,i  #aafth ,,congress  #ast ,session    
,h4 ,r4 #dbgd  ,,in ,,the ,,house ,,of  
,,representatives  ,september #aj1      
#bjai,mr4 ,gottheimer 7for himself and  
,mr4 ,zeldin7 introduced the following  
bill2 which was referred to the         
,committee on ,ways and ,means  ,a      
,,bill  ,to amend the ,internal ,revenue
 ,code of #aihf to repeal the limitation
 on the deduction for certain taxes1    
including ,state and local property and 
income taxes1 to limit the step-up in   
basis allowed in the case of property   
acquired from a decedent1 and to deem a 
sale on any contribution of property to 
a private foundation4  #a4 ,short title 
,this ,act may be cited as the ,cutting 
,local ,taxes by ,reinstating ,,salt    
,act4  #b4 ,repeal of limitation on     
deduction for ,state and local1 etc4    
taxes  7a7 ,in general ,section #afd7;b7
 of the ,internal ,revenue ,code of     
#aihf is amended by striking paragraph  
7#f7 7as added by ,public ,law #aae-ig7 
and all that follows4  7b7 ,effective   

date ,the amendments made by this       
section shall apply to taxable years    
beginning after ,december #ca1 #bjag4   
#c4 ,step-up in basis of property       
acquired from decedent limited to       
#e1jjj1jjj  7a7 ,in general ,section    
#ajad7;a7 of the ,internal ,revenue     
,code of #aihf is amended to read as    
follows3  7a7 ,in general ,except as    
otherwise provided in this section1 the 
basis of property in the hands of a     
person acquiring the property from a    
decedent or to whom the property passed 
from a decedent shall1 if not sold1     
exchanged1 or otherwise disposed of     
before the decedent's death by such     
person1 be the lesser of--  7#a7 the    
adjusted basis of the decedent1 or  7#b7
 the fair market value of the property  
at the date of the decedent's death4  4 
7b7 #e1jjj1jjj basis increase ,section  
#ajad of such ,code is amended by adding
 at the end the following new           
subsection3  7g7 #e1jjj1jjj basis       
increase  7#a7 ,in general ,the basis of

 a decedent's property to which         
subsection 7a7 applies shall be         
increased by an amount equal to a       
portion of the aggregate basis increase1
 which shall be allocated amongst       
property of the decedent in proportion  
to the net appreciation in value of the 
property4  7#b7 ,aggregate basis        
increase ,for purposes of this          
subsection1 the aggregate basis increase
 shall be an amount equal to the lesser 
of--  7,a7 #e1jjj1jjj1 or  7,b7 the     
aggregate net appreciation in value of  
all the decedent's property to which    
subsection 7a7 applies4  7#c7 ,net      
appreciation ,for purposes of this      
subsection1 the net appreciation in     
value of any property is the amount by  
which 7if any7 the fair market value of 
the property exceeds the decedent's     
adjusted basis as of the date of the    
decedent's death4  7#d7 ,special rules  
for certain property ,for purposes of   
determining net appreciation in value of
 property1 in lieu of fair market value1

 the following shall be used3  7,a7 ,in 
the case of an election under #bjcb1 the
 property value at the applicable       
valuation date prescribed by such       
section4  7,b7 ,in the case of an       
election under section #bjcb;,a1 the    
property value determined under such    
section4  7,c7 ,to the extent of the    
applicability of the exclusion described
 in section #bjca7;c71 the basis in the 
hands of the decedent4  4  7c7          
,conforming amendments  7#a7 ,section   
#ajad7;d7 of such ,code is amended by   
striking under subsection 7a71 such     
basis 7determined before the application
 of this subsection7 and inserting under
 this section 7determined without regard
 to this subsection71 such basis4  7#b7 
,section #ajad7;e7 of such ,code is     
amended by inserting before the period  
at the end the following3 and subsection
 7g7 shall not apply to such property4  
7d7 ,effective date ,the amendments made
 by this section shall apply to the     
estates of decedents dying after        

,december #ca1 #bjai4  #d4 ,tax         
treatment of contributions of property  
to private foundation  7a7 ,in general  
,part ,,iv of subchapter ,p of the      
,internal ,revenue ,code of #aihf is    
amended by adding at the end the        
following new section3  #abfa4          
,treatment of contributions of property 
to private foundation  7a7 ,in general  
,any property contributed by a taxpayer 
to a private foundation shall be treated
 for purposes of this title as sold by  
the taxpayer on the date of such        
contribution for its fair market value4 
7b7 ,determination and recognition of   
gain and loss ,in the case of any sale  
for the taxable year under subsection   
7a7-- 7#a7 this subchapter shall be     
applied separately with respect to all  
gains and losses from such sales1  7#b7 
losses shall be allowed only to the     
extent of gains1 and  7#c7 the tax      
imposed by this chapter for such taxable
 year shall not be less than the amount 
of such tax 7determined without regard  

to this section7 increased by an amount 
equal to the increase in such tax which 
would result solely from the inclusion  
of any net gain from all such sales4    
7c7 ,coordination with deduction ,no    
deduction shall be allowed under any    
other provision of this chapter by      
reason of any contribution to which     
subsection 7a7 applies4  4  7b7         
,clerical amendment ,the table of       
sections for subchapter ,p of such ,code
 is amended by adding at the end the    
following new item3  ,sec4 #abfa4       
,treatment of contributions of property 
to private foundation4  4  7c7          
,effective date ,the amendments made by 
this section shall apply to             
contributions of property in taxable    
years beginning after ,december #ca1    
#bjai4