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  1. #2451
    Guest Member S Landreth's Avatar
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    Biden hits road to tout infrastructure bill

    President Biden needs no lessons in pitching voters on the importance of American ports, highways, bridges and rail. He’s been doing it for months. He did it as vice president during visits to Granite City, Ill.; Cleveland, Ohio; and Norfolk, Va. He gave an interview about infrastructure on Monday to a Cincinnati TV station. He’ll repeat it on Wednesday at the Port of Baltimore. And he’ll recap his points later this month when senators and House members from both parties stand shoulder to shoulder in the White House as the bill they helped write becomes a $1.2 trillion law.

    In Kentucky on Monday, Senate Minority Leader Mitch McConnell (R-Ky.) applauded the passage of the infrastructure bill he voted to support in August. “This will be the first time I have come up here in a quarter of a century where I thought maybe there was a way forward on the Brent Spence Bridge,” he said in remarks in Covington, Ky., where the much-discussed span stretching to Cincinnati has been declared functionally obsolete by the Federal Highway Administration since the 1990s (Kentucky Politics).




    Here are the 19 Republicans who voted in favor of the bill:

    Roy Blunt, Missouri
    Richard Burr, North Carolina
    Shelley Moore Capito, West Virginia
    Bill Cassidy, Louisiana
    Susan Collins, Maine
    Kevin Cramer, North Dakota
    Mike Crapo, Idaho
    Deb Fischer, Nebraska
    Lindsey Graham, South Carolina
    Chuck Grassley, Iowa
    John Hoeven, North Dakota
    Mitch McConnell, Kentucky
    Lisa Murkowski, Alaska
    Rob Portman, Ohio
    James Risch, Idaho
    Mitt Romney, Utah
    Dan Sullivan, Alaska
    Thom Tillis, North Carolina
    Roger Wicker, Mississippi
    Last edited by S Landreth; 09-11-2021 at 07:14 PM.
    Keep your friends close and your enemies closer.

  2. #2452
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    Just a quick question, leaving aside the Build back bill, has the infrastructure bill been finalised or does it still require FURTHER votes?

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    Quote Originally Posted by Cujo View Post
    Just a quick question, leaving aside the Build back bill, has the infrastructure bill been finalised or does it still require FURTHER votes?
    Yeah, I was wondering which bill you were talking about.

    The infrastructure bill has passed the senate and house — and will be signed by Biden when he holds a ceremony with congressmen next week.

  4. #2454
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  5. #2455
    Guest Member S Landreth's Avatar
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    Quote Originally Posted by RPETER65 View Post
    I’m happy to know how the rest of the world thinks of the US today…….

    Quote Originally Posted by S Landreth View Post
    U.S. leadership approval rebounds from Trump low



    A Gallup report published Tuesday found approval of United States leadership in 46 countries and territories hit 49% — up from 30% at the end of Donald Trump's presidency, and matching former President Obama's first year (2009).

    Why it matters: Biden's efforts to reengage with the international community following the Trump administration appear to be improving the global approval ratings for U.S. leadership, though this poll does not take into account the withdrawal from Afghanistan in August.

    Gallup said America's global approval ratings will likely continue to shift as it completes its polling for 2021, though it is unlikely to drop to Trump-era lows.

    By the numbers: The transition from Trump to Biden significantly improved the approval rating of U.S. leadership in 36 of the 46 countries and territories surveyed by Gallup through the first half of the year.

    Ratings improved the most among European allies, including Portugal (52 percentage points), the Netherlands (45 points), Norway (42 points) and Sweden (41 points).

    After Biden assumed office, ratings of U.S. leadership decreased in just three countries: Russia, Serbia and Benin.

  6. #2456
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    Quote Originally Posted by RPETER65 View Post
    Have a look
    Do you remember how virtually everyone in the world, including country leaders, mocked Trump? HE was the face of the USA and brought irreparable damage to the place

  7. #2457
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  8. #2458
    Thailand Expat russellsimpson's Avatar
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    Quote Originally Posted by S Landreth View Post
    though this poll does not take into account the withdrawal from Afghanistan in August.
    I'm happy that was added because I wasn't believing those poll numbers. Afghanistan was a deal breaker' it may live in infamy.

