,,ii ,calendar ,no4 #cdi #aahth ,,congress #b;d ,session ,h4 ,r4 #gjbd ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,february #a1 #bjbd,received ,march #bj1 #bjbd ,read the first time ,march #ba1 #bjbd,read the second time and placed on the calendar ,,an ,,act ,to make improvements to the child tax credit1 to provide tax incentives to promote economic growth1 to provide special rules for the taxation of certain residents of ,taiwan with income from sources within the ,united ,states1 to provide tax relief with respect to certain ,federal disasters1 to make improvements to the low-income housing tax credit1 and for other purposes4 #a4 ,short title2 table of contents2 etc 7a7 ,short title ,this ,act may be cited as the ,tax ,relief for ,american ,families and ,workers ,act of #bjbd4 7b7 ,amendment of #aihf ,code ,except as otherwise expressly provided1 whenever in this ,act an amendment or repeal is expressed in terms of an amendment to1 or repeal of1 a section or other provision1 the reference shall be considered to be made to a section or other provision of the ,internal ,revenue ,code of #aihf4 7c7 ,table of contents ,the table of contents of this ,act is as follows3 ,sec4 #a4 ,short title2 table of contents2 etc4,title ,i--,tax ,relief for ,working ,families,sec4 #aja4 ,per-child calculation of refundable portion of child tax credit4,sec4 #ajb4 ,increase in refundable portion4,sec4 #ajc4 ,inflation of credit amount4,sec4 #ajd4 ,rule for determination of earned income4,sec4 #aje4 ,special rule for certain early-filed #bjbc returns4,title ,,ii--,american ,innovation and ,growth,sec4 #bja4 ,deduction for domestic research and experimental expenditures4,sec4 #bjb4 ,extension of allowance for depreciation1 amortization1 or depletion in determining the limitation on business interest4,sec4 #bjc4 ,extension of #ajj percent bonus depreciation4,sec4 #bjd4 ,increase in limitations on expensing of depreciable business assets4,title ,,iii--,increasing ,global ,competitiveness,subtitle ,a--,united ,states-,taiwan ,expedited ,double-,tax ,relief ,act,sec4 #cja4 ,short title4,sec4 #cjb4 ,special rules for taxation of certain residents of ,taiwan4,subtitle ,b--,united ,states-,taiwan ,tax ,agreement ,authorization ,act,sec4 #caa4 ,short title4,sec4 #cab4 ,definitions4,sec4 #cac4 ,authorization to negotiate and enter into agreement4,sec4 #cad4 ,consultations with ,congress4,sec4 #cae4 ,approval and implementation of agreement4,sec4 #caf4 ,submission to ,congress of agreement and implementation policy4,sec4 #cag4 ,consideration of approval legislation and implementing legislation4,sec4 #cah4 ,relationship of agreement to ,internal ,revenue ,code of #aihf4,sec4 #cai4 ,authorization of subsequent tax agreements relative to ,taiwan4,sec4 #cbj4 ,united ,states treatment of double taxation matters with respect to ,taiwan4,title ,,iv--,assistance for ,disaster-,impacted ,communities,sec4 #dja4 ,short title4,sec4 #djb4 ,extension of rules for treatment of certain disaster-related personal casualty losses4,sec4 #djc4 ,exclusion from gross income for compensation for losses or damages resulting from certain wildfires4,sec4 #djd4 ,east ,palestine disaster relief payments4,title ,v--,more ,affordable housing,sec4 #eja4 ,state housing credit ceiling increase for low-income housing credit4,sec4 #ejb4 ,tax-exempt bond financing requirement4,title ,,vi--,tax ,administration and ,eliminating ,fraud,sec4 #fja4 ,increase in threshold for requiring information reporting with respect to certain payees4,sec4 #fjb4 ,enforcement provisions with respect to ,,covid-related employee retention credits4 ,i ,tax ,relief for ,working ,families #aja4 ,per-child calculation of refundable portion of child tax credit 7a7 ,in general ,subparagraph 7,a7 of section #bd7;h77#e7 is amended to read as follows3 7,a7 ,in general ,in applying subsection 7d7-- 7i7 the amount determined under paragraph 7#a77;,a7 of such subsection with respect to any qualifying child shall not exceed #a1djj1 and such paragraph shall be applied without regard to paragraph 7#d7 of this subsection1 and 7ii7 paragraph 7#a77;,b7 of such subsection shall be applied by multiplying each of-- 7,i7 the amount determined under clause 7i7 thereof1 and 7,,ii7 the excess determined under clause 7ii7 thereof1 by the number of qualifying children of the taxpayer4 4 7b7 ,conforming amendment ,the heading of paragraph 7#e7 of section #bd7;h7 is amended by striking ,maximum amount of and inserting ,special rules for4 7c7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after ,december #ca1 #bjbb4 #ajb4 ,increase in refundable portion 7a7 ,in general ,paragraph 7#e7 of section #bd7;h7 is amended by redesignating subparagraph 7,b7 as subparagraph 7,c7 and by inserting after subparagraph 7,a7 the following new subparagraph3 7,b7 ,amounts for #bjbc1 #bjbd1 and #bjbe ,in the case of a taxable year beginning after #bjbb1 subparagraph 7,a7 shall be applied by substituting for #a1djj-- 7i7 in the case of taxable year #bjbc1 #a1hjj1 7ii7 in the case of taxable year #bjbd1 #a1ijj1 and 7iii7 in the case of taxable year #bjbe1 #b1jjj4 4 7b7 ,conforming amendment ,subparagraph 7,c7 of section #bd7;h77#e71 as redesignated by subsection 7a71 is amended by inserting and before #bjbc after #bjah4 7c7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after ,december #ca1 #bjbb4 #ajc4 ,inflation of credit amount 7a7 ,in general ,paragraph 7#b7 of section #bd7;h7 is amended-- 7#a7 by striking amount4--,subsection and inserting 8amount4-- 7,a7 ,in general ,subsection 1 and 7#b7 by adding at the end the following new subparagraph3 7,b7 ,adjustment for inflation ,in the case of a taxable year beginning after #bjbc1 the #b1jjj amounts in subparagraph 7,a7 and paragraph 7#e77;,b77iii7 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;f77#c7 for the calendar year in which the taxable year begins1 determined by substituting #bjbb for #bjaf in subparagraph 7,a77ii7 thereof4 ,if any increase under this clause is not a multiple of #ajj1 such increase shall be rounded to the next lowest multiple of #ajj4 4 7b7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after ,december #ca1 #bjbc4 #ajd4 ,rule for determination of earned income 7a7 ,in general ,paragraph 7#f7 of section #bd7;h7 of the ,internal ,revenue ,code of #aihf is amended-- 7#a7 by striking credit4--,subsection and inserting 8credit4-- 7,a7 ,in general ,subsection 1 and 7#b7 by adding at the end the following new subparagraphs 7,b7 ,rule for determination of earned income 7i7 ,in general ,in the case of a taxable year beginning after #bjbc1 if the earned income of the taxpayer for such taxable year is less than the earned income of the taxpayer for the preceding taxable year1 subsection 7d77#a77;,b77i7 may1 at the election of the taxpayer1 be applied by substituting-- 7,i7 the earned income for such preceding taxable year1 for 7,,ii7 the earned income for the current taxable year4 7ii7 ,application to joint returns ,for purposes of clause 7i71 in the case of a joint return1 the earned income of the taxpayer for the preceding taxable year shall be the sum of the earned income of each spouse for such preceding taxable year4 4 7b7 ,errors treated as mathematical errors ,paragraph 7#b7 of section #fbac7;g7 of the ,internal ,revenue ,code of #aihf is amended by striking and at the end of subparagraph 7,u71 by striking the period at the end of subparagraph 7,v7 and inserting 1 and1 and by inserting after subparagraph 7,v7 the following new subparagraph3 7,w7 in the case of a taxpayer electing the application of section #bd7;h77#f77;,b7 for any taxable year1 an entry on a return of earned income pursuant to such section which is inconsistent with the amount of such earned income determined by the ,secretary for the preceding taxable year4 4 7c7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after ,december #ca1 #bjbc4 #aje4 ,special rule for certain early-filed #bjbc returns ,in the case of an individual who claims1 on the taxpayer's return of tax for the first taxable year beginning after ,december #ca1 #bjbb1 a credit under section #bd of the ,internal ,revenue ,code of #aihf which is determined without regard to the amendments made by sections #aja and #ajb of this ,act1 the ,secretary of the ,treasury 7or the ,secretary's delegate7 shall1 to the maximum extent practicable-- 7#a7 redetermine the amount of such credit 7after taking into account such amendments7 on the basis of the information provided by the taxpayer on such return1 and 7#b7 to the extent that such redetermination results in an overpayment of tax1 credit or refund such overpayment as expeditiously as possible4 ,,ii ,american ,innovation and ,growth #bja4 ,deduction for domestic research and experimental expenditures 7a7 ,delay of amortization of domestic research and experimental expenditures ,section #agd is amended by adding at the end the following new subsection3 7e7 ,suspension of application of section to domestic research and experimental expenditures ,in the case of any domestic research or experimental expenditures 7as defined in section #agd;,a7b771 this section-- 7#a7 shall apply to such expenditures paid or incurred in taxable years beginning after ,december #ca1 #bjbe1 and 7#b7 shall not apply to such expenditures paid or incurred in taxable years beginning on or before such date4 4 7b7 ,reinstatement of expensing for domestic research and experimental expenditures ,part ,,vi of subchapter ,b of chapter #a is amended by inserting after section #agd the following new section3 #agd;,a4 ,temporary rules for domestic research and experimental expenditures 7a7 ,treatment as expenses ,notwithstanding section #bfc1 there shall be allowed as a deduction any domestic research or experimental expenditures which are paid or incurred by the taxpayer during the taxable year4 7b7 ,domestic research or experimental expenditures ,for purposes of this section1 the term domestic research or experimental expenditures means research or experimental expenditures paid or incurred by the taxpayer in connection with the taxpayer's trade or business other than such expenditures which are attributable to foreign research 7within the meaning of section #da7;d77#d77;,f774 7c7 ,amortization of certain domestic