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Tax Cuts and Jobs Act (H.R.) Changes Made To The Committee-Reported Bill During Floor Consideration



US Senate Finance Committee _ TCJA

Changes Made by the Perfecting Amendment (Hatch #1618)

(Note: All JCT estimates are relative to the committee-reported version of H.R. 1)

Modifications
Increased Pass-Through Deduction (Sec. 11011)

  • This provision increased the deduction for qualified business income on individual returns from 17.4 percent to 23 percent of such income.
  • JCT Estimate: Change would reduce revenues by an additional $114 billion over ten years.

Extended Bonus Depreciation (Sec. 13204)

  • This provision extends the bill’s five-year 100 percent expensing period for an additional four years, decreasing gradually over that time.
  • JCT Estimate: This change would decrease revenues by $35 billion over ten years.

Restoration of IC-DISC (Sec. 14224)

  • This provision preserves current law tax treatment for Interest Charge Domestic International Sales Corporations.
  • JCT Estimate: This change would reduce revenues by $5.3 billion over ten years.

Treatment Of Non-Profit And Clergy Pension Plans (Sec. 13611)

  • This provision maintains current law pension contribution limits for employees of non-profits and governmental entities.
  • JCT Estimate: This change would reduce revenues by $1.7 billion over ten years.

Increased AMT Exemption And Phase-Out (Sec. 12002)

  • This provision maintains the individual AMT, with increased exemption amounts and phase-out thresholds.
  • JCT Estimate: This provision would increase revenues by $132.9 billion over ten years.

Increased Toll On Repatriated Corporate Earnings (Sec. 14103)

  • This provision increases the toll on earnings deemed repatriated under the bill to 14.49 percent for liquid assets and 7.49 percent for illiquid assets.
  • JCT Estimate: This change would increase revenues by $113B over 10 years. 

Corporate AMT Reinstated (Sec. 12001)

  • This provision strikes the repeal of the corporate alternative minimum tax, maintaining current law.
  • JCT Estimate: This change would increase revenues by $40.3 billion over 10 years

Child Tax Credit Eligibility Adjustment (Sec. 11022)

  • This provision decreased the age of a child qualifying for the expanded credit from 17 to 16 (same as current law), for 2025.
  • JCT Estimate: This change would increase revenues by $4.6 billion over 10 years.

Provisions Removed for Byrd Rule Compliance

  • 11028 – 529 savings accounts for unborn children
  • 11029 – Relief for Mississippi Delta Flood Disaster
  • 11072 – Individuals held harmless on improper levy on retirement plans
  • 11074 – Form 1040SR for Seniors
  • 11075 – Sense of the Senate on improving customer service and protections for taxpayers by reinstating appropriate funding levels
  • 11076 – Return preparation programs for low-income taxpayers
  • 11077 — Free File Program
  • 13011 – Dividends paid deduction
  • 13303(b)(5) — Special rules for certain mutual ditch companies
  • 13401(b) – Public disclosure regarding orphan drug credit
  • 13411-13416 – Revisions to the Low-Income Housing Tax Credit.
  • 13704 – Repeal of tax-exempt status professional sports leagues.
  • 13705 – Modification of taxes on excess benefit transactions.
  • 13706 — Exemption from private foundation excess business holding tax for independently operated philanthropic business holdings
  • 13801 – Craft Beverage Modernization and Tax Reform – Rule of construction
  • 13804 – Craft Beverage Modernization and Tax Reform – Simplification of rules regarding records, statements and returns
  • 14505 – Repeal of exclusion applicable to certain passenger aircraft operated by a foreign corporation.

