,i  #aaith ,,congress  #ast ,session    
,h4 ,r4 #cbga  ,,in ,,the ,,house ,,of  
,,representatives  ,may #h1 #bjbe,mr4   
,boyle of ,pennsylvania 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 increase funding for 
,social ,security and ,medicare4  #a4   
,short title ,this ,act may be cited as 
the ,medicare and ,social ,security     
,fair ,share ,act4  #b4 ,modification of
 payroll taxes  7a7 ,wage base for taxes
 funding social security  7#a7 ,in      
general ,paragraph 7#a7 of section      
#caba7;a7 of the ,internal ,revenue     
,code of #aihf is amended to read as    
follows3  7#a7 in the case of taxes     
imposed by sections #caja7;a7 and       
#caaa7;a71 for any calendar year in     
which the contribution and benefit base 
7as determined under section #bcj of the
 ,social ,security ,act7 is less than   
#djj1jjj1 so much of the remuneration   
7other than remuneration referred to in 

the succeeding paragraphs of this       
subsection7 with respect to employment  
that has been paid to an individual by  
an employer during the calendar year as 
exceeds such contribution and benefit   
base but does not exceed #djj1jjj2  4   
7#b7 ,conforming amendments  7,a7       
,successor employers ,section #caba of  
the ,internal ,revenue ,code of #aihf is
 amended by adding at the end the       
following new subsection3  7aa7 ,special
 rules for successor employers ,for     
purposes of subsection 7a77#a71 if an   
employer 7hereinafter referred to as    
successor employer7 during any calendar 
year acquires substantially all the     
property used in a trade or business of 
another employer 7hereinafter referred  
to as a predecessor71 or used in a      
separate unit of a trade or business of 
a predecessor1 and immediately after the
 acquisition employs in his trade or    
business an individual who immediately  
prior to the acquisition was employed in
 the trade or business of such          

predecessor1 then1 for the purpose of   
determining the amount of remuneration  
paid by the successor employer under    
such subsection1 any remuneration 7other
 than remuneration referred to in the   
paragraphs succeeding paragraph 7#a7 of 
subsection 7a77 with respect to         
employment paid 7or considered under    
this subsection as having been paid7 to 
such individual by such predecessor     
during such calendar year and prior to  
such acquisition shall be considered as 
having been paid by such successor      
employer4  4  7,b7 ,application to      
railroad retirement taxes ,clause 7i7 of
 section #cbca7;e77#b77;,a7 of such     
,code is amended to read as follows3    
7i7 ,in general ,for any calendar year  
in which the applicable base is less    
than #djj1jjj1 the term compensation    
does not include so much of the         
remuneration paid during any calendar   
year to an individual by an employer for
 services rendered as an employee to    
such employer as exceeds the applicable 

base but does not exceed #djj1jjj4  4   
7b7 ,further additional hospital        
insurance tax on very high income       
taxpayers  7#a7 ,in general ,section    
#caja7;b7 of the ,internal ,revenue     
,code of #aihf is amended by adding at  
the end the following new paragraph3    
7#c7 ,further additional tax ,in        
addition to the tax imposed by          
paragraphs 7#a7 and 7#b7 and the        
preceding subsection1 there is hereby   
imposed on every taxpayer 7other than a 
corporation1 estate1 or trust7 a tax    
equal to #a4b percent of wages which are
 received with respect to employment 7as
 defined in section #caba7;b77 during   
the taxable year which are in excess    
of-- 7,a7 in the case of a joint return1
 #ejj1jjj1  7,b7 in the case of a       
married taxpayer 7as defined in section 
#ggjc7 filing a separate return1  of the
 dollar amount determined under         
subparagraph 7,a71 and  7,c7 in any     
other case1 #djj1jjj4  4  7#b7          
,collection of tax ,section #cajb of    

such ,code is amended by adding at the  
end the following new subsection3  7g7  
,special rules for further additional   
tax  7#a7 ,in general ,in the case of   
any tax imposed by section              
#caja7;b77#c71 subsection 7a7 shall only
 apply to the extent to which the       
taxpayer receives wages from the        
employer in excess of #djj1jjj1 and the 
employer may disregard the amount of    
wages received by such taxpayer's       
spouse4  7#b7 ,collection of amounts not
 withheld ,to the extent that the amount
 of any tax imposed by section          
#caja7;b77#c7 is not collected by the   
employer1 such tax shall be paid by the 
employee4  7#c7 ,tax paid by recipient  
,if an employer1 in violation of this   
chapter1 fails to deduct and withhold   
the tax imposed by section #caja7;b77#c7
 and thereafter the tax is paid by the  
employee1 the tax so required to be     
deducted and withheld shall not be      
collected from the employer1 but this   
paragraph shall in no case relieve the  

