H.R. 1 -- The Tax Reform Act of 2014

"(B)(i) the joint return child credit phaseout threshold, in the case of a joint return or a surviving spouse (as defined in section 2(a)), or

"(B) the amount by which the aggregate amount of credits allowed under the subpart (determined without regard to this subsection) would increase if the limitation under section 26(a) were increased by 25 percent of the taxpayer's earned income for the taxable year.

"(B) JOINT RETURNS. -- In the case of a joint return, the requirement of subparagraph (A) shall be treated as met if the Social Security number of either spouse is included on such return.

"(B) in the case of a taxpayer with 1 qualifying child, $2,400.

"(B) so much of the taxpayer's investment income for the taxable year as exceeds $3,300.

"(B) QUALIFYING CHILD INELIGIBLE. -- If an individual is the qualifying child of a taxpayer for any taxable year of such taxpayer beginning in a calendar year, such individual shall not be treated as an eligible individual for any taxable year of such individual beginning in such calendar year.

"(C) EXCEPTION FOR INDIVIDUAL CLAIMING BENEFITS UNDER SECTION 911. -- The term 'eligible individual' does not include any individual who claims the benefits of section 911 (relating to citizens or residents living abroad) for the taxable year.

"(D) LIMITATION ON ELIGIBILITY OF NONRESIDENT ALIENS. -- The term 'eligible individual' shall not include any individual who is a nonresident alien individual for any portion of the taxable year unless such individual is treated for such taxable year as a resident of the United States for purposes of this chapter by reason of an election under subsection (g) or (h) of section 6013.

"(B) any tax imposed under sections 3201(a), 3211(a), or 3221(a) on the compensation (as defined in section 3231(e)) received by the taxpayer during the calendar year in which the taxable year begins, and

"(C) any tax imposed under section 1401 on the self-employment income of the taxpayer for the taxable year.

"(B) PLACE OF ABODE. -- For purposes of subparagraph (A), the requirements of section 7705(c)(1)(B) shall be met only if the principal place of abode is in the United States.

"(C) TREATMENT OF MILITARY PERSONNEL STATIONED OUTSIDE THE UNITED STATES. -- For purposes of subparagraph (B), the principal place of abode of a member of the Armed Forces of the United States shall be treated as in the United States during any period during which such member is stationed outside the United States while serving on extended active duty with the Armed Forces of the United States. For purposes of the preceding sentence, the term 'extended active duty' means any period of active duty pursuant to a call or order to such duty for a period in excess of 90 days or for an indefinite period.

"(B) interest received or accrued during the taxable year which is exempt from tax imposed by this chapter,

"(C) the excess (if any) of --

"(E) the excess (if any) of --

"(B) the name, age, and Social Security number of each qualifying child taken into account under subsection (b)(1).

"(B) DISALLOWANCE PERIOD. -- For purposes of paragraph (1), the disallowance period is --

"(B) title V of the Housing Act of 1949, "(C) section 101 of the Housing and Urban Development Act of 1965,

"(D) sections 221(d)(3), 236 of the National Housing Act, and

"(E) the Food and Nutrition Act of 2008, any refund made to an individual (or the spouse of an individual) by reason of this section, and any payment made to such individual (or such spouse) by an employer under section 3507, shall not be treated as income (and shall not be taken into account in determining resources for the month of its receipt and the following month).

"(B) notwithstanding subsection (i), the dollar limitation applicable to such individual under subsection (b)(1) shall be $100 (twice such amount in the case of a joint return),

"(C) subsection (b)(2)(A) shall be applied by substituting '$8,000 ($13,000' for '$20,000 ($27,000', and

"(D) subsection (i)(1) shall not apply and the employment-related taxes with respect to such individual for any taxable year shall not exceed the sum of --

"(B) such individual's principal place of abode is in the United States for more than one-half of such taxable year,

"(C) such individual (or, if the individual is married (within the meaning of section 7703), either the individual or the individual's spouse) has attained age 25 but not attained age 65 before the close of the taxable year, and

"(D) such individual is not a dependent of another taxpayer for any taxable year beginning in the same calendar year as such taxable year.

"(B) the amount of the credit allowed under section 6413(c)(1). Such credit shall not be taken into account for purposes of determining any amount deducted and withheld under section 3202.".

(c) CONFORMING AMENDMENTS. --

(e) TREATMENT OF TAXPAYERS WHO IMPROPERLY CLAIMED CREDIT IN PRIOR YEARS. -- A claim of credit under section 32 of the Internal Revenue Code of 1986 (as in effect before the amendments made by this section) shall not fail to be taken into account under subsection (e) of such section (as amended by this section) merely because such claim is for a taxable year beginning before January 1, 2015.

(f) TREASURY REPORT ON MAKING CREDIT ADVANCEABLE. -- Not later than the date which is 180 days after the date of the enactment of this Act, the Secretary of the Treasury (or the Secretary's designee) shall submit a report to Congress making recommendations regarding the best method for providing for advance payment of the credits established by the amendments made by this section. The recommendations in such report shall seek to --

(b) DEFINITION OF DEPENDENT RETAINED. --

(e) MODIFICATION OF WAGE WITHHOLDING RULES. --

(50) Section 7703(a) is amended by striking "part V of subchapter B of chapter 1 and".

