S.Amdt. 2440

SA 2440. Mr. REID (for Mr. Sanders) submitted an amendment intended
to

[[Page S5852]]

be proposed to amendment SA 2266 proposed by Mr. McConnell to the bill
H.R. 22, to amend the Internal Revenue Code of 1986 to exempt employees
with health coverage under TRICARE or the Veterans Administration from
being taken into account for purposes of determining the employers to
which the employer mandate applies under the Patient Protection and
Affordable Care Act; which was ordered to lie on the table; as follows:

Strike title LII of division E and insert the following:

TITLE LII--OFFSETS

Subtitle A--Tax Provisions

SEC. 52101. CONSISTENT BASIS REPORTING BETWEEN ESTATE AND
PERSON ACQUIRING PROPERTY FROM DECEDENT.

(a) Property Acquired From a Decedent.--
(1) In general.--Section 1014 of the Internal Revenue Code
of 1986 is amended by adding at the end the following new
subsection:
``(f) Basis Must Be Consistent With Estate Tax Value.--
``(1) In general.--The basis under subsection (a) of any
property shall not exceed--
``(A) in the case of property the value of which has been
finally determined for purposes of the tax imposed by chapter
11 on the estate of such decedent, such value, and
``(B) in the case of property not described in subparagraph
(A) and with respect to which a statement has been furnished
under section 6035(a) identifying the value of such property,
such value.
``(2) Determination.--For purposes of paragraph (1), the
value of property has been finally determined for purposes of
the tax imposed by chapter 11 if--
``(A) the value of such property is shown on a return under
section 6018 and such value is not contested by the Secretary
before the expiration of the time for assessing a tax under
chapter 11,
``(B) in a case not described in subparagraph (A), the
value is specified by the Secretary and such value is not
timely contested by the executor of the estate, or
``(C) the value is determined by a court or pursuant to a
settlement agreement with the Secretary.
``(3) Regulations.--The Secretary may by regulations
provide exceptions to the application of this subsection.''.
(2) Effective date.--The amendments made by this subsection
shall apply to property with respect to which an estate tax
return is filed after the date of the enactment of this Act.
(b) Information Reporting.--
(1) In general.--Subpart A of part III of subchapter A of
chapter 61 of the Internal Revenue Code of 1986 is amended by
inserting after section 6034A the following new section:

``SEC. 6035. BASIS INFORMATION TO PERSONS ACQUIRING PROPERTY
FROM DECEDENT.

``(a) Information With Respect to Property Acquired From
Decedents.--
``(1) In general.--The executor of any estate required to
file a return under section 6018(a) shall furnish to the
Secretary and to each person acquiring any interest in
property included in the decedent's gross estate for Federal
estate tax purposes a statement identifying the value of each
interest in such property as reported on such return and such
other information with respect to such interest as the
Secretary may prescribe.
``(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.--
``(A) In general.--Each statement required to be furnished
under paragraph (1) or (2) shall be furnished at such time as
the Secretary may prescribe, but in no case at a time later
than the earlier of--
``(i) the date which is 30 days after the date on which the
return under section 6018 was required to be filed (including
extensions, if any), or
``(ii) the date which is 30 days after the date such return
is filed.
``(B) Adjustments.--In any case in which there is an
adjustment to the information required to be included on a
statement filed under paragraph (1) or (2) after such
statement has been filed, a supplemental statement under such
paragraph shall be filed not later than the date which is 30
days after such adjustment is made.
``(b) Regulations.--The Secretary shall prescribe such
regulations as necessary to carry out this section, including
regulations relating to--
``(1) the extension of this section to property of estates
not required to file an estate tax return, and
``(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.--
(A) Return.--Section 6724(d)(1) of such Code is amended by
striking ``and'' at the end of subparagraph (B), by striking
the period at the end of subparagraph (C) and inserting ``,
and'', and by adding at the end the following new
subparagraph:
``(D) any statement required to be filed with the Secretary
under section 6035.''.
(B) Statement.--Section 6724(d)(2) of such Code is amended
by striking ``or'' at the end of subparagraph (GG), by
striking the period at the end of subparagraph (HH) and
inserting ``, or'', and by adding at the end the following
new subparagraph:

``(II) section 6035 (other than a statement described in
paragraph (1)(D)).''.

(3) Clerical amendment.--The table of sections for subpart
A of part III of subchapter A of chapter 61 of such Code is
amended by inserting after the item relating to section 6034A
the following new item:

``SEC. 6035. BASIS INFORMATION TO PERSONS ACQUIRING PROPERTY
FROM DECEDENT.''.

(4) Effective date.--The amendments made by this subsection
shall take effect on the date of the enactment of this Act.
(c) Penalty for Inconsistent Reporting.--
(1) In general.--Subsection (b) of section 6662 of the
Internal Revenue Code of 1986 is amended by inserting after
paragraph (7) the following new paragraph:
``(8) Any inconsistent estate basis.''.
(2) Inconsistent basis reporting.--Section 6662 of such
Code is amended by adding at the end the following new
subsection:
``(k) Inconsistent Estate Basis Reporting.--For purposes of
this section, there is an `inconsistent estate basis' if the
basis of property (determined without regard to adjustments
to basis during the period the property was held by the
taxpayer) claimed on a return exceeds the basis as determined
under section 1014(f).''.
(3) Effective date.--The amendments made by this subsection
shall apply to returns filed after the date of the enactment
of this Act.

SEC. 52102. REVOCATION OR DENIAL OF PASSPORT IN CASE OF
CERTAIN UNPAID TAXES.

(a) In General.--Subchapter D of chapter 75 of the Internal
Revenue Code of 1986 is amended by adding at the end the
following new section:

``SEC. 7345. REVOCATION OR DENIAL OF PASSPORT IN CASE OF
CERTAIN TAX DELINQUENCIES.