research and experimental expenditures 7#a7 ,in general ,at the election of the taxpayer1 made in accordance with regulations or other guidance provided by the ,secretary1 in the case of domestic research or experimental expenditures which would 7but for subsection 7a77 be chargeable to capital account but not chargeable to property of a character which is subject to the allowance under section #afg 7relating to allowance for depreciation1 etc47 or section #faa 7relating to allowance for depletion71 subsection 7a7 shall not apply and the taxpayer shall-- 7,a7 charge such expenditures to capital account1 and 7,b7 be allowed an amortization deduction of such expenditures ratably over such period of not less than #fj months as may be selected by the taxpayer 7beginning with the month in which the taxpayer first realizes benefits from such expenditures74 7#b7 ,time for and scope of election ,the election provided by paragraph 7#a7 may be made for any taxable year1 but only if made not later than the time prescribed by law for filing the return for such taxable year 7including extensions thereof74 ,the method so elected1 and the period selected by the taxpayer1 shall be adhered to in computing taxable income for the taxable year for which the election is made and for all subsequent taxable years unless1 with the approval of the ,secretary1 a change to a different method 7or to a different period7 is authorized with respect to part or all of such expenditures4 ,the election shall not apply to any expenditure paid or incurred during any taxable year before the taxable year for which the taxpayer makes the election4 7d7 ,election to capitalize expenses ,in the case of a taxpayer which elects 7at such time and in such manner as the ,secretary may provide7 the application of this subsection1 subsections 7a7 and 7c7 shall not apply and domestic research or experimental expenditures shall be chargeable to capital account4 ,such election shall not apply to any expenditure paid or incurred during any taxable year before the taxable year for which the taxpayer makes the election and may be made with respect to part of the expenditures paid or incurred during any taxable year only with the approval of the ,secretary4 7e7 ,special rules 7#a7 ,land and other property ,this section shall not apply to any expenditure for the acquisition or improvement of land1 or for the acquisition or improvement of property to be used in connection with the research or experimentation and of a character which is subject to the allowance under section #afg 7relating to allowance for depreciation1 etc47 or section #faa 7relating to allowance for depletion72 but for purposes of this section allowances under section #afg1 and allowances under section #faa1 shall be considered as expenditures4 7#b7 ,exploration expenditures ,this section shall not apply to any expenditure paid or incurred for the purpose of ascertaining the existence1 location1 extent1 or quality of any deposit of ore or other mineral 7including oil and gas74 7#c7 ,software development ,for purposes of this section1 any amount paid or incurred in connection with the development of any software shall be treated as a research or experimental expenditure4 7f7 ,termination 7#a7 ,in general ,this section shall not apply to amounts paid or incurred in taxable years beginning after ,december #ca1 #bjbe4 7#b7 ,change in method of accounting ,in the case of a taxpayer's first taxable year beginning after ,december #ca1 #bjbe1 paragraph 7#a7 7and the corresponding application of section #agd7 shall be treated as a change in method of accounting for purposes of section #dha and-- 7,a7 such change shall be treated as initiated by the taxpayer1 7,b7 such change shall be treated as made with the consent of the ,secretary1 and 7,c7 such change shall be applied only on a cut-off basis for any domestic research or experimental expenditures paid or incurred in taxable years beginning after ,december #ca1 #bjbe1 and no adjustment under section #dha7;a7 shall be made4 4 7c7 ,coordination with certain other provisions 7#a7 ,research credit 7,a7 ,section #da7;d77#a77;,a7 is amended by inserting or domestic research or experimental expenditures under section #agd;,a after section #agd4 7,b7 ,section #bhj;,c7c77#a7 is amended to read as follows3 7#a7 ,in general ,the domestic research or experimental expenditures otherwise taken into account under section #agd or #agd;,a 7as the case may be7 shall be reduced by the amount of the credit allowed under section #da7;a74 4 7#b7 ,,amt adjustment ,section #ef7;b77#b7 is amended by striking #agd7;a7 each place it appears and inserting #agd;,a7a74 7#c7 ,optional #aj-year writeoff ,section #ei7;e77#b77;,b7 is amended by striking section #agd7;a7 7relating to research and experimental expenditures7 and inserting section #agd;,a7a7 7relating to temporary rules for domestic research and experimental expenditures74 7#d7 ,qualified small issue bonds ,section #add7;a77#d77;,c77iv7 is amended by striking #agd7;a7 and inserting #agd;,a7a74 7#e7 ,start-up expenditures ,section #aie7;c77#a7 is amended by striking or #agd in the last sentence and inserting #agd1 or #agd;,a4 7#f7 ,capital expenditures 7,a7 ,section #bfc7;a77#a77;,b7 is amended by inserting or #agd;,a after #agd4 7,b7 ,section #bfc;,a7c77#b7 is amended by inserting or #agd;,a after #agd4 7#g7 ,active business computer software royalties ,section #edc7;d77#d77;,a77i7 is amended by inserting #agd;,a1 after #agd14 7#h7 ,source rules ,section #hfd7;g77#b7 is amended in the last sentence-- 7,a7 by striking treated as deferred expenses under subsection 7b7 of section #agd and inserting allowed as an amortization deduction under section #agd7;a7 or section #agd;,a7c711 and 7,b7 by striking such subsection and inserting such section 7as the case may be74 7#i7 ,basis adjustment ,section #ajaf7;a77#ad7 is amended by striking deductions as deferred expenses under section #agd7;b77#a7 7relating to research and experimental expenditures7 and inserting deductions under section #agd or #agd;,a4 7#aj7 ,small business stock ,section #abjb7;e77#b77;,b7 is amended by striking research and experimental expenditures under section #agd and inserting specified research or experimental expenditures under section #agd or domestic research or experimental expenditures under section #agd;,a4 7d7 ,conforming amendments 7#a7 ,section #acbjf of ,public ,law #aae-ig is amended by striking subsection 7b7 7relating to change in method of accounting74 7#b7 ,the table of sections for part ,,vi of subchapter ,b of chapter #a is amended by inserting after the item relating to section #agd the following new item3 ,sec4 #agd;,a4 ,temporary rules for domestic research and experimental expenditures4 4 7e7 ,effective date 7#a7 ,in general ,except as otherwise provided in this subsection1 the amendments made by this section shall apply to amounts paid or incurred in taxable years beginning after ,december #ca1 #bjba4 7#b7 ,coordination with research credit ,the amendment made by subsection 7c77#a77;,b7 shall apply to taxable years beginning after ,december #ca1 #bjbb4 7#c7 ,repeal of superceded change in method of accounting rules ,the amendment made by subsection 7d77#a7 shall take effect as if included in ,public ,law #aae-ig4 7#d7 ,no inference with respect to coordination with research credit for prior periods ,the amendment made by subsection 7c77#a77;,b7 shall not be construed to create any inference with respect to the proper application of section #bhj;,c7c7 of the ,internal ,revenue ,code of #aihf with respect to taxable years beginning before ,january #a1 #bjbc4 7f7 ,transition rules 7#a7 ,in general ,except as otherwise provided by the ,secretary1 an election made under subsection 7c7 or 7d7 of section #agd;,a of the ,internal ,revenue ,code of #aihf 7as added by this section7 for the taxpayer's first taxable year beginning after ,december #ca1 #bjba1 shall not fail to be treated as timely made 7or as made on the return7 if made during the #a-year period beginning on the date of the enactment of this ,act on an amended return for the taxpayer's first taxable year beginning after ,december #ca1 #bjba1 or in such other manner as the ,secretary may provide4 7#b7 ,election regarding treatment as change in method of accounting ,in the case of any taxpayer which 7as of the date of the enactment of this ,act7 had adopted a method of accounting provided by section #agd of the ,internal ,revenue ,code of #aihf 7as in effect prior to the amendments made by this section7 for the taxpayer's first taxable year beginning after ,december #ca1 #bjba1 and elects the application of this paragraph-- 7,a7 the amendments made by this section shall be treated as a change in method of accounting for purposes of section #dha of such ,code1 7,b7 such change shall be treated as initiated by the taxpayer for the taxpayer's immediately succeeding taxable year1 7,c7 such change shall be treated as made with the consent of the ,secretary1 7,d7 such change shall be applied on a modified cut-off basis1 taking into account for purposes of section #dha7;a7 of such ,code only the domestic research or experimental expenditures 7as defined in section #agd;,a7b7 of such ,code 7as added by this section7 and determined by applying the rules of section #agd;,a7e7 of such ,code7 paid or incurred in the taxpayer's first taxable year beginning after ,december #ca1 #bjba1 and not allowed as a deduction in such taxable year1 and 7,e7 in the case of a taxpayer which elects the application of this subparagraph1 the amount of such change 7as determined under subparagraph 7,d77 shall be taken into account ratably over the #b-taxable-year period beginning with the taxable year referred to in subparagraph 7,b74 7#c7 ,election regarding #aj-year writeoff 7,a7 ,in general ,except as otherwise provided by the ,secretary1 an eligible taxpayer which files1 during the #a-year period beginning on the date of the enactment of this ,act1 an amended income tax return for the taxable year described in subparagraph 7,b77ii7 may elect the application of section #ei7;e7 of the ,internal ,revenue ,code of #aihf with respect to qualified expenditures described in section #ei7;e77#b77;,b7 of such ,code 7as amended by