ment or repeal is expressed in terms of an amendment 
to, or repeal of, a section or other provision, the reference 
shall be considered to be made to a section or other provi-
sion of the Internal Revenue Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents of 
this Act is as follows: 
Sec. 1. Short title; etc. 
Sec. 2. Tax benefits for Gulf Oil Spill Recovery Zone. 
Sec. 3. Special extension of bonus depreciation placed in service date for tax-
payers affected by the Gulf Oil Spill. 
Sec. 4. Gulf Coast Recovery Bonds. 
SEC. 2. TAX BENEFITS FOR GULF OIL SPILL RECOVERY 
ZONE. 
(a) IN GENERAL.—Subchapter Y of chapter 1 is 
amended by adding at the end the following new part: 
‘‘PART IV—TAX BENEFITS FOR GULF OIL SPILL 
RECOVERY ZONE 
‘‘Sec. 1400V–1. Gulf Oil Spill Recovery Zone. 
‘‘Sec. 1400V–2. Tax benefits for Gulf Oil Spill Recovery Zone. 
‘‘Sec. 1400V–3. Housing tax benefits. 
‘‘Sec. 1400V–4. Special rules for use of retirement funds. 
‘‘Sec. 1400V–5. Employee Retention Credit for Employers Affected by Gulf Oil 
Spill. 
‘‘Sec. 1400V–6. Additional tax relief provisions. 
‘‘Sec. 1400V–7. Special rules for mortgage revenue bonds. 
‘‘SEC. 1400V–1. GULF OIL SPILL RECOVERY ZONE. 
‘‘For purposes of this part— 
‘‘(1) GULF OIL SPILL RECOVERY ZONE.—The 
term ‘Gulf Oil Spill Recovery Zone’ means the fol-
lowing counties and parishes affected by the Gulf Oil 
Spill: 
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‘‘(A) Terrebone, LaFourche, Jefferson, 
Plaquemines, St. Bernard, Orleans, and St. 
Tammany parishes in the State of Louisiana, 
‘‘(B) Mobile and Baldwin counties in the 
State of Alabama, 
‘‘(C) Hancock, Harrison, and Jackson 
counties in the State of Mississippi, and 
‘‘(D) Escambia, Santa Rosa, Okaloosa, 
Walton, Bay, Holmes, Washington, Gulf, and 
Franklin counties in the State of Florida. 
‘‘(2) GULF
OIL
SPILL.—The term ‘Gulf Oil 
Spill’ means the discharge of oil by reason of the ex-
plosion on, and sinking of, the mobile offshore drill-
ing unit Deepwater Horizon. 
‘‘SEC. 1400V–2. TAX BENEFITS FOR GULF OIL SPILL RECOV-
ERY ZONE. 
‘‘(a) TAX-EXEMPT BOND FINANCING.— 
‘‘(1) IN GENERAL.—For purposes of this title— 
‘‘(A) any qualified Gulf Oil Spill Recovery 
Zone Bond described in paragraph (2)(A)(i) 
shall be treated as an exempt facility bond, and 
‘‘(B) any qualified Gulf Oil Spill Recovery 
Zone Bond described in paragraph (2)(A)(ii) 
shall be treated as a qualified mortgage bond. 
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‘‘(2) QUALIFIED
GULF
OIL
SPILL
RECOVERY 
ZONE BOND.—For purposes of this subsection, the 
term ‘qualified Gulf Oil Spill Recovery Zone Bond’ 
means any bond issued as part of an issue if— 
‘‘(A)(i) 95 percent or more of the net pro-
ceeds (as defined in section 150(a)(3)) of such 
issue are to be used for qualified project costs, 
or 
‘‘(ii) such issue meets the requirements of 
a qualified mortgage issue, except as otherwise 
provided in this subsection, 
‘‘(B) such bond is issued by the State of 
Florida, Alabama, Louisiana, or Mississippi, or 
any political subdivision thereof, 
‘‘(C) such bond is designated for purposes 
of this section by— 
‘‘(i) in the case of a bond which is re-
quired under State law to be approved by 
the bond commission of such State, such 
bond commission, and 
‘‘(ii) in the case of any other bond, 
the Governor of such State, 
‘‘(D) such bond is issued after the date of 
the enactment of this section and before Janu-
ary 1, 2016, and 
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‘‘(E) no portion of the proceeds of such 
issue is to be used to provide any property de-
scribed in section 144(c)(6)(B). 
