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   116th Congress }                                  {   Report
                        HOUSE OF REPRESENTATIVES 
   1st Session    }                                  {  116-161
                                                       
_______________________________________________________________________

                                     


             PROMOTING RESPECT FOR INDIVIDUALS' DIGNITY AND
                          EQUALITY ACT OF 2019

                               ----------                              

                              R E P O R T

                                 OF THE

                      COMMITTEE ON WAYS AND MEANS
                        HOUSE OF REPRESENTATIVES

                                   on

                               H.R. 3299

      [Including cost estimate of the Congressional Budget Office]

                             together with

                             MINORITY VIEWS
                             

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]



                 July 18, 2019.--Ordered to be printed
                 
                 
                 
                 



             PROMOTING RESPECT FOR INDIVIDUALS' DIGNITY AND

                          EQUALITY ACT OF 2019
                          
                          
                          
                          
                          
                          
116th Congress   }                                          {     Report
                         HOUSE OF REPRESENTATIVES                 
1st Session      }                                          {    116-161
_______________________________________________________________________

                                     


             PROMOTING RESPECT FOR INDIVIDUALS' DIGNITY AND

                          EQUALITY ACT OF 2019

                               __________

                              R E P O R T

                                 OF THE

                      COMMITTEE ON WAYS AND MEANS

                        HOUSE OF REPRESENTATIVES

                                   on

                               H.R. 3299

      [Including cost estimate of the Congressional Budget Office]

                             together with

                             MINORITY VIEWS
                             
                             

[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]



                 July 18, 2019.--Ordered to be printed
                 
                            ________
                 
                 U.S. GOVERNMENT PUBLISHING OFFICE
                   
37-115                 WASHINGTON : 2019    
 
 
 
                 
                 
                            C O N T E N T S

                                                                   Page
I. SUMMARY AND BACKGROUND........................................     7
    A. Purpose and Summary.......................................     7
    B. Background and Need for Legislation.......................     8
    C. Legislative History.......................................     8
II. EXPLANATION OF THE BILL......................................     9
    A. Extension of period of limitation for certain legally 
      married couples (sec. 2 of the bill and sec. 6511 of the 
      Code)......................................................     9
    B. Rules relating to all legally married couples, and rules 
      relating to the gender of spouses, etc. (secs. 3 and 4 of 
      the bill)..................................................    11
III. VOTES OF THE COMMITTEE......................................    12
IV. BUDGET EFFECTS OF THE BILL...................................    12
    A. Committee Estimate of Budgetary Effects...................    12
    B. Statement Regarding New Budget Authority and Tax 
      Expenditures Budget Authority..............................    14
    C. Cost Estimate Prepared by the Congressional Budget Office.    14
V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE....    15
    A. Committee Oversight Findings and Recommendations..........    15
    B. Statement of General Performance Goals and Objectives.....    16
    C. Information Relating to Unfunded Mandates.................    16
    D. Applicability of House Rule XXI, Clause 5(b)..............    16
    E. Tax Complexity Analysis...................................    16
    F. Congressional Earmarks, Limited Tax Benefits, and Limited 
      Tariff Benefits............................................    16
    G. Duplication of Federal Programs...........................    17
    H. Hearings..................................................    17
VI. CHANGES IN EXISTING LAW MADE BY THE BILL.....................    17
    A. Changes in Existing Law Proposed by the Bill..............    17
VII. MINORITY VIEWS..............................................   588






116th Congress   }                                           {   Report
                        HOUSE OF REPRESENTATIVES
 1st Session     }                                           {  116-161

======================================================================



 
  PROMOTING RESPECT FOR INDIVIDUALS' DIGNITY AND EQUALITY ACT OF 2019

                                _______
                                

 July 18, 2019.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

                                _______
                                

Mr. Neal, from the Committee on Ways and Means, submitted the following

                              R E P O R T

                             together with

                             MINORITY VIEWS

                        [To accompany H.R. 3299]

      [Including cost estimate of the Congressional Budget Office]

    The Committee on Ways and Means, to whom was referred the 
bill (H.R. 3299) to permit legally married same-sex couples to 
amend their filing status for income tax returns outside the 
statute of limitations, to amend the Internal Revenue Code of 
1986 to clarify that all provisions shall apply to legally 
married same-sex couples in the same manner as other married 
couples, and for other purposes, having considered the same, 
report favorably thereon with an amendment and recommend that 
the bill as amended do pass.
    The amendment is as follows:
  Strike all after the enacting clause and insert the 
following:

SECTION 1. SHORT TITLE.

  This Act may be cited as the ``Promoting Respect for Individuals' 
Dignity and Equality Act of 2019'' or as the ``PRIDE Act of 2019''.

SEC. 2. EXTENSION OF PERIOD OF LIMITATION FOR CERTAIN LEGALLY MARRIED 
                    COUPLES.