(51) Section 7703(b)(1) is amended by striking "section 152(f)(1)" and all that follows and inserting "section 7705(f)(1),".

(52) Section 7705(a), as redesignated by this section, is amended by striking "this subtitle" and inserting "subtitle A".

(53)(A) Section 7705(d)(1)(B), as redesignated by this section, is amended by striking "the exemption amount (as defined in section 151(d))" and inserting "$3,900".

"(c) LIMITATION BASED ON MODIFIED ADJUSTED GROSS INCOME. --

(b) REQUIREMENT TO REPORT TUITION PAID RATHER THAN TUITION BILLED. -- Section 6050S(b)(2)(B)(i) is amended by striking "or the aggregate amount billed".

(c) CONFORMING AMENDMENTS. --

(2) by striking "received by an individual as a scholarship" and inserting the following: "received by an individual --

(2) ROLLOVERS TO QUALIFIED TUITION PROGRAMS. -- The amendments made by subsection (b) shall apply to distributions after December 31, 2014.

(2) Section

(3) Section 3231(e)(5) is amended by striking "108(f)(4),".

(4) Section 3306(b)(16) is amended by striking "108(f)(4),".

(5) Section 3401(a)(19) is amended by striking "108(f)(4),".

(3) Section 414(t)(2) is amended by striking "117(d),".

(2) Section 132(j)(8) is amended by striking "which are not excludable from gross income under section 127".

(3) Section 137(c) is amended to read as follows:

"(2) ELIGIBILITY. -- The program shall benefit employees who qualify under a classification set up by the employer and found by the Secretary not to be discriminatory in favor of employees who are highly compensated employees (within the meaning of section 414(q)) or their dependents. For purposes of this paragraph, there shall be excluded from consideration employees not included in the program who are included in a unit of employees covered by an agreement which the Secretary of Labor finds to be a collective bargaining agreement between employee representatives and one or more employers, if there is evidence that adoption assistance benefits were the subject of good faith bargaining between such employee representatives and such employer or employers.

"(3) PRINCIPAL SHAREHOLDERS OR OWNERS. -- Not more than 5 percent of the amounts paid or incurred by the employer for adoption assistance during the year may be provided for the class of individuals who are shareholders or owners (or their spouses or dependents), each of whom (on any day of the year) owns more than 5 percent of the stock or of the capital or profits interest in the employer.

"(4) NOTIFICATION OF EMPLOYEES. -- Reasonable notification of the availability and terms of the program must be provided to eligible employees.

"(5) NO FUNDING REQUIRED. -- A program referred to in paragraph (1) is not required to be funded.

"(6) CERTAIN FEDERAL PROGRAMS. -- An adoption reimbursement program operated under section 1052 of title 10, United States Code (relating to armed forces) or section 514 of title 14, United States Code (relating to members of the Coast Guard) shall be treated as an adoption assistance program for purposes of this section.".

(4) Section 414(n)(3)(C) is amended by striking "127,".

(5) Section 414(t)(2) is amended by striking "127,".

(6) Section 3121(a)(18) is amended by striking "127,".

(7) Section

(8) Section 3231(e) is amended by striking paragraph (6).

(9) Section 3306(b)(13) is amended by striking "127,".

(10) Section 3401(a)(18) is amended by striking "127,".

(11) Section 6039D(d)(1) is amended by striking "127,".

(2) Section 129(e)(1) is amended to read as follows:

"(1) DEPENDENT CARE ASSISTANCE. --

(2) Subsections (d) and (e) of section 23 (prior to being stricken by subsection (a)) are each moved to section 137 (after amendment by paragraph (1)) and inserted after subsection (c) as new subsections (d) and (e), respectively.

(3) Section 137(d)(1)(D), as amended by paragraphs (1) and (2), is amended by inserting "(determined without regard to reimbursements under this section)" before the period at the end.

(4) Section 137(e), as amended by paragraphs (1) and (2), is amended by striking "(as defined in section 217(h)(3))" and inserting "(or any possession of the United States)".

(5) Section 137 is amended by redesignating subsection (f) as subsection (h), and by inserting before subsection (h) (as so redesignated) the following new subsections:

(2) SPECIAL NEEDS ADOPTIONS. -- For purposes of paragraph (1), any amount treated as paid by the taxpayer under section 23(a)(3) of the Internal Revenue Code of 1986 (as in effect before its repeal by subsection (a)) shall be treated as paid on the date that the adoption referred to in such section becomes final.

(2) Section 6501(m) is amended by striking "section 30(e)(6),".

(2) Section 1016(a) is amended by striking paragraph (35).

(3) Section 6501(m) is amended by striking "30B(h)(9),".

(2) Section 1016(a) is amended by striking paragraph (36).

(3) Section 6501(m) is amended by striking "30C(e)(5),".

(2) Section 1016(a) is amended by striking paragraph (37).

(3) Section 6501(m) is amended by striking "30D(e)(4),".

