,,ii #aacth ,,congress #b;d ,session ,s4 #bfha ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,july #bi1 #bjad ,mr4 ,pryor 7for himself and ,mr4 ,walsh7 introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to provide incentives for businesses to keep jobs in the ,united ,states4 #a4 ,short title ,this ,act may be cited as the ,keeping ,jobs in ,america ,act4 #b4 ,inbound investment program to recruit jobs to the ,united ,states 7a7 ,definitions ,in this section3 7#a7 ,distressed ,the term distressed1 with respect to an area1 means an area in the ,united ,states that1 on the date on which the program is established under subsection 7b7-- 7,a7 is included in the most recent classification of labor surplus areas by the ,secretary of ,labor2 and 7,b7 has an unemployment rate equal to or greater than #aaj percent of the unemployment rate of the ,united ,states4 7#b7 ,eligible entity ,the term eligible entity means an entity that employs not fewer than #ej full-time equivalent employees in high-value jobs4 7#c7 ,eligible facility ,the term eligible facility means a facility at which-- 7,a7 an eligible entity employs not fewer than #ej full-time equivalent employees in high-value jobs2 7,b7 with respect to a rural or distressed area1 the mean of the wages provided by the eligible entity to individuals employed at such facility is greater than the mean wage for the county in which the rural or distressed area is located2 and 7,c7 derives at least the majority of its revenues from-- 7i7 goods production2 or 7ii7 providing product design1 engineering1 marketing1 or information technology services4 7#d7 ,high-value job defined ,the term high-value job means a job that-- 7,a7 exists within an eligible facility2 and 7,b7 has a ,north ,american ,industrial ,classification that corresponds with manufacturing1 software publishers1 computer systems design1 or related codes1 and is higher than the mean hourly wage in the country4 7#e7 ,rural ,the term rural1 with respect to an area1 means any area in the ,united ,states which1 as confirmed by the latest decennial census1 is not located within-- 7,a7 a city or town that has a population of greater than #ej1jjj inhabitants2 or 7,b7 an urbanized area contiguous and adjacent to a city or town described in subparagraph 7,a74 7b7 ,program required ,not later than #ahj days after the date of the enactment of this ,act1 the ,secretary of ,commerce shall establish a program to award grants to ,states that are recruiting high-value jobs4 ,grants awarded under this section may be used to issue forgivable loans to eligible entities that are deciding whether to locate eligible facilities in the ,united ,states to assist such entities in locating such facilities in rural or distressed areas4 7c7 ,federal grants to ,states 7#a7 ,in general ,the ,secretary shall carry out the program through the award of grants to ,states to provide loans and loan guarantees described in subsection 7d74 7#b7 ,application 7,a7 ,in general ,a ,state seeking a grant under the program shall submit an application to the ,secretary in such manner and containing such information as the ,secretary may require4 ,once the program is operational1 any ,state may apply for a grant on an ongoing basis1 until funds are exhausted4 ,the ,secretary may also establish a process for pre-clearing applications from ,states4 ,the ,secretary shall notify all ,states of this grant opportunity once the program is operational4 ,all information about the program and the ,state application process must be online and must be in a format that is easily understood and is widely accessible4 7,b7 ,elements ,each application submitted by a ,state under subparagraph 7,a7 shall include-- 7i7 a description of the eligible entity the ,state proposes to assist in locating an eligible facility in a rural or distressed area of the ,state2 7ii7 a description of such facility1 including the number of high-value jobs relating to such facility2 7iii7 a description of such rural or distressed area2 7iv7 a description of the resources of the ,state that the ,state has committed to assisting such corporation in locating such facility1 including tax incentives provided1 bonding authority exercised1 and land granted2 and 7v7 such other elements as the ,secretary considers appropriate4 7,c7 ,notice ,as soon as practicable after establishing the program under subsection 7b71 the ,secretary shall notify all ,states of the grants available under the program and the process for applying for such grants4 7,d7 ,online submission of applications ,the ,secretary shall establish a mechanism for the electronic submission of applications under subparagraph 7,a74 ,such mechanism shall utilize an ,internet website and all information on such website shall be in a format that is