employer from liability for any         
penalties or additions to tax otherwise 
applicable in respect of such failure to
 deduct and withhold4  4  7c7 ,effective
 date ,the amendments made by this      
section shall apply to remuneration     
paid1 and taxable years beginning1 on or
 after ,january #a of the first calendar
 year that begins after the date of     
enactment of this ,act4  #c4            
,modification of taxes on               
self-employment income  7a7 ,tax on net 
earnings from self-,employment up to    
contribution and benefit base and more  
than #djj1jjj ,paragraph 7#a7 of section
 #adjb7;b7 of the ,internal ,revenue    
,code of #aihf is amended to read as    
follows3  7#a7 in the case of the tax   
imposed by section #adja7;a7 for any    
taxable year beginning in a calendar    
year in which the contribution and      
benefit base 7as determined under       
section #bcj of the ,social ,security   
,act7 is less than #djj1jjj1 the excess 
7if any7 of-- 7,a7 so much of the net   

earnings from self-employment which is  
in excess of--  7i7 an amount equal to  
the contribution and benefit base 7as   
determined under section #bcj of the    
,social ,security ,act7 which is        
effective for the calendar year in which
 such taxable year begins1 reduced 7but 
not below zero7 by  7ii7 the amount of  
the wages paid to such individual during
 such taxable year1 over  7,b7 the sum  
of-- 7i7 the excess 7if any7 of--  7,i7 
the net earnings from self-employment   
reduced by the excess 7if any7 of       
subparagraph 7,a77i7 over subparagraph  
7,a77ii71 over  7,,ii7 #djj1jjj1 reduced
 by such contribution and benefit base1 
plus  7ii7 the amount of the wages paid 
to such individual during such taxable  
year in excess of such contribution and 
benefit base and not in excess of       
#djj1jjj2 or  4  7b7 ,further additional
 hospital insurance tax on very high    
income taxpayers  7#a7 ,in general      
,section #adja7;b7 of the ,internal     
,revenue ,code of #aihf is amended by   

adding at the end the following new     
paragraph3  7#c7 ,further additional tax
  7,a7 ,in general ,in addition to the  
tax imposed by paragraphs 7#a7 and 7#b7 
and the preceding subsection1 there is  
hereby imposed on every taxpayer 7other 
than a corporation1 estate1 or trust7   
for each taxable year a tax equal to    
#a4b percent of the self-employment     
income for such taxable year which is in
 excess of-- 7i7 in the case of a joint 
return1 #ejj1jjj1  7ii7 in the case of a
 married taxpayer 7as defined in section
 #ggjc7 filing a separate return1  of   
the dollar amount determined under      
subparagraph 7,a71 and  7iii7 in any    
other case1 #djj1jjj4  7,b7             
,coordination with ,,fica ,the amounts  
under clause 7i71 7ii71 or 7iii7        
7whichever is applicable7 of            
subparagraph 7,a7 shall be reduced 7but 
not below zero7 by the amount of wages  
taken into account in determining the   
tax imposed under section #caja7;b77#c7 
with respect to the taxpayer4  4  7#b7  

,no deduction for further additional tax
  7,a7 ,in general ,section #afd7;f7 of 
such ,code is amended by striking       
section #adja7;b77#b7 and inserting     
paragraphs 7#b7 and 7#c7 of section     
#adja7;b74  7,b7 ,deduction for net     
earnings from self-employment ,section  
#adjb7;a77#ab77;,b7 of such ,code is    
amended by striking the rate imposed    
under paragraph 7#b7 of section         
#adja7;b7 and inserting the rates       
imposed under paragraphs 7#b7 and 7#c7  
of section #adja7;b74  7#c7 ,technical  
amendment ,section #adja7;b77#b77;,b7 of
 such ,code is amended by striking      
section #caba7;b77#b7 and inserting     
section #caja7;b77#b74  7c7 ,effective  
date ,the amendments made by this       
section shall apply to net earnings from
 self-employment derived1 and taxable   
years beginning1 on or after ,january #a
 of the first calendar year that begins 
after the date of enactment of this     
,act4  #d4 ,taxes on unearned income    
7a7 ,modifications to tax on net        