subsection 7c77#c77 with respect to such taxable year4 ,such election shall be filed with such amended income tax return and shall be effective only to the extent that such election would have been effective if filed with the original income tax return for such taxable year 7determined after taking into account the amendment made by subsection 7c77#c774 7,b7 ,eligible taxpayer ,for purposes of subparagraph 7,a71 the term eligible taxpayer means any taxpayer which-- 7i7 does not elect the application of paragraph 7#b71 and 7ii7 filed an income tax return for such taxpayer's first taxable year beginning after ,december #ca1 #bjba1 before the earlier of-- 7,i7 the due date for such return1 and 7,,ii7 the date of the enactment of this ,act4 7#d7 ,election regarding coordination with research credit ,except as otherwise provided by the ,secretary1 an eligible taxpayer 7as defined in paragraph 7#c77;,b7 without regard to clause 7i7 thereof7 which files1 during the #a-year period beginning on the date of the enactment of this ,act1 an amended income tax return for the taxpayer's first taxable year beginning after ,december #ca1 #bjba1 may1 notwithstanding subparagraph 7,c7 of section #bhj;,c7c77#b7 of the ,internal ,revenue ,code of #aihf make1 or revoke1 on such amended return the election under such section for such taxable year4 #bjb4 ,extension of allowance for depreciation1 amortization1 or depletion in determining the limitation on business interest 7a7 ,in general ,section #afc7;j77#h77;,a77v7 is amended by striking ,january #a1 #bjbb and inserting ,january #a1 #bjbf4 7b7 ,effective date 7#a7 ,in general ,except as otherwise provided in this subsection1 the amendment made by this section shall apply to taxable years beginning after ,december #ca1 #bjbc4 7#b7 ,election to apply extension retroactively ,in the case of a taxpayer which elects 7at such time and in such manner as the ,secretary may provide7 the application of this paragraph1 paragraph 7#a7 shall be applied by substituting ,december #ca1 #bjba for ,december #ca1 #bjbc4 #bjc4 ,extension of #ajj percent bonus depreciation 7a7 ,in general ,section #afh7k77#f77;,a7 is amended-- 7#a7 in clause 7i7-- 7,a7 by striking #bjbc and inserting #bjbf1 and 7,b7 by adding and at the end1 and 7#b7 by striking clauses 7ii71 7iii71 and 7iv71 and redesignating clause 7v7 as clause 7ii74 7b7 ,property with longer production periods ,section #afh7k77#f77;,b7 is amended-- 7#a7 in clause 7i7-- 7,a7 by striking #bjbd and inserting #bjbg1 and 7,b7 by adding and at the end1 and 7#b7 by striking clauses 7ii71 7iii71 and 7iv71 and redesignating clause 7v7 as clause 7ii74 7c7 ,plants bearing fruits and nuts ,section #afh7k77#f77;,c7 is amended-- 7#a7 in clause 7i7-- 7,a7 by striking #bjbc and inserting #bjbf1 and 7,b7 by adding and at the end1 and 7#b7 by striking clauses 7ii71 7iii71 and 7iv71 and redesignating clause 7v7 as clause 7ii74 7d7 ,effective dates 7#a7 ,in general ,except as otherwise provided in this subsection1 the amendments made by this section shall apply to property placed in service after ,december #ca1 #bjbb4 7#b7 ,plants bearing fruits and nuts ,the amendments made by subsection 7c7 shall apply to specified plants planted or grafted after ,december #ca1 #bjbb4 #bjd4 ,increase in limitations on expensing of depreciable business assets 7a7 ,in general ,section #agi7;b7 is amended-- 7#a7 by striking #a1jjj1jjj in paragraph 7#a7 and inserting #a1bij1jjj1 and 7#b7 by striking #b1ejj1jjj in paragraph 7#b7 and inserting #c1bbj1jjj4 7b7 ,inflation adjustment ,section #agi7;b77#f7 is amended-- 7#a7 by striking #bjah and inserting #bjbd 7#bjah in the case of the dollar amount in paragraph 7#e77;,a771 and 7#b7 by striking #8calendar year #bjag and inserting calendar year #bjbd 7calendar year #bjag in the case of the dollar amount in paragraph 7#e77;,a774 7c7 ,effective date ,the amendments made by this section shall apply to property placed in service in taxable years beginning after ,december #ca1 #bjbc4 ,,iii ,increasing ,global ,competitiveness ,a ,united ,states-,taiwan ,expedited ,double-,tax ,relief ,act #cja4 ,short title ,this subtitle may be cited as the ,united ,states-,taiwan ,expedited ,double-,tax ,relief ,act4 #cjb4 ,special rules for taxation of certain residents of ,taiwan 7a7 ,in general ,subpart ,d of part ,,ii of subchapter ,n of chapter #a is amended by inserting after section #hid the following new section3 #hid;,a4 ,special rules for qualified residents of ,taiwan 7a7 ,certain income from ,united ,states sources 7#a7 ,interest1 dividends1 and royalties1 etc 7,a7 ,in general ,in the case of interest 7other than original issue discount71 dividends1 royalties1 amounts described in section #hga7;a77#a77;,c71 and gains described in section #hga7;a77#a77;,d7 received by or paid to a qualified resident of ,taiwan-- 7i7 sections #hga7;a71 #hha7;a71 #adda7;a71 #adda7;c77#e71 and #addb7;a7 shall each be applied by substituting the applicable percentage 7as defined in section #hid;,a7a77#a77;,c77 for #cj percent each place it appears1 and 7ii7 sections #hga7;a71 #hha7;a71 and #adda7;c77#a7 shall each be applied by substituting a ,united ,states permanent establishment of a qualified resident of ,taiwan for a trade or business within the ,united ,states each place it appears4 7,b7 ,exceptions 7i7 ,in general ,subparagraph 7,a7 shall not apply to-- 7,i7 any dividend received from or paid by a real estate investment trust which is not a qualified ,,reit dividend1 7,,ii7 any amount subject to section #hig1 7,,iii7 any amount received from or paid by an expatriated entity 7as defined in section #ghgd7;a77#b77 to a foreign related person 7as defined in section #ghgd7;d77#c771 and 7,,iv7 any amount which is included in income under section #hfj;,c to the extent that such amount does not exceed an excess inclusion with respect to a ,,remic4 7ii7 ,qualified ,,reit dividend ,for purposes of clause 7i77,i71 the term qualified ,,reit dividend means any dividend received from or paid by a real estate investment trust if such dividend is paid with respect to a class of shares that is publicly traded and the recipient of the dividend is a person who holds an interest in any class of shares of the real estate investment trust of not more than #e percent4 7,c7 ,applicable percentage ,for purposes of applying subparagraph 7,a77i7-- 7i7 ,in general ,except as provided in clause 7ii71 the term applicable percentage means #aj percent4 7ii7 ,special rules for dividends ,in the case of any dividend in respect of stock received by or paid to a qualified resident of ,taiwan1 the applicable percentage shall be #ae percent 7#aj percent in the case of a dividend which meets the requirements of subparagraph 7,d7 and is received by or paid to an entity taxed as a corporation in ,taiwan74 7,d7 ,requirements for lower dividend rate 7i7 ,in general ,the requirements of this subparagraph are met with respect to any dividend in respect of stock in a corporation if1 at all times during the #ab-month period ending on the date such stock becomes ex-dividend with respect to such dividend-- 7,i7 the dividend is derived by a qualified resident of ,taiwan1 and 7,,ii7 such qualified resident of ,taiwan has held directly at least #aj percent 7by vote and value7 of the total outstanding shares of stock in such corporation4 ,for purposes of subclause 7,,ii71 a person shall be treated as directly holding a share of stock during any period described in the preceding sentence if the share was held by a corporation from which such person later acquired that share and such corporation was1 at the time the share was acquired1 both a connected person to such person and a qualified resident of ,taiwan4 7ii7 ,exception for ,r,i,cs and ,r,e,i,ts ,notwithstanding clause 7i71 the requirements of this subparagraph shall not be treated as met with respect to any dividend paid by a regulated investment company or a real estate investment trust4 7#b7 ,qualified wages 7,a7 ,in general ,no tax shall be imposed under this chapter 7and no amount shall be withheld under section #adda7;a7 or chapter #bd7 with respect to qualified wages paid to a qualified resident of ,taiwan who-- 7i7 is not a resident of the ,united ,states 7determined without regard to subsection 7c77#c77;,e771 or 7ii7 is employed as a member of the regular component of a ship or aircraft operated in international traffic4 7,b7 ,qualified wages 7i7 ,in general ,the term qualified wages means wages1 salaries1 or similar remunerations with respect to employment involving the performance of personal services within the ,united ,states which-- 7,i7 are paid by 7or on behalf of7 any employer other than a ,united ,states person1 and 7,,ii7 are not borne by a ,united ,states permanent establishment of any person other than a ,united ,states person4 7ii7 ,exceptions ,such term shall not include directors' fees1 income derived as an entertainer or athlete1 income derived as a student or trainee1 pensions1 amounts paid with respect to employment with the ,united ,states1 any ,state 7or political subdivision thereof71 or any possession of the ,united ,states 7or any political subdivision thereof71 or other amounts specified in regulations or guidance under subsection 7f77#a77;,f74 7#c7 ,income derived from entertainment or athletic activities 7,a7 ,in general ,no tax shall be imposed under this chapter 7and no amount shall be withheld under section #adda7;a7 or chapter #bd7 with respect to income derived by an entertainer or athlete who is a qualified resident of ,taiwan from personal activities as such performed in the ,united ,states if the aggregate amount of gross receipts from such activities for the taxable year do not exceed #cj1jjj4 7,b7 ,exception ,subparagraph 7,a7 shall not apply with respect to-- 7i7 income which is qualified wages 7as defined in paragraph 7#b77;,b71 determined without regard to clause 7ii7 thereof71 or 7ii7 income which is effectively connected with a ,united ,states permanent establishment4 7b7 ,income connected with a ,united ,states permanent establishment of a qualified resident of ,taiwan 7#a7 ,in general 7,a7 ,in general ,in lieu of applying sections #hga7;b7 and #hhb1 a qualified resident of ,taiwan that carries on a trade or business