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H.R. 6776, JOBS Credit Act of 2020

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Bills Bills 116Hr6776Ih Bills 116Hr6776Ih
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Bills Bills 116Hr6776Ih Bills 116Hr6776Ih

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                                                                                                                                                                          I




                                                                       116TH CONGRESS
                                                                          2D SESSION
                                                                                                            H. R. 6776
                                                                           To provide for improvements related to the employee retention tax credit.




                                                                                    IN THE HOUSE OF REPRESENTATIVES
                                                                                                         MAY 8, 2020
                                                                       Mrs. MURPHY of Florida (for herself, Mr. KATKO, Ms. DELBENE, Mr.
                                                                           FITZPATRICK, and Mr. PAPPAS) introduced the following bill; which was
                                                                           referred to the Committee on Ways and Means, and in addition to the
                                                                           Committee on Small Business, for a period to be subsequently determined
                                                                           by the Speaker, in each case for consideration of such provisions as fall
                                                                           within the jurisdiction of the committee concerned




                                                                                                                 A BILL
                                                                               To provide for improvements related to the employee
                                                                                               retention tax credit.

                                                                         1              Be it enacted by the Senate and House of Representa-
                                                                         2 tives of the United States of America in Congress assembled,
                                                                         3    SECTION 1. SHORT TITLE.

                                                                         4              This Act may be cited as the ‘‘Jumpstarting Our
                                                                         5 Businesses’ Success Credit Act of 2020’’ or as the ‘‘JOBS
                                                                         6 Credit Act of 2020’’.




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                                                                         1    SEC. 2. IMPROVEMENTS TO EMPLOYEE RETENTION CRED-

                                                                         2                             IT.

                                                                         3              (a) INCREASE IN CREDIT PERCENTAGE.—Section
                                                                         4 2301(a) of the CARES Act is amended by striking ‘‘50
                                                                         5 percent’’ and inserting ‘‘80 percent’’.
                                                                         6              (b) INCREASE IN PER EMPLOYEE LIMITATION.—Sec-
                                                                         7 tion 2301(b)(1) of the CARES Act is amended by striking
                                                                         8 ‘‘for all calendar quarters shall not exceed $10,000.’’ and
                                                                         9 inserting ‘‘shall not exceed—
                                                                       10                                  ‘‘(A) $15,000 in any calendar quarter, and
                                                                       11                                  ‘‘(B) $45,000 in the aggregate for all cal-
                                                                       12                        endar quarters.’’.
                                                                       13               (c) MODIFICATION OF THRESHOLD FOR TREATMENT
                                                                       14     AS A LARGE EMPLOYER.—

                                                                       15                        (1) IN GENERAL.—Section 2301(c)(3)(A) of the
                                                                       16               CARES Act is amended—
                                                                       17                                  (A) by striking ‘‘for which the average
                                                                       18                        number of full-time employees (within the
                                                                       19                        meaning of section 4980H of the Internal Rev-
                                                                       20                        enue Code of 1986) employed by such eligible
                                                                       21                        employer during 2019 was greater than 100’’ in
                                                                       22                        clause (i) and inserting ‘‘which is a large em-
                                                                       23                        ployer’’, and
                                                                       24                                  (B) by striking ‘‘for which the average




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                                                                       25                        number of full-time employees (within the
                                                                       26                        meaning of section 4980H of the Internal Rev-
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                                                                         1                       enue Code of 1986) employed by such eligible
                                                                         2                       employer during 2019 was not greater than
                                                                         3                       100’’ in clause (ii) and inserting ‘‘which is not
                                                                         4                       a large employer’’.
                                                                         5                       (2)        LARGE            EMPLOYER                 DEFINED.—Section

                                                                         6              2301(c) of the CARES Act is amended by redesig-
                                                                         7              nating paragraph (6) as paragraph (7) and by in-
                                                                         8              serting after paragraph (5) the following new para-
                                                                         9              graph:
                                                                       10                        ‘‘(6) LARGE EMPLOYER.—The term ‘large em-
                                                                       11               ployer’ means any eligible employer if—
                                                                       12                                  ‘‘(A) the average number of full-time em-
                                                                       13                        ployees (as determined for purposes of deter-
                                                                       14                        mining whether an employer is an applicable
                                                                       15                        large         employer               for       purposes              of    section
                                                                       16                        4980H(c)(2) of the Internal Revenue Code of
                                                                       17                        1986) employed by such eligible employer dur-
                                                                       18                        ing calendar year 2019 was greater than 1,500,
                                                                       19                        and
                                                                       20                                  ‘‘(B) the gross receipts (within the mean-
                                                                       21                        ing of section 448(c) of the Internal Revenue
                                                                       22                        Code of 1986) of such eligible employer during
                                                                       23                        calendar              year           2019         was            greater     than




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                                                                       24                        $41,500,000.’’.




