TITLE I—MIDDLE CLASS TAX RELIEF MADE PERMANENT 
Sec. 101. Middle class tax relief made permanent. 
Sec. 102. Certain provisions not applicable to high income individuals. 
Sec. 103. Related amendments. 
TITLE II—EXPENSING BY SMALL BUSINESSES OF CERTAIN 
DEPRECIABLE ASSETS 
Sec. 201. Increased limitations on expensing by small businesses of certain depre-
ciable assets. 
TITLE III—EXTENSION OF ALTERNATIVE MINIMUM TAX RELIEF 
Sec. 301. Extension of alternative minimum tax relief for nonrefundable personal 
credits. 
Sec. 302. Extension of increased alternative minimum tax exemption amount. 
TITLE IV—BUDGETARY PROVISION 
Sec. 401. Paygo compliance. 
TITLE I—MIDDLE CLASS TAX 
RELIEF MADE PERMANENT 
SEC. 101. MIDDLE CLASS TAX RELIEF MADE PERMANENT. 
(a) IN GENERAL.—Section 901 of the Economic 
Growth and Tax Relief Reconciliation Act of 2001 shall not 
apply to the following provisions of such Act (and to the 
amendments made by such provisions): 
(1) Title I (relating to individual income tax 
rate reductions). 
(2) Title II (relating to tax benefits related to 
children). 
(3) Title III (relating to marriage penalty re-
lief). 
(4) Title IV (relating to affordable education 
provisions).
(b) REDUCED RATES ON CAPITAL GAINS AND DIVI-
DENDS.—The Jobs and Growth Tax Relief Reconciliation 
Act of 2003 is amended by striking section 303. 
SEC. 102. CERTAIN PROVISIONS NOT APPLICABLE TO HIGH 
INCOME INDIVIDUALS. 
(a) INDIVIDUAL INCOME TAX RATES.—Subsection (i) 
of section 1 is amended by striking paragraph (2), by redes-
ignating paragraph (3) as paragraph (4), and by inserting 
after paragraph (1) the following new paragraphs: 
‘‘(2) 25- AND 28-PERCENT RATE BRACKETS.—The 
tables under subsections (a), (b), (c), (d), and (e) shall 
be applied— 
‘‘(A) by substituting ‘25%’ for ‘28%’ each 
place it appears (before the application of sub-
paragraph (B)), and 
‘‘(B) by substituting ‘28%’ for ‘31%’ each 
place it appears. 
‘‘(3) 33-PERCENT RATE BRACKET.— 
‘‘(A) IN GENERAL.—In the case of taxable 
years beginning after December 31, 2010— 
‘‘(i) the rate of tax under subsections 
(a), (b), (c), and (d) on a taxpayer’s taxable 
income in the fourth rate bracket shall be 33 
percent to the extent such income does not 
exceed an amount equal to the excess of—
‘‘(I) the applicable amount, over 
‘‘(II) the dollar amount at which 
such bracket begins, and 
‘‘(ii) the 36 percent rate of tax under 
such subsections shall apply only to the tax-
payer’s taxable income in such bracket in 
excess of the amount to which clause (i) ap-
plies. 
‘‘(B) APPLICABLE AMOUNT.—For purposes 
of this paragraph, the term ‘applicable amount’ 
means the excess of— 
‘‘(i) the applicable threshold, over 
‘‘(ii) the sum of the following amounts 
in effect for the taxable year: 
‘‘(I) the basic standard deduction 
(within 
the 
meaning 
of 
section 
63(c)(2)), and 
‘‘(II) 
the 
exemption 
amount 
(within 
the 
meaning 
of 
section 
151(d)(1)) (or, in the case of subsection 
(a), 2 such exemption amounts). 
‘‘(C) APPLICABLE THRESHOLD.—For pur-
poses of this paragraph, the term ‘applicable 
threshold’ means—
‘‘(i) $250,000 in the case of subsection 
(a), 
‘‘(ii) $200,000 in the case of sub-
sections (b) and (c), and 
‘‘(iii) 1⁄2 the amount applicable under 
clause (i) (after adjustment, if any, under 
subparagraph (E)) in the case of subsection 
(d). 
‘‘(D) FOURTH RATE BRACKET.—For pur-
poses of this paragraph, the term ‘fourth rate 
bracket’ means the bracket which would (deter-
mined without regard to this paragraph) be the 
36-percent rate bracket. 
‘‘(E) INFLATION
ADJUSTMENT.—For pur-
poses of this paragraph, a rule similar to the 
rule of paragraph (1)(C) shall apply with respect 
to taxable years beginning in calendar years 
after 2010, applied by substituting ‘2008’ for 
‘1992’ in subsection (f)(3)(B).’’. 
