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be the lowest percentage specified in paragraph 
(2) of such section. 
‘‘(C) DETERMINATION OF AVERAGE MATU-
RITY.—For purposes of subparagraph (A)(i), 
average maturity shall be determined in accord-
ance with section 147(b)(2)(A).’’. 
(e) CLARIFICATION
RELATED
TO
LEVEES
AND 
FLOOD CONTROL PROJECTS.—Subparagraph (A) of sec-
tion 54AA(g)(2) is amended by inserting ‘‘(including cap-
ital expenditures for levees and other flood control 
projects)’’ after ‘‘capital expenditures’’. 
SEC. 202. EXEMPT-FACILITY BONDS FOR SEWAGE AND 
WATER SUPPLY FACILITIES. 
(a) BONDS FOR WATER AND SEWAGE FACILITIES 
EXEMPT FROM VOLUME CAP
ON PRIVATE ACTIVITY 
BONDS.— 
(1) IN
GENERAL.—Paragraph (3) of section 
146(g) is amended by inserting ‘‘(4), (5),’’ after 
‘‘(2),’’. 
(2) CONFORMING
AMENDMENT.—Paragraphs 
(2) and (3)(B) of section 146(k) are both amended 
by striking ‘‘(4), (5), (6),’’ and inserting ‘‘(6)’’. 
(b) TAX-EXEMPT ISSUANCE BY INDIAN TRIBAL GOV-
ERNMENTS.— 
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(1) IN
GENERAL.—Subsection (c) of section 
7871 is amended by adding at the end the following 
new paragraph: 
‘‘(4) EXCEPTION FOR BONDS FOR WATER AND 
SEWAGE FACILITIES.—Paragraph (2) shall not apply 
to an exempt facility bond 95 percent or more of the 
net proceeds (as defined in section 150(a)(3)) of 
which are to be used to provide facilities described 
in paragraph (4) or (5) of section 142(a).’’. 
(2) CONFORMING AMENDMENT.—Paragraph (2) 
of section 7871(c) is amended by striking ‘‘para-
graph (3)’’ and inserting ‘‘paragraphs (3) and (4)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to obligations issued after the date 
of the enactment of this Act. 
SEC. 203. EXTENSION OF EXEMPTION FROM ALTERNATIVE 
MINIMUM TAX TREATMENT FOR CERTAIN 
TAX-EXEMPT BONDS. 
(a) IN GENERAL.—Clause (vi) of section 57(a)(5)(C) 
is amended— 
(1) by striking ‘‘January 1, 2011’’ in subclause 
(I) and inserting ‘‘January 1, 2012’’; and 
(2) by striking ‘‘AND 2010’’ in the heading and 
inserting ‘‘, 2010, AND 2011’’. 
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(b) ADJUSTED CURRENT EARNINGS.—Clause (iv) of 
section 56(g)(4)(B) is amended— 
(1) by striking ‘‘January 1, 2011’’ in subclause 
(I) and inserting ‘‘January 1, 2012’’; and 
(2) by striking ‘‘AND 2010’’ in the heading and 
inserting ‘‘, 2010, AND 2011’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to obligations issued after Decem-
ber 31, 2010. 
SEC. 204. ELECTIVE PAYMENTS IN LIEU OF LOW INCOME 
HOUSING CREDITS. 
(a) IN GENERAL.—Chapter 65 (relating to abate-
ments, credits, and refunds) is amended by adding at the 
end the following new subchapter: 
‘‘Subchapter C—Direct Payment Provisions 
‘‘Sec. 6451. Elective payments in lieu of low income housing credit for bond- 
financed buildings. 
‘‘SEC. 6451. ELECTIVE PAYMENTS IN LIEU OF LOW INCOME 
HOUSING 
CREDIT 
FOR 
BOND-FINANCED 
BUILDINGS. 
‘‘(a) IN GENERAL.—Any person making an election 
under this section with respect to any qualified bond-fi-
nanced low-income building originally placed in service by 
such person during the taxable year shall be treated as 
making a payment, against the tax imposed by subtitle 
A for the taxable year, equal to the direct payment amount 
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with respect to such building. Such payment shall be treat-
ed as made on the later of the due date of the return of 
such tax or the date on which such return is filed. 
‘‘(b) 
QUALIFIED
BOND-FINANCED
LOW-INCOME 
BUILDING.—For purposes of this section, the term ‘quali-
fied bond-financed low-income building’ means any quali-
fied low-income building to which paragraph (1) of section 
42(h) does not apply by reason of paragraph (4)(B) of 
such section. 
