I 
116TH CONGRESS 
1ST SESSION H. R. 5523 
To amend the Internal Revenue Code of 1986 to provide investment and 
production tax credits for emerging energy technologies, and for other 
purposes. 
IN THE HOUSE OF REPRESENTATIVES 
DECEMBER 19, 2019 
Mr. REED (for himself, Mr. PANETTA, Mr. LAHOOD, Mr. SUOZZI, Mr. 
GOTTHEIMER, and Mr. SCHWEIKERT) 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 provide 
investment and production tax credits for emerging en-
ergy technologies, 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. 
This Act may be cited as the ‘‘Energy Sector Innova-
tion Credit Act of 2019’’. 
SEC. 2. PURPOSES. 
The energy sector innovation credit is a technology- 
neutral approach that would leverage new private invest-
ment in nascent clean technologies, help cutting-edge tech-
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nologies break into the market, and then naturally 
phasedown as each technology proves commercial viability. 
It could bring about the new technologies needed to quick-
ly and cheaply reduce global emissions. The innovation 
ESIC incentivizes is key to a strong energy supply plus 
will help address the climate and environmental challenge 
of this generation. The United States must lead on clean 
energy technology development. 
SEC. 3. INVESTMENT CREDIT FOR EMERGING ENERGY 
TECHNOLOGY. 
(a) IN GENERAL.—Subpart E of part IV of sub-
chapter A of chapter 1 of the Internal Revenue Code of 
1986 is amended by inserting after section 48C the fol-
lowing new section: 
‘‘SEC. 48D. EMERGING ENERGY TECHNOLOGY CREDIT. 
‘‘(a) IN GENERAL.—For purposes of section 46, the 
emerging energy technology credit for any taxable year is 
an amount equal to 30 percent of the basis of any qualified 
emerging energy property placed in service by the taxpayer 
during such taxable year. 
‘‘(b) CERTAIN QUALIFIED PROGRESS EXPENDITURE 
RULES MADE APPLICABLE.—Rules similar to the rules of 
subsections (c)(4) and (d) of section 46 (as in effect on 
the day before the enactment of the Revenue Reconcili-
ation Act of 1990) shall apply for purposes of this section. 
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‘‘(c) QUALIFIED EMERGING ENERGY PROPERTY.— 
For purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘qualified emerg-
ing energy property’ means property which is con-
structed, reconstructed, erected, or acquired by the 
taxpayer, and the original use of which commences 
with the taxpayer, which is— 
‘‘(A) a qualified production facility (as de-
fined in section 45T(d), determined without re-
gard to paragraph (2) thereof) which is a tier 
1 facility (as defined in section 45T(e)(1)), or 
‘‘(B) property which is placed in service at 
and used in connection with an existing electric 
generating facility which is a point source of air 
pollutants and which, with respect to such facil-
ity— 
‘‘(i) contains equipment which can 
separate and sequester— 
‘‘(I) not less than 60 percent of 
such facility’s maximum hourly car-
bon oxide emission rate, and 
‘‘(II) not less than 100,000 met-
ric tons of qualified carbon oxide (as 
defined in section 45Q(c)) annually, 
and 
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‘‘(ii) places such carbon oxide in se-
cure geological storage (as determined 
under section 45Q(f)(2)). 
‘‘(2) DENIAL
OF
DOUBLE
BENEFIT.—Such 
term shall not include— 
‘‘(A) any property which, 
‘‘(B) property any portion of which, or 
‘‘(C) property placed in service at and used 
in connection with a facility which, 
has been treated as a qualified facility for purposes 
of section 45(d), as an advanced nuclear power facil-
ity for purposes of section 45J, as a qualified facility 
for purposes of section 45Q, as a qualified produc-
tion facility for purposes of section 45T, as energy 
property for purposes of section 48, or as a qualified 
investment for purposes of section 48A, 48B, or 
48C, for any taxable year. 
‘‘(3) POINT SOURCE.—For purposes of para-
graph (1)(B), the term ‘point source’ means a mega-
watt-scale, stationary and non-mobile, identifiable 
source of emissions that releases pollutants into the 
atmosphere. 
‘‘(d) FIRST OF ITS KIND TECHNOLOGY.— 
‘‘(1) IN GENERAL.—In the case of any qualified 
emerging energy property which is the first of its 
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kind, subsection (a) shall be applied by substituting 
‘40’ for ‘30’. 