(b) PHASEOUT
OF
PERSONAL
EXEMPTIONS
AND 
ITEMIZED DEDUCTIONS.— 
(1) OVERALL LIMITATION ON ITEMIZED DEDUC-
TIONS.—Section 68 is amended— 
(A) by striking ‘‘the applicable amount’’ the 
first place it appears in subsection (a) and in-
serting ‘‘the applicable threshold in effect under 
section 1(i)(3)’’, 
(B) by striking ‘‘the applicable amount’’ in 
subsection (a)(1) and inserting ‘‘such applicable 
threshold’’, 
(C) by striking subsection (b) and redesig-
nating subsections (c), (d), and (e) as subsections 
(b), (c), and (d), respectively, and 
(D) by striking subsections (f) and (g). 
(2) PHASEOUT OF DEDUCTIONS FOR PERSONAL 
EXEMPTIONS.— 
(A) IN GENERAL.—Paragraph (3) of section 
151(d) is amended— 
(i) by striking ‘‘the threshold amount’’ 
in subparagraphs (A) and (B) and insert-
ing ‘‘the applicable threshold in effect under 
section 1(i)(3)’’, 
(ii) by striking subparagraph (C) and 
redesignating subparagraph (D) as sub-
paragraph (C), and 
(iii) by striking subparagraphs (E) 
and (F). 
(B) CONFORMING AMENDMENT.—Paragraph 
(4) of section 151(d) is amended— 
(i) by striking subparagraph (B),
(ii) by redesignating clauses (i) and 
(ii) of subparagraph (A) as subparagraphs 
(A) and (B), respectively, and by indenting 
such subparagraphs (as so redesignated) ac-
cordingly, and 
(iii) by striking all that precedes ‘‘in a 
calendar year after 1989,’’ and inserting the 
following: 
‘‘(4) INFLATION
ADJUSTMENT.—In the case of 
any taxable year beginning’’. 
(c) REDUCED RATE ON CAPITAL GAINS AND DIVI-
DENDS.— 
(1) IN
GENERAL.—Paragraph (1) of section 
(1)(h) is amended by striking subparagraph (C), by 
redesignating subparagraphs (D) and (E) as subpara-
graphs (E) and (F) and by inserting after subpara-
graph (B) the following new subparagraphs: 
‘‘(C) 15 percent of the lesser of— 
‘‘(i) so much of the adjusted net capital 
gain (or, if less, taxable income) as exceeds 
the amount on which a tax is determined 
under subparagraph (B), or 
‘‘(ii) the excess (if any) of— 
‘‘(I) the amount of taxable income 
which would (without regard to this
subsection) be taxed at a rate below 36 
percent, over 
‘‘(II) the sum of the amounts on 
which tax is determined under sub-
paragraphs (A) and (B), 
‘‘(D) 20 percent of the adjusted net capital 
gain (or, if less, taxable income) in excess of the 
sum of the amounts on which tax is determined 
under subparagraphs (B) and (C),’’. 
(2) DIVIDENDS.—Subparagraph (A) of section 
1(h)(11) is amended by striking ‘‘qualified dividend 
income’’ and inserting ‘‘so much of the qualified divi-
dend income as does not exceed the excess (if any) 
of— 
‘‘(i) the amount of taxable income 
which would (without regard to this sub-
section) be taxed at a rate below 36 percent, 
over 
‘‘(ii) taxable income reduced by quali-
fied dividend income.’’. 
(3) MINIMUM TAX.—Section 55 is amended by 
adding at the end the following new subsection: 
‘‘(f) APPLICATION OF MAXIMUM RATE OF TAX ON NET 
CAPITAL GAIN OF NONCORPORATE TAXPAYERS.—In the 
case of taxable years beginning after December 31, 2010,
the amount determined under subparagraph (C) of sub-
section (b)(3) shall be the sum of— 
‘‘(1) 15 percent of the lesser of— 
‘‘(A) so much of the adjusted net capital 
gain (or, if less, taxable excess) as exceeds the 
amount on which tax is determined under sub-
paragraph (B) of subsection (b)(3), or 
‘‘(B) 
the 
excess 
described 
in 
section 
1(h)(1)(C)(ii), plus 
‘‘(2) 20 percent of the adjusted net capital gain 
(or, if less, taxable excess) in excess of the sum of the 
amounts on which tax is determined under subsection 
(b)(3)(B) and paragraph (1).’’. 
(4) CONFORMING AMENDMENTS.— 
(A) The following provisions are amended 
by striking ‘‘15 percent’’ and inserting ‘‘20 per-
cent’’: 
(i) Section 1445(e)(1). 
(ii) The second sentence of section 
7518(g)(6)(A). 
(iii) Section 53511(f)(2) of title 46, 
United States Code. 
(B) Sections 531 and 541 are each amended 
by striking ‘‘15 percent of’’ and inserting ‘‘the
product of the highest rate of tax under section 
1(c) and’’. 
(C) Section 1445(e)(6) is amended by strik-
ing ‘‘15 percent (20 percent in the case of taxable 
years beginning after December 31, 2010)’’ and 
inserting ‘‘20 percent’’. 