within the ,united ,states through a ,united ,states permanent establishment shall be taxable as provided in section #a1 #aa1 #ee1 or #ei;,a1 on its taxable income which is effectively connected with such permanent establishment4 7,b7 ,determination of taxable income ,in determining taxable income for purposes of paragraph 7#a71 gross income includes only gross income which is effectively connected with the permanent establishment4 7#b7 ,treatment of dispositions of ,united ,states real property ,in the case of a qualified resident of ,taiwan1 section #hig7;a7 shall be applied-- 7,a7 by substituting carried on a trade or business within the ,united ,states through a ,united ,states permanent establishment for were engaged in a trade or business within the ,united ,states1 and 7,b7 by substituting such ,united ,states permanent establishment for such trade or business4 7#c7 ,treatment of branch profits taxes ,in the case of any corporation which is a qualified resident of ,taiwan1 section #hhd shall be applied-- 7,a7 by substituting #aj percent for #cj percent in subsection 7a7 thereof1 and 7,b7 by substituting a ,united ,states permanent establishment of a qualified resident of ,taiwan for the conduct of a trade or business within the ,united ,states in subsection 7d77#a7 thereof4 7#d7 ,special rule with respect to income derived from certain entertainment or athletic activities 7,a7 ,in general ,paragraph 7#a7 shall not apply to the extent that the income is derived-- 7i7 in respect of entertainment or athletic activities performed in the ,united ,states1 and 7ii7 by a qualified resident of ,taiwan who is not the entertainer or athlete performing such activities4 7,b7 ,exception ,subparagraph 7,a7 shall not apply if the person described in subparagraph 7,a77ii7 is contractually authorized to designate the individual who is to perform such activities4 7#e7 ,special rule with respect to certain amounts ,paragraph 7#a7 shall not apply to any income which is wages1 salaries1 or similar remuneration with respect to employment or with respect to any amount which is described in subsection 7a77#b77;,b77ii74 7c7 ,qualified resident of ,taiwan ,for purposes of this section-- 7#a7 ,in general ,the term qualified resident of ,taiwan means any person who-- 7,a7 is liable to tax under the laws of ,taiwan by reason of such person's domicile1 residence1 place of management1 place of incorporation1 or any similar criterion1 7,b7 is not a ,united ,states person 7determined without regard to paragraph 7#c77;,e771 and 7,c7 in the case of an entity taxed as a corporation in ,taiwan1 meets the requirements of paragraph 7#b74 7#b7 ,limitation on benefits for corporate entities of ,taiwan 7,a7 ,in general ,subject to subparagraphs 7,e7 and 7,f71 an entity meets the requirements of this paragraph only if it-- 7i7 meets the ownership and income requirements of subparagraph 7,b71 7ii7 meets the publicly traded requirements of subparagraph 7,c71 or 7iii7 meets the qualified subsidiary requirements of subparagraph 7,d74 7,b7 ,ownership and income requirements ,the requirements of this subparagraph are met for an entity if-- 7i7 at least #ej percent 7by vote and value7 of the total outstanding shares of stock in such entity are owned directly or indirectly by qualified residents of ,taiwan1 and 7ii7 less than #ej percent of such entity's gross income 7and in the case of an entity that is a member of a tested group1 less than #ej percent of the tested group's gross income7 is paid or accrued1 directly or indirectly1 in the form of payments that are deductible for purposes of the income taxes imposed by ,taiwan1 to persons who are not-- 7,i7 qualified residents of ,taiwan1 or 7,,ii7 ,united ,states persons who meet such requirements with respect to the ,united ,states as determined by the ,secretary to be equivalent to the requirements of this subsection 7determined without regard to paragraph 7#a77;,b77 with respect to residents of ,taiwan4 7,c7 ,publicly traded requirements ,an entity meets the requirements of this subparagraph if-- 7i7 the principal class of its shares 7and any disproportionate class of shares7 of such entity are primarily and regularly traded on an established securities market in ,taiwan1 or 7ii7 the primary place of management and control of the entity is in ,taiwan and all classes of its outstanding shares described in clause 7i7 are regularly traded on an established securities market in ,taiwan4 7,d7 ,qualified subsidiary requirements ,an entity meets the requirement of this subparagraph if-- 7i7 at least #ej percent 7by vote and value7 of the total outstanding shares of the stock of such entity are owned directly or indirectly by #e or fewer entities-- 7,i7 which meet the requirements of subparagraph 7,c71 or 7,,ii7 which are ,united ,states persons the principal class of the shares 7and any disproportionate class of shares7 of which are primarily and regularly traded on an established securities market in the ,united ,states1 and 7ii7 the entity meets the requirements of clause 7ii7 of subparagraph 7,b74 7,e7 ,only indirect ownership through qualifying intermediaries counted 7i7 ,in general ,stock in an entity owned by a person indirectly through #a or more other persons shall not be treated as owned by such person in determining whether the person meets the requirements of subparagraph 7,b77i7 or 7,d77i7 unless all such other persons are qualifying intermediate owners4 7ii7 ,qualifying intermediate owners ,the term qualifying intermediate owner means a person that is-- 7,i7 a qualified resident of ,taiwan1 or 7,,ii7 a resident of any other foreign country 7other than a foreign country that is a foreign country of concern7 that has in effect a comprehensive convention with the ,united ,states for the avoidance of double taxation4 7iii7 ,special rule for qualified subsidiaries ,for purposes of applying subparagraph 7,d77i71 the term qualifying intermediate owner shall include any person who is a ,united ,states person who meets such requirements with respect to the ,united ,states as determined by the ,secretary to be equivalent to the requirements of this subsection 7determined without regard to paragraph 7#a77;,b77 with respect to residents of ,taiwan4 7,f7 ,certain payments not included ,in determining whether the requirements of subparagraph 7,b77ii7 or 7,d77ii7 are met with respect to an entity1 the following payments shall not be taken into account3 7i7 ,arm's-length payments by the entity in the ordinary course of business for services or tangible property4 7ii7 ,in the case of a tested group1 intra-group transactions4 7#c7 ,dual residents 7,a7 ,rules for determination of status 7i7 ,in general ,an individual who is an applicable dual resident and who is described in subparagraph 7,b71 7,c71 or 7,d7 shall be treated as a qualified resident of ,taiwan4 7ii7 ,applicable dual resident ,for purposes of this paragraph1 the term applicable dual resident means an individual who-- 7,i7 is not a ,united ,states citizen1 7,,ii7 is a resident of the ,united ,states 7determined without regard to subparagraph 7,e771 and 7,,iii7 would be a qualified resident of ,taiwan but for paragraph 7#a77;,b74 7,b7 ,permanent home ,an individual is described in this subparagraph if such individual-- 7i7 has a permanent home available to such individual in ,taiwan1 and 7ii7 does not have a permanent home available to such individual in the ,united ,states4 7,c7 ,center of vital interests ,an individual is described in this subparagraph if-- 7i7 such individual has a permanent home available to such individual in both ,taiwan and the ,united ,states1 and 7ii7 such individual's personal and economic relations 7center of vital interests7 are closer to ,taiwan than to the ,united ,states4 7,d7 ,habitual abode ,an individual is described in this subparagraph if-- 7i7 such individual-- 7,i7 does not have a permanent home available to such individual in either ,taiwan or the ,united ,states1 or 7,,ii7 has a permanent home available to such individual in both ,taiwan and the ,united ,states but such individual's center of vital interests under subparagraph 7,c77ii7 cannot be determined1 and 7ii7 such individual has a habitual abode in ,taiwan and not the ,united ,states4 7,e7 ,united ,states tax treatment of qualified resident of ,taiwan ,notwithstanding section #ggja1 an individual who is treated as a qualified resident of ,taiwan by reason of this paragraph for all or any portion of a taxable year shall not be treated as a resident of the ,united ,states for purposes of computing such individual's ,united ,states income tax liability for such taxable year or portion thereof4 7#d7 ,rules of special application 7,a7 ,dividends ,for purposes of applying this section to any dividend1 paragraph 7#b77;,d7 shall be applied without regard to clause 7ii7 thereof4 7,b7 ,items of income emanating from an active trade or business in ,taiwan ,for purposes of this section-- 7i7 ,in general ,notwithstanding the preceding paragraphs of this subsection1 if an entity taxed as a corporation in ,taiwan is not a qualified resident of ,taiwan but meets the requirements of subparagraphs 7,a7 and 7,b7 of paragraph 7#a71 any qualified item of income such entity derived from the ,united ,states shall be treated as income of a qualified resident of ,taiwan4 7ii7 ,qualified items of income 7,i7 ,in general ,the term qualified item of income means any item of income which emanates from1 or is incidental to1 the conduct of an active trade or business in ,taiwan 7other than operating as a holding company1 providing overall supervision or administration of a group of companies1 providing group financing1 or making or managing investments 7unless such making or managing investments is carried on by a bank1 insurance company1 or registered securities dealer in the ordinary course of its business as such774 7,,ii7 ,substantial activity requirement ,an item of income which is derived from a trade or business conducted in the ,united ,states or from a connected person shall be a qualified item of income only if the trade or business activity conducted in ,taiwan to which the item is related is substantial in relation to the same or a complementary trade or business activity carried