I 
114TH CONGRESS 
2D SESSION 
H. R. 6439 
To amend the Internal Revenue Code of 1986 to make technical corrections, 
and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
DECEMBER 6, 2016 
Mr. BRADY of Texas (for himself and Mr. NEAL) introduced the following bill; 
which was referred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to make 
technical corrections, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE; TABLE OF CONTENTS; ETC. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Tax Technical Corrections Act of 2016’’. 
(b) AMENDMENT OF INTERNAL REVENUE CODE OF 
1986.—Except as otherwise expressly provided, whenever 
in this Act an amendment or repeal is expressed in terms 
of an amendment to, or repeal of, a section or other provi-
sion, the reference shall be considered to be made to a 
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section or other provision of the Internal Revenue Code 
of 1986. 
(c) TABLE OF CONTENTS.—The table of contents for 
this Act is as follows: 
Sec. 1. Short title; table of contents; etc. 
TITLE I—TAX TECHNICAL CORRECTIONS 
Sec. 101. Amendments relating to Protecting Americans from Tax Hikes Act 
of 2015. 
Sec. 102. Amendment relating to Consolidated Appropriations Act, 2016. 
Sec. 103. Amendments relating to Fixing America’s Surface Transportation 
Act. 
Sec. 104. Amendments relating to Surface Transportation and Veterans Health 
Care Choice Improvement Act of 2015. 
Sec. 105. Amendments relating to Stephen Beck, Jr., ABLE Act of 2014. 
Sec. 106. Amendment relating to American Taxpayer Relief Act of 2012. 
Sec. 107. Amendment relating to United States-Korea Free Trade Agreement 
Implementation Act. 
Sec. 108. Amendment relating to SAFETEA–LU. 
Sec. 109. Amendment relating to the American Jobs Creation Act of 2004. 
TITLE II—TECHNICAL CORRECTIONS RELATED TO PARTNERSHIP 
AUDIT RULES 
Sec. 201. Scope of adjustments subject to partnership audit rules. 
Sec. 202. Determination of imputed underpayments. 
Sec. 203. Alternative procedure to filing amended returns for purposes of modi-
fying imputed underpayment. 
Sec. 204. Treatment of passthrough partners in tiered structures. 
Sec. 205. Treatment of failure of partnership to pay imputed underpayment. 
Sec. 206. Other technical corrections related to partnership audit rules. 
Sec. 207. Effective date. 
TITLE III—OTHER CORRECTIONS 
Sec. 301. Amendments relating to the Bipartisan Budget Act of 2015. 
Sec. 302. Amendments relating to the Energy Policy Act of 2005. 
TITLE IV—CLERICAL CORRECTIONS AND DEADWOOD 
Sec. 401. Clerical corrections and deadwood-related provisions. 
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TITLE I—TAX TECHNICAL 
CORRECTIONS 
SEC. 101. AMENDMENTS RELATING TO PROTECTING AMER-
ICANS FROM TAX HIKES ACT OF 2015. 
(a) AMENDMENT RELATING TO SECTION 105.—Sec-
tion 132(f)(6)(A) is amended by striking the second sen-
tence. 
(b) AMENDMENTS RELATING TO SECTION 121.— 
Section 41(c) is amended— 
(1) by striking paragraph (4), 
(2) by redesignating paragraphs (5), (6), and 
(7) as paragraphs (4), (5), and (6), respectively, and 
(3) by striking the last sentence of paragraph 
(4)(C) (as so redesignated). 
(c) AMENDMENTS RELATING TO SECTION 143.— 
(1) Section 168(k)(2)(B)(i)(III) is amended by 
inserting ‘‘binding’’ before ‘‘contract’’. 
(2) Section 168(k)(5)(B)(ii) is amended— 
(A) by inserting ‘‘crop or’’ after ‘‘more 
than one’’, and 
(B) by inserting ‘‘a marketable crop or 
yield of’’ after ‘‘begins bearing’’. 
(3) Section 168(k)(5)(F) is amended— 
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(A) by striking ‘‘(or is grafted to a plant 
that has already been planted before such 
date)’’, 
(B) by inserting ‘‘or grafted’’ after ‘‘which 
is planted’’, and 
(C) by striking ‘‘(or so grafted)’’ in clauses 
(i) and (ii) and inserting ‘‘or grafted’’. 
(4) Section 168(k)(6) is amended to read as fol-
lows: 
‘‘(6) PHASE-DOWN.—In the case of qualified 
property placed in service by the taxpayer after De-
cember 31, 2017 (December 31, 2018, in the case 
of property described in subparagraph (B) or (C) of 
paragraph (2)), paragraph (1)(A) shall be applied by 
substituting for ‘50 percent’— 
‘‘(A) ‘40 percent’ in the case of— 
‘‘(i) property placed in service in 2018 
(other than property described in subpara-
graph (B) or (C) of paragraph (2)), and 
‘‘(ii) property described in subpara-
graph (B) or (C) of paragraph (2) which 
is placed in service in 2019, and 
‘‘(B) ‘30 percent’ in the case of— 
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‘‘(i) property placed in service in 2019 
(other than property described in subpara-
graph (B) or (C) of paragraph (2)), and 
‘‘(ii) property described in subpara-
graph (B) or (C) of paragraph (2) which 
is placed in service in 2020.’’. 
(5) Section 168(k)(7) is amended by striking 
‘‘paragraphs (1) and (2)(F)’’ and inserting ‘‘para-
graphs (1), (2)(F), and (4)’’. 
(d) AMENDMENTS RELATING TO SECTION 167.— 
(1) Section 168(j)(3) is amended by striking 
‘‘property to which paragraph (1) applies’’ and in-
serting ‘‘qualified Indian reservation property’’. 
(2) Section 168(j)(8) is amended by striking 
‘‘this subsection’’ and inserting ‘‘paragraph (1)’’. 
(e) AMENDMENTS RELATING TO SECTION 202.— 
(1) Section 6722(c)(3)(A) is amended— 
(A) by striking ‘‘any information return’’ 
in clause (iii) and inserting ‘‘such payee state-
ment’’, and 
(B) by striking ‘‘filed’’ in the flush matter 
at the end and inserting ‘‘furnished’’. 
(2) Section 202(e) of the Protecting Americans 
from Tax Hikes Act of 2015 is amended by striking 
‘‘provided’’ and inserting ‘‘furnished’’. 
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(f) AMENDMENTS RELATING TO SECTION 203.— 
(1) Section 6109(i)(1)(A)(i) is amended by 
striking 
‘‘community-based 
certified 
acceptance 
agent’’ and inserting ‘‘community-based certifying 
acceptance agent’’. 
(2) Section 6109(i)(1)(B) is amended by strik-
ing ‘‘Internal Revenue Service’’ and inserting ‘‘Inter-
nal Revenue Service, a community-based certifying 
acceptance agent approved by the Secretary,’’. 
(3) Section 6109(i)(3) is amended— 
(A) in subparagraph (A)— 
(i) by inserting ‘‘ending after the 
issuance of such number’’ before the period 
at the end of the first sentence, and 
(ii) by striking ‘‘on the last day of 
such third consecutive taxable year’’ and 
inserting ‘‘on the day after the due date 
for the return of tax for such third con-
secutive taxable year’’, and 
(B) by striking subparagraph (B)(ii) and 
inserting the following: 
‘‘(ii) if the individual does not file a 
return of tax (or is not included as a de-
pendent on the return of tax of another 
taxpayer) for 3 consecutive taxable years 
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at least one of which ends after December 
18, 2015, the due date for the return of 
tax for such third consecutive taxable 
year.’’. 
(4) Section 203(c) of the Protecting Americans 
from Tax Hikes Act of 2015 is amended— 
(A) by striking ‘‘section 6109(i)(1)(A)(i)’’ 
and inserting ‘‘section 6109(i)(1)’’, 
(B) by striking ‘‘community-based certified 
acceptance agents’’ and inserting ‘‘community- 
based certifying acceptance agents’’, and 
(C) by striking ‘‘CERTIFIED’’ in the head-
ing thereof and inserting ‘‘CERTIFYING’’. 
(5) Section 203(f) of the Protecting Americans 
from Tax Hikes Act of 2015 is amended by striking 
‘‘The amendments’’ and inserting ‘‘Except to the ex-
tent provided in section 6109(i)(3) of the Internal 
Revenue Code of 1986, the amendments’’. 
(g) AMENDMENTS RELATING TO SECTION 204.— 
Section 204(b) of the Protecting Americans from Tax 
Hikes Act of 2015 is amended— 
(1) by striking paragraph (2), and 
(2) by striking so much as precedes ‘‘amend-
ment made by this section’’ and inserting the fol-
lowing: ‘‘(b) EFFECTIVE DATE.—The’’. 
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(h) AMENDMENTS RELATING TO SECTION 205.— 
(1) Section 24(e)(2) is amended by striking 
‘‘identifying number’’ and inserting ‘‘taxpayer identi-
fication number’’. 
(2) Section 205(c) of the Protecting Americans 
from Tax Hikes Act of 2015 is amended— 
(A) by striking paragraph (2), and 
(B) by striking so much as precedes ‘‘shall 
apply to any return of tax’’ and inserting the 
following: ‘‘(c) EFFECTIVE DATE.—The amend-
ments made by this section’’. 
(i) AMENDMENTS RELATING TO SECTION 206.—Sec-
tion 206(b) of the Protecting Americans from Tax Hikes 
Act of 2015 is amended— 
(1) by striking ‘‘Except as provided in para-
graph (2), the amendment’’ in paragraph (1) and in-
serting ‘‘The amendment’’, and 
(2) by striking paragraph (2) and redesignating 
paragraph (3) as paragraph (2). 
(j) AMENDMENT RELATING TO SECTION 209.—Sec-
tion 209(d)(2) of the Protecting Americans from Tax 
Hikes Act of 2015 is amended by striking ‘‘amendment 
made by subsection (b)’’ and inserting ‘‘amendments made 
by subsections (b) and (c)’’. 
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(k) AMENDMENTS RELATED TO SECTIONS 102, 206, 
207, 208, AND 211.— 
(1) Section 25A(b)(1) is amended— 
(A) in subparagraph (A) by striking 
‘‘$1,000’’ and inserting ‘‘$2,000’’, and 
(B) in subparagraph (B)— 
(i) by striking ‘‘50 percent’’ and in-
serting ‘‘25 percent’’, 
(ii) by striking ‘‘$1,000’’ and insert-
ing ‘‘$2,000’’, and 
(iii) by striking ‘‘the applicable limit’’ 
and inserting ‘‘$4,000’’. 
(2) Subparagraphs (A) and (C) of section 
25A(b)(2) are amended by striking ‘‘2’’ in the head-
ing and text of each subparagraph and inserting 
‘‘4’’. 
(3) Section 25A(b)(4) is amended to read as 
follows: 
‘‘(4) RESTRICTIONS ON TAXPAYERS WHO IM-
PROPERLY CLAIMED AMERICAN OPPORTUNITY TAX 
CREDIT IN PRIOR YEARS.— 
‘‘(A) TAXPAYERS MAKING PRIOR FRAUDU-
LENT OR RECKLESS CLAIMS.— 
‘‘(i) IN GENERAL.—No American Op-
portunity Tax Credit shall be allowed 
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chapter B of chapter 63, no American Oppor-
tunity Tax Credit shall be allowed under this 
section for any subsequent taxable year unless 
the taxpayer provides such information as the 
Secretary may require to demonstrate eligibility 
for such credit.’’. 
(4) Section 25A(d) is amended to read as fol-
lows: 
‘‘(d) LIMITATIONS BASED ON MODIFIED ADJUSTED 
GROSS INCOME.— 
‘‘(1) AMERICAN OPPORTUNITY TAX CREDIT.— 
The American Opportunity Tax Credit (determined 
without regard to this paragraph) shall be reduced 
(but not below zero) by the amount which bears the 
same ratio to such credit (as so determined) as— 
‘‘(A) the excess of— 
‘‘(i) the taxpayer’s modified adjusted 
gross income for such taxable year, over 
‘‘(ii) $80,000 ($160,000 in the case of 
a joint return), bears to 
‘‘(B) $10,000 ($20,000 in the case of a 
joint return). 
‘‘(2) LIFETIME LEARNING CREDIT.—The Life-
time Learning Credit (determined without regard to 
this paragraph) shall be reduced (but not below 
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zero) by the amount which bears the same ratio to 
such credit (as so determined) as— 
‘‘(A) the excess of— 
‘‘(i) the taxpayer’s modified adjusted 
gross income for such taxable year, over 
‘‘(ii) $40,000 ($80,000 in the case of 
a joint return), bears to 
‘‘(B) $10,000 ($20,000 in the case of a 
joint return). 
‘‘(3) MODIFIED
ADJUSTED
GROSS
INCOME.— 
For purposes of this subsection, the term ‘modified 
adjusted gross income’ means the adjusted gross in-
come of the taxpayer for the taxable year increased 
by any amount excluded from gross income under 
section 911, 931, or 933.’’. 
(5) Section 25A(f)(1) is amended by adding at 
the end the following new subparagraph: 
‘‘(D) 
REQUIRED
COURSE
MATERIALS 
TAKEN INTO ACCOUNT FOR AMERICAN OPPOR-
TUNITY TAX CREDIT.—For purposes of deter-
mining the American Opportunity Tax Credit, 
subparagraph (A) shall be applied by sub-
stituting ‘tuition, fees, and course materials’ for 
‘tuition and fees’.’’. 
(6) Section 25A(g)(1) is amended— 
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(A) by striking ‘‘No credit’’ and inserting 
the following: 
‘‘(A) IN GENERAL.—No credit’’, and 
(B) by adding at the end the following new 
subparagraph: 
‘‘(B) ADDITIONAL
IDENTIFICATION
RE-
QUIREMENTS WITH RESPECT TO AMERICAN OP-
PORTUNITY TAX CREDIT.— 
‘‘(i) STUDENT.—The requirements of 
subparagraph (A) shall not be treated as 
met with respect to the American Oppor-
tunity Tax Credit unless the individual’s 
taxpayer identification number was issued 
on or before the due date for filing the re-
turn of tax for the taxable year. 
‘‘(ii) TAXPAYER.—No American Op-
portunity Tax Credit shall be allowed 
under this section if the taxpayer identi-
fication number of the taxpayer was issued 
after the due date for filing the return for 
the taxable year. 
‘‘(iii) 
INSTITUTION.—No 
American 
Opportunity Tax Credit shall be allowed 
under this section unless the taxpayer in-
cludes the employer identification number 
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of any institution to which qualified tuition 
and related expenses were paid with re-
spect to the individual.’’. 
(7) Section 25A(h) is amended to read as fol-
lows: 
‘‘(h) INFLATION ADJUSTMENT.— 
‘‘(1) IN GENERAL.—In the case of a taxable 
year beginning after 2001, the $40,000 and $80,000 
amounts in subsection (d)(2) shall each be increased 
by an amount equal to— 
‘‘(A) such dollar amount, multiplied by 
‘‘(B) the cost-of-living adjustment deter-
mined under section 1(f)(3) for the calendar 
year in which the taxable year begins, deter-
mined by substituting ‘calendar year 2000’ for 
‘calendar year 1992’ in subparagraph (B) 
thereof. 