(2) Section 4980B(f)(5)(C)(iv)(II) is amended by inserting "as in effect before its repeal" after "section 35(c)".

(3) Section 6211(b)(4)(A) is amended by striking "35,".

(2) Section 1400C(e) is amended by striking paragraph (4).

(3) Section 6211(b)(4)(A) is amended by striking "36,".

(4) Section 6213(g)(2) is amended by striking subparagraphs (O) and (P).

(2) by striking "2 years" and inserting "5 years".

"(2) MODIFIED ADJUSTED GROSS INCOME. --

(2) The following provisions of section 121 are each amended by striking "5-year period" each place it appears therein and inserting "8-year period":

"(3) QUALIFIED RESIDENCE INTEREST. -- For purposes of this subsection --

"(2) SPECIAL RULE FOR CERTAIN PROPERTY. --

(3) CONFORMING AMENDMENTS. --

"(7) SPECIAL RULE WITH RESPECT TO GOLF COURSES. -- An interest in real property shall not be treated as a qualified real property interest for purposes of this subsection if (at the time of the contribution of such interest) such property is, or is reasonably expected to be, used as a golf course.".

(3) CONFORMING AMENDMENTS. --

(2) CONFORMING AMENDMENTS. -- Section 6050L is amended --

(2) QUALIFIED CONSERVATION CONTRIBUTIONS. -- The amendments made by subsection (e) shall apply to contributions made in taxable years beginning after December 31, 2013.

(2)(A) Section 216(a) is amended by striking "proportionate share of --" and all that follows and inserting "proportionate share of the interest allowable as a deduction to the corporation under section 163 which is paid or incurred by the corporation on its indebtedness contracted --

"(1) in the acquisition, construction, alteration, rehabilitation, or maintenance of the houses or apartment building, or

"(2) in the acquisition of the land on which the houses (or apartment building) are situated.".

(4) Section 280A(b) is amended by striking "TAXES," in the heading thereof.

(5) Section 911(c)(3)(A)(ii) is amended --

(2) Subsection (i) of section 165 is amended --

(6) Section 274(f) is amended by striking "CASUALTY LOSSES," in the heading thereof.

(7) Section 280A(b) is amended by striking "CASUALTY LOSSES," in the heading thereof.

(8) Section 873(b), as amended by the preceding provisions of this Act, is amended by striking paragraph (1) and by redesignating paragraphs (2) and (3) as paragraphs (1) and (2), respectively.

"(2) AMOUNTS PAID FOR CERTAIN LODGING AWAY FROM HOME TREATED AS PAID FOR MEDICAL CARE. -- Amounts paid for lodging (not lavish or extravagant under the circumstances) while away from home primarily for and essential to medical care referred to in paragraph (1)(A) shall be treated as amounts paid for medical care if --

"(3) PHYSICIAN. -- The term 'physician' has the meaning given to such term by section 1861(r) of the Social Security Act (42 U.S.C. 1395x(r)).

"(4) CONTRACTS COVERING OTHER THAN MEDICAL CARE. -- In the case of an insurance contract under which amounts are payable for other than medical care referred to in subparagraphs (A), (B) and (C) of paragraph (1) --

"(6) COSMETIC SURGERY. --

(4) Section 162(l) is amended by striking paragraph (3).

(5) Section 402(l) is amended by striking paragraph (7) and redesignating paragraph (8) as paragraph (7).

(6) Section 220(f) is amended by striking paragraph (6).

(7) Section 223(f) is amended by striking paragraph (6).

(8) Section 7702B(e) is amended by striking paragraph (2).

(9) Section 7705(f)(7), as redesignated by this Act, is amended by striking "sections 105(b), 132(h)(2)(B), and 213(d)(5)" and inserting "sections 105(b) and 132(h)(2)(B)".

(2) Part II of subchapter B of chapter 1 is amended by striking section 71 (and by striking the item relating to such section in the table of sections for such part).

(3) Subpart F of part I of subchapter J of chapter 1 is amended by striking section 682 (and by striking the item relating to such section in the table of sections for such subpart).

(2) any divorce or separation instrument (as so defined) executed on or before such date and modified after such date if the modification expressly provides that the amendments made by this section apply to such modification.

(2)(A) Section 132(a) is amended by striking paragraph (6).

(5) Section 3121(a) is amended by striking paragraph (11).

(6) Section 209(a) of the Social Security Act is amended by striking paragraph (9).

(7) Section 3306(b) is amended by striking paragraph (9).

(8) Section 3401(a) is amended by striking paragraph (15).

(9) Section 7872(f) is amended by striking paragraph (11).

(2) Section 106(d) is amended by striking paragraph (2), by redesignating paragraph (3) as paragraph (6), and by inserting after paragraph (1) the following new paragraphs:

"(2) NO CONSTRUCTIVE RECEIPT. -- No amount shall be included in the gross income of any employee solely because the employee may choose between the contributions referred to in paragraph (1) and employer contributions to another health plan of the employer.