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                                                                         1              (d) PHASE-IN OF ELIGIBILITY BASED ON REDUC-
                                                                         2    TION IN GROSS RECEIPTS.—

                                                                         3                       (1) DECREASE OF REDUCTION IN GROSS RE-
                                                                         4              CEIPTS NECESSARY TO QUALIFY FOR CREDIT.—Sec-

                                                                         5              tion 2301(c)(2)(B)(i) of the CARES Act is amended
                                                                         6              by striking ‘‘50 percent’’ and inserting ‘‘80 per-
                                                                         7              cent’’.
                                                                         8                       (2) PHASE-IN OF CREDIT IF REDUCTION IN
                                                                         9              GROSS RECEIPTS IS LESS THAN 50 PERCENT.—Sec-

                                                                       10               tion 2301(c)(2) of the CARES Act is amended by
                                                                       11               adding at the end the following new subparagraph:
                                                                       12                                  ‘‘(D) PHASE-IN OF CREDIT WHERE BUSI-
                                                                       13                        NESS        NOT        SUSPENDED                 AND        REDUCTION    IN

                                                                       14                        GROSS RECEIPTS LESS THAN 50 PERCENT.—

                                                                       15                                         ‘‘(i) IN GENERAL.—In the case of any
                                                                       16                                  calendar quarter with respect to which an
                                                                       17                                  eligible employer would not be an eligible
                                                                       18                                  employer if subparagraph (B)(i) were ap-
                                                                       19                                  plied by substituting ‘50 percent’ for ‘80
                                                                       20                                  percent’, the amount of the credit allowed
                                                                       21                                  under subsection (a) shall be reduced by
                                                                       22                                  the amount which bears the same ratio to
                                                                       23                                  the amount of such credit (determined




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                                                                       24                                  without regard to this subparagraph) as—




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                                                                         1                                                 ‘‘(I) the excess gross receipts per-
                                                                         2                                        centage point amount, bears to
                                                                         3                                                 ‘‘(II) 30 percentage points.
                                                                         4                                        ‘‘(ii) EXCESS GROSS RECEIPTS PER-
                                                                         5                                 CENTAGE POINT AMOUNT.—For                                      purposes
                                                                         6                                 of this subparagraph, the term ‘excess
                                                                         7                                 gross receipts percentage point amount’
                                                                         8                                 means, with respect to any calendar quar-
                                                                         9                                 ter, the excess of—
                                                                       10                                                  ‘‘(I) the lowest of the gross re-
                                                                       11                                         ceipts percentage point amounts de-
                                                                       12                                         termined with respect to any calendar
                                                                       13                                         quarter during the period ending with
                                                                       14                                         such calendar quarter and beginning
                                                                       15                                         with the first calendar quarter during
                                                                       16                                         the period described in subparagraph
                                                                       17                                         (B), over
                                                                       18                                                  ‘‘(II) 50 percentage points.
                                                                       19                                         ‘‘(iii) GROSS RECEIPTS PERCENTAGE
                                                                       20                                  POINT AMOUNTS.—For                            purposes of this
                                                                       21                                  subparagraph, the term ‘gross receipts per-
                                                                       22                                  centage point amount’ means, with respect
                                                                       23                                  to any calendar quarter, the percentage




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                                                                       24                                  (expressed as a number of percentage
                                                                       25                                  points) obtained by dividing—


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                                                                         1                                                 ‘‘(I) the gross receipts (within
                                                                         2                                        the meaning of subparagraph (B)) for
                                                                         3                                        such calendar quarter, by
                                                                         4                                                 ‘‘(II) the gross receipts for the
                                                                         5                                        same calendar quarter in calendar
                                                                         6                                        year 2019.’’.
                                                                         7                       (3) GROSS RECEIPTS OF TAX-EXEMPT ORGANI-
                                                                         8              ZATIONS.—Section 2301(c)(2)(C) of the CARES Act