‘‘(2) ROUNDING.—If any amount as adjusted 
under paragraph (1) is not a multiple of $1,000, 
such amount shall be rounded to the next lowest 
multiple of $1,000.’’. 
(8) Section 25A(i) is amended to read as fol-
lows: 
‘‘(i) PORTION
OF AMERICAN OPPORTUNITY TAX 
CREDIT MADE REFUNDABLE.—Forty percent of so much 
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of the credit allowed under subsection (a) as is attrib-
utable to the American Opportunity Tax Credit (deter-
mined after application of subsection (d) and without re-
gard to this paragraph and section 26(a)) shall be treated 
as a credit allowable under subpart C (and not allowed 
under subsection (a)). The preceding sentence shall not 
apply to any taxpayer for any taxable year if such tax-
payer is a child to whom subsection (g) of section 1 applies 
for such taxable year.’’. 
(9) The heading of section 25A is amended by 
striking ‘‘HOPE’’ and inserting ‘‘AMERICAN OP-
PORTUNITY’’. 
(10) The item relating to section 25A in the 
table of contents for subpart A of part IV of sub-
chapter A of chapter 1 is amended to read as fol-
lows: 
‘‘Sec. 25A. American Opportunity and Lifetime Learning credits.’’. 
(11) The heading of section 25A(b) is amended 
by striking ‘‘HOPE SCHOLARSHIP CREDIT’’ and in-
serting ‘‘AMERICAN OPPORTUNITY TAX CREDIT’’. 
(12) The heading of section 25A(b)(2) is 
amended by striking ‘‘HOPE SCHOLARSHIP CREDIT’’ 
and inserting ‘‘AMERICAN OPPORTUNITY TAX CRED-
IT’’. 
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(13) The heading of section 25A(c)(2)(A) is 
amended by striking ‘‘HOPE SCHOLARSHIP’’ and in-
serting ‘‘AMERICAN OPPORTUNITY TAX CREDIT’’. 
(14) Section 25A, as amended by the preceding 
provisions of this Act, is amended by striking ‘‘Hope 
Scholarship Credit’’ each place it appears in the text 
and inserting ‘‘American Opportunity Tax Credit’’. 
(15) The heading of section 529(c)(3)(B)(v) is 
amended by striking ‘‘HOPE’’ and inserting ‘‘AMER-
ICAN OPPORTUNITY’’. 
(16) The heading of section 530(d)(2)(C) is 
amended by striking ‘‘HOPE’’ and inserting ‘‘AMER-
ICAN OPPORTUNITY’’. 
(17) Section 6211(b)(4)(A), as amended by this 
Act, is amended by striking ‘‘subsection (i)(5)’’ and 
inserting ‘‘subsection (i)’’. 
(18) Section 6213(g)(2)(Q) is amended to read 
as follows: 
‘‘(Q) an omission of information required 
by section 25A(b)(4)(B) or an entry on the re-
turn claiming the American Opportunity Tax 
Credit for a taxable year for which such credit 
is disallowed under section 25A(b)(4)(A).’’. 
(19) Section 207(b)(1) of the Protecting Ameri-
cans from Tax Hikes Act of 2015 is amended by 
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striking ‘‘the American opportunity tax credit under 
section 25A(i) of such Code’’ and inserting ‘‘the 
American Opportunity Tax Credit under section 25A 
of such Code’’. 
(l) AMENDMENT RELATING TO SECTION 311.— 
(1) The last sentence of section 355(h)(2)(B) is 
amended by striking ‘‘80 percent’’ both places it ap-
pears and inserting ‘‘at least 80 percent’’. 
(2) Section 355(h)(2) is amended— 
(A) by striking ‘‘SPINOFFS’’ in the heading 
of such paragraph and inserting ‘‘DISTRIBU-
TIONS’’, and 
(B) by striking ‘‘SPINOFFS’’ in the head-
ings of subparagraphs (A) and (B) and insert-
ing ‘‘DISTRIBUTIONS’’. 
(m) AMENDMENT RELATING TO SECTION 318.— 
(1) Section 856(c)(9)(A) is amended— 
(A) by striking ‘‘Personal property’’ and 
inserting the following: 
‘‘(i) IN
GENERAL.—Personal prop-
erty’’, and 
(B) by adding at the end the following new 
clause: 
‘‘(ii) TREATMENT
OF
GAIN
ON
DIS-
POSITION.—If— 
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and (3)(H) as gain from the disposition of 
a real estate asset.’’. 
(2) Section 856(c)(9)(B) is amended to read as 
follows: 
‘‘(B) 
CERTAIN
PERSONAL
PROPERTY 
MORTGAGED IN CONNECTION WITH REAL PROP-
ERTY.— 
‘‘(i) IN GENERAL.—In the case of an 
obligation secured by a mortgage on both 
real property and personal property, if the 
fair market value of such personal property 
does not exceed 15 percent of the total fair 
market value of all such property, such ob-
ligation shall be treated— 
‘‘(I) for purposes of paragraph 
(3)(B), as an obligation described 
therein, 
‘‘(II) for purposes of paragraph 
(4)(A), as a real estate asset, and 
‘‘(III) for purposes of paragraphs 
(2)(D) and (3)(C), as a mortgage on 
real property. 
‘‘(ii) DETERMINATION OF FAIR MAR-
KET VALUE.— 
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‘‘(I) IN
GENERAL.—Except as 
provided in subclause (II), the fair 
market value of all such property shall 
be determined for purposes of clause 
(i) in the same manner as the fair 
market value of real property is deter-
mined for purposes of apportioning in-
terest income between real property 
and personal property under para-
graph (3)(B). 
‘‘(II) GAIN
ON
DISPOSITION.— 
For purposes of applying clause 
(i)(III), fair market value shall be de-
termined at the time of sale or other 
disposition.’’. 
(n) AMENDMENTS RELATING TO SECTION 322.— 
(1) Section 897(k)(2) is amended— 
(A) by striking so much of subparagraph 
(B) as precedes ‘‘amounts realized by the quali-
fied shareholder’’ and inserting the following: 
‘‘(B) EXCEPTION.—In the case of a quali-
fied shareholder with one or more applicable in-
vestors— 
‘‘(i) subparagraph (A)(i) shall not 
apply to the applicable percentage of the 
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stock of the real estate investment trust 
held by the qualified shareholder, and 
‘‘(ii) the applicable percentage of the’’, 
and 
(B) by adding at the end the following new 
subparagraph: 
‘‘(F) 
APPLICABLE
PERCENTAGE.—For 
purposes of subparagraph (B), the term ‘appli-
cable percentage’ means the percentage of the 
value of the interests (other than interests held 
solely as a creditor) in the qualified shareholder 
held by applicable investors.’’. 
(2) Section 897(k)(2)(D) is amended by strik-
ing ‘‘paragraph’’ and inserting ‘‘subsection’’. 
(3) Section 897(k)(2)(E) is amended by strik-
ing ‘‘and (C) and paragraph (4)’’ and inserting ‘‘and 
(D)’’. 
(4) Section 897(k)(3)(B)(i) is amended by 
striking so much as precedes ‘‘for a reduced rate of 
withholding’’ and inserting the following: 
‘‘(i) which— 
‘‘(I) is eligible for benefits under 
the comprehensive income tax treaty 
described in subparagraph (A)(i)(I), 
but only if the dividends article of 
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such treaty imposes conditions on the 
benefits allowable in the case of divi-
dends paid by a real estate investment 
trust, and 
‘‘(II) is eligible under such trea-
ty’’. 
(5) Section 897(k)(3)(B)(ii) is amended— 
(A) by adding ‘‘and’’ at the end of sub-
clause (II), and 
(B) by striking ‘‘United States corpora-
tion’’ in subclause (III) and inserting ‘‘domestic 
corporation’’. 
(6) Section 322 of the Protecting Americans 
from Tax Hikes Act of 2015 is amended by striking 
subsections (b)(2) and (c)(3), and the Internal Rev-
enue Code of 1986 shall be applied as if such sub-
sections, and amendments made thereby, had never 
been enacted. 
(7) Section 322(c)(2) of such Act is amended 
by striking ‘‘take effect on’’ and inserting the fol-
lowing: ‘‘apply with respect to testing periods (as de-
fined in section 897(h)(4)(D) of the Internal Rev-
enue Code of 1986) ending on or after’’. 
(o) AMENDMENTS RELATED TO SECTION 323.— 
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(1) So much of subsection (l) of section 897 as 
precedes paragraph (2) thereof is amended to read 
as follows: 
‘‘(l) EXCEPTION FOR QUALIFIED FOREIGN PENSION 
FUNDS.— 
‘‘(1) IN GENERAL.—For purposes of this sec-
tion, a qualified foreign pension fund shall not be 
treated as a nonresident alien individual or a foreign 
corporation. For purposes of the preceding sentence, 
an entity all the interests of which are held by a 
qualified foreign pension fund shall be treated as 
such a fund.’’. 
(2) Subparagraph (B) of section 897(l)(2) is 
amended to read as follows: 
‘‘(B) which is established— 
‘‘(i) by such country (or one or more 
political subdivisions thereof) to provide re-
tirement or pension benefits to participants 
or beneficiaries that are current or former 
employees (including self-employed individ-
uals) or persons designated by such em-
ployees, as a result of services rendered by 
such employees to their employers, or 
‘‘(ii) by one or more employers to pro-
vide retirement or pension benefits to par-
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ticipants or beneficiaries that are current 
or former employees (including self-em-
ployed individuals) or persons designated 
by such employees in consideration for 
services rendered by such employees to 
such employers,’’. 
(3) Section 897(l)(2)(D) is amended by striking 
‘‘provides annual information reporting about its 
beneficiaries to the relevant tax authorities’’ and in-
serting ‘‘with respect to which annual information 
about its beneficiaries is provided, or is otherwise 
available, to the relevant tax authorities’’. 
(4) Section 897(l)(2)(E) is amended— 
(A) by striking ‘‘such entity’’ in clause (i) 
and inserting ‘‘such entity or arrangement’’, 
and 
(B) by striking ‘‘or such income is taxed at 
a reduced rate’’ in clause (ii) and inserting ‘‘, 
or such income is excluded from the gross in-
come of such entity or arrangement or is taxed 
at a reduced rate’’. 
(p) AMENDMENTS RELATING TO SECTION 333.— 
(1) Section 831(b)(2) is amended by redesig-
nating subparagraph (D) as subparagraph (E) and 
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by inserting after subparagraph (C) the following 
new subparagraph: 
‘‘(D) LOOK-THROUGH
OF
REINSURANCE 
AND FRONTING ARRANGEMENTS.—In the case 
of reinsurance or any fronting, intermediary, or 
similar arrangement, the term ‘policyholder’ 
means each policyholder of the underlying di-
rect written insurance with respect to such rein-
surance or arrangement.’’. 
(2)(A) Subclause (II) of section 831(b)(2)(B)(i) 
is amended by striking ‘‘specified assets’’ and insert-
ing ‘‘relevant specified assets’’. 
(B) Section 831(b)(2)(B)(ii) is amended by re-
designating subclauses (II), (III), and (IV) as sub-
clauses (III), (IV), and (V), respectively, and by in-
serting after subclause (I) the following new sub-
clause: 
‘‘(II) RELEVANT SPECIFIED AS-
SETS.—The term ‘relevant specified 
assets’ means, with respect to any 
specified holder with respect to any 
insurance company, the aggregate 
amount of the specified assets, with 
respect to such insurance company, 
any interest in which is held (directly 
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or indirectly) by any spouse or speci-
fied relation of such specified holder. 
Such term shall not include any speci-
fied asset solely by reason of an inter-
est in such asset which was acquired 
by such spouse or specified relation by 
bequest, devise, or inheritance from a 
decedent during the taxable year of 
the insurance company or the pre-
ceding taxable year. For purposes of 
this subclause, the term ‘specified re-
lation’ means any individual with re-
spect to whom the specified holder 
bears a relationship described in sub-
clause (I).’’. 
(q) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in the provision 
of the Protecting Americans from Tax Hikes Act of 2015 
to which they relate. 
SEC. 102. AMENDMENT RELATING TO CONSOLIDATED AP-
PROPRIATIONS ACT, 2016. 
(a) AMENDMENT RELATING TO SECTION 305 OF DI-
VISION P.—Section 199(c)(3)(C)(i) is amended— 
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(1) by inserting ‘‘who elects the application of 
this clause for any taxable year,’’ after ‘‘In the case 
of any taxpayer’’, 
(2) by striking ‘‘and who’’ and inserting ‘‘, and 
who’’, 
(3) by striking ‘‘the taxable year’’ and inserting 
‘‘such taxable year’’, and 
(4) by striking ‘‘under subsection (d)(9)(B)’’ 
and inserting ‘‘(as defined in subsection (d)(9)(B))’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 305 
of division P of the Consolidated Appropriations Act, 
2016. 
SEC. 103. AMENDMENTS RELATING TO FIXING AMERICA’S 
SURFACE TRANSPORTATION ACT. 
(a) AMENDMENTS RELATING TO SECTION 32101.— 
(1) Section 7345(e)(1) is amended— 
(A) by striking ‘‘or the Tax Court’’ and in-
serting ‘‘, or against the Commissioner in the 
Tax Court,’’, and 
(B) by adding at the end the following: 
‘‘For purposes of the preceding sentence, the 
court first acquiring jurisdiction over such an 
action shall have sole jurisdiction.’’. 
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(2) Section 7345(f) is amended by striking 
‘‘subsection 
(a)’’ 
and 
inserting 
‘‘subsection 
(b)(1)(B)’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in section 
32101 of the Fixing America’s Surface Transportation 
Act. 
SEC. 104. AMENDMENTS RELATING TO SURFACE TRANS-
PORTATION AND VETERANS HEALTH CARE 
CHOICE IMPROVEMENT ACT OF 2015. 
(a) AMENDMENT RELATING TO SECTION 2004.— 
Section 6662(k) is amended to read as follows: 
‘‘(k) INCONSISTENT ESTATE BASIS REPORTING.— 
For purposes of this section, there is an ‘inconsistent es-
tate basis’ if the adjusted basis of property (to which sec-
tion 1014(f) applies) claimed on a return exceeds the 
amount that would have been so claimed if the basis of 
such property had been properly determined under such 
section.’’. 
(b) AMENDMENTS RELATING TO SECTION 2008.— 
Section 9503(e)(2) is amended— 
(1) by striking ‘‘per gallon’’ in subparagraph 
(C) and inserting ‘‘per energy equivalent of a gallon 
of diesel (as defined in section 4041(a)(2)(D))’’, and 
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(2) by striking ‘‘per gallon’’ in subparagraph 
(D) and inserting ‘‘per energy equivalent of a gallon 
of gasoline (as defined in section 4041(a)(2)(C))’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in the provision 
of the Surface Transportation and Veterans Health Care 
Choice Improvement Act of 2015 to which they relate. 
SEC. 105. AMENDMENTS RELATING TO STEPHEN BECK, JR., 
ABLE ACT OF 2014. 