``(a) In General.--If the Secretary receives certification
by the Commissioner of Internal Revenue that any individual
has a seriously delinquent tax debt in an amount in excess of
$50,000, the Secretary shall transmit such certification to
the Secretary of State for action with respect to denial,
revocation, or limitation of a passport pursuant to section
52102(d) of the Transportation Funding Act of 2015.
``(b) Seriously Delinquent Tax Debt.--For purposes of this
section, the term `seriously delinquent tax debt' means an
outstanding debt under this title for which a notice of lien
has been filed in public records pursuant to section 6323 or
a notice of levy has been filed pursuant to section 6331,
except that such term does not include--
``(1) a debt that is being paid in a timely manner pursuant
to an agreement under section 6159 or 7122, and
``(2) a debt with respect to which collection is suspended
because a collection due process hearing under section 6330,
or relief under subsection (b), (c), or (f) of section 6015,
is requested or pending.
``(c) Adjustment for Inflation.--In the case of a calendar
year beginning after 2016, the dollar amount in subsection
(a) shall be increased by an amount equal to--
``(1) such dollar amount, multiplied by
``(2) the cost-of-living adjustment determined under
section 1(f)(3) for the calendar year, determined by
substituting `calendar year 2015' for `calendar year 1992' in
subparagraph (B) thereof.
If any amount as adjusted under the preceding sentence is not
a multiple of $1,000, such amount shall be rounded to the
next highest multiple of $1,000.''.
(b) Clerical Amendment.--The table of sections for
subchapter D of chapter 75 of the Internal Revenue Code of
1986 is amended by adding at the end the following new item:

``Sec. 7345. Revocation or denial of passport in case of certain tax
delinquencies.''.
(c) Authority for Information Sharing.--
(1) In general.--Subsection (l) of section 6103 of the
Internal Revenue Code of 1986 is amended by adding at the end
the following new paragraph:
``(23) Disclosure of return information to department of
state for purposes of passport revocation under section
7345.--
``(A) In general.--The Secretary shall, upon receiving a
certification described in section 7345, disclose to the
Secretary of State return information with respect to a
taxpayer who has a seriously delinquent tax debt described in
such section. Such return information shall be limited to--
``(i) the taxpayer identity information with respect to
such taxpayer, and
``(ii) the amount of such seriously delinquent tax debt.
``(B) Restriction on disclosure.--Return information
disclosed under subparagraph (A) may be used by officers and
employees of the Department of State for the purposes of, and
to the extent necessary in, carrying out the requirements of
section 52102(d) of the Transportation Funding Act of
2015.''.
(2) Conforming amendment.--Paragraph (4) of section 6103(p)
of such Code is amended by striking ``or (22)'' each place it
appears in subparagraph (F)(ii) and in the matter preceding
subparagraph (A) and inserting ``(22), or (23)''.

[[Page S5853]]

(d) Authority to Deny or Revoke Passport.--
(1) Denial.--
(A) In general.--Except as provided under subparagraph (B),
upon receiving a certification described in section 7345 of
the Internal Revenue Code of 1986 from the Secretary of the
Treasury, the Secretary of State shall not issue a passport
to any individual who has a seriously delinquent tax debt
described in such section.
(B) Emergency and humanitarian situations.--Notwithstanding
subparagraph (A), the Secretary of State may issue a
passport, in emergency circumstances or for humanitarian
reasons, to an individual described in such subparagraph.
(2) Revocation.--
(A) In general.--The Secretary of State may revoke a
passport previously issued to any individual described in
paragraph (1)(A).
(B) Limitation for return to united states.--If the
Secretary of State decides to revoke a passport under
subparagraph (A), the Secretary of State, before revocation,
may--
(i) limit a previously issued passport only for return
travel to the United States; or
(ii) issue a limited passport that only permits return
travel to the United States.
(3) Hold harmless.--The Secretary of the Treasury and the
Secretary of State shall not be liable to an individual for
any action with respect to a certification by the
Commissioner of Internal Revenue under section 7345 of the
Internal Revenue Code of 1986.
(e) Revocation or Denial of Passport in Case of Individual
Without Social Security Account Number.--
(1) Denial.--
(A) In general.--Except as provided under subparagraph (B),
upon receiving an application for a passport from an
individual that either--
(i) does not include the social security account number
issued to that individual, or
(ii) includes an incorrect or invalid social security
number willfully, intentionally, negligently, or recklessly
provided by such individual,
the Secretary of State is authorized to deny such application
and is authorized to not issue a passport to the individual.
(B) Emergency and humanitarian situations.--Notwithstanding
subparagraph (A), the Secretary of State may issue a
passport, in emergency circumstances or for humanitarian
reasons, to an individual described in subparagraph (A).
(2) Revocation.--
(A) In general.--The Secretary of State may revoke a
passport previously issued to any individual described in
paragraph (1)(A).
(B) Limitation for return to united states.--If the
Secretary of State decides to revoke a passport under
subparagraph (A), the Secretary of State, before revocation,
may--
(i) limit a previously issued passport only for return
travel to the United States; or
(ii) issue a limited passport that only permits return
travel to the United States.
(f) Effective Date.--The provisions of, and amendments made
by, this section shall take effect on January 1, 2016.

SEC. 52103. CLARIFICATION OF 6-YEAR STATUTE OF LIMITATIONS IN
CASE OF OVERSTATEMENT OF BASIS.

(a) In General.--Subparagraph (B) of section 6501(e)(1) of
the Internal Revenue Code of 1986 is amended--
(1) by striking ``and'' at the end of clause (i), by
redesignating clause (ii) as clause (iii), and by inserting
after clause (i) the following new clause:
``(ii) An understatement of gross income by reason of an
overstatement of unrecovered cost or other basis is an
omission from gross income; and'',
(2) by inserting ``(other than in the case of an
overstatement of unrecovered cost or other basis)'' in clause
(iii) (as so redesignated) after ``In determining the amount
omitted from gross income'', and
(3) by inserting ``amount omitted from'' after
``Determination of'' in the heading thereof.
(b) Effective Date.--The amendments made by this section
shall apply to--
(1) returns filed after the date of the enactment of this
Act, and
(2) returns filed on or before such date if the period
specified in section 6501 of the Internal Revenue Code of
1986 (determined without regard to such amendments) for
assessment of the taxes with respect to which such return
relates has not expired as of such date.

