II
118THCONGRESS
1
STSESSION S. 1226
To amend the Internal Revenue Code of 1986 to make permanent the
individual tax provisions of the tax reform law, and for other purposes.
IN THE SENATE OF THE UNITED STATES
APRIL20, 2023
Mr. C
RUZ(for himself and Mr. BRAUN) introduced the following bill; which
was read twice and referred to the Committee on Finance
A BILL
To amend the Internal Revenue Code of 1986 to make
permanent the individual tax provisions of the tax reform
law, and for other purposes.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. PERMANENT MODIFICATION OF INDIVIDUAL 3
RATE BRACKETS. 4
(a) M
ARRIEDINDIVIDUALSFILINGJOINTRETURNS 5
ANDSURVIVINGSPOUSES.—The table contained in sub-6
section (a) of section 1 of the Internal Revenue Code of 7
1986 is amended to read as follows: 8
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‘‘If taxable income is: The tax is:
Not over $19,050 ...................................... 10% of taxable income.
Over $19,050 but not over $77,400 .......... $1,905, plus 12% of the excess over
$19,050.
Over $77,400 but not over $165,000 ........ $8,907, plus 22% of the excess over
$77,400.
Over $165,000 but not over $315,000 ...... $28,179, plus 24% of the excess
over $165,000.
Over $315,000 but not over $400,000 ...... $64,179, plus 32% of the excess
over $315,000.
Over $400,000 but not over $600,000 ...... $91,379, plus 35% of the excess
over $400,000.
Over $600,000 ........................................... $161,379, plus 37% of the excess
over $600,000.’’.
(b) HEADS OFHOUSEHOLDS.—The table contained 1
in subsection (b) of section 1 of the Internal Revenue Code 2
of 1986 is amended to read as follows: 3
‘‘If taxable income is: The tax is:
Not over $13,600 ...................................... 10% of taxable income.
Over $13,600 but not over $51,800 .......... $1,360, plus 12% of the excess over
$13,600.
Over $51,800 but not over $82,500 .......... $5,944, plus 22% of the excess over
$51,800.
Over $82,500 but not over $157,500 ........ $12,698, plus 24% of the excess
over $82,500.
Over $157,500 but not over $200,000 ...... $30,698, plus 32% of the excess
over $157,500.
Over $200,000 but not over $500,000 ...... $44,298, plus 35% of the excess
over $200,000.
Over $500,000 ........................................... $149,298, plus 37% of the excess
over $500,000.’’.
(c) UNMARRIEDINDIVIDUALSOTHERTHANSUR-4
VIVINGSPOUSES AND HEADS OFHOUSEHOLDS.—The 5
table contained in subsection (c) of section 1 of the Inter-6
nal Revenue Code of 1986 is amended to read as follows: 7
‘‘If taxable income is: The tax is:
Not over $9,525 ........................................ 10% of taxable income.
Over $9,525 but not over $38,700 ............ $952.50, plus 12% of the excess
over $9,525.
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‘‘If taxable income is: The tax is:
Over $38,700 but not over $82,500 .......... $4,453.50, plus 22% of the excess
over $38,700.
Over $82,500 but not over $157,500 ........ $14,089.50, plus 24% of the excess
over $82,500.
Over $157,500 but not over $200,000 ...... $32,089.50, plus 32% of the excess
over $157,500.
Over $200,000 but not over $500,000 ...... $45,689.50, plus 35% of the excess
over $200,000.
Over $500,000 ........................................... $150,689.50, plus 37% of the ex-
cess over $500,000.’’.
(d) MARRIEDINDIVIDUALSFILINGSEPARATERE-1
TURNS.—The table contained in subsection (d) of section 2
1 of the Internal Revenue Code of 1986 is amended to 3
read as follows: 4
‘‘If taxable income is: The tax is:
Not over $9,525 ........................................ 10% of taxable income.
Over $9,525 but not over $38,700 ............ $952.50, plus 12% of the excess
over $9,525.
Over $38,700 but not over $82,500 .......... $4,453.50, plus 22% of the excess
over $38,700.
Over $82,500 but not over $157,500 ........ $14,089.50, plus 24% of the excess
over $82,500.
Over $157,500 but not over $200,000 ...... $32,089.50, plus 32% of the excess
over $157,500.
Over $200,000 but not over $300,000 ...... $45,689.50, plus 35% of the excess
over $200,000.
Over $300,000 ........................................... $80,689.50, plus 37% of the excess
over $300,000.’’.
(e) ESTATES ANDTRUSTS.—The table contained in 5
subsection (e) of section 1 of the Internal Revenue Code 6
of 1986 is amended to read as follows: 7
‘‘If taxable income is: The tax is:
Not over $2,550 ........................................ 10% of taxable income.
Over $2,550 but not over $9,150 .............. $255, plus 24% of the excess over
$2,550.
Over $9,150 but not over $12,500 ............ $1,839, plus 35% of the excess over
$9,150.
Over $12,500 ............................................. $3,011.50, plus 37% of the excess
over $12,500.’’.
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(f) ADJUSTMENT FOR INFLATION.—Subsection (f) of 1
section 1 of the Internal Revenue Code of 1986 is amend-2
ed— 3
(1) by striking ‘‘1993’’ in paragraph (1) and in-4
serting ‘‘2018’’, 5
(2) by striking ‘‘determined—’’ and all that fol-6
lows in paragraph (2)(A) and inserting ‘‘determined 7
by substituting ‘2017’ for ‘2016’ in paragraph 8
(3)(A)(ii),’’, 9
(3) by striking ‘‘a married individual filing a 10
separate return’’ in paragraph (7)(B) and inserting 11
‘‘any unmarried individual other than a surviving 12
spouse or head of household’’, 13
(4) by striking ‘‘
MARRIED INDIVIDUALS FILING 14
SEPARATELY’’ in the heading of subparagraph (B) of 15
paragraph (7) and inserting ‘‘
CERTAIN UNMARRIED 16
INDIVIDUALS’’, and 17
(5) by striking paragraph (8). 18
(g) C
APITALGAINSBRACKETS.—Subsection (h) of 19
section 1 of the Internal Revenue Code of 1986 is amend-20
ed— 21
(1) by striking ‘‘which would (without regard to 22
this paragraph) be taxed at a rate below 25 percent’’ 23
in paragraph (1)(B)(i) and inserting ‘‘below the 24
maximum zero rate amount’’, 25
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(2) by striking ‘‘which would (without regard to 1
this paragraph) be taxed at a rate below 39.6 per-2
cent’’ in paragraph (1)(C)(ii)(I) and inserting 3
‘‘below the maximum 15-percent rate amount’’, and 4
(3) by adding at the end the following new 5
paragraph: 6
‘‘(12) M
AXIMUM AMOUNTS DEFINED .—For pur-7
poses of this subsection— 8
‘‘(A) M
AXIMUM ZERO RATE AMOUNT .—The 9
maximum zero rate amount shall be— 10
‘‘(i) in the case of a joint return or 11
surviving spouse, $77,200, 12
‘‘(ii) in the case of an individual who 13
is a head of household (as defined in sec-14
tion 2(b)), $51,700, 15
‘‘(iii) in the case of any other indi-16
vidual (other than an estate or trust), an 17
amount equal to
1
∕2of the amount in effect 18
for the taxable year under clause (i), and 19
‘‘(iv) in the case of an estate or trust, 20
$2,600. 21
‘‘(B) M
AXIMUM 15 -PERCENT RATE 22
AMOUNT.—The maximum 15-percent rate 23
amount shall be— 24
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‘‘(i) in the case of a joint return or 1
surviving spouse, $479,000 (
1
∕2such 2
amount in the case of a married individual 3
filing a separate return), 4
‘‘(ii) in the case of an individual who 5
is the head of a household (as defined in 6
section 2(b)), $452,400, 7
‘‘(iii) in the case of any other indi-8
vidual (other than an estate or trust), 9