"(3) SPECIAL RULE FOR DEDUCTION OF EMPLOYER CONTRIBUTIONS. -- Any employer contribution to a health savings account (as so defined), if otherwise allowable as a deduction under this chapter, shall be allowed only for the taxable year in which paid.

"(4) EMPLOYER HEALTH SAVINGS ACCOUNT CONTRIBUTION REQUIRED TO BE SHOWN ON RETURN. -- Every individual required to file a return under section 6012 for the taxable year shall include on such return the aggregate amount contributed by employers to the health savings accounts (as so defined) of such individual or such individual's spouse for such taxable year.

"(5) HEALTH SAVINGS ACCOUNT CONTRIBUTIONS NOT PART OF COBRA COVERAGE. -- Paragraph (1) shall not apply for purposes of section 4980B.".

(3) Section 223(b)(4) is amended by striking subparagraph (A) and by redesignating subparagraphs (B) and (C) as subparagraphs (A) and (B), respectively.

(4) Section 3231(e) is amended by striking paragraph (10) and by redesignating paragraphs (11) and (12) as paragraphs (10) and (11), respectively.

(5) Section 3306(b) is amended by striking paragraph (17).

(6) Section 3401(a) is amended by striking paragraph (21).

(7) Chapter 43 is amended by striking section 4980E (and by striking the item relating to such section in the table of sections for such chapter).

(8) Section 4980G is amended to read as follows:

"(2) COMPARABLE CONTRIBUTIONS. --

(10) Section 6051(a)(14)(A) is amended by striking "paragraphs (11) and (12)" and inserting "paragraph (12)".

(3) Section 302(b)(5) is amended by striking "section 67(c)(2)(B)" and inserting "section 562(c)(2)".

(4) Section 562(c) is amended --

(2) Section 414(n)(3)(C) is amended by striking "274(j),".

(3) Section 414(t)(2) is amended by striking "274(j),".

(4) Section 3121(a)(20) is amended by striking "74(c),".

(5) Section 209(a)(17) of the Social Security Act is amended by striking "74(c),".

(6) Section 3231(e)(5) is amended by striking "74(c),".

(7) Section 3306(b)(16) is amended by striking "74(c),".

(8) Section 3401(a)(19) is amended by striking "74(c),".

(2) by striking "deceased plan participant's beneficiary" and inserting "deceased employee's beneficiary who is not a surviving spouse, dependent (as so defined), or child (as so defined)".

(2) by inserting "or 501(c)(9)" after "section 115" in subparagraph (B) thereof.

"(2) LIMITATION TO 1 HOME. -- Subsections (a) and (d) (separately and in combination) shall not apply with respect to more than 1 residence of the taxpayer at any given time. In the case of a joint return, the preceding sentence shall apply separately to each spouse for any period during which each spouse resides separate from the other spouse in a residence which is provided in connection with the employment of each spouse, respectively.".

"(3) REGULATIONS. -- The Secretary may by regulations provide exceptions to the application of this subsection.".

"(2) STATEMENTS BY BENEFICIARIES. -- Each person required to file a return under section 6018(b) shall furnish to the Secretary and to each other person who holds a legal or beneficial interest in the property to which such return relates a statement identifying the information described in paragraph (1).

"(3) TIME FOR FURNISHING STATEMENT. --

"(2) situations in which the surviving joint tenant or other recipient may have better information than the executor regarding the basis or fair market value of the property.".

(2) PENALTY FOR FAILURE TO FILE. --

"(8) Any inconsistent estate basis.".

(2) INCONSISTENT BASIS REPORTING. -- Section 6662 is amended by adding at the end the following new subsection:

(2) APPLICATION OF ADJUSTMENTS. -- Section 1402(a) is amended by inserting "and such pro rata share of S corporation nonseparately computed income or loss" after "such distributive share of partnership ordinary income or loss" in the matter preceding paragraph (1).

(3) CONFORMING AMENDMENTS. -- Section 211(a) of the Social Security Act is amended in the matter preceding paragraph (1) --

(2) CONFORMING AMENDMENT. -- Section 211(a) of the Social Security Act is amended by striking paragraph (12).

"(3) 100 PERCENT DEDUCTION WHERE NO MATERIAL PARTICIPATION. --

"(3) 100 PERCENT DEDUCTION WHERE NO MATERIAL PARTICIPATION. --

(2) by inserting ", and the remuneration paid by the employer with respect to such service during such calendar year is less than the dollar amount in effect under section 213(d) of the Social Security Act (relating to amount required for a quarter of coverage) with respect to such year" before the semicolon at the end.

(2) by inserting ", if the remuneration paid by the employer with respect to such service during such calendar year is less than the dollar amount in effect under section 213(d) of the Social Security Act (relating to amount required for a quarter of coverage) with respect to such year" before the semicolon at the end.

(2) Revenue Ruling 58-128,

(3) Revenue Ruling 60-330,

(4) so much of the holding of Revenue Ruling 77-347 as relates to Plan (1) and Plan (2),

(5) Revenue Ruling 90-72, and

(6) any other ruling, regulation, or other guidance provided by the Secretary of the Treasury, or his designee, to the extent that such ruling, regulation, or guidance provides that any payment made by an employer by reason of involuntary termination of employment shall not be treated as wages or compensation for purposes of any provision of the Internal Revenue Code of 1986, shall be null and void. The preceding sentence shall not apply to the extent a ruling, regulation, or other guidance implements a statutory exception to wages or compensation.

