Ways and Means Chairman Offers More Amendments to Tax Cuts and Jobs Act

Chairman Brady added more proposed amendments to the Tax Cuts and Jobs Act that were released on Thursday.

Chairman’s Second Amendment Summary

  • Removed self-employment tax revisions (which includes S corporations)
  • Restores adoption credit
  • Require SSN for child in order to claim entire amount of the enhanced child credit
  • Can rollover from 529 to ABLE account
  • Floor plan financing interest fully deductible but no full expensing for such businesses
  • S corporation gets special 6 year rule if terminates status due to Act for
    • Accounting method changes
    • Also gets special rule for distributions to be pro-rata from E&P and AAA
  • Requirement to capitalize research and development are required to be capitalized and amortized over 5 years (15 years for foreign)
  • Immediate deduction for expenses of attorney in contingent fee litigation
  • Remove changes to deferred compensation
  • 83(b) election cannot be made on restricted stock units (RSU)
  • Raised rate on repatriated assets to
  • 7% on earnings held in illiquid investments
  • 14% on other earnings and profits