rower’s annual or aggregate loan limits under section 428 
or 428H. 
‘‘(e) NO ELIGIBILITY FOR SERVICE-RELATED RE-
PAYMENT.—Notwithstanding 
sections 
428K(a)(2)(A), 
428L(b)(2), 455(m)(3)(A), and 460(b), a Federal Direct 
Refinanced Private Loan, or any Federal Direct Consoli-
dation Loan to the extent such loan was used to repay 
a Federal Direct Refinanced Private Loan, shall not be 
eligible for any loan repayment or loan forgiveness pro-
gram under section 428K, 428L, or 460 or for the repay-
ment plan for public service employees under section 
455(m). 
‘‘(f) ORIGINATION FEE.—The Secretary shall charge 
the borrower of a Federal Direct Refinanced Private Loan 
an origination fee that equals the origination fee charged 
for Federal Direct Unsubsidized Stafford Loans disbursed 
on the date upon which the Federal Direct Refinanced 
Private Loan is issued. 
‘‘(g) EXPIRATION OF AUTHORITY.—The Secretary’s 
authority to reissue loans under this section shall expire 
on the date that is determined in accordance with section 
4 of the Fairness in Student Loan Lending Act.’’. 
(c) AMENDMENTS TO PUBLIC SERVICE REPAYMENT 
PLAN PROVISIONS.—Section 455(m) of the Higher Edu-
cation Act of 1965 (20 U.S.C. 1087e(m)) is amended— 
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(1) by redesignating paragraphs (3) and (4) as 
paragraphs (4) and (5), respectively; 
(2) by inserting after paragraph (2) the fol-
lowing: 
‘‘(3) SPECIAL
RULES
FOR
SECTION
460A 
LOANS.— 
‘‘(A) 
REFINANCED
FEDERAL
DIRECT 
LOANS.—Notwithstanding paragraph (1), in de-
termining the number of monthly payments 
that meet the requirements of such paragraph 
for an eligible Federal Direct Loan reissued 
under section 460A that was originally a loan 
under this part, the Secretary shall include all 
monthly payments made on the original loan 
that meet the requirements of such paragraph. 
‘‘(B) REFINANCED FFEL LOANS.—In the 
case of an eligible Federal Direct Loan reissued 
under section 460A that was originally a loan 
under part B, only monthly payments made 
after the date on which the loan was reissued 
may be included for purposes of paragraph 
(1).’’; and 
(3) in paragraph (4)(A) (as redesignated by 
paragraph (1) of this subsection), by inserting ‘‘(in-
cluding any Federal Direct Stafford Loan, Federal 
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Direct PLUS Loan, Federal Direct Unsubsidized 
Stafford Loan, or Federal Direct Consolidation 
Loan reissued under section 460A)’’ before the pe-
riod at the end. 
(d) INCOME-BASED REPAYMENT.—Section 493C of 
the Higher Education Act of 1965 (20 U.S.C. 1098e) is 
amended by adding at the end the following: 
‘‘(f) SPECIAL RULE FOR REFINANCED LOANS.— 
‘‘(1) REFINANCED FEDERAL DIRECT AND FFEL 
LOANS.—In calculating the period of time during 
which a borrower of a loan that is reissued under 
section 460A has made monthly payments for pur-
poses of subsection (b)(7), the Secretary shall deem 
the period to include all monthly payments made for 
the original loan, and all monthly payments made 
for the reissued loan, that otherwise meet the re-
quirements of this section. 
‘‘(2) FEDERAL DIRECT REFINANCED PRIVATE 
LOANS.—In calculating the period of time during 
which a borrower of a Federal Direct Refinanced 
Private Loan under section 460B has made monthly 
payments for purposes of subsection (b)(7), the Sec-
retary shall include only payments— 
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‘‘(A) that are made after the date of the 
issuance of the Federal Direct Refinanced Pri-
vate Loan; and 
‘‘(B) that otherwise meet the requirements 
of this section.’’. 
SEC. 3. FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS. 
(a) IN GENERAL.—Subchapter A of chapter 1 of the 
Internal Revenue Code of 1986 is amended by adding at 
the end the following new part: 
‘‘PART VII—FAIR SHARE TAX ON HIGH-INCOME 
TAXPAYERS 
‘‘Sec. 59A. Fair share tax. 
‘‘SEC. 59A. FAIR SHARE TAX. 
‘‘(a) GENERAL RULE.— 
‘‘(1) PHASE-IN OF TAX.—In the case of any 
high-income taxpayer, there is hereby imposed for a 
taxable year (in addition to any other tax imposed 
by this subtitle) a tax equal to the product of— 
‘‘(A) the amount determined under para-
graph (2), and 
‘‘(B) a fraction (not to exceed 1)— 
‘‘(i) the numerator of which is the ex-
cess of— 
‘‘(I) 
the 
taxpayer’s 
adjusted 
gross income, over 
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‘‘(II) the dollar amount in effect 
under subsection (c)(1), and 
‘‘(ii) the denominator of which is the 
dollar amount in effect under subsection 
(c)(1). 
‘‘(2) AMOUNT OF TAX.—The amount of tax de-
termined under this paragraph is an amount equal 
to the excess (if any) of— 
‘‘(A) the tentative fair share tax for the 
taxable year, over 
‘‘(B) the excess of— 
‘‘(i) the sum of— 
‘‘(I) the regular tax liability (as 
defined in section 26(b)) for the tax-
able year, 
‘‘(II) the tax imposed by section 
55 for the taxable year, plus 
‘‘(III) the payroll tax for the tax-
able year, over 
‘‘(ii) the credits allowable under part 
IV of subchapter A (other than sections 
27(a), 31, and 34). 