‘‘(3) LIMITATIONS ON BONDS.— 
‘‘(A) AGGREGATE AMOUNT DESIGNATED.— 
The maximum aggregate face amount of bonds 
which may be designated under this subsection 
with respect to any State shall not exceed the 
product of $2,500 multiplied by the portion of 
the State population which is in the Gulf Oil 
Spill Recovery Zone (as determined on the basis 
of the most recent census estimate of resident 
population released by the Bureau of Census 
before April 20, 2010). 
‘‘(B) MOVABLE
PROPERTY.—No bonds 
shall be issued which are to be used for movable 
fixtures and equipment. 
‘‘(4) QUALIFIED
PROJECT
COSTS.—For pur-
poses of this subsection, the term ‘qualified project 
costs’ means— 
‘‘(A) the cost of any qualified residential 
rental project (as defined in section 142(d)) lo-
cated in the Gulf Oil Spill Recovery Zone, and 
‘‘(B) the cost of acquisition, construction, 
reconstruction, and renovation of— 
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‘‘(i) nonresidential real property (in-
cluding fixed improvements associated with 
such property) located in the Gulf Oil Spill 
Recovery Zone, and 
‘‘(ii) public utility property (as defined 
in section 168(i)(10)) located in the Gulf 
Oil Spill Recovery Zone. 
‘‘(5) SPECIAL RULES.—In applying this title to 
any qualified Gulf Oil Spill Recovery Zone Bond, the 
following modifications shall apply: 
‘‘(A) Section 142(d)(1) (defining qualified 
residential rental project) shall be applied— 
‘‘(i) by substituting ‘60 percent’ for 
‘50 percent’ in subparagraph (A) thereof, 
and 
‘‘(ii) by substituting ‘70 percent’ for 
‘60 percent’ in subparagraph (B) thereof. 
‘‘(B) Section 143 (relating to mortgage 
revenue bonds: qualified mortgage bond and 
qualified veterans’ mortgage bond) shall be ap-
plied— 
‘‘(i) only with respect to owner-occu-
pied residences in the Gulf Oil Spill Recov-
ery Zone, 
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‘‘(ii) by treating any such residence in 
the Gulf Oil Spill Recovery Zone as a tar-
geted area residence, 
‘‘(iii) by applying subsection (f)(3) 
thereof without regard to subparagraph 
(A) thereof, and 
‘‘(iv) by substituting ‘$150,000’ for 
‘$15,000’ in subsection (k)(4) thereof. 
‘‘(C) Except as provided in section 143, re-
payments of principal on financing provided by 
the issue of which such bond is a part may not 
be used to provide financing. 
‘‘(D) Section 146 (relating to volume cap) 
shall not apply. 
‘‘(E) Section 147(d)(2) (relating to acqui-
sition of existing property not permitted) shall 
be applied by substituting ‘50 percent’ for ‘15 
percent’ each place it appears. 
‘‘(F) Section 148(f)(4)(C) (relating to ex-
ception from rebate for certain proceeds to be 
used to finance construction expenditures) shall 
apply to the available construction proceeds of 
bonds which are part of an issue described in 
paragraph (2)(A)(i). 
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‘‘(G) Section 57(a)(5) (relating to tax-ex-
empt interest) shall not apply. 
‘‘(6) SEPARATE
ISSUE
TREATMENT
OF
POR-
TIONS
OF
AN
ISSUE.—This subsection shall not 
apply to the portion of an issue which (if issued as 
a separate issue) would be treated as a qualified 
bond or as a bond that is not a private activity bond 
(determined without regard to paragraph (1)), if the 
issuer elects to so treat such portion. 
‘‘(b) ADVANCE REFUNDINGS OF CERTAIN TAX-EX-
EMPT BONDS.— 
‘‘(1) IN GENERAL.—With respect to a bond de-
scribed in paragraph (3), one additional advance re-
funding after the date of the enactment of this sec-
tion and before January 1, 2016, shall be allowed 
under the applicable rules of section 149(d) if— 
‘‘(A) the Governor of the State designates 
the advance refunding bond for purposes of this 
subsection, and 
‘‘(B) the requirements of paragraph (5) 
are met. 
‘‘(2) CERTAIN
PRIVATE
ACTIVITY
BONDS.— 
With respect to a bond described in paragraph (3) 
which is an exempt facility bond described in para-
graph (1) or (2) of section 142(a), one advance re-
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funding after the date of the enactment of this sec-
tion and before January 1, 2016, shall be allowed 
under the applicable rules of section 149(d) (not-
withstanding paragraph (2) thereof) if the require-
ments of subparagraphs (A) and (B) of paragraph 
(1) are met. 