SEC. 52104. ADDITIONAL INFORMATION ON RETURNS RELATING TO
MORTGAGE INTEREST.

(a) In General.--Paragraph (2) of section 6050H(b) of the
Internal Revenue Code of 1986 is amended by striking ``and''
at the end of subparagraph (C), by redesignating subparagraph
(D) as subparagraph (G), and by inserting after subparagraph
(C) the following new subparagraphs:
``(D) the unpaid balance with respect to such mortgage at
the close of the calendar year,
``(E) the address of the property securing such mortgage,
``(F) the date of the origination of such mortgage, and''.
(b) Payee Statements.--Subsection (d) of section 6050H of
the Internal Revenue Code of 1986 is amended by striking
``and'' at the end of paragraph (1), by striking the period
at the end of paragraph (2) and inserting ``, and'', and by
inserting after paragraph (2) the following new paragraph:
``(3) the information required to be included on the return
under subparagraphs (D), (E), and (F) of subsection
(b)(2).''.
(c) Effective Date.--The amendments made by this section
shall apply to returns and statements the due date for which
(determined without regard to extensions) is after December
31, 2016.

SEC. 52105. RETURN DUE DATE MODIFICATIONS.

(a) New Due Date for Partnership Form 1065, S Corporation
Form 1120S, and C Corporation Form 1120.--
(1) Partnerships.--
(A) In general.--Section 6072 of the Internal Revenue Code
of 1986 is amended by adding at the end the following new
subsection:
``(f) Returns of Partnerships.--Returns of partnerships
under section 6031 made on the basis of the calendar year
shall be filed on or before the 15th day of March following
the close of the calendar year, and such returns made on the
basis of a fiscal year shall be filed on or before the 15th
day of the third month following the close of the fiscal
year.''.
(B) Conforming amendment.--Section 6072(a) of such Code is
amended by striking ``6017, or 6031'' and inserting ``or
6017''.
(2) S corporations.--
(A) In general.--So much of subsection (b) of section 6072
of the Internal Revenue Code of 1986 as precedes the second
sentence thereof is amended to read as follows:
``(b) Returns of Certain Corporations.--Returns of S
corporations under sections 6012 and 6037 made on the basis
of the calendar year shall be filed on or before the 31st day
of March following the close of the calendar year, and such
returns made on the basis of a fiscal year shall be filed on
or before the last day of the third month following the close
of the fiscal year.''.
(B) Conforming amendments.--
(i) Section 1362(b) of such Code is amended--

(I) by striking ``15th'' each place it appears and
inserting ``last'',
(II) by striking ``2\1/2\'' each place it appears in the
headings and the text and inserting ``3'', and
(III) by striking ``2 months and 15 days'' in paragraph (4)
and inserting ``3 months''.

(ii) Section 1362(d)(1)(C)(i) of such Code is amended by
striking ``15th'' and inserting ``last''.
(iii) Section 1362(d)(1)(C)(ii) of such Code is amended by
striking ``such 15th day'' and inserting ``the last day of
the 3d month thereof''.
(3) Conforming amendments relating to c corporations.--
(A) Section 170(a)(2)(B) of such Code is amended by
striking ``third month'' and inserting ``4th month''.
(B) Section 563 of such Code is amended by striking ``third
month'' each place it appears and inserting ``4th month''.
(C) Section 1354(d)(1)(B)(i) of such Code is amended by
striking ``3d month'' and inserting ``4th month''.
(D) Subsection (a) and (c) of section 6167 of such Code are
each amended by striking ``third month'' and inserting ``4th
month''.
(E) Section 6425(a)(1) of such Code is amended by striking
``third month'' and inserting ``4th month''.
(F) Section 6655 of such Code is amended--
(i) by striking ``3rd month'' each place it appears in
subsections (b)(2)(A), (g)(3), and (h)(1) and inserting ``4th
month'', and
(ii) in subsection (g)(4), by redesignating subparagraph
(E) as subparagraph (F) and by inserting after subparagraph
(D) the following new subparagraph:
``(E) Subsection (b)(2)(A) shall be applied by substituting
`the last day of the 3rd month' for `the 15th day of the 4th
month'.''.
(4) Effective dates.--
(A) In general.--Except as otherwise provided in this
paragraph, the amendments made by this subsection shall apply
to returns for taxable years beginning after December 31,
2015.
(B) Conforming amendments relating to s corporations.--The
amendments made by paragraph (2)(B) shall apply with respect
to elections for taxable years beginning after December 31,
2015.
(C) Conforming amendments relating to c corporations.--The
amendments made by paragraph (3) shall apply to taxable years
beginning after December 31, 2015.
(5) Special rule for certain c corporation in 2025.--In the
case of a taxable year of a C Corporation ending on June 30,
2025, section 6072(a) of the Internal Revenue Code of 1986
shall be applied by substituting ``third month'' for ``fourth
month''.
(b) Modification of Due Dates by Regulation.--In the case
of returns for any taxable period beginning after December
31, 2015, the Secretary of the Treasury or the Secretary's
delegate shall modify appropriate regulations to provide as
follows:
(1) The maximum extension for the returns of partnerships
filing Form 1065 shall be a 6-month period beginning on the
due date for filing the return (without regard to any
extensions).
(2) The maximum extension for the returns of trusts and
estates filing Form 1041 shall be a 5\1/2\-month period
beginning on the due date for filing the return (without
regard to any extensions).
(3) The maximum extension for the returns of employee
benefit plans filing Form 5500 shall be an automatic 3\1/2\-
month period beginning on the due date for filing the return
(without regard to any extensions).

