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with respect to services performed by persons 
other than individuals, 
‘‘(E) a value added tax, goods and services 
tax, sales tax, or other similar tax on consump-
tion, 
‘‘(F) a tax imposed with respect to trans-
actions on a per-unit or per-transaction basis 
rather than on an ad valorem basis, 
‘‘(G) a tax on real or personal property, an 
estate tax, a gift tax, other similar tax, 
‘‘(H) a tax which would not be an 
extraterritorial tax or discriminatory tax (deter-
mined without regard to this subparagraph) ex-
cept by reason of consolidation or loss sharing 
rules that generally apply only with respect to 
income of tax residents of the foreign country, 
or 
‘‘(I) any other tax identified by the Sec-
retary for purposes of this paragraph. 
‘‘(d) OTHER DEFINITIONS.—For purposes of this 
section—
‘‘(1) DISCRIMINATORY
FOREIGN
COUNTRY.—
The term ‘discriminatory foreign country’ means any 
foreign country which has one or more unfair for-
eign taxes.
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‘‘(2) FOREIGN
COUNTRY.—The term ‘foreign 
country’ means a foreign country (or political sub-
division thereof) or a dependent territory or posses-
sion of a foreign country. Such term does not in-
clude any possession of the United States. 
‘‘(3) TAX.—The term ‘tax’ includes any in-
crease in tax whether effectuated by an increase in 
the rate or base of a tax, by a denial of deductions 
or credits, or otherwise. 
‘‘(e) REGULATIONS
AND OTHER GUIDANCE.—The 
Secretary shall issue such regulations or other guidance 
as may be necessary or appropriate to carry out the pur-
poses of this section, including regulations or other guid-
ance which—
‘‘(1) provide for such adjustments to the appli-
cation of this section as are necessary to prevent the 
avoidance of the purposes of this section, including 
the application of this section (including subsections 
(b)(1)(E) 
and 
(c)(2)(A)(ii)) 
with 
respect 
to 
branches, partnerships, and other entities (whether 
or not otherwise disregarded for purposes of this 
chapter), 
‘‘(2) list the discriminatory foreign countries 
(and each such country’s applicable date) in guid-
ance, and update such guidance on a quarterly basis,
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‘‘(3) provide notice to Congress with respect to 
changes to the list under paragraph (2), 
‘‘(4) exercise the authority to provide exceptions 
under subsections (b)(1), (c)(4), and 
‘‘(5) prevent the application of subsection 
(a)(2)(D) from resulting in double counting of 
amounts for purposes of section 59A(c)(4)(A)(ii).’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for subpart D of part II of subchapter N of chapter 1 
is amended by adding at the end the following new item:
‘‘Sec. 899. Enforcement of remedies against unfair foreign taxes.’’.
SEC. 112029. MODIFICATION OF TREATMENT OF SILENC-
ERS. 
(a) IN GENERAL.—Section 5845(a) is amended by 
striking ‘‘(7) any silencer’’ and all that follows through 
‘‘; and (8)’’ and inserting ‘‘and (7)’’. 
(b) TRANSFER TAX.—Section 5811(a) is amended to 
read as follows: 
‘‘(a) RATE.—There shall be levied, collected, and paid 
on firearms transferred a tax at the rate of—
‘‘(1) $5 for each firearm transferred in the case 
of a weapon classified as any other weapon under 
section 5845(e), 
‘‘(2) $0 for each firearm transferred in the case 
of a silencer (as defined in section 921 of title 18, 
United States Code), and
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‘‘(3) $200 for any other firearm transferred.’’. 
(c) MAKING TAX.—Section 5821(a) is amended to 
read as follows: 
‘‘(a) RATE.—There shall be levied, collected, and paid 
upon the making of a firearm a tax at the rate of—
‘‘(1) $0 for each silencer (as defined in section 
921 of title 18, United States Code) made, and 
‘‘(2) $200 for any other firearm made.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to calendar quarters beginning 
more than 90 days after the date of the enactment of this 
Act. 
SEC. 112030. MODIFICATIONS TO DE MINIMIS ENTRY PRIVI-
LEGE FOR COMMERCIAL SHIPMENTS. 
