‘‘(c) APPLICABILITY.—Subsections (a) and (b) shall 
not apply with respect to tenant-based assistance provided 
under section 8(o) of the United States Housing Act of 
1937 (42 U.S.C. 1437f(o)).’’. 
(b) SUPPLEMENTAL ADMINISTRATIVE FEE.—Section 
8(q)(2)(B) of the United States Housing Act of 1937 (42 
U.S.C. 1437f(q)(2)(B)) is amended by inserting ‘‘, includ-
ing the cost of assisting families with children that move 
to lower poverty, higher opportunity neighborhoods (as de-
termined by the Secretary based on objective, evidence- 
based criteria)’’ after ‘‘programs’’. 
(c) REGIONAL PLANNING TO INCREASE ACCESS TO 
HIGHER OPPORTUNITY AREAS.—Section 8(o) of the 
United States Housing Act of 1937 (42 U.S.C. 1437f(o)) 
is amended by adding at the end the following: 
‘‘(21) INCREASE
ACCESS
TO
HIGHER
OPPOR-
TUNITY AREAS.— 
‘‘(A) LOCATION ANALYSIS.— 
‘‘(i) IN GENERAL.—A public housing 
agency that administers the program 
under this subsection in a metropolitan 
area shall— 
‘‘(I) analyze the locations where 
the participants of the program of the 
public housing agency live; and 
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‘‘(II) based on the analysis de-
scribed in subclause (I), establish poli-
cies and practices to reduce disparities 
and barriers to access to locations 
throughout the metropolitan area that 
evidence indicates are more likely to 
improve outcomes for children or 
adults. 
‘‘(ii) CONSIDERATIONS.—The location 
analysis required under this subparagraph 
shall— 
‘‘(I) consider separately the loca-
tions of families with children, house-
holds that include a person with dis-
abilities, and other groups protected 
under the Fair Housing Act (42 
U.S.C. 3601 et seq.); and 
‘‘(II) include an analysis of the 
locations in relation to dwelling units 
with rents that are potentially afford-
able to voucher holders and the likely 
impact of key neighborhood attributes 
on their well-being and long-term suc-
cess, based on Federal and available 
local data. 
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‘‘(iii) MAPPING
TOOLS.—The Sec-
retary shall— 
‘‘(I) provide mapping tools and 
other information necessary for a pub-
lic housing agency to perform the lo-
cation analysis under this subpara-
graph using the demographic data on 
participating families submitted to the 
Secretary under part 908 of title 24, 
Code of Federal Regulations, or any 
successor regulation; 
‘‘(II) publish a notice in the Fed-
eral Register, subject to public com-
ment, that specifies the data sources 
and definitions that will be incor-
porated in each mapping tool required 
under subclause (I); and 
‘‘(III) update the notice required 
under subclause (II) as needed based 
on changes in the availability of rel-
evant data or evidence of neighbor-
hood attributes likely to impact the 
well-being and long-term success of 
participants in the program under this 
subsection. 
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‘‘(iv) 
FREQUENCY
AND
AVAIL-
ABILITY.—The location analysis required 
under this subparagraph shall— 
‘‘(I) be performed by each public 
housing agency described in clause (i) 
not less frequently than once every 5 
years; 
‘‘(II) be performed by all public 
housing agencies in a metropolitan 
area in the same year, as determined 
by the Secretary; and 
‘‘(III) be made available to the 
public in a manner that protects the 
privacy of program participants. 
‘‘(B) REGIONAL
POLICIES
TO
INCREASE 
ACCESS TO HIGHER OPPORTUNITY NEIGHBOR-
HOODS.—Each public housing agency described 
in subparagraph (A)(i) shall— 
‘‘(i) consult with other such public 
housing agencies in the same metropolitan 
area, or smaller regional area approved by 
the Secretary, about the possible barriers 
and other reasons for the disparities iden-
tified in the location analysis required 
under subparagraph (A); 
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‘‘(ii) identify policies or practices that 
those public housing agencies could adopt 
individually or in collaboration, or other 
strategies that recipients of grants or other 
funding from the Secretary could adopt, to 
reduce the barriers and disparities and in-
crease the share of families with children 
and other demographic groups using 
vouchers in higher-opportunity neighbor-
hoods in the metropolitan area or region; 
and 
‘‘(iii) include in the administrative 
plan required under section 982.54 of title 
24, Code of Federal Regulations, or any 
successor regulation, the policies that the 
public housing agency has adopted under 
this paragraph. 