‘‘(c) DIRECT PAYMENT AMOUNT.—For purposes of 
this section, the term ‘direct payment amount’ means, 
with respect to any building, 25.5 percent of the qualified 
basis of such building. 
‘‘(d) SPECIAL
RULES
FOR
CERTAIN
NON-TAX-
PAYERS.— 
‘‘(1) DENIAL
OF
PAYMENT.—Subsection (a) 
shall not apply with respect to any building placed 
in service by— 
‘‘(A) any governmental entity, or 
‘‘(B) any organization described in section 
501(c) or 401(a) and exempt from tax under 
section 501(a). 
‘‘(2) SPECIAL RULES FOR PARTNERSHIPS AND 
S CORPORATIONS.—In the case of property originally 
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placed in service by a partnership or an S corpora-
tion— 
‘‘(A) the election under subsection (a) may 
be made only by such partnership or S corpora-
tion, 
‘‘(B) such partnership or S corporation 
shall be treated as making the payment referred 
to in subsection (a) only to the extent of the 
proportionate share of such partnership or S 
corporation as is owned by persons who would 
be treated as making such payment if the build-
ing were placed in service by such persons, and 
‘‘(C) the return required to be made by 
such partnership or S corporation under section 
6031 or 6037 (as the case may be) shall be 
treated as a return of tax for purposes of sub-
section (a). 
For purposes of subparagraph (B), rules similar to the 
rules of section 168(h)(6) (other than subparagraph (F) 
thereof) shall apply. 
‘‘(e) COORDINATION WITH LOW INCOME HOUSING 
CREDIT.—In the case of any property with respect to 
which an election is made under this section, no credit 
shall be determined under section 42 with respect to such 
building for any taxable year. 
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‘‘(f) OTHER DEFINITIONS AND SPECIAL RULES.— 
For purposes of this section— 
‘‘(1) OTHER DEFINITIONS.—Terms used in this 
section which are also used in section 42 shall have 
the same meaning for purposes of this section as 
when used in such section. 
‘‘(2) APPLICATION
OF
RECAPTURE
RULES, 
ETC.—Except as otherwise provided by the Sec-
retary, rules similar to the rules of section 42 shall 
apply, including the recapture rules of section 42(j). 
‘‘(3) PROVISION OF INFORMATION.—A person 
shall not be treated as having elected the application 
of this section unless the taxpayer provides such in-
formation as the Secretary may require for purposes 
of verifying the proper amount to be treated as a 
payment under subsection (a) and evaluating the ef-
fectiveness of this section. 
‘‘(4) EXCLUSION FROM GROSS INCOME.—Any 
credit or refund allowed or made by reason of this 
section shall not be includible in gross income or al-
ternative minimum taxable income. 
‘‘(g) TERMINATION.—Subsection (a) shall not apply 
with respect to any building placed in service during a tax-
able year beginning after December 31, 2010.’’. 
(b) CONFORMING AMENDMENTS.— 
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(1) Subparagraph (A) of section 6211(b)(4) is 
amended by inserting ‘‘and subchapter C of chapter 
65 (including any payment treated as made under 
such subchapter)’’ after ‘‘6431’’. 
(2) Subparagraph (B) of section 6425(c)(1) is 
amended— 
(A) by striking ‘‘the credits’’ and inserting 
‘‘the sum of— 
‘‘(i) the credits’’; 
(B) by striking the period at the end of 
clause (i) thereof (as amended by this para-
graph) and inserting ‘‘, plus’’; and 
(C) by adding at the end the following new 
clause: 
‘‘(ii) the credits allowed (and pay-
ments treated as made) under subchapter 
C.’’. 
(3) Paragraph (3) of section 6654(f) is amend-
ed— 
(A) by striking ‘‘the credits’’ and inserting 
‘‘the sum of— 
‘‘(A) the credits’’; 
(B) by striking the period at the end of 
subparagraph (A) thereof (as amended by this 
paragraph) and inserting ‘‘, and’’; and 
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(C) by adding at the end the following new 
subparagraph: 
‘‘(B) the credits allowed (and payments 
treated as made) under subchapter C of chapter 
65.’’. 
(4) Subparagraph (B) of section 6655(g)(1) is 
amended— 
(A) by striking ‘‘the credits’’ and inserting 
‘‘the sum of— 
‘‘(i) the credits’’; 
(B) by striking the period at the end of 
clause (i) thereof (as amended by this para-
graph) and inserting ‘‘, plus’’; and 
(C) by adding at the end the following new 
clause: 
‘‘(ii) the credits allowed (and pay-
ments treated as made) under subchapter 
C of chapter 65.’’. 
