,i  #aafth ,,congress  #b;d ,session    
,h4 ,r4 #hife  ,,in ,,the ,,house ,,of  
,,representatives  ,december #ad1       
#bjbj,ms4 ,sewell of ,alabama 7for      
herself and ,mr4 ,reed7 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 make certain         
improvements to the new markets tax     
credit1 and for other purposes4  #a4    
,short title ,this ,act may be cited as 
the ,new ,markets ,stabilization ,act4  
#b4 ,improvements to new markets tax    
credit  7a7 ,additional allocations     
7#a7 ,in general ,section #de;,d7f77#a7 
of the ,internal ,revenue ,code of #aihf
 is amended by striking subparagraphs   
7,g7 and 7,h7 and inserting the         
following new subparagraphs3  7,g7      
#c1ejj1jjj1jjj for each of calendar     
years #bjaj through #bjah1  7,h7        
#d1jjj1jjj1jjj for calendar year #bjai1 
7,i7 #g1jjj1jjj1jjj for calendar year   
#bjbj1  7,j7 #f1ejj1jjj1jjj for calendar

 year #bjba1 and  7,k7 #e1ejj1jjj1jjj   
for calendar year #bjbb4  4  7#b7       
,conforming amendment ,section          
#de;,d7f77#c7 of such ,code is amended  
by striking #bjbe and inserting #bjbg4  
7#c7 ,special rule for allocations of   
increased #bjai and #bjbj limitation    
,the amount of the increase by reason of
 the amendments made by paragraph 7#a7  
in the new markets tax credit limitation
 for calendar year #bjai and the amount 
of such increase for calendar year #bjbj
 shall each be allocated in accordance  
with section #de;,d7f77#b7 of the       
,internal ,revenue ,code of #aihf to    
qualified community development entities
 7as defined in section #de;,d7c7 of    
such ,code7 which-- 7,a7 submitted an   
allocation application with respect to  
the calendar year to which such increase
 relates1 and  7,b7 7i7 did not receive 
an allocation with respect to such      
calendar year1 or  7ii7 received an     
allocation for such calendar year in an 
amount less than the amount requested in

 the allocation application4  7b7       
,permanent allowance of credit against  
alternative minimum tax  7#a7 ,in       
general ,section #ch7;c77#d77;,b7 of the
 ,internal ,revenue ,code of #aihf is   
amended clauses 7vii7 through 7xii7 as  
clauses 7viii7 through 7xiii71          
respectively1 and by inserting after    
clause 7vi7 the following new clause3   
7vii7 the credit determined under       
section #de;,d to the extent            
attributable to qualified equity        
investments originally issued after the 
date of the enactment of this clause1  4
  7#b7 ,effective date ,the amendments  
made by this subsection shall apply to  
taxable years ending after the date of  
the enactment of this ,act4  7c7 ,credit
 allowed ,to be carried back #e years   
and ,to offset entire tax liability as  
temporary incentive for making          
investments in qualified community      
development entities  7#a7 ,in general  
,in the case of the portion of the new  
markets tax credit determined under     

section #de;,d of the ,internal ,revenue
 ,code of #aihf which is attributable to
 qualified equity investments originally
 issued after the date of the enactment 
of this ,act and before ,january #a1    
#bjbc-- 7,a7 sections #ch and #ci of    
such ,code shall be applied separately  
with respect to such portion1  7,b7     
notwithstanding section #ci7;d7 of such 
,code1 section #ci7;a7 of such ,code    
shall be applied-- 7i7 by substituting  
each of the #e taxable years for the    
taxable year in paragraph 7#a77;,a7     
thereof1  7ii7 by substituting #be      
taxable years for #ba taxable years in  
paragraph 7#b77;,a7 thereof1 and  7iii7 
by substituting #bd taxable years for   
#bj taxable years in subparagraph       
7#b77;,b7 thereof1  7,c7 the amounts    
described in subparagraphs 7,a7 and 7,b7
 of section #ch7;c77#a7 of such ,code   
shall each be treated as being zero1 and
  7,d7 the limitation under section     
#ch7;c77#a7 of such ,code 7as modified  
by subparagraph 7,c77 shall be reduced  

by the credit allowed under section     
#ch7;a7 for the taxable year 7other than
 the portion of qualified new markets   
tax credit to which this paragraph      
applies74  7#b7 ,coordination with other
 limitations ,the portion of the new    
markets tax credit to which paragraph   
7#a7 applies-- 7,a7 shall not be taken  
into account as a credit allowed under  
section #ch7;a7 of such ,code for       
purposes of paragraphs                  
7#b77;,a77ii77,,ii7 and                 
7#d77;,a77ii77,,ii7 of section #ch7;c7  
of such ,code1 and  7,b7 shall not be   
treated as described in section         
#ch7;c77#d77;,b77vii7 of such ,code1 as 
amended by this ,act4  7d7 ,temporary   
override of certain regulations treating
 debt modifications as exchanges  7#a7  
,in general ,for purposes of the        
,internal ,revenue ,code of #aihf1 any  
modification of a ,,qcde loan which     
occurs during the period beginning on   
,march #ab1 #bjbj1 and ending on        
,december #ca1 #bjbb1 shall not be      

treated an exchange of an existing debt 
instrument for a new debt instrument4   
7#b7 ,,qcde loan ,for purposes of this  
subsection1 the term ,,qcde loan means  
any debt instrument held by a qualified 
community development entity 7as defined
 in section #de;,d7c7 of the ,internal  
,revenue ,code of #aihf7 to the extent  
that the borrower is a qualified active 
low-income community business 7as       
defined in section #de;,d7d77#b7 of such
 ,code74