  9. #2459
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    Here is a more sobering assessment of Joe, one year on. Afghanistan the big exception, but otherwise he has achieved basically nothing on the foreign policy front-


    Electing Biden: One Year Later

    by Ted SniderPosted onNovember 11, 2021Sunday marked one year since Americans elected Joe Biden president. And on his first year report card, Americans give him a failing grade. Only 42% of Americans approve of Biden’s performance.

    Biden may have received a failing grade, in part, because on several key foreign policy issues, he has done nothing. And on the few he has, he has made things worse.
    Middle East

    On the key Middle Eastern question, an Israeli-Palestinian peace plan still has not made it onto Biden’s to do list. It is simply not a priority of the Biden administration. Or, as Secretary of State Antony Blinken explained it, "I don’t think we’re at the – in a place where the getting to some kind of negotiation for what ultimately I think has to be the result, which is a two-state solution, is the first order of business."

    In Yemen, despite his promises, Biden has done nothing. Despite his promise that "we are ending all American support for offensive operations in the war in Yemen, including relevant arms sales," his State Department just notified Congress of a $650 million arms sale to Saudi Arabia, which sounds a lot like "American support for offensive operations in the war in Yemen, including relevant arms sales." The sale will include 280 advanced medium-range air-to-air missiles and 596 missile rail launchers.

    But Biden never was keeping his promise to stop supporting Saudi offensive operations in Yemen, since the US never stopped servicing Saudi Arabia’s military planes. In September, Biden’s State Department approved a possible $500 million contract with Saudi Arabia for equipment and maintenance support for their helicopters.

    On the key foreign policy issue of returning to the JCPOA nuclear agreement with Iran, though this could have been an easy early success for Biden, as he suggested it could be, Biden did nothing, while Rouhani and Iran waited for months for the US to restart the negotiations. He refused to end the policy of maximum pressure, and he refused to put an end to the cruel and illegal sanctions. Most seriously, and most cynically, according to reporting by Trita Parsi, Biden was unwilling to provide Iran with a guarantee that he would honor his agreements and commitments as binding even for the duration of his own term.

    Latin America

    As in the Middle East, in Latin America, Biden has done nothing.

    The Venezuela file remains unopened. Since Biden’s election, Venezuelan President Nicolas Maduro says, "There hasn’t been a single positive sign. None." The Biden administration continues to recognize Juan Guaidó as Venezuela’s legitimate president, and it continues to pursue “an effective policy that can restore Venezuela to democracy.”

    In Cuba, Biden has done worse than nothing. As in Yemen and Iran, that represents a broken promise. While campaigning to be president, Biden said that he would "promptly reverse the failed Trump policies that have inflicted harm on the Cuban people and done nothing to advance democracy and human rights." But once he was president, the White House explained instead that "A shift in Cuba policy is not among President Joe Biden’s top foreign policy priorities."

    In fact, Biden has increased sanctions on several senior Cuban officials in the military and police and, most significantly, vowed to intensify US support for Cuban dissidents. Biden has voted against the near unanimous UN resolution to finally end the blockade on Cuba, and he has refused to lift the restrictions on remittances to Cuba that make it impossible for Cuban Americans to send money home to their families. He has listed Cuba as a country “not cooperating fully with United States anti-terrorism efforts," a move toward keeping Cuba on the state sponsors of terrorism list.

    Cuba expert William LeoGrande reports that the US embassy in Havana "has taken a leading role supporting dissident activists, pushing the boundaries of what’s normally allowed under the Vienna Convention on Diplomatic Relations." Cuban journalist Rosa Miriam Elizalde reports that "in September, the United States Agency for International Development (USAID) gave $6,669,000 in grants for projects aimed at ‘regime change’ in Cuba." LeoGrande says that "The United States and Cuba are on a collision course over U.S. diplomats’ support for "democracy promotion" programs."

    Russia and China

    In the most important foreign policy issue of his administration, Biden has done worse than nothing on Russia and China.