‘‘(C) ASSESSMENT.—The Secretary shall 
include public housing agency performance in 
achieving the goal described in subparagraph 
(A)(i)(II) in the periodic assessment of agency 
performance in managing the program under 
this subsection required under part 985 of title 
24, Code of Federal Regulations, or any suc-
cessor regulation.’’. 
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(d) REQUIRED REGULATORY CHANGES TO PUBLIC 
HOUSING AGENCY CONSORTIA.— 
(1) DEFINITIONS.—In this subsection: 
(A) MOVING
TO
WORK
DEMONSTRATION 
PROGRAM.—The term ‘‘Moving to Work dem-
onstration program’’ means the program estab-
lished under section 204 of the Departments of 
Veterans Affairs and Housing and Urban De-
velopment, and Independent Agencies Appro-
priations Act, 1996 (Public Law 104–134; 110 
Stat. 1321–281). 
(B) PUBLIC HOUSING AGENCY.—The term 
‘‘public housing agency’’ has the meaning given 
the term in section 3(b)(6) of the United States 
Housing Act of 1937 (42 U.S.C. 1437a(b)(6)). 
(2) REQUIREMENT.—Not later than 1 year 
after the date of enactment of this Act, the Sec-
retary of Housing and Urban Development shall es-
tablish policies and procedures that— 
(A) enable public housing agencies that 
elect to operate in consortia under section 13(a) 
of the United States Housing Act of 1937 (42 
U.S.C. 1437k(a)), excluding public housing 
agencies participating in the Moving to Work 
demonstration program— 
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(i) to consolidate their funding con-
tracts for assistance provided under section 
8(o) of such Act (42 U.S.C. 1437f(o)) into 
a single contract; 
(ii) to consolidate their funding con-
tracts for assistance provided under sub-
sections (d) and (e) of section 9 of such 
Act 42 U.S.C. 1437g); or 
(iii) to exercise the consolidation op-
tions under each of clauses (i) and (ii); and 
(B) enable public housing agencies to form 
partial consortia under such section 13(a) (42 
U.S.C. 1437k(a)) that consolidate administra-
tion of certain aspects of their housing pro-
grams to increase access to higher-opportunity 
areas or for other purposes, subject to such re-
quirements as the Secretary may establish. 
(3) MOVING TO WORK AGENCIES.—Any flexi-
bility or waiver applicable to the Moving to Work 
demonstration program shall not apply to any activi-
ties or funds administered through a partial con-
sortia formed under paragraph (2)(B) by 1 or more 
public housing agencies participating in the Moving 
to Work demonstration program. 
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TITLE IV—ESTATE TAX REFORM 
SEC. 401. AMENDMENT TO INTERNAL REVENUE CODE OF 
1986. 
Except as otherwise expressly provided, whenever in 
this title 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 
section or other provision of the Internal Revenue Code 
of 1986. 
SEC. 402. RATE ADJUSTMENT. 
(a) INCREASE IN MAXIMUM ESTATE TAX RATES.— 
The table contained in section 2001(c) is amended by 
striking the last row and inserting the following: 
Over $1,000,000 ............................
$345,800, plus 55 percent of the ex-
cess 
of 
such 
amount 
over 
$1,000,000. 
Over $13,000,000 ..........................
$6,945,800, plus 60 percent of the 
excess 
of 
such 
amount 
over 
$13,000,000. 
Over $93,000,000 ..........................
$54,945,800, plus 65 percent of the 
excess 
of 
such 
amount 
over 
$93,000,000. 
(b) REDUCTION OF BASIC EXCLUSION AMOUNT.— 
Paragraph (3) of section 2010(c) is amended to read as 
follows: 
‘‘(3) BASIC
EXCLUSION
AMOUNT.—For pur-
poses of this subsection, the basic exclusion amount 
is $3,500,000.’’. 
(c) SURTAX ON BILLION DOLLAR ESTATES.—Section 
2001 is amended— 
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(1) in subsection (b), by striking ‘‘The tax’’ and 
inserting ‘‘Subject to subsection (h), the tax’’; and 
(2) by adding at the end the following new sub-
section: 
‘‘(h) SURTAX ON BILLION DOLLAR ESTATES.— 
‘‘(1) IN GENERAL.—In the case of a taxable es-
tate for which the applicable amount is in excess of 
$1,000,000,000, the tax determined under sub-
section (b) shall be increased by an amount equal to 
10 percent of such applicable amount. 