(d) EFFECTIVE DATES.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section shall 
apply to taxable years beginning after December 31, 
2010. 
(2) WITHHOLDING.—The amendments made by 
subparagraphs (A)(i) and (C) of subsection (c)(4) 
shall apply to amounts paid on or after January 1, 
2011. 
SEC. 103. RELATED AMENDMENTS. 
(a) APPLICATION OF INCREASE IN REFUNDABLE POR-
TION OF CHILD TAX CREDIT.— 
(1) IN GENERAL.—Subsection (d) of section 24 is 
amended— 
(A) by striking ‘‘$10,000’’ in paragraph 
(1)(B)(i) and inserting ‘‘$3,000’’, and 
(B) by striking paragraphs (3) and (4).
(2) EFFECTIVE DATE.—The amendments made 
by this subsection shall apply to taxable years begin-
ning after December 31, 2010. 
(b) APPLICATION OF INCREASE IN EARNED INCOME 
TAX CREDIT.— 
(1) IN GENERAL.—Subparagraph (B) of section 
32(b)(2) is amended to read as follows: 
‘‘(B) JOINT RETURNS.— 
‘‘(i) IN GENERAL.—In the case of a 
joint return filed by an eligible individual 
and such individual’s spouse, the phaseout 
amount determined under subparagraph 
(A) shall be increased by $5,000. 
‘‘(ii) INFLATION ADJUSTMENT.—In the 
case of any taxable year beginning after 
2010, the $5,000 amount in clause (i) shall 
be increased by an amount equal to— 
‘‘(I) such dollar amount, multi-
plied by 
‘‘(II) the cost of living adjustment 
determined under section 1(f)(3) for 
the calendar year in which the taxable 
year begins determined by substituting 
‘calendar year 2008’ for ‘calendar year 
1992’ in subparagraph (B) thereof.
‘‘(ii) 
PHASEOUT
AMOUNT.—If 
the 
amount in paragraph (2) as increased 
under subparagraph (A) is not a multiple 
of $10,000, such amount shall be rounded to 
the nearest multiple of $10,000.’’. 
(d) AUTHORITY TO REVOKE ELECTION MADE PERMA-
NENT.—Paragraph (2) of section 179(c) is amended by 
striking ‘‘and before 2012’’. 
(e) TREATMENT OF CERTAIN COMPUTER SOFTWARE AS 
SECTION 179 PROPERTY MADE PERMANENT.—Clause (ii) 
of section 179(d)(1)(A) is amended by striking ‘‘and before 
2012’’. 
(f) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2011. 
TITLE III—EXTENSION OF AL-
TERNATIVE MINIMUM TAX RE-
LIEF 
SEC. 301. EXTENSION OF ALTERNATIVE MINIMUM TAX RE-
LIEF 
FOR 
NONREFUNDABLE 
PERSONAL 
CREDITS. 
(a) IN GENERAL.—Paragraph (2) of section 26(a) is 
amended— 
(1) by striking ‘‘2000, 2001, 2002, 2003, 2004, 
2005, 2006, 2007, 2008, or 2009’’ and inserting ‘‘the
period beginning with calendar year 2000 and ending 
with calendar year 2011’’, and 
(2) by striking ‘‘2009’’ in the heading thereof and 
inserting ‘‘2011’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2009. 
SEC. 302. EXTENSION OF INCREASED ALTERNATIVE MIN-
IMUM TAX EXEMPTION AMOUNT. 
(a) IN GENERAL.—Paragraph (1) of section 55(d) is 
amended— 
(1) by striking ‘‘($70,950 in the case of taxable 
years beginning in 2009)’’ in subparagraph (A) and 
inserting ‘‘($72,450 in the case of taxable years begin-
ning in 2010 or 2011)’’, and 
(2) by striking ‘‘($46,700 in the case of taxable 
years beginning in 2009)’’ in subparagraph (B) and 
inserting ‘‘($47,450 in the case of taxable years begin-
ning in 2010 or 2011)’’. 
(b) NONAPPLICATION OF EGTRRA SUNSET.—Section 
901 of the Economic Growth and Tax Relief Reconciliation 
Act of 2001 shall not apply to the amendments made by 
section 701 of such Act.
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2009. 
TITLE IV—BUDGETARY 
PROVISION 
SEC. 401. PAYGO COMPLIANCE. 
The budgetary effects of this Act, for the purpose of 
complying with the Statutory Pay-As-You-Go Act of 2010, 
shall be determined by reference to the latest statement titled 
‘‘Budgetary Effects of PAYGO Legislation’’ for this Act, 
submitted for printing in the Congressional Record by the 
Chairman of the House Budget Committee, provided that 
such statement has been submitted prior to the vote on pas-
sage. 
Attest: 
Clerk.
111TH CONGRESS 
2D SESSION 
H.R. 4853 
HOUSE AMENDMENT TO 
SENATE AMENDMENT