Keeping Jobs in America Act - Directs the Secretary of Commerce to establish a program to award grants to states that are recruiting high-value jobs (e.g., manufacturing, software publishing, and computer system design jobs that pay a higher than average wage). Allows the use of grants to issue forgivable loans to entities that employ not fewer than 50 full-time employees in high-value jobs and that are deciding whether to locate in rural and distressed areas.
Amends the Internal Revenue Code to: (1) grant business taxpayers a tax credit for up to 20% of insourcing expenses incurred for eliminating a business located outside the United States and relocating it within the United States, and (2) deny a tax deduction for outsourcing expenses incurred in relocating a U.S. business outside the United States. Requires an increase in the taxpayer's employment of full-time employees in the United States in order to claim the tax credit for insourcing expenses.
Extends through 2017 the additional allowance for depreciation of business property (bonus depreciation) and the election to accelerate the alternative minimum tax credit in lieu of bonus depreciation. Makes permanent: (1) the increased $500,000 expensing allowance for depreciable business property and qualified real property, and (2) the new markets tax credit.
[Congressional Bills 113th Congress]
[From the U.S. Government Publishing Office]
[S. 2681 Introduced in Senate (IS)]
113th CONGRESS
2d Session
S. 2681
To amend the Internal Revenue Code of 1986 to provide incentives for
businesses to keep jobs in the United States.
_______________________________________________________________________
IN THE SENATE OF THE UNITED STATES
July 29, 2014
Mr. Pryor (for himself and Mr. Walsh) introduced the following bill;
which was read twice and referred to the Committee on Finance
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to provide incentives for
businesses to keep jobs in the United States.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Keeping Jobs in America Act''.
SEC. 2. INBOUND INVESTMENT PROGRAM TO RECRUIT JOBS TO THE UNITED
STATES.
(a) Definitions.--In this section:
(1) Distressed.--The term ``distressed'', with respect to
an area, means an area in the United States that, on the date
on which the program is established under subsection (b)--
(A) is included in the most recent classification
of labor surplus areas by the Secretary of Labor; and
(B) has an unemployment rate equal to or greater
than 110 percent of the unemployment rate of the United
States.
(2) Eligible entity.--The term ``eligible entity'' means an
entity that employs not fewer than 50 full-time equivalent
employees in high-value jobs.
(3) Eligible facility.--The term ``eligible facility''
means a facility at which--
(A) an eligible entity employs not fewer than 50
full-time equivalent employees in high-value jobs;
(B) with respect to a rural or distressed area, the
mean of the wages provided by the eligible entity to
individuals employed at such facility is greater than
the mean wage for the county in which the rural or
distressed area is located; and
(C) derives at least the majority of its revenues
from--
(i) goods production; or
(ii) providing product design, engineering,
marketing, or information technology services.
(4) High-value job defined.--The term ``high-value job''
means a job that--
(A) exists within an eligible facility; and
(B) has a North American Industrial Classification
that corresponds with manufacturing, software
publishers, computer systems design, or related codes,
and is higher than the mean hourly wage in the country.
(5) Rural.--The term ``rural'', with respect to an area,
means any area in the United States which, as confirmed by the
latest decennial census, is not located within--
(A) a city or town that has a population of greater
than 50,000 inhabitants; or
(B) an urbanized area contiguous and adjacent to a
city or town described in subparagraph (A).
(b) Program Required.--Not later than 180 days after the date of
the enactment of this Act, the Secretary of Commerce shall establish a
program to award grants to States that are recruiting high-value jobs.
Grants awarded under this section may be used to issue forgivable loans
to eligible entities that are deciding whether to locate eligible
facilities in the United States to assist such entities in locating
such facilities in rural or distressed areas.
(c) Federal Grants to States.--
(1) In general.--The Secretary shall carry out the program
through the award of grants to States to provide loans and loan
guarantees described in subsection (d).
(2) Application.--
(A) In general.--A State seeking a grant under the
program shall submit an application to the Secretary in
such manner and containing such information as the
Secretary may require. Once the program is operational,
any State may apply for a grant on an ongoing basis,
until funds are exhausted. The Secretary may also
establish a process for pre-clearing applications from
States. The Secretary shall notify all States of this
grant opportunity once the program is operational. All
information about the program and the State application
process must be online and must be in a format that is
easily understood and is widely accessible.