‘‘(2) APPLICABLE AMOUNT.—For purposes of 
this subsection, the applicable amount shall be equal 
to the sum of the amounts under subparagraphs (A) 
and (B) of paragraph (1) of subsection (b) for the 
taxable estate.’’. 
SEC. 403. REQUIRED MINIMUM 10-YEAR TERM, ETC., FOR 
GRANTOR RETAINED ANNUITY TRUSTS. 
(a) IN GENERAL.—Subsection (b) of section 2702 is 
amended— 
(1) by redesignating paragraphs (1), (2), and 
(3) as subparagraphs (A), (B), and (C), respectively, 
and by moving such subparagraphs (as so redesig-
nated) 2 ems to the right; 
(2) by striking ‘‘For purposes of’’ and inserting 
the following: 
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‘‘(1) IN GENERAL.—For purposes of’’; 
(3) by striking ‘‘paragraph (1) or (2)’’ in para-
graph (1)(C) (as so redesignated) and inserting 
‘‘subparagraph (A) or (B)’’; and 
(4) by adding at the end the following new 
paragraph: 
‘‘(2) ADDITIONAL
REQUIREMENTS
WITH
RE-
SPECT
TO
GRANTOR
RETAINED
ANNUITIES.—For 
purposes of subsection (a), in the case of an interest 
described in paragraph (1)(A) (determined without 
regard to this paragraph) which is retained by the 
transferor, such interest shall be treated as de-
scribed in such paragraph only if— 
‘‘(A) the right to receive the fixed amounts 
referred to in such paragraph is for a term of 
not less than 10 years, 
‘‘(B) such fixed amounts, when determined 
on an annual basis, do not decrease relative to 
any prior year during the first 10 years of the 
term referred to in subparagraph (A), and 
‘‘(C) the remainder interest has a value 
equal to or greater than 10 percent of the value 
of the assets transferred to the trust, deter-
mined as of the time of the transfer.’’. 
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(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to transfers made after the date 
of the enactment of this Act. 
SEC. 404. CERTAIN TRANSFER TAX RULES APPLICABLE TO 
GRANTOR TRUSTS. 
(a) IN GENERAL.—Subtitle B is amended by adding 
at the end the following new chapter: 
‘‘CHAPTER 16—SPECIAL RULES FOR 
GRANTOR TRUSTS 
‘‘Sec. 2901. Application of transfer taxes. 
‘‘SEC. 2901. APPLICATION OF TRANSFER TAXES. 
‘‘(a) IN GENERAL.—In the case of any portion of a 
trust to which this section applies— 
‘‘(1) the value of the gross estate of the de-
ceased deemed owner of such portion shall include 
all assets attributable to that portion at the time of 
the death of such owner, 
‘‘(2) any distribution from such portion to one 
or more beneficiaries during the life of the deemed 
owner of such portion shall be treated as a transfer 
by gift for purposes of chapter 12, and 
‘‘(3) if at any time during the life of the 
deemed owner of such portion, such owner ceases to 
be treated as the owner of such portion under sub-
part E of part 1 of subchapter J of chapter 1, all 
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assets attributable to such portion at such time shall 
be treated for purposes of chapter 12 as a transfer 
by gift made by the deemed owner. 
‘‘(b) PORTION OF TRUST TO WHICH SECTION AP-
PLIES.—This section shall apply to— 
‘‘(1) the portion of a trust with respect to 
which the grantor is the deemed owner, and 
‘‘(2) the portion of the trust to which a person 
who is not the grantor is a deemed owner by reason 
of the rules of subpart E of part 1 of subchapter J 
of chapter 1, and such deemed owner engages in a 
sale, exchange, or comparable transaction with the 
trust that is disregarded for purposes of subtitle A. 
For purposes of paragraph (2), the portion of the trust 
described with respect to a transaction is the portion of 
the trust attributable to the property received by the trust 
in such transaction, including all retained income there-
from, appreciation thereon, and reinvestments thereof, net 
of the amount of consideration received by the deemed 
owner in such transaction. 
‘‘(c) EXCEPTIONS.—This section shall not apply to— 
‘‘(1) any trust that is includible in the gross es-
tate of the deemed owner (without regard to sub-
section (a)(1)), and 
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