‘‘(2) FIRST OF ITS KIND.—Property shall be 
treated as the first of its kind if such property is 1 
of the first 3 original demonstrations in the United 
States of a megawatt-scale electric power generation 
facility which generates revenue from sales of elec-
tric power to an unrelated person (within the mean-
ing of section 45(e)(4)). 
‘‘(3) DETERMINATION.— 
‘‘(A) IN GENERAL.—The Secretary, in con-
sultation with the Secretary of Energy, shall de-
velop a process to determine whether qualified 
emerging energy property is first of its kind. 
Such process shall include a certification, at the 
request of the taxpayer before the commence-
ment of construction, that the property will be 
treated as first of its kind. 
‘‘(B) EFFECTIVE
PERIOD
OF
CERTIFI-
CATION.—Except as provided by the Secretary, 
a certification granted under subparagraph (A) 
with respect to any property shall be in effect 
for the period, not to exceed 5 years, beginning 
on the date of the certification and ending on 
the date construction commences with respect 
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to the property. If construction does not com-
mence within the 5-year period beginning on 
the date of the certification, the property shall 
not be treated as first of its kind unless the cer-
tification is renewed. 
‘‘(e) TRANSFER OF CREDIT BY CERTAIN PUBLIC EN-
TITIES.— 
‘‘(1) IN GENERAL.—If, with respect to a credit 
under subsection (a) for any taxable year— 
‘‘(A) a qualified public entity would be the 
taxpayer (but for this paragraph), and 
‘‘(B) such entity elects the application of 
this paragraph for such taxable year with re-
spect to all (or any portion specified in such 
election) of such credit, the eligible project part-
ner specified in such election, and not the quali-
fied public entity, shall be treated as the tax-
payer for purposes of this title with respect to 
such credit (or such portion thereof). 
‘‘(2) DEFINITIONS.—For purposes of this sub-
section— 
‘‘(A) QUALIFIED
PUBLIC
ENTITY.—The 
term ‘qualified public entity’ means— 
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‘‘(i) a Federal, State, or local govern-
ment entity, or any political subdivision, 
agency, or instrumentality thereof, 
‘‘(ii) a mutual or cooperative electric 
company described in section 501(c)(12) or 
1381(a)(2), or 
‘‘(iii) a not-for-profit electric utility 
which had or has received a loan or loan 
guarantee under the Rural Electrification 
Act of 1936. 
‘‘(B) ELIGIBLE PROJECT PARTNER.—The 
term ‘eligible project partner’ means any person 
who— 
‘‘(i) is responsible for, or participates 
in, the design or construction of the quali-
fied emerging energy property to which the 
credit under subsection (a) relates, 
‘‘(ii) is a financial institution pro-
viding financing for the construction or op-
eration of such property (other than fi-
nancing provided in connection with be-
coming eligible for the credit under this 
section by reason of this subsection), or 
‘‘(iii) has an ownership interest in 
such property. 
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‘‘(3) SPECIAL RULES.— 
‘‘(A) APPLICATION TO PARTNERSHIPS.—In 
the case of a credit under subsection (a) which 
is determined at the partnership level— 
‘‘(i) for purposes of paragraph (1)(A), 
a qualified public entity shall be treated as 
the taxpayer with respect to such entity’s 
distributive share of such credit, and 
‘‘(ii) the term ‘eligible project partner’ 
shall include any partner of the partner-
ship. 
‘‘(B) TAXABLE
YEAR
IN
WHICH
CREDIT 
TAKEN
INTO
ACCOUNT.—In the case of any 
credit (or portion thereof) with respect to which 
an election is made under paragraph (1), such 
credit shall be taken into account in the first 
taxable year of the eligible project partner end-
ing with, or after, the qualified public entity’s 
taxable year with respect to which the credit 
was determined. 
‘‘(C) TREATMENT
OF
TRANSFER
UNDER 
PRIVATE USE RULES.—For purposes of section 
141(b)(1), any benefit derived by an eligible 
project partner in connection with an election 
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under this subsection shall not be taken into ac-
count as a private business use. 
‘‘(f) CERTAIN
RULES
NOT
APPLICABLE.—Para-
graphs (3) and (4) of section 50(d) shall not apply for 
purposes of this section.’’. 
