establish additional report-
ing and information requirements for any 
recipient of financing support made avail-
able pursuant to this section; 
‘‘(iii) shall establish appropriate mech-
anisms to ensure appropriate use and com-
pliance with all terms of any financing 
support made available pursuant to this 
section; 
‘‘(iv) may, in addition to and con-
sistent with any other authority under ap-
plicable law, deobligate financing support 
made available pursuant to this section to 
entities that demonstrate an insufficient 
level of performance, or wasteful or fraud-
ulent spending, as defined in advance by 
the Chief Executive Officer, and award 
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these funds competitively to new or exist-
ing applicants consistent with this section; 
‘‘(v) shall create and maintain a fully 
searchable database, accessible on the 
Internet (or successor protocol) at no cost 
to the public, that contains at least— 
‘‘(I) a list of each entity that has 
applied for a loan, loan guarantee, in-
surance, portfolio insurance, or other 
forms of financing support or risk 
management under this section; 
‘‘(II) a description of each appli-
cation; 
‘‘(III) the status of each such ap-
plication; 
‘‘(IV) the name of each entity re-
ceiving funds made available pursuant 
to this section; 
‘‘(V) the purpose for which such 
entity is receiving such funds; 
‘‘(VI) each quarterly report sub-
mitted by the entity pursuant to this 
section; and 
‘‘(VII) such other information 
sufficient to allow the public to under-
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stand and monitor loans, loan guaran-
tees, insurance, portfolio insurance, 
and other forms of financing support 
or risk management provided under 
this section; 
‘‘(vi) to the extent practicable, data 
maintained under clause (v) shall be used 
to inform private capital markets, includ-
ing the development of underwriting stand-
ards for the financing of clean energy 
projects and energy efficiency projects; 
‘‘(vii) shall make all financing trans-
actions available for public inspection, in-
cluding formal annual reviews by both a 
private auditor and the Comptroller Gen-
eral; and 
‘‘(viii) shall at all times be available to 
receive public comment in writing on the 
activities of the Bank. 
‘‘(B) 
PROTECTION
OF
CONFIDENTIAL 
BUSINESS INFORMATION.—To the extent nec-
essary and appropriate, the Chief Executive Of-
ficer may redact any information regarding ap-
plicants and borrowers to protect confidential 
business information. 
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‘‘(13) GUARANTEE.—Except as provided in sec-
tion 3102A(e) with respect to Green Bonds, finan-
cial support provided by the Bank shall not be fully 
and unconditionally guaranteed by the United 
States.’’. 
SEC. 3. CONFORMING AMENDMENTS. 
(a) TAX EXEMPT STATUS.—Subsection (l) of section 
501 of the Internal Revenue Code of 1986 is amended by 
adding at the end the following: 
‘‘(4) The Green Bank established under section 
9801 of title 31, United States Code.’’. 
(b) WHOLLY
OWNED
GOVERNMENT
CORPORA-
TION.—Paragraph (3) of section 9101 of title 31, United 
States Code, is amended by adding at the end the fol-
lowing: 
‘‘(S) the Green Bank.’’. 
(c) CLERICAL AMENDMENTS.— 
(1) The table of sections for chapter 31 of title 
31, United States Code, is amended by inserting 
after the item relating to section 3102 the following 
new item: 
‘‘3102A. Green bonds.’’. 
(2) The table of chapters for subtitle VI of title 
31, United States Code, is amended by adding at 
the end the following new item: 
‘‘98. Green Bank ................................................................................ 9801’’. 
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SEC. 4. DEFER DEDUCTION OF INTEREST EXPENSE RE-
LATED TO DEFERRED INCOME. 
(a) IN GENERAL.—Section 163 of the Internal Rev-
enue Code of 1986 (relating to deductions for interest ex-
pense) is amended by redesignating subsection (n) as sub-
section (o) and by inserting after subsection (m) the fol-
lowing new subsection: 
‘‘(n) DEFERRAL OF DEDUCTION FOR INTEREST EX-
PENSE RELATED TO DEFERRED INCOME.— 
‘‘(1) GENERAL RULE.—In the case of any tax-
payer, the amount of foreign-related interest expense 
allowed as a deduction under this chapter for any 
taxable year shall not exceed an amount that bears 
the same ratio to the sum of the foreign-related in-
terest expense for such year and the deferred for-
eign-related interest expense as the current inclusion 
ratio. 
‘‘(2) 
TREATMENT
OF
DEFERRED
DEDUC-
TIONS.—If, for any taxable year— 
‘‘(A) the amount that bears the same ratio 
to the sum of the foreign-related interest ex-
pense for such year and the deferred foreign-re-
lated interest expense as the current inclusion 
ratio, exceeds 
‘‘(B) the foreign-related interest expense 
for such year, there shall be allowed as a deduc-
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tion for such year an amount equal to the lesser 
of such excess and the deferred foreign-related 
interest expense. 