(a) CIVIL PENALTY.—
(1) ADDITIONAL
PENALTY
IMPOSED.—Section 
321 of the Tariff Act of 1930 (19 U.S.C. 1321) is 
amended by adding at the end the following new 
subsection: 
‘‘(c) Any person who enters, introduces, facilitates, 
or attempts to introduce an article into the United States 
using the privilege of this section, the importation of which 
violates any other provision of United States customs law, 
shall be assessed, in addition to any other penalty per-
mitted by law, a civil penalty of up to $5,000 for the first
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violation and up to $10,000 for each subsequent viola-
tion.’’. 
(2) EFFECTIVE DATE.—The amendment made 
by paragraph (1) shall take effect 30 days after the 
date of the enactment of this Act. 
(b) REPEAL
OF COMMERCIAL SHIPMENT EXCEP-
TION.—
(1) REPEAL.—Section 321(a)(2)(B) of such Act 
(19 U.S.C. 1321(a)(2)(B)) is amended by striking 
‘‘of this Act, or’’ and all that follows through ‘‘sub-
division (2); and’’ and inserting ‘‘of this Act; and’’. 
(2) CONFORMING REPEAL.—Subsection (c) of 
such section 321, as added by subsection (a) of this 
section, is repealed. 
(3) EFFECTIVE DATE.—The amendments made 
by this subsection shall take effect on July 1, 2027. 
SEC. 112031. LIMITATION ON DRAWBACK OF TAXES PAID 
WITH RESPECT TO SUBSTITUTED MERCHAN-
DISE. 
Effective for claims filed on or after July 1, 2026, 
for purposes of drawback of internal revenue tax imposed 
under chapter 52 of the Internal Revenue Code of 1986, 
the amount of drawback granted under such Code, or the 
Tariff Act of 1930, on the export or destruction of sub-
stituted merchandise may not exceed the amount of taxes
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paid (and not returned by refund, credit, or drawback) 
on the substituted merchandise. 
SEC. 112032. TREATMENT OF PAYMENTS FROM PARTNER-
SHIPS TO PARTNERS FOR PROPERTY OR 
SERVICES. 
(a) IN GENERAL.—Section 707(a)(2) is amended by 
striking ‘‘Under regulations prescribed’’ and inserting 
‘‘Except as provided’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to services performed, and property 
transferred, after the date of the enactment of this Act. 
(c) RULE OF CONSTRUCTION.—Nothing in this sec-
tion, or the amendments made by this section, shall be 
construed to create any inference with respect to the prop-
er treatment under section 707(a) of the Internal Revenue 
Code of 1986 with respect to payments from a partnership 
to a partner for services performed, or property trans-
ferred, on or before the date of the enactment of this Act. 
PART 2—REMOVING TAXPAYER BENEFITS FOR 
ILLEGAL IMMIGRANTS 
SEC. 112101. PERMITTING PREMIUM TAX CREDIT ONLY FOR 
CERTAIN INDIVIDUALS. 
(a) IN GENERAL.—Section 36B(e)(1) is amended by 
inserting ‘‘or, in the case of aliens who are lawfully
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present, are not eligible aliens’’ after ‘‘individuals who are 
not lawfully present’’. 
(b) ELIGIBLE ALIENS.—Section 36B(e)(2) is amend-
ed—
(1) by striking ‘‘For purposes of this section, 
an individual’’ and inserting the following: ‘‘For pur-
poses of this section—
‘‘(A) IN GENERAL.—An individual’’, and 
(2) by adding at the end the following new sub-
paragraph: 
‘‘(B) ELIGIBLE
ALIENS.—An individual 
who is an alien and lawfully present shall be 
treated as an eligible alien if and only if such 
individual is, and is reasonably expected to be 
for the entire period of enrollment for which the 
credit under this section is being claimed—
‘‘(i) an alien who is lawfully admitted 
for permanent residence under the Immi-
gration and Nationality Act (8 U.S.C. 
1101 et seq.), 
‘‘(ii) an alien who—
‘‘(I) is a citizen or national of the 
Republic of Cuba, 
‘‘(II) is the beneficiary of an ap-
proved petition under section 203(a)
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of the Immigration and Nationality 
Act (8 U.S.C. 1153(a)), 
‘‘(III) meets all eligibility re-
quirements for an immigrant visa but 
for whom such a visa is not imme-
diately available, 
‘‘(IV) is not otherwise inadmis-
sible under section 212(a) of such Act 
(8 U.S.C. 1182(a)), and 
‘‘(V) is physically present in the 
United States pursuant to a grant of 
parole in furtherance of the commit-
ment of the United States to the min-
imum level of annual legal migration 
of Cuban nationals to the United 
States specified in the U.S.-Cuba 
Joint 
Communique´
on 
Migration, 
done at New York September 9, 1994, 
and reaffirmed in the Cuba-United 
States: Joint Statement on Normal-
ization of Migration, Building on the 
Agreement of September 9, 1994, 
done at New York May 2, 1995, or 
‘‘(iii) an individual who lawfully re-
sides in the United States in accordance
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with a Compact of Free Association re-
ferred to in section 402(b)(2)(G) of the 
Personal Responsibility and Work Oppor-
tunity Reconciliation Act of 1996 (8 
U.S.C. 1612(b)(2)(G)).’’. 
