# Pub. L. 111-147: changes to the Internal Revenue Code 2010-03-18, 124 Stat. 74. Source: . ## Legislative history - Bill: [H.R. 2847](https://www.congress.gov/bill/111th-congress/house-bill/2847) - House report: [H. Rept. 111-149](https://www.govinfo.gov/content/pkg/CRPT-111hrpt149/html/CRPT-111hrpt149.htm) - Senate report: [S. Rept. 111-34](https://www.govinfo.gov/content/pkg/CRPT-111srpt34/html/CRPT-111srpt34.htm) - Bluebook: [JCT general explanation (2011)](https://www.govinfo.gov/app/details/CPRT-112JPRT64669) ## § 51: Amount of credit - § 51(c)(5): Pub. L. 111–147 added par. (5). ## § 149: Bonds must be registered to be tax exempt; other requirements - § 149(a)(2): Pub. L. 111–147 inserted “or” at end of subpar. (A), substituted period for “, or” in subpar. (B), and struck out subpar. (C) which read as follows: “is described in section 163(f)(2)(B).” ## § 163: Interest - § 163(f)(2)(A)(ii), § 163(f)(2)(A)(iii), § 163(f)(2)(A): Pub. L. 111–147, § 502(a)(2)(B), inserted “or” at end of cl. (ii), substituted period for “, or” in cl. (iii), and struck out cl. (iv), which read as follows: “is described in subparagraph (B).” - § 163(f)(2)(B): Pub. L. 111–147, § 502(a)(1), (2)(C)(i), redesignated subpar. (C) as (B), struck out “, and subparagraph (B),” after “subparagraph (A)” in introductory provisions, and struck out former subpar. (B) which related to certain obligations not included as registration-required obligations. - § 163(f)(2)(B)(i): Pub. L. 111–147, § 502(a)(2)(C)(ii), amended cl. (i) generally. Prior to amendment, cl. (i) read as follows: “in the case of— - § 163(f)(2): Pub. L. 111–147, § 502(a)(1), redesignated subpar. (C) as (B). - § 163(f)(3): Pub. L. 111–147, § 502(c), inserted before period at end “, except that a dematerialized book entry system or other book entry system specified by the Secretary shall be treated as a book entry system described in such section”. ## § 165: Losses - § 165(j)(2)(A): Pub. L. 111–147 struck out “except that clause (iv) of subparagraph (A), and subparagraph (B), of such section shall not apply” before period. ## § 179: Election to expense certain depreciable business assets - § 179(b)(1): Pub. L. 111–147, § 201(a)(1), substituted “($250,000 in the case of taxable years beginning after 2007 and before 2011)” for “($125,000 in the case of taxable years beginning after 2006 and before 2011)”. - § 179(b)(2): Pub. L. 111–147, § 201(a)(2), substituted “($800,000 in the case of taxable years beginning after 2007 and before 2011)” for “($500,000 in the case of taxable years beginning after 2006 and before 2011)”. - § 179(b)(5): Pub. L. 111–147, § 201(a)(3), (4), redesignated par. (6) as (5) and struck out former par. (5) which related to inflation adjustments. - § 179(b)(6): Pub. L. 111–147, § 201(a)(4), redesignated par. (6) as (5). - § 179(b): Pub. L. 111–147, § 201(a)(3), struck out par. (7) which related to increase in limitations for 2008 and 2009. ## § 643: Definitions applicable to subparts A, B, C, and D - § 643(i)(1): Pub. L. 111–147, § 533(a), substituted “(or permits the use of any other trust property) directly or indirectly to or by” for “directly or indirectly to” in introductory provisions and inserted “(or the fair market value of the use of such property)” after “the amount of such loan” in concluding provisions. - § 643(i)(2)(E): Pub. L. 111–147, § 533(b), added subpar. (E). - § 643(i)(3): Pub. L. 111–147, § 533(d), struck out “regarding loan principal” after “transactions” in heading and inserted “(or use of property)” after “If any loan” and “or the return of such property” after “otherwise)”. ## § 679: Foreign