    Donald Trump hoped to improve relations with Russia, seeing them as still a potential ally in the emerging struggle with China. Hillary Clinton, the Democrat Party and Russiagate squashed that hope, and, according to Richard Sakwa in his soon to be published book Deception: Russiagate and the New Cold War, relations with Russia "deteriorated to a level below anything seen during the original cold war."

    That deterioration has intensified under Biden. His summit with Putin accomplished little if anything. And continued sanctions, exclusion, hostility and threatened NATO encroachment in Ukraine and Georgia has gone so far as to push Russia toward China in a Second Cold War.

    The pivot to China precedes Biden’s administration. It began when he was vice president and intensified during the Trump administration. By 2016, the trade war on China compelled the realization in Beijing that cooperation with the US was a chimera. But it wasn’t until the unyielding pressure of the Biden administration attempted to force the world into blocs that were on one side or the other that China finally, reluctantly accepted Biden’s framework of a Second Cold War.

    Since then, provocative action in Taiwan and threatening action by US warships and aircraft near China have only further deteriorated relations with China and further pushed the world toward a Second Cold War. Biden has done more than any president since the close of the cold war to squander the peace and push the world back into a cold war.

    On several key foreign policy issues, Biden has done nothing. He has done nothing in the Middle East and Latin America, while in Russia and China, the most important foreign policy issue of the day, he has made things worse.

    https://original.antiwar.com/Ted_Snider/2021/11/10/electing-biden-one-year-later/

  10. #2460
    Guest Member S Landreth's Avatar
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    Biden Delivers Remarks Promoting Bipartisan Infrastructure Deal



    Biden touts infrastructure bill ahead of Monday signing

    President Biden on Wednesday said the $1.2 trillion bipartisan infrastructure bill would "stabilize" the supply chain and "modernize" the country's infrastructure.

    Why it matters: The president's remarks at a briefing in Baltimore come days after the House passed the long-awaited bipartisan infrastructure package and ahead of the bill's signing ceremony on Monday.


    • At the ceremony, which will be attended by members of Congress and state and local lawmakers across the country, Biden will highlight how the package will "deliver to American families."
    • Biden acknowledged in Baltimore that the U.S. still faces economic challenges, adding that "we're tracking these issues and trying to figure out how to tackle them head on."


    What they're saying: "We did something long overdue, long talked about in Washington, but almost never actually done," Biden said.


    • "This is a once in a generation investment to create good-paying jobs, modernize our infrastructure [and] turn a climate crisis into an opportunity."
    • "Progress has already begun and now that we've passed the bipartisan infrastructure deal it's only going to accelerate," he added.

  11. #2461
    Thailand Expat harrybarracuda's Avatar
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    Quote Originally Posted by RPETER65 View Post
    How about you read the whole bill and analyse its effects rather than picking out one small change?

    As the saying goes, "The lord giveth and the Lord taketh away".


  12. #2462
    Guest Member S Landreth's Avatar
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    Biden signs infrastructure bill at White House



    Biden signs infrastructure bill into law at rare bipartisan gathering

    President Joe Biden signs the $1.2 trillion bipartisan infrastructure package into law

    Once signed, it will deliver $550 billion of new federal investments in America's infrastructure over five years, including money for roads, bridges, mass transit, rail, airports, ports and waterways. The package includes a $65 billion investment in improving the nation's broadband infrastructure and invests tens of billions of dollars in improving the electric grid and water systems. Another $7.5 billion would go to building a nationwide network of plug-in electric vehicle chargers, according to the bill text

  13. #2463
    Thailand Expat harrybarracuda's Avatar
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    Of course now all those republican wankers that have opposed this since day one will be running back to their dumb base and taking credit for it.

    C u n t s.

  14. #2464
    Guest Member S Landreth's Avatar
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    Democrats press toward vote on massive Biden bill

    There was a bump in the road.

    But the vote is planned for 8:00 (EST) Friday

    final vote…..

    Yeas - enough

    Nays - not enough

    Americans win again

    What’s in Biden’s $1.75 trillion ‘Build Back Better’ package?