$425,800, and 10
‘‘(iv) in the case of an estate or trust, 11
$12,700. 12
‘‘(C) I
NFLATION ADJUSTMENT .—In the 13
case of any taxable year beginning after 2018, 14
each of the dollar amounts in subparagraphs 15
(A) and (B) shall be increased by an amount 16
equal to— 17
‘‘(i) such dollar amount, multiplied by 18
‘‘(ii) the cost-of-living adjustment de-19
termined under subsection (f)(3) for the 20
calendar year in which the taxable year be-21
gins, determined by substituting ‘calendar 22
year 2017’ for ‘calendar year 2016’ in sub-23
paragraph (A)(ii) thereof. 24
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If any increase under this subparagraph is not 1
a multiple of $50, such increase shall be round-2
ed to the next lowest multiple of $50.’’. 3
(h) C
ONFORMINGAMENDMENTS.— 4
(1) Section 1 of the Internal Revenue Code of 5
1986 is amended by striking subsections (i) and (j). 6
(2) Section 3402(q)(1) of such Code is amend-7
ed by striking ‘‘third lowest’’ and inserting ‘‘fourth 8
lowest’’. 9
(i) S
ECTION15 NOTTOAPPLY.—Section 15 of the 10
Internal Revenue Code of 1986 shall not apply to any 11
change in a rate of tax by reason of this section. 12
(j) E
FFECTIVEDATE.—The amendments made by 13
this section shall apply to taxable years beginning after 14
December 31, 2022. 15
SEC. 2. PERMANENT EXTENSION OF DEDUCTION FOR 16
QUALIFIED BUSINESS INCOME OF PASS-THRU 17
ENTITIES. 18
(a) I
NGENERAL.—Section 199A of the Internal Rev-19
enue Code of 1986 is amended by striking subsection (i). 20
(b) E
FFECTIVEDATE.—The amendment made by 21
this section shall apply to taxable years beginning after 22
December 31, 2022. 23
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SEC. 3. PERMANENT EXTENSION OF LIMITATION ON 1
LOSSES FOR TAXPAYERS OTHER THAN COR-2
PORATIONS. 3
(a) I
NGENERAL.—Paragraph (1) of section 461(l) 4
of the Internal Revenue Code of 1986 is amended to read 5
as follows: 6
‘‘(1) L
IMITATION.—In the case of taxable year 7
of a taxpayer other than a corporation, any excess 8
business loss of the taxpayer for the taxable year 9
shall not be allowed.’’. 10
(b) C
ONFORMINGAMENDMENT.—Section 461 of the 11
Internal Revenue Code of 1986 is amended by striking 12
subsection (j) (relating to limitation on excess farm losses 13
of certain taxpayers). 14
(c) E
FFECTIVEDATE.—The amendments made by 15
this section shall apply to taxable years beginning after 16
December 31, 2022. 17
SEC. 4. PERMANENT EXTENSION OF INCREASE IN STAND-18
ARD DEDUCTION. 19
(a) I
NGENERAL.—Section 63(c)(2) of the Internal 20
Revenue Code of 1986 is amended— 21
(1) by striking ‘‘$4,400’’ in subparagraph (B) 22
and inserting ‘‘$18,800’’, and 23
(2) by striking ‘‘$3,000’’ in subparagraph (C) 24
and inserting ‘‘$12,000’’. 25
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(b) INFLATIONADJUSTMENT.—Paragraph (4) of sec-1
tion 63(c) of the Internal Revenue Code of 1986 is amend-2
ed to read as follows: 3
‘‘(4) A
DJUSTMENTS FOR INFLATION .— 4
‘‘(A) I
N GENERAL.—In the case of any 5
taxable year beginning in a calendar year after 6
2018, the $18,000 and $12,000 amounts in 7
paragraph (2) shall each be increased by an 8
amount equal to— 9
‘‘(i) such dollar amount, multiplied by 10
‘‘(ii) the cost-of-living adjustment de-11
termined under section 1(f)(3) for the cal-12
endar year in which the taxable year be-13
gins, by substituting ‘2017’ for ‘2016’ in 14
subparagraph (A)(ii) thereof. 15
‘‘(B) C
ERTAIN AMOUNTS.—In the case of 16
any taxable year beginning in a calendar year 17
after 1988, each dollar amount contained in 18
paragraph (5) or subsection (f) shall be in-19
creased by an amount equal to— 20
‘‘(i) such dollar amount, multiplied by 21
‘‘(ii) the cost-of-living adjustment de-22
termined under section 1(f)(3) for the cal-23
endar year in which the taxable year be-24
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gins, by substituting for ‘calendar year 1
2016’ in subparagraph (A)(ii) thereof— 2
‘‘(I) ‘calendar year 1987’ in the 3
case of the dollar amounts contained 4
in paragraph (5)(A) or subsection (f), 5
and 6
‘‘(II) ‘calendar year 1997’ in the 7
case of the dollar amount contained in 8
paragraph (5)(B).’’. 9
(c) C
ONFORMINGAMENDMENT.—Section 63(c) of the 10
Internal Revenue Code of 1986 is amended by striking 11
paragraph (7). 12
(d) E
FFECTIVEDATE.—The amendments made by 13
this section shall apply to taxable years beginning after 14
December 31, 2022. 15
SEC. 5. PERMANENT INCREASE AND MODIFICATION OF 16
CHILD TAX CREDIT. 17
(a) I
NCREASE INCREDITAMOUNT.—Section 24(a) of 18
the Internal Revenue Code of 1986 is amended by striking 19
‘‘$1,000’’ and inserting ‘‘$2,000’’. 20
(b) L
IMITATION.—Paragraph (2) of section 24(b) of 21
the Internal Revenue Code of 1986 is amended to read 22
as follows: 23
‘‘(2) T
HRESHOLD AMOUNT .—For purposes of 24
paragraph (1), the term ‘threshold amount’ means— 25
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‘‘(A) $400,000 in the case of a joint re-1
turn, and 2
‘‘(B) $200,000 in any other case.’’. 3
(c) P
ARTIALCREDITALLOWED FOR CERTAIN 4
O
THERDEPENDENTS.—Subsection (h) of section 24 of 5
the Internal Revenue Code of 1986 is amended to read 6
as follows: 7
‘‘(h) P
ARTIALCREDITALLOWED FOR CERTAIN 8
O
THERDEPENDENTS.— 9
‘‘(1) I
N GENERAL.—The credit determined 10
under subsection (a) shall be increased by $500 for 11
each dependent of the taxpayer (as defined in sec-12
tion 7706) other than a qualifying child described in 13
subsection (c). 14
‘‘(2) E
XCEPTION FOR CERTAIN NONCITIZENS .— 15
Paragraph (1) shall not apply with respect to any 16
individual who would not be a dependent if subpara-17
graph (A) of section 7706(b)(3) were applied with-18
out regard to all that follows ‘resident of the United 19
States’. 20
‘‘(3) C
ERTAIN QUALIFYING CHILDREN .—In the 21
case of any qualifying child with respect to whom a 22
credit is not allowed under this section by reason of 23
subsection (e)(1), such child shall be treated as a de-24
pendent to whom subparagraph (A) applies.’’. 25
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(d) MAXIMUMAMOUNT OFREFUNDABLECREDIT.— 1
Subsection (d) of section 24 of the Internal Revenue Code 2
of 1986 is amended by inserting after paragraph (2) the 3
following new paragraph: 4
‘‘(3) L
IMITATION.— 5
‘‘(A) I
N GENERAL.—The amount deter-6
mined under paragraph (1)(A) with respect to 7
any qualifying child shall not exceed $1,400, 8
and such paragraph shall be applied without re-9
gard to subsection (h). 10
‘‘(B) A
DJUSTMENT FOR INFLATION .—In 11
the case of a taxable year beginning after 2018, 12
the $1,400 amount in subparagraph (A) shall 13
be increased by an amount equal to— 14
‘‘(i) such dollar amount, multiplied by 15
‘‘(ii) the cost-of-living adjustment de-16
termined under section 1(f)(3) for the cal-17
endar year in which the taxable year be-18
gins, determined by substituting ‘2017’ for 19
‘2016’ in subparagraph (A)(ii) thereof. 20
If any increase under this clause is not a mul-21
tiple of $100, such increase shall be rounded to 22
the next lowest multiple of $100.’’. 23
(e) E
ARNEDINCOMETHRESHOLD FORREFUNDABLE 24
C
REDIT.—Section 24(d)(1)(B) of the Internal Revenue 25