trusts having one or more United States beneficiaries - § 679(c)(1): Pub. L. 111–147, § 531(a), inserted concluding provisions. - § 679(c)(4), § 679(c)(5): Pub. L. 111–147, § 531(b), (c), added pars. (4) and (5). - § 679(c)(6): Pub. L. 111–147, § 533(c), added par. (6). - § 679(d), § 679(e): Pub. L. 111–147, § 532(a), added subsec. (d) and redesignated former subsec. (d) as (e). ## § 864: Definitions and special rules - § 864(f): Pub. L. 111–147 substituted “December 31, 2020” for “December 31, 2017”. ## § 871: Tax on nonresident alien individuals - § 871(h)(2): Pub. L. 111–147, § 502(b)(1), amended par. (2) generally. Prior to amendment, par. (2) defined portfolio interest to also include interest on certain obligations not in registered form. - § 871(h)(3)(A): Pub. L. 111–147, § 502(b)(2)(A), struck out “subparagraph (A) or (B) of” before “paragraph (2)”. - § 871(l): Pub. L. 111–147, § 541(a), added subsec. (l). Former subsec. (l) redesignated (m). - § 871(m): Pub. L. 111–147, § 541(a), redesignated subsec. (l) as (m). ## § 881: Tax on income of foreign corporations not connected with United States business - § 881(c)(2): Pub. L. 111–147 amended par. (2) generally. Prior to amendment, par. (2) defined portfolio interest to also include interest on certain obligations not in registered form. ## § 1287: Denial of capital gain treatment for gains on certain obligations not in registered form - § 1287(b)(1): Pub. L. 111–147 struck out “except that clause (iv) of subparagraph (A), and subparagraph (B), of such section shall not apply” before period. ## § 1291: Interest on tax deferral - § 1291(e): Pub. L. 111–147 substituted “and (d)” for “, (d), and (f)”. ## § 1298: Special rules - § 1298(f), § 1298(g): Pub. L. 111–147 added subsec. (f) and redesignated former subsec. (f) as (g). ## § 1471: Withholdable payments to foreign financial institutions - Enacted 26 U.S.C. § 1471. ## § 1472: Withholdable payments to other foreign entities - Enacted 26 U.S.C. § 1472. ## § 1473: Definitions - Enacted 26 U.S.C. § 1473. ## § 1474: Special rules - Enacted 26 U.S.C. § 1474. ## § 3111: Rate of tax - § 3111(d): Pub. L. 111–147 added subsec. (d). ## § 3221: Rate of tax - § 3221(c), § 3221: Pub. L. 111–147 added subsec. (c) and redesignated former subsec. (c) as (d). ## § 4701: Tax on issuer of registration-required obligation not in registered form - § 4701(b)(1): Pub. L. 111–147 amended par. (1) generally. Prior to amendment, text read as follows: “The term ‘registration-required obligation’ has the same meaning as when used in section 163(f), except that such term shall not include any obligation required to be registered under section 149(a).” ## § 6011: General requirement of return, statement, or list - § 6011(e)(4): Pub. L. 111–147 added par. (4). ## § 6038D: Information with respect to foreign financial assets - Enacted 26 U.S.C. § 6038D. ## § 6048: Information with respect to certain foreign trusts - § 6048(b)(1): Pub. L. 111–147 inserted “shall submit such information as the Secretary may prescribe with respect to such trust for such year and” before “shall be responsible to ensure” in introductory provisions. ## § 6414: Income tax withheld - § 6414: Pub. L. 111–147 inserted “or 4” after “chapter 3”. ## § 6501: Limitations on assessment and collection - § 6501(b)(1): Pub. L. 111–147, § 501(c)(2), inserted “4,” after “chapter 3,”. - § 6501(b)(2): Pub. L. 111–147, § 501(c)(3), substituted “and withholding taxes” for “taxes and tax imposed by chapter 3” in heading and inserted “4,” after “chapter 3,” in text. - § 6501(c)(8): Pub. L. 111–147, § 513(b), (c), substituted “pursuant to an