[[Page S5854]]

(4) The maximum extension for the Forms 990 (series)
returns of organizations exempt from income tax shall be an
automatic 6-month period beginning on the due date for filing
the return (without regard to any extensions).
(5) The maximum extension for the returns of organizations
exempt from income tax that are required to file Form 4720
returns of excise taxes shall be an automatic 6-month period
beginning on the due date for filing the return (without
regard to any extensions).
(6) The maximum extension for the returns of trusts
required to file Form 5227 shall be an automatic 6-month
period beginning on the due date for filing the return
(without regard to any extensions).
(7) The maximum extension for filing Form 6069, Return of
Excise Tax on Excess Contributions to Black Lung Benefit
Trust Under Section 4953 and Computation of Section 192
Deduction, shall be an automatic 6-month period beginning on
the due date for filing the return (without regard to any
extensions).
(8) The maximum extension for a taxpayer required to file
Form 8870 shall be an automatic 6-month period beginning on
the due date for filing the return (without regard to any
extensions).
(9) The due date of Form 3520-A, Annual Information Return
of a Foreign Trust with a United States Owner, shall be the
15th day of the 3rd month after the close of the trust's
taxable year, and the maximum extension shall be a 6-month
period beginning on such day.
(10) The due date of FinCEN Form 114 (relating to Report of
Foreign Bank and Financial Accounts) shall be April 15 with a
maximum extension for a 6-month period ending on October 15,
and with provision for an extension under rules similar to
the rules of 26 C.F.R. 1.6081-5. For any taxpayer required to
file such form for the first time, the Secretary of the
Treasury may waive any penalty for failure to timely request
or file an extension.
(11) Taxpayers filing Form 3520, Annual Return to Report
Transactions with Foreign Trusts and Receipt of Certain
Foreign Gifts, shall be allowed to extend the time for filing
such form separately from the income tax return of the
taxpayer, for an automatic 6-month period beginning on the
due date for filing the return (without regard to any
extensions).
(c) Corporations Permitted Statutory Automatic 6-month
Extension of Income Tax Returns.--
(1) In general.--Section 6081(b) of the Internal Revenue
Code of 1986 is amended by striking ``3 months'' and
inserting ``6 months''.
(2) Effective date.--The amendments made by this subsection
shall apply to returns for taxable years beginning after
December 31, 2015.
(3) Special rule for certain c corporations in 2024.--In
the case of any taxable year of a C corporation ending on
December 31, 2024, subsections (a) and (b) of section 6081 of
the Internal Revenue Code of 1986 shall each be applied to
returns of income taxes under subtitle A by substituting ``5
months'' for ``6 months''.

SEC. 52106. SPECIAL COMPLIANCE PERSONNEL PROGRAM.

(a) In General.--Subsection (c) of section 6306 of the
Internal Revenue Code of 1986 is amended by striking ``for
collection enforcement activities of the Internal Revenue
Service'' in paragraph (2) and inserting ``to fund the
special compliance personnel program account under section
6307''.
(b) Special Compliance Personnel Program Account.--
Subchapter A of chapter 64 of the Internal Revenue Code of
1986 is amended by adding at the end the following new
section:

``SEC. 6307. SPECIAL COMPLIANCE PERSONNEL PROGRAM ACCOUNT.

``(a) Establishment of a Special Compliance Personnel
Program Account.--The Secretary shall establish an account
within the Department for carrying out a program consisting
of the hiring, training, and employment of special compliance
personnel, and shall transfer to such account from time to
time amounts retained by the Secretary under section
6306(c)(2).
``(b) Restrictions.--The program described in subsection
(a) shall be subject to the following restrictions:
``(1) No funds shall be transferred to such account except
as described in subsection (a).
``(2) No other funds from any other source shall be
expended for special compliance personnel employed under such
program, and no funds from such account shall be expended for
the hiring of any personnel other than special compliance
personnel.
``(3) Notwithstanding any other authority, the Secretary is
prohibited from spending funds out of such account for any
purpose other than for costs under such program associated
with the employment of special compliance personnel and the
retraining and reassignment of current noncollections
personnel as special compliance personnel, and to reimburse
the Internal Revenue Service or other government agencies for
the cost of administering qualified tax collection contracts
under section 6306.
``(c) Reporting.--Not later than March of each year, the
Commissioner of Internal Revenue shall submit a report to the
Committees on Finance and Appropriations of the Senate and
the Committees on Ways and Means and Appropriations of the
House of Representatives consisting of the following:
``(1) For the preceding fiscal year, all funds received in
the account established under subsection (a), administrative
and program costs for the program described in such
subsection, the number of special compliance personnel hired
and employed under the program, and the amount of revenue
actually collected by such personnel.
``(2) For the current fiscal year, all actual and estimated
funds received or to be received in the account, all actual
and estimated administrative and program costs, the number of
all actual and estimated special compliance personnel hired
and employed under the program, and the actual and estimated
revenue actually collected or to be collected by such
personnel.
``(3) For the following fiscal year, an estimate of all
funds to be received in the account, all estimated
administrative and program costs, the estimated number of
special compliance personnel hired and employed under the
program, and the estimated revenue to be collected by such
personnel.
``(d) Definitions.--For purposes of this section--
``(1) Special compliance personnel.--The term `special
compliance personnel' means individuals employed by the
Internal Revenue Service as field function collection
officers or in a similar position, or employed to collect
taxes using the automated collection system or an equivalent
replacement system.
``(2) Program costs.--The term `program costs' means--
``(A) total salaries (including locality pay and bonuses),
benefits, and employment taxes for special compliance
personnel employed or trained under the program described in
subsection (a), and
``(B) direct overhead costs, salaries, benefits, and
employment taxes relating to support staff, rental payments,
office equipment and furniture, travel, data processing
services, vehicle costs, utilities, telecommunications,
postage, printing and reproduction, supplies and materials,
lands and structures, insurance claims, and indemnities for
special compliance personnel hired and employed under this
section.
For purposes of subparagraph (B), the cost of management and
supervision of special compliance personnel shall be taken
into account as direct overhead costs to the extent such
costs, when included in total program costs under this
paragraph, do not represent more than 10 percent of such
total costs.''.
(c) Clerical Amendment.--The table of sections for
subchapter A of chapter 64 of the Internal Revenue Code of
1986 is amended by inserting after the item relating to
section 6306 the following new item:

``Sec. 6307. Special compliance personnel program account.''.
(d) Effective Date.--The amendment made by subsection (a)
shall apply to amounts collected and retained by the
Secretary after the date of the enactment of this Act.

SEC. 52107. TRANSFERS OF EXCESS PENSION ASSETS TO RETIREE
HEALTH ACCOUNTS.