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Code of 1986 is amended by striking ‘‘$3,000’’ and insert-1
ing ‘‘$2,500’’. 2
(f) S
OCIALSECURITYNUMBERREQUIRED.—Para-3
graph (1) of section 24(e) of the Internal Revenue Code 4
of 1986 is amended to read as follows: 5
‘‘(1) Q
UALIFYING CHILD SOCIAL SECURITY 6
NUMBER REQUIREMENT .—No credit shall be allowed 7
under this section to a taxpayer with respect to any 8
qualifying child unless the taxpayer includes the 9
name and social security number of such child on 10
the return of tax for the taxable year. For purposes 11
of the preceding sentence, the term ‘social security 12
number’ means a social security number issued to an 13
individual by the Social Security Administration, but 14
only if the social security number is issued— 15
‘‘(A) to a citizen of the United States or 16
pursuant to subclause (I) (or that portion of 17
subclause (III) that relates to subclause (I)) of 18
section 205(c)(2)(B)(i) of the Social Security 19
Act, and 20
‘‘(B) before the due date for such return.’’. 21
(g) R
EPEAL OFDEADWOOD.— 22
(1) I
N GENERAL.—Section 24 of the Internal 23
Revenue Code of 1986 is amended by striking sub-24
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sections (i) and (j) and by redesignating subsection 1
(k) as subsection (i). 2
(2) C
ONFORMING AMENDMENTS .—Subsection 3
(i) of section 24 of such Code, as redesignated by 4
paragraph (1), is amended— 5
(A) by striking paragraph (2)(A), 6
(B) in paragraph (2)(B)— 7
(i) by striking and all that precedes 8
‘‘In the case’’, and 9
(ii) by redesignating clauses (i) and 10
(ii) as subparagraphs (A) and (B), respec-11
tively, and by moving such subparagraphs 12
2 ems to the left, 13
(C) in paragraph (3)(A), by striking ‘‘and 14
without regard to the application of this section 15
to bona fide residents of Puerto Rico under 16
subsection (i)(1)’’, and 17
(D) in paragraph (3)(C)(ii)— 18
(i) by striking ‘‘under subparagraph 19
(B)’’ and all that follows through ‘‘Decem-20
ber 31, 2021,’’ and inserting ‘‘under sub-21
paragraph (B),’’, and 22
(ii) by striking ‘‘paragraph (2)(B)’’ 23
and inserting ‘‘paragraph (2)’’. 24
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(h) EFFECTIVEDATE.—The amendments made by 1
this section shall apply to taxable years beginning after 2
December 31, 2022. 3
SEC. 6. PERMANENT EXTENSION OF INCREASED LIMITA-4
TION FOR CERTAIN CHARITABLE CONTRIBU-5
TIONS. 6
(a) I
NGENERAL.—Section 170(b)(1)(G) of the Inter-7
nal Revenue Code of 1986 is amended— 8
(1) by striking ‘‘for any taxable year beginning 9
after December 31, 2017, and before January 1, 10
2026,’’ in clause (i), 11
(2) by striking ‘‘for any taxable year described 12
in such clause’’ in clause (ii), and 13
(3) by striking ‘‘For each taxable year de-14
scribed in clause (i), and each taxable year to which 15
any contribution under this subparagraph is carried 16
over under clause (ii), subparagraph (A)’’ in clause 17
(iii) and inserting ‘‘Subparagraph (A)’’. 18
(b) E
FFECTIVEDATE.—The amendments made by 19
this section shall apply to contributions in taxable years 20
beginning after December 31, 2025. 21
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SEC. 7. PERMANENT EXTENSION OF INCREASED CON-1
TRIBUTIONS TO ABLE ACCOUNTS. 2
(a) I
NGENERAL.—Section 529A(b)(2)(B)(ii) of the 3
Internal Revenue Code of 1986 is amended by striking 4
‘‘before January 1, 2026’’. 5
(b) A
LLOWANCE OF SAVERSCREDIT.—Section 6
25B(d)(1)(D) of the Internal Revenue Code of 1986 is 7
amended by striking ‘‘before January 1, 2026,’’. 8
(c) E
FFECTIVEDATE.—The amendments made by 9
this section shall apply to taxable years beginning after 10
the date of the enactment of this Act. 11
SEC. 8. PERMANENT EXTENSION OF ROLLOVERS TO ABLE 12
PROGRAMS FROM 529 PROGRAMS. 13
(a) I
NGENERAL.—Section 529(c)(3)(C)(i)(III) is 14
amended by striking ‘‘before January 1, 2026,’’. 15
(b) E
FFECTIVEDATE.—The amendments made by 16
this section shall apply to distributions made after the 17
date of the enactment of this Act. 18
SEC. 9. PERMANENT EXTENSION OF TREATMENT OF CER-19
TAIN INDIVIDUALS PERFORMING SERVICES 20
IN THE SINAI PENINSULA OF EGYPT. 21
(a) I
NGENERAL.—Subsection (c) of section 11026 22
of Public Law 115–97 is amended— 23
(1) by striking ‘‘beginning before January 1, 24
2026’’ in paragraph (1)(B), and 25
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(2) by striking ‘‘beginning before January 1, 1
2026’’ in paragraph (2)(B). 2
(b) E
FFECTIVEDATE.—The amendments made by 3
this section shall take effect on the date of the enactment 4
of this Act. 5
SEC. 10. PERMANENT EXTENSION OF TREATMENT OF STU-6
DENT LOANS DISCHARGED ON ACCOUNT OF 7
DEATH OR DISABILITY. 8
(a) I
NGENERAL.—Subparagraph (A) of section 9
108(f)(5) of the Internal Revenue Code of 1986 is amend-10
ed by striking ‘‘and before January 1, 2026,’’. 11
(b) E
FFECTIVEDATE.—The amendment made by 12
this section shall apply to discharges of indebtedness after 13
December 31, 2022. 14
SEC. 11. REPEAL OF DEDUCTION FOR PERSONAL EXEMP-15
TIONS. 16
(a) I
NGENERAL.—Part V of subchapter B of chapter 17
1 of the Internal Revenue Code of 1986 is hereby repealed. 18
(b) D
EFINITION OFDEPENDENTRETAINED.—Sec-19
tion 152 of the Internal Revenue Code of 1986, prior to 20
repeal by subsection (a), is hereby redesignated as section 21
7706 of such Code and moved to the end of chapter 79 22
of such Code. 23
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(c) APPLICATION TOESTATES ANDTRUSTS.—Sub-1
paragraph (C) of section 642(b)(2) of the Internal Rev-2
enue Code of 1986 is amended— 3
(1) by striking ‘‘the exemption amount under 4
section 151(d)’’ in clause (i) and inserting ‘‘$4,150’’, 5
and 6
(2) by striking clause (iii) and inserting the fol-7
lowing: 8
‘‘(iii) I
NFLATION ADJUSTMENT .—In 9
the case of any taxable year beginning in 10
a calendar year after 2018, the $4,150 11
amount in clause (i) shall be increased by 12
an amount equal to— 13
‘‘(I) such dollar amount, multi-14
plied by 15
‘‘(II) the cost-of-living adjust-16
ment determined under section 1(f)(3) 17
for the calendar year in which the tax-18
able begins, determined by sub-19
stituting ‘2017’ for ‘2016’ in subpara-20
graph (A)(ii) thereof. 21
If any increase determined under the pre-22
ceding sentence is not a multiple of $100, 23
such increase shall be rounded to the next 24
lowest multiple of $100.’’. 25
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(d) APPLICATION TONONRESIDENTALIENS.—Sec-1
tion 873(b) of the Internal Revenue Code of 1986 is 2
amended by striking paragraph (3). 3
(e) M
ODIFICATION OFRETURNREQUIREMENT.— 4
(1) I
N GENERAL.—Section 6012 of the Internal 5
Revenue Code of 1986 is amended— 6
(A) by striking paragraph (1) of subsection 7
(a) and inserting the following: 8
‘‘(1) Every individual who has gross income for 9
the taxable year, except that a return shall not be 10
required of— 11
‘‘(A) an individual who is not married (de-12
termined by applying section 7703) and who 13
has gross income for the taxable year which 14
does not exceed the standard deduction applica-15
ble to such individual for such taxable year 16
under section 63, or 17
‘‘(B) an individual entitled to make a joint 18
return if— 19
‘‘(i) the gross income of such indi-20