    Family benefits

    Free preschool for all three- and four-year-olds
    Support for childcare costs: Families that earn less than $300,000 per year would pay no more than 7 percent of their income on childcare
    Tax credits worth up to $300 per child per month
    Bolsters coverage of home care costs for the elderly and disabled people through the Medicaid health programme
    Expands free school meals and provides $65 per month in grocery money during summer months for 29 million low-income children who are eligible for free lunches at school

    Climate

    Rebates and credits to cut the cost of rooftop solar systems by 30 percent and union-made electric vehicles produced in the US by $12,500
    Incentives to encourage US manufacturing of clean energy technology and shift other industries to reduce carbon emissions
    Creates 300,000-strong Civilian Climate Corps to work on environmental and climate projects
    Creates a Clean Energy and Sustainability Accelerator to invest in climate-related projects, with at least 40 percent serving disadvantaged communities
    New spending on coastal restoration, forest management and soil conservation

    Healthcare

    Enables the Medicare health plan for seniors to negotiate lower prices for prescription drugs that have been on the market for at least nine years
    Penalises drug companies that increase prices faster than inflation
    Caps out-of-pocket prescription drug prices at $2,000 per year and lowers insulin prices to $35 per month
    Expands Medicare to cover hearing aids
    Reduces Affordable Care Act premiums by an average of $600 per person per year
    Expands Medicaid coverage to low-income people in the 12 states that have opted not to expand the programme on their own

    Housing

    Expands affordable housing, public housing and rental assistance programmes
    Broadens downpayment assistance to bolster homeownership
    Expands lead paint removal efforts
    Supports community-led redevelopment in low-income neighbourhoods
    Encourages local governments to ease zoning restrictions that limit housing density

    Education

    Increases Pell Grants for college costs
    More aid for historically Black colleges and other minority-serving schools
    Boosts the Labor Department’s job training programmes by 50 percent
    Play Video
    24:02
    The tug of war within the US Democratic Party | The Bottom Line

    Immigration*

    $100bn in “immigration reform”, which is additional funding beyond the $1.75 trillion
    Efforts to reduce backlogs, expand legal services and improve border processing and asylum programmes

    Other programmes

    Expands a tax credit for low-income workers to cover those who do not have children
    More money for rural projects
    Supports community violence intervention

    Taxes

    15 percent minimum tax on corporate profits for companies with more than $1bn in profits
    1 percent surcharge on stock buybacks
    15 percent minimum tax on foreign profits of US corporations
    5 percent surtax on personal income above $10m
    Additional 3 percent surtax on income above $25m
    Close loophole to prevent the wealthy from avoiding 3.8 percent Medicare tax
    Bolster the Internal Revenue Service to improve customer service and focus enforcement on wealthy tax evaders
    Expands a deduction for state and local taxes that primarily benefits upper-income households in high-tax states. Republicans had reduced that benefit in their 2017 tax cut package

    *Immigration provisions could be removed from the legislation by the Senate parliamentarian

    Voting now…






    Last edited by S Landreth; 19-11-2021 at 07:08 PM.

  15. #2465
    Thailand Expat russellsimpson's Avatar
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    America turns inward again.
    Buy America provisions will create hardship on either side of the border both in Canada and Mexico.
    Provisions will cripple auto manufacturing in Canada and USA.
    Provisions will exclude both Canadians and Mexicans from bidding on contracts under Build Back Better provisions.

    Screw America. Screw Biden.
    A true diplomat is a person who can tell you to go to hell in such a manner that you will be asking for directions.

  16. #2466
    Thailand Expat harrybarracuda's Avatar
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    Quote Originally Posted by russellsimpson View Post
    America turns inward again.
    Buy America provisions will create hardship on either side of the border both in Canada and Mexico.
    Provisions will cripple auto manufacturing in Canada and USA.
    Provisions will exclude both Canadians and Mexicans from bidding on contracts under Build Back Better provisions.

    Screw America. Screw Biden.
    Ah yes, because of course America exists solely for the benefit of its noisy neighbours.