(5) Paragraph (2) of section 1324(b) of title 
31, United States Code, is amended by inserting ‘‘, 
or from the provisions of subchapter C of chapter 65 
of such Code’’ before the period at the end. 
(6) The table of subchapters for chapter 65 is 
amended by adding at the end the following new 
item: 
SUBCHAPTER C. DIRECT PAYMENT PROVISIONS 
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(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to buildings placed in service after 
the date of the enactment of this Act. 
SEC. 205. EXTENSION AND ADDITIONAL ALLOCATIONS OF 
RECOVERY ZONE BOND AUTHORITY. 
(a) EXTENSION OF RECOVERY ZONE BOND AUTHOR-
ITY.—Section 
1400U–2(b)(1) 
and 
section 
1400U– 
3(b)(1)(B) are each amended by striking ‘‘January 1, 
2011’’ and inserting ‘‘January 1, 2012’’. 
(b) ADDITIONAL ALLOCATIONS OF RECOVERY ZONE 
BOND AUTHORITY BASED ON UNEMPLOYMENT.—Section 
1400U–1 is amended by adding at the end the following 
new subsection: 
‘‘(c) ALLOCATION OF 2010 RECOVERY ZONE BOND 
LIMITATIONS BASED ON UNEMPLOYMENT.— 
‘‘(1) IN GENERAL.—The Secretary shall allo-
cate the 2010 national recovery zone economic devel-
opment bond limitation and the 2010 national recov-
ery zone facility bond limitation among the States in 
the proportion that each such State’s 2009 unem-
ployment number bears to the aggregate of the 2009 
unemployment numbers for all of the States. 
‘‘(2) MINIMUM
ALLOCATION.—The Secretary 
shall adjust the allocations under paragraph (1) for 
each State to the extent necessary to ensure that no 
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State (prior to any reduction under paragraph (3)) 
receives less than 0.9 percent of the 2010 national 
recovery zone economic development bond limitation 
and 0.9 percent of the 2010 national recovery zone 
facility bond limitation. 
‘‘(3) ALLOCATIONS BY STATES.— 
‘‘(A) IN GENERAL.—Each State with re-
spect to which an allocation is made under 
paragraph (1) shall reallocate such allocation 
among the counties and large municipalities (as 
defined in subsection (a)(3)(B)) in such State 
in the proportion that each such county’s or 
municipality’s 2009 unemployment number 
bears to the aggregate of the 2009 unemploy-
ment numbers for all the counties and large 
municipalities (as so defined) in such State. 
‘‘(B) 2010 
ALLOCATION
REDUCED
BY 
AMOUNT
OF
PREVIOUS
ALLOCATION.—Each 
State shall reduce (but not below zero)— 
‘‘(i) the amount of the 2010 national 
recovery zone economic development bond 
limitation allocated to each county or large 
municipality (as so defined) in such State 
by the amount of the national recovery 
zone economic development bond limitation 
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allocated to such county or large munici-
pality under subsection (a)(3)(A) (deter-
mined without regard to any waiver there-
of), and 
‘‘(ii) the amount of the 2010 national 
recovery zone facility bond limitation allo-
cated to each county or large municipality 
(as so defined) in such State by the 
amount of the national recovery zone facil-
ity bond limitation allocated to such county 
or large municipality under subsection 
(a)(3)(A) (determined without regard to 
any waiver thereof). 
‘‘(C) WAIVER
OF
SUBALLOCATIONS.—A 
county or municipality may waive any portion 
of an allocation made under this paragraph. A 
State may by law treat a county or municipality 
as waiving any portion of an allocation made 
under this paragraph if there is a reasonable 
expectation that such allocation would not oth-
erwise be used. 
‘‘(D) SPECIAL RULE FOR A MUNICIPALITY 
IN A COUNTY.—In the case of any large munici-
pality any portion of which is in a county, such 
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(c) AUTHORITY OF STATE TO WAIVE CERTAIN 2009 
ALLOCATIONS.—Subparagraph (A) of section 1400U– 
1(a)(3) is amended by adding at the end the following: 
‘‘A State may by law treat a county or municipality as 
waiving any portion of an allocation made under this sub-
paragraph if there is a reasonable expectation that such 
allocation would not otherwise be used.’’. 
SEC. 206. ALLOWANCE OF NEW MARKETS TAX CREDIT 
AGAINST ALTERNATIVE MINIMUM TAX. 