                                                                         9              is amended—
                                                                       10                                  (A) by striking ‘‘of such Code, clauses (i)
                                                                       11                        and (ii)(I)’’ and inserting ‘‘of such Code—
                                                                       12                                         ‘‘(i) clauses (i) and (ii)(I)’’,
                                                                       13                                  (B) by striking the period at the end and
                                                                       14                        inserting ‘‘, and’’, and
                                                                       15                                  (C) by adding at the end the following new
                                                                       16                        clause:
                                                                       17                                         ‘‘(ii) any reference in this section to
                                                                       18                                  gross receipts shall be treated as a ref-
                                                                       19                                  erence to gross receipts within the meaning
                                                                       20                                  of section 6033 of such Code.’’.
                                                                       21               (e) MODIFICATION                      OF       TREATMENT                  OF      HEALTH
                                                                       22 PLAN EXPENSES.—
                                                                       23                        (1) IN GENERAL.—Section 2301(c)(5) of the




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                                                                       24               CARES Act is amended to read as follows:
                                                                       25                        ‘‘(5) WAGES.—


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                                                                         1                                 ‘‘(A) IN           GENERAL.—The                        term ‘wages’
                                                                         2                       means wages (as defined in section 3121(a) of
                                                                         3                       the Internal Revenue Code of 1986) and com-
                                                                         4                       pensation (as defined in section 3231(e) of such
                                                                         5                       Code).
                                                                         6                                 ‘‘(B) ALLOWANCE FOR CERTAIN HEALTH
                                                                         7                       PLAN EXPENSES.—

                                                                         8                                        ‘‘(i) IN GENERAL.—Such term shall
                                                                         9                                 include amounts paid or incurred by the el-
                                                                       10                                  igible employer to provide and maintain a
                                                                       11                                  group health plan (as defined in section
                                                                       12                                  5000(b)(1) of the Internal Revenue Code
                                                                       13                                  of 1986), but only to the extent that such
                                                                       14                                  amounts are excluded from the gross in-
                                                                       15                                  come of employees by reason of section
                                                                       16                                  106(a) of such Code.
                                                                       17                                         ‘‘(ii) ALLOCATION RULES.—For pur-
                                                                       18                                  poses of this section, amounts treated as
                                                                       19                                  wages under clause (i) shall be treated as
                                                                       20                                  paid with respect to any employee (and
                                                                       21                                  with respect to any period) to the extent
                                                                       22                                  that such amounts are properly allocable to
                                                                       23                                  such employee (and to such period) in such




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                                                                       24                                  manner as the Secretary may prescribe.
                                                                       25                                  Except as otherwise provided by the Sec-


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                                                                         1                                 retary, such allocation shall be treated as
                                                                         2                                 properly made if made on the basis of
                                                                         3                                 being pro rata among periods of cov-
                                                                         4                                 erage.’’.
                                                                         5                       (2)          CONFORMING                        AMENDMENT.—Section

                                                                         6              2301(c)(3) of the CARES Act is amended by strik-
                                                                         7              ing subparagraph (C).
                                                                         8              (f) QUALIFIED WAGES PERMITTED TO INCLUDE
                                                                         9 AMOUNTS FOR TIP REPLACEMENT.—
                                                                       10                        (1) IN GENERAL.—Section 2301(c)(3)(B) of the
                                                                       11               CARES Act is amended by inserting ‘‘(including tips
                                                                       12               which would have been deemed to be paid by the em-
                                                                       13               ployer under section 3121(q))’’ after ‘‘would have
                                                                       14               been paid’’.
                                                                       15                        (2)          CONFORMING                        AMENDMENT.—Section

                                                                       16               2301(h)(2) of the CARES Act is amended by insert-
                                                                       17               ing ‘‘45B or’’ before ‘‘45S’’.
                                                                       18               (g) CERTAIN GOVERNMENTAL EMPLOYERS ELIGIBLE
                                                                       19     FOR CREDIT.—

                                                                       20                        (1) IN           GENERAL.—Section                         2301(f) of the
                                                                       21               CARES Act is amended to read as follows:
                                                                       22               ‘‘(f) CERTAIN GOVERNMENTAL EMPLOYERS.—
                                                                       23                        ‘‘(1) IN GENERAL.—The credit under this sec-




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                                                                       24               tion shall not be allowed to the Federal Government
                                                                       25               or any agency or instrumentality thereof.