‘‘(3) DEFINITIONS
AND
SPECIAL
RULE.—For 
purposes of this subsection— 
‘‘(A) FOREIGN-RELATED
INTEREST
EX-
PENSE.—The term ‘foreign-related interest ex-
pense’ means, for any taxable year, an amount 
of interest expense for such taxable year allo-
cated and apportioned under sections 861 and 
864(e) to income from sources outside the 
United States which bears the same proportion 
to such interest expense as the value of all 
stock held by the taxpayer in all section 902 
corporations (as defined in section 909(d)(5)) 
with respect to which the taxpayer meets the 
ownership requirements of subsection (a) or (b) 
of section 902 bears to the value of all assets 
of the taxpayer which generate gross income 
from sources outside the United States. 
‘‘(B) DEFERRED
FOREIGN-RELATED
IN-
TEREST EXPENSE.—The term ‘deferred foreign- 
related interest expense’ means the excess, if 
any, of the aggregate foreign-related interest 
expense for all prior taxable years, over the ag-
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gregate amount allowed as a deduction under 
paragraphs (1) and (2) for all prior taxable 
years. 
‘‘(C) VALUE OF ASSETS.—Except as other-
wise provided by the Secretary, for purposes of 
paragraph (3)(A)(i), the value of any asset shall 
be the amount with respect to such asset used 
as determined for purposes of allocating and 
apportioning interest expense under sections 
861 and 864(e). 
‘‘(D) CURRENT
INCLUSION
RATIO.—The 
term ‘current inclusion ratio’ means, with re-
spect to any domestic corporation which meets 
the ownership requirements of subsection (a) or 
(b) of section 902 with respect to one or more 
section 902 corporations for any taxable year, 
the ratio (expressed as a percentage) of— 
‘‘(i) the sum of all dividends received 
by the domestic corporation from a section 
902 corporation during the taxable year 
plus amounts includible in gross income 
under section 951(a) from such section 
902 corporation, in each case computed 
without regard to section 78, divided by 
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‘‘(ii) the aggregate amount of post- 
1986 undistributed earnings for the tax-
able year. 
‘‘(E) AGGREGATE AMOUNT OF POST-1986 
UNDISTRIBUTED EARNINGS.—The term ‘aggre-
gate amount of post-1986 undistributed earn-
ings’ means, with respect to any domestic cor-
poration which meets the ownership require-
ments of subsection (a) or (b) of section 902 
with respect to one or more section 902 cor-
porations, the domestic corporation’s pro rata 
share of the post-1986 undistributed earnings 
(as defined in section 902(c)(1)) of all such sec-
tion 902 corporations. 
‘‘(F) FOREIGN CURRENCY CONVERSION.— 
For purposes of determining the current inclu-
sion ratio, and except as otherwise provided by 
the Secretary, the aggregate amount of post- 
1986 undistributed earnings for the taxable 
year shall be determined by translating each 
section 902 corporation’s post-1986 undistrib-
uted earnings into dollars using the average ex-
change rate for such year. 
‘‘(4) TREATMENT
OF
AFFILIATED
GROUPS.— 
The current inclusion ratio of each member of an af-
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filiated group (as defined in section 864(e)(5)(A)) 
shall be determined as if all members of such group 
were a single corporation. 
‘‘(5) APPLICATION TO SEPARATE CATEGORIES 
OF INCOME.—This subsection shall be applied sepa-
rately with respect to the categories of income speci-
fied in section 904(d)(1). 
‘‘(6) REGULATIONS.—The Secretary may pre-
scribe such regulations or other guidance as is nec-
essary or appropriate to carry out the purposes of 
this subsection, including regulations or other guid-
ance providing— 
‘‘(A) for the proper application of this sub-
section with respect to changes in ownership of 
a section 902 corporation, 
‘‘(B) that certain corporations that other-
wise would not be members of the affiliated 
group will be treated as members of the affili-
ated group for purposes of this subsection, 
‘‘(C) for the proper application of this sub-
section with respect to the taxpayer’s share of 
a deficit in earnings and profits of a section 
902 corporation, 
‘‘(D) for appropriate adjustments to the 
determination of the value of stock in any sec-
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tion 902 corporation for purposes of this sub-
section or to the foreign-related interest expense 
to account for income that is subject to tax 
under section 882(a)(1), and 
‘‘(E) for the proper application of this sub-
section with respect to interest expense that is 
directly allocable to income with respect to cer-
tain assets.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning on or 
after January 1, 2015. 
Æ 
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