(B) Elements.--Each application submitted by a
State under subparagraph (A) shall include--
(i) a description of the eligible entity
the State proposes to assist in locating an
eligible facility in a rural or distressed area
of the State;
(ii) a description of such facility,
including the number of high-value jobs
relating to such facility;
(iii) a description of such rural or
distressed area;
(iv) a description of the resources of the
State that the State has committed to assisting
such corporation in locating such facility,
including tax incentives provided, bonding
authority exercised, and land granted; and
(v) such other elements as the Secretary
considers appropriate.
(C) Notice.--As soon as practicable after
establishing the program under subsection (b), the
Secretary shall notify all States of the grants
available under the program and the process for
applying for such grants.
(D) Online submission of applications.--The
Secretary shall establish a mechanism for the
electronic submission of applications under
subparagraph (A). Such mechanism shall utilize an
Internet website and all information on such website
shall be in a format that is easily understood and
widely accessible.
(E) Confidentiality.--The Secretary may not make
public any information submitted by a State to the
Secretary under this paragraph regarding the efforts of
such State to assist an eligible entity in locating an
eligible facility in such State without the express
consent of the State.
(3) Selection.--The Secretary shall award grants under the
program on a competitive basis to States that--
(A) the Secretary determines are most likely to
succeed with a grant under the program in assisting an
eligible entity in locating an eligible facility in a
rural or distressed area;
(B) if successful in assisting an eligible entity
as described in subparagraph (A), will create the
greatest number of high-value jobs in rural or
distressed areas;
(C) have committed significant resources, to the
extent of their ability as determined by the Secretary,
to assisting eligible entities in locating eligible
facilities in a rural or distressed areas; or
(D) meet such other criteria as the Secretary
considers appropriate, including criteria relating to
marketing plans, benefits to ongoing regional or State
strategies for economic development, and job growth.
(4) Limitation on competition between states.--The
Secretary may not award a grant to a State under the program to
assist an eligible entity--
(A) in locating an eligible facility in such State
if another State is already seeking to assist such
eligible entity in locating such eligible facility in
such other State; or
(B) from relocating an eligible facility from one
State to another State.
(5) Availability of grant amounts.--For each grant awarded
to a State under the program, the Secretary shall make
available to such State the amount of such grant not later than
30 days after the date on which the Secretary awarded the
grant. The total amount of grants awarded under this program
may not exceed $100,000,000.
(d) Loans and Loan Guarantees From States to Corporations.--
(1) In general.--Amounts received by a State under the
program shall be used to provide assistance to an eligible
entity to locate an eligible facility in a rural or distressed
area of the State.
(2) Loans and loan guarantees.--A State receiving a grant
under the program may provide assistance under paragraph (1) in
the form of--
(A) a single loan to a single eligible entity as
described in paragraph (1) to cover the costs incurred
by the eligible entity in locating the eligible
facility as described in such paragraph; or
(B) a single loan guarantee to a financial
institution making a single loan to a single eligible
entity as described in paragraph (1) to cover the costs
incurred by the eligible entity in locating the
eligible facility as described in such paragraph.
(3) Terms and conditions.--Each loan or loan guarantee
provided under paragraph (2) shall have a term of 5 years and
shall bear interest at rates equal to the Federal long-term
rate under section 1274(d)(1)(C) of the Internal Revenue Code
of 1986.
(4) Amount.--The amount of a loan or loan guarantee issued
to an eligible entity under the program for the location of an
eligible facility shall be an amount equal to not more than
$5,000 per full-time equivalent employee to be employed at such
facility.
(5) Repayment.--Repayment of a loan issued by a State to an
eligible entity under the program shall be repaid in accordance
with such schedule as the State shall establish in accordance
with such rules as the Secretary shall prescribe for purposes
of the program. Such rules shall provide for the following:
(A) Forgiveness of all or a portion of the loan,
the amount of such forgiveness depending upon the
following:
(i) The performance of the borrower.
(ii) The number or quality of the jobs at
the facility located under the program.
(B) Repayment of principal or interest, if any, at
the end of the term of the loan.
(e) Assessment and Recommendations.--
(1) Ongoing assessment.--The Secretary shall conduct an
ongoing assessment of the program.
(2) Recommendations.--The Secretary may submit to Congress
recommendations for such legislative action as the Secretary
considers appropriate to improve the program, including with
respect to any findings of the Secretary derived by comparing
the program established under subsection (b) with the programs
and policies of governments of other countries used to recruit
high-value jobs.