  17. #2467
    Thailand Expat russellsimpson's Avatar
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    I believe America is going to be in violation, both in spirit and in letter , of the NAFTA 2.0, Canada and Mexico can challenge of course but by the time things work there way through the court with the auto pact in particular the auto industry in both neighbouring countries will be ruined. America should be good neighbours, there is no excuse for them to be otherwise. Canada in particular has been a very good neighbour supporting them in both world wars, Korea, Vietnam, and Afghanistan. If this is how America treats its closest allies then I think a general reappraisal of relations between the two nations is probably in order.

  18. #2468
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    The Nay vote carried the day.

  19. #2469
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    Quote Originally Posted by russellsimpson View Post
    Screw America. Screw Biden.
    Yes, I long for the Trump days, when we were holding hands, sharing a Coke, and singing Kumbaya, with our neighbors.



    Dick

  20. #2470
    Thailand Expat russellsimpson's Avatar
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    I always thought you were Canadian beachbound. That's the impression I got back in AF days anyway?

  21. #2471
    Guest Member S Landreth's Avatar
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    Update - House passes Biden's social spending bill

    Quote Originally Posted by S Landreth View Post
    final vote…..

    Yeas - 220

    Nays - 213

    Americans win again

    What’s in Biden’s $1.75 trillion ‘Build Back Better’ package?

    Family benefits

    Free preschool for all three- and four-year-olds
    Support for childcare costs: Families that earn less than $300,000 per year would pay no more than 7 percent of their income on childcare
    Tax credits worth up to $300 per child per month
    Bolsters coverage of home care costs for the elderly and disabled people through the Medicaid health programme
    Expands free school meals and provides $65 per month in grocery money during summer months for 29 million low-income children who are eligible for free lunches at school

    Climate

    Rebates and credits to cut the cost of rooftop solar systems by 30 percent and union-made electric vehicles produced in the US by $12,500
    Incentives to encourage US manufacturing of clean energy technology and shift other industries to reduce carbon emissions
    Creates 300,000-strong Civilian Climate Corps to work on environmental and climate projects
    Creates a Clean Energy and Sustainability Accelerator to invest in climate-related projects, with at least 40 percent serving disadvantaged communities
    New spending on coastal restoration, forest management and soil conservation

    Healthcare

    Enables the Medicare health plan for seniors to negotiate lower prices for prescription drugs that have been on the market for at least nine years
    Penalises drug companies that increase prices faster than inflation
    Caps out-of-pocket prescription drug prices at $2,000 per year and lowers insulin prices to $35 per month
    Expands Medicare to cover hearing aids
    Reduces Affordable Care Act premiums by an average of $600 per person per year
    Expands Medicaid coverage to low-income people in the 12 states that have opted not to expand the programme on their own

    Housing

    Expands affordable housing, public housing and rental assistance programmes
    Broadens downpayment assistance to bolster homeownership
    Expands lead paint removal efforts
    Supports community-led redevelopment in low-income neighbourhoods
    Encourages local governments to ease zoning restrictions that limit housing density

    Education

    Increases Pell Grants for college costs
    More aid for historically Black colleges and other minority-serving schools
    Boosts the Labor Department’s job training programmes by 50 percent

    Immigration*

    $100bn in “immigration reform”, which is additional funding beyond the $1.75 trillion
    Efforts to reduce backlogs, expand legal services and improve border processing and asylum programmes

    Other programmes

    Expands a tax credit for low-income workers to cover those who do not have children
    More money for rural projects
    Supports community violence intervention

    Taxes

    15 percent minimum tax on corporate profits for companies with more than $1bn in profits
    1 percent surcharge on stock buybacks
    15 percent minimum tax on foreign profits of US corporations
    5 percent surtax on personal income above $10m
    Additional 3 percent surtax on income above $25m
    Close loophole to prevent the wealthy from avoiding 3.8 percent Medicare tax
    Bolster the Internal Revenue Service to improve customer service and focus enforcement on wealthy tax evaders
    Expands a deduction for state and local taxes that primarily benefits upper-income households in high-tax states. Republicans had reduced that benefit in their 2017 tax cut package

    *Immigration provisions could be removed from the legislation by the Senate parliamentarian

    Voting now (1:45:00)…






    In other news……..

