Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,
.
(a) .—
This Act may be cited as the ``Tax Increase Prevention and Reconciliation Act of 2005´´.
(b) .—
Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986.
(c) .—
The table of contents for this Act is as follows:
Sec. 1. Short Title, Etc.
TITLE I—EXTENSION AND MODIFICATION OF CERTAIN PROVISIONS
Sec. 101. Increased expensing for small business. Sec. 102. Capital gains and dividends rates. Sec. 103. Controlled foreign corporations.
TITLE II—OTHER PROVISIONS
Sec. 201. Clarification of taxation of certain settlement funds. Sec. 202. Modification of active business definition under section 355. Sec. 203. Veterans' mortgage bonds. Sec. 204. Capital gains treatment for certain self-created musical works. Sec. 205. Vessel tonnage limit. Sec. 206. Modification of special arbitrage rule for certain funds. Sec. 207. Amortization of expenses incurred in creating or acquiring music or music copyrights. Sec. 208. Modification of effective date of disregard of certain capital expenditures for purposes of qualified small issue bonds. Sec. 209. Modification of treatment of loans to qualified continuing care facilities.
TITLE III—ALTERNATIVE MINIMUM TAX RELIEF
Sec. 301. Increase in alternative minimum tax exemption amount for 2006. Sec. 302. Allowance of nonrefundable personal credits against regular and alternative minimum tax liability.
TITLE IV—CORPORATE ESTIMATED TAX PROVISIONS
Sec. 401. Time for payment of corporate estimated taxes.
TITLE V—REVENUE OFFSET PROVISIONS
Sec. 501. Application of earnings stripping rules to partners which are corporations. Sec. 502. Reporting of interest on tax-exempt bonds. Sec. 503. 5-year amortization of geological and geophysical expenditures for certain major integrated oil companies. Sec. 504. Application of FIRPTA to regulated investment companies. Sec. 505. Treatment of distributions attributable to FIRPTA gains. Sec. 506. Prevention of avoidance of tax on investments of foreign persons in United States real property through wash sale transactions. Sec. 507. Section 355 not to apply to distributions involving disqualified investment companies. Sec. 508. Loan and redemption requirements on pooled financing requirements. Sec. 509. Partial payments required with submission of offers-in-compromise. Sec. 510. Increase in age of minor children whose unearned income is taxed as if parent's income. Sec. 511. Imposition of withholding on certain payments made by government entities. Sec. 512. Conversions to Roth IRAs. Sec. 513. Repeal of FSC/ETI binding contract relief. Sec. 514. Only wages attributable to domestic production taken into account in determining deduction for domestic production. Sec. 515. Modification of exclusion for citizens living abroad. Sec. 516. Tax involvement of accommodation parties in tax shelter transactions.
TITLE I—EXTENSION AND MODIFICATION OF CERTAIN PROVISIONS
SEC. 101. INCREASED EXPENSING FOR SMALL BUSINESS.
Subsections (b)(1), (b)(2), (b)(5), (c)(2), and (d)(1)(A)(ii) of section 179 (relating to election to expense certain depreciable business assets) are each amended by striking ``2008'' and inserting ``2010''.
SEC. 102. CAPITAL GAINS AND DIVIDENDS RATES.
Section 303 of the Jobs and Growth Tax Relief Reconciliation Act of 2003 is amended by striking ``December 31, 2008'' and inserting ``December 31, 2010''.
SEC. 103. CONTROLLED FOREIGN CORPORATIONS.
(a) Subpart F Exception for Active Financing.—
(1) Exempt insurance income.—
Paragraph (10) of section 953(e) (relating to application) is amended—
(A) by striking ``January 1, 2007'' and inserting ``January 1, 2009'', and
(B) by striking ``December 31, 2006'' and inserting ``December 31, 2008''. (2) Exception to treatment as foreign personal holding company income.— Paragraph (9) of section 954(h) (relating to application) is amended by striking ``January 1, 2007'' and inserting ``January 1, 2009''.