SEC. 3. CREDIT FOR INSOURCING EXPENSES.
(a) In General.--Subpart D of part IV of subchapter A of chapter 1
of the Internal Revenue Code of 1986 is amended by adding at the end
the following new section:
``SEC. 45S. CREDIT FOR INSOURCING EXPENSES.
``(a) In General.--For purposes of section 38, the insourcing
expenses credit for any taxable year is an amount equal to 20 percent
of the eligible insourcing expenses of the taxpayer which are taken
into account in such taxable year under subsection (d).
``(b) Eligible Insourcing Expenses.--For purposes of this section--
``(1) In general.--The term `eligible insourcing expenses'
means--
``(A) eligible expenses paid or incurred by the
taxpayer in connection with the elimination of any
business unit of the taxpayer (or of any member of any
expanded affiliated group in which the taxpayer is also
a member) located outside the United States, and
``(B) eligible expenses paid or incurred by the
taxpayer in connection with the establishment of any
business unit of the taxpayer (or of any member of any
expanded affiliated group in which the taxpayer is also
a member) located within the United States,
if such establishment constitutes the relocation of the
business unit so eliminated. For purposes of the preceding
sentence, a relocation shall not be treated as failing to occur
merely because such elimination occurs in a different taxable
year than such establishment.
``(2) Eligible expenses.--The term `eligible expenses'
means--
``(A) any amount for which a deduction is allowed
to the taxpayer under section 162, and
``(B) permit and license fees, lease brokerage
fees, equipment installation costs, and, to the extent
provided by the Secretary, other similar expenses.
Such term does not include any compensation which is paid or
incurred in connection with severance from employment and, to
the extent provided by the Secretary, any similar amount.
``(3) Business unit.--The term `business unit' means--
``(A) any trade or business, and
``(B) any line of business, or functional unit,
which is part of any trade or business.
``(4) Expanded affiliated group.--The term `expanded
affiliated group' means an affiliated group as defined in
section 1504(a), determined without regard to section
1504(b)(3) and by substituting `more than 50 percent' for `at
least 80 percent' each place it appears in section 1504(a). A
partnership or any other entity (other than a corporation)
shall be treated as a member of an expanded affiliated group if
such entity is controlled (within the meaning of section
954(d)(3)) by members of such group (including any entity
treated as a member of such group by reason of this paragraph).
``(5) Expenses must be pursuant to insourcing plan.--
Amounts shall be taken into account under paragraph (1) only to
the extent that such amounts are paid or incurred pursuant to a
written plan to carry out the relocation described in paragraph
(1).
``(6) Operating expenses not taken into account.--Any
amount paid or incurred in connection with the on-going
operation of a business unit shall not be treated as an amount
paid or incurred in connection with the establishment or
elimination of such business unit.
``(c) Increased Domestic Employment Requirement.--No credit shall
be allowed under this section unless the number of full-time equivalent
employees of the taxpayer for the taxable year for which the credit is
claimed exceeds the number of full-time equivalent employees of the
taxpayer for the last taxable year ending before the first taxable year
in which such eligible insourcing expenses were paid or incurred. For
purposes of this subsection, full-time equivalent employees has the
meaning given such term under section 45R(d) (and the applicable rules
of section 45R(e)). All employers treated as a single employer under
subsection (b), (c), (m), or (o) of section 414 shall be treated as a
single employer for purposes of this subsection.
``(d) Credit Allowed Upon Completion of Insourcing Plan.--
``(1) In general.--Except as provided in paragraph (2),
eligible insourcing expenses shall be taken into account under
subsection (a) in the taxable year during which the plan
described in subsection (b)(5) has been completed and all
eligible insourcing expenses pursuant to such plan have been
paid or incurred.
``(2) Election to apply employment test and claim credit in
first full taxable year after completion of plan.--If the
taxpayer elects the application of this paragraph, eligible
insourcing expenses shall be taken into account under
subsection (a) in the first taxable year after the taxable year
described in paragraph (1).
``(e) Possessions Treated as Part of the United States.--For
purposes of this section, the term `United States' shall be treated as
including each possession of the United States (including the
Commonwealth of Puerto Rico and the Commonwealth of the Northern
Mariana Islands).
``(f) Regulations.--The Secretary shall prescribe such regulations
or other guidance as may be necessary or appropriate to carry out the
purposes of this section.''.
