Stop Child Summer Hunger Act of 2014

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Stop Child Summer Hunger Act of 
2014''.

SEC. 2. SUMMER ELECTRONIC BENEFITS TRANSFER FOR CHILDREN PROGRAM.

    Section 13(a) of the Richard B. Russell National School Lunch Act 
(42 U.S.C. 1761(a)) is amended by adding at the end the following:
            ``(13) Summer electronic benefits transfer for children 
        program.--
                    ``(A) Definitions.--In this paragraph:
                            ``(i) Eligible household.--The term 
                        `eligible household' means a household that 
                        includes 1 or more children who are eligible to 
                        receive free or reduced price lunches under 
                        this Act or free or reduced price breakfasts 
                        under the Child Nutrition Act of 1966 (42 
                        U.S.C. 1771 et seq.).
                            ``(ii) Summer ebt card.--The term `summer 
                        EBT card' means an electronic benefit transfer 
                        card that is issued to an eligible household 
                        under this paragraph and limited to food 
                        purchases.
                    ``(B) Program.--The Secretary shall establish a 
                program under which the Secretary shall provide to 
                eligible households summer EBT cards for the purpose of 
                providing access to food for children during summer 
                months--
                            ``(i) to reduce or eliminate the food 
                        insecurity and hunger of children; and
                            ``(ii) to improve the nutritional status of 
                        children.
                    ``(C) Use.--An eligible household may use a summer 
                EBT card only to purchase food from retail food stores 
                that have been approved for participation in the 
                supplemental nutrition assistance program established 
                under the Food and Nutrition Act of 2008 (7 U.S.C. 2011 
                et seq.), in accordance with section 7(b) of that Act 
                (7 U.S.C. 2016(b)).
                    ``(D) Amount.--Each summer EBT card issued shall be 
                in an amount of--
                            ``(i) for calendar year 2016, $150 in food 
                        assistance per child per summer; and
                            ``(ii) for each subsequent calendar year, 
                        the amount specified in clause (i) as adjusted 
                        to reflect changes in reimbursement rates for 
                        school meals under this Act between calendar 
                        year 2016 and the most recent calendar year.
                    ``(E) Timing.--Summer EBT cards shall be issued at 
                the end of the regular school year.
                    ``(F) Funding.--
                            ``(i) In general.--On October 1, 2015, and 
                        on each October 1 thereafter, out of any funds 
                        in the Treasury not otherwise appropriated, the 
                        Secretary of the Treasury shall transfer to the 
                        Secretary such sums as are necessary to carry 
                        out this section, to remain available until 
                        expended.
                            ``(ii) Receipt and acceptance.--The 
                        Secretary shall be entitled to receive, shall 
                        accept, and shall use to carry out this section 
                        the funds transferred under clause (i), without 
                        further appropriation. 
                    ``(G) Regulations.--
                            ``(i) In general.--Not later than October 
                        1, 2015, the Secretary shall issue regulations 
                        to carry out this paragraph.
                            ``(ii) Requirements.--Regulations issued 
                        under this subparagraph shall require that--
                                    ``(I) children shall be eligible to 
                                participate and shall be enrolled into 
                                the program under this paragraph for a 
                                summer without further application if 
                                the children are enrolled to 
                                participate in the free or reduced 
                                price lunch program under this Act or 
                                the free or reduced price breakfast 
                                program under the Child Nutrition Act 
                                of 1966 (42 U.S.C. 1771 et seq.) during 
                                the school year immediately preceding 
                                the summer; and
                                    ``(II) local educational agencies 
                                shall distribute to the families of all 
                                children enrolled in schools 
                                participating in programs authorized 
                                under this Act and the Child Nutrition 
                                Act of 1966 (42 U.S.C. 1771 et seq.) 
                                and, to the maximum extent practicable, 
                                the families of all children enrolled 
                                in schools of the local educational 
                                agency information, as provided by the 
                                Secretary,--
                                            ``(aa) regarding the 
                                        program authorized under this 
                                        paragraph, including 
                                        eligibility rules and how 
                                        children in eligible households 
                                        that are not automatically 
                                        enrolled under subclause (I) 
                                        may apply for program benefits; 
                                        and
                                            ``(bb) to assist households 
                                        receiving summer EBT cards in 
                                        making healthy food choices and 
                                        maximizing resources.
                            ``(iii) Alternative timing.--
                                    ``(I) In general.--In issuing 
                                regulations under this subparagraph, 
                                the Secretary shall allow alternative 
                                plans for the timing of issuance of the 
                                summer electronic benefit cards under 
                                subparagraph (D) in any part of a State 
                                in which the school year does not 
                                include a typical summer break, on the 
                                condition that the Secretary determines 
                                that no alternative plan increases or 
                                decreases Federal costs.
                                    ``(II) Considerations.--In 
                                developing regulations under subclause 
                                (I), the Secretary shall consider the 
                                ability of a State effectively to issue 
                                benefits under an alternative 
                                schedule.''.