investment income  7#a7 ,in general     
,section #adaa of the ,internal ,revenue
 ,code of #aihf is amended by adding at 
the end the following new subsection3   
7f7 ,additional amount for certain high 
income individuals  7#a7 ,inclusion of  
specified net income  7,a7 ,in general  
,in the case of any individual whose    
modified adjusted gross income for the  
taxable year exceeds the high income    
threshold amount1 subsection 7a77#a7    
shall be applied by substituting the    
greater of specified net income or net  
investment income for net investment    
income in subparagraph 7,a7 thereof4    
7,b7 ,phase-in of increase ,the increase
 in the tax imposed under subsection    
7a77#a7 by reason of the application of 
subparagraph 7,a7 7determined before    
application of paragraph 7#b77 shall not
 exceed the amount which bears the same 
ratio to the amount of such increase    
7determined without regard to this      
paragraph7 as--  7i7 the excess         
described in subparagraph 7,a71 bears to

  7ii7 #ajj1jjj 7#a_/b such amount in   
the case of a married taxpayer 7as      
defined in section #ggjc7 filing a      
separate return74  7#b7 ,additional rate
 bracket ,in the case of any individual 
whose modified adjusted gross income for
 the taxable year exceeds the high      
income threshold amount1 the amount of  
tax imposed under subsection 7a77#a7    
shall be increased by an amount equal to
 #ac4f percent of the lesser of-- 7,a7  
the greater of the specified net income 
or net investment income for the taxable
 year1 or  7,b7 the excess 7if any7 of--
 7i7 the modified adjusted gross income 
for such taxable year1 over  7ii7 the   
high income threshold amount4  7#c7     
,definitions  7,a7 ,high income         
threshold amount ,for purposes of this  
subsection1 the term high income        
threshold amount means--  7i7 except as 
provided in clause 7ii7 or 7iii71       
#djj1jjj1  7ii7 in the case of a        
taxpayer making a joint return under    
section #fjac or a surviving spouse 7as 

defined in section #b7;a771 #ejj1jjj1   
and  7iii7 in the case of a married     
taxpayer 7as defined in section #ggjc7  
filing a separate return1 #a_/b of the  
dollar amount determined under clause   
7ii74  7,b7 ,specified net income ,for  
purposes of this section1 the term      
specified net income means net          
investment income determined--  7i7     
without regard to the phrase other than 
such income which is derived in the     
ordinary course of a trade or business  
not described in paragraph 7#b71 in     
subsection 7c77#a77;,a77i71  7ii7       
without regard to the phrase described  
in paragraph 7#b7 in subsection         
7c77#a77;,a77ii71  7iii7 without regard 
to the phrase other than property held  
in a trade or business not described in 
paragraph 7#b7 in subsection            
7c77#a77;,a77iii71  7iv7 without regard 
to paragraphs 7#b71 7#c71 and 7#d7 of   
subsection 7c71 and  7v7 by treating    
paragraphs 7#e7 and 7#f7 of section     
#dfi7;c7 7determined without regard to  

the phrase ,to the extent provided in   
regulations1 in such paragraph 7#f77 as 
applying for purposes of subsection 7c7 
of this section4  4  7b7 ,application to
 trusts and estates ,section            
#adaa7;a77#b7 of the ,internal ,revenue 
,code of #aihf is amended--  7#a7 by    
striking #c4h percent and inserting     
#ag4d percent1 and  7#b7 in subparagraph
 7,a7 thereof1 by striking undistributed
 net investment income and inserting the
 greater of undistributed specified net 
income or undistributed net investment  
income4  7c7 ,clarifications with       
respect to determination of net         
investment income  7#a7 ,certain        
exceptions ,section #adaa7;c77#f7 of the
 ,internal ,revenue ,code of #aihf is   
amended to read as follows3  7#f7       
,special rules ,net investment income   
shall not include--  7,a7 any item taken
 into account in determining            
self-employment income for such taxable 
year on which a tax is imposed by       
section #adja7;b71  7,b7 wages received 

with respect to employment on which a   
tax is imposed under section #caja7;b7  
7determined without regard to section   
#caja7;c77 or #cbja7;a7 7including      
amounts taken into account under section
 #caba7v77#b771 and  7,c7 wages received
 from the performance of services earned
 outside the ,united ,states for a      
foreign employer4  4  7#b7 ,net         
operating losses not taken into account 
,section #adaa7;c77#a77;,b7 of such     
,code is amended by inserting 7other    
than section #agb7 after this subtitle4 
7#c7 ,inclusion of certain foreign      
income  7,a7 ,in general ,section       
#adaa7;c77#a77;,a7 of such ,code is     
amended by striking and at the end of   
clause 7ii71 by striking over at the end
 of clause 7iii7 and inserting and1 and 
by adding at the end the following new  
clause3  7iv7 any amount includible in  
gross income under section #iea1        
#iea;,a1 #abic1 or #abif1 over  4  7,b7 
,proper treatment of certain previously 
taxed earnings and profits ,section     

