after 2015, the $5,000,000 amount in subpara-
graph (A)(vi) shall be increased by an amount 
equal to—
‘‘(i) such dollar amount, multiplied by 
‘‘(ii) the cost-of-living adjustment de-
termined under section 1(f)(3) for such 
calendar year by substituting ‘calendar 
year 2014’ for ‘calendar year 1992’ in sub-
paragraph (B) thereof. 
If any amount as adjusted under the preceding 
sentence is not a multiple of $100,000, such 
amount shall be rounded to the nearest multiple 
of $100,000. 
‘‘(4) AGGREGATE DECEASED SPOUSAL UNUSED 
EXCLUSION
AMOUNT.—For purposes of this sub-
section, the term ‘aggregate deceased spousal unused 
exclusion amount’ means the lesser of—
‘‘(A) the basic exclusion amount, or 
‘‘(B) the sum of the deceased spousal un-
used exclusion amounts of the surviving spouse. 
‘‘(5) DECEASED SPOUSAL UNUSED EXCLUSION 
AMOUNT.—For purposes of this subsection, the term 
‘deceased spousal unused exclusion amount’ means, 
with respect to the surviving spouse of any deceased
spouse dying after December 31, 2009, the excess (if 
any) of—
‘‘(A) the applicable exclusion amount of 
the deceased spouse, over 
‘‘(B) the amount with respect to which the 
tentative tax is determined under section 
2001(b)(1) on the estate of such deceased 
spouse. 
‘‘(6) SPECIAL RULES.—
‘‘(A) ELECTION
REQUIRED.—A deceased 
spousal unused exclusion amount may not be 
taken into account by a surviving spouse under 
paragraph (5) unless the executor of the estate 
of the deceased spouse files an estate tax return 
on which such amount is computed and makes 
an election on such return that such amount 
may be so taken into account. Such election, 
once made, shall be irrevocable. No election 
may be made under this subparagraph if such 
return is filed after the time prescribed by law 
(including extensions) for filing such return. 
‘‘(B) EXAMINATION
OF
PRIOR
RETURNS 
AFTER EXPIRATION OF PERIOD OF LIMITATIONS 
WITH
RESPECT
TO
DECEASED
SPOUSAL
UN-
USED
EXCLUSION
AMOUNT.—Notwithstanding
any period of limitation in section 6501, after 
the time has expired under section 6501 within 
which a tax may be assessed under chapter 11 
or 12 with respect to a deceased spousal unused 
exclusion amount, the Secretary may examine a 
return of the deceased spouse to make deter-
minations with respect to such amount for pur-
poses of carrying out this subsection. 
‘‘(7) REGULATIONS.—The Secretary shall pre-
scribe such regulations as may be necessary or ap-
propriate to carry out this subsection.’’. 
(b) CONFORMING AMENDMENTS.—
(1) Paragraph (1) of section 2505(a), as 
amended by section 101, is amended to read as fol-
lows: 
‘‘(1) the applicable credit amount under section 
2010(c) which would apply if the donor died as of 
the end of the calendar year, reduced by’’. 
(2) Section 2631(c) is amended by striking ‘‘the 
applicable exclusion amount’’ and inserting ‘‘the 
basic exclusion amount’’. 
(3) Section 6018(a)(1), after the application of 
section 101(g), is amended by striking ‘‘applicable 
exclusion amount’’ and inserting ‘‘basic exclusion 
amount’’.
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to estates of decedents dying, gen-
eration-skipping transfers, and gifts made, after Decem-
ber 31, 2009. 
TITLE II—EXTENSION AND EX-
PANSION OF CERTAIN TAX 
RELIEF PROVISIONS 
Subtitle A—Extension and 
Modification of Certain Provisions 
SEC. 201. DEDUCTION FOR QUALIFIED TUITION AND RE-
LATED EXPENSES. 
(a) IN GENERAL.—Section 222(e) is amended by 
striking ‘‘2005’’and inserting ‘‘2007’’. 
(b) 
CONFORMING
AMENDMENTS.—Section 
222(b)(2)(B) is amended—
(1) by striking ‘‘a taxable year beginning in 
2004 or 2005’’ and inserting ‘‘any taxable year be-
ginning after 2003’’, and 
(2) by striking ‘‘2004 AND 2005’’ in the heading 
and inserting ‘‘AFTER 2003’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2005.