on in the ,united ,states4 ,for purposes of applying this subclause1 activities conducted by persons that are connected to the entity described in clause 7i7 shall be deemed to be conducted by such entity4 7iii7 ,exception ,this subparagraph shall not apply to any item of income derived by an entity if at least #ej percent 7by vote or value7 of such entity is owned 7directly or indirectly7 or controlled by residents of a foreign country of concern4 7d7 ,other definitions and special rules ,for purposes of this section-- 7#a7 ,united ,states permanent establishment 7,a7 ,in general ,the term ,united ,states permanent establishment means1 with respect to a qualified resident of ,taiwan1 a permanent establishment of such resident which is within the ,united ,states4 7,b7 ,special rule ,the determination of whether there is a permanent establishment of a qualified resident of ,taiwan within the ,united ,states shall be made without regard to whether an entity which is taxed as a corporation in ,taiwan and which is a qualified resident of ,taiwan controls or is controlled by-- 7i7 a domestic corporation1 or 7ii7 any other person that carries on business in the ,united ,states 7whether through a permanent establishment or otherwise74 7#b7 ,permanent establishment 7,a7 ,in general ,the term permanent establishment means a fixed place of business through which a trade or business is wholly or partly carried on4 ,such term shall include-- 7i7 a place of management1 7ii7 a branch1 7iii7 an office1 7iv7 a factory1 7v7 a workshop1 and 7vi7 a mine1 an oil or gas well1 a quarry1 or any other place of extraction of natural resources4 7,b7 ,special rules for certain temporary projects 7i7 ,in general ,a building site or construction or installation project1 or an installation or drilling rig or ship used for the exploration or exploitation of the sea bed and its subsoil and their natural resources1 constitutes a permanent establishment only if it lasts1 or the activities of the rig or ship lasts1 for more than #ab months4 7ii7 ,determination of #ab-month period ,for purposes of clause 7i71 the period over which a building site or construction or installation project of a person lasts shall include any period of more than #cj days during which such person does not carry on activities at such building site or construction or installation project but connected activities are carried on at such building site or construction or installation project by one or more connected persons4 7,c7 ,habitual exercise of contract authority treated as permanent establishment ,notwithstanding subparagraphs 7,a7 and 7,b71 where a person 7other than an agent of an independent status to whom subparagraph 7,d77ii7 applies7 is acting on behalf of a trade or business of a qualified resident of ,taiwan and has and habitually exercises an authority to conclude contracts that are binding on the trade or business1 that trade or business shall be deemed to have a permanent establishment in the country in which such authority is exercised in respect of any activities that the person undertakes for the trade or business1 unless the activities of such person are limited to those described in subparagraph 7,d77i7 that1 if exercised through a fixed place of business1 would not make this fixed place of business a permanent establishment under the provisions of that subparagraph4 7,d7 ,exclusions 7i7 ,in general ,notwithstanding subparagraphs 7,a7 and 7,b71 the term permanent establishment shall not include-- 7,i7 the use of facilities solely for the purpose of storage1 display1 or delivery of goods or merchandise belonging to the trade or business1 7,,ii7 the maintenance of a stock of goods or merchandise belonging to the trade or business solely for the purpose of storage1 display1 or delivery1 7,,iii7 the maintenance of a stock of goods or merchandise belonging to the trade or business solely for the purpose of processing by another trade or business1 7,,iv7 the maintenance of a fixed place of business solely for the purpose of purchasing goods or merchandise1 or of collecting information1 for the trade or business1 7,v7 the maintenance of a fixed place of business solely for the purpose of carrying on1 for the trade or business1 any other activity of a preparatory or auxiliary character1 or 7,,vi7 the maintenance of a fixed place of business solely for any combination of the activities mentioned in subclauses 7,i7 through 7,v71 provided that the overall activity of the fixed place of business resulting from this combination is of a preparatory or auxiliary character4 7ii7 ,brokers and other independent agents ,a trade or business shall not be considered to have a permanent establishment in a country merely because it carries on business in such country through a broker1 general commission agent1 or any other agent of an independent status1 provided that such persons are acting in the ordinary course of their business as independent agents4 7#c7 ,tested group ,the term tested group includes1 with respect to any entity taxed as a corporation in ,taiwan1 such entity and any other entity taxed as a corporation in ,taiwan that-- 7,a7 participates as a member with such entity in a tax consolidation1 fiscal unity1 or similar regime that requires members of the group to share profits or losses1 or 7,b7 shares losses with such entity pursuant to a group relief or other loss sharing regime4 7#d7 ,connected person ,two persons shall be connected persons if one owns1 directly or indirectly1 at least #ej percent of the interests in the other 7or1 in the case of a corporation1 at least #ej percent of the aggregate vote and value of the corporation's shares7 or another person owns1 directly or indirectly1 at least #ej percent of the interests 7or1 in the case of a corporation1 at least #ej percent of the aggregate vote and value of the corporation's shares7 in each person4 ,in any case1 a person shall be connected to another if1 based on all the relevant facts and circumstances1 one has control of the other or both are under the control of the same person or persons4 7#e7 ,foreign country of concern ,the term foreign country of concern has the meaning given such term under paragraph 7#g7 of section #iija of the ,william ,m4 7,mac7 ,thornberry ,national ,defense ,authorization ,act for ,fiscal ,year #bjba 7#ae ,u4,s4,c4 #dfea7g771 as added by section #ajc7;a77#d7 of the ,,chips ,act of #bjbb74 7#f7 ,partnerships2 beneficiaries of estates and trusts ,for purposes of this section-- 7,a7 a qualified resident of ,taiwan which is a partner of a partnership which carries on a trade or business within the ,united ,states through a ,united ,states permanent establishment shall be treated as carrying on such trade or business through such permanent establishment1 and 7,b7 a qualified resident of ,taiwan which is a beneficiary of an estate or trust which carries on a trade or business within the ,united ,states through a ,united ,states permanent establishment shall be treated as carrying on such trade or business through such permanent establishment4 7#g7 ,denial of benefits for certain payments through hybrid entities ,for purposes of this section1 rules similar to the rules of section #hid7;c7 shall apply4 7e7 ,application 7#a7 ,in general ,this section shall not apply to any period unless the ,secretary has determined that ,taiwan has provided benefits to ,united ,states persons for such period that are reciprocal to the benefits provided to qualified residents of ,taiwan under this section4 7#b7 ,provision of reciprocity ,the ,president or his designee is authorized to exchange letters1 enter into an agreement1 or take other necessary and appropriate steps relative to ,taiwan for the reciprocal provision of the benefits described in this section4 7f7 ,regulations or other guidance 7#a7 ,in general ,the ,secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the provisions of this section1 including such regulations or guidance for-- 7,a7 determining-- 7i7 what constitutes a ,united ,states permanent establishment of a qualified resident of ,taiwan1 and 7ii7 income that is effectively connected with such a permanent establishment1 7,b7 preventing the abuse of the provisions of this section by persons who are not 7or who should not be treated as7 qualified residents of ,taiwan1 7,c7 requirements for record keeping and reporting1 7,d7 rules to assist withholding agents or employers in determining whether a foreign person is a qualified resident of ,taiwan for purposes of determining whether withholding or reporting is required for a payment 7and1 if withholding is required1 whether it should be applied at a reduced rate71 7,e7 the application of subsection 7a77#a77;,d77i7 to stock held by predecessor owners1 7,f7 determining what amounts are to be treated as qualified wages for purposes of subsection 7a77#b71 7,g7 determining the amounts to which subsection 7a77#c7 applies1 7,h7 defining established securities market for purposes of subsection 7c71 7,i7 the application of the rules of subsection 7c77#d77;,b71 7,j7 the application of subsection 7d77#f7 and section #addf1 7,k7 determining ownership interests held by residents of a foreign country of concern1 and 7,l7 determining the starting and ending dates for periods with respect to the application of this section under subsection 7e71 which may be separate dates for taxes withheld at the source and other taxes4 7#b7 ,regulations to be consistent with model treaty ,any regulations or other guidance issued under this section shall1 to the extent practical1 be consistent with the provisions of the ,united ,states model income tax convention dated ,february #g1 #bjaf4 4 7b7 ,conforming amendment to withholding tax ,subchapter ,a of chapter #c is amended by adding at the end the following new section3 #addg4 ,withholding for qualified residents of ,taiwan ,for reduced rates of withholding for certain residents of ,taiwan1 see section #hid;,a4 4 7c7 ,clerical amendments 7#a7 ,the table of sections for subpart ,d of part ,,ii of subchapter ,n of chapter #a is amended by inserting after the item relating to section #hid the following new item3 ,sec4 #hid;,a4 ,special rules for qualified residents of ,taiwan4 4 7#b7 ,the table of sections for