(a) IN GENERAL.—Subparagraph (B) of section 
38(c)(4) is amended by redesignating clauses (v) through 
(viii) as clauses (vi) through (ix), respectively, and by in-
serting after clause (iv) the following new clause: 
‘‘(v) the credit determined under sec-
tion 45D, but only with respect to credits 
determined with respect to qualified equity 
investments (as defined in section 45D(b)) 
initially made before January 1, 2012,’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to qualified equity investments (as 
defined in section 45D(b) of the Internal Revenue Code 
of 1986) initially made after March 15, 2010. 
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TITLE III—REVENUE 
PROVISIONS 
SEC. 301. LIMITATION ON TREATY BENEFITS FOR CERTAIN 
DEDUCTIBLE PAYMENTS. 
(a) IN GENERAL.—Section 894 (relating to income 
affected by treaty) is amended by adding at the end the 
following new subsection: 
‘‘(d) LIMITATION ON TREATY BENEFITS FOR CER-
TAIN DEDUCTIBLE PAYMENTS.— 
‘‘(1) IN GENERAL.—In the case of any deduct-
ible related-party payment, any withholding tax im-
posed under chapter 3 (and any tax imposed under 
subpart A or B of this part) with respect to such 
payment may not be reduced under any treaty of the 
United States unless any such withholding tax would 
be reduced under a treaty of the United States if 
such payment were made directly to the foreign par-
ent corporation. 
‘‘(2) 
DEDUCTIBLE
RELATED-PARTY
PAY-
MENT.—For purposes of this subsection, the term 
‘deductible related-party payment’ means any pay-
ment made, directly or indirectly, by any person to 
any other person if the payment is allowable as a de-
duction under this chapter and both persons are 
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members of the same foreign controlled group of en-
tities. 
‘‘(3) FOREIGN CONTROLLED GROUP OF ENTI-
TIES.—For purposes of this subsection— 
‘‘(A) IN
GENERAL.—The term ‘foreign 
controlled group of entities’ means a controlled 
group of entities the common parent of which 
is a foreign corporation. 
‘‘(B) CONTROLLED GROUP OF ENTITIES.— 
The term ‘controlled group of entities’ means a 
controlled group of corporations as defined in 
section 1563(a)(1), except that— 
‘‘(i) ‘more than 50 percent’ shall be 
substituted for ‘at least 80 percent’ each 
place it appears therein, and 
‘‘(ii) the determination shall be made 
without regard to subsections (a)(4) and 
(b)(2) of section 1563. 
A partnership or any other entity (other than a 
corporation) shall be treated as a member of a 
controlled group of entities if such entity is con-
trolled 
(within 
the 
meaning 
of 
section 
954(d)(3)) by members of such group (includ-
ing any entity treated as a member of such 
group by reason of this sentence). 
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‘‘(4) FOREIGN
PARENT
CORPORATION.—For 
purposes of this subsection, the term ‘foreign parent 
corporation’ means, with respect to any deductible 
related-party payment, the common parent of the 
foreign controlled group of entities referred to in 
paragraph (3)(A). 
‘‘(5) REGULATIONS.—The Secretary may pre-
scribe such regulations or other guidance as are nec-
essary or appropriate to carry out the purposes of 
this subsection, including regulations or other guid-
ance which provide for— 
‘‘(A) the treatment of two or more persons 
as members of a foreign controlled group of en-
tities if such persons would be the common par-
ent of such group if treated as one corporation, 
and 
‘‘(B) the treatment of any member of a 
foreign controlled group of entities as the com-
mon parent of such group if such treatment is 
appropriate taking into account the economic 
relationships among such entities.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to payments made after the date 
of the enactment of this Act. 
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SEC. 302. TREATMENT OF SECURITIES OF A CONTROLLED 
CORPORATION EXCHANGED FOR ASSETS IN 
CERTAIN REORGANIZATIONS. 
(a) IN GENERAL.—Section 361 (relating to non-
recognition of gain or loss to corporations; treatment of 
distributions) is amended by adding at the end the fol-
lowing new subsection: 
‘‘(d) SPECIAL RULES FOR TRANSACTIONS INVOLVING 
SECTION 355 DISTRIBUTIONS.—In the case of a reorga-
nization described in section 368(a)(1)(D) with respect to 
which stock or securities of the corporation to which the 
assets are transferred are distributed in a transaction 
which qualifies under section 355— 
‘‘(1) this section shall be applied by substituting 
‘stock other than nonqualified preferred stock (as 
defined in section 351(g)(2))’ for ‘stock or securities’ 
in subsections (a) and (b)(1), and 
‘‘(2) the first sentence of subsection (b)(3) shall 
apply only to the extent that the sum of the money 
and the fair market value of the other property 
transferred to such creditors does not exceed the ad-
justed bases of such assets transferred (reduced by 
the amount of the liabilities assumed (within the 
meaning of section 357(c))).’’. 
