17144.
(a) Section 108(b)(2)(B) of the Internal Revenue Code, relating to general business credit, is modified by substituting “this part” in lieu of “Section 38 (relating to general business credit).”(b) Section 108(b)(2)(G) of the Internal Revenue Code, relating to foreign tax credit carryovers, shall not apply.
(c) Section 108(b)(3)(B) of the Internal Revenue Code, relating to credit carryover reduction, is modified by substituting “11.1 cents” in lieu of “331/3 cents” in each place in which it appears. In the case where more than one credit is allowable under this part, the credits shall be reduced on a pro rata basis.
(d) Section 108(g)(3)(B) of the Internal Revenue Code, relating to adjusted tax attributes, is modified by substituting “($9)” in lieu of “($3).”
(e) (1) If a taxpayer makes an election for federal income tax purposes under Section 108(c) of the Internal Revenue Code, relating to treatment of discharge of qualified real property business indebtedness, a separate election shall not be allowed under paragraph (3) of subdivision (e) of Section 17024.5 and the federal election shall be binding for purposes of this part.
(2) If a taxpayer has not made an election for federal income tax purposes under Section 108(c) of the Internal Revenue Code, relating to treatment of discharge of qualified real property business indebtedness, then the taxpayer shall not be allowed to make that election for purposes of this part.
(f) (1) Section 108(i) Paragraph (1) of Section 108(a) of the Internal Revenue Code, relating to deferral and ratable inclusion of income arising from business indebtedness discharged by the reacquisition of a debt instrument, shall not apply. Code is modified by striking “or” at the end of subparagraph (C), by striking the period at the end of subparagraph (D) and inserting “, or” and by inserting after subparagraph (D) the following new subparagraph:
(E) The indebtedness discharged is qualified principal residence indebtedness which is discharged before January 1, 2010.
(2) For purposes of this section, the term “qualified principal residence indebtedness” means acquisition indebtedness (within the meaning of Section 163 (h)(3)(B) of the Internal Revenue Code, applied by substituting “$2,000,000 ($1,000,000” for “$1,000,000 ($500,000” in clause (ii) thereof) with respect to the principal residence of the taxpayer.
(g) For purposes of this section, all of the following rules shall apply:
(1) The amount excluded from gross income by reason of Section 108(a)(1)(E) of the Internal Revenue Code shall be applied to reduce (but not below zero) the basis of the principal residence of the taxpayer.
(2) Section 108(a)(1)(E) of the Internal Revenue Code shall not apply to the discharge of a loan if the discharge is on account of services performed for the lender or any other factor not directly related to a decline in the value of the residence or to the financial condition of the taxpayer.
(3) If any loan is discharged, in whole or in part, and only a portion of that loan is qualified principal residence indebtedness, Section 108(a)(1)(E) of the Internal Revenue Code shall apply only to so much of the amount discharged as exceeds the amount of the loan (as determined immediately before such discharge) that is not qualified principal residence indebtedness.
(4) The term “principal residence” has the same meaning as when used in Section 121 of the Internal Revenue Code.
(h) (1) Section 108(a)(2)(A) of the Internal Revenue Code is modified by substituting “(D), and (E)” in lieu of “and D.”
(2) Section 108(a)(1)(B) of the Internal Revenue Code shall not apply to a discharge to which Section 108(a)(1)(E) of the Internal Revenue Code, as modified by this section, applies unless the taxpayer elects to apply paragraph (1)(B) of Section 108(a) of the Internal Revenue Code in lieu of paragraph (1)(E) of Section 108(a) of the Internal Revenue Code.
(i) The amendments to this section by the act adding this subdivision shall apply to discharges of indebtedness that occur on or after January 1, 2007.