(a) AMENDMENTS RELATING TO SECTION 208.— 
Section 208(h) of the Stephen Beck, Jr., ABLE Act of 
2014 is amended— 
(1) by striking so much as precedes ‘‘made by 
this section’’ and inserting the following: 
‘‘(h) EFFECTIVE DATE.— 
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments’’, 
(2) by inserting ‘‘, and statements required to 
be furnished,’’ after ‘‘returns required to be filed’’, 
and 
(3) by adding at the end the following new 
paragraph: 
‘‘(2) SUBSECTION (c).—The amendment made 
by subsection (c) shall apply to returns or claims for 
refund filed after December 31, 2014.’’. 
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(b) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in section 208 
of the Stephen Beck, Jr., ABLE Act of 2014. 
SEC. 106. AMENDMENT RELATING TO AMERICAN TAXPAYER 
RELIEF ACT OF 2012. 
(a) AMENDMENT RELATING TO SECTION 104.—Sec-
tion 6211(b)(4)(A) is amended by striking ‘‘subsection 
(i)(6)’’ and inserting ‘‘subsection (i)(5)’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 104 
of the American Taxpayer Relief Act of 2012. 
SEC. 107. AMENDMENT RELATING TO UNITED STATES- 
KOREA FREE TRADE AGREEMENT IMPLE-
MENTATION ACT. 
(a) AMENDMENT RELATING TO SECTION 501.—Sec-
tion 501(b) of the United States-Korea Free Trade Agree-
ment Implementation Act is amended by striking ‘‘returns 
required to be filed’’ and inserting ‘‘documents prepared’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 501 
of the United States-Korea Free Trade Agreement Imple-
mentation Act. 
SEC. 108. AMENDMENT RELATING TO SAFETEA–LU. 
(a) AMENDMENT RELATING TO SECTION 11125.— 
Section 5681(b) is amended by striking ‘‘who has paid the 
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special tax (or who is exempt from payment of such special 
tax by reason of the provisions of section 5113(a))’’ and 
inserting ‘‘who meets the requirements of section 5121(a) 
and section 5124 (or who is exempt from such require-
ments by reason of section 5121(b))’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 
11125 of the Safe, Accountable, Flexible, Efficient Trans-
portation Equity Act: A Legacy for Users. 
SEC. 109. AMENDMENT RELATING TO THE AMERICAN JOBS 
CREATION ACT OF 2004. 
(a) AMENDMENT RELATING TO SECTION 319.—Sec-
tion 501(c)(12)(E) is amended by striking ‘‘means the 
Federal Energy Regulatory Commission’’ and all that fol-
lows and inserting: ‘‘means— 
‘‘(i) the Federal Energy Regulatory 
Commission, and 
‘‘(ii) in the case of any utility with re-
spect to which all of the electricity gen-
erated, transmitted, or distributed by such 
utility is generated, transmitted, distrib-
uted, and consumed in the same State, the 
State agency of such State with the au-
thority to regulate electric utilities.’’. 
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(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect as if included in section 319 
of the American Jobs Creation Act of 2004. 
TITLE II—TECHNICAL CORREC-
TIONS 
RELATED 
TO 
PART-
NERSHIP AUDIT RULES 
SEC. 201. SCOPE OF ADJUSTMENTS SUBJECT TO PARTNER-
SHIP AUDIT RULES. 
(a) IN GENERAL.—Section 6241(2) is amended to 
read as follows: 
‘‘(2) PARTNERSHIP ADJUSTMENT.— 
‘‘(A) IN GENERAL.—The term ‘partnership 
adjustment’ means any adjustment to a part-
nership-related item. 
‘‘(B) PARTNERSHIP-RELATED ITEM.—The 
term ‘partnership-related item’ means— 
‘‘(i) any item or amount with respect 
to the partnership (without regard to 
whether or not such item or amount ap-
pears on the partnership’s return and in-
cluding any item or amount relating to any 
transaction with, basis in, or liability of, 
the partnership) which is relevant (deter-
mined without regard to this subchapter) 
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in determining the tax liability of any per-
son under chapter 1, and 
‘‘(ii) any partner’s distributive share 
of any item or amount described in clause 
(i).’’. 
(b) COORDINATION WITH OTHER CHAPTERS.—Sec-
tion 6241 is amended by adding at the end the following 
new paragraph: 
‘‘(9) COORDINATION WITH OTHER CHAPTERS.— 
This subchapter shall not apply with respect to any 
tax imposed (or any amount required to be deducted 
or withheld) under chapter 2, 2A, 3, or 4, except 
that any partnership adjustment determined under 
this subchapter for purposes of chapter 1 shall be 
taken into account for purposes of determining any 
such tax to the extent that such adjustment is rel-
evant to such determination.’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 6211(c) is amended to read as fol-
lows: 
‘‘(c) COORDINATION WITH SUBCHAPTER C.—In de-
termining the amount of any deficiency for purposes of 
this subchapter, adjustments to partnership-related items 
shall be made only as provided in subchapter C.’’. 
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(2) Section 6221(a) is amended to read as fol-
lows: 
‘‘(a) IN GENERAL.—Any adjustment to a partner-
ship-related item shall be determined, and any tax attrib-
utable thereto shall be assessed and collected, and the ap-
plicability of any penalty, addition to tax, or additional 
amount which relates to an adjustment to any such item 
shall be determined, at the partnership level, except to the 
extent otherwise provided in this subchapter.’’. 
(3) Section 6222(a) is amended to read as fol-
lows: 
‘‘(a) IN GENERAL.—A partner shall, on the partner’s 
return, treat any partnership-related item in a manner 
which is consistent with the treatment of such item on 
the partnership return.’’. 
(4) Section 6226(a)(2) is amended by striking 
‘‘any adjustment to income, gain, loss, deduction, or 
credit’’ and inserting ‘‘any adjustment to a partner-
ship-related item’’. 
(5) Section 6227(a) is amended by striking 
‘‘items of income, gain, loss, deduction, or credit of 
the partnership’’ and inserting ‘‘partnership-related 
items’’. 
(6) Section 6231(a)(1) is amended by striking 
‘‘any item of income, gain, loss, deduction, or credit 
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of a partnership for a partnership taxable year’’ and 
inserting ‘‘any partnership-related item for any part-
nership taxable year’’. 
(7) Section 6234(c) is amended by striking ‘‘all 
items of income, gain, loss, deduction, or credit of 
the partnership’’ and inserting ‘‘all partnership-re-
lated items’’. 
SEC. 202. DETERMINATION OF IMPUTED UNDERPAYMENTS. 
(a) IN GENERAL.—Section 6225(b) is amended to 
read as follows: 
‘‘(b) DETERMINATION
OF
IMPUTED
UNDERPAY-
MENTS.—For purposes of this subchapter— 
‘‘(1) IN GENERAL.—Except as otherwise pro-
vided in this section, any imputed underpayment 
with respect to any reviewed year shall be deter-
mined by the Secretary by— 
‘‘(A) appropriately netting all partnership 
adjustments with respect to such reviewed year, 
and 
‘‘(B) applying the highest rate of tax in ef-
fect for the reviewed year under section 1 or 
11. 
‘‘(2) ADJUSTMENTS TO DISTRIBUTIVE SHARES 
OF PARTNERS NOT NETTED.—In the case of any ad-
justment which reallocates the distributive share of 
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any item from one partner to another, such adjust-
ment shall be taken into account by disregarding so 
much of such adjustment as results in a decrease in 
the amount of the imputed underpayment. 
‘‘(3) ADJUSTMENTS SEPARATELY NETTED BY 
CATEGORY.—For purposes of paragraph (1)(A), 
partnership adjustments for any reviewed year shall 
first be separately determined (and netted as appro-
priate) within each category of items that are re-
quired to be taken into account separately under 
section 702(a) or other provision of this title. 
‘‘(4) LIMITATION ON ADJUSTMENTS THAT MAY 
BE
TAKEN
INTO
ACCOUNT.—If any adjustment 
would (but for this paragraph)— 
‘‘(A) result in a decrease in the amount of 
the imputed underpayment, and 
‘‘(B) could be subject to any additional 
limitation under the provisions of this title (or 
not allowed, in whole or in part, against ordi-
nary income) if such adjustment were taken 
into account by any person, 
such adjustment shall not be taken into account 
under paragraph (1)(A) except to the extent other-
wise provided by the Secretary.’’. 
(b) CONFORMING AMENDMENTS.— 
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(1) Section 6225(a) is amended to read as fol-
lows: 
‘‘(a) IN GENERAL.—In the case of any adjustments 
by the Secretary to any partnership-related items with re-
spect to any reviewed year of a partnership— 
‘‘(1) if such adjustments result in an imputed 
underpayment, the partnership shall pay an amount 
equal to such imputed underpayment in the adjust-
ment year as provided in section 6232, and 
‘‘(2) if such adjustments do not result in an im-
puted underpayment, such adjustments shall be 
taken into account by the partnership in the adjust-
ment year.’’. 
(2) Section 6225(c) is amended by adding at 
the end the following new paragraph: 
‘‘(9) MODIFICATION OF ADJUSTMENTS NOT RE-
SULTING
IN
AN
IMPUTED
UNDERPAYMENT.—The 
Secretary shall establish procedures under which the 
adjustments described in subsection (a)(2) may be 
modified in such manner as the Secretary deter-
mines appropriate.’’. 
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SEC. 203. ALTERNATIVE PROCEDURE TO FILING AMENDED 
RETURNS FOR PURPOSES OF MODIFYING IM-
PUTED UNDERPAYMENT. 
(a) IN GENERAL.—Section 6225(c)(2) is amended to 
read as follows: 
‘‘(2) PROCEDURES FOR PARTNERS TO TAKE AD-
JUSTMENTS INTO ACCOUNT.— 
‘‘(A) AMENDED RETURNS OF PARTNERS.— 
Such procedures shall provide that if— 
‘‘(i) one or more partners file returns 
for the taxable year of the partners which 
includes the end of the reviewed year of 
the partnership (and for any taxable year 
with respect to which any tax attribute is 
affected by reason of any adjustment re-
ferred to in clause (ii)), 
‘‘(ii) such returns take into account 
all adjustments under subsection (a) prop-
erly allocable to such partners (and the ef-
fect of such adjustments on any tax at-
tributes), and 
‘‘(iii) payment of any tax due is in-
cluded with such returns, 
then the imputed underpayment amount shall 
be determined without regard to the portion of 
the adjustments so taken into account. 
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‘‘(B) ALTERNATIVE PROCEDURE TO FIL-
ING
AMENDED
RETURNS.—Such procedures 
shall provide that, with respect to any partner 
referred to in subparagraph (A), the require-
ments of subparagraph (A) shall be treated as 
satisfied with respect to adjustments properly 
allocable to such partner if, in lieu of filing the 
returns described in such subparagraph— 
‘‘(i) the amounts described in sub-
paragraph (A)(iii) are paid by the partner, 
‘‘(ii) the adjustments to the tax at-
tributes of such partner referred to in sub-
paragraph (A)(ii) are binding with respect 
to all subsequent taxable years of the part-
ner, and 
‘‘(iii) such partner provides, in the 
form and manner specified by the Sec-
retary (including, if the Secretary so speci-
fies, in the same form as on an amended 
return), such information as the Secretary 
may require to carry out this subpara-
graph. 
‘‘(C) REALLOCATION
OF
DISTRIBUTIVE 
SHARE.—In the case of any adjustment which 
reallocates the distributive share of any item 
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from one partner to another, this paragraph 
shall apply with respect to any such partner 
only if the requirements of subparagraph (A) or 
(B) are satisfied with respect to all partners af-
fected by such adjustment. 
‘‘(D) APPLICATION OF STATUTE OF LIMI-
TATIONS.—Sections 6501 and 6511 shall not 
apply with respect to any return filed for pur-
poses of subparagraph (A)(i) or any amount 
paid under subparagraph (A)(iii) or (B)(i), but 
only with respect to adjustments referred to in 
subparagraph (A)(ii). 
‘‘(E) APPLICATION TO TIERED PARTNER-
SHIPS.—In the case of any partnership any 
partner of which is a partnership, except as 
otherwise provided by the Secretary, subpara-
graph (B) shall apply with respect to any part-
ner in the chain of ownership of such partner-
ships. For purposes of applying the preceding 
sentence, an S corporation and its shareholders 
shall be treated in the same manner as a part-
nership and its partners.’’. 
(b) CONFORMING AMENDMENT.—Section 6201(a)(1) 
is amended by inserting ‘‘(or payments under section 
6225(c)(2)(B)(i))’’ after ‘‘returns or lists’’. 
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SEC. 204. TREATMENT OF PASSTHROUGH PARTNERS IN 
TIERED STRUCTURES. 
(a) IN GENERAL.—Section 6226(b) is amended by 
adding at the end the following new paragraph: 
‘‘(4) TREATMENT OF PARTNERSHIPS IN TIERED 
STRUCTURES.— 
‘‘(A) IN GENERAL.—If a partner which re-
ceives a statement under subsection (a)(2) is a 
partnership or an S corporation, such partner 
shall, with respect to the partner’s share of the 
adjustment— 
‘‘(i) file with the Secretary a partner-
ship adjustment tracking report which in-
cludes such information as the Secretary 
may require, and 
‘‘(ii) either— 
‘‘(I) pay the imputed under-
payment under rules similar to the 
rules of section 6225 (other than 
paragraphs (2)(A), (6), (7), and (9) of 
subsection (c) thereof), or 
‘‘(II) furnish statements under 
rules similar to the rules of subsection 
(a)(2). 
‘‘(B) DUE DATE.—For purposes of sub-
paragraph (A), with respect to a partner’s 
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share of the adjustment, the partnership adjust-
ment tracking report shall be filed, and the im-
puted underpayment shall be paid or state-
ments shall be furnished, not later than the due 
date for the return for the taxable year of the 
audited partnership which includes the date the 
final determination was made with respect to 
such partnership. 
‘‘(C) PARTNERSHIP PAYMENT OF TAX NOT 
PERMITTED
IF
ELECTED
OUT
OF
SUB-
CHAPTER.—In the case of a partnership which 
has elected the application of section 6221(b) 
with respect to the taxable year of the partner-
ship which includes the end of the reviewed year 
of the audited partnership, this paragraph shall 
apply notwithstanding such election, except that 
subparagraph (A) shall be applied without re-
gard to clause (ii)(I) thereof. 
‘‘(D) AUDITED
PARTNERSHIP.—For pur-
poses of this paragraph, the term ‘audited part-
nership’ means, with respect to any partner de-
scribed in subparagraph (A), the partnership in 
the chain of ownership originally electing the 
application of this section.’’. 
(b) CONFORMING AMENDMENTS.— 
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(1) Section 6226(b)(1) is amended by striking 
‘‘Each partner’s’’ and inserting ‘‘Except as provided 
in paragraph (4), each partner’s’’. 
(2) Section 6226(c)(2) is amended by inserting 
‘‘or 
which 
is 
described 
in 
subsection 
(b)(4)(A)(ii)(I),’’ after ‘‘is elected,’’. 