‘‘(b) TENTATIVE FAIR SHARE TAX.—For purposes 
of this section— 
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‘‘(1) IN GENERAL.—The tentative fair share tax 
for the taxable year is 30 percent of the excess of— 
‘‘(A) the adjusted gross income of the tax-
payer, over 
‘‘(B) the modified charitable contribution 
deduction for the taxable year. 
‘‘(2) MODIFIED
CHARITABLE
CONTRIBUTION 
DEDUCTION.—For purposes of paragraph (1)— 
‘‘(A) IN
GENERAL.—The modified chari-
table contribution deduction for any taxable 
year is an amount equal to the amount which 
bears the same ratio to the deduction allowable 
under section 170 (section 642(c) in the case of 
a trust or estate) for such taxable year as— 
‘‘(i) the amount of itemized deduc-
tions allowable under the regular tax (as 
defined in section 55) for such taxable 
year, determined after the application of 
section 68, bears to 
‘‘(ii) such amount, determined before 
the application of section 68. 
‘‘(B) TAXPAYER
MUST
ITEMIZE.—In the 
case of any individual who does not elect to 
itemize deductions for the taxable year, the 
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modified charitable contribution deduction shall 
be zero. 
‘‘(c) HIGH-INCOME TAXPAYER.—For purposes of this 
section— 
‘‘(1) IN GENERAL.—The term ‘high-income tax-
payer’ means, with respect to any taxable year, any 
taxpayer (other than a corporation) with an adjusted 
gross income for such taxable year in excess of 
$1,000,000 (50 percent of such amount in the case 
of a married individual who files a separate return). 
‘‘(2) INFLATION ADJUSTMENT.— 
‘‘(A) IN GENERAL.—In the case of a tax-
able year beginning after 2016, the $1,000,000 
amount under paragraph (1) shall be increased 
by an amount equal to— 
‘‘(i) such dollar amount, multiplied by 
‘‘(ii) the cost-of-living adjustment de-
termined under section 1(f)(3) for the cal-
endar year in which the taxable year be-
gins, determined by substituting ‘calendar 
year 2015’ for ‘calendar year 1992’ in sub-
paragraph (B) thereof. 
‘‘(B) ROUNDING.—If any amount as ad-
justed under subparagraph (A) is not a multiple 
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of $10,000, such amount shall be rounded to 
the next lowest multiple of $10,000. 
‘‘(d) PAYROLL TAX.—For purposes of this section, 
the payroll tax for any taxable year is an amount equal 
to the excess of— 
‘‘(1) the taxes imposed on the taxpayer under 
sections 1401, 1411, 3101, 3201, and 3211(a) (to 
the extent such taxes are attributable to the rate of 
tax in effect under section 3101) with respect to 
such taxable year or wages or compensation received 
during the taxable year, over 
‘‘(2) the deduction allowable under section 
164(f) for such taxable year. 
‘‘(e) SPECIAL RULE FOR ESTATES AND TRUSTS.— 
For purposes of this section, in the case of an estate or 
trust, adjusted gross income shall be computed in the 
manner described in section 67(e). 
‘‘(f) NOT TREATED AS TAX IMPOSED BY THIS CHAP-
TER FOR CERTAIN PURPOSES.—The tax imposed under 
this section shall not be treated as tax imposed by this 
chapter for purposes of determining the amount of any 
credit under this chapter (other than the credit allowed 
under section 27(a)) or for purposes of section 55.’’. 
(b) CONFORMING AMENDMENT.—Section 26(b)(2) of 
the Internal Revenue Code of 1986 is amended by insert-
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ing after subparagraph (A) the following new subpara-
graph: 
‘‘(B) section 59A (relating to fair share 
tax),’’. 
(c) CLERICAL AMENDMENT.—The table of parts for 
subchapter A of chapter 1 of the Internal Revenue Code 
of 1986 is amended by adding at the end the following 
new item: 
‘‘PART VII—FAIR SHARE TAX ON HIGH-INCOME TAXPAYERS’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
December 31, 2015. 
SEC. 4. DEFICIT NEUTRAL IMPLEMENTATION OF STUDENT 
LOAN REFINANCING PROGRAMS. 
(a) AMOUNT OF REVENUE.—Not later than 1 year 
after the date of enactment of the Fairness in Student 
Loan Lending Act, the Secretary of Education shall esti-
mate the amount that is equal to the amount of the net 
increase in revenue received in the Treasury during the 
10-year period beginning on the date of enactment of the 
Fairness in Student Loan Lending Act attributable to the 
amendments made by section 3 of the Fairness in Student 
Loan Lending Act. 
(b) DEFICIT-NEUTRAL TERMINATION OF THE REFI-
NANCING PROGRAM.—The Secretary of Education shall 
terminate the refinancing programs carried out under sec-
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tions 460A and 460B of the Higher Education Act of 
1965 on the date that the net cost of carrying out such 
refinancing programs is equal to the amount of additional 
revenue estimated under subsection (a). 
(c) METHODOLOGY.—When estimating cost and rev-
enue under this section, the Secretary shall utilize the ac-
counting methods and assumptions that are used by the 
Congressional Budget Office, as of the date of enactment 
of this Act, to make such estimations. 
SEC. 5. UNDUE HARDSHIP EXCEPTIONS TO DISCHARGE. 
Section 523(a)(8) of title 11, United States Code, is 
amended by striking ‘‘dependents, for’’ and all that follows 
through the end of subparagraph (B) and inserting ‘‘de-
pendents, for an educational benefit overpayment or loan 
made, insured, or guaranteed by a governmental unit or 
made under any program funded in whole or in part by 
a governmental unit or an obligation to repay funds re-
ceived from a governmental unit as an educational benefit, 
scholarship, or stipend;’’. 
Æ 
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