(a) In General.--Section 420(b)(4) of the Internal Revenue
Code of 1986 is amended by striking ``December 31, 2021'' and
inserting ``December 31, 2025''.
(b) Conforming ERISA Amendments.--
(1) Sections 101(e)(3), 403(c)(1), and 408(b)(13) of the
Employee Retirement Income Security Act of 1974 (29 U.S.C.
1021(e)(3), 1103(c)(1), 1108(b)(13)) are each amended by
striking ``MAP-21'' and inserting ``DRIVE Act''.
(2) Section 408(b)(13) of such Act (29 U.S.C. 1108(b)(13))
is amended by striking ``January 1, 2022'' and inserting
``January 1, 2026''.

Subtitle B--Fees and Receipts

SEC. 52201. EXTENSION OF DEPOSITS OF SECURITY SERVICE FEES IN
THE GENERAL FUND.

Section 44940(i)(4) of title 49, United States Code, is
amended by adding at the end the following:
``(K) $1,750,000,000 for each of fiscal years 2024 and
2025.''.

SEC. 52202. ADJUSTMENT FOR INFLATION OF FEES FOR CERTAIN
CUSTOMS SERVICES.

(a) In General.--Section 13031 of the Consolidated Omnibus
Budget Reconciliation Act of 1985 (19 U.S.C. 58c) is amended
by adding at the end the following:
``(l) Adjustment of Fees for Inflation.--
``(1) In general.--The Secretary of the Treasury shall
adjust the fees established under subsection (a), and the
limitations on such fees under paragraphs (2), (3), (5), (6),
(8), and (9) of subsection (b), on October 1, 2015, and
annually thereafter, to reflect the percentage (if any) of
the increase in the average of the Consumer Price Index for
the preceding 12-month period compared to the Consumer Price
Index for fiscal year 2014.
``(2) Special rules for calculation of adjustment.--In
adjusting under paragraph (1) the amount of the fees
established under subsection (a), and the limitations on such
fees under paragraphs (2), (3), (5), (6), (8), and (9) of
subsection (b), the Secretary--
``(A) shall round the amount of any increase in the
Consumer Price Index to the nearest dollar; and
``(B) may ignore any such increase of less than 1 percent.
``(3) Consumer price index defined.--For purposes of this
subsection, the term `Consumer Price Index' means the
Consumer Price Index for All Urban Consumers published by the
Bureau of Labor Statistics of the Department of Labor.''.

[[Page S5855]]

(b) Deposits Into Customs User Fee Account.--Section
13031(f) of the Consolidated Omnibus Budget Reconciliation
Act of 1985 (19 U.S.C. 58c(f)) is amended--
(1) in paragraph (1), in the matter preceding subparagraph
(A), by striking ``all fees collected under subsection (a)''
and inserting ``the amount of fees collected under subsection
(a) (determined without regard to any adjustment made under
subsection (l))''; and
(2) in paragraph (3)(A), in the matter preceding clause
(i)--
(A) by striking ``fees collected'' and inserting ``amount
of fees collected''; and
(B) by striking ``), each appropriation'' and inserting ``,
and determined without regard to any adjustment made under
subsection (l)), each appropriation''.
(c) Conforming Amendments.--Section 13031 of the
Consolidated Omnibus Budget Reconciliation Act of 1985 (19
U.S.C. 58c), as amended by subsections (a) and (b), is
further amended--
(1) in subsection (a), in the matter preceding paragraph
(1), by inserting ``(subject to adjustment under subsection
(l))'' after ``following fees''; and
(2) in subsection (b)--
(A) in paragraph (2), by inserting ``(subject to adjustment
under subsection (l))'' after ``in fees'';
(B) in paragraph (3), by inserting ``(subject to adjustment
under subsection (l))'' after ``in fees'';
(C) in paragraph (5)(A), by inserting ``(subject to
adjustment under subsection (l))'' after ``in fees'';
(D) in paragraph (6), by inserting ``(subject to adjustment
under subsection (l))'' after ``in fees'';
(E) in paragraph (8)(A)--
(i) in clause (i), by inserting ``or (l)'' after
``subsection (a)(9)(B)''; and
(ii) in clause (ii), by inserting ``(subject to adjustment
under subsection (l))'' after ``$3''; and
(F) in paragraph (9)--
(i) in subparagraph (A)--

(I) in the matter preceding clause (i), by inserting ``and
subject to adjustment under subsection (l)'' after ``Tariff
Act of 1930''; and
(II) in clause (ii)(I), by inserting ``(subject to
adjustment under subsection (l))'' after ``bill of lading'';
and

(ii) in subparagraph (B)(i), by inserting ``(subject to
adjustment under subsection (l))'' after ``bill of lading''.

SEC. 52203. DIVIDENDS AND SURPLUS FUNDS OF RESERVE BANKS.

Section 7(a)(1)(A) of the Federal Reserve Act (12 U.S.C.
289(a)(1)(A)) is amended by striking ``6 percent'' and
inserting ``6 percent (1.5 percent in the case of a
stockholder having total consolidated assets of more than
$1,000,000,000 (determined as of September 30 of the
preceding fiscal year))''.

SEC. 52204. STRATEGIC PETROLEUM RESERVE DRAWDOWN AND SALE.

(a) Drawdown and Sale.--
(1) In general.--Notwithstanding section 161 of the Energy
Policy and Conservation Act (42 U.S.C. 6241), except as
provided in subsection (b), the Secretary of Energy shall
drawdown and sell from the Strategic Petroleum Reserve--
(A) 4,000,000 barrels of crude oil during fiscal year 2018;
(B) 5,000,000 barrels of crude oil during fiscal year 2019;
(C) 8,000,000 barrels of crude oil during fiscal year 2020;
(D) 8,000,000 barrels of crude oil during fiscal year 2021;
(E) 10,000,000 barrels of crude oil during fiscal year
2022;
(F) 16,000,000 barrels of crude oil during fiscal year
2023;
(G) 25,000,000 barrels of crude oil during fiscal year
2024; and
(H) 25,000,000 barrels of crude oil during fiscal year
2025.
(2) Deposit of amounts received from sale.--Amounts
received from a sale under paragraph (1) shall be deposited
in the general fund of the Treasury during the fiscal year in
which the sale occurs.
(b) Emergency Protection.--In any 1 fiscal year described
in subsection (a)(1), the Secretary of Energy shall not
drawdown and sell crude oil under this section in quantities
that would result in a Strategic Petroleum Reserve that
contains an inventory of petroleum products representing
fewer than 90 days of emergency reserves, based on the
average daily level of net imports of crude oil and petroleum
products in the calendar year preceding that fiscal year.