vidual, when combined with the gross in-21
come of such individual’s spouse, for the 22
taxable year does not exceed the standard 23
deduction which would be applicable to the 24
taxpayer for such taxable year under sec-25
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tion 63 if such individual and such individ-1
ual’s spouse made a joint return, 2
‘‘(ii) such individual and such individ-3
ual’s spouse have the same household as 4
their home at the close of the taxable year, 5
‘‘(iii) such individual’s spouse does not 6
make a separate return, and 7
‘‘(iv) neither such individual nor such 8
individual’s spouse is an individual de-9
scribed in section 63(c)(2) who has income 10
(other than earned income) in excess of the 11
amount in effect under section 12
63(c)(2)(A).’’, and 13
(B) by striking subsection (f). 14
(2) B
ANKRUPTCY ESTATES .—Paragraph (8) of 15
section 6012(a) of such Code is amended by striking 16
‘‘the sum of the exemption amount plus the basic 17
standard deduction under section 63(c)(2)(D)’’ and 18
inserting ‘‘the standard deduction in effect under 19
section 63(c)(1)(B)’’. 20
(f) C
ONFORMINGAMENDMENTS.— 21
(1) Section 1(f)(7) of the Internal Revenue 22
Code of 1986 is amended— 23
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(A) by striking ‘‘section 151(d)(4)’’ in sub-1
paragraph (A) and inserting ‘‘section 2
7706(d)(6)’’, and 3
(B) by striking ‘‘151(d)(4)’’ in subpara-4
graph (B) and inserting ‘‘7706(d)(6)’’. 5
(2) Section 2(a)(1)(B) of the Internal Revenue 6
Code of 1986 is amended by striking ‘‘a dependent’’ 7
and all that follows through ‘‘section 151’’ and in-8
serting ‘‘a dependent who (within the meaning of 9
section 7706, determined without regard to sub-10
sections (b)(1), (b)(2), and (d)(1)(B) thereof) is a 11
son, stepson, daughter, or stepdaughter of the tax-12
payer’’. 13
(3) Section 21 of such Code is amended— 14
(A) in subsection (b)(1)(A), by striking 15
‘‘section 152(a)(1)’’ and inserting ‘‘section 16
7706(a)(1)’’, 17
(B) in subsection (b)(1)(B), by striking 18
‘‘section 152’’ and inserting ‘‘section 7706’’, 19
(C) in subsection (e)(5)— 20
(i) by striking ‘‘section 152(e)’’ in 21
subparagraph (A) and inserting ‘‘section 22
7706(e)’’, and 23
(ii) by striking ‘‘section 152(e)(4)(A)’’ 24
and inserting ‘‘section 7706(e)(4)(A)’’, and 25
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(D) in subsection (e)(6)(B), by striking 1
‘‘section 152(f)(1)’’ and inserting ‘‘section 2
7706(f)(1)’’. 3
(4) Section 24(a) of such Code is amended by 4
striking ‘‘for which the taxpayer is allowed a deduc-5
tion under section 151’’ and inserting ‘‘which is a 6
dependent of the taxpayer’’. 7
(5) Section 24(c) of such Code is amended— 8
(A) in paragraph (1), by striking ‘‘section 9
152(c)’’ and inserting ‘‘section 7706(c)’’, and 10
(B) in paragraph (2), by striking ‘‘section 11
152(b)(3)’’ and inserting ‘‘section 7706(b)(3)’’. 12
(6) Section 25A(f)(1)(A)(iii) of such Code is 13
amended by striking ‘‘with respect to whom the tax-14
payer is allowed a deduction under section 151’’. 15
(7) Section 25A(g)(3) of such Code is amended 16
by striking ‘‘If a deduction under section 151 with 17
respect to an individual is allowed to another tax-18
payer’’ and inserting ‘‘If an individual is a depend-19
ent (as defined in section 7706) of another tax-20
payer’’. 21
(8) Section 25B(c)(2) of such Code is amend-22
ed— 23
(A) in subparagraph (A), by striking ‘‘with 24
respect to whom a deduction under section 151 25
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is allowed to another taxpayer’’ and inserting 1
‘‘who is a dependent of another taxpayer’’, and 2
(B) in subparagraph (B), by striking ‘‘sec-3
tion 152(f)(2)’’ and inserting ‘‘section 4
7706(f)(2)’’. 5
(9) Section 25E(c)(3)(C) is amended by strik-6
ing ‘‘with respect to whom no deduction is allowable 7
with respect to another taxpayer under section 151’’ 8
and inserting ‘‘who is a dependent (as defined in 9
section 7706) of another taxpayer’’. 10
(10) Section 32(c)(1)(A)(iii) of such Code is 11
amended by striking ‘‘for whom a deduction is allow-12
able under section 151 to’’ and inserting ‘‘of’’. 13
(11) Section 32(c)(3) of such Code is amend-14
ed— 15
(A) in subparagraph (A)— 16
(i) by striking ‘‘section 152(c)’’ and 17
inserting ‘‘section 7706(c)’’, and 18
(ii) by striking ‘‘section 152(e)’’ and 19
inserting ‘‘section 7706(e)’’, 20
(B) in subparagraph (B), by striking ‘‘un-21
less the taxpayer is entitled to a deduction 22
under section 151 for such taxable year with re-23
spect to such individual (or would be so entitled 24
but for section 152(e))’’ and inserting ‘‘unless 25
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such individual is a dependent (as defined in 1
section 7706) of such taxpayer for such taxable 2
year (or would be a dependent bu for section 3
7706(e)’’, and 4
(C) in subparagraph (C), by striking ‘‘sec-5
tion 152(c)(1)(B)’’ and inserting ‘‘section 6
7706(c)(1)(B)’’. 7
(12) Section 35(d)(1) of such Code is amended 8
by striking ‘‘with respect to whom the taxpayer is 9
entitled to a deduction under section 151(c)’’. 10
(13) Section 35(d)(2) of such Code is amend-11
ed— 12
(A) by striking ‘‘section 152(e)’’ and in-13
serting ‘‘section 7706(e)’’, and 14
(B) by striking ‘‘section 152(e)(4)(A)’’ and 15
inserting ‘‘section 7706(e)(4)(A)’’. 16
(14) Section 35(g)(4) of such Code is amended 17
by striking ‘‘with respect to whom a deduction under 18
section 151 is allowable to’’ and inserting ‘‘is a de-19
pendent (as defined in section 7706) of’’. 20
(15) Section 35(g)(10)(C)(ii) of such Code is 21
amended by striking ‘‘the taxpayer to whom the de-22
duction under section 151 is allowable’’ and insert-23
ing ‘‘the taxpayer of whom such individual is a de-24
pendent of’’. 25
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(16) Section 36(d)(3) of such Code is amended 1
by striking ‘‘a deduction under section 151 with re-2
spect to such taxpayer is allowable to another tax-3
payer for such taxable year’’ and inserting ‘‘such 4
taxpayer is a dependent of another taxpayer for such 5
taxable year’’. 6
(17) Section 36B(b)(2)(A) of such Code is 7
amended by striking ‘‘section 152’’ and inserting 8
‘‘section 7706’’. 9
(18) Section 36B(b)(3)(B) of such Code is 10
amended— 11
(A) by striking ‘‘who is not allowed a de-12
duction under section 151 for the taxable year 13
with respect to a dependent’’ and inserting 14
‘‘who does not have any dependents for the tax-15
able year’’, and 16
(B) by striking ‘‘unless a deduction is al-17
lowed under section 151 for the taxable year 18
with respect to a dependent’’ in the flush mat-19
ter at the end and inserting ‘‘unless the tax-20
payer has a dependent for the taxable year’’. 21
(19) Section 36B(c)(1)(D) of such Code is 22
amended by striking ‘‘with respect to whom a deduc-23
tion under section 151 is allowable to another tax-24
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•S 1226 IS
payer’’ and inserting ‘‘who is a dependent of another 1
taxpayer’’. 2
(20) Section 36B(d)(1) of such Code is amend-3
ed by striking ‘‘equal to the number of individuals 4
for whom the taxpayer is allowed a deduction under 5
section 151 (relating to allowance of deduction for 6