SEC. 3. DEFER DEDUCTION OF INTEREST EXPENSE RELATED TO DEFERRED INCOME.

    (a) In General.--Section 163 of the Internal Revenue Code of 1986 
(relating to deductions for interest expense) is amended by 
redesignating subsection (n) as subsection (o) and by inserting after 
subsection (m) the following new subsection:
    ``(n) Deferral of Deduction for Interest Expense Related to 
Deferred Income.--
            ``(1) General rule.--The amount of foreign-related interest 
        expense of any taxpayer allowed as a deduction under this 
        chapter for any taxable year shall not exceed an amount equal 
        to the applicable percentage of the sum of--
                    ``(A) the taxpayer's foreign-related interest 
                expense for the taxable year, plus
                    ``(B) the taxpayer's deferred foreign-related 
                interest expense.
        For purposes of this paragraph, the applicable percentage is 
        the percentage equal to the current inclusion ratio.
            ``(2) Treatment of deferred deductions.--If, for any 
        taxable year, the amount of the limitation determined under 
        paragraph (1) exceeds the taxpayer's foreign-related interest 
        expense for the taxable year, there shall be allowed as a 
        deduction for the taxable year an amount equal to the lesser 
        of--
                    ``(A) such excess, or
                    ``(B) the taxpayer's deferred foreign-related 
                interest expense.
            ``(3) Definitions and special rule.--For purposes of this 
        subsection--
                    ``(A) Foreign-related interest expense.--The term 
                `foreign-related interest expense' means, with respect 
                to any taxpayer for any taxable year, the amount which 
                bears the same ratio to the amount of interest expense 
                for such taxable year allocated and apportioned under 
                sections 861, 864(e), and 864(f) to income from sources 
                outside the United States as--
                            ``(i) the value of all stock held by the 
                        taxpayer in all section 902 corporations with 
                        respect to which the taxpayer meets the 
                        ownership requirements of subsection (a) or (b) 
                        of section 902, bears to
                            ``(ii) the value of all assets of the 
                        taxpayer which generate gross income from 
                        sources outside the United States.
                    ``(B) Deferred foreign-related interest expense.--
                The term `deferred foreign-related interest expense' 
                means the excess, if any, of the aggregate foreign-
                related interest expense for all prior taxable years 
                beginning after December 31, 2014, over the aggregate 
                amount allowed as a deduction under paragraphs (1) and 
                (2) for all such prior taxable years.
                    ``(C) Value of assets.--Except as otherwise 
                provided by the Secretary, for purposes of subparagraph 
                (A)(ii), the value of any asset shall be the amount 
                with respect to such asset determined for purposes of 
                allocating and apportioning interest expense under 
                sections 861, 864(e), and 864(f).
                    ``(D) Current inclusion ratio.--The term `current 
                inclusion ratio' means, with respect to any domestic 
                corporation which meets the ownership requirements of 
                subsection (a) or (b) of section 902 with respect to 
                one or more section 902 corporations for any taxable 
                year, the ratio (expressed as a percentage) of--
                            ``(i) the sum of all dividends received by 
                        the domestic corporation from all such section 
                        902 corporations during the taxable year plus 
                        amounts includible in gross income under 
                        section 951(a) from all such section 902 
                        corporations, in each case computed without 
                        regard to section 78, divided by
                            ``(ii) the aggregate amount of post-1986 
                        undistributed earnings.
                    ``(E) Aggregate amount of post-1986 undistributed 
                earnings.--The term `aggregate amount of post-1986 