‘‘(3) BONDS DESCRIBED.—A bond is described 
in this paragraph if such bond was outstanding on 
April 20, 2010, and is issued by the State of Flor-
ida, Alabama, Louisiana, or Mississippi, or a polit-
ical subdivision thereof. 
‘‘(4) AGGREGATE LIMIT.—The maximum aggre-
gate face amount of bonds which may be designated 
under this subsection by the Governor of a State 
shall not exceed— 
‘‘(A) $4,500,000,000 in the case of the 
State of Florida, 
‘‘(B) $4,500,000,000 in the case of the 
State of Louisiana, 
‘‘(C) $4,500,000,000 in the case of the 
State of Mississippi, and 
‘‘(D) $4,500,000,000 in the case of the 
State of Alabama. 
‘‘(5) ADDITIONAL
REQUIREMENTS.—The re-
quirements of this paragraph are met with respect 
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to any advance refunding of a bond described in 
paragraph (3) if— 
‘‘(A) no advance refundings of such bond 
would be allowed under this title on or after 
April 20, 2010, 
‘‘(B) the advance refunding bond is the 
only other outstanding bond with respect to the 
refunded bond, and 
‘‘(C) the requirements of section 148 are 
met with respect to all bonds issued under this 
subsection. 
‘‘(6) USE OF PROCEEDS REQUIREMENT.—This 
subsection shall not apply to any advance refunding 
of a bond which is issued as part of an issue if any 
portion of the proceeds of such issue (or any prior 
issue) was (or is to be) used to provide any property 
described in section 144(c)(6)(B). 
‘‘(c) LOW-INCOME HOUSING CREDIT.— 
‘‘(1) ADDITIONAL
HOUSING
CREDIT
DOLLAR 
AMOUNT FOR GULF OIL SPILL RECOVERY ZONE.— 
‘‘(A) IN GENERAL.—For purposes of sec-
tion 42, in the case of calendar years 2010, 
2011, and 2012, the State housing credit ceil-
ing of each State, any portion of which is lo-
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cated in the Gulf Oil Spill Recovery Zone, shall 
be increased by the lesser of— 
‘‘(i) the aggregate housing credit dol-
lar amount allocated by the State housing 
credit agency of such State to buildings lo-
cated in the Gulf Oil Spill Recovery Zone 
for such calendar year, or 
‘‘(ii) the Gulf Oil Spill Recovery hous-
ing amount for such State for such cal-
endar year. 
‘‘(B) 
GULF
OPPORTUNITY
HOUSING 
AMOUNT.—For purposes of subparagraph (A), 
the term ‘Gulf Oil Spill Recovery housing 
amount’ means, for any calendar year, the 
amount equal to the product of $18.00 multi-
plied by the portion of the State population 
which is in the Gulf Oil Spill Recovery Zone (as 
determined on the basis of the most recent cen-
sus estimate of resident population released by 
the Bureau of Census before April 20, 2010). 
‘‘(C) ALLOCATIONS
TREATED
AS
MADE 
FIRST FROM ADDITIONAL ALLOCATION AMOUNT 
FOR
PURPOSES
OF
DETERMINING
CARRY-
OVER.—For purposes of determining the un-
used State housing credit ceiling under section 
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42(h)(3)(C) for any calendar year, any increase 
in the State housing credit ceiling under sub-
paragraph (A) shall be treated as an amount 
described in clause (ii) of such section. 
‘‘(2) DIFFICULT DEVELOPMENT AREA.— 
‘‘(A) IN GENERAL.—For purposes of sec-
tion 42, in the case of property placed in service 
during 2011, 2012, or 2013, the Gulf Oil Spill 
Recovery Zone— 
‘‘(i) shall be treated as difficult devel-
opment areas designated under subclause 
(I) of section 42(d)(5)(C)(iii), and 
‘‘(ii) shall not be taken into account 
for purposes of applying the limitation 
under subclause (II) of such section. 
‘‘(B) APPLICATION.—Subparagraph (A) 
shall apply only to— 
‘‘(i) housing credit dollar amounts al-
located during the period beginning on 
January 1, 2011, and ending on December 
31, 2013, and 
‘‘(ii) buildings placed in service during 
such period to the extent that paragraph 
(1) of section 42(h) does not apply to any 
building by reason of paragraph (4) there-
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of, but only with respect to bonds issued 
after December 31, 2010. 