(b) CONFORMING AMENDMENT.—Paragraph (3) of 
section 361(b) is amended by striking the last sentence. 
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(c) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section 
shall apply to exchanges after the date of the enact-
ment of this Act. 
(2) 
TRANSITION
RULE.—The 
amendments 
made by this section shall not apply to any exchange 
pursuant to a transaction which is— 
(A) made pursuant to an agreement which 
was binding on March 15, 2010, and at all 
times thereafter; 
(B) described in a ruling request submitted 
to the Internal Revenue Service on or before 
such date; or 
(C) described on or before such date in a 
public announcement or in a filing with the Se-
curities and Exchange Commission. 
SEC. 303. REPEAL OF SPECIAL RULES FOR INTEREST AND 
DIVIDENDS RECEIVED FROM PERSONS MEET-
ING THE 80-PERCENT FOREIGN BUSINESS RE-
QUIREMENTS. 
(a) REPEAL OF SPECIAL RULE TREATING INTEREST 
AS UNITED STATES SOURCE.—Paragraph (1) of section 
861(a) is amended by striking subparagraph (A) and by 
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redesignating subparagraphs (B) and (C) as subpara-
graphs (A) and (B), respectively. 
(b) REPEAL OF EXCEPTION TO TAX ON DIVIDENDS 
RECEIVED BY NONRESIDENT ALIENS.—Paragraph (2) of 
section 871(i) is amended by striking subparagraph (B) 
and by redesignating subparagraphs (C) and (D) as sub-
paragraphs (B) and (C), respectively. 
(c) CONFORMING AMENDMENTS.— 
(1) Section 861 is amended by striking sub-
section (c) and by redesignating subsections (d), (e), 
and (f) as subsections (c), (d), and (e), respectively. 
(2) Paragraph (9) of section 904(h) is amended 
to read as follows: 
‘‘(9) TREATMENT OF CERTAIN DOMESTIC COR-
PORATIONS.—In the case of any dividend treated as 
not from sources with the United States under sec-
tion 861(a)(2)(A), the corporation paying such divi-
dend shall be treated for purposes of this subsection 
as a United States-owned foreign corporation.’’. 
(3) Subsection (c) of section 2104 is amended 
in the last sentence by striking ‘‘or to a debt obliga-
tion of a domestic corporation’’ and all that follows 
and inserting a period. 
(d) EFFECTIVE DATE.— 
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(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section 
shall apply to taxable years beginning after Decem-
ber 31, 2010. 
(2) GRANDFATHER
RULE
FOR
OUTSTANDING 
DEBT OBLIGATIONS.— 
(A) IN GENERAL.—The amendments made 
by this section shall not apply to payments of 
interest on obligations issued before the date of 
the enactment of this Act. 
(B) EXCEPTION
FOR
RELATED
PARTY 
DEBT.—Subparagraph (A) shall not apply to 
any interest which is payable to a related per-
son (determined under rules similar to the rules 
of section 954(d)(3)). 
(C) SIGNIFICANT MODIFICATIONS TREAT-
ED AS NEW ISSUES.—For purposes of subpara-
graph (A), a significant modification of the 
terms of any obligation (including any extension 
of the term of such obligation) shall be treated 
as a new issue. 
SEC. 304. INFORMATION REPORTING FOR RENTAL PROP-
ERTY EXPENSE PAYMENTS. 
(a) IN GENERAL.—Section 6041 is amended by add-
ing at the end the following new subsection: 
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‘‘(h) TREATMENT OF RENTAL PROPERTY EXPENSE 
PAYMENTS.— 
‘‘(1) IN GENERAL.—For purposes of subsection 
(a), a person receiving rental income from real es-
tate (other than a qualified residence) shall be con-
sidered to be engaged in a trade or business of rent-
ing property. 
‘‘(2) QUALIFIED RESIDENCE.—For purposes of 
paragraph (1), the term ‘qualified residence’ 
means— 
‘‘(A) the principal residence (within the 
meaning of section 121) of the taxpayer, and 
‘‘(B) 1 other residence of the taxpayer 
which is selected by the taxpayer for purposes 
of this subsection for the taxable year and 
which is used by the taxpayer as a residence 
(within the meaning of section 280A(d)(1)).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to payments made after December 
31, 2010. 
SEC. 305. APPLICATION OF LEVY TO PAYMENTS TO FED-
ERAL VENDORS RELATING TO PROPERTY. 