(b) SPECIAL RULE FOR PROCEEDS OF TRANSFERS 
FOR MUTUAL OR COOPERATIVE ELECTRIC COMPANIES.— 
Section 501(c)(12)(I) of such Code is amended by insert-
ing ‘‘or 48D(e)’’ after ‘‘section 45J(e)(1)’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 46 of such Code is amended by 
striking ‘‘and’’ at the end of paragraph (5), by strik-
ing the period at the end of paragraph (6) and in-
serting ‘‘, and’’, and by adding at the end the fol-
lowing new paragraph: 
‘‘(7) the emerging energy technology credit.’’. 
(2) Section 49(a)(1)(C) of such Code is amend-
ed by striking ‘‘and’’ at the end of clause (iv), by 
striking the period at the end of clause (v) and in-
serting ‘‘, and’’, and by adding at the end the fol-
lowing new clause: 
‘‘(vi) the basis of any qualified emerg-
ing energy property (as defined in section 
48D(c)(1)).’’. 
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(3) The table of sections for subpart E of part 
IV of subchapter A of chapter 1 of such Code is 
amended by inserting after the item relating to sec-
tion 48C the following new item: 
‘‘Sec. 48D. Emerging energy technology credit.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to property placed in service in 
taxable years beginning after the date of the enactment 
of this Act, under rules similar to the rules of section 
48(m) of the Internal Revenue Code of 1986 (as in effect 
on the day before the date of the enactment of the Rev-
enue Reconciliation Act of 1990). 
SEC. 4. PRODUCTION CREDIT FOR EMERGING ENERGY 
TECHNOLOGY. 
(a) IN GENERAL.—Subpart D of part IV of sub-
chapter A of chapter 1 of the Internal Revenue Code of 
1986 is amended by adding at the end the following new 
section: 
‘‘SEC. 45T. ELECTRICITY PRODUCED FROM EMERGING EN-
ERGY TECHNOLOGY. 
‘‘(a) GENERAL RULE.—For purposes of section 38, 
the emerging energy technology production credit deter-
mined under this section for any taxable year beginning 
in the credit period with respect to a qualified production 
facility of the taxpayer is an amount equal to the applica-
ble percentage of the lesser of— 
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‘‘(1) the annual gross receipts of the taxpayer 
from the sale of electricity generated at the qualified 
production facility to an unrelated person (within 
the meaning of section 45(e)(4)) during such taxable 
year, or 
‘‘(2) the product of— 
‘‘(A) the national average wholesale price 
of a kilowatt hour of electricity in the preceding 
taxable year, as determined by the Secretary in 
consultation with the Administrator of the En-
ergy Information Administration, and 
‘‘(B) the number of kilowatt hours of elec-
tricity produced at the qualified production fa-
cility and sold to an unrelated person (within 
the meaning of section 45(e)(4)) during the tax-
able year. 
‘‘(b) APPLICABLE PERCENTAGE.—For purposes of 
subsection (a), the applicable percentage is— 
‘‘(1) in the case of a tier 1 facility, 60 percent, 
‘‘(2) in the case of a tier 2 facility, 45 percent, 
‘‘(3) in the case of a tier 3 facility, 30 percent, 
and 
‘‘(4) in the case of any other facility, zero per-
cent. 
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‘‘(c) CREDIT PERIOD.—For purposes of this section, 
the credit period with respect to any qualified production 
facility is the 10-year period beginning with the date the 
facility was originally placed in service. 