                undistributed earnings' means, with respect to any 
                domestic corporation which meets the ownership 
                requirements of subsection (a) or (b) of section 902 
                with respect to one or more section 902 corporations, 
                the domestic corporation's pro rata share of the post-
                1986 undistributed earnings (as defined in section 
                902(c)(1)) of all such section 902 corporations.
                    ``(F) Foreign currency conversion.--For purposes of 
                determining the current inclusion ratio, and except as 
                otherwise provided by the Secretary, the aggregate 
                amount of post-1986 undistributed earnings for the 
                taxable year shall be determined by translating each 
                section 902 corporation's post-1986 undistributed 
                earnings into dollars using the average exchange rate 
                for such year.
                    ``(G) Section 902 corporation.--The term `section 
                902 corporation' has the meaning given to such term by 
                section 909(d)(5).
            ``(4) Treatment of affiliated groups.--The current 
        inclusion ratio of each member of an affiliated group (as 
        defined in section 864(e)(5)(A)) shall be determined as if all 
        members of such group were a single corporation.
            ``(5) Application to separate categories of income.--This 
        subsection shall be applied separately with respect to the 
        categories of income specified in section 904(d)(1).
            ``(6) Regulations.--The Secretary may prescribe such 
        regulations or other guidance as is necessary or appropriate to 
        carry out the purposes of this subsection, including 
        regulations or other guidance providing--
                    ``(A) for the proper application of this subsection 
                with respect to changes in ownership of a section 902 
                corporation,
                    ``(B) that certain corporations that otherwise 
                would not be members of the affiliated group will be 
                treated as members of the affiliated group for purposes 
                of this subsection,
                    ``(C) for the proper application of this subsection 
                with respect to the taxpayer's share of a deficit in 
                earnings and profits of a section 902 corporation,
                    ``(D) for appropriate adjustments to the 
                determination of the value of stock in any section 902 
                corporation for purposes of this subsection or to the 
                foreign-related interest expense to account for income 
                that is subject to tax under section 882(a)(1), and
                    ``(E) for the proper application of this subsection 
                with respect to interest expense that is directly 
                allocable to income with respect to certain assets.''.
    (b) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 2014.

Summary: Stop Child Summer Hunger Act of 2014 - Amends the Richard B. Russell National School Lunch Act to require the Secretary of Agriculture (USDA) to establish a program providing eligible households with summer Electronic Benefits Transfer (EBT) cards that give children access to food during the summer months to: (1) reduce or eliminate children's food insecurity and hunger, and (2) improve their nutritional status. Defines an &quot;eligible household&quot; as a household that includes one or more children who are eligible to receive free or reduced price meals under the school lunch or breakfast programs. Sets the amount on each summer EBT card at $150 per child in 2016, with adjustments thereafter reflecting changes in reimbursement rates for school meals under the school lunch program. Requires children to be enrolled in the program without further application if they are enrolled to receive free or reduced price meals under the school lunch or breakfast programs. Requires summer EBT cards to be used only to purchase food from retail food stores that have been approved for participation in the supplemental nutrition assistance program (SNAP, formerly known as the food stamp program). Amends the Internal Revenue Code to limit the amount of a taxpayer's foreign-related interest expense that is allowed as a deduction for any taxable year. Sets that limit pursuant to a formula that takes into account a domestic corporation's undistributed foreign earnings.