Amendments Filed and Accepted

Ernst #1588

  • Eliminates deduction for members of Congress’s living expenses

JCT Estimate: Increases revenue by less than $50 million

Graham #1595

  • Strikes bill’s provision on the treatment of contingency fee cases

JCT Estimate: Reduces revenue by $500 million

Collins #1613

  • Repeals Obamacare limit on the deductibility of medical expenses, allowing deduction if medical expenses exceed 7.5 percent of AGI

JCT Estimate: Reduces revenue by $4.6 billion

Paul #1622 & Hoeven#1673

  • Makes interest costs for vehicle floor plan financing fully deductible
    JCT Estimate: Reduces revenue by $600 million

Murkowski #1630

  • Modifies the bill’s provisions regarding tax treatment of Alaska Native Corporations
    JCT Estimate: Increases revenue by less than $50 million

Roberts #1631

  • Treat agricultural/horticultural co-ops same as other farming businesses
    JCT Estimate: Reduces revenue by less than $50 million

Roberts #1632

  • Modifies the low income housing credit to add preferences for veterans and rural housing
    JCT Estimate: Reduces revenue by less than $50 million

Sullivan #1678

  • Strikes the provision of the bill relating to passenger cruise ships
    JCT Estimate: Reduces revenue by $700 million

Hatch #1684

  • Prohibit cash or gift cards as employee achievement awards
    JCT Estimate: Increases revenue by less than $50 million

Thune #1711(modified)

  • Provides pass-through deduction to certain agricultural and horticultural cooperatives (with modified effective date)
    JCT Estimate: Reduces revenue by less than $50 million

Cornyn #1715

  • Allows the deduction for pass-through business income to apply to distributions from publicly-traded partnerships
    JCT Estimate: Reduces revenue by $700 million

Hatch #1724

  • Strikes the provision treating name and logo royalties as UBIT
    JCT Estimate: Reduces revenue by $2 billion

Hatch #1728

  • Clarifies the effective date for the recovery period for real property
    JCT Estimate: Reduces revenue by $400 million

Hatch #1729

  • Clarifies the effective date of repeal of Section 199
    CT Estimate: Increases revenue by $3.7 billion

Hatch #1730

  • Makes a technical change to the partnership provisions for the interest deduction limitation
    JCT Estimate: No revenue effect

Hatch #1731

  • Clarifies the definition of total equity for the purposes of the bill’s worldwide interest limitation rule
    JCT Estimate: No revenue effect

Rounds #1735

  • Adds an exemption for mortgage service rights from the requirements of the new income inclusion rule JCT Estimate: Reduces revenue by $3.8 billion

Alexander #1738

  • Raises the required asset/student for the university endowment excise tax from $250,000/student to $500,000/student
    JCT Estimate: Reduces revenue by $700 million

Burr #1745

  • Clarifies the limit on contributions to ABLE Act accounts
    JCT Estimate: Reduces revenue by $400 million

Cassidy #1756

  • Modifies the rules regarding overall domestic losses for purposes of the foreign tax credit
    JCT Estimate: Reduces revenue by $1.8 billion

Isakson #1764

  • Provides separate rules regarding the timing of inclusion of income for original issue discount
    JCT Estimate: Reduces revenue by $700 million

Fischer #1793

  • Improves employer credit for paid family and medical leave
    JCT Estimate: Increases revenue by less than $50 million

Cassidy #1794

  • Provides tax relief to individuals in all areas declared disasters in 2016
    JCT Estimate: Reduces revenue by $4.6 billion

Hatch #1809

  • Clarifies the definition of qualified trade or business for the purposes of the bill’s pass-through deduction
    JCT Estimate: Negligible effect

Toomey #1816

  • Provides a phase-in for the indebtedness requirements of the worldwide interest limitation rule
    JCT Estimate: Reduces revenue by $400 million

Hatch #1819

  • Clarification on rules relating to foreign-derived, related-party intangible income
    JCT Estimate: Negligible Effect

Hatch #1820

  • Modifies the treatment of S corporations converting to C corporations
    JCT Estimate: Reduces revenue by $6.1 billion

Scott #1826

  • Modifies rules regarding the tax treatment of life insurance companies
    JCT Estimate: Increases revenue by $23 billion

Scott #1833

  • Modifies bill’s provision on opportunity zones
    JCT Estimate: No revenue effect

Hatch #1836

  • Modifications to the BEAT for certain financial institutions
    JCT Estimate: Increases revenue by $2.4 billion

 

 

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One thought on “Tax Cuts and Jobs Act (H.R.) Changes Made To The Committee-Reported Bill During Floor Consideration

  1. Tom Kerester says:

    Terrific! Thanks. Tom Kerester

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