S.Amdt. 2540

1. Adds SEC. __. MODIFICATIONS TO IMPLEMENTATION OF INCREASES IN TAX RATES ON INVESTMENT INCOME at the end of the bill

   Adds a section

   In S. 2237 · Placed on Calendar Senate

   (ii) multiplying the limitation under subparagraph (B)(ii) of such paragraph (as so in effect) by a fraction the numerator of which is the number of days in the taxable year after December 31, 2011, and the denominator of which is the number of days in the taxable year.

   Inserted: SEC. __. MODIFICATIONS TO IMPLEMENTATION OF INCREASES IN TAX RATES ON INVESTMENT INCOME.

   Inserted: (a) Rates on Capital Gains and Dividends.--Section 303 of the Jobs and Growth Tax Relief Reconciliation Act of 2003 is amended--

   Inserted: (1) by striking "All" and inserting the following:

   Inserted: "(a) In General.--All",

   Inserted: (2) by striking "to taxable years beginning after December 31, 2012" and inserting "to the first termination taxable year and to all taxable years after such first termination taxable year", and

   Inserted: (3) by adding at the end the following new subsection:

   Inserted: "(b) Termination Taxable Year.--For purposes of this section--

   Inserted: "(1) In general.--The term 'termination taxable year' means, with respect to any taxpayer, the later of--

   Inserted: "(A) the first taxable year beginning after December 31, 2012, or

   Inserted: "(B) the first taxable year ending after the date on which both the integrated capital gains rate and the integrated dividend rate do not exceed the average integrated OECD rate.

   Inserted: "(2) Integrated capital gains rate.--The term 'integrated capital gains rate' means the sum of--

   Inserted: "(A) the highest rate of tax imposed on corporations under section 11 of the Internal Revenue Code of 1986,

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   Inserted: "(B) the average of the highest rate of tax imposed on corporations under the laws of the States,

   Inserted: "(C) the highest rate of tax imposed on capital gains under section 1 of such Code, and

   Inserted: "(D) the rate of tax imposed under section 1411 of such Code.

   Inserted: "(3) Integrated dividends rate.--The term 'integrated dividends rate' means the sum of--

   Inserted: "(A) the highest rate of tax imposed on corporations under section 11 of the Internal Revenue Code of 1986,

   Inserted: "(B) the average of the highest rate of tax imposed on corporations under the laws of the States,

   Inserted: "(C) the highest rate of tax imposed on dividends under section 1 of such Code, and

   Inserted: "(D) the rate of tax imposed under section 1411 of such Code.

   Inserted: "(4) Average integrated oecd rate.--The term 'average integrated OECD rate' means the average of the highest rates of tax imposed on corporations (including taxes imposed by regional, local, or sub-central authorities) by countries with membership in the Organisation of Economic Co-operation and Development.".

   Inserted: (b) Additional Tax on Unearned Income.--Section 1411(e) of the Internal Revenue Code of 1986 is amended by striking "or" at the end of paragraph (1), by striking the period at the end of paragraph (2) and inserting ", or", and by adding at the end the following new paragraph:

   Inserted: "(3) to any other taxpayer for any taxable year ending before the date on which both the integrated capital gains rate and the integrated dividend tax rate do not exceed the average integrated OECD rate (as such terms are defined under section 303(b) of the Jobs and Growth Tax Relief Reconciliation Act of 2003).".

   Original wording

   At the end, add the following:

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As printed