personal exemptions) for the taxable year’’ and in-7
serting ‘‘the sum of 1 (2 in the case of a joint re-8
turn) plus the number of the taxpayer’s dependents 9
for the taxable year’’. 10
(21) Section 36B(e)(1) of such Code is amend-11
ed by striking ‘‘1 or more individuals for whom a 12
taxpayer is allowed a deduction under section 151 13
(relating to allowance of deduction for personal ex-14
emptions) for the taxable year (including the tax-15
payer or his spouse)’’ and inserting ‘‘1 or more of 16
the taxpayer, the taxpayer’s spouse, or any depend-17
ent of the taxpayer’’. 18
(22) Section 42(i)(3)(D)(ii)(I) of such Code is 19
amended by striking ‘‘section 152’’ and inserting 20
‘‘section 7706’’. 21
(23) Section 45R(e)(1)(A)(iv) of such Code is 22
amended— 23
(A) by striking ‘‘section 152(d)(2)’’ and in-24
serting ‘‘section 7706(d)(2)’’, and 25
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(B) by striking ‘‘section 152(d)(2)(H)’’ 1
and inserting ‘‘section 7706(d)(2)(H)’’. 2
(24) Section 51(i)(1) of such Code is amend-3
ed— 4
(A) by striking ‘‘section 152(d)(2)’’ each 5
place it appears and inserting ‘‘section 6
7706(d)(2)’’, and 7
(B) by striking ‘‘section 152(d)(2)(H)’’ in 8
subparagraph (C) thereof and inserting ‘‘section 9
7706(d)(2)(H)’’. 10
(25) Section 56(b)(1)(D) of such Code is 11
amended by striking ‘‘, the deduction for personal 12
exemptions under section 151,’’. 13
(26) Section 63(b) of such Code is amended by 14
striking paragraph (2) and by redesignating para-15
graphs (3) and (4) as paragraphs (2) and (3), re-16
spectively. 17
(27) Section 63(c)(5) is amended by striking 18
‘‘with respect to whom a deduction under section 19
151 is allowable to’’ and inserting ‘‘who is a depend-20
ent of’’. 21
(28) Subparagraph (B) of section 63(f)(1) of 22
such Code is amended to read as follows: 23
‘‘(B) for the spouse of the taxpayer if— 24
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‘‘(i) the spouse has attained age 65 1
before the close of the taxable year, and 2
‘‘(ii) a joint return is not made by the 3
taxpayer and his spouse, and the spouse, 4
for the calendar year in which the taxable 5
year of the taxpayer begins, has no gross 6
income and is not the dependent of an-7
other taxpayer.’’. 8
(29) Subparagraph (B) of section 63(f)(2) of 9
such Code is amended to read as follows: 10
‘‘(B) for the spouse of the taxpayer if— 11
‘‘(i) the spouse is blind as of the close 12
of the taxable year, and 13
‘‘(ii) a joint return is not made by the 14
taxpayer and his spouse, and the spouse, 15
for the calendar year in which the taxable 16
year of the taxpayer begins, has no gross 17
income and is not the dependent of an-18
other taxpayer.’’. 19
(30) Section 72(t)(2)(D)(i)(III) of such Code is 20
amended by striking ‘‘section 152’’ and inserting 21
‘‘section 7706’’. 22
(31) Section 72(t)(7)(A)(iii) of such Code is 23
amended by striking ‘‘section 152(f)(1)’’ and insert-24
ing ‘‘section 7706(f)(1)’’. 25
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(32) Section 105(b) of such Code is amended— 1
(A) by striking ‘‘as defined in section 152’’ 2
and inserting ‘‘as defined in section 7706’’, 3
(B) by striking ‘‘section 152(f)(1)’’ and in-4
serting ‘‘section 7706(f)(1)’’, and 5
(C) by striking ‘‘section 152(e)’’ and in-6
serting ‘‘section 7706(e)’’. 7
(33) Section 105(c)(1) of such Code is amended 8
by striking ‘‘section 152’’ and inserting ‘‘section 9
7706’’. 10
(34) Section 125(e)(1)(D) of such Code is 11
amended by striking ‘‘section 152’’ and inserting 12
‘‘section 7706’’. 13
(35) Section 129(c) of such Code is amended— 14
(A) by striking ‘‘with respect to whom, for 15
such taxable year, a deduction is allowable 16
under section 151(c) (relating to personal ex-17
emptions for dependents) to’’ in paragraph (1) 18
and inserting ‘‘who is a dependent of’’, and 19
(B) by striking ‘‘section 152(f)(1)’’ in 20
paragraph (2) and inserting ‘‘section 21
7706(f)(1)’’. 22
(36) Section 132(h)(2)(B) of such Code is 23
amended— 24
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(A) by striking ‘‘section 152(f)(1)’’ and in-1
serting ‘‘section 7706(f)(1)’’, and 2
(B) by striking ‘‘section 152(e)’’ and in-3
serting ‘‘section 7706(e)’’. 4
(37) Section 135(c)(2)(A)(iii) is amended by 5
striking ‘‘with respect to whom the taxpayer is al-6
lowed a deduction under section 151’’. 7
(38) Section 139D(c)(5) of such Code is 8
amended by striking ‘‘section 152’’ and inserting 9
‘‘section 7706’’. 10
(39) Section 139E(c)(2) of such Code is 11
amended by striking ‘‘section 152’’ and inserting 12
‘‘section 7706’’. 13
(40) Section 162(l)(1)(D) of such Code is 14
amended by striking ‘‘section 152(f)(1)’’ and insert-15
ing ‘‘section 7706(f)(1)’’. 16
(41) Section 170(g)(1) of such Code is amend-17
ed by striking ‘‘section 152’’ and inserting ‘‘section 18
7706’’. 19
(42) Section 170(g)(3) of such Code is amend-20
ed by striking ‘‘section 152(d)(2)’’ and inserting 21
‘‘section 7706(d)(2)’’. 22
(43) Section 172(d) of such Code is amended 23
by striking paragraph (3). 24
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(44) Section 213(a) of such Code is amended 1
by striking ‘‘section 152’’ and inserting ‘‘section 2
7706’’. 3
(45) Section 213(d)(5) of such Code is amend-4
ed by striking ‘‘section 152(e)’’ and inserting ‘‘sec-5
tion 7706(e)’’. 6
(46) Section 213(e)(11) of such Code is amend-7
ed by striking ‘‘section 152(d)(2)’’ and inserting 8
‘‘section 7706(d)(2)’’. 9
(47) Section 220(b)(6) of such Code is amend-10
ed by striking ‘‘with respect to whom a deduction 11
under section 151 is allowable to’’ and inserting 12
‘‘who is a dependent of’’. 13
(48) Section 220(d)(2)(A) of such Code is 14
amended by striking ‘‘section 152’’ and inserting 15
‘‘section 7706’’. 16
(49) Section 221(c) of such Code is amended by 17
striking ‘‘a deduction under section 151 with respect 18
to such individual is allowed to’’ and inserting ‘‘such 19
individual is a dependent of’’. 20
(50) Section 221(d)(4) of such Code is amend-21
ed by striking ‘‘section 152’’ and inserting ‘‘section 22
7706’’. 23
(51) Section 223(b)(6) of such Code is amend-24
ed by striking ‘‘with respect to whom a deduction 25
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under section 151 is allowable to’’ and inserting 1
‘‘who is a dependent of’’. 2
(52) Section 223(d)(2)(A) of such Code is 3
amended by striking ‘‘section 152’’ and inserting 4
‘‘section 7706’’. 5
(53) Section 401(h) of such Code is amended 6
by striking ‘‘section 152(f)(1)’’ in the last sentence 7
and inserting ‘‘section 7706(f)(1)’’. 8
(54) Section 402(l)(4)(D) of such Code is 9
amended by striking ‘‘section 152’’ and inserting 10
‘‘section 7706’’. 11
(55) Section 409A(a)(2)(B)(ii)(I) of such Code 12
is amended by striking ‘‘section 152(a)’’ and insert-13
ing ‘‘section 7706(a)’’. 14
(56) Section 443 is amended by striking sub-15
section (c). 16
(57) Section 501(c)(9) of such Code is amended 17
by striking ‘‘section 152(f)(1)’’ and inserting ‘‘sec-18
tion 7706(f)(1)’’. 19
(58) Section 529(c)(9)(C)(iii) of such Code is 20
amended by striking ‘‘section 152(d)(2)(B)’’ and in-21
serting ‘‘section 7706(d)(2)(B)’’. 22
(59) Section 529(e)(2)(B) of such Code is 23
amended by striking ‘‘section 152(d)(2)’’ and insert-24