    Biden pardons turkeys Peanut Butter and Jelly ahead of Thanksgiving

    President Biden pardoned turkeys Peanut Butter and Jelly on Friday afternoon in a ceremony at the White House.


    Last edited by S Landreth; 20-11-2021 at 05:02 AM.

  22. #2472
    Thailand Expat helge's Avatar
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    Quote Originally Posted by russellsimpson View Post
    I always thought you were Canadian beachbound.
    You haven't got beaches, Russ

    Beach Bum is the essence of a narrowminded seppo.

    He thinks that he isn't though

  23. #2473
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    Quote Originally Posted by helge

    Beach Bum is the essence of a narrowminded seppo.
    High praise from the biggest sanctimonious twat on the forum.

  24. #2474
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    Quote Originally Posted by helge View Post
    Beach Bum is the essence of a narrowminded seppo.

    He thinks that he isn't though
    Quote Originally Posted by beachbound View Post
    High praise from the biggest sanctimonious twat on the forum.
    Bingo

  25. #2475
    Guest Member S Landreth's Avatar
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    Quote Originally Posted by S Landreth View Post
    What’s in Biden’s $1.75 trillion ‘Build Back Better’ package?

    Taxes

    15 percent minimum tax on corporate profits for companies with more than $1bn in profits
    1 percent surcharge on stock buybacks
    15 percent minimum tax on foreign profits of US corporations
    5 percent surtax on personal income above $10m
    Additional 3 percent surtax on income above $25m
    Close loophole to prevent the wealthy from avoiding 3.8 percent Medicare tax
    Bolster the Internal Revenue Service to improve customer service and focus enforcement on wealthy tax evaders
    Expands a deduction for state and local taxes that primarily benefits upper-income households in high-tax states. Republicans had reduced that benefit in their 2017 tax cut package

    Little more

    Tax provisions in the Build Back Better act

    One year extension of expanded child tax credit; permanent extension of refundability

    The changes to the child tax credit enacted by the American Rescue Plan Act (ARPA), P.L. 117-2, for 2021 would be extended through 2022. This would include the requirement that the IRS make advance payments of the credit throughout 2022. Taxpayers whose adjusted gross income (AGI) exceeds $150,000 for joint filers, $112,500 for heads of household, or $75,000 for other taxpayers, would not be eligible for advance payments.

    The bill would extend the refundability of the child tax credit beyond 2022.

    The bill would also implement new rules to avoid fraud. For payments of advance payment to taxpayers who file joint returns, one-half will be credited to each individual filing the joint return.

    Extending expanded earned income tax credit

    The bill would extend the changes to the earned income tax credit that were enacted by ARPA through 2022. The increase in the earned income and phaseout amounts would be indexed for inflation in 2022.

    SALT deduction cap

    The bill would increase the Sec. 164(b) limitation on the deduction for state and local taxes from $10,000 to $80,000 ($40,000 for married taxpayers filing separately and for trusts and estates) but would extend the limitation through 2031.

    Expanded premium tax credit

    The bill would increase the amounts for premium assistance in Sec. 36B through 2025. The bill would also extend through 2025 the rule that allows the premium tax credit to certain taxpayers whose household income exceeds 400% of the poverty line. The bill would also modify the employer-sponsored coverage affordability test in the premium tax credit through 2025.

    The bill would exclude a portion of lump-sum Social Security benefit payments when determining household income for purposes of the credit. The bill would also exclude the first $3,500 of income of dependents who have not reached the age of 24.

    Through 2025, the bill would also allow certain low-income employees who are offered employer-provided health coverage to claim the credit. The bill would also make permanent the Sec. 35 health coverage credit, which is currently scheduled to expire at the end of 2022.

    15% minimum tax on profits of large corporations

    The bill would impose a 15% minimum tax on the profits of corporations that report over $1 billion in profits to shareholders. Any corporation (other than an S corporation, regulated investment company, or real estate investment trust) that for any three-year period has average annual adjusted financial statement income (as defined in new Sec. 56A) over $1 billion and, in the case of corporations with foreign parents, has annual adjusted financial statement income in excess of $100 million, would pay a tax of 15% of its adjusted financial statement income for the year over the amount of its corporate AMT foreign tax credit.