(b) Credit To Be Part of General Business Credit.--Subsection (b)
of section 38 of such Code is amended by striking ``plus'' at the end
of paragraph (35), by striking the period at the end of paragraph (36)
and inserting ``, plus'', and by adding at the end the following new
paragraph:
``(37) the insourcing expenses credit determined under
section 45S(a).''.
(c) Clerical Amendment.--The table of sections for subpart D of
part IV of subchapter A of chapter 1 of such Code is amended by adding
at the end the following new item:
``Sec. 45S. Credit for insourcing expenses.''.
(d) Effective Date.--The amendments made by this section shall
apply to amounts paid or incurred after the date of the enactment of
this Act.
(e) Application to United States Possessions.--
(1) Payments to possessions.--
(A) Mirror code possessions.--The Secretary of the
Treasury shall make periodic payments to each
possession of the United States with a mirror code tax
system in an amount equal to the loss to that
possession by reason of section 45S of the Internal
Revenue Code of 1986. Such amount shall be determined
by the Secretary of the Treasury based on information
provided by the government of the respective
possession.
(B) Other possessions.--The Secretary of the
Treasury shall make annual payments to each possession
of the United States which does not have a mirror code
tax system in an amount estimated by the Secretary of
the Treasury as being equal to the aggregate benefits
that would have been provided to residents of such
possession by reason of section 45S of such Code if a
mirror code tax system had been in effect in such
possession. The preceding sentence shall not apply with
respect to any possession of the United States unless
such possession has a plan, which has been approved by
the Secretary of the Treasury, under which such
possession will promptly distribute such payment to the
residents of such possession.
(2) Coordination with credit allowed against united states
income taxes.--No credit shall be allowed against United States
income taxes under section 45S of such Code to any person--
(A) to whom a credit is allowed against taxes
imposed by the possession by reason of such section, or
(B) who is eligible for a payment under a plan
described in paragraph (1)(B).
(3) Definitions and special rules.--
(A) Possessions of the united states.--For purposes
of this section, the term ``possession of the United
States'' includes the Commonwealth of Puerto Rico and
the Commonwealth of the Northern Mariana Islands.
(B) Mirror code tax system.--For purposes of this
section, the term ``mirror code tax system'' means,
with respect to any possession of the United States,
the income tax system of such possession if the income
tax liability of the residents of such possession under
such system is determined by reference to the income
tax laws of the United States as if such possession
were the United States.
(C) Treatment of payments.--For purposes of section
1324(b)(2) of title 31, United States Code, the
payments under this section shall be treated in the
same manner as a refund due from sections referred to
in such section 1324(b)(2).
SEC. 4. DENIAL OF DEDUCTION FOR OUTSOURCING EXPENSES.
(a) In General.--Part IX of subchapter B of chapter 1 of the
Internal Revenue Code of 1986 is amended by adding at the end the
following new section:
``SEC. 280I. OUTSOURCING EXPENSES.
``(a) In General.--No deduction otherwise allowable under this
chapter shall be allowed for any specified outsourcing expense.
``(b) Specified Outsourcing Expense.--For purposes of this
section--
``(1) In general.--The term `specified outsourcing expense'
means--
``(A) any eligible expense paid or incurred by the
taxpayer in connection with the elimination of any
business unit of the taxpayer (or of any member of any
expanded affiliated group in which the taxpayer is also
a member) located within the United States, and
``(B) any eligible expense paid or incurred by the
taxpayer in connection with the establishment of any
business unit of the taxpayer (or of any member of any
expanded affiliated group in which the taxpayer is also
a member) located outside the United States,
if such establishment constitutes the relocation of the
business unit so eliminated. For purposes of the preceding
sentence, a relocation shall not be treated as failing to occur
merely because such elimination occurs in a different taxable
year than such establishment.
``(2) Application of certain definitions and rules.--
``(A) Definitions.--For purposes of this section,
the terms `eligible expenses', `business unit', and
`expanded affiliated group' shall have the respective
meanings given such terms by section 45S(b).
``(B) Operating expenses not taken into account.--A
rule similar to the rule of section 45S(b)(6) shall
apply for purposes of this section.
``(c) Special Rules.--
``(1) Application to deductions for depreciation and
amortization.--In the case of any portion of a specified
outsourcing expense which is not deductible in the taxable year
in which paid or incurred, such portion shall neither be
chargeable to capital account nor amortizable.
``(2) Possessions treated as part of the united states.--
For purposes of this section, the term `United States' shall be
treated as including each possession of the United States
(including the Commonwealth of Puerto Rico and the Commonwealth
of the Northern Mariana Islands).