‘‘(3) SPECIAL
RULE
FOR
APPLYING
INCOME 
TESTS.—In the case of property placed in service— 
‘‘(A) during 2011, 2012, or 2013, 
‘‘(B) in the Gulf Oil Spill Recovery Zone, 
and 
‘‘(C) in a nonmetropolitan area (as defined 
in section 42(d)(5)(C)(iv)(IV)), 
section 42 shall be applied by substituting ‘national 
nonmetropolitan median gross income (determined 
under rules similar to the rules of section 
142(d)(2)(B))’ for ‘area median gross income’ in 
subparagraphs (A) and (B) of section 42(g)(1). 
‘‘(4) DEFINITIONS.—Any term used in this sub-
section which is also used in section 42 shall have 
the same meaning as when used in such section. 
‘‘(d) SPECIAL ALLOWANCE FOR CERTAIN PROPERTY 
ACQUIRED ON OR AFTER APRIL 20, 2010.— 
‘‘(1) ADDITIONAL ALLOWANCE.—In the case of 
any qualified Gulf Oil Spill Recovery Zone prop-
erty— 
‘‘(A) the depreciation deduction provided 
by section 167(a) for the taxable year in which 
such property is placed in service shall include 
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an allowance equal to 50 percent of the ad-
justed basis of such property, and 
‘‘(B) the adjusted basis of the qualified 
Gulf Oil Spill Recovery Zone property shall be 
reduced by the amount of such deduction before 
computing the amount otherwise allowable as a 
depreciation deduction under this chapter for 
such taxable year and any subsequent taxable 
year. 
‘‘(2) QUALIFIED
GULF
OIL
SPILL
RECOVERY 
ZONE
PROPERTY.—For purposes of this sub-
section— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
Gulf Oil Spill Recovery Zone property’ means 
property— 
‘‘(i)(I) which is described in section 
168(k)(2)(A)(i), or 
‘‘(II) which is nonresidential real 
property or residential rental property, 
‘‘(ii) substantially all of the use of 
which is in the Gulf Oil Spill Recovery 
Zone and is in the active conduct of a 
trade or business by the taxpayer in such 
Zone, 
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‘‘(iii) the original use of which in the 
Gulf Oil Spill Recovery Zone commences 
with the taxpayer on or after April 20, 
2010, 
‘‘(iv) which is acquired by the tax-
payer by purchase (as defined in section 
179(d)) on or after April 20, 2010, but 
only if no written binding contract for the 
acquisition was in effect before April 20, 
2010, and 
‘‘(v) which is placed in service by the 
taxpayer on or before December 31, 2012 
(December 31, 2013, in the case of non-
residential real property and residential 
rental property). 
‘‘(B) EXCEPTIONS.— 
‘‘(i) 
ALTERNATIVE
DEPRECIATION 
PROPERTY.—Such term shall not include 
any 
property 
described 
in 
section 
168(k)(2)(D)(i). 
‘‘(ii) TAX-EXEMPT
BOND-FINANCED 
PROPERTY.—Such term shall not include 
any property any portion of which is fi-
nanced with the proceeds of any obligation 
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the interest on which is exempt from tax 
under section 103. 
‘‘(iii) 
QUALIFIED
REVITALIZATION 
BUILDINGS.—Such term shall not include 
any qualified revitalization building with 
respect to which the taxpayer has elected 
the application of paragraph (1) or (2) of 
section 1400I(a). 
‘‘(iv) ELECTION OUT.—If a taxpayer 
makes an election under this clause with 
respect to any class of property for any 
taxable year, this subsection shall not 
apply to all property in such class placed 
in service during such taxable year. 
‘‘(3) SPECIAL
RULES.—For purposes of this 
subsection, rules similar to the rules of subpara-
graph (E) of section 168(k)(2) shall apply, except 
that such subparagraph shall be applied— 
‘‘(A) by substituting ‘April 20, 2010’ for 
‘December 31, 2007’ each place it appears 
therein, 
‘‘(B) by substituting ‘January 1, 2013’ for 
‘January 1, 2010’ in clause (i) thereof, and 
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‘‘(C) by substituting ‘qualified Gulf Oil 
Spill Recovery Zone property’ for ‘qualified 
property’ in clause (iv) thereof. 
‘‘(4) ALLOWANCE AGAINST ALTERNATIVE MIN-
IMUM TAX.—For purposes of this subsection, rules 
similar to the rules of section 168(k)(2)(G) shall 
apply. 