  (a) In General.--In the case of an individual first treated as 
married for purposes of the Internal Revenue Code of 1986 by the 
application of the holdings of Revenue Ruling 2013-17--
          (1) if such individual filed a return (other than a joint 
        return) for a taxable year ending before September 16, 2013, 
        for which a joint return could have been made by the individual 
        and the individual's spouse but for the fact that such holdings 
        were not effective at the time of filing, such return shall be 
        treated as a separate return within the meaning of section 
        6013(b) of such Code and the time prescribed by section 
        6013(b)(2)(A) of such Code for filing a joint return after 
        filing a separate return shall not expire before the date 
        prescribed by law (including extensions) for filing the return 
        of tax for the taxable year that includes the date of the 
        enactment of this Act, and
          (2) in the case of a joint return filed pursuant to paragraph 
        (1)--
                  (A) the period of limitation prescribed by section 
                6511(a) of such Code for any such taxable year shall be 
                extended until the date prescribed by law (including 
                extensions) for filing the return of tax for the 
                taxable year that includes the date of the enactment of 
                this Act, and
                  (B) section 6511(b)(2) of such Code shall not apply 
                to any claim of credit or refund with respect to such 
                return.
  (b) Amendments, etc. Restricted to Change in Marital Status.--
Subsection (a) shall apply only with respect to amendments to the 
return of tax, and claims for credit or refund, relating to a change in 
the marital status for purposes of the Internal Revenue Code of 1986 of 
the individual.

SEC. 3. RULES RELATING TO ALL LEGALLY MARRIED COUPLES.

  (a) In General.--The Internal Revenue Code of 1986 is amended--
          (1) in section 21(d)(2)--
                  (A) by striking ``himself'' in the heading and 
                inserting ``self''; and
                  (B) by striking ``any husband and wife'' and 
                inserting ``any married couple'';
          (2) in section 22(e)(1)--
                  (A) by striking ``husband and wife who live'' and 
                inserting ``married couple who lives''; and
                  (B) by striking ``the taxpayer and his spouse'' and 
                inserting ``the taxpayer and the spouse of the 
                taxpayer'';
          (3) in section 38(c)(6)(A), by striking ``husband or wife who 
        files'' and inserting ``married individual who files'';
          (4) in section 42(j)(5)(C), by striking clause (i) and 
        inserting the following new clause:
                          ``(i) Married couple treated as 1 partner.--
                        For purposes of subparagraph (B), individuals 
                        married to one another (and their estates) 
                        shall be treated as 1 partner.'';
          (5) in section 62(b)(3)--
                  (A) in subparagraph (A)--
                          (i) by striking ``husband and wife who lived 
                        apart'' and inserting ``married couple who 
                        lived apart''; and
                          (ii) by striking ``the taxpayer and his 
                        spouse'' and inserting ``the taxpayer and the 
                        spouse of the taxpayer''; and
                  (B) in subparagraph (D), by striking ``husband and 
                wife'' and inserting ``married couple'';
          (6) in section 121--
                  (A) in subsection (b)(2), by striking ``husband and 
                wife who make'' and inserting ``married couple who 
                makes''; and
                  (B) in subsection (d)(1), by striking ``husband and 
                wife make'' and inserting ``married couple makes'';
          (7) in section 165(h)(4)(B), by striking ``husband and wife'' 
        and inserting ``married couple'';
          (8) in section 179(b)(4), by striking ``a husband and wife 
        filing'' and inserting ``individuals married to one another who 
        file'';
          (9) in section 213(d)(8), by striking ``status as husband and 
        wife'' and inserting ``marital status'';
          (10) in section 219(g)(4), in the matter preceding 
        subparagraph (A), by striking ``A husband and wife'' and 
        inserting ``Married individuals'';
          (11) in section 274(b)(2)(B), by striking ``husband and 
        wife'' and inserting ``married couple'';
          (12) in section 643(f), by striking ``husband and wife'' in 
        the second sentence and inserting ``married couple'';
          (13) in section 761(f)--
                  (A) in paragraph (1), by striking ``husband and 
                wife'' and inserting ``married couple''; and
                  (B) in paragraph (2)(A), by striking ``husband and 
                wife'' and inserting ``married couple'';
          (14) in section 911--
                  (A) in subsection (b)(2), by striking subparagraph 
                (C) and inserting the following new subparagraph:
                  ``(C) Treatment of community income.--In applying 
                subparagraph (A) with respect to amounts received from 
                services performed by a married individual which are 
                community income under community property laws 
                applicable to such income, the aggregate amount which 
                may be excludable from the gross income of such 
                individual and such individual's spouse under 
                subsection (a)(1) for any taxable year shall equal the 
                amount which would be so excludable if such amounts did 
                not constitute community income.''; and
                  (B) in subsection (d)(9)(A), by striking ``where a 
                husband and wife each have'' and inserting ``where both 
                spouses have'';
          (15) in section 1244(b)(2), by striking ``a husband and wife 
        filing'';
          (16) in section 1272(a)(2)(D), by striking clause (iii) and 
        inserting the following new clause:
                          ``(iii) Treatment of a married couple.--For 
                        purposes of this subparagraph, a married couple 
                        shall be treated as 1 person. The preceding 
                        sentence shall not apply where the spouses 
                        lived apart at all times during the taxable 
                        year in which the loan is made.'';
          (17) in section 1313(c)(1), by striking ``husband and wife'' 
        and inserting ``spouses'';
          (18) in section 1361(c)(1)(A)(i), by striking ``a husband and 
        wife'' and inserting ``a married couple'';
          (19) in section 2040(b), by striking ``Certain Joint 
        Interests of Husband and Wife'' in the heading and inserting 
        ``Certain Joint Interests of Married Couple'';
          (20) in section 2513--
                  (A) by striking ``gift by