``(d) Regulations.--The Secretary shall prescribe such regulations
or other guidance as may be necessary or appropriate to carry out the
purposes of this section, including regulations which provide (or
create a rebuttable presumption) that certain establishments of
business units outside the United States will be treated as relocations
(based on timing or such other factors as the Secretary may provide) of
business units eliminated within the United States.''.
(b) Limitation on Subpart F Income of Controlled Foreign
Corporations Determined Without Regard to Specified Outsourcing
Expenses.--Subsection (c) of section 952 of such Code is amended by
adding at the end the following new paragraph:
``(4) Earnings and profits determined without regard to
specified outsourcing expenses.--For purposes of this
subsection, earnings and profits of any controlled foreign
corporation shall be determined without regard to any specified
outsourcing expense (as defined in section 280I(b)).''.
(c) Clerical Amendment.--The table of sections for part IX of
subchapter B of chapter 1 of such Code is amended by adding at the end
the following new item:
``Sec. 280I. Outsourcing expenses.''.
(d) Effective Date.--The amendments made by this section shall
apply to amounts paid or incurred after the date of the enactment of
this Act.
SEC. 5. EXTENSION OF BONUS DEPRECIATION.
(a) In General.--Paragraph (2) of section 168(k) of the Internal
Revenue Code of 1986 is amended--
(1) by striking ``January 1, 2015'' in subparagraph (A)(iv)
and inserting ``January 1, 2019'', and
(2) by striking ``January 1, 2014'' each place it appears
and inserting ``January 1, 2018''.
(b) Special Rule for Federal Long-Term Contracts.--Clause (ii) of
section 460(c)(6)(B) of such Code is amended by striking ``January 1,
2014 (January 1, 2015'' and inserting ``January 1, 2018 (January 1,
2019''.
(c) Extension of Election To Accelerate the AMT Credit in Lieu of
Bonus Depreciation.--
(1) In general.--Subclause (II) of section
168(k)(4)(D)(iii) of such Code is amended by striking ``2014''
and inserting ``2018''.
(2) Round 4 extension property.--Paragraph (4) of section
168(k) of such Code is amended by adding at the end the
following new subparagraph:
``(K) Special rules for round 4 extension
property.--
``(i) In general.--In the case of round 4
extension property, in applying this paragraph
to any taxpayer--
``(I) the limitation described in
subparagraph (B)(i) and the business
credit increase amount under
subparagraph (E)(iii) thereof shall not
apply, and
``(II) the bonus depreciation
amount, maximum amount, and maximum
increase amount shall be computed
separately from amounts computed with
respect to eligible qualified property
which is not round 4 extension
property.
``(ii) Election.--
``(I) A taxpayer who has an
election in effect under this paragraph
for round 3 extension property shall be
treated as having an election in effect
for round 4 extension property unless
the taxpayer elects to not have this
paragraph apply to round 4 extension
property.
``(II) A taxpayer who does not have
an election in effect under this
paragraph for round 3 extension
property may elect to have this
paragraph apply to round 4 extension
property.
``(iii) Round 4 extension property.--For
purposes of this subparagraph, the term `round
4 extension property' means property which is
eligible qualified property solely by reason of
the extension of the application of the special
allowance under paragraph (1) pursuant to the
amendments made by section 5(a) of the Keeping
Jobs in America Act (and the application of
such extension to this paragraph pursuant to
the amendment made by section 5(c) of such
Act).''.
(d) Conforming Amendments.--
(1) The heading for subsection (k) of section 168 of such
Code is amended by striking ``January 1, 2014'' and inserting
``January 1, 2018''.
(2) The heading for clause (ii) of section 168(k)(2)(B) of
such Code is amended by striking ``pre-january 1, 2014'' and
inserting ``pre-january 1, 2018''.
(3) Subparagraph (C) of section 168(n)(2) of such Code is
amended by striking ``January 1, 2014'' and inserting ``January
1, 2018''.
(4) Subparagraph (D) of section 1400L(b)(2) of such Code is
amended by striking ``January 1, 2014'' and inserting ``January
1, 2018''.
(5) Subparagraph (B) of section 1400N(d)(3) of such Code is
amended by striking ``January 1, 2014'' and inserting ``January
1, 2018''.