‘‘(5) RECAPTURE.—For purposes of this sub-
section, rules similar to the rules under section 
179(d)(10) shall apply with respect to any qualified 
Gulf Oil Spill Recovery Zone property which ceases 
to be qualified Gulf Oil Spill Recovery Zone prop-
erty. 
‘‘(e) INCREASE
IN EXPENSING UNDER SECTION 
179.— 
‘‘(1) IN
GENERAL.—For purposes of section 
179— 
‘‘(A) the dollar amount in effect under sec-
tion 179(b)(1) for the taxable year shall be in-
creased by the lesser of— 
‘‘(i) $100,000, or 
‘‘(ii) the cost of qualified section 179 
Gulf Oil Spill Recovery Zone property 
placed in service during the taxable year, 
and 
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‘‘(B) the dollar amount in effect under sec-
tion 179(b)(2) for the taxable year shall be in-
creased by the lesser of— 
‘‘(i) $600,000, or 
‘‘(ii) the cost of qualified section 179 
Gulf Oil Spill Recovery Zone property 
placed in service during the taxable year. 
‘‘(2) QUALIFIED SECTION 179 GULF OIL SPILL 
RECOVERY ZONE PROPERTY.—For purposes of this 
subsection, the term ‘qualified section 179 Gulf Oil 
Spill Recovery Zone property’ means section 179 
property (as defined in section 179(d)) which is 
qualified Gulf Oil Spill Recovery Zone property (as 
defined in subsection (d)(2)). 
‘‘(3) 
COORDINATION
WITH
EMPOWERMENT 
ZONES AND RENEWAL COMMUNITIES.—For purposes 
of sections 1397A and 1400J, qualified section 179 
Gulf Oil Spill Recovery Zone property shall not be 
treated as qualified zone property or qualified re-
newal property, unless the taxpayer elects not to 
take such qualified section 179 Gulf Oil Spill Recov-
ery Zone property into account for purposes of this 
subsection. 
‘‘(4) RECAPTURE.—For purposes of this sub-
section, rules similar to the rules under section 
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179(d)(10) shall apply with respect to any qualified 
section 179 Gulf Oil Spill Recovery Zone property 
which ceases to be qualified section 179 Gulf Oil 
Spill Recovery Zone property. 
‘‘(f) EXPENSING
FOR CERTAIN DEMOLITION
AND 
CLEAN-UP COSTS.— 
‘‘(1) IN GENERAL.—A taxpayer may elect to 
treat 50 percent of any qualified Gulf Oil Spill Re-
covery Zone clean-up cost as an expense which is not 
chargeable to capital account. Any cost so treated 
shall be allowed as a deduction for the taxable year 
in which such cost is paid or incurred. 
‘‘(2) QUALIFIED
GULF
OIL
SPILL
RECOVERY 
ZONE CLEAN-UP COST.—For purposes of this sub-
section, the term ‘qualified Gulf Oil Spill Recovery 
Zone clean-up cost’ means any amount paid or in-
curred during the period beginning on April 20, 
2010, and ending on December 31, 2012, for the re-
moval of debris from, or the demolition of structures 
on, real property which is located in the Gulf Oil 
Spill Recovery Zone and which is— 
‘‘(A) held by the taxpayer for use in a 
trade or business or for the production of in-
come, or 
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‘‘(B) 
property 
described 
in 
section 
1221(a)(1) in the hands of the taxpayer. 
For purposes of the preceding sentence, amounts 
paid or incurred shall be taken into account only to 
the extent that such amount would (but for para-
graph (1)) be chargeable to capital account. 
‘‘(g) EXTENSION
OF EXPENSING
FOR ENVIRON-
MENTAL REMEDIATION COSTS.—With respect to any 
qualified environmental remediation expenditure (as de-
fined in section 198(b)) paid or incurred on or after April 
20, 2010, in connection with a qualified contaminated site 
located in the Gulf Oil Spill Recovery Zone, section 198 
(relating to expensing of environmental remediation costs) 
shall be applied— 
‘‘(1) in the case of expenditures paid or in-
curred on or after April 20, 2010, and before Janu-
ary 1, 2013, by substituting ‘December 31, 2012’ 
for the date contained in section 198(h), and 
‘‘(2) except as provided in section 198(d)(2), by 
treating petroleum products (as defined in section 
4612(a)(3)) as a hazardous substance. 