(2) CONFORMING AMENDMENTS. --

"(2) the exemptions, exclusions, definitions, and other rules which are based on type of employer and which would (but for paragraph (1)) apply shall apply with respect to such taxes imposed on such remuneration.

"(2) a customer whose service contract with a certified professional employer organization is terminated with respect to a work site employee shall be treated as a successor employer and the certified professional employer organization shall be treated as a predecessor employer.

"(2) exemptions, exclusions, definitions, and other rules which are based on type of employer and which would (but for paragraph (1)) apply shall apply with respect to such taxes imposed on such remuneration.

"(2) agrees that it will satisfy the bond and independent financial review requirements of subsections (c) on an ongoing basis,

"(3) agrees that it will satisfy such reporting obligations as may be imposed by the Secretary,

"(4) computes its taxable income using an accrual method of accounting unless the Secretary approves another method,

"(5) agrees to verify on such periodic basis as the Secretary may prescribe that it continues to meet the requirements of this subsection, and

"(6) agrees to notify the Secretary in writing, within such time as the of Secretary may prescribe, of any change that materially affects the continuing accuracy of any agreement or information which was previously made or provided.

"(5) FAILURE TO FILE ASSERTION AND ATTESTATION. -- If the certified professional employer organization fails to file the assertion and attestation required by paragraph (3) with respect to any calendar quarter, then the requirements of paragraph (3) with respect to such failure shall be treated as not satisfied for the period beginning on the due date for such attestation.

"(6) AUDIT DATE. -- For purposes of paragraph (3)(A), the audit date shall be six months after the completion of the organization's fiscal year.

(2) CERTIFICATION PROGRAM. -- The Secretary of the Treasury shall establish the certification program described in section 7706(b) of the Internal Revenue Code of 1986, as added by this section, not later than 6 months before the effective date determined under paragraph (1).

(2) for purposes of any other provision of law.

(2) INDIVIDUAL RETIREMENT ANNUITIES. --

"(9) MARRIED INDIVIDUALS. -- The limitation under this subsection shall be computed separately for each individual, and this section shall be applied without regard to any community property laws.

"(10) SPECIAL RULE FOR COMPENSATION EARNED BY MEMBERS OF ARMED FORCES FOR SERVICES IN COMBAT ZONE. -- For purposes of paragraphs (1)(A)(ii) and (2), the amount of compensation includible in an individual's gross income shall be determined without regard to section 112.".

(6) AMENDMENTS RELATING TO EXCISE TAX ON EXCESS CONTRIBUTIONS. --

"(5) TIME WHEN CONTRIBUTIONS DEEMED MADE. -- For purposes of this section, a taxpayer shall be deemed to have made a contribution to a health savings account on the last day of the preceding taxable year if the contribution is made on account of such taxable year and is made not later than the time prescribed by law for filing the return for such taxable year (not including extensions thereof).

"(6) EMPLOYER PAYMENTS. -- Except as provided in section 106(d), for purposes of this title, any amount paid by an employer to a health savings account shall be treated as payment of compensation to the employee (other than a self-employed individual who is an employee within the meaning of section 401(c)(1)) includible in his gross income in the taxable year for which the amount was contributed, whether or not a deduction for such payment is allowable under this section to the employee.".

(2) Section 408A(d), as amended by this Act, is amended by striking paragraph (5) and by redesignating paragraph (6) as paragraph (5).

"(9) TERMINATION. -- This subsection shall not apply to years beginning after December 31, 2014. The preceding sentence shall not apply to any simplified employee pension of an employer if such simplified employee pension, and the terms thereof, meet the requirements of this subsection on and after such date.".

(2) Section 402(h) is amended by adding at the end the following new paragraph:

"(4) TERMINATION. -- This subsection shall not apply to any simplified employee pension the arrangement for which is established after December 31, 2014.".

(2) GOVERNMENT 457(b) PLANS. --

"(11) ROTH CONTRIBUTIONS. -- For purposes of this section --

"(12) INCREASE IN MAXIMUM LIMITATION FOR SIMPLE ROTH. -- In the case of any simple retirement account, subparagraphs (A)(i) and (B) of paragraph (1) shall be applied by disregarding any contributions made to a simple retirement account and any qualified rollover contributions.".

(3) CONFORMING AMENDMENTS. --

(2) SUBSECTION (c). -- The amendments made by subsection (c) shall apply to calendar years beginning after December 31, 2014.

(2) REQUIRED BEGINNING DATE. -- The amendment made by subsection (c) shall apply to employees becoming a 5-percent owner with respect to plan years ending in calendar years beginning before, on, or after the date of the enactment of this Act, except that --

(2) to make any other modifications necessary to carry out the purposes of section 401(k)(2)(B)(i)(IV) of the Internal Revenue Code of 1986.

