1. On carried interest, applying a blended tax rate and capital characterization during a transition period, but ultimately the compensation will be taxed at ordinary income tax rates. There are no carve outs. The provision is expected to raise $20 billion.
2. No longer allowing companies to "split" foreign tax credits, which is expected to raise $9.5 billion.
3. Giving companies a break on pension funding requirements, which is expected to raise $2 billion.
4. Subchapter S compliance with Medicare tax in case of professional service corporations, which is expected to raise #10 billion.
5. An increase in the oil spill trust fund tax, which is expected to raise $5 billion.
6. Various compliance provisions, which could raise $10 billion.
According to the document, House Ways and Means Chairman Sandy Levin (D-Mich.) also intends to include a modified version of the House-passed small business package in which case additional offsets will be required and may include some unspecified limitations on foreign tax credit of oil and gas companies as well as some additional international tax provisions dealing with "80-20" and dual capacity proposals from President Obama's budget proposal. Levin last night told reporters that Build America Bonds would be included in the package, but details on the provision remained in flux.
The document does not include the ban on treaty shopping, which Ways and Means Chairman Sandy Levin (D-Mich.) told reporters was in the bill.
The Ways and Means Committee did not respond to a request asking to confirm the document.
A vote on the bill could occur a week from today, Wednesday, and travel to the floor under a closed rule. Aside from extending several expired tax breaks, the legislation is also expected to extend unemployment insurance, COBRA, TANF, FMAP, and the so called 'doc fix' until the end of the year.