ing ‘‘section 7706(d)(2)’’. 25
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(60) Section 529A(e)(4) of such Code is amend-1
ed— 2
(A) by striking ‘‘section 152(d)(2)(B)’’ and 3
inserting ‘‘section 7706(d)(2)(B)’’, and 4
(B) by striking ‘‘section 152(f)(1)(B)’’ and 5
inserting ‘‘section 7706(f)(1)(B)’’. 6
(61) Section 703(a)(2) of such Code is amended 7
by striking subparagraph (A) and by redesignating 8
subparagraphs (B) through (F) as subparagraphs 9
(A) through (E), respectively. 10
(62) Section 873(b) is amended by striking 11
paragraph (3). 12
(63) Section 874 of such Code is amended by 13
striking subsection (b) and by redesignating sub-14
section (c) as subsection (b). 15
(64) Section 891 of such Code is amended by 16
striking ‘‘under section 151 and’’. 17
(65) Section 904(b) of such Code is amended 18
by striking paragraph (1). 19
(66) Section 931(b)(1) of such Code is amend-20
ed by striking ‘‘(other than the deduction under sec-21
tion 151, relating to personal exemptions)’’. 22
(67) Section 933 of such Code is amended— 23
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(A) by striking ‘‘(other than the deduction 1
under section 151, relating to personal exemp-2
tions)’’ in paragraph (1), and 3
(B) by striking ‘‘(other than the deduction 4
for personal exemptions under section 151)’’ in 5
paragraph (2). 6
(68) Section 1212(b)(2)(B)(ii) of such Code is 7
amended to read as follows: 8
‘‘(ii) in the case of an estate or trust, 9
the deduction allowed for such year under 10
section 642(b).’’. 11
(69) Section 1361(c)(1)(C) of such Code is 12
amended by striking ‘‘section 152(f)(1)(C)’’ and in-13
serting ‘‘section 7706(f)(1)(C)’’. 14
(70) Section 1402(a) of such Code is amended 15
by striking paragraph (7). 16
(71) Section 2032A(c)(7)(D) of such Code is 17
amended by striking ‘‘section 152(f)(2)’’ and insert-18
ing ‘‘section 7706(f)(2)’’. 19
(72) Section 3402(f)(1)(A) of such Code is 20
amended by striking ‘‘for whom a deduction is al-21
lowed with respect to another taxpayer under section 22
151’’ and inserting ‘‘who is a dependent of another 23
taxpayer’’. 24
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(73) Section 3402(m)(1) of such Code is 1
amended by striking ‘‘other than the deductions re-2
ferred to in section 151 and’’. 3
(74) Section 3402(r)(2) of such Code is amend-4
ed by striking ‘‘the sum of—’’ and all that follows 5
and inserting ‘‘the standard deduction in effect 6
under section 63(c)(1)(B).’’. 7
(75) Section 5000A(b)(3)(A) of such Code is 8
amended by striking ‘‘section 152’’ and inserting 9
‘‘section 7706’’. 10
(76) Section 5000A(c)(4)(A) of such Code is 11
amended by striking ‘‘the number of individuals for 12
whom the taxpayer is allowed a deduction under sec-13
tion 151 (relating to allowance of deduction for per-14
sonal exemptions) for the taxable year’’ and insert-15
ing ‘‘the sum of 1 (2 in the case of a joint return) 16
plus the number of the taxpayer’s dependents for 17
the taxable year’’. 18
(77) Section 6013(b)(3)(A) of such Code is 19
amended— 20
(A) by striking ‘‘had less than the exemp-21
tion amount of gross income’’ in clause (ii) and 22
inserting ‘‘had no gross income’’, 23
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(B) by striking ‘‘had gross income of the 1
exemption amount or more’’ in clause (iii) and 2
inserting ‘‘had any gross income’’, and 3
(C) by striking the flush language fol-4
lowing clause (iii). 5
(78) Section 6103(l)(21)(A)(iii) of such Code is 6
amended to read as follows: 7
‘‘(iii) the number of the taxpayer’s de-8
pendents,’’. 9
(79) Section 6213(g)(2)(H) of such Code is 10
amended by striking ‘‘or section 151 (relating to al-11
lowance of deductions for personal exemptions)’’. 12
(80) Section 6334(d)(2) of such Code is amend-13
ed to read as follows: 14
‘‘(2) E
XEMPT AMOUNT.— 15
‘‘(A) I
N GENERAL.—For purposes of para-16
graph (1), the term ‘exempt amount’ means an 17
amount equal to— 18
‘‘(i) the sum of the amount deter-19
mined under subparagraph (B) and the 20
standard deduction, divided by 21
‘‘(ii) 52. 22
‘‘(B) A
MOUNT DETERMINED .—For pur-23
poses of subparagraph (A), the amount deter-24
mined under this subparagraph is $4,150 multi-25
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plied by the number of the taxpayer’s depend-1
ents for the taxable year in which the levy oc-2
curs. 3
‘‘(C) I
NFLATION ADJUSTMENT .—In the 4
case of any taxable year beginning after 2018, 5
the $4,150 amount in subparagraph (B) shall 6
be increased by an amount equal to— 7
‘‘(i) such dollar amount, multiplied by 8
‘‘(ii) the cost-of-living adjustment de-9
termined under section 1(f)(3) for the cal-10
endar year in which the taxable year be-11
gins, by substituting ‘calendar year 2017’ 12
for ‘calendar year 2016’ in subparagraph 13
(A) thereof. 14
If any increase determined under the preceding 15
sentence is not a multiple of $100, such in-16
crease shall be rounded to the next lowest mul-17
tiple of $100. 18
‘‘(D) V
ERIFIED STATEMENT .—Unless the 19
taxpayer submits to the Secretary a written and 20
properly verified statement specifying the facts 21
necessary to determine the proper amount 22
under subparagraph (A), subparagraph (A) 23
shall be applied as if the taxpayer were a mar-24
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ried individual filing a separate return with no 1
dependents.’’. 2
(81) Section 6334(d) of such Code is amended 3
by striking paragraph (4). 4
(82) Section 7702B(f)(2)(C)(iii) of such Code is 5
amended by striking ‘‘section 152(d)(2)’’ and insert-6
ing ‘‘section 7706(d)(2)’’. 7
(83) Section 7703(a) of such Code is amended 8
by striking ‘‘part V of subchapter B of chapter 1 9
and’’. 10
(84) Section 7703(b)(1) of such Code is amend-11
ed— 12
(A) by striking ‘‘section 152(f)(1)’’ and all 13
that follows and inserting ‘‘section 7706(f)(1),’’, 14
and 15
(B) by striking ‘‘section 152(e)’’ and in-16
serting ‘‘section 7706(e)’’. 17
(85) Section 7706(a) of such Code, as redesig-18
nated by this section, is amended by striking ‘‘this 19
subtitle’’ and inserting ‘‘subtitle A’’. 20
(86)(A) Section 7706(d)(1)(B) of such Code, as 21
redesignated by this section, is amended by striking 22
‘‘the exemption amount (as defined in section 23
151(d))’’ and inserting ‘‘$4,150’’. 24
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(B) Section 7706(d) of such Code, as redesig-1
nated by this section, is amended by adding at the 2
end the following new paragraph: 3
‘‘(6) I
NFLATION ADJUSTMENT .—In the case of 4
any calendar year beginning after 2018, the $4,150 5
amount in paragraph (1)(B) shall be increased by an 6
amount equal to— 7
‘‘(A) such dollar amount, multiplied by 8
‘‘(B) the cost-of-living adjustment deter-9
mined under section 1(f)(3) for such calendar 10
year, determined by substituting ‘calendar year 11
2017’ for ‘calendar year 2016’ in subparagraph 12
(A)(ii) thereof. 13
If any increase determined under the preceding sen-14
tence is not a multiple of $100, such increase shall 15
be rounded to the next lowest multiple of $100.’’. 16
(87) The table of sections for chapter 79 of 17
such Code is amended by adding at the end the fol-18
lowing new item: 19
‘‘Sec. 7706. Dependent defined.’’.
