[Congressional Bills 116th Congress]
[From the U.S. Government Publishing Office]
[H.R. 5617 Introduced in House (IH)]
<DOC>
116th CONGRESS
2d Session
H. R. 5617
To amend the Internal Revenue Code of 1986 to exclude discharges of
indebtedness on taxi medallions from gross income.
_______________________________________________________________________
IN THE HOUSE OF REPRESENTATIVES
January 15, 2020
Mr. Meeks (for himself, Ms. Velazquez, Mr. Rose of New York, Mrs.
Carolyn B. Maloney of New York, Ms. Meng, Mr. Suozzi, Mr. Engel, Ms.
Clarke of New York, Mr. Espaillat, Mr. Nadler, Mr. Serrano, Mr.
Jeffries, Mr. King of New York, Ms. Ocasio-Cortez, and Miss Rice of New
York) introduced the following bill; which was referred to the
Committee on Ways and Means
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to exclude discharges of
indebtedness on taxi medallions from gross income.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Taxi Medallion Loan Forgiveness Debt
Relief Act of 2020''.
SEC. 2. EXCLUSION OF DISCHARGES OF QUALIFIED TAXI MEDALLION
INDEBTEDNESS.
(a) In General.--Section 108(a)(1) of the Internal Revenue Code of
1986 is amended by striking ``or'' at the end of subparagraph (D), by
striking the period at the end of subparagraph (E) and inserting ``,
or'', and by inserting after subparagraph (E) the following new
subparagraph:
``(F) in the case of a taxpayer other than a C
corporation, the indebtedness discharged is qualified
taxi medallion indebtedness which is discharged before
January 1, 2023.''.
(b) Special Rules Relating to Qualified Taxi Medallion
Indebtedness.--Section 108 of such Code is amended by adding at the end
the following new subsection:
``(j) Special Rules Relating to Qualified Taxi Medallion
Indebtedness.--
``(1) Basis reduction.--The amount excluded from gross
income by reason of subsection (a)(1)(E) shall be applied to
reduce (but not below zero) the basis of the taxi medallions of
the taxpayer that secure the discharged indebtedness.
``(2) Qualified taxi medallion indebtedness.--For purposes
of this section--
``(A) In general.--The term `qualified taxi
medallion indebtedness' means indebtedness which--
``(i) is secured by a taxi medallion, and
``(ii) with respect to which such taxpayer
makes an election to have this paragraph apply.
``(B) Limitation.--With respect to a taxpayer, the
aggregate amount treated as qualified taxi medallion
indebtedness for any period shall not exceed $2,000,000
($1,000,000 in the case of a married individual filing
a separate return).
``(C) Exception for certain discharges not related
to taxpayer's financial condition.--Subsection
(a)(1)(F) shall not apply to the discharge of a loan if
the discharge is on account of services performed for
the lender or any other factor not directly related to
a decline in the value of the taxi medallion or to the
financial condition of the taxpayer.
``(D) Ordering rule.--If any loan is discharged, in
whole or in part, and only a portion of such loan is
qualified taxi medallion indebtedness, subsection
(a)(1)(F) shall apply only to so much of the amount
discharged as exceeds the amount of the loan (as
determined immediately before such discharge) which is
not qualified taxi medallion indebtedness.''.
(c) Conforming Amendments.--
(1) Section 108(a)(2) of such Code is amended by adding at
the end the following new subparagraph:
``(D) Taxi medallion exclusion takes precedence
over insolvency exclusion unless elected otherwise.--
Paragraph (1)(B) shall not apply to a discharge to
which paragraph (1)(F) applies unless the taxpayer
elects to apply paragraph (1)(B) in lieu of paragraph
(1)(F).''.
(d) Effective Date.--The amendments made by this section shall
apply to discharges of indebtedness after December 31, 2016.
<all>