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
1 comment on “Tax Cuts and Jobs Act (H.R.) Changes Made To The Committee-Reported Bill During Floor Consideration”
Terrific! Thanks. Tom Kerester
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