(g) EFFECTIVEDATE.—The amendments made by 20
this section shall apply to taxable years beginning after 21
December 31, 2022. 22
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SEC. 12. PERMANENT EXTENSION OF LIMITATION ON DE-1
DUCTION FOR STATE AND LOCAL, ETC., 2
TAXES. 3
(a) I
NGENERAL.—Paragraph (6) of section 164(b) 4
of the Internal Revenue Code of 1986 is amended— 5
(1) by striking ‘‘, and before January 1, 2026’’, 6
and 7
(2) by striking ‘‘
2018 THROUGH 2025’’ in the 8
heading and inserting ‘‘
AFTER 2017’’. 9
(b) E
FFECTIVEDATE.—The amendments made by 10
this section shall apply to taxable years beginning after 11
December 31, 2022. 12
SEC. 13. PERMANENT EXTENSION OF LIMITATION ON DE-13
DUCTION FOR QUALIFIED RESIDENCE INTER-14
EST. 15
(a) R
EPEAL OFHOMEEQUITYINDEBTEDNESS.— 16
(1) I
N GENERAL.—Section 163(h)(3)(A) of the 17
Internal Revenue Code of 1986 is amended by strik-18
ing ‘‘during the taxable year on’’ and all that follows 19
through ‘‘For purposes of’’ and inserting ‘‘during 20
the taxable year on acquisition indebtedness with re-21
spect to any qualified principal residence of the tax-22
payer. For purposes of’’. 23
(2) C
ONFORMING AMENDMENT .—Section 24
163(h)(3) of such Code is amended by striking sub-25
paragraph (C). 26
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(b) LIMITATION ONACQUISITIONINDEBTEDNESS.— 1
(1) I
N GENERAL.—Section 163(h)(3)(B)(ii) of 2
the Internal Revenue Code of 1986 is amended by 3
striking ‘‘$1,000,000 ($500,000’’ and inserting 4
‘‘$750,000 ($375,000’’. 5
(2) T
REATMENT OF INDEBTEDNESS INCURRED 6
ON OR BEFORE DECEMBER 31 , 2017; 7
REFINANCINGS.—Section 163(h)(3) of the Internal 8
Revenue Code of 1986, as amended by subsection 9
(a)(2), is amended by inserting after subparagraph 10
(B) the following new subparagraph: 11
‘‘(C) T
REATMENT OF INDEBTEDNESS IN -12
CURRED ON OR BEFORE DECEMBER 15 , 2017; 13
REFINANCINGS.— 14
‘‘(i) I
N GENERAL.—In the case of any 15
indebtedness incurred on or before Decem-16
ber 15, 2017, subparagraph (B)(ii) shall 17
apply as in effect immediately before the 18
enactment of the Public Law 115–97, and, 19
in applying such subparagraph to any in-20
debtedness incurred after such date, the 21
limitation under such subparagraph shall 22
be reduced (but not below zero) by the 23
amount of any indebtedness incurred on or 24
before December 15, 2017, which is treat-25
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ed as acquisition indebtedness for purposes 1
of this subsection for the taxable year. 2
‘‘(ii) B
INDING CONTRACT EXCEP -3
TION.—In the case of a taxpayer who en-4
ters into a written binding contract before 5
December 15, 2017, to close on the pur-6
chase of a principal residence before Janu-7
ary 1, 2018, and who purchases such resi-8
dence before April 1, 2018, subclause (III) 9
shall be applied by substituting ‘April 1, 10
2018’ for ‘December 15, 2017’. 11
‘‘(iii) T
REATMENT OF REFINANCINGS 12
OF INDEBTEDNESS.— 13
‘‘(I) I
N GENERAL.—In the case 14
of any indebtedness which is incurred 15
to refinance indebtedness, such refi-16
nanced indebtedness shall be treated 17
for purposes of clause (i) as incurred 18
on the date that the original indebted-19
ness was incurred to the extent the 20
amount of the indebtedness resulting 21
from such refinancing does not exceed 22
the amount of the refinanced indebt-23
edness. 24
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‘‘(II) LIMITATION ON PERIOD OF 1
REFINANCING.—Subclause (I) shall 2
not apply to any indebtedness after 3
the expiration of the term of the origi-4
nal indebtedness or, if the principal of 5
such original indebtedness is not am-6
ortized over its term, the expiration of 7
the term of the 1st refinancing of 8
such indebtedness (or if earlier, the 9
date which is 30 years after the date 10
of such 1st refinancing).’’. 11
(c) C
OORDINATIONWITHEXCLUSION OF INCOME 12
F
ROM DISCHARGE OF INDEBTEDNESS.—Section 13
108(h)(2) of the Internal Revenue Code of 1986 is amend-14
ed by striking ‘‘, applied by substituting’’ and all that fol-15
lows through ‘‘section 163(h)(3)(F)(i)(II)’’. 16
(d) C
ONFORMINGAMENDMENTS.—Section 163(h)(3) 17
of the Internal Revenue Code of 1986 is amended— 18
(1) in the heading of subparagraph (D)(ii), by 19
striking ‘‘$1,000,000’’, and 20
(2) by striking subparagraph (F). 21
(e) E
FFECTIVEDATE.—The amendments made by 22
this section shall apply to taxable years beginning after 23
December 31, 2022. 24
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SEC. 14. PERMANENT EXTENSION OF MODIFICATIONS TO 1
DEDUCTION FOR PERSONAL CASUALTY 2
LOSSES. 3
(a) I
NGENERAL.—Paragraph (5) of section 165(h) 4
of the Internal Revenue Code of 1986 is amended— 5
(1) by striking ‘‘, and before January 1, 2026’’ 6
in subparagraph (A), and 7
(2) by striking ‘‘
2018 THROUGH 2025’’ in the 8
heading and inserting ‘‘
AFTER 2017’’. 9
(b) E
FFECTIVEDATE.—The amendments made by 10
this section shall apply to losses incurred in taxable years 11
beginning after December 31, 2022. 12
SEC. 15. REPEAL OF MISCELLANEOUS ITEMIZED DEDUC-13
TIONS. 14
(a) I
NGENERAL.—Section 67 of the Internal Rev-15
enue Code of 1986 is amended— 16
(1) by striking subsection (a) and inserting the 17
following: 18
‘‘(a) G
ENERALRULE.—No miscellaneous itemized 19
deduction shall be allowed for any taxable year beginning 20
after December 31, 2017.’’, 21
(2) by striking subsection (g), and 22
(3) by striking ‘‘
2-PERCENT FLOOR ON ’’ in 23
the heading and inserting ‘‘
TREATMENT OF ’’. 24
(b) C
ONFORMINGAMENDMENT.—The table of sec-25
tions for part I of subchapter B of chapter 1 of the Inter-26
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nal Revenue Code of 1986 is amended by striking ‘‘2-per-1
cent floor on’’ in the item relating to section 67 and insert-2
ing ‘‘Treatment of’’. 3
(c) E
FFECTIVEDATE.—The amendments made by 4
this section shall apply to taxable years beginning after 5
December 31, 2022. 6
SEC. 16. REPEAL OF OVERALL LIMITATION ON ITEMIZED 7
DEDUCTIONS. 8
(a) I
NGENERAL.—Part 1 of subchapter B of chapter 9
1 of the Internal Revenue Code of 1986 is amended by 10
striking section 68 (and the item relating to such section 11
in the table of sections for such part). 12
(b) C
ONFORMINGAMENDMENTS.— 13
(1) Section 1(f)(7) of the Internal Revenue 14
Code of 1986, as amended by this Act, is amended 15
by striking ‘‘section 63(c)(4), or section 68(b)(2)’’ 16
and inserting ‘‘or section 63(c)(4)’’. 17
(2) Section 56(b)(1) of such Code is amended 18
by striking subparagraph (E). 19
(3) Section 164(b)(5)(H)(ii)(III) of such Code 20
is amended by inserting ‘‘(as in effect before the 21
date of the enactment of the Tax Cuts and Jobs 22
Act)’’ after ‘‘68(b)’’. 23
(4) Section 642(b)(2)(C)(i)(I) of such Code is 24
amended by striking ‘‘as an individual described in 25
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section 68(b)(1)(C)’’ and inserting ‘‘as an individual 1
who is not married and who is not a surviving 2
spouse or head of household’’. 3
(5) Section 773(a)(3)(B) of such Code is 4
amended by striking clause (i) and redesignating 5
clauses (ii) through (iv) as clauses (i) through (iii), 6
respectively. 7
(c) E
FFECTIVEDATE.—The amendments made by 8
this section shall apply to taxable years beginning after 9
December 31, 2022. 10
SEC. 17. REPEAL OF EXCLUSION FOR QUALIFIED BICYCLE 11
COMMUTING REIMBURSEMENT. 12
(a) I
NGENERAL.—Section 132(f)(1) of the Internal 13
Revenue Code of 1986 is amended by striking subpara-14
graph (D). 15
(b) C
ONFORMINGAMENDMENTS.— 16
(1) Section 132(f)(2) of the Internal Revenue 17