(c) CONFORMING AMENDMENTS.—
(1) VERIFICATION OF INFORMATION.—Section 
1411 of the Patient Protection and Affordable Care 
Act (42 U.S.C. 18081) is amended—
(A) in subsection (a)—
(i) in paragraph (1), by striking ‘‘and 
section 36B(e) of the Internal Revenue 
Code of 1986’’; and 
(ii) in paragraph (2)—
(I) in subparagraph (A), by strik-
ing ‘‘and’’ at the end; 
(II) in subparagraph (B), by add-
ing ‘‘and’’ at the end; and 
(III) by adding at the end the 
following new subparagraph: 
‘‘(C) in the case such individual is an alien 
lawfully present in the United States, whether 
such individual is an eligible alien (within the 
meaning of section 36B(e)(2) of such Code);’’;
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(B) in subsection (b)(3), by adding at the 
end the following new subparagraph: 
‘‘(D) IMMIGRATION STATUS.—In the case 
the individual’s eligibility is based on an attes-
tation of the enrollee’s immigration status, an 
attestation that such individual is an eligible 
alien (within the meaning of 36B(e)(2) of the 
Internal Revenue Code of 1986).’’; and 
(C) in subsection (c)(2)(B)(ii), by adding 
at the end the following new subclause: 
‘‘(III) In the case of an indi-
vidual described in clause (i)(I) with 
respect to whom a premium tax credit 
or reduced cost-sharing under section 
36B of the Internal Revenue Code of 
1986 or section 1402 is being claimed, 
the attestation that the individual is 
an eligible alien (within the meaning 
of section 36B(e)(2) of such Code).’’. 
(2) 
ADVANCE
DETERMINATIONS.—Section 
1412(d) of the Patient Protection and Affordable 
Care Act (42 U.S.C. 18082(d)) is amended by in-
serting before the period at the end the following: 
‘‘or, in the case of aliens who are lawfully present,
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are not eligible aliens (within the meaning of section 
36B(e)(2) of the Internal Revenue Code of 1986)’’. 
(3) 
COST-SHARING
REDUCTIONS.—Section 
1402(e) of the Patient Protection and Affordable 
Care Act (42 U.S.C. 18071(e)) is amended—
(A) in the header, by inserting ‘‘OR NOT 
ELIGIBLE ALIENS’’ after ‘‘INDIVIDUALS NOT 
LAWFULLY PRESENT’’; 
(B) in paragraph (1), in the matter pre-
ceding subparagraph (A), by inserting ‘‘or, in 
the case of an alien who is lawfully present, is 
not an eligible alien (within the meaning of sec-
tion 36B(e)(2) of the Internal Revenue Code of 
1986)’’ after ‘‘not lawfully present’’; and 
(C) by amending paragraph (2) to read as 
follows: 
‘‘(2) ELIGIBLE ALIENS.—For purposes of this 
section, an individual shall be treated as an eligible 
alien (within the meaning of section 36B(e)(2) of 
the Internal Revenue Code of 1986) if, and only if, 
the individual is, and for the entire period of enroll-
ment for which the cost-sharing reduction under this 
section is being claimed is reasonably expected to be, 
such an alien.’’.
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(4) 
BASIC
HEALTH
PROGRAMS.—Section 
1331(e)(1) of the Patient Protection and Affordable 
Care Act (42 U.S.C. 18051(e)(1)) is amended by in-
serting before the period at the end the following: 
‘‘or, in the case of an alien who is lawfully present, 
an individual who is not an eligible alien (as defined 
in section 36B(e)(2) of the Internal Revenue Code 
of 1986’’. 
(5) EFFECTIVE DATE.—The amendments made 
by this subsection shall apply with respect to plan 
years beginning on or after January 1, 2027. 