‘‘(d) QUALIFIED PRODUCTION FACILITY.—For pur-
poses of this section— 
‘‘(1) IN GENERAL.—The term ‘qualified produc-
tion facility’ means any electric generating facility 
which is certified by the Secretary, which is located 
in the United States or a possession of the United 
States (as such terms are used in section 638), and 
which utilizes— 
‘‘(A) any power conversion fuel-based tech-
nology which captures and sequesters at least 
60 percent of the produced carbon oxide, 
‘‘(B) any reactor design licensed by the 
Nuclear Regulatory Commission which produces 
electricity through nuclear fission or a fusion 
chain reaction and which— 
‘‘(i) reduces the high-level radioactive 
waste or spent nuclear fuel per unit of en-
ergy yield, 
‘‘(ii) improves fuel utilization by not 
less than 20 percent, 
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‘‘(iii) decreases core damage frequency 
or large early release frequency by at least 
a factor of 10, or 
‘‘(iv) increases thermal efficiency by 
not less than 20 percent, as compared to 
existing nuclear commercial technologies, 
‘‘(C) any new technology or new improve-
ment to technology which generates electricity 
from renewable energy, as defined in section 
203(b)(2) of the Energy Policy Act of 2005, 
and which generates at least a 20-percent in-
crease in the conversion efficiency or a 20-per-
cent increase in the capacity factor of the facil-
ity as compared with the commercial technology 
of the same type as such technology which is 
considered to be the best of its type in commer-
cial use, 
‘‘(D) technology which the Secretary, in 
consultation with the Secretary of Energy, de-
termines would increase the technical resource 
potential for renewable energy development in 
the United States by at least 500 terawatt 
hours per year, or 
‘‘(E) technology which the Secretary, in 
consultation with the Secretary of Energy, de-
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termines could produce electricity with an emis-
sions rate less than 150g Co2-e per kWh with 
a 75-percent capacity factor. 
‘‘(2) DENIAL
OF
DOUBLE
BENEFIT.—Such 
term shall not include any facility which has been 
treated as a qualified facility for purposes of section 
45(d), as an advanced nuclear power facility for pur-
poses of section 45J, as a qualified facility for pur-
poses of section 45Q, as energy property for pur-
poses of section 48, as a qualified investment for 
purposes of section 48A, 48B, or 48C, or as quali-
fied emerging energy property for purposes of sec-
tion 48D, for any taxable year. 
‘‘(3) Co2-e.—The term ‘Co2-e’ means the quan-
tity of a greenhouse gas that has a global warming 
potential equivalent to 1 metric ton of carbon diox-
ide, as determined under table A–1 of subpart A of 
part 98 of title 40, Code of Federal Regulations, as 
in effect on the date of enactment of this section. 
‘‘(4) CONVERSION
EFFICIENCY.—The term 
‘conversion efficiency’ means the fraction— 
‘‘(A) the numerator of which is the total 
useful electrical or thermal power produced by 
an electric generating facility at normal oper-
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ating rates, and expected to be consumed in its 
normal application, and 
‘‘(B) the denominator of which is the inci-
dent energy, whether mechanical, radiation, or 
thermal energy, which is measurable at the 
input of the electric generating facility. 
‘‘(5) ENERGY EFFICIENCY.—The efficiency of 
an electric generating facility is the fraction— 
‘‘(A) the numerator of which is the total 
useful electrical, thermal, and mechanical power 
which is produced by the facility at normal op-
erating rates and expected to be consumed in 
its normal operation, and 
‘‘(B) the denominator of which is the lower 
heating value of the energy sources for the fa-
cility. 
‘‘(6) PERFORMANCE BASELINE.—Not less fre-
quently than every 10 years, the Secretary, in con-
sultation with the Secretary of Energy, shall estab-
lish baseline levels with respect to the types of elec-
tric generating facilities and the measures of per-
formance described in paragraph (1) which a facility 
must exceed in order to meet the requirements of 
such paragraph. 
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‘‘(7) COMMERCIAL
TECHNOLOGY.—The term 
‘commercial technology’ means a design that has 
been installed in and is being used in 3 or more 
projects in the United States marketplace in the 
same general application as in the electric gener-
ating facility, and has been in such use in at least 
1 of such projects for a period of at least 5 years. 
‘‘(8) CORE
DAMAGE
FREQUENCY.—The term 
‘core damage frequency’ means the likelihood that, 
given the way a reactor is designed and operated, an 
accident could cause the fuel in the reactor to be 
damaged. 
‘‘(9) LARGE
EARLY
RELEASE
FREQUENCY.— 
The term ‘large early release frequency’ means the 
likelihood of a release into the environment of a suf-
ficiently large quantity of fission products in an 
early enough time frame to have the potential for a 
prompt fatality. 
‘‘(10) GROSS RECOVERABLE RESOURCE POTEN-
TIAL.—The term ‘gross recoverable resource poten-
tial’ means the subset of total resource potential for 
any given renewable energy resource within the 
boundaries of the United States economic exclusion 
zone that can be considered theoretically recoverable 
without allowing for common technological con-
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straints that exist as of the most recent date on 
which the Secretary has established baseline levels 
described in paragraph (6). 