(2) ELIMINATION OF POST TERMINATION NON-ELECTIVE CONTRIBUTIONS. -- Subsection (b) of section 403 is amended --

(4) ELIMINATION OF SEPARATE 415(c) LIMITS. -- Paragraph (4) of section 415(k) is amended by striking "each employer with respect to which the participant has the control required" and inserting "the employer and each employer which is part of a controlled group or under common control".

(4) Section 414(u)(2)(C) is amended by inserting "by an eligible employer described in section 457(e)(1)(B)" after "(as defined in section 457(b))".

(5) Section 414(v)(2)(D) is amended --

(7) Section 414(v)(6)(B) is amended by striking "subsection (u)(2)(C)" and inserting "section 402(g)(3)".

(8) Section 414(v)(6) is amended by striking subparagraph (C).

(2) INFLATION ADJUSTMENT. -- Section 415(d) is amended --

(2) INFLATION ADJUSTMENT. -- Subsection (d) of section 415 is amended --

(2) Section 415(b) is amended by striking "$160,000" in the fourth sentence of paragraph (7) and inserting "$210,000".

(3) The headings for subparagraphs (C) and (D) of section 415(b)(2) are each amended by striking "$160,000" and inserting "$210,000".

(4) The heading for subparagraph (A) of section 415(d)(3) is amended by striking "$160,000" and inserting "$210,000".

(5) The heading for subparagraph (D) of section 415(d)(3) is amended by striking "$40,000" and inserting "$52,000".

(6) The heading for subparagraph (A) of section 415(d)(4) is amended by striking "$160,000" and inserting "$210,000".

(7) The heading for subparagraph (B) of section 415(d)(4) is amended by striking "$40,000" and inserting "$52,000".

(2) by striking "$15,000" and inserting "$17,500", and

(3) by striking "2005" and inserting "2022".

(2) by striking "$10,000" and inserting "$12,000",

(3) by striking "2004" and inserting "2022".

(2) SIMPLE 401(k) AND SIMPLE RETIREMENT ACCOUNTS. -- Clause (ii) of section 414(v)(2)(B) is amended by striking "determined in accordance with the following table" and all that follows through the period at the end and inserting "$2,500.".

(2) by striking "$5,000" and inserting "$5,500", and

(3) by striking "2005" and inserting "2022".

(2) by striking "the $15,000 amount under subparagraph (A)" and inserting "the $17,500 amount under subsection (b)(2)(A)", and

(3) by striking "2005" and inserting "2022".

"(2) the benefits provided under such program --

"(2) DEPENDENT. -- The term 'dependent' has the meaning given such term by section 7705, determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B).

"(3) LAVISH OR EXTRAVAGANT. -- The Secretary shall, in consultation with the Tribal Advisory Committee (as established under section 1702 of the Tax Reform Act of 2014), establish guidelines for what constitutes lavish or extravagant benefits with respect to Indian tribal government programs.

"(4) ESTABLISHMENT OF TRIBAL GOVERNMENT PROGRAM. -- A program shall not fail to be treated as an Indian tribal government program solely by reason of the program being established by tribal custom or government practice.".

(2) ONE-YEAR WAIVER OF STATUTE OF LIMITATIONS. -- If the period of limitation on a credit or refund resulting from the amendments made by subsection (a) expires before the end of the 1-year period beginning on the date of the enactment of this Act, refund or credit of such overpayment (to the extent attributable to such amendments) may, nevertheless, be made or allowed if claim therefor is filed before the close of such 1-year period.

(2) EDUCATION AND TRAINING. -- The Secretary shall, in consultation with the Committee, establish and require --

(2) INDIAN TRIBE. -- The term "Indian tribe" shall have the meaning given such term by section 139D(c)(1) of such Code, as amended by this Act.

"(2) AMT REFUNDABLE CREDIT AMOUNT. -- For purposes of paragraph (1), the AMT refundable credit amount is an amount equal to 50 percent (100 percent in the case of a taxable year beginning in 2019) of the excess (if any) of --

"(4) SHORT TAXABLE YEARS. -- In the case of any taxable year of less than 365 days, the AMT refundable credit amount determined under paragraph (2) with respect to such taxable year shall be the amount which bears the same ratio to such amount determined without regard to this paragraph as the number of days in such taxable year bears to 365.".

(3) TREATMENT OF REFERENCES. -- Section 53(d) is amended by adding at the end the following new paragraph:

"(3) AMT TERM REFERENCES. -- Any references in this subsection to section 55, 56, or 57 shall be treated as a reference to such section as in effect before its repeal by the Tax Reform Act of 2014.".

(4) REPEAL OF SPECIAL RULES WITH RESPECT TO TREATMENT OF INCENTIVE STOCK OPTIONS. -- Section 53 is amended by striking subsection (f).

(2) Section 5(a) is amended by striking paragraph (4).

(3) Section 11(d) is amended by striking "the taxes imposed by subsection (a) and section 55" and inserting "the tax imposed by subsection (a)".

(4) Section 13, as redesignated by title I, is amended by striking paragraph (7).