(a) IN GENERAL.—Section 6331(h)(3) is amended by 
striking ‘‘goods or services’’ and inserting ‘‘property, 
goods, or services’’. 
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(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to levies approved after the date 
of the enactment of this Act. 
SEC. 306. APPLICATION OF CONTINUOUS LEVY TO TAX LI-
ABILITIES OF CERTAIN FEDERAL CONTRAC-
TORS. 
(a) IN GENERAL.—Subsection (f) of section 6330 is 
amended by striking ‘‘or’’ at the end of paragraph (2), 
by inserting ‘‘or’’ at the end of paragraph (3), and by in-
serting after paragraph (3) the following new paragraph: 
‘‘(4) the Secretary has served a Federal con-
tractor levy,’’. 
(b) FEDERAL CONTRACTOR LEVY.—Subsection (h) 
of section 6330 is amended— 
(1) by striking all that precedes ‘‘any levy in 
connection with the collection’’ and inserting the fol-
lowing: 
‘‘(h) DEFINITIONS RELATED TO EXCEPTIONS.—For 
purposes of subsection (f)— 
‘‘(1) DISQUALIFIED EMPLOYMENT TAX LEVY.— 
A disqualified employment tax levy is’’; and 
(2) by adding at the end the following new 
paragraph: 
‘‘(2) FEDERAL CONTRACTOR LEVY.—A Federal 
contractor levy is any levy if the person whose prop-
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erty is subject to the levy (or any predecessor there-
of) is a Federal contractor.’’. 
(c) CONFORMING AMENDMENT.—The heading of 
subsection (f) of section 6330 is amended by striking 
‘‘JEOPARDY AND STATE REFUND COLLECTION’’ and in-
serting ‘‘EXCEPTIONS’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to levies issued after December 31, 
2010. 
SEC. 307. 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: 
‘‘(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: 
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‘‘(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 
greater than zero determined as of the time of 
the transfer.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to transfers made after the date 
of the enactment of this Act. 
SEC. 308. INCREASE IN INFORMATION RETURN PENALTIES. 
(a) FAILURE TO FILE CORRECT INFORMATION RE-
TURNS.— 
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(1) 
IN
GENERAL.—Subsections 
(a)(1), 
(b)(1)(A), and (b)(2)(A) of section 6721 are each 
amended by striking ‘‘$50’’ and inserting ‘‘$100’’. 
(2) AGGREGATE
ANNUAL
LIMITATION.—Sub-
sections (a)(1), (d)(1)(A), and (e)(3)(A) of section 
6721 are each amended by striking ‘‘$250,000’’ and 
inserting ‘‘$1,500,000’’. 
(b) REDUCTION WHERE CORRECTION WITHIN 30 
DAYS.— 
(1) IN GENERAL.—Subparagraph (A) of section 
6721(b)(1) is amended by striking ‘‘$15’’ and insert-
ing ‘‘$30’’. 
(2) AGGREGATE
ANNUAL
LIMITATION.—Sub-
sections (b)(1)(B) and (d)(1)(B) of section 6721 are 
each amended by striking ‘‘$75,000’’ and inserting 
‘‘$250,000’’. 
(c) REDUCTION WHERE CORRECTION ON OR BEFORE 
AUGUST 1.— 
(1) IN GENERAL.—Subparagraph (A) of section 
6721(b)(2) is amended by striking ‘‘$30’’ and insert-
ing ‘‘$60’’. 
(2) AGGREGATE
ANNUAL
LIMITATION.—Sub-
sections (b)(2)(B) and (d)(1)(C) of section 6721 are 
each amended by striking ‘‘$150,000’’ and inserting 
‘‘$500,000’’. 
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(d) AGGREGATE ANNUAL LIMITATIONS FOR PER-
SONS WITH GROSS RECEIPTS
OF NOT MORE THAN 
$5,000,000.—Paragraph (1) of section 6721(d) is amend-
ed— 
(1) by striking ‘‘$100,000’’ in subparagraph 
(A) and inserting ‘‘$500,000’’; 
(2) by striking ‘‘$25,000’’ in subparagraph (B) 
and inserting ‘‘$75,000’’; and 
(3) by striking ‘‘$50,000’’ in subparagraph (C) 
and inserting ‘‘$200,000’’. 
(e) PENALTY
IN
CASE
OF
INTENTIONAL
DIS-
REGARD.—Paragraph (2) of section 6721(e) is amended 
by striking ‘‘$100’’ and inserting ‘‘$250’’. 
