[Congressional Bills 118th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4055 Introduced in House (IH)]
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118th CONGRESS
1st Session
H. R. 4055
To amend the Internal Revenue Code of 1986 to exclude interest on loans
by depository institutions to qualified opportunity zone businesses
from gross income, and for other purposes.
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IN THE HOUSE OF REPRESENTATIVES
June 13, 2023
Mr. Barr introduced the following bill; which was referred to the
Committee on Ways and Means
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A BILL
To amend the Internal Revenue Code of 1986 to exclude interest on loans
by depository institutions to qualified opportunity zone businesses
from gross income, and for other purposes.
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 ``Opportunity Zones Enhancement Act of
2023''.
SEC. 2. EXCLUSION FOR INTEREST ON LOANS TO QUALIFIED OPPORTUNITY ZONE
BUSINESSES.
(a) In General.--Part III of subchapter B of chapter 1 of the
Internal Revenue Code of 1986 is amended by inserting after section
139I the following new section:
``SEC. 139J. INTEREST ON LOANS TO QUALIFIED OPPORTUNITY ZONE
BUSINESSES.
``(a) Exclusion.--Gross income shall not include an amount equal to
so much of the interest received by a depository institution on any
loan to a qualified borrower as does not exceed the lesser of--
``(1) the taxpayer's retained earnings attributable to the
taxable year, or
``(2) $5,000,000.
``(b) Depository Institution.--For purposes of this section, the
term `depository institution' has the meaning given such term in
section 3 of the Federal Deposit Insurance Act.
``(c) Qualified Borrower.--For purposes of this section, the term
`qualified borrower' means a borrower that at the time of origination
of the loan is a qualified opportunity zone business (as defined in
section 1400Z-2(d)).
``(d) Retained Earnings.--For purposes of this section, the term
`retained earnings' means the excess of the taxpayer's earnings and
profits (within the meaning of section 316(a)(2)) for the taxable year
over the dividends paid by the taxpayer during such taxable year.
``(e) Inflation Adjustment.--
``(1) In general.--In the case of any taxable year
beginning after 2023, the dollar amounts in subsections (a)(2)
and (e) 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
`calendar year 2022' for `calendar year 2016' in
subparagraph (A)(ii).
``(2) Rounding.--Any amount under paragraph (1) shall be
rounded to the nearest multiple of $1,000,000.
``(f) Controlled Group.--
``(1) In general.--In the case of a depository institution
which is a member of a controlled group which includes one or
more other depository institutions, such institutions shall for
purposes of applying the dollar amounts in subsections (a) and
(b) be treated as one depository institution.
``(2) Definition.--For purposes of this subsection, the
term `controlled group' means any group treated as a single
employer under subsection (b), (c), (m), or (o) of section 414.
``(g) Regulations.--The Secretary shall prescribe such regulations
as may be necessary or appropriate to carry out the purposes of this
section.
``(h) Coordination With Section 265.--Loans from a depository
institution to a qualified borrower shall be treated as obligations
described in section 265(a)(2) the interest on which is wholly exempt
from the taxes imposed by this subtitle.''.
(b) Clerical Amendment.--The table of sections for such part III is
amended by inserting after the item relating to section 139I the
following new item:
``Sec. 139J. Interest on loans to qualified opportunity zone
businesses.''.
(c) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after the date of the enactment of
this Act.
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