#adaa7;c7 of such ,code is amended by   
adding at the end the following new     
paragraph3  7#g7 ,certain earnings and  
profits of foreign corporations  7,a7   
,in general ,except as otherwise        
provided by the ,secretary1 a           
distribution of earnings and profits    
that is not treated as a dividend for   
purposes of chapter #a by reason of     
section #iei7;d7 or section #abic7;c7   
shall not be treated as a dividend for  
purposes of this section4  7,b7         
,regulations and other guidance ,the    
,secretary shall issue regulations or   
other guidance providing for the        
treatment of distributions by a foreign 
corporation after ,december #ca1 #bjbe1 
of earnings and profits of such foreign 
corporation which accrued before such   
date1 but which have not been previously
 subject to tax under this section4  4  
7d7 ,transfers of revenues to ,old-,age 
and ,survivors1 ,disability ,insurance1 
and ,federal ,hospital ,insurance ,trust
 ,funds  7#a7 ,federal ,old-,age and    

,survivors ,trust ,fund  7,a7 ,in       
general ,section #bja7;a7 of the ,social
 ,security ,act 7#db ,u4,s4,c4 #dja7;a77
 is amended--  7i7 by striking #ajj per 
centum of1  7ii7 by inserting #ajj      
percent of before the taxes each place  
it appears in paragraphs 7#a71 7#b71    
7#c71 and 7#d71 and  7iii7 by striking  
and at the end of paragraph 7#c71 by    
striking the period at the end of       
paragraph 7#d7 and inserting 2 and1 and 
by inserting after paragraph 7#d7 the   
following new paragraph3  7#e7 #ga4c    
percent of the taxes imposed by section 
#adaa of the ,internal ,revenue ,code of
 #aihf for any taxable year beginning   
after ,december #ca1 #bjbe1 as          
determined by the ,secretary of the     
,treasury or the ,secretary's delegate  
based on tax returns under subtitle ,f  
of such ,code1 less the amounts         
specified in paragraph 7#c7 of          
subsection 7b74  4  7,b7 ,conforming    
amendment ,the fourth sentence of       
section #bja7;a7 of such ,act 7#db      

,u4,s4,c4 #dja7;a77 is amended by       
striking clauses 7#c7 and 7#d7 each     
place it appears and inserting          
paragraphs 7#c71 7#d71 and 7#e74  7#b7  
,federal ,disability ,insurance ,trust  
,fund ,section #bja7;b7 of the ,social  
,security ,act 7#db ,u4,s4,c4 #dja7;b77 
is amended--  7,a7 by striking #ajj per 
centum of1 and  7,b7 by striking and at 
the end of paragraph 7#a71 by striking  
the period at the end of paragraph 7#b7 
and inserting 2 and1 and by inserting   
after paragraph 7#b7 the following new  
paragraph3  7#c7 #aj4c percent of the   
taxes imposed by section #adaa of the   
,internal ,revenue ,code of #aihf for   
any taxable year beginning after        
,december #ca1 #bjbe1 as determined by  
the ,secretary of the ,treasury or the  
,secretary's delegate based on tax      
returns under subtitle ,f of such ,code4
  4  7#c7 ,federal ,hospital ,insurance 
,trust ,fund ,section #ahag7;a7 of the  
,social ,security ,act 7#db ,u4,s4,c4   
#acie;i7a77 is amended--  7,a7 by       

striking #ajj per centum of1  7,b7 by   
inserting #ajj percent of before the    
taxes each place it appears in          
paragraphs 7#a7 and 7#b71 and  7,c7 by  
striking and at the end of paragraph    
7#a71 by striking the period at the end 
of paragraph 7#b7 and inserting 2 and1  
and by inserting after paragraph 7#b7   
the following new paragraph3  7#c7 #bh4g
 percent of the taxes imposed by section
 #adaa of the ,internal ,revenue ,code  
of #aihf for any taxable year beginning 
after ,december #ca1 #bjbe1 as          
determined by the ,secretary of the     
,treasury or the ,secretary's delegate  
based on tax returns under subtitle ,f  
of such ,code4  4  7e7 ,effective date  
,the amendments made by this section    
shall apply to taxable years beginning  
after ,december #ca1 #bjbe4