[Pages S7757-S7758]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 1854. Mr. BROWN (for himself, Mr. Bennet, Mr. Durbin, Mr. Casey, 
Mr. Wyden, Mrs. Murray, and Mr. Menendez) submitted an amendment 
intended to be proposed by him to the bill H.R. 1, to provide for 
reconciliation pursuant to titles II and V of the concurrent resolution 
on the budget for fiscal year 2018; which was ordered to lie on the 
table; as follows:

       Strike section 11022 and insert the following:

     SEC. 11022. INCREASE IN AND MODIFICATION OF CHILD TAX CREDIT.

       (a) In General.--Section 24 is amended--
       (1) by striking subsections (a) and (b) and inserting the 
     following:
       ``(a) Allowance of Credit.--There shall be allowed as a 
     credit against the tax imposed by this chapter for the 
     taxable year an amount equal to the sum of--
       ``(1) with respect to each qualifying child of the taxpayer 
     who has attained 6 years of age before the close of such 
     taxable year and for which the taxpayer is allowed a 
     deduction under section 151, an amount equal to $2,000, and
       ``(2) with respect to each qualifying child of the taxpayer 
     who has not attained 6 years of age before the close of such 
     taxable year and for which the taxpayer is allowed a 
     deduction under section 151, an amount equal to $2,500.
       ``(b) Limitation.--
       ``(1) In general.--The amount of the credit allowable under 
     subsection (a) (including any increase pursuant to subsection 
     (h)) shall be reduced (but not below zero) by an amount equal 
     to 5 percent of the taxpayer's adjusted gross income which is 
     in excess of the threshold amount.
       ``(2) Threshold amount.--
       ``(A) In general.--For purposes of paragraph (1), the term 
     `threshold amount' means--
       ``(i) $250,000 in the case of a joint return,
       ``(ii) $200,000 in the case of an individual who is not 
     married, and
       ``(iii) $125,000 in the case of a married individual filing 
     a separate return.
       ``(B) Marital status.--For purposes of this paragraph, 
     marital status shall be determined under section 7703.'',
       (2) in subsection (d)(1)--
       (A) in subparagraph (A), by inserting ``, subsection (h),'' 
     after ``this subsection'', and
       (B) in subparagraph (B)(i)--
       (i) by striking ``15 percent'' and inserting ``45 
     percent'', and
       (ii) by striking ``as exceeds $3,000'', and
       (3) by adding at the end the following new subsections:
       ``(h) Additional Credit for Certain Other Dependents.--
       ``(1) In general.--In the case of a taxable year beginning 
     after December 31, 2017, and before January 1, 2026, the 
     credit determined under subsection (a) shall be increased by 
     $500 for each dependent of the taxpayer (as defined in 
     section 152) other than a qualifying child described in 
     subsection (c).
       ``(2) Exception for certain non-citizens.--Paragraph (1) 
     shall not apply with respect to any individual who would not 
     be a dependent if subparagraph (A) of section 152(b)(3) were 
     applied without regard to all that follows `resident of the 
     United States'.
       ``(i) Definition of Qualifying Child.--In the case of a 
     taxable year beginning before January 1, 2025, paragraph (1) 
     of subsection (c) shall be applied by substituting `18' for 
     `17'.
       ``(j) Inflation Adjustment.--
       ``(1) In general.--In the case of any taxable year 
     beginning after 2018, each of the dollar amounts in 
     subsection (a) shall be increased by an amount equal to--
       ``(A) such dollar amount, multiplied by
       ``(B) the cost-of-living adjustment determined under 
     section 1(f)(3) for the calendar year in which the taxable 
     year begins, determined by substituting `2017' for `2016' in 
     subparagraph (A)(ii) thereof.
       ``(2) Rounding.--If any increase determined under paragraph 
     (1) is not a multiple of $100, such increase shall be rounded 
     to the next lowest multiple of $100.''.
       (b) Effective Date.--The amendments made by subsection (a) 
     shall apply to taxable years beginning after December 31, 
     2017.

[[Page S7758]]

       (c) Offsets.--
       (1) Adjustment and termination of corporate rate.--Section 
     11, as amended by section 13001 of this Act, is amended--
       (A) in subsection (b), by striking ``20 percent'' and 
     inserting ``25 percent''
       (B) by adding at the end the following:
       ``(e) Termination of 25 Percent Rate.--In the case of any 
     taxable year beginning after December 31, 2027--
       ``(1) the tax computed under subsection (a) shall be 
     computed in the same manner as such tax was computed under 
     subsection (b) (as in effect on the day before the date of 
     the enactment of the Tax Cuts and Jobs Act), and
       ``(2) this title shall be applied and administered as if 
     the amendments made by section 13002 of such Act had not been 
     enacted.''.
       (2) Adjustment of highest rate bracket.--
       (A) Joint returns.--The last row of the table contained in 
     section 1(j)(2)(A), as added by section 11001(a), is amended 
     to read as follows:

``Over $1,000,000.........................  $301,479, plus 39.6% of the
                                             excess over $1,000,000.''.

       (B) Heads of households.--The last row of the table 
     contained in section 1(j)(2)(B), as added by section 
     11001(a), is amended to read as follows:

``Over $500,000...........................  $149,348, plus 39.6% of the
                                             excess over $500,000.''.

       (C) Unmarried individuals.--The last row of the table 
     contained in section 1(j)(2)(C), as added by section 
     11001(a), is amended to read as follows:

``Over $500,000...........................  $150,739.50, plus 39.6% of
                                             the excess over
                                             $500,000.''.

       (D) Married individuals filing separate returns.--The last 
     row of the table contained in section 1(j)(2)(D), as added by 
     section 11001(a), is amended to read as follows:

``Over $500,000...........................  $150,739.50, plus 39.6% of
                                             the excess over
                                             $500,000.''.

       (E) Effective date.--The amendments made by this paragraph 
     shall apply to taxable years beginning after December 31, 
     2017.
       (3) Global intangible low-taxed income on a country-by-
     country basis.--
       (A) In general.--Section 951(a), as added by section 14201 
     of this Act, is amended by adding at the end the following:
       ``(g) Determination of Global Intangible Low-taxed Income 
     on a Country-by-country Rather Than Aggregate Basis.--
       ``(1) In general.--Notwithstanding any other provision of 
     this section, the global intangible low-taxed income of any 
     United States shareholder for any taxable year shall be 
     determined separately with respect to each foreign country by 
     taking into account such shareholder's pro rata share of net 
     CFC tested income and net deemed tangible income return which 
     is properly allocable to such foreign country.
       ``(2) Application.--The Secretary shall take such actions 
     as are necessary to provide for the application of this 
     section, and any provision of this title to which this 
     section relates, on a country-by-country rather than an 
     aggregate basis.''.
       (B) Effective date.--The amendment made by this subsection 
     shall take effect as if included in the amendments made by 
     section 14201 of this Act.
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