SEC. 205. TREATMENT OF FAILURE OF PARTNERSHIP TO 
PAY IMPUTED UNDERPAYMENT. 
Section 6232 is amended by adding at the end the 
following new subsection: 
‘‘(f) FAILURE TO PAY IMPUTED UNDERPAYMENT.— 
‘‘(1) IN GENERAL.—If any amount of any im-
puted underpayment to which section 6225 applies 
or which is described in section 6226(b)(4)(A)(ii)(I) 
(or any interest or penalties with respect to any such 
amount) has not been paid by the date which is 10 
days after the date on which the Secretary provides 
notice and demand for such payment— 
‘‘(A) section 6621(a)(2)(B) shall be ap-
plied by substituting ‘5 percentage points’ for ‘3 
percentage points’ with respect to such amount, 
and 
‘‘(B) the Secretary may assess upon each 
partner of the partnership (determined as of 
the close of the adjustment year) a tax equal to 
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such partner’s proportionate share of such 
amount (including any such interest or pen-
alties, determined after application of subpara-
graph (A)). 
‘‘(2) PROPORTIONATE SHARE.—For purposes of 
paragraph (1), a partner’s proportionate share is 
such percentage as the Secretary may determine on 
the basis of such partner’s distributive share of 
items under section 702. The Secretary shall make 
determinations under the preceding sentence such 
that the aggregate proportionate shares so deter-
mined total 100 percent. 
‘‘(3) COORDINATION
WITH
PARTNERSHIP
LI-
ABILITY.—The liability of the partnership for any 
amount with respect to which a partner is made lia-
ble under paragraph (1) shall be reduced upon pay-
ment by the partner of such amount. Paragraph 
(1)(B) shall not apply with respect to any amount 
after the date on which such amount is paid by the 
partnership. 
‘‘(4) S CORPORATIONS.—For purposes of this 
subsection, an S corporation and its shareholders 
shall be treated in the same manner as a partner-
ship and its partners. 
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‘‘(5) RULES
RELATED
TO
ASSESSMENT
AND 
COLLECTION.— 
‘‘(A) DEFICIENCY PROCEDURES NOT AP-
PLICABLE.—Subchapter B shall not apply to 
any assessment or collection under this para-
graph. 
‘‘(B) LIMITATION
ON
ASSESSMENT.—Ex-
cept as otherwise provided in this chapter, no 
assessment may be made with respect to any 
partner with respect to an amount under para-
graph (1) (and no levy or proceeding in any 
court for the collection of such amount may 
begin) after the date which is 2 years after the 
date on which the Secretary provides notice and 
demand to the partnership with respect to such 
amount.’’. 
SEC. 206. OTHER TECHNICAL CORRECTIONS RELATED TO 
PARTNERSHIP AUDIT RULES. 
(a) LIMITATION ON AMENDMENT OF STATEMENTS 
FURNISHED TO PARTNERS NOT APPLICABLE TO PART-
NERSHIPS
ELECTING
OUT
OF
PARTNERSHIP
AUDIT 
RULES.—Section 6031(b) is amended by striking the last 
sentence and inserting the following: ‘‘Information re-
quired to be furnished by the partnership under this sub-
section may not be amended after the due date of the re-
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turn under subsection (a) to which such information re-
lates, except— 
‘‘(1) in the case of a partnership which has 
elected the application of section 6221(b) for the 
taxable year, 
‘‘(2) as provided in the procedures under sec-
tion 6225(c), 
‘‘(3) with respect to statements under section 
6226, or 
‘‘(4) as otherwise provided by the Secretary.’’. 
(b) ADMINISTRATIVE ADJUSTMENT REQUEST AND 
PARTNERSHIP ADJUSTMENT TRACKING REPORT NOT 
TREATED
AS AMENDED RETURN
FOR PURPOSES
OF 
MODIFICATION OF IMPUTED UNDERPAYMENTS.—Section 
6225(c)(2), as amended by the preceding provisions of this 
Act, is amended by adding at the end the following new 
subparagraph: 
‘‘(F) ADJUSTMENTS
NOT
TREATED
AS 
AMENDED RETURN.—An administrative adjust-
ment request under section 6227 and a partner-
ship adjustment tracking report under section 
6226(b)(4)(A) shall not be treated as a return 
for purposes of this paragraph.’’. 
(c) CLARIFICATION
OF
FINAL
DETERMINATION 
WITH RESPECT TO PARTNERSHIP ADJUSTMENT.— 
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(1) 
IN
GENERAL.—Section 
6226(a)(2) 
is 
amended by striking ‘‘in the notice of final partner-
ship adjustment’’ and inserting ‘‘by reference to the 
final determination with respect to such adjust-
ment’’. 
(2) FINAL DETERMINATION.—Section 6225(d) 
is amended by adding at the end the following new 
paragraph: 
‘‘(3) FINAL DETERMINATION.—The final deter-
mination is made with respect to an adjustment on 
the date on which— 
‘‘(A) in the case of an adjustment pursu-
ant to the decision of a court in a proceeding 
brought under section 6234, such decision be-
comes final, 
‘‘(B) in the case of an administrative ad-
justment request under section 6227, such ad-
ministrative adjustment request is filed, or 
‘‘(C) in any other case, 90 days after the 
date on which the notice of the final partner-
ship adjustment is mailed under section 6231.’’. 
(3) CONFORMING AMENDMENTS.— 
(A) Section 6225(d)(2) is amended by 
striking ‘‘in which—’’ and all that follows and 
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inserting ‘‘in which the final determination is 
made with respect to the adjustment.’’. 
(B) Section 6227(b) is amended by strik-
ing ‘‘is made’’ both places it appears and in-
serting ‘‘is filed’’. 
(d) CLARIFICATION OF ASSESSMENT AUTHORITY.— 
Section 6226(a) is amended by inserting ‘‘(and no assess-
ment of tax, levy, or proceeding in any court for the collec-
tion of such underpayment shall be made against such 
partnership)’’ after ‘‘section 6225 shall not apply with re-
spect to such underpayment’’. 
(e) TREATMENT
OF PARTNERSHIP ADJUSTMENTS 
THAT RESULT IN DECREASE IN TAX IN CASE OF ELEC-
TION TO PUSH OUT ADJUSTMENTS.—Section 6226(b) is 
amended— 
(1) by striking ‘‘increased’’ in paragraph (1) 
and inserting ‘‘adjusted’’, 
(2) by striking ‘‘adjustment amounts’’ each 
place it appears in paragraphs (1) and (2) and in-
serting ‘‘correction amounts’’, 
(3) by striking ‘‘increase’’ each place it appears 
in subparagraphs (A) and (B) of paragraph (2) and 
inserting ‘‘increase or decrease’’, 
(4) by striking ‘‘plus’’ at the end of paragraph 
(2)(A) and inserting ‘‘and’’, and 
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(5) by striking ‘‘ADJUSTMENT
AMOUNTS’’ in 
the heading of paragraph (2) and inserting ‘‘COR-
RECTION AMOUNTS’’. 
(f) TIME LIMITATION FOR NOTICE OF PROPOSED 
ADJUSTMENT.— 
(1) IN GENERAL.—Section 6231 is amended by 
redesignating subsections (b) and (c) as subsections 
(c) and (d), respectively, and by inserting after sub-
section (a) the following new subsection: 
‘‘(b) TIMING OF NOTICES.— 
‘‘(1) NOTICE OF PROPOSED PARTNERSHIP AD-
JUSTMENT.—Any notice of a proposed partnership 
adjustment shall not be mailed later than the date 
determined under section 6235 (determined without 
regard to paragraphs (2) and (3) of subsection (a) 
thereof). 
‘‘(2) NOTICE OF FINAL PARTNERSHIP ADJUST-
MENT.— 
‘‘(A) IN GENERAL.—Except to the extent 
that the partnership elects to waive the applica-
tion of this subparagraph, any notice of a final 
partnership adjustment shall not be mailed ear-
lier than 270 days after the date on which the 
notice of the proposed partnership adjustment 
is mailed. 
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‘‘(B) STATUTE
OF
LIMITATIONS
ON
AD-
JUSTMENT.—For the period of limitations on 
making adjustments, see section 6235.’’. 
(2) 
CONFORMING
AMENDMENT.—Section 
6231(a) is amended by striking ‘‘Any notice of a 
final partnership adjustment’’ and all that follows 
through ‘‘Such notices’’ and inserting ‘‘Any notice of 
a final partnership adjustment’’. 
(g) DEPOSIT TO SUSPEND INTEREST ON IMPUTED 
UNDERPAYMENT.—Section 6233 is amended by adding at 
the end the following new subsection: 
‘‘(c) DEPOSIT TO SUSPEND INTEREST.—For rules 
allowing deposits to suspend running of interest on poten-
tial underpayments, see section 6603.’’. 
(h) TREATMENT OF SPECIAL ENFORCEMENT MAT-
TERS.—Section 6241, as amended by the preceding provi-
sions of this Act, is amended by adding at the end the 
following new paragraph: 
‘‘(10) TREATMENT OF SPECIAL ENFORCEMENT 
MATTERS.— 
‘‘(A) IN GENERAL.—In the case of part-
nership-related items which involve special en-
forcement matters, the Secretary may prescribe 
regulations pursuant to which— 
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‘‘(i) this subchapter (or any portion 
thereof) does not apply to such items, and 
‘‘(ii) such items are subject to such 
special rules (including rules related to as-
sessment and collection) as the Secretary 
determines to be necessary for the effective 
and efficient enforcement of this title. 
‘‘(B) SPECIAL ENFORCEMENT MATTERS.— 
For purposes of subparagraph (A), the term 
‘special enforcement matters’ means— 
‘‘(i) failure to comply with the re-
quirements of section 6226(b)(4)(A)(ii), 
‘‘(ii) assessments under section 6851 
(relating to termination assessments of in-
come tax) or section 6861 (relating to 
jeopardy assessments of income, estate, 
gift, and certain excise taxes), 
‘‘(iii) criminal investigations, 
‘‘(iv) indirect methods of proof of in-
come, 
‘‘(v) foreign partnerships, and 
‘‘(vi) other matters that the Secretary 
determines by regulation present special 
enforcement considerations.’’. 
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(i) PENALTIES RELATED TO ADMINISTRATIVE AD-
JUSTMENT REQUESTS AND PARTNERSHIP ADJUSTMENT 
TRACKING REPORTS.— 
(1) FAILURE TO PAY.—Section 6651 is amend-
ed by redesignating subsection (i) as subsection (j) 
and by inserting after subsection (h) the following 
new subsection: 
‘‘(i) APPLICATION TO IMPUTED UNDERPAYMENT.— 
For purposes of this section, any failure to comply with 
section 6226(b)(4)(A)(ii) shall be treated as a failure to 
pay the amount described in subclause (I) thereof and 
such amount shall be treated for purposes of this section 
as an amount shown as tax on a return specified in sub-
section (a)(1).’’. 
(2) FAILURE TO FILE PARTNERSHIP ADJUST-
MENT
TRACKING
REPORT.—Section 6698(a) is 
amended— 
(A) in the matter preceding paragraph (1) 
by inserting ‘‘, or a partnership adjustment 
tracking report under section 6226(b)(4)(A),’’ 
after ‘‘under section 6031’’, 
(B) in paragraph (1) by inserting ‘‘, or 
such report,’’ after ‘‘such return’’, and 
(C) in paragraph (2)— 
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(i) by inserting ‘‘or a report’’ after ‘‘a 
return’’, and 
(ii) by inserting ‘‘or 6226(b)(4)(A), 
respectively’’ before the comma at the end. 
(3) TAX
RETURN
PREPARER
RELATED
PEN-
ALTIES.—Section 6696(e)(1) is amended by insert-
ing ‘‘, any administrative adjustment request under 
section 6227, and any partnership adjustment track-
ing report under section 6226(b)(4)(A)’’ before the 
period at the end. 
(4) FRIVOLOUS
TAX
SUBMISSIONS.—Section 
6702 is amended by adding at the end the following 
new subsection: 
‘‘(f) PARTNERSHIP ADJUSTMENTS.—An administra-
tive adjustment request under section 6227 and a partner-
ship 
adjustment 
tracking 
report 
under 
section 
6226(b)(4)(A) shall be treated as a return for purposes 
of this section.’’. 
(j) ADJUSTED SCHEDULE K–1 TREATED AS PAYEE 
STATEMENT.—Section 6724(d)(2) is amended by striking 
‘‘or’’ at the end of subparagraph (HH), by striking the 
period at the end of subparagraph (II) and inserting ‘‘, 
or’’, and by inserting after subparagraph (II) the following 
new subparagraph: 
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‘‘(JJ) section 6226(a)(2) (relating to state-
ments relating to alternative to payment of im-
puted underpayment by partnership) or under 
any other provision of this title which provides 
for the application of rules similar to such sec-
tion.’’. 
(k) CLERICAL CORRECTIONS.— 
(1) Section 6232(d)(1)(A) is amended by strik-
ing ‘‘a item’’ and inserting ‘‘an item’’. 
(2) Section 6232(e) is amended by striking 
‘‘thereof’’. 
(3) Section 6235(a) is amended by striking 
‘‘subpart’’ and inserting ‘‘subchapter’’. 
(4) Section 6235(a)(3) is amended by striking 
‘‘section 
6225(c)(7)’’ 
and 
inserting 
‘‘section 
6225(c)(7))’’. 
(5) Section 6241(5) is amended by striking 
‘‘sections 6234’’ and inserting ‘‘section 6234’’. 
(6) The heading of the first part of subchapter 
C of chapter 63 is amended to read as follows: 
‘‘PART I—IN GENERAL’’. 
(7) The heading of the second part of sub-
chapter C of chapter 63 is amended to read as fol-
lows: 
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‘‘PART II—PARTNERSHIP ADJUSTMENTS’’. 
(8) The heading of the third part of subchapter 
C of chapter 63 is amended to read as follows: 
‘‘PART III—PROCEDURE’’. 
(9) The heading of the fourth part of sub-
chapter C of chapter 63 is amended to read as fol-
lows: 
‘‘PART IV—DEFINITIONS AND SPECIAL RULES’’. 
SEC. 207. EFFECTIVE DATE. 
The amendments made by this title shall take effect 
as if included in section 1101 of the Bipartisan Budget 
Act of 2015. 
TITLE III—OTHER CORRECTIONS 
SEC. 301. AMENDMENTS RELATING TO THE BIPARTISAN 
BUDGET ACT OF 2015. 
(a) AMENDMENTS RELATING TO SECTION 1101.— 
(1) Section 6011(e) is amended by adding at 
the end the following new paragraph: 
‘‘(5) SPECIAL RULES FOR PARTNERSHIPS.— 
‘‘(A) PARTNERSHIPS
PERMITTED
TO
BE 
REQUIRED TO FILE ON MAGNETIC MEDIA.—In 
the case of a partnership, paragraph (2)(A) 
shall be applied by substituting for ‘250’ the 
following amount: 
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‘‘(i) In the case of returns and state-
ments relating to calendar year 2018, 
‘200’. 