(f) ADJUSTMENT FOR INFLATION.—Section 6721 is 
amended by adding at the end the following new sub-
section: 
‘‘(f) ADJUSTMENT FOR INFLATION.— 
‘‘(1) IN
GENERAL.—For each fifth calendar 
year beginning after 2012, each of the dollar 
amounts under subsections (a), (b), (d) (other than 
paragraph (2)(A) thereof), and (e) shall be increased 
by such dollar amount multiplied by the cost-of-liv-
ing adjustment determined under section 1(f)(3) de-
termined by substituting ‘calendar year 2011’ for 
‘calendar year 1992’ in subparagraph (B) thereof. 
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‘‘(2) ROUNDING.—If any amount adjusted 
under paragraph (1)— 
‘‘(A) is not less than $75,000 and is not 
a multiple of $500, such amount shall be 
rounded to the next lowest multiple of $500, 
and 
‘‘(B) is not described in subparagraph (A) 
and is not a multiple of $10, such amount shall 
be rounded to the next lowest multiple of $10.’’. 
(g) EFFECTIVE DATE.—The amendments made by 
this section shall apply with respect to information returns 
required to be filed on or after January 1, 2011. 
SEC. 309. CRUDE TALL OIL INELIGIBLE FOR CELLULOSIC 
BIOFUEL PRODUCER CREDIT. 
(a) IN GENERAL.—Section 40(B)(6)(E) of the Inter-
nal Revenue Code of 1986 is amended by adding at the 
end the following new clause: 
‘‘(iv) EXCLUSION OF CERTAIN PROC-
ESSED
FUELS
WITH
A
HIGH
ACID
CON-
TENT.—The term ‘cellulosic biofuel’ shall 
not include any processed fuel with an acid 
number greater than 25. For purposes of 
the preceding sentence, the term ‘processed 
fuel’ means any fuel other than a fuel— 
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‘‘(I) more than 4 percent of 
which (determined by weight) is any 
combination of water and sediment, or 
‘‘(II) the ash content of which is 
more than 1 percent (determined by 
weight).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to fuels sold or used on or after 
January 1, 2010. 
SEC. 310. TIME FOR PAYMENT OF CORPORATE ESTIMATED 
TAXES. 
(a) SHIFT FROM 2015 TO 2014.—The percentage 
under paragraph (1) of section 202(b) of the Corporate 
Estimated Tax Shift Act of 2009 in effect on the date 
of the enactment of this Act is increased by 4.5 percentage 
points. 
(b) SHIFT FROM 2016 TO 2015.—The percentage 
under paragraph (2) of section 561 of the Hiring Incen-
tives to Restore Employment Act in effect on the date of 
the enactment of this Act is increased by 3.5 percentage 
points. 
(c) SHIFT FROM 2020 TO 2019.—The percentage 
under paragraph (3) of section 561 of the Hiring Incen-
tives to Restore Employment Act in effect on the date of 
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the enactment of this Act is increased by 1.25 percentage 
points. 
TITLE IV—EXTENSION OF EMER-
GENCY CONTINGENCY FUND 
FOR STATE TEMPORARY AS-
SISTANCE FOR NEEDY FAMI-
LIES PROGRAMS 
SEC. 401. ONE-YEAR EXTENSION OF THE EMERGENCY CON-
TINGENCY FUND FOR STATE TEMPORARY AS-
SISTANCE FOR NEEDY FAMILIES PROGRAMS. 
(a) IN GENERAL.—Section 403(c) of the Social Secu-
rity Act (42 U.S.C. 603(c)) is amended— 
(1) in paragraph (2)(A), by inserting ‘‘, and for 
fiscal year 2011, $2,500,000,000’’ before ‘‘for pay-
ment’’; 
(2) by striking paragraph (2)(B) and inserting 
the following: 
‘‘(B) AVAILABILITY AND USE OF FUNDS.— 
‘‘(i) FISCAL YEARS 2009 AND 2010.— 
The amounts appropriated to the Emer-
gency Fund under subparagraph (A) for 
fiscal year 2009 shall remain available 
through fiscal year 2010 and shall be used 
to make grants to States in each of fiscal 
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years 2009 and 2010 in accordance with 
the requirements of paragraph (3). 
‘‘(ii) FISCAL YEAR 2011.—Subject to 
clause (iii), the amounts appropriated to 
the Emergency Fund under subparagraph 
(A) for fiscal year 2011 shall remain avail-
able through fiscal year 2012 and shall be 
used to make grants to States based on ex-
penditures in fiscal year 2011 for benefits 
and services provided in fiscal year 2011 in 
accordance with the requirements of para-
graph (3). 