(e) Technical Amendment Relating to Section 331 of the American
Taxpayer Relief Act of 2012.--
(1) In general.--Clause (iii) of section 168(k)(4)(J) of
such Code is amended by striking ``any taxable year'' and
inserting ``its first taxable year''.
(2) Effective date.--The amendment made by this subsection
shall take effect as if included in the provision of the
American Taxpayer Relief Act of 2012 to which it relates.
(f) Effective Date.--The amendments made by this section shall
apply to property placed in service after December 31, 2013, in taxable
years ending after such date.
SEC. 6. INCREASED EXPENSING LIMITATIONS AND TREATMENT OF CERTAIN REAL
PROPERTY AS SECTION 179 PROPERTY.
(a) In General.--
(1) Dollar limitation.--Paragraph (1) of section 179(b) of
the Internal Revenue Code of 1986 is amended by striking
``shall not exceed--'' and all that follows and inserting
``shall not exceed $500,000.''.
(2) Reduction in limitation.--Paragraph (2) of section
179(b) of such Code is amended by striking ``exceeds--'' and
all that follows and inserting ``exceeds $2,000,000.''.
(b) Computer Software.--Clause (ii) of section 179(d)(1)(A) of such
Code is amended by striking ``, to which section 167 applies, and which
is placed in service in a taxable year beginning after 2002 and before
2014'' and inserting ``and to which section 167 applies''.
(c) Election.--Paragraph (2) of section 179(c) of such Code is
amended--
(1) by striking ``may not be revoked'' and all that follows
through ``and before 2014'', and
(2) by striking ``irrevocable'' in the heading thereof.
(d) Air Conditioning and Heating Units.--Paragraph (1) of section
179(d) of such Code is amended by striking ``and shall not include air
conditioning or heating units''.
(e) Qualified Real Property.--Subsection (f) of section 179 of such
Code is amended--
(1) by striking ``beginning in 2010, 2011, 2012, or 2013''
in paragraph (1), and
(2) by striking paragraphs (3) and (4).
(f) Inflation Adjustment.--Subsection (b) of section 179 of such
Code is amended by adding at the end the following new paragraph:
``(6) Inflation adjustment.--
``(A) In general.--In the case of any taxable year
beginning after 2014, the dollar amounts in paragraphs
(1) and (2) shall each be increased by an amount equal
to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment
determined under section 1(c)(2)(A) for such
calendar year, determined by substituting
calendar year 2013 for calendar year 2012 in
clause (ii) thereof.
``(B) Rounding.--The amount of any increase under
subparagraph (A) shall be rounded to the nearest
multiple of $10,000.''.
(g) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2013.
SEC. 7. PERMANENT EXTENSION OF NEW MARKETS TAX CREDIT.
(a) Extension.--
(1) In general.--Subparagraph (G) of section 45D(f)(1) of
the Internal Revenue Code of 1986 is amended by striking ``,
2011, 2012, and 2013'' and inserting ``and each calendar year
thereafter''.
(2) Conforming amendment.--Section 45D(f)(3) of such Code
is amended by striking the last sentence.
(b) Inflation Adjustment.--Subsection (f) of section 45D of the
Internal Revenue Code of 1986 is amended by adding at the end the
following new paragraph:
``(4) Inflation adjustment.--
``(A) In general.--In the case of any calendar year
beginning after 2013, the dollar amount in paragraph
(1)(G) shall be increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment
determined under section 1(f)(3) for the
calendar year, determined by substituting
`calendar year 2000' for `calendar year 1992'
in subparagraph (B) thereof.
``(B) Rounding rule.--Any increase under
subparagraph (A) which is not a multiple of $1,000,000
shall be rounded to the nearest multiple of
$1,000,000.''.
(c) Alternative Minimum Tax Relief.--Subparagraph (B) of section
38(c)(4) of the Internal Revenue Code of 1986 is amended--
(1) by redesignating clauses (v) through (ix) as clauses
(vi) through (x), respectively, and
(2) by inserting after clause (iv) the following new
clause:
``(v) the credit determined under section
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, 2014,''.
(d) Effective Dates.--
(1) In general.--Except as provided in paragraph (2), the
amendments made by this section shall take effect on the date
of the enactment of this Act.
(2) Alternative minimum tax relief.--The amendments made by
subsection (c) shall apply to credits determined with respect
to qualified equity investments (as defined in section 45D(b)
of the Internal Revenue Code of 1986) initially made after the
date of the enactment of this Act.
<all>
Introduced in Senate
Read twice and referred to the Committee on Finance.
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