‘‘(h) INCREASE IN REHABILITATION CREDIT.—In the 
case of qualified rehabilitation expenditures (as defined in 
section 47(c)) paid or incurred during the period begin-
ning on April 20, 2010, and ending on December 31, 
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2013, with respect to any qualified rehabilitated building 
or certified historic structure (as defined in section 47(c)) 
located in the Gulf Oil Spill Recovery Zone, subsection (a) 
of section 47 (relating to rehabilitation credit) shall be ap-
plied— 
‘‘(1) by substituting ‘13 percent’ for ‘10 per-
cent’ in paragraph (1) thereof, and 
‘‘(2) by substituting ‘26 percent’ for ‘20 per-
cent’ in paragraph (2) thereof. 
‘‘(i) TREATMENT OF NET OPERATING LOSSES AT-
TRIBUTABLE
TO GULF OIL SPILL RECOVERY ZONE 
LOSSES.— 
‘‘(1) IN GENERAL.—If a portion of any net op-
erating loss of the taxpayer for any taxable year is 
a qualified Gulf Oil Spill Recovery Zone loss, the fol-
lowing rules shall apply: 
‘‘(A) EXTENSION
OF
CARRYBACK
PE-
RIOD.—Section 172(b)(1) shall be applied with 
respect to such portion— 
‘‘(i) by substituting ‘5 taxable years’ 
for ‘2 taxable years’ in subparagraph 
(A)(i), and 
‘‘(ii) by not taking such portion into 
account in determining any eligible loss of 
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the taxpayer under subparagraph (F) 
thereof for the taxable year. 
‘‘(B) SUSPENSION
OF
PERCENT
AMT 
LIMITATION.—Section 56(d)(1) shall be applied 
by increasing the amount determined under 
subparagraph (A)(ii)(I) thereof by the sum of 
the carrybacks and carryovers of any net oper-
ating loss attributable to such portion. 
‘‘(2) QUALIFIED
GULF
OIL
SPILL
RECOVERY 
ZONE LOSS.—For purposes of paragraph (1), the 
term ‘qualified Gulf Oil Spill Recovery Zone loss’ 
means the lesser of— 
‘‘(A) the excess of— 
‘‘(i) the net operating loss for such 
taxable year, over 
‘‘(ii) the specified liability loss for 
such taxable year to which a 10-year 
carryback 
applies 
under 
section 
172(b)(1)(C), or 
‘‘(B) the aggregate amount of the fol-
lowing deductions to the extent taken into ac-
count in computing the net operating loss for 
such taxable year: 
‘‘(i) Any deduction for any qualified 
Gulf Oil Spill Recovery Zone casualty loss. 
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‘‘(ii) Any deduction for moving ex-
penses paid or incurred after April 19, 
2010, and before January 1, 2014, and al-
lowable under this chapter to any taxpayer 
in connection with the employment of any 
individual— 
‘‘(I) whose principal place of 
abode was located in the Gulf Oil Spill 
Recovery Zone before April 20, 2010, 
‘‘(II) who was unable to remain 
in such abode as the result of the Gulf 
Oil Spill, and 
‘‘(III) whose principal place of 
employment with the taxpayer after 
such expense is located in the Gulf Oil 
Spill Recovery Zone. 
For purposes of this clause, the term ‘mov-
ing expenses’ has the meaning given such 
term by section 217(b), except that the 
taxpayer’s former residence and new resi-
dence may be the same residence if the ini-
tial vacating of the residence was by rea-
son of the Gulf Oil Spill. 
‘‘(iii) Any deduction allowable under 
this chapter for expenses paid or incurred 
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after April 19, 2010, and before January 
1, 2013, to temporarily house any em-
ployee of the taxpayer whose principal 
place of employment is in the Gulf Oil Spill 
Recovery Zone. 
‘‘(iv) Any deduction for depreciation 
(or amortization in lieu of depreciation) al-
lowable under this chapter with respect to 
any qualified Gulf Oil Spill Recovery Zone 
property (as defined in subsection (d)(2), 
but 
without 
regard 
to 
subparagraph 
(B)(iv) thereof)) for the taxable year such 
property is placed in service. 
‘‘(v) Any deduction allowable under 
this chapter for repair expenses (including 
expenses for removal of debris) paid or in-
curred after April 19, 2010, and before 
January 1, 2013, with respect to any dam-
age attributable to the Gulf Oil Spill and 
in connection with property which is lo-
cated in the Gulf Oil Spill Recovery Zone. 