    1% surcharge on corporate stock buybacks

    The bill would impose a tax equal to 1% of the fair market value of any stock of a corporation that the corporation repurchases during the year, effective for repurchases of stock after Dec. 31, 2021. The provision would apply to any domestic corporation the stock of which is traded on an established securities market.

    Limitation on interest expense deduction

    The bill would add a new Sec. 163(n) that limits the amount of net interest expense of certain domestic corporations (or foreign corporations engaged in a U.S. trade or business) that are members in an international financial reporting group. The provision limits the interest expense deduction to an "allowable percentage" of 110% of the domestic corporation's net interest expense.

    FDII and GILTI changes

    The bill would reduce the applicable percentage in Sec. 250(a) for the foreign-derived intangible income (FDII) deduction from 37.5% to 24.8% and the applicable percentage for the global intangible low-taxed income (GILTI) deduction from 50% to 28.5%, resulting in an effective FDII rate of 15.8% and an effective GILTI rate of 15%. The bill would also allow the FDII deduction to be taken into account when determining a net operating loss deduction.

    Sec. 951A would be amended to have the GILTI provisions apply on a country-by-country basis, based on controlled foreign corporation taxable units.

    Foreign tax credit limitation

    The bill would amend Sec. 904 to apply the foreign tax credit limitation on a country-by-country basis, by taxable unit. Taxable units would include the taxpayer corporation itself, each foreign corporation of which the taxpayer is a shareholder, interests held by the taxpayer in a passthrough entity, and any branch of the taxpayer. The bill would also repeal the carryback of the foreign tax credit. The foreign tax credit changes will apply to tax years beginning after Dec. 31, 2022.

    Country-by-country minimum tax on foreign profits of US corporations

    The bill would modify the Sec. 59A base-erosion and anti-abuse tax to gradually increase the applicable percentage from 10% to 12.5% in 2023, 15% in 2024, and 18% after 2024. Amounts would not be subject to the base-erosion and anti-abuse tax if they were subject to an effective rate of foreign tax of at least 15% (or 18% after 2024).

    Small business stock and high-income taxpayers

    The bill would amend Sec. 1202 to disallow the 75% and 100% exclusion of gain from the sale of stock if the taxpayer's AGI is over $400,000 or if the taxpayer is a trust or estate.

    Wash-sale rules

    The bill would amend Sec. 1091 to make commodities, foreign currencies, and cryptoassets subject to the wash-sale rules.

    Net investment income tax

    The bill would amend Sec. 1411 to apply the tax to net investment income derived in the ordinary course of a trade or business for taxpayers with taxable income over $400,000 (single filers), $500,000 (married taxpayers filing jointly or surviving spouses) or $250,000 (married taxpayers filing separately).

    Excess business losses

    The bill would make permanent the Sec. 461 limitation on excess losses of noncorporate taxpayers.

    High-income surcharge
    The bill would create a new Sec. 1A, imposing a surcharge (in addition to any other income tax imposed) on high-income individuals, estates, and trusts. The surcharge tax would equal the sum of 5% of the amount of the taxpayer's AGI that exceeds $10 million ($5 million for married taxpayers filing separately; $200,000 for an estate or trust), plus 3% of the amount of the taxpayer's AGI that exceeds $25 million ($12.5 million for married taxpayers filing separately; $500,000 for an estate or trust).

    Green energy incentives

    The bill covers a wide variety of new and existing green energy incentives, which it generally arranges as two-tiered incentives, providing either a base rate or a bonus rate. The bonus rate is five times the base rate, and it would apply to projects that meet certain prevailing wage and apprenticeship requirements.

    The bill extends the production tax credit for production of energy from renewable sources and the Sec. 48 investment tax credit for certain energy property. The incentive for solar and wind energy under Sec. 48 is increased.

    Taxpayers are given the option to elect to be treated as having made a payment of tax equal to the value of the credit they would otherwise be eligible for under various energy credits, rather than opting to carry the credit forward.