Subtitle C--Outlays

SEC. 52301. INTEREST ON OVERPAYMENT.

Section 111 of the Federal Oil and Gas Royalty Management
Act of 1982 (30 U.S.C. 1721) is amended--
(1) by striking subsections (h) and (i);
(2) by redesignating subsections (j) through (l) as
subsections (h) through (j), respectively; and
(3) in subsection (h) (as so redesignated), by striking the
fourth sentence.

Subtitle D--Corporate Tax Dodging Prevention

SEC. 52401. DEFERRAL OF ACTIVE INCOME OF CONTROLLED FOREIGN
CORPORATIONS.

Section 952 of the Internal Revenue Code of 1986 is amended
by adding at the end the following new subsection:
``(e) Special Application of Subpart.--
``(1) In general.--For taxable years beginning after
December 31, 2015, notwithstanding any other provision of
this subpart, the term `subpart F income' means, in the case
of any controlled foreign corporation, the income of such
corporation derived from any foreign country.
``(2) Applicable rules.--Rules similar to the rules under
the last sentence of subsection (a) and subsection (d) shall
apply to this subsection.''.

SEC. 52402. MODIFICATIONS OF FOREIGN TAX CREDIT RULES
APPLICABLE TO LARGE INTEGRATED OIL COMPANIES
WHICH ARE DUAL CAPACITY TAXPAYERS.

(a) In General.--Section 901 of the Internal Revenue Code
of 1986 is amended by redesignating subsection (n) as
subsection (o) and by inserting after subsection (m) the
following new subsection:
``(n) Special Rules Relating to Large Integrated Oil
Companies Which Are Dual Capacity Taxpayers.--
``(1) General rule.--Notwithstanding any other provision of
this chapter, any amount paid or accrued by a dual capacity
taxpayer which is a large integrated oil company to a foreign
country or possession of the United States for any period
shall not be considered a tax--
``(A) if, for such period, the foreign country or
possession does not impose a generally applicable income tax,
or
``(B) to the extent such amount exceeds the amount
(determined in accordance with regulations) which--
``(i) is paid by such dual capacity taxpayer pursuant to
the generally applicable income tax imposed by the country or
possession, or
``(ii) would be paid if the generally applicable income tax
imposed by the country or possession were applicable to such
dual capacity taxpayer.
Nothing in this paragraph shall be construed to imply the
proper treatment of any such amount not in excess of the
amount determined under subparagraph (B).
``(2) Dual capacity taxpayer.--For purposes of this
subsection, the term `dual capacity taxpayer' means, with
respect to any foreign country or possession of the United
States, a person who--
``(A) is subject to a levy of such country or possession,
and
``(B) receives (or will receive) directly or indirectly a
specific economic benefit (as determined in accordance with
regulations) from such country or possession.
``(3) Generally applicable income tax.--For purposes of
this subsection--
``(A) In general.--The term `generally applicable income
tax' means an income tax (or a series of income taxes) which
is generally imposed under the laws of a foreign country or
possession on income derived from the conduct of a trade or
business within such country or possession.
``(B) Exceptions.--Such term shall not include a tax unless
it has substantial application, by its terms and in practice,
to--
``(i) persons who are not dual capacity taxpayers, and
``(ii) persons who are citizens or residents of the foreign
country or possession.
``(4) Large integrated oil company.--For purposes of this
subsection, the term `large integrated oil company' means,
with respect to any taxable year, an integrated oil company
(as defined in section 291(b)(4)) which--
``(A) had gross receipts in excess of $1,000,000,000 for
such taxable year, and
``(B) has an average daily worldwide production of crude
oil of at least 500,000 barrels for such taxable year.''.
(b) Effective Date.--
(1) In general.--The amendments made by this section shall
apply to taxes paid or accrued in taxable years beginning
after the date of the enactment of this Act.
(2) Contrary treaty obligations upheld.--The amendments
made by this section shall not apply to the extent contrary
to any treaty obligation of the United States.

SEC. 52403. REINSTITUTION OF PER COUNTRY FOREIGN TAX CREDIT.

(a) In General.--Subsection (a) of section 904 of the
Internal Revenue Code of 1986 is amended to read as follows:
``(a) Limitation.--The amount of the credit in respect of
the tax paid or accrued to any foreign country or possession
of the United States shall not exceed the same proportion of
the tax against which such credit is taken which the
taxpayer's taxable income from sources within such country or
possession (but not in excess of the taxpayer's entire
taxable income) bears to such taxpayer's entire taxable
income for the same taxable year.''.
(b) Effective Date.--The amendment made by this section
shall apply to taxable years beginning after December 31,
2015.

SEC. 52404. TREATMENT OF FOREIGN CORPORATIONS MANAGED AND
CONTROLLED IN THE UNITED STATES AS DOMESTIC
CORPORATIONS.