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                                                                         1                       ‘‘(2) EXCEPTION.—Paragraph (1) shall not
                                                                         2              apply to any organization described in section
                                                                         3              501(c)(1) of the Internal Revenue Code of 1986 and
                                                                         4              exempt from tax under section 501(a) of such Code.
                                                                         5                       ‘‘(3) SPECIAL RULES.—In the case of any State
                                                                         6              government, Indian tribal government, or any agen-
                                                                         7              cy, instrumentality, or political subdivision of the
                                                                         8              foregoing—
                                                                         9                                 ‘‘(A) clauses (i) and (ii)(I) of subsection
                                                                       10                        (c)(2)(A) shall apply to all operations of such
                                                                       11                        entity, and
                                                                       12                                  ‘‘(B)        subclause                (II)        of           subsection
                                                                       13                        (c)(2)(A)(ii) shall not apply.’’.
                                                                       14                        (2) COORDINATION WITH APPLICATION OF CER-
                                                                       15               TAIN DEFINITIONS.—

                                                                       16                                  (A) IN GENERAL.—Section 2301(c)(5)(A)
                                                                       17                        of the CARES Act, as amended by the pre-
                                                                       18                        ceding provisions of this Act, is amended by
                                                                       19                        adding at the end the following: ‘‘For purposes
                                                                       20                        of the preceding sentence (other than for pur-
                                                                       21                        poses of subsection (b)(2)), wages as defined in
                                                                       22                        section 3121(a) of the Internal Revenue Code
                                                                       23                        of 1986 shall be determined without regard to




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                                                                       24                        paragraphs (1), (5), (6), (7), (8), (10), (13),
                                                                       25                        (18), (19), and (22) of section 3212(b) of such


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                                                                         1                       Code (except with respect to services performed
                                                                         2                       in a penal institution by an inmate thereof).’’.
                                                                         3                                 (B)         CONFORMING                  AMENDMENTS.—Sec-

                                                                         4                       tions 2301(c)(6) of the CARES Act is amended
                                                                         5                       by striking ‘‘Any term’’ and inserting ‘‘Except
                                                                         6                       as otherwise provided in this section, any
                                                                         7                       term’’.
                                                                         8              (h) EFFECTIVE DATE.—The amendments made by
                                                                         9 this section shall take effect as if included in section 2301
                                                                       10 of the CARES Act.
                                                                       11     SEC. 3. IMPROVED COORDINATION BETWEEN PAYCHECK

                                                                       12                              PROTECTION PROGRAM AND EMPLOYEE RE-

                                                                       13                              TENTION TAX CREDIT.

                                                                       14               (a) AMENDMENT TO PAYCHECK PROTECTION PRO-
                                                                       15     GRAM.—Section 1106(a)(8) of the CARES Act is amended

                                                                       16 by inserting ‘‘, except that such costs shall not include
                                                                       17 qualified wages taken into account in determining the
                                                                       18 credit allowed under section 2301 of this Act’’ before the
                                                                       19 period at the end.
                                                                       20               (b) AMENDMENTS TO EMPLOYEE RETENTION TAX
                                                                       21 CREDIT.—
                                                                       22                        (1) IN           GENERAL.—Section                        2301(g) of the
                                                                       23               CARES Act is amended to read as follows:




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                                                                       24               ‘‘(g) ELECTION TO NOT TAKE CERTAIN WAGES
                                                                       25 INTO ACCOUNT.—


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                                                                         1                       ‘‘(1) IN GENERAL.—This section shall not apply
                                                                         2              to qualified wages paid by an eligible employer with
                                                                         3              respect to which such employer makes an election
                                                                         4              (at such time and in such manner as the Secretary
                                                                         5              may prescribe) to have this section not apply to such
                                                                         6              wages.
                                                                         7                       ‘‘(2) COORDINATION WITH PAYCHECK PROTEC-
                                                                         8              TION        PROGRAM.—The                      Secretary, in consultation
                                                                         9              with the Administrator of the Small Business Ad-
                                                                       10               ministration, shall issue guidance providing that
                                                                       11               payroll costs paid or incurred during the covered pe-
                                                                       12               riod shall not fail to be treated as qualified wages
                                                                       13               under this section by reason of an election under
                                                                       14               paragraph (1) to the extent that a covered loan of
                                                                       15               the eligible employer is not forgiven by reason of a
                                                                       16               decision under section 1106(g). Terms used in the
                                                                       17               preceding sentence which are also used in section
                                                                       18               1106 shall have the same meaning as when used in
                                                                       19               such section.’’.
                                                                       20                        (2) CONFORMING AMENDMENTS.—
                                                                       21                                  (A) Section 2301 of the CARES Act is
                                                                       22                        amended by striking subsection (j).
                                                                       23                                  (B) Section 2301(l) of the CARES Act is




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                                                                       24                        amended by striking paragraph (3) and by re-




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                                                                         1                       designating paragraphs (4) and (5) as para-
                                                                         2                       graphs (3) and (4), respectively.
                                                                         3              (c) EFFECTIVE DATE.—The amendments made by
                                                                         4 this section shall take effect as if included in the provisions
                                                                         5 of the CARES Act to which they relate.
                                                                                                                              Æ




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