    The bill also provides various other green energy production tax incentives, including a nuclear power production credit and a credit for production of clean hydrogen.

    Individual taxpayers would be eligible for various green energy and energy-efficiency incentives under the bill. The bill extends the Sec. 25C nonbusiness energy property credit to property placed in service before the end of 2031. It also modifies and extends the credit.

    The bill would extend the Sec. 25D credit for residential energy-efficient property through 2033 (it is currently scheduled to expire after 2023). It would a refundable credit for years after 2023. Qualified battery storage technology expenditures would be made eligible for the credit. The Sec. 45L credit for new energy-efficient homes would be extended through 2031 and would be increased and modified.

    The bill extends the Sec. 48C qualified advanced energy property credit through 2031 and provides a new investment tax credit worth up to 25% for advanced manufacturing facilities. The bill also creates a credit for the production of solar polysilicon wafers, cells, and modules and wind blades, nacelles, towers, and offshore wind foundations.

    The bill also creates an emissions-based incentive for electricity generating facilities. Taxpayers are able to choose between a production tax credit under new Sec. 45BB or an investment tax credit under new Sec. 48F.

    The bill also creates a technology-neutral tax credit for the domestic production of clean fuels.

    Electric vehicle tax credits

    The bill provides for a refundable income tax credit of up to $8,500 for new qualified plug-in electric drive motor vehicles. The credit would be available for qualified electric vehicles that cost up to $80,000 (for vans, SUVs, and trucks) or $55,000 (for other vehicles). The bill would also provide a credit of up to $7,500 for two- or three-wheeled plug-in electric vehicles. The credit would phase out for taxpayers with AGI over $500,000 (married taxpayers filing jointly) or $250,000 (single taxpayers). A smaller credit would be available for the purchase of qualifying used electric vehicles. The bill also provides a credit for the purchase of certain new electric bicycles.

    The bill would provide a credit for any qualified commercial electric vehicle placed in service by a taxpayer. The credit would equal up to 30% of the basis of a fully electric vehicle or 15% of the basis of a hybrid vehicle.

    The bill also extends the credit for the purchase of a qualified fuel cell motor vehicle and the alternative fuel vehicle refueling property credit through 2031.

    The bill eliminates the temporary suspension of the exclusion for qualified bicycle commuting benefits and increases the maximum benefit from $20 per month to $81 per month.

    Retirement plans

    The bill prohibits further contributions to a Roth or traditional IRA for a tax year if the contributions would cause the total value of an individual's IRA and defined contribution retirement accounts as of the end of the prior tax year to exceed (or further exceed) $10 million. The limitation would apply to individuals with income over $400,000 (single filers and married filing separately), $425,000 (heads of household), or $450,000 (married taxpayers filing jointly).

    If an individual's combined traditional IRA, Roth IRA, and defined contribution retirement account balances generally exceed $10 million at the end of a tax year and the individual meets these same income thresholds, a minimum distribution would be required for the following year.

    These provisions would be effective for tax years beginning after Dec. 31, 2028.

    The bill prohibits all employee after-tax contributions in qualified plans and after-tax IRA contributions from being converted to a Roth IRA regardless of income level, effective for distributions, transfers, and contributions made after Dec. 31, 2021.

    The bill also eliminates Roth conversions for both IRAs and employer-sponsored plans for single taxpayers (or taxpayers married filing separately) with taxable income over $400,000, married taxpayers filing jointly with taxable income over $450,000, and heads of household with taxable income over $425,000 (all indexed for inflation). This provision applies to distributions, transfers, and contributions made in tax years beginning after Dec. 31, 2031.

    Housing credits

    The bill would increase the 9% housing credit and small state minimums under the low-income housing credit for the years 2022–2025 and makes other changes to the credit. It also creates a new neighborhood homes credit to encourage rehabilitation of deteriorated homes in distressed neighborhoods. The new credit would be administered by the states, and rehabilitated homes would have to be owner occupied in order for investors to receive the credit

    IRS

    The bill would repeal the Sec. 6751(b) requirement for written supervisory approval of IRS penalties. The bill would also provide more funding for IRS enforcement, technology, and customer service.

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