‘‘(ii) In the case of returns and state-
ments relating to calendar year 2019, 
‘150’. 
‘‘(iii) In the case of returns and state-
ments relating to calendar year 2020, 
‘100’. 
‘‘(iv) In the case of returns and state-
ments relating to calendar year 2021, ‘50’. 
‘‘(v) In the case of returns and state-
ments relating to calendar years after 
2021, ‘20’. 
‘‘(B) PARTNERSHIPS REQUIRED TO FILE 
ON
MAGNETIC
MEDIA.—Notwithstanding sub-
paragraph (A) and paragraph (2)(A), the Sec-
retary shall require partnerships having more 
than 100 partners to file returns on magnetic 
media.’’. 
(2) Section 6011(e)(2) is amended by striking 
the last sentence. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall take effect as if included in section 1101 
of the Bipartisan Budget Act of 2015. 
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SEC. 302. AMENDMENTS RELATING TO THE ENERGY POL-
ICY ACT OF 2005. 
(a) AMENDMENTS RELATING TO SECTION 1253.— 
(1) Subclause (II) of section 168(e)(3)(B)(vi) is 
amended by striking ‘‘is a qualifying small power 
production facility’’ and all that follows and insert-
ing ‘‘has a power production capacity of not greater 
than 80 megawatts, or’’. 
(2) The last sentence of section 168(e)(3)(B) is 
amended by striking ‘‘clause (vi)(I)’’ and all that fol-
lows and inserting ‘‘subclause (I) or (II) of clause 
(vi) by reason of being public utility property.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to property placed in service after 
the date of the enactment of this Act. 
TITLE IV—CLERICAL 
CORRECTIONS AND DEADWOOD 
SEC. 401. CLERICAL CORRECTIONS AND DEADWOOD-RE-
LATED PROVISIONS. 
(a) CLERICAL CORRECTIONS.— 
(1) The table of subchapters for chapter 1 is 
amended by moving the item relating to subchapter 
R before the item relating to subchapter S. 
(2)(A) 
Sections 
22(c)(3)(A)(i)(III), 
104(b)(2)(D), 140(a)(3), and 149(b)(3)(A)(i) are 
each amended by striking ‘‘Veterans’ Administra-
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tion’’ and inserting ‘‘Department of Veterans Af-
fairs’’. 
(B) The heading of section 4980H(c)(2)(F) is 
amended by striking ‘‘VETERANS ADMINISTRATION’’ 
and inserting ‘‘DEPARTMENT
OF
VETERANS
AF-
FAIRS’’. 
(C) Section 6050H(h)(3)(B)(i) is amended by 
striking ‘‘Veterans Administration’’ and inserting 
‘‘Department of Veterans Affairs’’. 
(3) Section 24(d) is amended by redesignating 
paragraph (5) as paragraph (3). 
(4) Section 25C(b)(2) is amended by striking 
‘‘subsection (c)(2)(B)’’ and inserting ‘‘subsection 
(c)(3)(B)’’. 
(5) Section 25C(d)(3) is amended— 
(A) by striking the period at the end of 
subparagraph (B) and inserting a comma, and 
(B) by striking the period at the end of 
subparagraph (D) and inserting ‘‘, and’’. 
(6) Section 25C(g)(2) is amended by striking 
‘‘2016..’’ and inserting ‘‘2016.’’. 
(7) The table of sections for subpart D of part 
IV of subchapter A of chapter 1 is amended— 
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(A) by striking the item relating to section 
41 which relates to the employee stock owner-
ship credit, and 
(B) by moving the item relating to section 
45K after the item relating to section 45J. 
(8) Section 38(b)(34) is amended by adding a 
comma at the end. 
(9) The heading of section 40(g)(2) is amended 
by striking ‘‘AGGREGRATION’’ and inserting ‘‘AG-
GREGATION’’. 
(10) The heading of section 42(e)(2)(B) is 
amended by striking ‘‘ETC,’’ and inserting ‘‘ETC.,’’. 
(11)(A) Section 42(d)(4)(C)(i) is amended by 
striking ‘‘as defined in paragraph (5)(C)’’ and in-
serting ‘‘as defined in paragraph (5)(B)(ii)’’. 
(B) Section 42(f)(5)(B)(ii)(I) is amended by 
striking ‘‘(d)(6)(C)’’ and inserting ‘‘(d)(6)(B)’’. 
(C) Section 42(k)(2)(B) is amended— 
(i) by striking ‘‘(d)(6)(B)’’ and inserting 
‘‘(d)(6)(C)’’, and 
(ii) by striking ‘‘building..’’ in clause (ii) 
and inserting ‘‘building.’’. 
(D) Section 42(m)(1)(B)(ii)(III) is amended by 
striking ‘‘as defined in subsection (d)(5)(C)’’ and in-
serting ‘‘as defined in subsection (d)(5)(B)(ii)’’. 
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(12) Section 42(h)(5)(C)(ii) is amended by 
striking ‘‘; and’’ and inserting ‘‘, and’’. 
(13) Section 42(i)(3)(D)(ii)(I) is amended by 
striking the period at the end. 
(14) Section 45(c)(6) is amended by striking 
‘‘section 2(27)’’ and inserting ‘‘section 1004(27)’’. 
(15) Section 45(c)(7)(A)(i)(II) is amended by 
striking ‘‘for purpose’’ and inserting ‘‘for the pur-
pose’’. 
(16) Section 45(c)(7)(A)(i)(III) is amended by 
striking the period at the end and inserting ‘‘, or’’. 
(17) Section 45C(b)(2)(A)(ii)(II) is amended by 
striking ‘‘; and’’ and inserting ‘‘, and’’. 
(18) Section 45D(f)(1)(F) is amended by add-
ing ‘‘, and’’ at the end. 
(19) Section 45H(d) is amended by striking 
‘‘purposes this’’ and inserting ‘‘purposes of this’’. 
(20) Section 48(a)(1) is amended by striking 
‘‘(3)(B), and (4)(B)’’ and inserting ‘‘and (3)(B)’’. 
(21) Section 48(a)(6)(B) is amended by strik-
ing ‘‘property energy property’’ and inserting ‘‘en-
ergy property’’. 
(22) Section 48(c)(2)(B) is amended by striking 
‘‘equal $200’’ and inserting ‘‘equal to $200’’. 
(23) Section 48(d)(3) is amended— 
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(A) by striking ‘‘shall’’ in the matter that 
precedes subparagraph (A), and 
(B) by inserting ‘‘shall’’ before ‘‘not’’ in 
subparagraph (A). 
(24) Section 49(a)(1)(D)(iii) is amended by 
striking ‘‘share-holder’’ in the last sentence and in-
serting ‘‘shareholder’’. 
(25) Section 50(b)(2)(A) is amended by strik-
ing the period at the end and inserting a semicolon. 
(26) Section 51(c)(4) is amended by adding a 
period at the end. 
(27) Section 51(d)(3)(A)(ii)(II) is amended by 
adding a comma at the end. 
(28) Section 51(d)(8) is amended by striking 
‘‘FOOD STAMP RECIPIENT’’ in the heading thereof 
and inserting ‘‘SUPPLEMENTAL NUTRITION ASSIST-
ANCE PROGRAM BENEFITS RECIPIENT’’. 
(29) Section 51(i)(1)(A) is amended by striking 
‘‘entity,’’ and inserting ‘‘entity’’. 
(30) The item relating to section 54C in the 
table of sections for subpart I of part IV of sub-
chapter A of chapter 1 is amended to read as fol-
lows: 
‘‘Sec. 54C. New clean renewable energy bonds.’’. 
(31) Section 58(a)(2)(A) is amended by striking 
‘‘461(j)’’ and inserting ‘‘461(k)’’. 
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(32) Section 62(a)(20) is amended by inserting 
a comma after ‘‘United States Code’’. 
(33) Section 62(e)(1) is amended by striking 
‘‘(2 U.S.C. 1202)’’ and inserting ‘‘(42 U.S.C. 
2000e–16b)’’. 
(34) Section 68(b)(2) is amended by striking 
‘‘shall be shall be’’ and inserting ‘‘shall be’’. 
(35) The heading of section 82 is amended by 
striking ‘‘FOR EXPENSES OF MOVING’’ and insert-
ing ‘‘OF MOVING EXPENSES’’. 
(36) The heading of section 84 is amended by 
striking ‘‘POLITICAL ORGANIZATION’’ and insert-
ing ‘‘POLITICAL ORGANIZATIONS’’. 
(37) Section 105(h)(7)(B) is amended by strik-
ing ‘‘subparagraph (A)’’ and inserting ‘‘subpara-
graph (A))’’. 
(38) Section 125(e)(2) is amended by striking 
‘‘subparagraphs’’ and inserting ‘‘subparagraph’’. 
(39) Section 132(c)(4) is amended by striking 
‘‘peforming’’ and inserting ‘‘performing’’. 
(40) Section 134(b)(6) is amended by striking 
‘‘an combat’’ and inserting ‘‘a combat’’. 
(41) Section 139(c)(2) is amended by striking 
‘‘federally’’ and inserting ‘‘a federally’’. 
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(52) Section 170(b)(1)(A)(ix) is amended by in-
serting ‘‘National’’ before ‘‘Agricultural’’. 
(53) Section 172(d)(5) is amended by striking 
‘‘section 243’’ and inserting ‘‘sections 243’’. 
(54) Section 179D(d)(1)(B) is amended by 
striking ‘‘which’’ and inserting ‘‘such that’’. 
(55) Section 199 is amended by striking so 
much of subsection (a) as precedes ‘‘There shall be 
allowed’’ and inserting ‘‘(a) ALLOWANCE OF DEDUC-
TION.—’’. 
(56) Section 219(f)(1) is amended by striking 
‘‘term compensation includes’’ in the last sentence 
and inserting ‘‘term ‘compensation’ includes’’. 
(57) Section 219(g)(8) is amended by striking 
‘‘shall each be’’ and inserting ‘‘shall be’’. 
(58) Section 223(d)(2)(A) is amended by strik-
ing 
‘‘section 
213(d)’’ 
and 
inserting 
‘‘section 
213(d))’’. 
(59) The item relating to section 280H in the 
table of sections for part IX of subchapter B of 
chapter 1 is amended to read as follows: 
‘‘Sec. 280H. Limitation on certain amounts paid to employee-owners by per-
sonal service corporations electing alternative taxable years.’’. 
(60) Subparagraphs (F) and (G) of section 
263(a)(1) are each amended by striking the semi-
colon at the end and inserting a comma. 
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(61) Section 263(a)(1) is amended by redesig-
nating subparagraphs (I) through (L) as subpara-
graphs (H) through (K), respectively. 
(62) Section 280C(a) is amended by striking 
‘‘and 1396(a),’’ and inserting ‘‘1396(a),’’. 
(63) Section 280F(d)(4)(A)(iv) is amended by 
striking ‘‘ ‘and’ ’’ at the end and inserting ‘‘and’’. 
(64) The heading of section 331 is amended by 
striking 
‘‘SHAREHOLDERS’’ 
and 
inserting 
‘‘SHAREHOLDER’’. 
(65) Section 338(h)(3)(A)(iii) is amended by 
striking ‘‘paragaraph’’ and inserting ‘‘paragraph’’. 
(66) 
The 
second 
sentence 
of 
section 
355(h)(2)(B) is amended by striking ‘‘of assets’’. 
(67) The heading of subpart C of part III of 
subchapter C of chapter 1 is amended by striking 
‘‘Corporation’’ and inserting ‘‘Corporations’’. 
(68) Section 362(a) is amended by striking the 
comma after ‘‘acquired’’. 
(69) Section 368(a)(2)(F)(vii) is amended by 
striking ‘‘(15 U.S.C. 80a-2(36))’’ and inserting ‘‘(15 
U.S.C. 80a–2(a)(36))’’. 
(70) Section 401(a)(2) is amended by striking 
‘‘determination).;’’ and inserting ‘‘determination));’’. 
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(71) Section 401(a)(15) is amended by striking 
‘‘a trust’’ and inserting ‘‘A trust’’. 
(72) Section 401(a)(32)(A) is amended by 
striking ‘‘section section’’ both places it appears and 
inserting ‘‘section’’. 
(73) Section 401(c)(2)(A)(iii) is amended by 
striking ‘‘sections 3121(d)(3)(A), (C), or (D), with-
out regard to paragraph (2) of section 1402(c)’’ and 
inserting ‘‘subparagraph (A), (C), or (D) of section 
3121(d)(3), without regard to section 1402(c)(2)’’. 
(74) Section 402(i) is amended by striking 
‘‘subparagraph (A) of subsection (d)(4)’’ and insert-
ing ‘‘subsection (e)(4)(D)(i)’’. 
(75) Section 404A(c)(4)(B) is amended by 
striking ‘‘and’’ at the end. 
(76) Section 408(a)(1) is amended by inserting 
‘‘or’’ after ‘‘subsection (d)(3)’’. 
(77) Section 408(m)(3)(B) is amended by strik-
ing ‘‘section 7’’ and inserting ‘‘section 5’’. 
(78) Section 408A(d)(3)(B) is amended by add-
ing a period at the end. 
(79) Section 408A(e)(2)(B) is amended by 
striking ‘‘the subparagraph (A)’’ and inserting ‘‘sub-
paragraph (A)’’. 
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(80) Section 409(n)(1)(A)(i) is amended by 
striking ‘‘securities,,,’’ and inserting ‘‘securities,’’. 
(81) Section 409A(b)(3)(B)(i) is amended by 
striking the semicolon at the end and inserting a 
comma. 
(82) The item relating to section 413 in the 
table of sections for subpart B of part I of sub-
chapter D of chapter 1 is amended to read as fol-
lows: 
‘‘Sec. 413. Collectively bargained plans, etc.’’. 
(83) Section 411(a)(4)(A) is amended by strik-
ing the comma at the end and inserting a semicolon. 
(84) Section 411(b)(5)(B)(iv) is amended by 
striking ‘‘similar amount’’ and inserting ‘‘similar ac-
count’’. 
(85) Section 412(c)(1)(A) is amended by add-
ing a period at the end. 
(86) Section 412(c)(4)(B) is amended by insert-
ing ‘‘section’’ before ‘‘433(d)’’. 
(87) Section 412(c)(7)(B)(iii) is amended by 
striking the comma after ‘‘subchapter D’’. 
(88) Section 414(l)(2)(G) is amended by strik-
ing ‘‘BANKS’’ in the heading thereof and inserting 
‘‘DEPOSITORY INSTITUTIONS’’. 
(89) Section 414(u)(6) is amended by striking 
‘‘section 403(b)’’ and inserting ‘‘section 403(b))’’. 
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(90) Section 414(x)(1) is amended by striking 
‘‘are’’ and inserting ‘‘is’’. 
(91) Section 414(y)(1)(C)(i) is amended by 
striking ‘‘of such Code’’. 
(92) Section 414(y)(2) is amended by striking 
‘‘subparagraph’’ and inserting ‘‘subparagraphs’’. 
(93) Section 418E is amended by striking ‘‘sub-
section 432(b)(2)’’ each place it appears and insert-
ing ‘‘section 432(b)(2)’’. 