(5) Section 26(a) is amended to read as follows:

(7) Section 26 is amended by striking subsection (c).

(8) Section 38(c) is amended --

(10) Section 54(c)(1) is amended to read as follows:

"(1) regular tax liability (as defined in section 26(b)), over".

(11) Section 54A(c)(1)(A) is amended to read as follows:

(14) Section 173 is amended by striking subsection (b).

(15) Section 174(f) is amended to read as follows:

(17) Section 382(l) is amended by striking paragraph (7) and by redesignating paragraph (8) as paragraph (7).

(18) Section 443 (relating to returns for a period of less than 12 months) adjustment in computing minimum tax and tax preferences) is amended by striking subsection (d) and by redesignating subsection (e) as subsection (d).

(19) Section 641(c) is amended --

(21) Section 815(c)(2) is amended by striking the last sentence.

(22) Section 847 is amended --

(24) Section 860E(a) is amended by striking paragraph (4).

(25) Section 871(b)(1) is amended by striking "or 55".

(26) Section 882(a)(1) is amended by striking "55,".

(27) Section 897(a) is amended to read as follows:

"(2) in the case of a foreign corporation, under section 882(a)(1), as if the taxpayer were engaged in a trade or business within the United States during the taxable year and as if such gain or loss were effectively connected with such trade or business.".

(28) Section 904(k) is amended to read as follows:

"(2) the tax which would be imposed by section 1 for such taxable year if the taxpayer's taxable income were equal to the amount excluded under subsection (a) for such taxable year.".

(30) Section 962(a)(1) is amended --

(32) Section 1202(a)(4) is amended by inserting "and" at the end of subparagraph (A), by striking ", and" and inserting a period at the end of subparagraph (B), and by striking subparagraph (C).

(33) Section 1374(b)(3)(B) is amended by striking the last sentence thereof.

(34) Section 1397E(c)(1) is amended to read as follows:

"(1) regular tax liability (as defined in section 26(b), over".

(35) Section 1561(a) is amended --

(37) Section 6425(c)(1)(A) is amended --

(2) PRIOR ELECTIONS WITH RESPECT TO CERTAIN TAX PREFERENCES. -- So much of the amendment made by subsection (a) as relates to the repeal of section 59(e) of the Internal Revenue Code of 1986 shall apply to amounts paid or incurred after December 31, 2014.

(3) TREATMENT OF NET OPERATING LOSS CARRYBACKS. -- For purposes of section 56(d) of the Internal Revenue Code of 1986 (as in effect before its repeal), the amount of any net operating loss which may be carried back from a taxable year beginning after December 31, 2014, to taxable years beginning before January 1, 2015, shall be determined without regard to any adjustments under section 56(d)(2)(A) of such Code (as so in effect).

"(2) PHASE-IN FOR TAXABLE YEARS BEGINNING BEFORE 2019. --

(2)(A) Part I of subchapter P of chapter 1 is amended by striking section 1201 (and by striking the item relating to such section in the table of sections for such part).

(E) Section 691(c)(4) is amended by striking "1201,".

(F) Section 801(a) is amended --

(5)(A) Part I of subchapter B of chapter 5 is amended by striking section 1551 (and by striking the item relating to such section in the table of sections for such part).

(6)(A) Section 1561, as amended by the preceding provisions of this Act, is amended to read as follows:

(2) WITHHOLDING. -- The amendments made by subsection (b)(3) shall apply to distributions made after December 31, 2014.

(3) CERTAIN TRANSFERS. -- The amendments made by subsection (b)(5) shall apply to transfers made after December 31, 2018.

(4) CERTAIN OTHER AMENDMENTS RELATED TO SINGLE RATE OF TAX. -- The amendments made by paragraphs (4) and (6) of subsection (b) shall apply to taxable years beginning after December 31, 2018.

"(2) any premium received by such entity with respect to any option on any interest in such entity.

"(3) APPLICATION TO ENTITIES OTHER THAN CORPORATIONS. -- In the case of any entity other than a corporation, rules similar to the rules of paragraphs (1) and (2) shall apply in the case of any contribution of money or other property to such entity in exchange for any interest in such entity.

"(2) the amount included in gross income by such corporation under section 76 with respect to such contribution.".

(2) CONTRIBUTIONS IN EXCHANGE FOR STOCK. -- Paragraph (2) of section 362(a) is amended by striking "contribution to capital" and inserting "contribution in exchange for stock of such corporation (determined under rules similar to the rules of paragraphs (2) and (3) of section 76(b))".

(2) Part III of subchapter B of chapter 1 is amended by striking section 118 (and by striking the item relating to such section in the table of sections for such part).

(3) The table of sections for part II of subchapter B of chapter 1 is amended by inserting after the item relating to section 75 the following new item:

"(2) ELECTION TO EXPENSE REPAIR IN LIEU OF DEDUCTING CASUALTY LOSS. -- If the taxpayer elects the application of this paragraph with respect to any property with respect to which there is a casualty loss, no deduction shall be allowable under this section for the casualty loss with respect to such property and paragraph (1) shall not apply to expenditures made for repair of damage to such property in connection with such casualty loss. Any election under this paragraph shall be made not later than the due date for the return of tax (including extensions) for the taxable year in which the casualty loss occurs and, once made, may be revoked only with the consent of the Secretary.".

