Mortgage Forgiveness Debt Relief Act of 2007 – Grupos do Google who can claim housing benefit

(a) in general- paragraph (1) of section 108(a) of the internal revenue code of 1986 is amended 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:

`(2) QUALIFIED PRINCIPAL RESIDENCE INDEBTEDNESS- for purposes of this section, the term `qualified principal residence indebtedness’ means acquisition indebtedness (within the meaning of section 163(h)(3)(B), 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.

`(3) EXCEPTION FOR CERTAIN DISCHARGES NOT RELATED TO TAXPAYER’S FINANCIAL CONDITION- subsection (a)(1)(E) 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.Who can claim housing benefit

`(4) ORDERING RULE- if any loan is discharged, in whole or in part, and only a portion of such loan is qualified principal residence indebtedness, subsection (a)(1)(E) shall apply only to so much of the amount discharged as exceeds the amount of the loan (as determined immediately before such discharge) which is not qualified principal residence indebtedness.

`(C) PRINCIPAL RESIDENCE EXCLUSION TAKES PRECEDENCE OVER INSOLVENCY EXCLUSION UNLESS ELECTED OTHERWISE- paragraph (1)(B) shall not apply to a discharge to which paragraph (1)(E) applies unless the taxpayer elects to apply paragraph (1)(B) in lieu of paragraph (1)(E).’.

`(ii) at all times during such taxable year, 80 percent or more of the total square footage of the corporation’s property is used or available for use by the tenant-stockholders for residential purposes or purposes ancillary to such residential use.Who can claim housing benefit

`(iii) 90 percent or more of the expenditures of the corporation paid or incurred during such taxable year are paid or incurred for the acquisition, construction, management, maintenance, or care of the corporation’s property for the benefit of the tenant-stockholders.’.

(a) in general- part III of subchapter B of chapter 1 of the internal revenue code of 1986 (relating to items specifically excluded from gross income) is amended by inserting after section 139A the following new section:

`(2) expenses paid or incurred by the taxpayer in connection with the performance of services as such a member shall be taken into account under section 170 only to the extent such expenses exceed the amount of any qualified payment excluded from gross income under subsection (a).

`(1) QUALIFIED STATE AND LOCAL TAX BENEFIT- the term `qualified state and local tax benefit’ means any reduction or rebate of a tax described in paragraph (1), (2), or (3) of section 164(a) provided by a state or political division thereof on account of services performed as a member of a qualified volunteer emergency response organization.Who can claim housing benefit

`(A) IN GENERAL- the term `qualified payment’ means any payment (whether reimbursement or otherwise) provided by a state or political division thereof on account of the performance of services as a member of a qualified volunteer emergency response organization.

`(B) APPLICABLE DOLLAR LIMITATION- the amount determined under subparagraph (A) for any taxable year shall not exceed $30 multiplied by the number of months during such year that the taxpayer performs such services.

`(I) single parents and their children and such parents are not dependents (as defined in section 152, determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof) of another individual and such children are not dependents (as so defined) of another individual other than a parent of such children, or.’ .

(2) buildings placed in service before, on, or after such date to the extent paragraph (1) of section 42(h) of the internal revenue code of 1986 does not apply to any building by reason of paragraph (4) thereof.Who can claim housing benefit

`(4) SPECIAL RULE FOR CERTAIN SALES BY SURVIVING SPOUSES- in the case of a sale or exchange of property by an unmarried individual whose spouse is deceased on the date of such sale, paragraph (1) shall be applied by substituting `$500,000′ for `$250,000′ if such sale occurs not later than 2 years after the date of death of such spouse and the requirements of paragraph (2)(A) were met immediately before such date of death.’.

`(10) LIMITATION ON CERTAIN DISCLOSURES UNDER THIS SUBSECTION- in the case of an inspection or disclosure under this subsection relating to the return of a partnership, S corporation, trust, or an estate, the information inspected or disclosed shall not include any supporting schedule, attachment, or list which includes the taxpayer identity information of a person other than the entity making the return or the person conducting the inspection or to whom the disclosure is made.’.Who can claim housing benefit

`(a) general rule- in addition to the penalty imposed by section 7203 (relating to willful failure to file return, supply information, or pay tax), if any S corporation required to file a return under section 6037 for any taxable year–

Such S corporation shall be liable for a penalty determined under subsection (b) for each month (or fraction thereof) during which such failure continues (but not to exceed 12 months), unless it is shown that such failure is due to reasonable cause.

`(d) deficiency procedures not to apply- subchapter B of chapter 63 (relating to deficiency procedures for income, estate, gift, and certain excise taxes) shall not apply in respect of the assessment or collection of any penalty imposed by subsection (a).’.

The percentage under subparagraph (B) of section 401(1) of the tax increase prevention and reconciliation act of 2005 in effect on the date of the enactment of this act is increased by 1.50 percentage points.Who can claim housing benefit