‘‘(3) QUALIFIED
GULF
OIL
SPILL
RECOVERY 
ZONE CASUALTY LOSS.— 
‘‘(A) IN GENERAL.—For purposes of para-
graph (2)(B)(i), the term ‘qualified Gulf Oil 
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Spill Recovery Zone casualty loss’ means any 
uncompensated section 1231 loss (as defined in 
section 1231(a)(3)(B)) of property located in 
the Gulf Oil Spill Recovery Zone if— 
‘‘(i) such loss is allowed as a deduc-
tion under section 165 for the taxable 
year, and 
‘‘(ii) such loss is by reason of the Gulf 
Oil Spill. 
‘‘(B) REDUCTION FOR GAINS FROM INVOL-
UNTARY CONVERSION.—The amount of quali-
fied Gulf Oil Spill Recovery Zone casualty loss 
which would (but for this subparagraph) be 
taken into account under subparagraph (A) for 
any taxable year shall be reduced by the 
amount of any gain recognized by the taxpayer 
for such year from the involuntary conversion 
by reason of the Gulf Oil Spill of property lo-
cated in the Gulf Oil Spill Recovery Zone. 
‘‘(C) COORDINATION WITH GENERAL DIS-
ASTER LOSS RULES.—Subsections (h) and (i) of 
section 165 shall not apply to any qualified 
Gulf Oil Spill Recovery Zone casualty loss to 
the extent such loss is taken into account under 
this subsection. 
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‘‘(4) SPECIAL RULES.—For purposes of para-
graph (1), rules similar to the rules of paragraphs 
(2) and (3) of section 172(i) shall apply with respect 
to such portion. 
‘‘(j) CREDIT TO HOLDERS OF GULF OIL SPILL RE-
COVERY TAX CREDIT BONDS.— 
‘‘(1) ALLOWANCE OF CREDIT.—If a taxpayer 
holds a Gulf Oil Spill Recovery tax credit bond on 
one or more credit allowance dates of the bond oc-
curring during any taxable year, there shall be al-
lowed as a credit against the tax imposed by this 
chapter for the taxable year an amount equal to the 
sum of the credits determined under paragraph (2) 
with respect to such dates. 
‘‘(2) AMOUNT OF CREDIT.— 
‘‘(A) IN
GENERAL.—The amount of the 
credit determined under this paragraph with re-
spect to any credit allowance date for a Gulf Oil 
Spill Recovery tax credit bond is 25 percent of 
the annual credit determined with respect to 
such bond. 
‘‘(B) ANNUAL CREDIT.—The annual credit 
determined with respect to any Gulf Oil Spill 
Recovery tax credit bond is the product of— 
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‘‘(i) the credit rate determined by the 
Secretary under subparagraph (C) for the 
day on which such bond was sold, multi-
plied by 
‘‘(ii) the outstanding face amount of 
the bond. 
‘‘(C) DETERMINATION.—For purposes of 
subparagraph (B), with respect to any Gulf Oil 
Spill Recovery tax credit bond, the Secretary 
shall determine daily or cause to be determined 
daily a credit rate which shall apply to the first 
day on which there is a binding, written con-
tract for the sale or exchange of the bond. The 
credit rate for any day is the credit rate which 
the Secretary or the Secretary’s designee esti-
mates will permit the issuance of Gulf Oil Spill 
Recovery tax credit bonds with a specified ma-
turity or redemption date without discount and 
without interest cost to the issuer. 
‘‘(D) CREDIT
ALLOWANCE
DATE.—For 
purposes of this subsection, the term ‘credit al-
lowance date’ means March 15, June 15, Sep-
tember 15, and December 15. Such term also 
includes the last day on which the bond is out-
standing. 
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‘‘(E) SPECIAL RULE FOR ISSUANCE AND 
REDEMPTION.—In the case of a bond which is 
issued during the 3-month period ending on a 
credit allowance date, the amount of the credit 
determined under this paragraph with respect 
to such credit allowance date shall be a ratable 
portion of the credit otherwise determined 
based on the portion of the 3-month period dur-
ing which the bond is outstanding. A similar 
rule shall apply when the bond is redeemed or 
matures. 
‘‘(3) LIMITATION
BASED
ON
AMOUNT
OF 
TAX.—The credit allowed under paragraph (1) for 
any taxable year shall not exceed the excess of— 
‘‘(A) the sum of the regular tax liability 
(as defined in section 26(b)) plus the tax im-
posed by section 55, over 
‘‘(B) the sum of the credits allowable 
under part IV of subchapter A (other than sub-
part C and this subsection). 