"(2) SALVAGE VALUE TREATED AS ZERO. -- Salvage value shall be treated as zero.".

"(2) SPECIAL RULES FOR DETERMINING CLASS LIFE OF CERTAIN PROPERTY. --

"(3) INFLATION ADJUSTMENT PERCENTAGE. -- For purposes of this subsection, the term 'inflation adjustment percentage' means, with respect to any calendar year, the cost-of-living adjustment which would be determined under section 1(c)(2)(A) for such calendar year if clause (ii) thereof were applied by substituting 'the C-CPI-U for the calendar year preceding the calendar year referred to in clause (i)' for 'the normalized CPI for calendar year 2012'.

"(4) INCREASE FOR FIRST TAXABLE YEAR REDUCED TO TAKE INTO ACCOUNT PLACED IN SERVICE CONVENTION. -- In the case of the taxable year in which any property is placed in service, the increase determined under paragraph (1) with respect to such property shall be equal to --

"(6) CERTAIN PROPERTY EXCLUDED. -- Paragraph (1) shall not apply to any specified property used outside the United States or to any property described in subsection (d)(2).

"(7) ELECTION. --

"(3) QUALIFIED LEASEHOLD IMPROVEMENT PROPERTY. -- For purposes of this subsection --

"(5) QUALIFIED RETAIL IMPROVEMENT PROPERTY. --

(2) ALTERNATIVE METHOD FOR CERTAIN TAXPAYERS. -- If, as of the first day of the taxable year that includes the date of enactment of this Act --

(2) Section 1250(b)(3) is amended by inserting "(as in effect before its repeal by the Tax Reform Act of 2014)" after "169".

(2) COORDINATION WITH LIMITATION ON DEDUCTION FOR CHARITABLE CONTRIBUTIONS. --

(2) CONFORMING AMENDMENTS. --

"(2) the taxpayer shall --

"(2) the taxpayer shall --

"(2) EXPLORATION EXPENDITURES. -- This section shall not apply to any expenditure paid or incurred for the purpose of ascertaining the existence, location, extent, or quality of any deposit of ore or other mineral (including oil and gas).

"(3) SOFTWARE DEVELOPMENT. -- For purposes of this section, any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure.

(2) ASSESSMENTS TREATED AS PAID OR INCURRED. -- In the case of any amount paid or incurred before December 31, 2014, and treated as paid or incurred in any succeeding taxable year by reason of section 175(f) of the Internal Revenue Code of 1986 (as in effect on the day before the date of the enactment of this Act), paragraph (1) shall not apply.

"(2) the taxpayer shall --

"(2) PHASEOUT OF EXEMPTION. -- In the case of a taxpayer whose otherwise deductible advertising expenses for any taxable year exceed $1,500,000, the dollar amount in effect under paragraph (1) with respect to such taxpayer for such taxable year shall be reduced (but not below zero) by twice such excess.

"(3) AGGREGATION; SHORT TAXABLE YEARS. -- For purposes of this subsection, rules similar to the rules of paragraphs (2) and (3)(B) of section 448(b) shall apply.

"(2) APPLICABLE PERCENTAGE. -- For purposes of this subsection, the term 'applicable percentage' means (with respect to the taxpayer's otherwise deductible advertising expenses for any taxable year) the percentage determined in accordance with the following table:

"(2) SPECIFIED ADVERTISING EXPENSES. -- The term 'specified advertising expenses' means any amount paid or incurred for the development, production, or placement (including any form of transmission, broadcast, publication, display, or distribution) of any communication to the general public (or portions thereof) which is intended to promote the taxpayer or a trade or business of the taxpayer (or any service, facility, or product provided pursuant to such trade or business).

"(3) EXCEPTIONS. -- The term 'specified advertising expenses' shall not include --

(2) REDUCTION IN LIMITATION. -- Paragraph (2) of section 179(b) is amended by striking "exceeds --" and all that follows and inserting "exceeds $800,000.".

(2) by striking "IRREVOCABLE" in the heading thereof.

(2) by striking paragraphs (3) and (4).

(2) Section 312(k)(3), as amended by the preceding provisions of this Act, is amended by striking ", 179D" each place it appears.

(2) by striking ", or 179E" each place it appears.

"(2) the taxpayer shall --

(2) Section 167(f) is amended by striking paragraph (3).

"(2) the taxpayer shall --

(2) Section 198 (and the item relating to such section in the table of sections for part VI of subchapter B of chapter 1) is amended by striking "EXPENSING" in the heading thereof and inserting "AMORTIZATION".

"(3) PHASEOUT. -- In the case of any taxable year beginning after 2014, paragraph (1) shall be applied by substituting for the percentage contained therein the phaseout percentage determined under the following table:

(3) EFFECTIVE DATE. -- The amendments made by this subsection shall apply to taxable years beginning after December 31, 2014.

(2) CONFORMING AMENDMENTS. --