(d) CLERICAL AMENDMENTS.—
(1) The heading for section 36B(e) is amended 
by inserting ‘‘AND NOT ELIGIBLE ALIENS’’ after 
‘‘INDIVIDUALS NOT LAWFULLY PRESENT’’. 
(2) The heading for section 36B(e)(2) is 
amended by inserting ‘‘; ELIGIBLE ALIENS’’ after 
‘‘LAWFULLY PRESENT’’. 
(e) REQUIREMENT TO MAINTAIN MINIMUM ESSEN-
TIAL COVERAGE.—Section 5000A(d)(3) is amended by 
striking ‘‘an alien lawfully present in the United States’’ 
and inserting ‘‘an eligible alien (within the meaning of sec-
tion 36B(e)(2))’’. 
(f) REGULATIONS.—The Secretary of the Treasury 
and the Secretary of Health and Human Services may
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each prescribe such rules and other guidance as may be 
necessary or appropriate to carry out the amendments 
made by this section. 
(g) EFFECTIVE DATE.—The amendments made by 
this section (other than the amendments made by sub-
section (c)) shall apply to taxable years beginning after 
December 31, 2026. 
SEC. 112102. DISALLOWING PREMIUM TAX CREDIT DURING 
PERIODS OF MEDICAID INELIGIBILITY DUE 
TO ALIEN STATUS. 
(a) IN GENERAL.—Section 36B(c)(1) is amended by 
striking subparagraph (B) and by redesignating subpara-
graphs (C), (D), and (E) as subparagraphs (B), (C), and 
(D), respectively. 
(b) CONFORMING AMENDMENTS.—
(1) Section 36B(g)(4)(A) is amended by strik-
ing ‘‘subsection (c)(1)(C)’’ and inserting ‘‘subsection 
(c)(1)(B)’’. 
(2) Section 1331(e)(1)(B) of the Patient Pro-
tection and Affordable Care Act (42 U.S.C. 
18051(e)(1)(B)) is amended by striking ‘‘, or, in the 
case of’’ and all that follows through ‘‘such alien 
status’’.
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may provide, to each person whose name is required to 
be set forth in such return a written statement showing—
‘‘(1) the name and address of the information 
contact of the required reporting person, and 
‘‘(2) the information described in subsection 
(a)(2) which relates to such person. 
‘‘(c) DEFINITIONS.—Any term used in this section 
which is also used in section 4475 shall have the meaning 
given such term in such section.’’. 
(2) PENALTIES.—Section 6724(d), as amended 
by the preceding provisions of this Act, is amend-
ed—
(A) in paragraph (1)(B), by striking ‘‘or’’ 
at the end of clause (xxviii), by striking ‘‘and’’ 
at the end of clause (xxix) and inserting ‘‘or’’, 
and by adding at the end the following new 
clause: 
‘‘(xxx) section 6050BB(a) (relating to 
returns relating to remittance transfers), 
and’’, and 
(B) in paragraph (2), by striking ‘‘or’’ at 
the end of subparagraph (NN), by striking the 
period at the end of subparagraph (OO) and in-
serting ‘‘, or’’, and by inserting after subpara-
graph (OO) the following new subparagraph:
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‘‘(C) with respect to whom such disability 
insurance benefit payments ceased to be pay-
able by reason of section 223(e)(1) of such Act. 
‘‘(3) 
QUALIFIED
BENEFIT
TERMINATION 
MONTH.—For purposes of this subsection—
‘‘(A) IN
GENERAL.—The term ‘qualified 
benefit termination month’ means, with respect 
to any specified Purple Heart recipient, each 
month during the 12-month period beginning 
with the first month with respect to which dis-
ability insurance benefit payments described in 
paragraph (2)(B) ceased to be payable as de-
scribed in paragraph (2)(C). 
‘‘(B) EXCEPTION FOR MONTHS FOR WHICH 
BENEFITS ARE REINSTATED, ETC.—Such term 
shall not include any month if the specified 
Purple Heart recipient receives any benefit pay-
ment under section 223(a) of the Social Secu-
rity Act with respect to such month. 
‘‘(4) SSDI BENEFIT SUBSTITUTION AMOUNT.—
For purposes of this subsection, the term ‘SSDI 
benefit substitution amount’ means, with respect to 
any specified Purple Heart recipient for any quali-
fied benefit termination month, an amount equal to 
the disability insurance benefit payment received by