election under section 1295(b) or under section 1298(f), 6038, 6038A, 6038B, 6038D,” for “under section 6038, 6038A, 6038B,” and “tax return, event,” for “event”. - § 6501(e)(1)(A): Pub. L. 111–147, § 513(a)(1), added subpar. (A). Former subpar. (A) redesignated (B). - § 6501(e)(1)(B): Pub. L. 111–147, § 513(a)(2)(A), substituted “Determination of gross income” for “General rule” in heading and “For purposes of subparagraph (A)” for “If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 6 years after the return was filed. For purposes of this subparagraph” in introductory provisions. - § 6501(e)(1)(B): Pub. L. 111–147, § 513(a)(1), redesignated subpar. (A) as (B). Former subpar. (B) redesignated (C). - § 6501(e)(1)(C): Pub. L. 111–147, § 513(a)(1), redesignated subpar. (B) as (C). ## § 6513: Time return deemed filed and tax considered paid - § 6513(b)(3): Pub. L. 111–147, § 501(c)(4), inserted “or 4” after “chapter 3” and “or 1474(b)” after “section 1462”. - § 6513(c): Pub. L. 111–147, § 501(c)(5), inserted “4,” after “chapter 3,” in introductory provisions. ## § 6611: Interest on overpayments - § 6611(e)(4): Pub. L. 111–147 added par. (4). ## § 6662: Imposition of accuracy-related penalty on underpayments - § 6662(b)(7): Pub. L. 111–147, § 512(a)(1), as amended by Pub. L. 113–295, § 208(a), added par. (7). - § 6662(j): Pub. L. 111–147, § 512(a)(2), added subsec. (j). ## § 6677: Failure to file information with respect to certain foreign trusts - § 6677(a): Pub. L. 111–147, in concluding provisions, inserted “the greater of $10,000 or” before “35 percent” and substituted “At such time as the gross reportable amount with respect to any failure can be determined by the Secretary, any subsequent penalty imposed under this subsection with respect to such failure shall be reduced as necessary to assure that the aggregate amount of such penalties do not exceed the gross reportable amount (and to the extent that such aggregate amount already exceeds the gross reportable amount the Secretary shall refund such excess to the taxpayer).” for “In no event shall the penalty under this subsection with respect to any failure exceed the gross reportable amount.” ## § 6724: Waiver; definitions and special rules - § 6724(c): Pub. L. 111–147, § 522(b), inserted before period at end “or with respect to a return described in section 6011(e)(4)”. - § 6724(d)(1): Pub. L. 111–147, § 501(c)(6), inserted “under chapter 4 or” after “filed with the Secretary” in concluding provisions. - § 6724(d)(2): Pub. L. 111–147, § 501(c)(7), inserted “or 4” after “chapter 3” in concluding provisions. ## § 9502: Airport and Airway Trust Fund - § 9502(a): Pub. L. 111–147 substituted “section 9503(c)(5)” for “section 9503(c)(7)”. ## § 9503: Highway Trust Fund - § 9503(b)(4)(D): Pub. L. 111–147, § 444(b)(2), substituted “paragraph (3)(D) or (4)(B)” for “paragraph (4)(D) or (5)(B)” in introductory provisions. - § 9503(b)(6)(B): Pub. L. 111–147, § 445(a)(3), substituted “December 31, 2010 (January 1, 2011” for “September 30, 2009 (October 1, 2009”. - § 9503(c)(1): Pub. L. 111–147, § 445(a)(1), substituted “December 31, 2010 (January 1, 2011” for “September 30, 2009 (October 1, 2009” and “under the Surface Transportation Extension Act of 2010 or any other provision of law which was referred to in this paragraph before the date of the enactment of such Act (as such Act and provisions of law are in effect on the date of the enactment of such Act).” for “under the first Continuing Appropriations Resolution for Fiscal Year 2010 enacted into law or any other provision of law which was referred to in this paragraph before the