easily understood and widely accessible4 7,e7 ,confidentiality ,the ,secretary may not make public any information submitted by a ,state to the ,secretary under this paragraph regarding the efforts of such ,state to assist an eligible entity in locating an eligible facility in such ,state without the express consent of the ,state4 7#c7 ,selection ,the ,secretary shall award grants under the program on a competitive basis to ,states that-- 7,a7 the ,secretary determines are most likely to succeed with a grant under the program in assisting an eligible entity in locating an eligible facility in a rural or distressed area2 7,b7 if successful in assisting an eligible entity as described in subparagraph 7,a71 will create the greatest number of high-value jobs in rural or distressed areas2 7,c7 have committed significant resources1 to the extent of their ability as determined by the ,secretary1 to assisting eligible entities in locating eligible facilities in a rural or distressed areas2 or 7,d7 meet such other criteria as the ,secretary considers appropriate1 including criteria relating to marketing plans1 benefits to ongoing regional or ,state strategies for economic development1 and job growth4 7#d7 ,limitation on competition between states ,the ,secretary may not award a grant to a ,state under the program to assist an eligible entity-- 7,a7 in locating an eligible facility in such ,state if another ,state is already seeking to assist such eligible entity in locating such eligible facility in such other ,state2 or 7,b7 from relocating an eligible facility from one ,state to another ,state4 7#e7 ,availability of grant amounts ,for each grant awarded to a ,state under the program1 the ,secretary shall make available to such ,state the amount of such grant not later than #cj days after the date on which the ,secretary awarded the grant4 ,the total amount of grants awarded under this program may not exceed #ajj1jjj1jjj4 7d7 ,loans and loan guarantees from ,states to corporations 7#a7 ,in general ,amounts received by a ,state under the program shall be used to provide assistance to an eligible entity to locate an eligible facility in a rural or distressed area of the ,state4 7#b7 ,loans and loan guarantees ,a ,state receiving a grant under the program may provide assistance under paragraph 7#a7 in the form of-- 7,a7 a single loan to a single eligible entity as described in paragraph 7#a7 to cover the costs incurred by the eligible entity in locating the eligible facility as described in such paragraph2 or 7,b7 a single loan guarantee to a financial institution making a single loan to a single eligible entity as described in paragraph 7#a7 to cover the costs incurred by the eligible entity in locating the eligible facility as described in such paragraph4 7#c7 ,terms and conditions ,each loan or loan guarantee provided under paragraph 7#b7 shall have a term of #e years and shall bear interest at rates equal to the ,federal long-term rate under section #abgd7;d77#a77;,c7 of the ,internal ,revenue ,code of #aihf4 7#d7 ,amount ,the amount of a loan or loan guarantee issued to an eligible entity under the program for the location of an eligible facility shall be an amount equal to not more than #e1jjj per full-time equivalent employee to be employed at such facility4 7#e7 ,repayment ,repayment of a loan issued by a ,state to an eligible entity under the program shall be repaid in accordance with such schedule as the ,state shall establish in accordance with such rules as the ,secretary shall prescribe for purposes of the program4 ,such rules shall provide for the following3 7,a7 ,forgiveness of all or a portion of the loan1 the amount of such forgiveness depending upon the following3 7i7 ,the performance of the borrower4 7ii7 ,the number or quality of the jobs at the facility located under the program4 7,b7 ,repayment of principal or interest1 if any1 at the end of the term of the loan4 7e7 ,assessment and recommendations 7#a7 ,ongoing assessment ,the ,secretary shall conduct an ongoing assessment of the program4 7#b7 ,recommendations ,the ,secretary may submit to ,congress recommendations for such legislative action as the ,secretary considers appropriate to improve the program1 including with respect to any findings of the ,secretary derived by comparing the program established under subsection 7b7 with the programs and policies of governments of other countries used to recruit high-value jobs4 #c4 ,credit for insourcing expenses 7a7 ,in general ,subpart ,d of part ,,iv of subchapter ,a of chapter #a of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new section3 #de,s4 ,credit for insourcing expenses 7a7 ,in general ,for purposes of section #ch1 the insourcing expenses credit for any taxable year is an amount equal to #bj percent of