subchapter ,a of chapter #c is amended by adding at the end the following new item3 ,sec4 #addg4 ,withholding for qualified residents of ,taiwan4 4 ,b ,united ,states-,taiwan ,tax ,agreement ,authorization ,act #caa4 ,short title ,this subtitle may be cited as the ,united ,states-,taiwan ,tax ,agreement ,authorization ,act4 #cab4 ,definitions ,in this subtitle3 7#a7 ,agreement ,the term ,agreement means the tax agreement authorized by section #cac7;a74 7#b7 ,appropriate congressional committees ,the term appropriate congressional committees means-- 7,a7 the ,committee on ,foreign ,relations and the ,committee on ,finance of the ,senate2 and 7,b7 the ,committee on ,ways and ,means of the ,house of ,representatives4 7#c7 ,approval legislation ,the term approval legislation means legislation that approves the ,agreement4 7#d7 ,implementing legislation ,the term implementing legislation means legislation that makes any changes to the ,internal ,revenue ,code of #aihf necessary to implement the ,agreement4 #cac4 ,authorization to negotiate and enter into agreement 7a7 ,in general ,subsequent to a determination under section #hid;,a7e77#a7 of the ,internal ,revenue ,code of #aihf 7as added by the ,united ,states-,taiwan ,expedited ,double-,tax ,relief ,act71 the ,president is authorized to negotiate and enter into a tax agreement relative to ,taiwan4 7b7 ,elements of agreement 7#a7 ,conformity with bilateral income tax conventions ,the ,president shall ensure that-- 7,a7 any provisions included in the ,agreement conform with provisions customarily contained in ,united ,states bilateral income tax conventions1 as exemplified by the #bjaf ,united ,states ,model ,income ,tax ,convention2 and 7,b7 the ,agreement does not include elements outside the scope of the #bjaf ,united ,states ,model ,income ,tax ,convention4 7#b7 ,incorporation of tax agreements and laws ,notwithstanding paragraph 7#a71 the ,agreement may incorporate and restate provisions of any agreement1 or existing ,united ,states law1 addressing double taxation for residents of the ,united ,states and ,taiwan4 7#c7 ,authority ,the ,agreement shall include the following statement3 ,the ,agreement is entered into pursuant to the ,united ,states-,taiwan ,tax ,agreement ,authorization ,act4 7#d7 ,entry into force ,the ,agreement shall include a provision conditioning entry into force upon-- 7,a7 enactment of approval legislation and implementing legislation pursuant to section #cag2 and 7,b7 confirmation by the ,secretary of the ,treasury that the relevant authority in ,taiwan has approved and taken appropriate steps required to implement the ,agreement4 #cad4 ,consultations with ,congress 7a7 ,notification upon commencement of negotiations ,the ,president shall provide written notification to the appropriate congressional committees of the commencement of negotiations between the ,united ,states and ,taiwan on the ,agreement at least #ae calendar days before commencing such negotiations4 7b7 ,consultations during negotiations 7#a7 ,briefings ,not later than #ij days after commencement of negotiations with respect to the ,agreement1 and every #ahj days thereafter until the ,president enters into the ,agreement1 the ,president shall provide a briefing to the appropriate congressional committees on the status of the negotiations1 including a description of elements under negotiation4 7#b7 ,meetings and other consultations 7,a7 ,in general ,in the course of negotiations with respect to the ,agreement1 the ,secretary of the ,treasury1 in coordination with the ,secretary of ,state1 shall-- 7i7 meet1 upon request1 with the chairman or ranking member of any of the appropriate congressional committees regarding negotiating objectives and the status of negotiations in progress2 and 7ii7 consult closely and on a timely basis with1 and keep fully apprised of the negotiations1 the appropriate congressional committees4 7,b7 ,elements of consultations ,the consultations described in subparagraph 7,a7 shall include consultations with respect to-- 7i7 the nature of the contemplated ,agreement2 7ii7 how and to what extent the contemplated ,agreement is consistent with the elements set forth in section #cac7;b72 and 7iii7 the implementation of the contemplated ,agreement1 including-- 7,i7 the general effect of the contemplated ,agreement on existing laws2 7,,ii7 proposed changes to any existing laws to implement the contemplated ,agreement2 and 7,,iii7 proposed administrative actions to implement the contemplated ,agreement4 #cae4 ,approval and implementation of agreement 7a7 ,in general ,the ,agreement may not enter into force unless-- 7#a7 the ,president1 at least #fj days before the day on which the ,president enters into the ,agreement1 publishes the text of the contemplated ,agreement on a publicly available website of the ,department of the ,treasury2 and 7#b7 there is enacted into law1 with respect to the ,agreement1 approval legislation and implementing legislation pursuant to section #cag4 7b7 ,entry into force ,the ,president may provide for the ,agreement to enter into force upon-- 7#a7 enactment of approval legislation and implementing legislation pursuant to section #cag2 and 7#b7 confirmation by the ,secretary of the ,treasury that the relevant authority in ,taiwan has approved and taken appropriate steps required to implement the ,agreement4 #caf4 ,submission to ,congress of agreement and implementation policy 7a7 ,submission of agreement ,not later than #bgj days after the ,president enters into the ,agreement1 the ,president or the ,president's designee shall submit to ,congress-- 7#a7 the final text of the ,agreement2 and 7#b7 a technical explanation of the ,agreement4 7b7 ,submission of implementation policy ,not later than #bgj days after the ,president enters into the ,agreement1 the ,secretary of the ,treasury shall submit to ,congress-- 7#a7 a description of those changes to existing laws that the ,president considers would be required in order to ensure that the ,united ,states acts in a manner consistent with the ,agreement2 and 7#b7 a statement of anticipated administrative action proposed to implement the ,agreement4 #cag4 ,consideration of approval legislation and implementing legislation 7a7 ,in general ,the approval legislation with respect to the ,agreement shall include the following3 ,congress approves the ,agreement submitted to ,congress pursuant to section #caf of the ,united ,states-,taiwan ,tax ,agreement ,authorization ,act on 41 with the blank space being filled with the appropriate date4 7b7 ,approval legislation committee referral ,the approval legislation shall-- 7#a7 in the ,senate1 be referred to the ,committee on ,foreign ,relations2 and 7#b7 in the ,house of ,representaives1 be referred to the ,committee on ,ways and ,means4 7c7 ,implementing legislation committee referral ,the implementing legislation shall-- 7#a7 in the ,senate1 be referred to the ,committee on ,finance2 and 7#b7 in the ,house of ,representatives1 be referred to the ,committee on ,ways and ,means4 #cah4 ,relationship of agreement to ,internal ,revenue ,code of #aihf 7a7 ,internal ,revenue ,code of #aihf to control ,no provision of the ,agreement or approval legislation1 nor the application of any such provision to any person or circumstance1 which is inconsistent with any provision of the ,internal ,revenue ,code of #aihf1 shall have effect4 7b7 ,construction ,nothing in this subtitle shall be construed-- 7#a7 to amend or modify any law of the ,united ,states2 or 7#b7 to limit any authority conferred under any law of the ,united ,states1 unless specifically provided for in this subtitle4 #cai4 ,authorization of subsequent tax agreements relative to ,taiwan 7a7 ,in general ,subsequent to the enactment of approval legislation and implementing legislation pursuant to section #cag-- 7#a7 the term 8tax agreement0 in section #cac7;a7 shall be treated as including any tax agreement relative to ,taiwan which supplements or supersedes the ,agreement to which such approval legislation and implementing legislation relates1 and 7#b7 the term 8,agreement0 shall be treated as including such tax agreement4 7b7 ,requirements1 etc41 to apply separately ,the provisions of this subtitle 7including section #cad7 shall be applied separately with respect to each tax agreement referred to in subsection 7a74 #cbj4 ,united ,states treatment of double taxation matters with respect to ,taiwan 7a7 ,findings ,congress makes the following findings3 7#a7 ,the ,united ,states addresses issues with respect to double taxation with foreign countries by entering into bilateral income tax conventions 7known as tax treaties7 with such countries1 subject to the advice and consent of the ,senate to ratification pursuant to article ,,ii of the ,constitution4 7#b7 ,the ,united ,states has entered into more than sixty such tax treaties1 which facilitate economic activity1 strengthen bilateral cooperation1 and benefit ,united ,states workers1 businesses1 and other ,united ,states taxpayers4 7#c7 ,due to ,taiwan's unique status1 the ,united ,states is unable to enter into an article ,,ii tax treaty with ,taiwan1 necessitating an agreement to address issues with respect to double taxation4 7b7 ,statement of policy ,it is the policy of the ,united ,states to-- 7#a7 provide for additional bilateral tax relief with respect to ,taiwan1 beyond that provided for in section #hid;,a of the ,internal ,revenue ,code of #aihf 7as added by the ,united ,states-,taiwan ,expedited ,double-,tax ,relief ,act71 only after entry into force of an ,agreement1 as provided for in section #cae1 and only in a manner consistent with such ,agreement2 and 7#b7 continue to provide for bilateral tax relief with sovereign states to address double taxation and other related matters through entering into bilateral income tax conventions1 subject to the ,senate's advice and consent to ratification pursuant to article ,,ii of the ,constitution4 ,,iv ,assistance for ,disaster-,impacted ,communities #dja4 ,short title ,this title may be cited as the ,federal ,disaster ,tax ,relief ,act of #bjbd4 #djb4 ,extension of rules for treatment of certain disaster-related personal casualty losses ,for purposes of applying section #cjd7;b7 of the ,taxpayer ,certainty