date of the enactment of such Continuing Appropriations Resolution (as such Resolution and provisions of law are in effect on the date of the enactment of the last amendment to such Resolution).” - § 9503(c)(2): Pub. L. 111–147, § 444(b)(3), inserted at end “The amounts payable from the Highway Trust Fund under the preceding sentence shall be determined by taking into account only the portion of the taxes which are deposited into the Highway Trust Fund.” - § 9503(c)(2): Pub. L. 111–147, § 444(a), redesignated par. (3) as (2) and struck out former par. (2) which related to transfers from the Highway Trust Fund for certain repayments and credits. - § 9503(c)(3), § 9503(c)(4), § 9503(c)(5), § 9503(c): Pub. L. 111–147, § 444(a), redesignated pars. (4) to (6) as (3) to (5), respectively. Former par. (3) redesignated (2). - § 9503(e)(1): Pub. L. 111–147, § 442(b), substituted “this section” for “this subsection”. - § 9503(e)(3): Pub. L. 111–147, § 445(a)(2), substituted “January 1, 2011” for “October 1, 2009” and “in accordance with the Surface Transportation Extension Act of 2010 or any other provision of law which was referred to in this paragraph before the date of the enactment of such Act (as such Act and provisions of law are in effect on the date of the enactment of such Act).” for “in accordance with the first Continuing Appropriations Resolution for Fiscal Year 2010 enacted into law or any other provision of law which was referred to in this paragraph before the date of the enactment of such Continuing Appropriations Resolution (as such Resolution and provisions of law are in effect on the date of the enactment of the last amendment to such Resolution).” - § 9503(e)(5)(A): Pub. L. 111–147, § 444(b)(4), substituted “(2) and (3)” for “(2), (3), and (4)”. - § 9503(f)(1): Pub. L. 111–147, § 441(b), struck out subpar. (A) designation before “the opening balance” and substituted “September 30, 1998,” for “September 30, 1998—” and “$8,000,000,000.” for “$8,000,000,000, and”. - § 9503(f)(1): Pub. L. 111–147, § 441(a), struck out subpar. (B) which read as follows: “notwithstanding section 9602(b), obligations held by such Fund after September 30, 1998, shall be obligations of the United States which are not interest-bearing.” - § 9503(f)(2): Pub. L. 111–147, § 442(a), amended par. (2) generally. Prior to amendment, text read as follows: “Out of money in the Treasury not otherwise appropriated, there is hereby appropriated (without fiscal year limitation) to the Highway Trust Fund $7,000,000,000.” - § 9503(f)(4): Pub. L. 111–147, § 443(a), added par. (4). ## § 9504: Sport Fish Restoration and Boating Trust Fund - § 9504(a): Pub. L. 111–147, § 444(b)(5), substituted “section 9503(c)(3), section 9503(c)(4)” for “section 9503(c)(4), section 9503(c)(5)”. - § 9504(b)(2): Pub. L. 111–147, § 444(b)(6), substituted “section 9503(c)(4)” for “section 9503(c)(5)” in concluding provisions. - § 9504(b)(2)(A), § 9504(b)(2)(B), § 9504(b)(2)(C): Pub. L. 111–147, § 445(b)(1), substituted “(as in effect on the date of the enactment of the Surface Transportation Extension Act of 2010)” for “(as in effect on the date of the enactment of the last amendment to the first Continuing Appropriations Resolution for Fiscal Year 2010)”. - § 9504(d)(2): Pub. L. 111–147, § 445(b)(2), substituted “January 1, 2011” for “October 1, 2009”. - § 9504(e): Pub. L. 111–147, § 444(b)(7), which directed amendment of subsec. (e) “by striking ‘section 9503(c)(4)’ and inserting section ‘9503(c)(3)’ ”, was executed by striking “section 9503(c)(4)” and inserting “section 9503(c)(3)” to reflect the probable intent of Congress.