the eligible insourcing expenses of the taxpayer which are taken into account in such taxable year under subsection 7d74 7b7 ,eligible insourcing expenses ,for purposes of this section-- 7#a7 ,in general ,the term eligible insourcing expenses means-- 7,a7 eligible expenses paid or incurred by the taxpayer in connection with the elimination of any business unit of the taxpayer 7or of any member of any expanded affiliated group in which the taxpayer is also a member7 located outside the ,united ,states1 and 7,b7 eligible expenses paid or incurred by the taxpayer in connection with the establishment of any business unit of the taxpayer 7or of any member of any expanded affiliated group in which the taxpayer is also a member7 located within the ,united ,states1 if such establishment constitutes the relocation of the business unit so eliminated4 ,for purposes of the preceding sentence1 a relocation shall not be treated as failing to occur merely because such elimination occurs in a different taxable year than such establishment4 7#b7 ,eligible expenses ,the term eligible expenses means-- 7,a7 any amount for which a deduction is allowed to the taxpayer under section #afb1 and 7,b7 permit and license fees1 lease brokerage fees1 equipment installation costs1 and1 to the extent provided by the ,secretary1 other similar expenses4 ,such term does not include any compensation which is paid or incurred in connection with severance from employment and1 to the extent provided by the ,secretary1 any similar amount4 7#c7 ,business unit ,the term business unit means-- 7,a7 any trade or business1 and 7,b7 any line of business1 or functional unit1 which is part of any trade or business4 7#d7 ,expanded affiliated group ,the term expanded affiliated group means an affiliated group as defined in section #aejd7;a71 determined without regard to section #aejd7;b77#c7 and by substituting more than #ej percent for at least #hj percent each place it appears in section #aejd7;a74 ,a partnership or any other entity 7other than a corporation7 shall be treated as a member of an expanded affiliated group if such entity is controlled 7within the meaning of section #ied7;d77#c77 by members of such group 7including any entity treated as a member of such group by reason of this paragraph74 7#e7 ,expenses must be pursuant to insourcing plan ,amounts shall be taken into account under paragraph 7#a7 only to the extent that such amounts are paid or incurred pursuant to a written plan to carry out the relocation described in paragraph 7#a74 7#f7 ,operating expenses not taken into account ,any amount paid or incurred in connection with the on-going operation of a business unit shall not be treated as an amount paid or incurred in connection with the establishment or elimination of such business unit4 7c7 ,increased domestic employment requirement ,no credit shall be allowed under this section unless the number of full-time equivalent employees of the taxpayer for the taxable year for which the credit is claimed exceeds the number of full-time equivalent employees of the taxpayer for the last taxable year ending before the first taxable year in which such eligible insourcing expenses were paid or incurred4 ,for purposes of this subsection1 full-time equivalent employees has the meaning given such term under section #de,r7d7 7and the applicable rules of section #de,r7e774 ,all employers treated as a single employer under subsection 7b71 7c71 7m71 or 7o7 of section #dad shall be treated as a single employer for purposes of this subsection4 7d7 ,credit allowed upon completion of insourcing plan 7#a7 ,in general ,except as provided in paragraph 7#b71 eligible insourcing expenses shall be taken into account under subsection 7a7 in the taxable year during which the plan described in subsection 7b77#e7 has been completed and all eligible insourcing expenses pursuant to such plan have been paid or incurred4 7#b7 ,election to apply employment test and claim credit in first full taxable year after completion of plan ,if the taxpayer elects the application of this paragraph1 eligible insourcing expenses shall be taken into account under subsection 7a7 in the first taxable year after the taxable year described in paragraph 7#a74 7e7 ,possessions treated as part of the ,united ,states ,for purposes of this section1 the term ,united ,states shall be treated as including each possession of the ,united ,states 7including the ,commonwealth of ,puerto ,rico and the ,commonwealth of the ,northern ,mariana ,islands74 7f7 ,regulations ,the ,secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section4 4 7b7 ,credit ,to be part of general business credit ,subsection 7b7 of section #ch of such ,code is amended by striking plus at the end of paragraph 7#ce71 by striking the period at the