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enrolled in a postsecondary vocational education program offered by the donee,

"(iii) such property is not transferred by the donee in exchange for money, other

property, or services, and

"(iv) the taxpayer receives from the donee a written statement representing that the donee's use and disposition of such property will be in accordance with the provisions of clauses (ii) and (iii).

"(C) POSTSECONDARY VOCATIONAL EDUCATION PROGRAM.-For purposes of this paragraph, the term 'postsecondary vocational education program' means an organized education program which

"(i) is a 2-year program in engineering, mathematics, or the physical or biological sciences, designed to prepare a student to work as a technician or at the semiprofessional level in engineering, scientific, or other technological fields requiring the understanding and application of basic engineering, scientific, or mathematical principles of knowledge, or

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"(ii) is directly related to the preparation of individuals for paid or unpaid employment or for a career which does not require a baccalaureate or advanced degree.".

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(b) EFFECTIVE DATE.-The amendment made by this

6 section shall apply to contributions made after December 31, 7 1982.

8 SEC. 2. POSTSECONDARY VOCATIONAL EDUCATION INSTRUC

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TION CREDIT.

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(a) IN GENERAL.-Subpart A of part IV of subchapter 11 A of chapter 1 of the Internal Revenue Code of 1954 (relat12 ing to credits allowable against tax) is amended by inserting 13 after section 44G the following new section:

14 "SEC. 44H. VOCATIONAL EDUCATION INSTRUCTION CREDIT.

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"(a) IN GENERAL.-There shall be allowed as a credit 16 against the tax imposed by this chapter for the taxable year 17 an amount equal to the sum of

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"(1) the product of

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"(A) $100, multiplied by

"(B) the number of postsecondary vocational education courses taught by qualified teaching em

ployees of the taxpayer during the taxable year,

plus

"(2) the product of—

"(A) $100, multiplied by

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"(B) the number of qualified vocational education instructors who were employed by the taxpayer during the taxable year.

"(b) LIMITATIONS.

"(1) LIMITATION ON THE NUMBER OF COURSES taught per emPLOYEE.-No more than 5 postsecondary vocational education courses taught by the same qualified teaching employee may be taken into account under subsection (a)(1)(B).

"(2) LIMITATION BASED ON AMOUNT OF TAX.—

"(A) IN GENERAL.-Except as provided in subparagraph (B), the credit allowed by subsection (a) for any taxable year shall not exceed the amount of the tax imposed by this chapter for the taxable year reduced by the sum of the credits allowable for the taxable year under a section of this part having a lower number or letter designation than this section, other than the credits allowable by sections 31, 39, and 43. For purposes of the preceding sentence, the term 'tax imposed by this chapter' shall not include any tax treated as not imposed by this chapter under the last sen

tence of section 53(a).

"(B) SPECIAL RULE FOR PASSTHROUGH OF CREDIT. In the case of an individual who

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trust, or

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"(iv) is a shareholder in an electing small business corporation (within the meaning of section 1371(b)),

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the credit allowed by subsection (a) for any taxable year shall not exceed the lesser of the amount determined under subparagraph (A) for the taxable year or an amount (separately computed with respect to such person's interest in such trade or business or entity) equal to the amount of tax attributable to that portion of a person's taxable income which is allocable or apportionable to the person's interest in such trade, business, or entity.

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(c) DEFINITIONS AND SPECIAL RULES.-For purposes 19 of this section

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"(1) POSTSECONDARY VOCATIONAL EDUCATION COURSES. The term 'postsecondary vocational education course' means any course of instruction which"(A) is offered by an institution of higher education as part of an organized education program that—

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"(i) owns an interest in an unincorporat

ed trade or business,

“(ii) is a partner in a partnership,

"(iii) is a beneficiary of an estate or

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“(i) is a 2-year program in engineering, mathematics, or the physical or biological sciences, designed to prepare a student to work as a technician or at the semiprofessional level in engineering, scientific, or other technological fields requiring the understanding and application of basic engineering, scientific, or mathematical principles of knowledge, or

“(ii) is directly related to the preparation of individuals for paid or unpaid employment or for a career which does not require a baccalaureate or advanced degree,

"(B) consists of a period of instruction which is at least equivalent to a course of instruction that provides 3 hours of instruction per week during an academic semester, and

“(C) has been completed before the close of the taxable year.

“(2) QUALIFIED VOCATIONAL EDUCATION IN

STRUCTOR.—The term 'qualified vocational education instructor' means an individual who

"(A) was employed by the taxpayer on a full-time basis for at least 3 months but not more

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