‘‘(iii) RESERVATION
OF
FUNDS.—Of 
the amounts appropriated to the Emer-
gency Fund under subparagraph (A) for 
fiscal year 2011, $500,000 shall be placed 
in reserve for use in fiscal year 2012, and 
shall be used to award grants for any ex-
penditures described in this subsection in-
curred by States after September 30, 
2011.’’; 
(3) in paragraph (2)(C), by striking ‘‘2010’’ 
and inserting ‘‘2012’’; 
(4) in paragraph (3)— 
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(A) in clause (i) of each of subparagraphs 
(A), (B), and (C)— 
(i) by striking ‘‘year 2009 or 2010’’ 
and inserting ‘‘years 2009 through 2011’’; 
(ii) by striking ‘‘and’’ at the end of 
subclause (I); 
(iii) by striking the period at the end 
of subclause (II) and inserting ‘‘; and’’; 
and 
(iv) by adding at the end the fol-
lowing: 
‘‘(III) if the quarter is in fiscal 
year 2011, has provided the Secretary 
with such information as the Sec-
retary may find necessary in order to 
make the determinations, or take any 
other action, described in paragraph 
(5)(C).’’; and 
(B) in subparagraph (C), by adding at the 
end the following: 
‘‘(iv) LIMITATION ON EXPENDITURES 
FOR
SUBSIDIZED
EMPLOYMENT.—An ex-
penditure for subsidized employment shall 
be taken into account under clause (ii) 
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only if the expenditure is used to subsidize 
employment for— 
‘‘(I) a member of a needy family 
(without regard to whether the family 
is receiving assistance under the State 
program funded under this part); or 
‘‘(II) an individual who has ex-
hausted (or, within 60 days, will ex-
haust) all rights to receive unemploy-
ment compensation under Federal and 
State law, and who is a member of a 
needy household (regardless of wheth-
er the household includes a child).’’; 
(5) by striking paragraph (5) and inserting the 
following: 
‘‘(5) LIMITATIONS ON PAYMENTS; ADJUSTMENT 
AUTHORITY.— 
‘‘(A) FISCAL YEARS 2009 AND 2010.—The 
total amount payable to a single State under 
subsection (b) and this subsection for fiscal 
years 2009 and 2010 combined shall not exceed 
50 percent of the annual State family assist-
ance grant. 
‘‘(B) FISCAL YEAR 2011.—Subject to sub-
paragraph (C), the total amount payable to a 
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single State under subsection (b) and this sub-
section for fiscal year 2011 shall not exceed 30 
percent of the annual State family assistance 
grant. 
‘‘(C) ADJUSTMENT
AUTHORITY.—If the 
Secretary determines that the Emergency Fund 
is at risk of being depleted before September 
30, 2011, or that funds are available to accom-
modate additional State requests under this 
subsection, the Secretary may, through program 
instructions issued without regard to the re-
quirements of section 553 of title 5, United 
States Code— 
‘‘(i) specify priority criteria for award-
ing grants to States during fiscal year 
2011; and 
‘‘(ii) adjust the percentage limitation 
applicable under subparagraph (B) with 
respect to the total amount payable to a 
single State for fiscal year 2011.’’; and 
(6) in paragraph (6), by inserting ‘‘or for ex-
penditures described in paragraph (3)(C)(iv)’’ before 
the period. 
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(b) CONFORMING AMENDMENTS.—Section 2101 of 
division B of the American Recovery and Reinvestment 
Act of 2009 (Public Law 111–5) is amended— 
(1) in subsection (a)(2)— 
(A) by striking ‘‘2010’’ and inserting 
‘‘2011’’; and 
(B) by striking all that follows ‘‘repealed’’ 
and inserting a period; and 
(2) in subsection (d)(1), by striking ‘‘2010’’ 
and inserting ‘‘2011’’. 
(c) PROGRAM GUIDANCE.—The Secretary of Health 
and Human Services shall issue program guidance, with-
out regard to the requirements of section 553 of title 5, 
United States Code, which ensures that the funds provided 
under the amendments made by this section for subsidized 
employment do not support any subsidized employment 
position the annual salary of which is greater than, at 
State option— 
(1) 200 percent of the poverty line (within the 
meaning of section 673(2) of the Omnibus Budget 
Reconciliation Act of 1981, including any revision 
required by such section 673(2)) for a family of 4; 
or 
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(2) the median wage in any jurisdiction oper-
ating a program with funds provided pursuant to the 
amendments. 
Passed the House of Representatives March 24, 
2010. 
Attest: 
LORRAINE C. MILLER, 
Clerk. 
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