end of paragraph 7#cf7 and inserting 1 plus1 and by adding at the end the following new paragraph3 7#cg7 the insourcing expenses credit determined under section #de,s7a74 4 7c7 ,clerical amendment ,the table of sections for subpart ,d of part ,,iv of subchapter ,a of chapter #a of such ,code is amended by adding at the end the following new item3 ,sec4 #de,s4 ,credit for insourcing expenses4 4 7d7 ,effective date ,the amendments made by this section shall apply to amounts paid or incurred after the date of the enactment of this ,act4 7e7 ,application to ,united ,states possessions 7#a7 ,payments to possessions 7,a7 ,mirror code possessions ,the ,secretary of the ,treasury shall make periodic payments to each possession of the ,united ,states with a mirror code tax system in an amount equal to the loss to that possession by reason of section #de,s of the ,internal ,revenue ,code of #aihf4 ,such amount shall be determined by the ,secretary of the ,treasury based on information provided by the government of the respective possession4 7,b7 ,other possessions ,the ,secretary of the ,treasury shall make annual payments to each possession of the ,united ,states which does not have a mirror code tax system in an amount estimated by the ,secretary of the ,treasury as being equal to the aggregate benefits that would have been provided to residents of such possession by reason of section #de,s of such ,code if a mirror code tax system had been in effect in such possession4 ,the preceding sentence shall not apply with respect to any possession of the ,united ,states unless such possession has a plan1 which has been approved by the ,secretary of the ,treasury1 under which such possession will promptly distribute such payment to the residents of such possession4 7#b7 ,coordination with credit allowed against united states income taxes ,no credit shall be allowed against ,united ,states income taxes under section #de,s of such ,code to any person-- 7,a7 to whom a credit is allowed against taxes imposed by the possession by reason of such section1 or 7,b7 who is eligible for a payment under a plan described in paragraph 7#a77;,b74 7#c7 ,definitions and special rules 7,a7 ,possessions of the ,united ,states ,for purposes of this section1 the term possession of the ,united ,states includes the ,commonwealth of ,puerto ,rico and the ,commonwealth of the ,northern ,mariana ,islands4 7,b7 ,mirror code tax system ,for purposes of this section1 the term mirror code tax system means1 with respect to any possession of the ,united ,states1 the income tax system of such possession if the income tax liability of the residents of such possession under such system is determined by reference to the income tax laws of the ,united ,states as if such possession were the ,united ,states4 7,c7 ,treatment of payments ,for purposes of section #acbd7;b77#b7 of title #ca1 ,united ,states ,code1 the payments under this section shall be treated in the same manner as a refund due from sections referred to in such section #acbd7;b77#b74 #d4 ,denial of deduction for outsourcing expenses 7a7 ,in general ,part ,,ix of subchapter ,b of chapter #a of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new section3 #bhj;,i4 ,outsourcing expenses 7a7 ,in general ,no deduction otherwise allowable under this chapter shall be allowed for any specified outsourcing expense4 7b7 ,specified outsourcing expense ,for purposes of this section-- 7#a7 ,in general ,the term specified outsourcing expense means-- 7,a7 any eligible expense paid or incurred by the taxpayer in connection with the elimination of any business unit of the taxpayer 7or of any member of any expanded affiliated group in which the taxpayer is also a member7 located within the ,united ,states1 and 7,b7 any eligible expense paid or incurred by the taxpayer in connection with the establishment of any business unit of the taxpayer 7or of any member of any expanded affiliated group in which the taxpayer is also a member7 located outside the ,united ,states1 if such establishment constitutes the relocation of the business unit so eliminated4 ,for purposes of the preceding sentence1 a relocation shall not be treated as failing to occur merely because such elimination occurs in a different taxable year than such establishment4 7#b7 ,application of certain definitions and rules 7,a7 ,definitions ,for purposes of this section1 the terms eligible expenses1 business unit1 and expanded affiliated group shall have the respective meanings given such terms by section #de,s7b74 7,b7 ,operating expenses not taken into account ,a rule similar to the rule of section #de,s7b77#f7 shall apply for purposes of this section4 7c7 ,special rules 7#a7 ,application to deductions for depreciation and amortization ,in the case of any portion of a