Code of 1986 is amended by inserting ‘‘and’’ at the 18
end of subparagraph (A), by striking ‘‘, and’’ at the 19
end of subparagraph (B) and inserting a period, and 20
by striking subparagraph (C). 21
(2) Section 132(f)(4) of such Code is amended 22
by striking ‘‘(other than a qualified bicycle com-23
muting reimbursement)’’. 24
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(3) Section 132(f)(5) of such Code is amended 1
by striking subparagraph (F). 2
(4) Section 132(f) of such Code is amended by 3
striking paragraph (8). 4
(c) E
FFECTIVEDATE.—The amendments made by 5
this section shall apply to taxable years beginning after 6
December 31, 2022. 7
SEC. 18. PERMANENT EXTENSION OF MODIFICATION OF EX-8
CLUSION FOR QUALIFIED MOVING EXPENSE 9
REIMBURSEMENT. 10
(a) I
NGENERAL.—Section 132(g) of the Internal 11
Revenue Code of 1986 is amended— 12
(1) in paragraph (1), by striking ‘‘individual’’ 13
and inserting ‘‘qualified military member’’, and 14
(2) by striking paragraph (2) and inserting the 15
following: 16
‘‘(2) Q
UALIFIED MILITARY MEMBER .—For pur-17
poses of paragraph (1), the term ‘qualified military 18
member’ means a member of the Armed Forces of 19
the United States on active duty who moves pursu-20
ant to a military order and incident to a permanent 21
change of station.’’. 22
(b) E
FFECTIVEDATE.—The amendments made by 23
this section shall apply to taxable years beginning after 24
December 31, 2022. 25
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SEC. 19. REPEAL OF DEDUCTION FOR MOVING EXPENSES. 1
(a) I
NGENERAL.—Subsection (a) of section 217 of 2
the Internal Revenue Code of 1986 is amended to read 3
as follows: 4
‘‘(a) D
EDUCTIONALLOWED.—There shall be allowed 5
as a deduction moving expenses paid or incurred during 6
the taxable year in connection with the commencement of 7
work by a member of the Armed Forces of the United 8
States on active duty who moves pursuant to a military 9
order and incident to a permanent change of station.’’. 10
(b) C
ONFORMINGAMENDMENTS.— 11
(1) Section 217 of the Internal Revenue Code 12
of 1986 is amended— 13
(A) by striking subsections (c), (d), (f), 14
and (i), 15
(B) by redesignating subsections (g), (h), 16
and (j) as subsections (c), (d), and (e), respec-17
tively, and 18
(C) in subsection (c), as so redesignated— 19
(i) by striking paragraph (1) and re-20
designating paragraphs (2) and (3) as 21
paragraphs (1) and (2), respectively, and 22
(ii) in paragraph (2) (as so redesig-23
nated), by striking ‘‘moving expenses of his 24
spouse and dependents’’ and all that fol-25
lows and inserting ‘‘moving expenses of his 26
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spouse and dependents as if his spouse 1
commenced work as an employee at a new 2
principal place of work at such location.’’. 3
(2) Section 23 of such Code is amended by 4
striking ‘‘217(h)(3)’’ each place it appears in sub-5
sections (d)(3) and (e) and inserting ‘‘217(d)(3)’’. 6
(c) E
FFECTIVEDATE.—The amendments made by 7
this section shall apply to taxable years beginning after 8
December 31, 2022. 9
SEC. 20. PERMANENT EXTENSION OF LIMITATION ON WA-10
GERING LOSSES. 11
(a) I
NGENERAL.—The second sentence of section 12
165(d) of the Internal Revenue Code of 1986 is amended 13
by striking ‘‘in the case of taxable years beginning after 14
December 31, 2017, and before January 1, 2026,’’. 15
(b) E
FFECTIVEDATE.—The amendments made by 16
this section shall not apply to taxable years beginning 17
after December 31, 2022. 18
SEC. 21. INCREASE IN ESTATE AND GIFT TAX EXEMPTION 19
MADE PERMANENT. 20
(a) I
NGENERAL.—Section 2010(c)(3)(A) of the In-21
ternal Revenue Code of 1986 is amended by striking 22
‘‘$5,000,000’’ and inserting ‘‘$10,000,000’’. 23
(b) C
ONFORMINGAMENDMENTS.— 24
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(1) Section 2010(c)(3) of the Internal Revenue 1
Code of 1986 is amended by striking subparagraph 2
(C). 3
(2) Subsection (g) of section 2001 of such Code 4
is amended to read as follows: 5
‘‘(g) M
ODIFICATIONSTOGIFTTAXPAYABLETORE-6
FLECTDIFFERENTTAXRATES.—For purposes of apply-7
ing subsection (b)(2) with respect to 1 or more gifts, the 8
rates of tax under subsection (c) in effect at the decedent’s 9
death shall, in lieu of the rates of tax in effect at the time 10
of such gifts, be used both to compute— 11
‘‘(1) the tax imposed by chapter 12 with respect 12
to such gifts, and 13
‘‘(2) the credit allowed against such tax under 14
section 2505, including in computing— 15
‘‘(A) the applicable credit amount under 16
section 2505(a)(1), and 17
‘‘(B) the sum of the amounts allowed as a 18
credit for all preceding periods under section 19
2505(a)(2).’’. 20
(c) E
FFECTIVEDATE.—The amendments made by 21
this section shall apply to estates of decedents dying and 22
gifts made after December 31, 2022. 23
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SEC. 22. INCREASE IN ALTERNATIVE MINIMUM TAX EXEMP-1
TION MADE PERMANENT. 2
(a) I
NGENERAL.—Section 55(d) of the Internal Rev-3
enue Code of 1986 is amended— 4
(1) in paragraph (1)— 5
(A) by striking ‘‘$78,750’’ in subparagraph 6
(A) and inserting ‘‘$109,400’’, and 7
(B) by striking ‘‘$50,600’’ in subpara-8
graph (B) and inserting ‘‘$70,300’’, and 9
(2) in paragraph (2)— 10
(A) by striking ‘‘$150,000’’ in subpara-11
graph (A) and inserting ‘‘$1,000,000’’, and 12
(B) by striking subparagraphs (B) and (C) 13
and inserting the following: 14
‘‘(B) 50 percent of the dollar amount ap-15
plicable under subparagraph (A) in the case of 16
a taxpayer described in subparagraph (B) or 17
(C) of paragraph (1), and 18
‘‘(C) 50 percent of $150,000 in the case of 19
a taxpayer described in paragraph (1)(D).’’. 20
(b) I
NFLATIONADJUSTMENT.— 21
(1) I
N GENERAL.—Section 55(d)(3)(A)(ii) of 22
the Internal Revenue Code of 1986 is amended to 23
read as follows: 24
‘‘(ii) the cost-of-living adjustment de-25
termined under section 1(f)(3) for the cal-26
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endar year in which the taxable year be-1
gins, by substituting for ‘calendar year 2
2016’ in subparagraph (A)(ii) thereof— 3
‘‘(I) ‘calendar year 2011’ in the 4
case of the dollar amounts described 5
in clauses (i), (iv), and (v) of subpara-6
graph (B), and 7
‘‘(II) ‘calendar year 2017’ in the 8
case of the dollar amounts described 9
in clauses (ii) and (iii) of subpara-10
graph (B).’’. 11
(2) C
ONFORMING AMENDMENTS .—Section 12
55(d)(3)(B) of such Code is amended— 13
(A) by striking ‘‘subparagraphs (A), (B), 14
and (D) of paragraph (1), and’’ in clause (ii) 15
and inserting ‘‘subparagraphs (A) and (B) of 16
paragraph (1),’’, 17
(B) by striking ‘‘subparagraphs (A) and 18
(B) of paragraph (2).’’ in clause (iii) and in-19
serting ‘‘paragraph (2)(A),’’, and 20
(C) by adding at the end the following: 21
‘‘(iv) the dollar amount contained in 22
paragraph (1)(D), and 23
‘‘(v) the dollar amount contained in 24
paragraph (2)(C).’’. 25
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(c) TREATMENT OF UNEARNEDINCOME OFMINOR 1
C
HILDREN.—Section 59 of the Internal Revenue Code of 2
1986 is amended by striking subsection (j). 3
(d) E
FFECTIVEDATE.—The amendments made by 4
this section shall apply to taxable years beginning after 5
December 31, 2022. 6
SEC. 23. TECHNICAL AMENDMENT. 7
Section 11000 of Public Law 115–97 is amended by 8
redesignating subsection (a) as subsection (b) and by in-9
serting before subsection (b) (as so redesignated) the fol-10
lowing new subsection: 11
‘‘(a) S
HORTTITLE.—This title may be cited as the 12
‘Tax Cuts and Jobs Act’.’’. 13
Æ
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