and ,disaster ,tax ,relief ,act of #bjbj1 section #cja of such ,act shall be applied by substituting the ,federal ,disaster ,tax ,relief ,act of #bjbd for this ,act each place it appears4 #djc4 ,exclusion from gross income for compensation for losses or damages resulting from certain wildfires 7a7 ,in general ,for purposes of the ,internal ,revenue ,code of #aihf1 gross income shall not include any amount received by an individual as a qualified wildfire relief payment4 7b7 ,qualified wildfire relief payment ,for purposes of this section-- 7#a7 ,in general ,the term qualified wildfire relief payment means any amount received by or on behalf of an individual as compensation for losses1 expenses1 or damages 7including compensation for additional living expenses1 lost wages 7other than compensation for lost wages paid by the employer which would have otherwise paid such wages71 personal injury1 death1 or emotional distress7 incurred as a result of a qualified wildfire disaster1 but only to the extent the losses1 expenses1 or damages compensated by such payment are not compensated for by insurance or otherwise4 7#b7 ,qualified wildfire disaster ,the term qualified wildfire disaster means any federally declared disaster 7as defined in section #afe7;i77#e77;,a7 of the ,internal ,revenue ,code of #aihf7 declared1 after ,december #ca1 #bjad1 as a result of any forest or range fire4 7c7 ,denial of double benefit ,notwithstanding any other provision of the ,internal ,revenue ,code of #aihf-- 7#a7 no deduction or credit shall be allowed 7to the person for whose benefit a qualified wildfire relief payment is made7 for1 or by reason of1 any expenditure to the extent of the amount excluded under this section with respect to such expenditure1 and 7#b7 no increase in the basis or adjusted basis of any property shall result from any amount excluded under this subsection with respect to such property4 7d7 ,limitation on application ,this section shall only apply to qualified wildfire relief payments received by the individual during taxable years beginning after ,december #ca1 #bjai1 and before ,january #a1 #bjbf4 #djd4 ,east ,palestine disaster relief payments 7a7 ,disaster relief payments to victims of ,east ,palestine train derailment ,east ,palestine train derailment payments shall be treated as qualified disaster relief payments for purposes of section #aci7;b7 of the ,internal ,revenue ,code of #aihf4 7b7 ,east ,palestine train derailment payments ,for purposes of this section1 the term ,east ,palestine train derailment payment means any amount received by or on behalf of an individual as compensation for loss1 damages1 expenses1 loss in real property value1 closing costs with respect to real property 7including realtor commissions71 or inconvenience 7including access to real property7 resulting from the ,east ,palestine train derailment if such amount was provided by-- 7#a7 a ,federal1 ,state1 or local government agency1 7#b7 ,norfolk ,southern ,railway1 or 7#c7 any subsidiary1 insurer1 or agent of ,norfolk ,southern ,railway or any related person4 7c7 ,train derailment ,for purposes of this section1 the term ,east ,palestine train derailment means the derailment of a train in ,east ,palestine1 ,ohio1 on ,february #c1 #bjbc4 7d7 ,effective date ,this section shall apply to amounts received on or after ,february #c1 #bjbc4 ,v ,more ,affordable housing #eja4 ,state housing credit ceiling increase for low-income housing credit 7a7 ,in general ,section #db7;h77#c77;,i7 is amended-- 7#a7 by striking and #bjba1 and inserting #bjba1 #bjbc1 #bjbd1 and #bjbe11 and 7#b7 by striking #bjah1 #bjai1 #bjbj1 and #bjba in the heading and inserting certain calendar years4 7b7 ,effective date ,the amendments made by this section shall apply to calendar years after #bjbb4 #ejb4 ,tax-exempt bond financing requirement 7a7 ,in general ,section #db7;h77#d7 is amended by striking subparagraph 7,b7 and inserting the following3 7,b7 ,special rule where minimum percent of buildings is financed with tax-exempt bonds subject to volume cap ,for purposes of subparagraph 7,a71 paragraph 7#a7 shall not apply to any portion of the credit allowable under subsection 7a7 with respect to a building if-- 7i7 #ej percent or more of the aggregate basis of such building and the land on which the building is located is financed by #a or more obligations described in subparagraph 7,a71 or 7ii7 7,i7 #cj percent or more of the aggregate basis of such building and the land on which the building is located is financed by #a or more qualified obligations1 and 7,,ii7 #a or more of such qualified obligations-- 7aa7 are part of an issue the issue date of which is after ,december #ca1 #bjbc1 and 7bb7 provide the financing for not less than #e percent of the aggregate basis of such building and the land on which the building is located4 7,c7 ,qualified obligation ,for purposes of subparagraph 7,b77ii71 the term qualified obligation means an obligation which is described in subparagraph 7,a7 and which is part of an issue the issue date of which is before ,january #a1 #bjbf4 4 7b7 ,effective date 7#a7 ,in general ,the amendment made by this section shall apply to buildings placed in service in taxable years beginning after ,december #ca1 #bjbc4 7#b7 ,rehabilitation expenditures treated as separate new building ,in the case of any building with respect to which any expenditures are treated as a separate new building under section #db7;e7 of the ,internal ,revenue ,code of #aihf1 for purposes of paragraph 7#a71 both the existing building and the separate new building shall be treated as having been placed in service on the date such expenditures are treated as placed in service under section #db7;e77#d7 of such ,code4 ,,vi ,tax ,administration and ,eliminating ,fraud #fja4 ,increase in threshold for requiring information reporting with respect to certain payees 7a7 ,in general ,sections #fjda7;a7 is amended by striking #fjj and inserting #a1jjj4 7b7 ,inflation adjustment ,section #fjda is amended by adding at the end the following new subsection3 7h7 ,inflation adjustment ,in the case of any calendar year after #bjbd1 the dollar amount in subsection 7a7 shall be increased by an amount equal to-- 7#a7 such dollar amount1 multiplied by 7#b7 the cost-of-living adjustment determined under section #a7;f77#c7 for such calendar year1 determined by substituting calendar year #bjbc for calendar year #bjaf in subparagraph 7,a77ii7 thereof4 ,if any increase under the preceding sentence is not a multiple of #ajj1 such increase shall be rounded to the nearest multiple of #ajj4 4 7c7 ,application to reporting on remuneration for services and direct sales ,section #fjda;,a is amended-- 7#a7 in subsection 7a77#b71 by striking is #fjj or more and inserting equals or exceeds the dollar amount in effect for such calendar year under section #fjda7;a71 and 7#b7 in subsection 7b77#a77;,b71 by striking is #e1jjj or more and inserting equals or exceeds the dollar amount in effect for such calendar year under section #fjda7;a74 7d7 ,application to backup withholding ,section #cdjf7;b77#f7 is amended-- 7#a7 by striking #fjj in subparagraph 7,a7 and inserting the dollar amount in effect for such calendar year under section #fjda7;a71 and 7#b7 by striking only where aggregate for calendar year is #fjj or more in the heading and inserting only if in excess of threshold4 7e7 ,conforming amendments 7#a7 ,the heading of section #fjda7;a7 is amended by striking of #fjj or more and inserting exceeding threshold4 7#b7 ,section #fjda7;a7 is amended by striking taxable year and inserting calendar year4 7f7 ,effective date ,the amendments made by this section shall apply with respect to payments made after ,december #ca1 #bjbc4 #fjb4 ,enforcement provisions with respect to ,,covid-related employee retention credits 7a7 ,increase in assessable penalty on ,,covid-,,ertc promoters for aiding and abetting understatements of tax liability 7#a7 ,in general ,if any ,,covid-,,ertc promoter is subject to penalty under section #fgja7;a7 of the ,internal ,revenue ,code of #aihf with respect to any ,,covid-,,ertc document1 notwithstanding paragraphs 7#a7 and 7#b7 of section #fgja7;b7 of such ,code1 the amount of the penalty imposed under such section #fgja7;a7 shall be the greater of-- 7,a7 #bjj1jjj 7#aj1jjj1 in the case of a natural person71 or 7,b7 #ge percent of the gross income derived 7or to be derived7 by such promoter with respect to the aid1 assistance1 or advice referred to in section #fgja7;a77#a7 of such ,code with respect to such document4 7#b7 ,no inference ,paragraph 7#a7 shall not be construed to create any inference with respect to the proper application of the knowledge requirement of section #fgja7;a77#c7 of the ,internal ,revenue ,code of #aihf4 7b7 ,failure to comply with due diligence requirements treated as knowledge for purposes of assessable penalty for aiding and abetting understatement of tax liability ,in the case of any ,,covid-,,ertc promoter1 the knowledge requirement of section #fgja7;a77#c7 of the ,internal ,revenue ,code of #aihf shall be treated as satisfied with respect to any ,,covid-,,ertc document with respect to which such promoter provided aid1 assistance1 or advice1 if such promoter fails to comply with the due diligence requirements referred to in subsection 7c77#a74 7c7 ,assessable penalty for failure to comply with due diligence requirements 7#a7 ,in general ,any ,,covid-,,ertc promoter which provides aid1 assistance1 or advice with respect to any ,,covid-,,ertc document and which fails to comply with due diligence requirements imposed by the ,secretary with respect to determining eligibility for1 or the amount of1 any ,,covid-related employee retention tax credit1 shall pay a penalty of #a1jjj for each such failure4 7#b7 ,due diligence requirements ,except as otherwise provided by the ,secretary1 the due diligence requirements referred to in paragraph 7#a7 shall be similar to the due diligence requirements imposed under section #ffie7;g74 7#c7 ,restriction to documents used in connection with returns or claims for refund ,paragraph 7#a7 shall not apply with respect to any ,,covid-,,ertc document unless such document constitutes1 or relates to1 a return or claim for refund4 7#d7 ,treatment