Enhanced deduction for wages paid to automobile manufacturing workers

(a) In general Part VI of subchapter B of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 199B. Wages paid to automobile manufacturing workers (a) In general In the case of any taxable year for which an election is made under subsection (g) by a qualifying taxpayer, there shall be allowed a deduction equal to 200 percent of an amount equal to the total amount of eligible wages paid or incurred by such taxpayer during such taxable year. (b) Qualifying taxpayer For purposes of this section, the term qualifying taxpayer means an entity which, with respect to any taxable year— (1) is engaged in the production of automobiles or automotive components in the United States, (2) with respect to any automobiles, light-duty trucks, and heavy-duty trucks sold by the entity for use in the United States during the preceding taxable year, the final assembly (as defined in section 30D(d)(5)) of not less than 75 percent of such vehicles occurred in the United States, (3) with respect to the manufacturing of finished engines, transmissions, or advanced battery cells (including manufacturing pursuant to joint ventures or other collaborative manufacturing agreements) during the preceding taxable year, not less than 75 percent of such finished engines, transmissions, or advanced battery cells which were incorporated into new automobiles, light-duty trucks, or heavy-duty trucks for sale by the entity were produced in the United States, (4) during the preceding taxable year, did not transfer production outside of the United States of any automobile or automobile component manufactured in the United States, (5) during the preceding taxable year, with respect to all applicable individuals, offered— (A) coverage for the applicable individual under a group health plan in the platinum level of coverage (as described in section 1302(d)(1)(D) of the Patient Protection and Affordable Care Act (42 U.S.C. 18022(d)(1)(D))) or a higher level of coverage, and (B) participation in a defined benefit plan or defined contribution plan that meets the applicable requirement of subsection (e), (6) during the preceding taxable year, with respect to all retired individuals who, prior to retirement, were applicable individuals, offered coverage for the retired individual under a group health plan in the platinum level of coverage (as described in section 1302(d)(1)(D) of the Patient Protection and Affordable Care Act (42 U.S.C. 18022(d)(1)(D))) or a higher level of coverage, (7) with respect to every $1,000,000,000 distributed as non-recurring dividends, or in stock which was redeemed (within the meaning of section 317(b)), by such entity during such taxable year, provided not less than $2,000 to each applicable individual through a profit-sharing plan, with such amount to be in addition to any prior commitment made by the entity pursuant to an existing profit-sharing plan, as determined as of the date of such distribution or redemption, and (8) maintained a neutral position during the preceding taxable year— (A) in any labor organization organizing effort, and (B) with respect to the exercise of employees and labor organizations of their rights under the National Labor Relations Act (29 U.S.C. 151 et seq.). (c) Eligible wages (1) In general For purposes of this section, the term eligible wages means any wages paid or incurred by a qualifying taxpayer during the taxable year to any applicable individual, provided that the wages paid to such individual during such taxable year are not less than the 75th percentile of wages paid for the occupation of the individual (as designated in accordance with the Standard Occupational Classification System) with respect to the applicable 4-digit industry group code of the North American Industry Classification System. (2) Limitation The amount of wages which may be taken into account under subsection (a)(1) with respect to any applicable individual shall not exceed $150,000 per taxable year. (d) Applicable individual For purposes of this section, the term applicable individual means an individual directly engaged in the manufacturing of automobiles or automotive components in the United States. (e) Pension requirements (1) Defined benefit pension plans The requirement described in this subsection with respect to a defined benefit plan is that such plan is projected to provide an applicable individual with not less than 50 percent wage replacement upon retirement, for the entire length of the individual's retirement, provided the applicable individual is employed by the qualifying taxpayer and a participant in the plan for a minimum of 30 years. (2) Defined contribution pension plans The requirement described in this subsection with respect to a defined contribution plan is that such plan is a qualified cash or deferred arrangement as defined in section 401(k) under the terms of which the employer contribution is not less than 10 percent of the participating employee’s wages during the preceding tax year. (f) Denial of deduction for trade or business expenses No deduction shall be allowed under section 162(a) with respect to any wages or contributions taken into account in determining the deduction under subsection (a). (g) Election Subsection (a) shall apply only with respect to such portion of the eligible wages paid or incurred by the qualifying taxpayer, or contributions made by such taxpayer, during the taxable year as are elected by such taxpayer. (h) Certification No deduction shall be allowed under subsection (a) unless the taxpayer submits to the Secretary (at such times and in such manner as the Secretary provides) a certification that the applicable requirements under this section have been satisfied.. (b) Adjusted financial statement income Section 56A(c) of the Internal Revenue Code of 1986 is amended— (1) by redesignating paragraph (15) as paragraph (16), and (2) by inserting after paragraph (14) the following new paragraph: (15) Wages paid to automobile manufacturing workers Adjusted financial statement income shall be— (A) reduced by the deduction for eligible wages allowed under section 199B to the extent of the amount allowed as deductions in computing taxable income for the taxable year, and (B) appropriately adjusted— (i) to disregard any wages taken into account on the taxpayer’s applicable financial statement that were also taken into account in determining the amount of the deduction allowed under section 199B, and (ii) to take into account any other item specified by the Secretary in order to provide that such wages are accounted for in the same manner as accounted for under this chapter.. (c) Clerical amendment The table of sections for part VI of subchapter B of chapter 1 of such Code is amended by adding at the end the following new item: Sec. 199B. Wages paid to automobile manufacturing workers.. (d) Effective date The amendments made by this section shall apply to taxable years beginning after the date of enactment of this Act.