specified outsourcing expense which is not deductible in the taxable year in which paid or incurred1 such portion shall neither be chargeable to capital account nor amortizable4 7#b7 ,possessions treated as part of the ,united ,states ,for purposes of this section1 the term ,united ,states shall be treated as including each possession of the ,united ,states 7including the ,commonwealth of ,puerto ,rico and the ,commonwealth of the ,northern ,mariana ,islands74 7d7 ,regulations ,the ,secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section1 including regulations which provide 7or create a rebuttable presumption7 that certain establishments of business units outside the ,united ,states will be treated as relocations 7based on timing or such other factors as the ,secretary may provide7 of business units eliminated within the ,united ,states4 4 7b7 ,limitation on subpart ,f income of controlled foreign corporations determined without regard to specified outsourcing expenses ,subsection 7c7 of section #ieb of such ,code is amended by adding at the end the following new paragraph3 7#d7 ,earnings and profits determined without regard to specified outsourcing expenses ,for purposes of this subsection1 earnings and profits of any controlled foreign corporation shall be determined without regard to any specified outsourcing expense 7as defined in section #bhj;,i7b774 4 7c7 ,clerical amendment ,the table of sections for part ,,ix of subchapter ,b of chapter #a of such ,code is amended by adding at the end the following new item3 ,sec4 #bhj;,i4 ,outsourcing expenses4 4 7d7 ,effective date ,the amendments made by this section shall apply to amounts paid or incurred after the date of the enactment of this ,act4 #e4 ,extension of bonus depreciation 7a7 ,in general ,paragraph 7#b7 of section #afh7k7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by striking ,january #a1 #bjae in subparagraph 7,a77iv7 and inserting ,january #a1 #bjai1 and 7#b7 by striking ,january #a1 #bjad each place it appears and inserting ,january #a1 #bjah4 7b7 ,special rule for ,federal long-,term contracts ,clause 7ii7 of section #dfj7;c77#f77;,b7 of such ,code is amended by striking ,january #a1 #bjad 7,january #a1 #bjae and inserting ,january #a1 #bjah 7,january #a1 #bjai4 7c7 ,extension of election ,to accelerate the ,,amt credit in lieu of bonus depreciation 7#a7 ,in general ,subclause 7,,ii7 of section #afh7k77#d77;,d77iii7 of such ,code is amended by striking #bjad and inserting #bjah4 7#b7 ,round #d extension property ,paragraph 7#d7 of section #afh7k7 of such ,code is amended by adding at the end the following new subparagraph3 7,k7 ,special rules for round #d extension property 7i7 ,in general ,in the case of round #d extension property1 in applying this paragraph to any taxpayer-- 7,i7 the limitation described in subparagraph 7,b77i7 and the business credit increase amount under subparagraph 7,e77iii7 thereof shall not apply1 and 7,,ii7 the bonus depreciation amount1 maximum amount1 and maximum increase amount shall be computed separately from amounts computed with respect to eligible qualified property which is not round #d extension property4 7ii7 ,election 7,i7 ,a taxpayer who has an election in effect under this paragraph for round #c extension property shall be treated as having an election in effect for round #d extension property unless the taxpayer elects to not have this paragraph apply to round #d extension property4 7,,ii7 ,a taxpayer who does not have an election in effect under this paragraph for round #c extension property may elect to have this paragraph apply to round #d extension property4 7iii7 ,round #d extension property ,for purposes of this subparagraph1 the term round #d extension property means property which is eligible qualified property solely by reason of the extension of the application of the special allowance under paragraph 7#a7 pursuant to the amendments made by section #e7;a7 of the ,keeping ,jobs in ,america ,act 7and the application of such extension to this paragraph pursuant to the amendment made by section #e7;c7 of such ,act74 4 7d7 ,conforming amendments 7#a7 ,the heading for subsection 7k7 of section #afh of such ,code is amended by striking ,january #a1 #bjad and inserting ,january #a1 #bjah4 7#b7 ,the heading for clause 7ii7 of section #afh7k77#b77;,b7 of such ,code is amended by striking pre-,january #a1 #bjad and inserting pre-,january #a1 #bjah4 7#c7 ,subparagraph 7,c7 of section #afh7n77#b7 of such ,code is amended by striking ,january #a1 #bjad and inserting ,january #a1 #bjah4 7#d7 ,subparagraph 7,d7 of section #adjj,l7b77#b7 of such ,code is amended by striking ,january #a1 #bjad and inserting ,january #a1 #bjah4 7#e7 ,subparagraph 7,b7 of section #adjj,n7d77#c7 of such ,code is amended by striking ,january #a1 #bjad and inserting ,january #a1 #bjah4 7e7 ,technical amendment relating to section #cca of the ,american ,taxpayer ,relief ,act of #bjab 7#a7 ,in general ,clause 7iii7 of section #afh7k77#d77;,j7 of such ,code is amended by striking any taxable year and inserting its first taxable year4 7#b7 ,effective date ,the amendment made by this subsection shall take effect as if included in the provision of the ,american ,taxpayer ,relief ,act of #bjab to which it relates4 7f7 ,effective date ,the amendments made by this section shall apply to property placed in service after ,december #ca1 #bjac1 in taxable years ending after such date4 #f4 ,increased expensing limitations and treatment of certain real property as section #agi property 7a7 ,in general 7#a7 ,dollar limitation ,paragraph 7#a7 of section #agi7;b7 of the ,internal ,revenue ,code of #aihf is amended by striking shall not exceed-- and all that follows and inserting shall not exceed #ejj1jjj44 7#b7 ,reduction in limitation ,paragraph 7#b7 of section #agi7;b7 of such ,code is amended by striking exceeds-- and all that follows and inserting exceeds #b1jjj1jjj44 7b7 ,computer software ,clause 7ii7 of section #agi7;d77#a77;,a7 of such ,code is amended by striking 1 to which section #afg applies1 and which is placed in service in a taxable year beginning after #bjjb and before #bjad and inserting and to which section #afg applies4 7c7 ,election ,paragraph 7#b7 of section #agi7;c7 of such ,code is amended-- 7#a7 by striking may not be revoked and all that follows through and before #bjad1 and 7#b7 by striking irrevocable in the heading thereof4 7d7 ,air conditioning and heating units ,paragraph 7#a7 of section #agi7;d7 of such ,code is amended by striking and shall not include air conditioning or heating units4 7e7 ,qualified real property ,subsection 7f7 of section #agi of such ,code is amended-- 7#a7 by striking beginning in #bjaj1 #bjaa1 #bjab1 or #bjac in paragraph 7#a71 and 7#b7 by striking paragraphs 7#c7 and 7#d74 7f7 ,inflation adjustment ,subsection 7b7 of section #agi of such ,code is amended by adding at the end the following new paragraph3 7#f7 ,inflation adjustment 7,a7 ,in general ,in the case of any taxable year beginning after #bjad1 the dollar amounts in paragraphs 7#a7 and 7#b7 shall each be increased by an amount equal to-- 7i7 such dollar amount1 multiplied by 7ii7 the cost-of-living adjustment determined under section #a7;c77#b77;,a7 for such calendar year1 determined by substituting calendar year #bjac for calendar year #bjab in clause 7ii7 thereof4 7,b7 ,rounding ,the amount of any increase under subparagraph 7,a7 shall be rounded to the nearest multiple of #aj1jjj4 4 7g7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after ,december #ca1 #bjac4 #g4 ,permanent extension of new markets tax credit 7a7 ,extension 7#a7 ,in general ,subparagraph 7,g7 of section #de;,d7f77#a7 of the ,internal ,revenue ,code of #aihf is amended by striking 1 #bjaa1 #bjab1 and #bjac and inserting and each calendar year thereafter4 7#b7 ,conforming amendment ,section #de;,d7f77#c7 of such ,code is amended by striking the last sentence4 7b7 ,inflation adjustment ,subsection 7f7 of section #de;,d of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new paragraph3 7#d7 ,inflation adjustment 7,a7 ,in general ,in the case of any calendar year beginning after #bjac1 the dollar amount in paragraph 7#a77;,g7 shall be increased by an amount equal to-- 7i7 such dollar amount1 multiplied by 7ii7 the cost-of-living adjustment determined under section #a7;f77#c7 for the calendar year1 determined by substituting calendar year #bjjj for calendar year #aiib in subparagraph 7,b7 thereof4 7,b7 ,rounding rule ,any increase under subparagraph 7,a7 which is not a multiple of #a1jjj1jjj shall be rounded to the nearest multiple of #a1jjj1jjj4 4 7c7 ,alternative minimum tax relief ,subparagraph 7,b7 of section #ch7;c77#d7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by redesignating clauses 7v7 through 7ix7 as clauses 7vi7 through 7x71 respectively1 and 7#b7 by inserting after clause 7iv7 the following new clause3 7v7 the credit determined under section #de;,d1 but only with respect to credits determined with respect to qualified equity investments 7as defined in section #de;,d7b77 initially made before ,january #a1 #bjad1 4 7d7 ,effective dates 7#a7 ,in general ,except as provided in paragraph 7#b71 the amendments made by this section shall take effect on the date of the enactment of this ,act4 7#b7 ,alternative minimum tax relief ,the amendments made by subsection 7c7 shall apply to credits determined with respect to qualified equity investments 7as defined in section #de;,d7b7 of the ,internal ,revenue ,code of #aihf7 initially made after the date of the enactment of this ,act4