(94) Section 418E(d)(1), as amended by the 
preceding paragraph, is amended— 
(A) by striking ‘‘section 432(b)(2),,’’ and 
inserting ‘‘section 432(b)(2),’’, and 
(B) by striking ‘‘section 432(b)(2),)’’ and 
inserting ‘‘section 432(b)(2))’’. 
(95) Section 418E(e)(1)(A) is amended to read 
as follows: 
‘‘(A) notify the Secretary and the parties 
described in section 101(f)(1) of the Employee 
Retirement Income Security Act of 1974 of that 
determination, and’’. 
(96) Section 419A(c)(6)(B) is amended by 
striking ‘‘(42 U.S.C. 300gg-91(d)(3))’’ and inserting 
‘‘(42 U.S.C. 300gg–91(d)(3)))’’. 
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(97) Section 420(c)(1)(A) is amended by strik-
ing ‘‘subsection (e)(1)(D)’’ and inserting ‘‘subsection 
(e)(1)(E)’’. 
(98) Section 424(g) is amended by striking 
‘‘section 
422(a)(2)’’ 
and 
inserting 
‘‘sections 
422(a)(2)’’. 
(99) Section 430(c)(7)(E)(v)(II) is amended by 
inserting ‘‘the’’ after ‘‘title I of’’. 
(100) Section 430(h)(2)(F) is amended by 
striking ‘‘section 417(e)(3)(D)(i)’’ and inserting 
‘‘section 417(e)(3)(D)’’. 
(101) Section 431(d)(2)(B)(i) is amended by 
striking ‘‘this Act’’ and inserting ‘‘the Pension Pro-
tection Act of 2006’’. 
(102) Section 432(b)(3)(A)(i) is amended by 
striking ‘‘paragraph (5),,’’ and inserting ‘‘paragraph 
(5),’’. 
(103) Section 432(b)(3)(B) is amended by re-
designating the clause (iv) relating to projections of 
critical and declining status as clause (v). 
(104) Section 432(b)(3)(D)(iv) is amended by 
inserting a comma after ‘‘Labor’’. 
(105) Section 432(e)(8)(C)(iii) is amended by 
striking ‘‘the Secretary shall’’ and inserting ‘‘The 
Secretary shall’’. 
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(106) Section 432(g)(1) is amended by striking 
‘‘subsection (e)(9))’’ and inserting ‘‘subsection 
(e)(9)’’. 
(107) Section 433(c)(5)(C)(ii)(II) is amended 
by inserting ‘‘of such Act’’ after ‘‘title IV’’. 
(108) The item relating to section 436 in the 
table of sections for subpart B of part III of sub-
chapter D of chapter 1 is amended to read as fol-
lows: 
‘‘Sec. 436. Funding-based limits on benefits and benefit accruals under single- 
employer plans.’’. 
(109) Section 447(h)(2)(A) is amended by 
striking ‘‘employes’’ and inserting ‘‘employees’’. 
(110) Section 447(i)(5)(B) is amended by re-
designating clause (iv) as clause (iii). 
(111) The heading of section 453B is amended 
by striking ‘‘LOSS
DISPOSITION’’ and inserting 
‘‘LOSS ON DISPOSITION’’. 
(112) Section 457(f)(4)(C)(i) is amended— 
(A) by striking ‘‘section 9101’’ and insert-
ing ‘‘section 8101’’, and 
(B) by striking ‘‘7801),’’ and inserting 
‘‘7801)),’’. 
(113) Section 457A(d)(4) is amended— 
(A) by striking ‘‘case a foreign’’ and in-
serting ‘‘case of a foreign’’, and 
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(B) by striking ‘‘had been’’ and inserting 
‘‘been’’. 
(114) Section 458(b)(9) is amended by striking 
‘‘REPURCHASED’’ in the heading thereof and insert-
ing ‘‘REPURCHASE’’. 
(115) Section 458(c)(1) is amended by striking 
‘‘regulations prescribed’’ and inserting ‘‘regulations 
prescribe’’. 
(116) Section 460(b)(2)(A) is amended by in-
serting a comma after ‘‘first’’. 
(117)(A) Section 461 is amended by redesig-
nating the second subsection (j) (relating to farming 
syndicate defined) as subsection (k). 
(B) Section 461(i)(4) is amended by striking 
‘‘subsection (j)’’ and inserting ‘‘subsection (k)’’. 
(118) The heading of section 464 is amended 
by inserting ‘‘EXPENSES’’ after ‘‘FARMING’’. 
(119) Section 464(d)(2)(B)(iii) is amended by 
striking ‘‘subsection (c)(2)(E)’’ and inserting ‘‘sec-
tion 461(k)(2)(E)’’. 
(120) Section 470(d)(2)(B) is amended by 
striking ‘‘clause (ii)’’ and inserting ‘‘subparagraph 
(A)(ii)’’. 
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2014’’ and inserting ‘‘Stephen Beck, Jr., ABLE Act 
of 2014’’. 
(130) Section 529A(e)(4) is amended by strik-
ing ‘‘subparagraph section’’ and inserting ‘‘section’’. 
(131) Section 530(d)(9)(B) is amended by 
striking ‘‘by the’’ and inserting ‘‘by’’. 
(132) Section 542(c)(5) is amended by striking 
the comma at the end and inserting a semicolon. 
(133) Section 542(c)(7) is amended by striking 
‘‘A small’’ and inserting ‘‘a small’’. 
(134) Section 543(a)(2)(B)(ii) is amended by 
striking ‘‘section 563(d)’’ and inserting ‘‘section 
563(c)’’. 
(135) Section 543(d)(5)(A)(ii) is amended by 
striking ‘‘section 563(d)’’ and inserting ‘‘section 
563(c)’’. 
(136) Section 613A(c)(7)(B) is amended by 
striking ‘‘taxpayers’’ and inserting ‘‘taxpayer’s’’. 
(137) Section 642(c)(1) is amended by striking 
‘‘other then’’ and inserting ‘‘other than’’. 
(138) The item relating to section 661 in the 
table of sections for subpart C of part I of sub-
chapter J of chapter 1 is amended to read as fol-
lows: 
‘‘Sec. 661. Deduction for estates and trusts accumulating income or distrib-
uting corpus.’’. 
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(139) Section 706(b)(5) is amended by striking 
‘‘section 584(h)’’ and inserting ‘‘section 584(i)’’. 
(140) Section 751(c) is amended by striking 
‘‘and, sections’’ both places it appears and inserting 
‘‘and sections’’. 
(141) Section 807(e)(7)(A)(i) is amended by 
striking ‘‘subparagraph (C)’’ and inserting ‘‘sub-
paragraph (B)’’. 
(142) Section 810(c)(2)(B) is amended by 
striking ‘‘corporations),’’ and inserting ‘‘corpora-
tions)’’. 
(143) Section 810(d)(1) is amended by striking 
‘‘paragraphs (2) and (3) of section 804) or’’ and in-
serting ‘‘paragraph (2) of section 804) for’’. 
(144) Section 810(f) is amended by striking 
‘‘section 
805(b)(5)’’ 
and 
inserting 
‘‘section 
805(b)(4)’’. 
(145) Section 831(c) is amended by striking 
‘‘section 816(a)).’’ and inserting ‘‘section 816(a).’’. 
(146) Section 832(b)(7)(E)(ii)(II) is amended 
by striking the comma at the end and inserting a pe-
riod. 
(147) Section 852(a)(1)(B) is amended by 
striking ‘‘265,’’ and inserting ‘‘265 and’’. 
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(148) Section 852(b)(2)(D) is amended by 
striking ‘‘the deduction’’ and inserting ‘‘The deduc-
tion’’. 
(149) Subparagraphs (A) and (B) of section 
856(c)(7) are each amended by striking ‘‘paragraph 
(4)(B)(iii)’’ and inserting ‘‘paragraph (4)(B)(iv)’’. 
(150) Paragraphs (1), (3), (4), and (5) of sec-
tion 856(m) are each amended by striking ‘‘sub-
section (c)(4)(B)(iii)’’ and inserting ‘‘subsection 
(c)(4)(B)(iv)’’. 
(151) Section 857(b)(6)(J) is amended by strik-
ing ‘‘section 856(c)(8)’’ and inserting ‘‘section 
856(c)(10)’’. 
(152) Section 860(f)(2)(A)(ii) is amended by 
striking ‘‘decreased’’ and inserting ‘‘decrease’’. 
(153) Section 860(i) is amended by striking 
‘‘willfull’’ and inserting ‘‘willful’’. 
(154) Section 860G(a)(3)(A)(iii)(III) is amend-
ed by striking the period at the end and inserting 
a comma. 
(155) Section 864(d)(8) is amended by striking 
‘‘section 
956(b)(3)’’ 
and 
inserting 
‘‘section 
956(c)(3)’’. 
(156) Section 877(d)(4)(B)(i) is amended by 
striking ‘‘in 957’’ and inserting ‘‘in section 957’’. 
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(174) Section 1033(h)(2) is amended by insert-
ing ‘‘is’’ before ‘‘located’’. 
(175) Section 1035(a)(1) is amended by strik-
ing ‘‘; or’’ and inserting a semicolon. 
(176) Section 1059(d)(3) is amended by strik-
ing ‘‘; except that’’ and all that follows and inserting 
‘‘and there shall not be taken into account any day 
which is more than 2 years after the date on which 
such share becomes ex-dividend.’’. 
(177) Section 1092(a)(2)(B) is amended by 
striking ‘‘with respect other’’ in the last sentence 
and inserting ‘‘with respect to other’’. 
(178) Section 1092(c)(4)(E) is amended by 
striking ‘‘(other than subparagraph (B) thereof)’’. 
(179) The item relating to section 1222 in the 
table of sections for part III of subchapter P of 
chapter 1 is amended to read as follows: 
‘‘Sec. 1222. Other terms relating to capital gains and losses.’’. 
(180) The item relating to section 1252 in the 
table of sections for part IV of subchapter P of 
chapter 1 is amended to read as follows: 
‘‘Sec. 1252. Gain from disposition of farm land.’’. 
(181) Section 1250(d)(3) is amended by strik-
ing ‘‘paragraph (9)’’ and inserting ‘‘paragraph (6)’’. 
(182) Section 1255(b)(2) is amended by strik-
ing ‘‘170(e),’’ and inserting ‘‘170(e)’’. 
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(183)(A) Subparagraphs (B) and (C) of section 
1256(e)(3) are each amended by striking ‘‘section 
464(e)(2)’’ and inserting ‘‘section 461(k)(4)’’. 
(B) Section 1258(d)(5)(C) is amended by strik-
ing ‘‘section 464(e)(2)’’ and inserting ‘‘section 
461(k)(4)’’. 
(184) Section 1257(c)(1) is amended— 
(A) by striking ‘‘section 1201(4)’’ and in-
serting ‘‘section 1201(a)(7)’’, and 
(B) by striking ‘‘16 U.S.C. 3801(4)’’ and 
inserting ‘‘16 U.S.C. 3801(7)’’. 
(185) Section 1257(c)(2) is amended— 
(A) by striking ‘‘section 1201(6)’’ and in-
serting ‘‘section 1201(a)(10)’’, and 
(B) by striking ‘‘16 U.S.C. 3801(6)’’ and 
inserting ‘‘16 U.S.C. 3801(10)’’. 
(186) Section 1274(b)(3)(B)(i) is amended by 
striking ‘‘section 6662(d)(2)(C)(iii)’’ and inserting 
‘‘section 6662(d)(2)(C)(ii)’’. 
(187) Section 1276(a)(4) is amended by strik-
ing ‘‘871(a),,’’ and inserting ‘‘871(a),’’. 
(188) Section 1278(b)(1) is amended by strik-
ing ‘‘871(a),,’’ and inserting ‘‘871(a),’’. 
(189) Section 1286(f) is amended by striking 
‘‘and 305(e),’’ and inserting ‘‘and section 305(e),’’. 
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(190) Section 1291(e) is amended by striking 
‘‘subsections (c) and (d) (e),’’ and inserting ‘‘sub-
sections (c), (d), and (e)’’. 
(191) Section 1298(b)(5)(B) is amended by 
striking ‘‘section 951(f)’’ and inserting ‘‘section 
951(c)’’. 
(192) Section 1298(d)(2)(A) is amended by 
striking ‘‘section 1296(a)(2)’’ and inserting ‘‘section 
1297(a)(2)’’. 
(193) Section 1298(e)(2)(B)(ii) is amended by 
striking ‘‘provisons’’ and inserting ‘‘provisions’’. 
(194) Section 1355(f)(3) is amended by strik-
ing ‘‘of which’’ and inserting ‘‘on which’’. 
(195) Section 1358(b)(1) is amended by strik-
ing ‘‘section 1352(a)(2)’’ and inserting ‘‘section 
1352(2)’’. 
(196) Section 1358(c)(2) is amended by strik-
ing ‘‘an person’s’’ and inserting ‘‘a person’s’’. 
(197) Sections 1361(f)(2), 1362(d)(3)(C)(v), 
and 4975(d)(16)(A) are each amended by striking 
‘‘1813(w)(1)),’’ and inserting ‘‘1813(w)(1))),’’. 
(198) Section 1362(f) is amended by striking 
‘‘may be during’’ and inserting ‘‘may be, during’’. 
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(199) Section 1366(e) is amended by striking 
‘‘section 
704(e)(3)’’ 
and 
inserting 
‘‘section 
704(e)(2)’’. 
(200) Section 1368(f)(2) is amended by strik-
ing ‘‘in included’’ and inserting ‘‘is included’’. 
(201) Section 1391(g)(3)(E)(ii) is amended by 
striking ‘‘Interior’’ and inserting ‘‘the Interior’’. 
(202) Section 1394(b)(3)(B)(i)(II) is amended 
by striking ‘‘subsection’’ and inserting ‘‘sub-
sections’’. 
(203) Section 1397C(d)(5)(B) is amended by 
striking ‘‘subparagraphs (A) or (B)’’ and inserting 
‘‘subparagraph (A) or (B)’’. 
(204) Section 1402(a)(1) is amended— 
(A) by striking ‘‘section 1233(2)’’ and in-
serting ‘‘section 1233(a)(2)’’, and 
(B) by striking ‘‘16 U.S.C. 3833(2)’’ and 
inserting ‘‘16 U.S.C. 3833(a)(2)’’. 
(205) Section 1402(b) is amended by striking 
‘‘3211,.’’ and inserting ‘‘3211.’’. 
(206) The heading of section 1446 is amended 
by striking ‘‘WITHHOLDING TAX’’ in the heading 
and inserting ‘‘WITHHOLDING OF TAX’’. 
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(207) Section 2031(c)(1) is amended by strik-
ing all that follows subparagraph (A) and inserting 
the following: 
‘‘(B) $500,000.’’. 
(208) Section 2031(c)(2) is amended by strik-
ing ‘‘paragraph (5)).’’ and inserting ‘‘paragraph 
(5))).’’. 
(209) Section 2055(e)(3)(G) is amended by 
striking ‘‘subparagraph (J)’’ and inserting ‘‘sub-
paragraph (J))’’. 