‘‘(4) GULF OIL SPILL RECOVERY TAX CREDIT 
BOND.—For purposes of this subsection— 
‘‘(A) IN
GENERAL.—The term ‘Gulf Oil 
Spill Recovery tax credit bond’ means any bond 
issued as part of an issue if— 
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‘‘(i) the bond is issued by the State of 
Florida, Alabama, Louisiana, or Mis-
sissippi, 
‘‘(ii) 95 percent or more of the pro-
ceeds of such issue are to be used to— 
‘‘(I) pay principal, interest, or 
premiums on qualified bonds issued 
by such State or any political subdivi-
sion of such State, or 
‘‘(II) make a loan to any political 
subdivision of such State to pay prin-
cipal, interest, or premiums on quali-
fied bonds issued by such political 
subdivision, 
‘‘(iii) the Governor of such State des-
ignates such bond for purposes of this sub-
section, 
‘‘(iv) the bond is a general obligation 
of such State and is in registered form 
(within the meaning of section 149(a)), 
‘‘(v) the maturity of such bond does 
not exceed 2 years, and 
‘‘(vi) the bond is issued after Decem-
ber 31, 2010, and before January 1, 2013. 
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‘‘(B) STATE MATCHING REQUIREMENT.—A 
bond shall not be treated as a Gulf Oil Spill Re-
covery tax credit bond unless— 
‘‘(i) the issuer of such bond pledges as 
of the date of the issuance of the issue an 
amount equal to the face amount of such 
bond to be used for payments described in 
subclause (I) of subparagraph (A)(ii), or 
loans described in subclause (II) of such 
subparagraph, as the case may be, with re-
spect to the issue of which such bond is a 
part, and 
‘‘(ii) any such payment or loan is 
made in equal amounts from the proceeds 
of such issue and from the amount pledged 
under clause (i). 
The requirement of clause (ii) shall be treated 
as met with respect to any such payment or 
loan made during the 1-year period beginning 
on the date of the issuance (or any successor 1- 
year period) if such requirement is met when 
applied with respect to the aggregate amount of 
such payments and loans made during such pe-
riod. 
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‘‘(C) AGGREGATE
LIMIT
ON
BOND
DES-
IGNATIONS.—The maximum aggregate face 
amount of bonds which may be designated 
under this subsection by the Governor of a 
State shall not exceed— 
‘‘(i) $200,000,000 in the case of the 
State of Florida, 
‘‘(ii) $200,000,000 in the case of the 
State of Louisiana, 
‘‘(iii) $100,000,000 in the case of the 
State of Mississippi, and 
‘‘(iv) $50,000,000 in the case of the 
State of Alabama. 
‘‘(D) SPECIAL RULES RELATING TO ARBI-
TRAGE.—A bond which is part of an issue shall 
not be treated as a Gulf Oil Spill Recovery tax 
credit bond unless, with respect to the issue of 
which the bond is a part, the issuer satisfies the 
arbitrage requirements of section 148 with re-
spect to proceeds of the issue and any loans 
made with such proceeds. 
‘‘(5) QUALIFIED BOND.—For purposes of this 
subsection— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
bond’ means any obligation of a State or polit-
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ical subdivision thereof which was outstanding 
on April 20, 2010. 
‘‘(B) EXCEPTION FOR PRIVATE ACTIVITY 
BONDS.—Such term shall not include any pri-
vate activity bond. 
‘‘(C) 
EXCEPTION
FOR
ADVANCE 
REFUNDINGS.—Such term shall not include any 
bond with respect to which there is any out-
standing refunded or refunding bond during the 
period in which a Gulf Oil Spill Recovery tax 
credit bond is outstanding with respect to such 
bond. 
‘‘(D) USE OF PROCEEDS REQUIREMENT.— 
Such term shall not include any bond issued as 
part of an issue if any portion of the proceeds 
of such issue was (or is to be) used to provide 
any property described in section 144(c)(6)(B). 
‘‘(6) CREDIT INCLUDED IN GROSS INCOME.— 
Gross income includes the amount of the credit al-
lowed to the taxpayer under this subsection (deter-
mined without regard to paragraph (3)) and the 
amount so included shall be treated as interest in-
come. 
‘‘(7) 
OTHER
DEFINITIONS
AND
SPECIAL 
RULES.—For purposes of this subsection— 
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