(a) In General.--Section 7701 of the Internal Revenue Code
of 1986 is amended by redesignating subsection (p) as
subsection (q) and by inserting after subsection (o) the
following new subsection:
``(p) Certain Corporations Managed and Controlled in the
United States Treated as Domestic for Income Tax.--
``(1) In general.--Notwithstanding subsection (a)(4), in
the case of a corporation described in paragraph (2) if--
``(A) the corporation would not otherwise be treated as a
domestic corporation for purposes of this title, but
``(B) the management and control of the corporation occurs,
directly or indirectly, primarily within the United States,
then, solely for purposes of chapter 1 (and any other
provision of this title relating to

[[Page S5856]]

chapter 1), the corporation shall be treated as a domestic
corporation.
``(2) Corporation described.--
``(A) In general.--A corporation is described in this
paragraph if--
``(i) the stock of such corporation is regularly traded on
an established securities market, or
``(ii) the aggregate gross assets of such corporation (or
any predecessor thereof), including assets under management
for investors, whether held directly or indirectly, at any
time during the taxable year or any preceding taxable year is
$50,000,000 or more.
``(B) General exception.--A corporation shall not be
treated as described in this paragraph if--
``(i) such corporation was treated as a corporation
described in this paragraph in a preceding taxable year,
``(ii) such corporation--

``(I) is not regularly traded on an established securities
market, and
``(II) has, and is reasonably expected to continue to have,
aggregate gross assets (including assets under management for
investors, whether held directly or indirectly) of less than
$50,000,000, and

``(iii) the Secretary grants a waiver to such corporation
under this subparagraph.
``(3) Management and control.--
``(A) In general.--The Secretary shall prescribe
regulations for purposes of determining cases in which the
management and control of a corporation is to be treated as
occurring primarily within the United States.
``(B) Executive officers and senior management.--Such
regulations shall provide that--
``(i) the management and control of a corporation shall be
treated as occurring primarily within the United States if
substantially all of the executive officers and senior
management of the corporation who exercise day-to-day
responsibility for making decisions involving strategic,
financial, and operational policies of the corporation are
located primarily within the United States, and
``(ii) individuals who are not executive officers and
senior management of the corporation (including individuals
who are officers or employees of other corporations in the
same chain of corporations as the corporation) shall be
treated as executive officers and senior management if such
individuals exercise the day-to-day responsibilities of the
corporation described in clause (i).
``(C) Corporations primarily holding investment assets.--
Such regulations shall also provide that the management and
control of a corporation shall be treated as occurring
primarily within the United States if--
``(i) the assets of such corporation (directly or
indirectly) consist primarily of assets being managed on
behalf of investors, and
``(ii) decisions about how to invest the assets are made in
the United States.''.
(b) Effective Date.--The amendments made by this section
shall apply to taxable years beginning on or after the date
which is 2 years after the date of the enactment of this Act.

SEC. 52405. RESTRICTIONS ON DEDUCTION FOR INTEREST EXPENSE OF
MEMBERS OF FINANCIAL REPORTING GROUPS WITH
EXCESS DOMESTIC INDEBTEDNESS.

(a) In General.--Section 163 of the Internal Revenue Code
of 1986 is amended by redesignating subsection (n) as
subsection (o) and by inserting after subsection (m) the
following new subsection:
``(n) Restriction on Deduction for Interest Expense of
Members of Financial Reporting Groups With Excess Domestic
Indebtedness.--
``(1) In general.--In the case of any corporation which is
a member of an applicable financial reporting group the
common parent of which is a foreign corporation, the
deduction allowed under this chapter for interest paid or
accrued by the corporation during the taxable year shall not
exceed the applicable limitation for the taxable year.
``(2) Carryforward.--Any amount disallowed under paragraph
(1) for any taxable year shall be treated as interest paid or
accrued in the succeeding taxable year.
``(3) Applicable limitation.--For purposes of this
subsection--
``(A) In general.--The applicable limitation with respect
to a taxpayer for any taxable year is the sum of--
``(i) the greater of--

``(I) the taxpayer's allocable share of the applicable
financial reporting group's net interest expense for the
taxable year, or
``(II) 10 percent of the taxpayer's adjusted taxable income
for the taxable year, plus

``(ii) the excess limitation carryforwards to the taxable
year from any preceding taxable year.
``(B) Limitation not less than includible interest.--The
applicable limitation under subparagraph (A) for any taxable
year shall not be less than the amount of interest includible
in the gross income of the taxpayer for the taxable year.
``(C) Excess limitation carryforward.--If the applicable
limitation of a taxpayer for any taxable year (determined
without regard to carryforwards under subparagraph (A)(ii))
exceeds the interest paid or accrued by the taxpayer during
the taxable year, such excess shall be an excess limitation
carryforward to the 1st succeeding taxable year and the 2nd
and 3rd succeeding taxable years to the extent not previously
taken into account under this paragraph.
``(4) Allocable share of net interest expense.--For
purposes of this subsection--
``(A) In general.--A taxpayer's allocable share of an
applicable financial reporting group's net interest expense
for any taxable year shall be the amount (not less than zero)
which bears the same ratio to such net interest expense as--
``(i) the net earnings of the taxpayer, bears to
``(ii) the aggregate net earnings of all members of the
applicable financial reporting group.
``(B) Net earnings.--The term `net earnings' means, with
respect to any taxpayer, the earnings of the taxpayer--
``(i) computed without regard to any reduction allowable
for--

``(I) net interest expense,
``(II) taxes, or
``(III) depreciation, amortization, or depletion, and