‘‘(11) TECHNICAL RESOURCE POTENTIAL.—The 
term ‘technical resource potential’ means the subset 
of gross recoverable resource potential for any given 
renewable energy resource that can be considered re-
coverable under available technological performance 
conditions as of the date of the enactment of this 
section while considering land-use and environmental 
siting constraints. 
‘‘(e) FACILITY TIERS.— 
‘‘(1) TIER 1 FACILITY.—The term ‘tier 1 facil-
ity’ means an electric generating facility using a 
type of technology which accounts for less than 1 
percent of annual domestic electricity production in 
the preceding taxable year, as determined by the 
Secretary on the basis of data reported by the En-
ergy Information Administration. 
‘‘(2) TIER 2 FACILITY.—The term ‘tier 2 facil-
ity’ means an electric generating facility using a 
type of technology which accounts for at least 1 per-
cent but less than 2 percent of annual domestic elec-
tricity production in the preceding taxable year, as 
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determined by the Secretary on the basis of data re-
ported by the Energy Information Administration. 
‘‘(3) TIER 3 FACILITY.—The term ‘tier 3 facil-
ity’ means an electric generating facility using a 
type of technology which accounts for at least 2 per-
cent but less than 3 percent of annual domestic elec-
tricity production in the preceding taxable year, as 
determined by the Secretary on the basis of data re-
ported by the Energy Information Administration. 
‘‘(f) TRANSFER OF CREDIT BY CERTAIN PUBLIC EN-
TITIES.—Rules similar to the rules of subsection (e) of 
section 48D shall apply for purposes of this section. 
‘‘(g) REGULATIONS.— 
‘‘(1) IN GENERAL.—Not later than 1 year after 
the date of the enactment of this section, the Sec-
retary shall prescribe such regulations as may be 
necessary or appropriate to carry out the purposes 
of this section. Such regulations shall include a proc-
ess for making eligibility certifications described in 
subsection (d)(1)(E). 
‘‘(2) CERTIFICATION.—The regulations devel-
oped under paragraph (1) shall include a certifi-
cation process under which the Secretary, in con-
sultation with the Secretary of Energy, determines 
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the eligibility of facilities for purposes of subsection 
(d)(1).’’. 
(b) CREDIT ALLOWED AS PART OF GENERAL BUSI-
NESS CREDIT.—Section 38(b) of the Internal Revenue 
Code of 1986 is amended by striking ‘‘plus’’ at the end 
of paragraph (31), by striking the period at the end of 
paragraph (32) and inserting ‘‘, plus’’, and by adding at 
the end the following new paragraph: 
‘‘(33) the emerging energy technology produc-
tion credit determined under section 45T(a).’’. 
(c) SPECIAL RULE FOR PROCEEDS OF TRANSFERS 
FOR MUTUAL OR COOPERATIVE ELECTRIC COMPANIES.— 
Section 501(c)(12)(I) of such Code, as amended by the 
preceding provisions of this Act, is amended by striking 
‘‘or 48D(e)’’ and inserting ‘‘, 45T(f), or 48D(e)’’. 
(d) CLERICAL AMENDMENT.—The table of sections 
for subpart D of part IV of subchapter A of chapter 1 
of the Internal Revenue Code of 1986 is amended by add-
ing at the end the following new item: 
‘‘Sec. 45T. Electricity produced from emerging energy technology.’’. 
(e) EFFECTIVE DATE.—The amendments made by 
this section shall apply to electricity produced and sold 
in taxable years beginning after the date of the enactment 
of this Act, at facilities placed in service after such date 
of enactment. 
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SEC. 5. ENERGY CREDIT FOR ENERGY STORAGE TECH-
NOLOGIES. 
(a) IN GENERAL.—Section 48(a)(2)(A)(i) of the In-
ternal Revenue Code of 1986 is amended by striking 
‘‘and’’ at the end of subclause (III) and by inserting after 
subclause (IV) the following new subclause: 
‘‘(V) energy property described in 
paragraph (3)(A)(viii), and’’. 