as assessable penalty1 etc ,for purposes of the ,internal ,revenue ,code of #aihf1 the penalty imposed under paragraph 7#a7 shall be treated in the same manner as a penalty imposed under section #ffie7;g74 7#e7 ,secretary ,for purposes of this subsection1 the term ,secretary means the ,secretary of the ,treasury or the ,secretary's delegate4 7d7 ,assessable penalties for failure to disclose information1 maintain client lists1 etc ,for purposes of sections #faaa1 #faab1 #fgjg and #fgjh of the ,internal ,revenue ,code of #aihf-- 7#a7 any ,,covid-related employee retention tax credit 7whether or not the taxpayer claims such ,,covid-related employee retention tax credit7 shall be treated as a listed transaction 7and as a reportable transaction7 with respect to any ,,covid-,,ertc promoter if such promoter provides any aid1 assistance1 or advice with respect to any ,,covid-,,ertc document relating to such ,,covid-related employee retention tax credit1 and 7#b7 such ,,covid-,,ertc promoter shall be treated as a material advisor with respect to such transaction4 7e7 ,,covid-,,ertc promoter ,for purposes of this section-- 7#a7 ,in general ,the term ,,covid-,,ertc promoter means1 with respect to any ,,covid-,,ertc document1 any person which provides aid1 assistance1 or advice with respect to such document if-- 7,a7 such person charges or receives a fee for such aid1 assistance1 or advice which is based on the amount of the refund or credit with respect to such document and1 with respect to such person's taxable year in which such person provided such assistance or the preceding taxable year1 the aggregate gross receipts of such person for aid1 assistance1 and advice with respect to all ,,covid-,,ertc documents exceeds #bj percent of the gross receipts of such person for such taxable year1 or 7,b7 with respect to such person's taxable year in which such person provided such assistance or the preceding taxable year-- 7i7 the aggregate gross receipts of such person for aid1 assistance1 and advice with respect to all ,,covid-,,ertc documents exceeds #ej percent of the gross receipts of such person for such taxable year1 or 7ii7 both-- 7,i7 such aggregate gross receipts exceeds #bj percent of the gross receipts of such person for such taxable year1 and 7,,ii7 the aggregate gross receipts of such person for aid1 assistance1 and advice with respect to all ,,covid-,,ertc documents 7determined after application of paragraph 7#c77 exceeds #ejj1jjj4 7#b7 ,exception for certified professional employer organizations ,the term ,,covid-,,ertc promoter shall not include a certified professional employer organization 7as defined in section #ggje74 7#c7 ,aggregation rule ,for purposes of paragraph 7#a77;,b77ii77,,ii71 all persons treated as a single employer under subsection 7a7 or 7b7 of section #eb of the ,internal ,revenue ,code of #aihf1 or subsection 7m7 or 7o7 of section #dad of such ,code1 shall be treated as #a person4 7#d7 ,short taxable years ,in the case of any taxable year of less than #ab months1 paragraph 7#a7 shall be applied with respect to the calendar year in which such taxable year begins 7in addition to applying to such taxable year74 7f7 ,,covid-,,ertc document ,for purposes of this section1 the term ,,covid-,,ertc document means any return1 affidavit1 claim1 or other document related to any ,,covid-related employee retention tax credit1 including any document related to eligibility for1 or the calculation or determination of any amount directly related to any ,,covid-related employee retention tax credit4 7g7 ,,covid-related employee retention tax credit ,for purposes of this section1 the term ,,covid-related employee retention tax credit means-- 7#a7 any credit1 or advance payment1 under section #cacd of the ,internal ,revenue ,code of #aihf1 and 7#b7 any credit1 or advance payment1 under section #bcja of the ,,cares ,act4 7h7 ,limitation on credit and refund of ,,covid-related employee retention tax credits ,notwithstanding section #feaa of the ,internal ,revenue ,code of #aihf or any other provision of law1 no credit or refund of any ,,covid-related employee retention tax credit shall be allowed or made after ,january #ca1 #bjbd1 unless a claim for such credit or refund is filed by the taxpayer on or before such date4 7i7 ,amendments to extend limitation on assessment 7#a7 ,in general ,section #cacd7l7 of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7l7 ,extension of limitation on assessment 7#a7 ,in general ,notwithstanding section #feja1 the limitation on the time period for the assessment of any amount attributable to a credit claimed under this section shall not expire before the date that is #f years after the latest of-- 7,a7 the date on which the original return which includes the calendar quarter with respect to which such credit is determined is filed1 7,b7 the date on which such return is treated as filed under section #feja7;b77#b71 or 7,c7 the date on which the claim for credit or refund with respect to such credit is made4 7#b7 ,deduction for wages taken into account in determining improperly claimed credit 7,a7 ,in general ,notwithstanding section #feaa1 in the case of an assessment attributable to a credit claimed under this section1 the limitation on the time period for credit or refund of any amount attributable to a deduction for improperly claimed ,,ertc wages shall not expire before the time period for such assessment expires under paragraph 7#a74 7,b7 ,improperly claimed ,,ertc wages ,for purposes of this paragraph1 the term improperly claimed ,,ertc wages means1 with respect to an assessment attributable to a credit claimed under this section1 the wages with respect to which a deduction would not have been allowed if the portion of the credit to which such assessment relates had been properly claimed4 4 7#b7 ,application to ,,cares ,act credit ,section #bcja of the ,,cares ,act is amended by adding at the end the following new subsection3 7o7 ,extension of limitation on assessment 7#a7 ,in general ,notwithstanding section #feja of the ,internal ,revenue ,code of #aihf1 the limitation on the time period for the assessment of any amount attributable to a credit claimed under this section shall not expire before the date that is #f years after the latest of-- 7,a7 the date on which the original return which includes the calendar quarter with respect to which such credit is determined is filed1 7,b7 the date on which such return is treated as filed under section #feja7;b77#b7 of such ,code1 or 7,c7 the date on which the claim for credit or refund with respect to such credit is made4 7#b7 ,deduction for wages taken into account in determining improperly claimed credit 7,a7 ,in general ,notwithstanding section #feaa of such ,code1 in the case of an assessment attributable to a credit claimed under this section1 the limitation on the time period for credit or refund of any amount attributable to a deduction for improperly claimed ,,ertc wages shall not expire before the time period for such assessment expires under paragraph 7#a74 7,b7 ,improperly claimed ,,ertc wages ,for purposes of this paragraph1 the term improperly claimed ,,ertc wages means1 with respect to an assessment attributable to a credit claimed under this section1 the wages with respect to which a deduction would not have been allowed if the portion of the credit to which such assessment relates had been properly claimed4 4 7j7 ,effective dates 7#a7 ,in general ,except as otherwise provided in this subsection1 the provisions of this section shall apply to aid1 assistance1 and advice provided after ,march #ab1 #bjbj4 7#b7 ,due diligence requirements ,subsections 7b7 and 7c7 shall apply to aid1 assistance1 and advice provided after the date of the enactment of this ,act4 7#c7 ,limitation on credit and refund of ,,covid-related employee retention tax credits ,subsection 7h7 shall apply to credits and refunds allowed or made after ,january #ca1 #bjbd4 7#d7 ,amendments to extend limitation on assessment ,the amendments made by subsection 7i7 shall apply to assessments made after the date of the enactment of this ,act4 7k7 ,transition rule with respect to requirements to disclose information1 maintain client lists1 etc ,any return under section #faaa of the ,internal ,revenue ,code of #aihf1 or list under section #faab of such ,code1 required by reason of subsection 7d7 of this section to be filed or maintained1 respectively1 with respect to any aid1 assistance1 or advice provided by a ,,covid-,,ertc promoter with respect to a ,,covid-,,ertc document before the date of the enactment of this ,act1 shall not be required to be so filed or maintained 7with respect to such aid1 assistance or advice7 before the date which is #ij days after such date4 7l7 ,provisions not to be construed to create negative inferences 7#a7 ,no inference with respect to application of knowledge requirement to pre-enactment conduct of ,,covid-,,ertc promoters1 etc ,subsection 7b7 shall not be construed to create any inference with respect to the proper application of section #fgja7;a77#c7 of the ,internal ,revenue ,code of #aihf with respect to any aid1 assistance1 or advice provided by any ,,covid-,,ertc promoter on or before the date of the enactment of this ,act 7or with respect to any other aid1 assistance1 or advice to which such subsection does not apply74 7#b7 ,requirements to disclose information1 maintain client lists1 etc ,subsections 7d7 and 7k7 shall not be construed to create any inference with respect to whether any ,,covid-related employee retention tax credit is 7without regard to subsection 7d77 a listed transaction 7or reportable transaction7 with respect to any ,,covid-,,ertc promoter2 and1 for purposes of subsection 7j71 a return or list shall not be treated as required 7with respect to such aid1 assistance1 or advice7 by reason of subsection 7d7 if such return or list would be so required without regard to subsection 7d74 7m7 ,regulations ,the ,secretary 7as defined in subsection 7c77#e77 shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section 7and the amendments made by this section74 ,passed the ,house of ,representatives ,january #ca1 #bjbd4,kevin ,f4 ,mc,cumber1,clerk4 ,march #ba1 #bjbd,read the second time and placed on the calendar