H.R.4351 - AMT Relief Act of 2007
To amend the Internal Revenue Code of 1986 to provide individuals temporary relief from the alternative minimum tax, and for other purposes. view all titles (3)
All Bill Titles
- Short: AMT Relief Act of 2007 as passed house.
- Short: AMT Relief Act of 2007 as introduced.
- Official: To amend the Internal Revenue Code of 1986 to provide individuals temporary relief from the alternative minimum tax, and for other purposes. as introduced.
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Official Summary12/12/2007--Passed House without amendment. (This measure has not been amended since it was introduced. The summary has been expanded because action occurred on the measure.)AMT Relief Act of 2007 - Title I: Individual Tax Relief - (Sec. 101) Amends the Internal Revenue Code to extend thro
Official Summary12/12/2007--Passed House without amendment. (This measure has not been amended since it was introduced. The summary has been expanded because action occurred on the measure.)
AMT Relief Act of 2007 - Title I: Individual Tax Relief -
(Sec. 101)Amends the Internal Revenue Code to extend through 2007 for individual taxpayers:
(1) the offset of nonrefundable personal tax credits against regular and alternative minimum tax (AMT) liability; and
(2) the increased AMT exemption amounts.
(Sec. 103)Increases the AMT refundable credit amount for individual taxpayers with long-term unused tax credits in prior taxable years. Abates any underpayment of tax and related interest and penalties attributable to the application of special AMT rules for the treatment of incentive stock options.
(Sec. 104)Lowers in 2008 (from $10,000 to $8,500) the earned income threshold amount for determining the refundable portion of the child tax credit.
Title II: Revenue Provisions - Subtitle A: Nonqualified Deferred Compensation From Certain Tax Indifferent Parties -
(Sec. 201)Requires the inclusion in gross income for income tax purposes of employee compensation deferred under a nonqualified deferred compensation plan of a nonqualified entity when there is no substantial risk of forfeiture of the rights to such compensation. Defines "nonqualified entity" as any foreign corporation unless substantially all of its income is:
(1) effectively connected with a trade or business in the United States; or
(2) subject to a comprehensive foreign income tax. Includes certain partnerships within such definition.
Subtitle B: Codification of Economic Substance Doctrine -
(Sec. 211)Sets forth rules and definitions for the application of the economic substance doctrine to transactions affecting tax liability. Deems a transaction as having economic substance only if:
(1) the transaction changes in a meaningful way (apart from federal income tax effects) the taxpayer's economic position; and
(2) the taxpayer has a substantial purpose for entering into such transaction. Requires the Secretary of the Treasury to prescribe regulations on economic substance.
(Sec. 212)Imposes a penalty of 40% of any underpayment of tax attributable to nondisclosed noneconomic substance transactions. Sets forth a special rule for reductions of underpayment amounts subject to a tax penalty for corporations with gross receipts of more than $100 million.
Subtitle C: Other Provisions -
(Sec. 221)Delays until 2018 the application of special rules for the worldwide allocation of interest for purposes of computing the limitation on the foreign tax credit.
(Sec. 222)Increases the penalty for failure to file a partnership tax return and extends from five to 12 the number of months in which such penalty may be imposed.
(Sec. 223)Imposes an additional penalty on S corporations for failure to file required tax returns.
(Sec. 224)Increases the minimum penalty for failure to file an individual income tax return.
(Sec. 225)Amends the Tax Increase Prevention and Reconciliation Act of 2005 to increase the estimated tax payment due in the third quarter of 2012 for corporations with assets of at least $1 billion.
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