``(ii) computed with such other adjustments as the
Secretary may by regulations prescribe.
``(C) Burden on taxpayer.--If a taxpayer elects not to
compute its allocable share, or fails to establish to the
satisfaction of the Secretary the amount of its allocable
share, for any taxable year, the allocable share shall be
zero.
``(5) Net interest expense and net earnings
determinations.--For purposes of this subsection--
``(A) Net interest expense.--Any determination of net
interest expense for any taxable year shall be made--
``(i) on the basis of the applicable financial statement of
the applicable financial reporting group for the last
financial reporting year ending with or within the taxable
year, and
``(ii) under United States tax principles.
``(B) Net earnings.--Any determination of net earnings for
any taxable year shall be made on the basis of the applicable
financial statement of the applicable financial reporting
group for the last financial reporting year ending with or
within the taxable year.
``(C) Applicable financial statement.--The term `applicable
financial statement' means a statement for financial
reporting purposes which is made on the basis of--
``(i) generally accepted accounting principles,
``(ii) international financial reporting standards, or
``(iii) any other method specified by the Secretary in
regulations.
A statement under clause (ii) or (iii) may be used as an
applicable financial statement by a group only if there is no
statement of the group under any preceding clause.
``(6) Applicable financial reporting group.--For purposes
of this subsection--
``(A) In general.--The term `applicable financial reporting
group' means, with respect to any corporation, a group of
which such corporation is a member and which files an
applicable financial statement.
``(B) Exception for groups with minimal domestic net
interest expense.--Such term shall not include a group if the
aggregate net interest expense for which a deduction is
allowable to all members of the group under this chapter
(determined without regard to this subsection or any other
limitation on deductibility of interest under this chapter)
is less than $5,000,000.
``(C) Exception for certain financial entities.--A
corporation which is described in section 864(f)(4)(B), or is
treated as described in section 864(f)(4)(B) by reason of
paragraph (4)(C) or (5)(A) of section 864(f) (without regard
to whether an election is made under such paragraph (5)(A)),
shall not be treated as a member of an applicable financial
reporting group of which it is otherwise a member and this
subsection shall not apply to such corporation.
``(7) Other definitions and rules.--For purposes of this
subsection--
``(A) Adjusted taxable income.--The term `adjusted taxable
income' has the meaning given such term by subsection
(j)(6)(A).
``(B) Net interest expense.--The term `net interest
expense' has the meaning given such term by subsection
(j)(6)(B).
``(C) Treatment of affiliated group.--All members of the
same affiliated group (within the meaning of section 1504(a))
shall be treated as 1 taxpayer.
``(8) Regulations.--The Secretary shall prescribe such
regulations as may be necessary to carry out the purposes of
this section, including regulations providing--
``(A) for the coordination of the application of this
subsection and other provisions of this chapter relating to
the deductibility of interest,
``(B) for the waiver of certain adjustments required under
United States tax principles in appropriate cases for
purposes of applying this subsection,
``(C) for the determination of which financial institutions
are eligible for the exception from membership in an
applicable financial reporting group under paragraph (6)(C)
and the application of this subsection to the other members
of the group which are not so excepted, and
``(D) for the application of this subsection in the case of
pass thru entities and for the treatment of pass thru
entities as corporations in cases where necessary to prevent
the avoidance of the purposes of this subsection.''.
(b) Coordination With Limitation on Related Party
Indebtedness.--Paragraph (2) of section 163(j) of the
Internal Revenue Code of 1986 is amended by adding at the end
the following new subparagraph:

[[Page S5857]]

``(D) Coordination with limitation on excess domestic
indebtedness.--This subsection shall not apply to any
corporation for any taxable year to which subsection (n)
applies to such corporation.''.
(c) Effective Date.--The amendments made by this section
shall apply to taxable years beginning after December 31,
2015.

SEC. 52406. MODIFICATIONS TO RULES RELATING TO INVERTED
CORPORATIONS.

(a) In General.--Subsection (b) of section 7874 of the
Internal Revenue Code of 1986 is amended to read as follows:
``(b) Inverted Corporations Treated as Domestic
Corporations.--
``(1) In general.--Notwithstanding section 7701(a)(4), a
foreign corporation shall be treated for purposes of this
title as a domestic corporation if--
``(A) such corporation would be a surrogate foreign
corporation if subsection (a)(2) were applied by substituting
`80 percent' for `60 percent', or
``(B) such corporation is an inverted domestic corporation.
``(2) Inverted domestic corporation.--For purposes of this
subsection, a foreign corporation shall be treated as an
inverted domestic corporation if, pursuant to a plan (or a
series of related transactions)--
``(A) the entity completes after May 8, 2014, the direct or
indirect acquisition of--
``(i) substantially all of the properties held directly or
indirectly by a domestic corporation, or
``(ii) substantially all of the assets of, or substantially
all of the properties constituting a trade or business of, a
domestic partnership, and
``(B) after the acquisition, more than 50 percent of the
stock (by vote or value) of the entity is held--
``(i) in the case of an acquisition with respect to a
domestic corporation, by former shareholders of the domestic
corporation by reason of holding stock in the domestic
corporation, or
``(ii) in the case of an acquisition with respect to a
domestic partnership, by former partners of the domestic
partnership by reason of holding a capital or profits
interest in the domestic partnership.
``(3) Exception for corporations with substantial business
activities in foreign country of organization.--A foreign
corporation described in paragraph (2) shall not be treated
as an inverted domestic corporation if after the acquisition
the expanded affiliated group which includes the entity has
substantial business activities in the foreign country in
which or under the law of which the entity is created or
organized when compared to the total business activities of
such expanded affiliated group. For purposes of subsection
(a)(2)(B)(iii) and the preceding sentence, the term
`substantial business activities' shall have the meaning
given such term under regulations in effect on May 8, 2014,
except that the Secretary may issue regulations increasing
the threshold percent in any of the tests under such
regulations for determining if business activities constitute
substantial business activities for purposes of this
paragraph.''.
(b) Conforming Amendments.--
(1) Clause (i) of section 7874(a)(2)(B) of the Internal
Revenue Code of 1986 is amended by striking ``after March 4,
2003,'' and inserting ``after March 4, 2003, and before May
9, 2014,''.
(2) Subsection (c) of section 7874 of such Code is
amended--
(A) in paragraph (2)--
(i) by striking ``subsection (a)(2)(B)(ii)'' and inserting
``subsections (a)(2)(B)(ii) and (b)(2)(B)'', and
(ii) by inserting ``or (b)(2)(A)'' after ``(a)(2)(B)(i)''
in subparagraph (B),
(B) in paragraph (3), by inserting ``or (b)(2)(B), as the
case may be,'' after ``(a)(2)(B)(ii)'',
(C) in paragraph (5), by striking ``subsection
(a)(2)(B)(ii)'' and inserting ``subsections (a)(2)(B)(ii) and
(b)(2)(B)'', and
(D) in paragraph (6), by inserting ``or inverted domestic
corporation, as the case may be,'' after ``surrogate foreign
corporation''.
(c) Effective Date.--The amendments made by this section
shall apply to taxable years ending after May 8, 2014.

TITLE LIII--ADDITIONAL SPENDING AUTHORIZATION

SEC. 53101. ADDITIONAL SPENDING AUTHORIZATION.

Notwithstanding any provision of this Act or any amendment
made by this Act, any amount authorized to be expended under
this Act or any amendment made by this Act shall be increased
by 50 percent of such amount.
______