(b) ENERGY
STORAGE
TECHNOLOGIES.—Section 
48(a)(3)(A) of such Code is amended by striking ‘‘or’’ at 
the end of clause (vi), by adding ‘‘or’’ at the end of clause 
(vii), and by adding at the end the following new clause: 
‘‘(viii) 
equipment 
which 
receives, 
stores, and delivers energy using batteries, 
compressed air, pumped hydropower, hy-
drogen storage (including hydrolysis), ther-
mal energy storage, regenerative fuel cells, 
flywheels, 
capacitors, 
superconducting 
magnets, or other technologies identified 
by the Secretary, in consultation with the 
Secretary of Energy,’’. 
(c) NATIONAL LIMITATION RELATING TO ENERGY 
STORAGE PROPERTY.—Section 48(a)(5) of such Code is 
amended by adding at the end the following new subpara-
graph: 
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‘‘(F) NATIONAL LIMITATION RELATING TO 
ENERGY STORAGE PROPERTY.— 
‘‘(i) IN
GENERAL.—The amount of 
credit which (but for this subsection) 
would be allowed with respect to all equip-
ment described in subsection (a)(3)(A)(viii) 
for any taxable year shall not exceed the 
national megawatt capacity limitation for 
energy storage property allocated to the 
project of which such equipment is a part. 
‘‘(ii) AMOUNT OF NATIONAL CREDIT 
LIMITATION.— 
‘‘(I) IN
GENERAL.—The aggre-
gate amount of national megawatt ca-
pacity limitation allocated to projects 
under clause (i) shall not exceed 
20,000 megawatts. 
‘‘(II) LIMITATION
ON
LITHIUM 
ION
ELECTRIC
STORAGE
BAT-
TERIES.—The Secretary shall ensure 
that not more than 15,000 megawatts 
of the national megawatt capacity lim-
itation are allocated to projects for 
lithium ion electric storage batteries, 
in an effort to facilitate the deploy-
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ment of a diverse suite of techno-
logical designs. 
‘‘(iii) ALLOCATION.— 
‘‘(I) ESTABLISHMENT
OF
PRO-
GRAM.—Not later than 180 days after 
the date of enactment of this subpara-
graph, the Secretary, in consultation 
with the Secretary of Energy, shall 
develop a process to allocate national 
megawatt capacity limitation under 
this subparagraph. 
‘‘(II) APPLICATIONS.—Each ap-
plicant for allocations under this sub-
paragraph shall submit an application 
to the Secretary. The Secretary shall 
issue a determination as whether an 
applicant has been allocated national 
megawatt capacity limitation not later 
than 60 days after the date of the 
submission of a completed application 
under this subclause. 
‘‘(III) TIME
LIMIT
ON
BEGIN-
NING
AND
COMPLETING
CONSTRUC-
TION.—An 
allocation 
of 
national 
megawatt capacity limitation under 
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this clause shall be void unless the 
taxpayer begins construction of the 
project not later than the date which 
is 1 year after the date on which such 
allocation is made and completes con-
struction of such project not later 
than the date which 5 years after the 
date on which such construction be-
gins. 
‘‘(IV) REALLOCATION
OF
UN-
USED
LIMITATION.—The 
Secretary 
shall reallocate national megawatt ca-
pacity limitation (and such realloca-
tion shall not be taken into account in 
applying the limitation of clause 
(ii)(I)) to the extent that any alloca-
tion is void under subclause (III) or to 
the extent that the credit attributable 
to such allocation is recaptured under 
section 50(a).’’. 
(d) TRANSFER
OF ENERGY STORAGE PROPERTY 
CREDIT BY CERTAIN PUBLIC ENTITIES.—Section 48 of 
such Code is amended by adding at the end the following 
new subsection: 
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‘‘(e) TRANSFER OF ENERGY STORAGE PROPERTY 
CREDIT BY CERTAIN PUBLIC ENTITIES.—In the case of 
any property described in subsection (a)(3)(A)(viii), rules 
similar to the rules of subsection (e) of section 48D shall 
apply for purposes of this section.’’. 
(e) EFFECTIVE DATE.—The amendments made by 
this section shall apply to property placed in service in 
taxable years beginning after the date of the enactment 
of this Act, under rules similar to the rules of section 
48(m) of the Internal Revenue Code of 1986 (as in effect 
on the day before the date of the enactment of the Rev-
enue Reconciliation Act of 1990). 
Æ 
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