(210) Section 2106(a)(4) is amended by insert-
ing ‘‘section’’ before ‘‘2058(a)’’. 
(211) Section 2522(c)(1) is amended by strik-
ing ‘‘to of for’’ and inserting ‘‘to or for’’. 
(212) Section 2523(g)(1) is amended by strik-
ing ‘‘noncharitable beneficiary’’ and inserting ‘‘bene-
ficiary who is not a charitable beneficiary’’. 
(213) Section 2523(g)(2) is amended by strik-
ing ‘‘noncharitable’’ and inserting ‘‘charitable’’. 
(214) Section 3101(a) is amended by adding a 
period at the end. 
(215) Section 3111(e)(5)(B) is amended by in-
serting ‘‘the’’ before ‘‘meaning’’. 
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(216) Section 3121(b)(5)(B)(i)(V) is amended 
by striking ‘‘section 105(e)(2)’’ and inserting ‘‘sec-
tion 104(e)(2)’’. 
(217) Section 3121(b)(5)(H)(i) is amended by 
striking ‘‘1997’’ and inserting ‘‘1997,’’. 
(218) Section 3304(a)(4)(G)(ii) is amended by 
striking ‘‘section 6402(f)(4)(B)’’ and inserting ‘‘sec-
tion 6402(f)(4)(C)’’. 
(219) Section 3306(b)(5)(F) is amended by 
striking the semicolon at the end and inserting a 
comma. 
(220) Section 3306(c)(19) is amended by strik-
ing ‘‘Service’’ and inserting ‘‘service’’. 
(221) Section 3306(u) is amended by striking 
‘‘25 U.S.C. 450b(e)’’ and inserting ‘‘25 U.S.C. 
5304(e)’’. 
(222) Section 3306(v) is amended by striking 
‘‘this part’’ and inserting ‘‘this section’’. 
(223) Section 3309(d) is amended by striking 
‘‘25 U.S.C. 450b(e)’’ and inserting ‘‘25 U.S.C. 
5304(e)’’. 
(224)(A) Paragraphs (1), (2), (3), (4)(B), (5), 
(6), (8)(A)(ii), (8)(B), (8)(D), (9), (10)(B), (11), 
(12)(A), (12)(B), (12)(C), (13), (14), and (15) of 
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section 3401(a) are each amended by striking ‘‘; or’’ 
at the end and inserting a comma. 
(B) Paragraphs 
(4)(A), 
(8)(A)(i), 
(8)(C), 
(10)(A), (12)(D), and (22) of section 3401(a) are 
each amended by striking ‘‘; or’’ at the end and in-
serting ‘‘, or’’. 
(C) Section 3401(a)(12)(E) is amended by 
striking ‘‘, or’’ at the end and inserting a comma. 
(D) Paragraphs (16)(A), (16)(B), (17), (18), 
(19), (20), and (21) of section 3401(a) are each 
amended by striking the semicolon at the end and 
inserting a comma. 
(225) Section 3509(d)(1)(C) is amended by 
striking ‘‘sections’’ and inserting ‘‘section’’. 
(226) Section 4051(a)(3) is amended by strik-
ing ‘‘Secretary.’’ and inserting ‘‘Secretary).’’. 
(227) Section 4104(a)(1) is amended by strik-
ing ‘‘section’’ and inserting ‘‘sections’’. 
(228) Section 4221(a) is amended by striking 
‘‘section 4051,’’ and inserting ‘‘section 4051’’. 
(229) The item relating to part III in the table 
of parts for subchapter C of chapter 33 is amended 
by striking ‘‘relating’’ and inserting ‘‘applicable’’. 
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(230) Section 4612(e)(2)(B)(ii)(I) is amended 
by striking ‘‘tranferred’’ and inserting ‘‘trans-
ferred’’. 
(231) Section 4958(f)(1)(D) is amended by 
striking the period at the end and inserting a 
comma. 
(232) Section 4971(c)(3) is amended by strik-
ing ‘‘applicable and’’ and inserting ‘‘applicable, 
and’’. 
(233) Section 4971(f) is amended by striking 
‘‘applicable for’’ and inserting ‘‘applicable, for’’. 
(234) Section 4971(g)(4)(C)(ii) is amended by 
striking ‘‘section 432(i)(9)’’ and inserting ‘‘section 
432(j)(9)’’. 
(235) Section 4975(d)(3) is amended by strik-
ing ‘‘an leveraged’’ and inserting ‘‘a leveraged’’. 
(236) Section 4975(d)(17) is amended by strik-
ing ‘‘Any’’ and inserting ‘‘any’’. 
(237) Section 4975(d)(21) is amended by strik-
ing ‘‘person person’’ and inserting ‘‘person’’. 
(238) Section 4975(f)(8)(C)(iv)(II) is amended 
by inserting ‘‘subsection’’ before ‘‘(d)(17)(A)(ii)’’. 
(239) Section 4975(f)(8)(F)(i)(I) is amended by 
striking ‘‘adviser,’’ and inserting ‘‘adviser’’. 
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(240) Section 4975(f)(8)(F)(i)(V) is amended 
by inserting ‘‘of’’ before ‘‘the manner’’. 
(241) Section 4980B(f)(1) is amended by strik-
ing ‘‘section 2162 of the Public Health Service Act’’ 
and inserting ‘‘section 1928(h)(6) of the Social Se-
curity Act (42 U.S.C. 1396s(h)(6))’’. 
(242) Section 4980B(f)(5)(C)(iii) is amended 
by striking ‘‘section 2701(c)(2)’’ and inserting ‘‘sec-
tion 2704(c)(2)’’. 
(243) Section 4980I(b)(3)(C)(iv) is amended by 
striking the comma at the end and inserting a pe-
riod. 
(244) Section 4980I(b)(3)(C)(v) is amended by 
striking ‘‘for for’’ and inserting ‘‘for’’. 
(245) Section 5054(a)(3)(B) is amended by 
striking ‘‘sections’’ and inserting ‘‘section’’. 
(246) Section 5066(d) is amended by striking 
‘‘section 
5001(a)(5)’’ 
and 
inserting 
‘‘section 
5001(a)(4)’’. 
(247) The item relating to subpart C in the 
table of subparts for part II of subchapter A of 
chapter 51 is amended to read as follows: 
‘‘SUBPART C. RECORDKEEPING AND REGISTRATION BY DEALERS’’. 
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(265) Section 6039(d)(2) is amended to read as 
follows: 
‘‘(2) the term ‘employee stock purchase plan’, 
see section 423(b).’’. 
(266) 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 6041 
the following new item: 
‘‘Sec. 6041A. Returns regarding payments of remuneration for services and di-
rect sales.’’. 
(267) The item relating to section 6050I in the 
table of sections for subpart B of part III of sub-
chapter A of chapter 61 is amended to read as fol-
lows: 
‘‘Sec. 6050I. Returns relating to cash received in trade or business, etc.’’. 
(268) The item relating to section 6050W in 
the table of sections for subpart B of part III of 
subchapter A of chapter 61 is amended to read as 
follows: 
‘‘Sec. 6050W. Returns relating to payments made in settlement of payment 
card and third party network transactions.’’. 
(269) Section 6050H(h)(3)(B)(i) is amended by 
striking ‘‘Rural Housing Administration’’ and insert-
ing ‘‘Rural Housing Service’’. 
(270) Section 6058(e) is amended by striking 
paragraph (1) and by redesignating paragraphs (2) 
and (3) as paragraphs (1) and (2), respectively. 
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(278) Section 6103(p)(3)(C)(ii) is amended by 
striking the comma at the end and inserting a pe-
riod. 
(279) Section 6103(p)(4) is amended by strik-
ing ‘‘7(a)(ii)’’ in the flush matter before subpara-
graph (A) and inserting ‘‘(7)(A)(ii)’’. 
(280) Section 6103(p)(4)(F)(ii) is amended— 
(A) by striking ‘‘subsections’’ and inserting 
‘‘subsection’’, and 
(B) by striking ‘‘subsection (l)(21),,,’’ and 
inserting ‘‘subsection (l)(21),’’. 
(281) Section 6103(p)(4) is amended by strik-
ing ‘‘subsection (l)(21),,’’ both places it appears in 
the flush matter at the end and inserting ‘‘sub-
section (l)(21),’’. 
(282) Section 6109(f) is amended by striking 
‘‘OF 1977’’ in the heading thereof. 
(283) Section 6213(g)(2)(O) is amended by 
adding a comma at the end. 
(284) Section 6213(g)(2)(P) is amended— 
(A) by striking ‘‘section 24(h)(2)’’ and in-
serting ‘‘section 24(g)(2)’’, and 
(B) by striking ‘‘subsection (h)(1)’’ and in-
serting ‘‘subsection (g)(1)’’. 
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(285) Section 6302(e)(2)(A) is amended by 
striking ‘‘sections’’ and inserting ‘‘section’’. 
(286) Section 6311(d)(3)(D) is amended— 
(A) by striking ‘‘section 103(f)’’ and in-
serting ‘‘section 103(g)’’, and 
(B) by striking ‘‘1602(f)’’ and inserting 
‘‘1602(g)’’. 
(287) Section 6330(d)(2) is amended by strik-
ing ‘‘, and’’ at the end and inserting a period. 
(288) Section 6334(a)(10)(A) is amended by 
striking ‘‘V,,’’ and inserting ‘‘V,’’. 
(289) Section 6342(a) is amended by striking 
‘‘subsection 
(c)(2)’’ 
and 
inserting 
‘‘subsection 
(d)(2)’’. 
(290) Section 6402(a) is amended by striking 
‘‘(f) refund’’ and inserting ‘‘(f), refund’’. 
(291) Section 6402(c) is amended by striking 
‘‘of of’’ and inserting ‘‘of’’. 
(292) Section 6402(d)(2) is amended by strik-
ing ‘‘section 402(a)(26) of the Social Security Act’’ 
and inserting ‘‘section 408(a)(3) of the Social Secu-
rity Act (42 U.S.C. 608(a)(3))’’. 
(293) Section 6404(g)(2)(E) is amended by 
striking ‘‘section 6664(d)(2)(A)’’ and inserting ‘‘sec-
tion 6664(d)(3)(A)’’. 
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(294) Section 6420(i)(4) is amended by striking 
‘‘State and’’ and inserting ‘‘State (and’’. 
(295) Section 6421(c) is amended by striking 
‘‘(4) (5)’’ and inserting ‘‘(4), (5)’’. 
(296) Section 6421(j)(3) is amended by striking 
‘‘State and’’ and inserting ‘‘State (and’’. 
(297) Section 6422 is amended— 
(A) by striking paragraph (7), 
(B) 
by 
redesignating 
paragraphs 
(8) 
through (12) as paragraphs (7) through (11), 
respectively, and 
(C) by striking ‘‘for credit’’ in paragraph 
(10) as so redesignated and inserting ‘‘For 
credit’’. 
(298) Section 6425(c)(1)(A) is amended by 
striking ‘‘The sum’’ and inserting ‘‘the sum’’. 
(299) Section 6426(b)(2)(A)(ii) is amended by 
striking ‘‘cents..’’ and inserting ‘‘cents.’’. 
(300) Section 6501(m) is amended by striking 
‘‘any election’’ and all that follows through ‘‘(or 
any’’ and inserting the following: ‘‘any election 
under section 30B(h)(9), 30C(e)(4), 30D(e)(4), 
35(g)(11), 40(f), 43, 45B, 45C(d)(4), 45H(g), or 
51(j) (or any’’. 
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(301) Section 6503(a)(1) is amended by strik-
ing ‘‘section 6230(a)).’’ and inserting ‘‘section 
6230(a))’’. 
(302) Section 6612(c) is amended— 
(A) 
by 
inserting 
‘‘sections’’ 
before 
‘‘2014(e)’’, and 
(B) by striking ‘‘and 6420’’ and inserting 
‘‘6420’’. 
(303) The item relating to section 6651 in the 
table of sections for part I of subchapter A of chap-
ter 68 is amended to read as follows: 
‘‘Sec. 6651. Failure to file tax return or to pay tax.’’. 
(304) Each of the following sections are amend-
ed by inserting ‘‘an amount equal to’’ after ‘‘in-
creased by’’ and by inserting ‘‘for the calendar year’’ 
after ‘‘section 1(f)(3)’’: 
(A) Section 6651(i). 
(B) Section 6652(c)(7)(A). 
(C) Section 6695(h)(1). 
(D) Section 6698(e)(1). 
(E) Section 6699(e)(1). 
(F) Section 6721(f)(1). 
(G) Section 6722(f)(1). 
(305) Section 6654(a) is amended by striking 
‘‘chapter 1 the tax’’ and inserting ‘‘chapter 1, the 
tax’’. 
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(306) Section 6654(f)(3) is amended by strik-
ing ‘‘taxes’’ and inserting ‘‘tax’’. 
(307) Section 6662(d)(3) is amended by strik-
ing ‘‘section 6664(d)(2)’’ and inserting ‘‘section 
6664(d)(3)’’. 
(308) Section 6662 is amended by moving sub-
section (i) before subsection (j). 
(309) The heading of section 6676(c) is amend-
ed by striking ‘‘REASONABLE BASIS’’ and inserting 
‘‘REASONABLE CAUSE’’. 
(310) The item relating to section 6684 in the 
table of sections for part I of subchapter B of chap-
ter 68 is amended to read as follows: 
‘‘Sec. 6684. Assessable penalties with respect to liability for tax under chapter 
42.’’. 
(311) The item relating to section 6686 in the 
table of sections for part I of subchapter B of chap-
ter 68 is amended to read as follows: 
‘‘Sec. 6686. Failure to file returns or supply information by DISC or former 
FSC.’’. 
(312) Section 6679(a)(1) is amended by strik-
ing ‘‘section 6046 and 6046A’’ and inserting ‘‘sec-
tion 6046 or 6046A’’. 
(313) Section 6695(h)(2) is amended by strik-
ing ‘‘subparagraph (A)’’ and inserting ‘‘paragraph 
(1)’’. 
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(314) Section 6695(h)(2)(B) is amended by 
striking ‘‘clause (i)’’ and inserting ‘‘subparagraph 
(A)’’. 
(315) Section 6696(a) is amended by striking 
‘‘section 6694,’’ and inserting ‘‘sections 6694,’’. 
(316) Section 6696(d)(1) is amended by strik-
ing ‘‘section 6695,’’ and inserting ‘‘6695,’’. 
(317) Section 6698(b)(2) is amended by adding 
a period at the end. 
(318) Section 6700(a) is amended by striking 
‘‘the $1,000’’ and inserting ‘‘$1,000’’. 
(319) Section 6724(d)(1)(B)(xx) is amended by 
striking ‘‘or’’ at the end. 
(320) Section 6724(d)(1)(B)(xxi) is amended 
by striking ‘‘and’’ at the end. 
(321) Section 6724(d)(1) is amended by strik-
ing ‘‘Such term also includes’’ and inserting the fol-
lowing: 
‘‘Such term also includes’’. 
(322) Section 6724(d)(2)(F) is amended by 
striking the period at the end and inserting a 
comma. 
(323) Section 6724(d)(2)(M) is amended by 
striking ‘‘(h)(2) relating’’ and inserting ‘‘(h)(2) (re-
lating’’. 
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101 
(b) GENERAL DEADWOOD-RELATED PROVISIONS.— 
(1) Section 25A(c)(1) is amended by striking 
‘‘($5,000 in the case of taxable years beginning be-
fore January 1, 2003)’’. 
(2) Section 26(b)(2) is amended by striking 
subparagraph (P). 
(3) Section 32(l) is amended by striking ‘‘, and 
any payment made to such individual (or such 
spouse) by an employer under section 3507,’’. 
(4)(A) Section 38(c)(5) is amended— 
(i) by striking all that precedes subpara-
graph (C) thereof and inserting the following: 
‘‘(5) RULES
RELATED
TO
ELIGIBLE
SMALL 
BUSINESSES.—’’, 
(ii) by redesignating subparagraphs (C) 
and (D) as subparagraphs (A) and (B), respec-
tively, and 
(iii) by amending subparagraph (B) (as so 
redesignated) to read as follows: 
‘‘(B) TREATMENT
OF
PARTNERS
AND
S 
CORPORATION SHAREHOLDERS.—For purposes 
of paragraph (4)(B)(ii), any credit determined 
under section 41 with respect to a partnership 
or S corporation shall not be treated as a speci-
fied credit by any partner or shareholder unless 
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102 
such partner or shareholder meets the gross re-
ceipts test under subparagraph (A) for the tax-
able year in which such credit is treated as a 
current year business credit.’’. 
(B) Section 38(c)(2)(A)(ii)(II) is amended by 
striking ‘‘the eligible small business credits,’’. 
(C) Section 38(c)(4)(A)(ii)(II) is amended by 
striking ‘‘the eligible small business credits and’’. 
(D) Section 38(c)(4)(B)(ii) is amended by strik-
ing ‘‘(as defined in paragraph (5)(C), after applica-
tion of rules similar to the rules of paragraph 
(5)(D))’’ and inserting ‘‘(as defined in paragraph 
(5)(A) after application of the rules of paragraph 
(5)(B))’’. 
(5) Section 56(d)(1)(A)(ii)(I) is amended by in-
serting ‘‘(as in effect before its repeal by the Tax In-
crease Prevention Act of 2014)’’ after ‘‘section 
172(b)(1)(H)’’. 
(6)(A) Section 139(c)(2) is amended by striking 
‘‘section 165(h)(3)(C)(i)’’ and inserting ‘‘section 
165(i)(5)(A)’’. 
(B) Section 7508A(a) is amended by striking 
‘‘section 165(h)(3)(C)(i)’’ and inserting ‘‘section 
165(i)(5)(A)’’. 
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103 
(7) Section 140(a) is amended by striking para-
graph (2) and by redesignating paragraphs (3) 
through (6) as paragraphs (2) through (5), respec-
tively. 
(8) Section 163(d)(4) is amended by striking 
subparagraph (E). 
(9) Section 168 is amended by striking sub-
section (n). 
(10) Section 172(b)(1)(D)(iv) is amended by 
striking ‘‘subsection (h)’’ and inserting ‘‘subsection 
(g)’’. 
(11) Section 246A(b)(1) is amended by striking 
‘‘without regard to section 243(d)(4)’’. 
(12) Section 409 is amended by striking sub-
section (m). 
(13) Section 411(a)(3)(F)(i) is amended by 
striking ‘‘under section 418D or’’. 
(14) Section 413(b)(6) is amended by striking 
‘‘and the last sentence of section 4971(a)’’ in the 
last sentence. 
(15) Section 415(g) is amended by striking 
‘‘subsection 
(f)(3)’’ 
and 
inserting 
‘‘subsection 
(f)(2)’’. 
(16)(A) Section 419(e)(3)(A) is amended by 
striking ‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 
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104 
(B) Section 419A(g)(1) is amended by striking 
‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 
(C) Section 419A(g)(2) is amended by striking 
‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 
(D) Section 505 is amended— 
(i) in the heading thereof, by striking 
‘‘PARAGRAPH (9), (17), OR (20)’’ and insert-
ing ‘‘PARAGRAPH (9) OR (17)’’, 
(ii) in the heading of subsection (a), by 
striking ‘‘PARAGRAPH (9) OR (20) OF SECTION 
501(c)’’ and inserting ‘‘SECTION 501(c)(9)’’, 
(iii) in subsection (a)(1), by striking ‘‘para-
graph (9) or (20) of subsection (c) of section 
501’’ and inserting ‘‘section 501(c)(9)’’, and 
(iv) in subsection (c)(1), by striking ‘‘para-
graph (9), (17), or (20)’’ and inserting ‘‘para-
graph (9) or (17)’’. 
(E) Subparagraphs (A), (C), and (D) of section 
512(a)(3) are each amended in the text thereof by 
striking ‘‘(17), or (20)’’ and inserting ‘‘or (17)’’. 
(F) Subparagraphs (B)(ii) and (E) of section 
512(a)(3) are each amended in the text thereof by 
striking ‘‘, (17), or (20)’’ and inserting ‘‘or (17)’’. 
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105 
(G) The heading of section 512(a)(3) is amend-
ed by striking ‘‘(17), OR
(20)’’ and inserting ‘‘OR 
(17)’’. 
(H) The heading of section 512(a)(3)(E) is 
amended by striking ‘‘, (17), OR (20)’’ and inserting 
‘‘OR (17)’’. 
(I) The item relating to section 505 in the table 
of sections for part I of subchapter F of chapter 1 
is amended to read as follows: 
‘‘Sec. 505. Additional requirements for organizations described in paragraph 
(9) or (17) of section 501(c).’’. 
(17) Section 501(p)(4) is amended by striking 
‘‘, 556(b)(2)’’. 
(18) Section 530(b)(3) is amended— 
(A) by striking ‘‘(as defined in section 
170(e)(6)(F)(i))’’ in subparagraph (A)(iii), and 
(B) by adding at the end the following new 
subparagraph: 
‘‘(C) COMPUTER TECHNOLOGY OR EQUIP-
MENT.—The term ‘computer technology or 
equipment’ means computer software (as de-
fined by section 197(e)(3)(B)), computer or pe-
ripheral equipment (as defined by section 
168(i)(2)(B)), and fiber optic cable related to 
computer use.’’. 
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106 
(19) Section 593(b)(2)(D)(iv) is amended by 
striking ‘‘(determined without regard to section 
596)’’. 
(20) Section 597(c)(1) is amended by striking 
‘‘or section 21A of the Federal Home Loan Bank 
Act’’. 
(21) Section 664(g)(3)(E) is amended by strik-
ing ‘‘limitations under sections 415(c) and (e)’’ and 
inserting ‘‘limitation under section 415(c)’’. 
(22) Section 810(b) is amended by striking 
paragraph (4). 
(23) Section 856(m) is amended by striking 
paragraph (6). 
(24) Section 871(a)(3) is amended by striking 
the last sentence thereof. 
(25) Section 992(d) is amended by striking 
paragraph (6) and by redesignating paragraph (7) 
as paragraph (6). 
(26) Section 1245(a)(3)(C) is amended by 
striking ‘‘, 185’’. 
(27)(A) Section 1252(a)(1) is amended by 
striking ‘‘during a taxable year beginning’’. 
(B) Section 1252(a)(1)(A) is amended— 
(i) by striking ‘‘sections’’ and inserting 
‘‘section’’, and 
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107 
(ii) by striking ‘‘and 182’’ and all that fol-
lows through ‘‘for expenditures’’ and inserting 
‘‘for expenditures’’. 
(C) Section 1252(a)(2) is amended— 
(i) by striking ‘‘sections’’ and inserting 
‘‘section’’, and 
(ii) by striking ‘‘or 182’’ and all that fol-
lows and inserting a period. 
(28) Section 3111 is amended by striking sub-
section (d). 
(29) Section 3127(b)(3) is amended by striking 
‘‘or 222(b)’’. 
(30) Section 3221 is amended by striking sub-
section (c) and by redesignating subsection (d) as 
subsection (c). 
(31) Section 4481(d) is amended to read as fol-
lows: 
‘‘(d) ONE TAX LIABILITY PER PERIOD.—To the ex-
tent that the tax imposed by this section is paid with re-
spect to any highway motor vehicle for any taxable period, 
no further tax shall be imposed by this section for such 
taxable period with respect to such vehicle.’’. 
(32) Section 4971(d) is amended by striking 
the last sentence. 
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108 
(33) Section 6050G(a)(2) is amended by strik-
ing ‘‘(to the extent not previously taken into account 
under section 72(d)(1))’’. 
(34) Section 6215(b) is amended by striking 
paragraph (5) and by redesignating paragraphs (6) 
and (7) as paragraphs (5) and (6), respectively. 
(35) Section 6601(b) is amended by striking 
paragraph (2) and by redesignating paragraphs (3) 
through (5) as paragraphs (2) through (4), respec-
tively. 
(36) Section 6654(d)(1)(C)(i) is amended by 
striking ‘‘by substituting’’ and all that follows and 
inserting ‘‘by substituting ‘110 percent’ for ‘100 
percent’.’’. 
(37) Section 6654(d)(1) is amended by striking 
subparagraph (D). 
(38) Part II of subchapter C of chapter 75 is 
amended by striking section 7326 (and by striking 
the item relating to such section in the table of sec-
tions for such part). 
(39) Section 7448(a)(5) is amended by striking 
‘‘, whether or not performing judicial duties under 
section 7443B’’. 
(40) Section 7448(a)(6) is amended by striking 
‘‘, and compensation received under section 7443B’’. 
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109 
(41) Section 7448(d) is amended by striking 
‘‘at 4 percent per annum to December 31, 1947, 
and 3 percent per annum thereafter’’ and inserting 
‘‘at 3 percent per annum’’. 
(42) Section 7701(a)(19)(A) is amended by 
striking ‘‘either (i)’’ and all that follows through 
‘‘(ii)’’. 
(43) Section 7701(a)(32)(A) is amended to 
read as follows: 
‘‘(A) is subject by law to supervision and 
examination by State or Federal authority hav-
ing supervision over such institutions, and’’. 
(c) REPEAL OF CERTAIN OBSOLETE BOND PROVI-
SIONS.— 
(1) CERTAIN RULES WITH RESPECT TO BONDS 
ISSUED BEFORE JULY 2, 1982.— 
(A) Section 1271 is amended— 
(i) by striking subsection (c) and by 
redesignating subsection (d) as subsection 
(c), and 
(ii) by striking ‘‘(and paragraph (2) of 
subsection (c))’’ in subsection (a)(2)(B). 
(B) Section 1272 is amended by striking 
subsection (b) and by redesignating subsections 
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110 
(c) and (d) as subsections (b) and (c), respec-
tively. 
(C) Section 163(e)(1) is amended by strik-
ing ‘‘In the case of any debt instrument issued 
after July 1, 1982, the portion of the original 
issue discount with respect to such debt instru-
ment which is’’ and inserting ‘‘The portion of 
the original issue discount with respect to any 
debt instrument which is’’. 
(D) Section 163(j)(2)(C)(ii) is amended by 
striking ‘‘or (b)(4)’’. 
(E) Section 1271(a)(2)(A)(ii) is amended 
by striking ‘‘subsection (a)(7) or (b)(4) of sec-
tion 1272’’ and inserting ‘‘section 1272(a)(7)’’. 
(F) Section 1271(b)(1) is amended to read 
as follows: 
‘‘(1) IN GENERAL.—This section shall not apply 
to any obligation issued by a natural person before 
June 9, 1997.’’. 
(G) Section 1272(a) is amended— 
(i) by striking ‘‘ON DEBT INSTRU-
MENTS ISSUED AFTER JULY 1, 1982,’’ in 
the heading, and 
(ii) by striking ‘‘issued after July 1, 
1982’’ in paragraph (1). 
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111 
(H) Section 1278(a)(4)(B) is amended by 
striking ‘‘or (b)(4)’’. 
(I) The amendments made by this para-
graph shall apply to debt instruments issued on 
or after July 2, 1982. 
(2) 
CERTAIN
RULES
WITH
RESPECT
TO 
STRIPPED
BONDS
PURCHASED
BEFORE
JULY
2, 
1982.— 
(A) Section 1286 is amended by striking 
subsection (c). 
(B) Subsections (a) and (b) of section 
1286 are each amended by striking ‘‘after July 
1, 1982,’’. 
(C) Section 1286(e)(5) is amended by 
striking the last sentence. 
(D) The amendments made by this para-
graph shall apply to bonds purchased on or 
after July 2, 1982. 
(3) CERTAIN RULES WITH RESPECT TO OBLIGA-
TIONS ISSUED BEFORE MARCH 2, 1984.— 
(A) Section 1272(a)(2) is amended by 
striking subparagraph (D) and by redesignating 
subparagraph (E) as subparagraph (D). 
(B) Section 163(e)(4) is amended to read 
as follows: 
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112 
‘‘(4) EXCEPTION.—This subsection shall not 
apply to any debt instrument described in section 
1272(a)(2)(D) (relating to loans between natural 
persons).’’. 
(C) The amendments made by this para-
graph shall apply to obligations issued on or 
after March 2, 1984. 
(d) DEADWOOD PROVISIONS INVOLVING REPEAL OF 
ONE OR MORE SECTIONS.— 
(1) ENERGY EFFICIENT APPLIANCE CREDIT.— 
(A) IN GENERAL.—Subpart D of part IV 
of subchapter A of chapter 1 is amended by 
striking section 45M (and by striking the item 
relating to such section in the table of sections 
for such subpart). 
(B) CONFORMING
AMENDMENT.—Section 
38(b), as amended by the preceding provisions 
of this Act, is amended by striking paragraph 
(24) and by redesignating paragraphs (25) 
through (36) as paragraphs (24) through (35), 
respectively. 
(2) 
QUALIFYING
THERAPEUTIC
DISCOVERY 
PROJECT CREDIT.— 
(A) IN GENERAL.—Subpart E of part IV 
of subchapter A of chapter 1 is amended by 
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113 
striking section 48D (and by striking the item 
relating to such section in the table of sections 
for such subpart). 
(B) CONFORMING AMENDMENTS.— 
(i) Section 49(a)(1)(C) is amended by 
adding ‘‘and’’ at the end of clause (iv), by 
striking ‘‘, and’’ at the end of clause (v) 
and inserting a period, and by striking 
clause (vi). 
(ii) Section 50(a)(2)(E) is amended 
by striking ‘‘48C(b)(2), or 48D(b)(4)’’ and 
inserting ‘‘or 48C(b)(2)’’. 
(iii) Section 280C is amended by 
striking the subsection (g) which relates to 
the qualifying therapeutic discovery project 
credit. 
(C) SAVINGS PROVISION.—In the case of 
the repeal of section 48D(e)(1) of the Internal 
Revenue Code of 1986, the amendments made 
by this paragraph shall not apply to expendi-
tures made in taxable years beginning before 
January 1, 2011. 
(3) DC ZONE PROVISIONS.— 
(A) IN GENERAL.—Chapter 1 is amended 
by striking subchapter W (and by striking the 
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