text: SECTION 1. SHORT TITLE; FINDINGS.
  
      (a) Short Title.--This Act may be cited as the ``Investing in Our 
  Future Act of 2011''.
      (b) Findings.--Congress finds the following:
              (1) While Wall Street continues to reap massive profits, 
          the 2008 global economic crisis they helped cause has 
          destabilized economies and impacted the budgets of the United 
          States and impoverished nations, compromising the ability of 
          governments to address pressing needs.
              (2) The scope of the financial crisis distorted our 
          national deficit. The Congressional Budget Office estimates 
          that Federal deficit spending is now at a record $1.5 trillion.
              (3) Millions of people around the world have been pushed 
          into poverty because of the global financial crisis, through no 
          fault of their own.
              (4) The impacts of climate change, disease, and ill health 
          undermine the economies of developing nations and their ability 
          to contribute to a secure, stable world.
              (5) Predictable, adequate, sustainable, long-term, public 
          funding to address global health and climate change in 
          developing countries at the scale needed does not currently 
          exist but it is urgently needed.
              (6) Cutting vital domestic programs such as education, 
          health care, and nutrition assistance to reduce the national 
          debt will have a harmful impact on the long-term prosperity of 
          the country. Alternative revenue generating mechanisms must be 
          considered to reduce the national debt and meet international 
          development and climate needs.
              (7) The financial institutions that caused the financial 
          crisis should play a significant role in providing funds that 
          will help developing countries mitigate and adapt to climate 
          change, fight global HIV/AIDS, improve maternal and child 
          health in impoverished nations, and reduce the national 
          deficit.
              (8) Currency speculation by financial institutions has 
          destabilizing impacts on the real economy and can contribute to 
          financial crises.
              (9) In 2008, $4 trillion in daily currency transactions 
          were undertaken, nearly 80 percent of which by a few major 
          banks, without taxation.
              (10) A tax on the currency market would be paid by these 
          same banks that caused the financial crisis and would generate 
          funds to help reduce our deficit.
              (11) A small levy on currency would curb some speculative 
          transactions, bringing greater stability into the currency 
          market.
              (12) Collection of a small tax would not disrupt legitimate 
          trading in the currency trading markets and would have no 
          significant impact on individual travelers or United States 
          corporations doing business.
              (13) The Secretary of State, Secretary of the Treasury, and 
          the nations in the Organization for Economic Cooperation and 
          Development should work together to implement a broader 
          currency transaction tax to reduce the Federal deficit and fund 
          global health, poverty, and climate change initiatives.
  
  SEC. 2. EXCISE TAX ON CURRENCY TRANSACTIONS.
  
      (a) In General.--Chapter 36 of the Internal Revenue Code of 1986 is 
  amended by inserting after subchapter B the following new subchapter:
  
                   ``Subchapter C--Currency Transactions
  
  ``Sec. 4475. Currency transactions.
  
  ``SEC. 4475. CURRENCY TRANSACTIONS.
  
      ``(a) In General.--There is hereby imposed a tax on each currency 
  transaction made by, or on behalf of, a United States person.
      ``(b) Exception for Low-Value Transactions.--
              ``(1) In general.--Subsection (a) shall not apply to any 
          currency transaction made by, or on behalf of, a United States 
          person, if the aggregate value of the currencies acquired by 
          such person in all such transactions made during the calendar 
          year does not exceed $10,000.
              ``(2) Coordination with withholding rules.--Subsection 
          (e)(2) shall not apply to any currency transaction unless the 
          value of the currency acquired by the United States person in 
          such transaction exceeds $10,000. The preceding sentence shall 
          not apply if the person who facilitates such currency 
          transaction knows, or has reason to know, that the exception 
          provided by paragraph (1) does not apply to such transaction.
      ``(c) Amount of Tax.--
              ``(1) In general.--The amount of the tax imposed under 
          subsection (a) with respect to any currency transaction shall 
          be equal to 0.005 percent of the value of the currency acquired 
          in the transaction.
              ``(2) Special rule for currency derivatives.--In the case 
          of any currency derivative, the value of the currency acquired 
          in the transaction shall be treated for purposes of this 
          section as being equal to--
                      ``(A) in the case of a forward contract, the value 
                  of the currency purchased or sold forward,
                      ``(B) in the case of a notional principal contract, 
                  the value of the notional principal amount of the 
                  contract,
                      ``(C) in the case of an option, the value of the 
                  currency that would be acquired in the event the option 
                  were exercised, and
                      ``(D) in the case of any other currency derivative, 
                  the value as determined by the Secretary.
              ``(3) Valuation of currency.--For purposes of this section, 
          the valuation of any currency shall be determined in the 
          taxpayer's functional currency (within the meaning of section 
          985) at the spot rate on the date of the transaction.
      ``(d) Currency Transaction.--For purposes of this section--
              ``(1) In general.--The term `currency transaction' means--
                      ``(A) the exchange of any currency for another 
                  currency, and
                      ``(B) entering into any currency derivative.
              ``(2) Currency derivative.--The term `currency derivative' 
          means--
                      ``(A) any currency notional principal contract, and
                      ``(B) any option, forward contract, short position, 
                  hedge, or similar financial instrument with respect to 
                  any currency or currency notional principal contract.
      ``(e) Liability for Tax; Withholding.--
              ``(1) Liability for tax.--The tax imposed under subsection 
          (a) with respect to any currency transaction shall be paid by 
          the United States person referred to in subsection (a). Such 
          person shall be allowed a credit against such tax in the amount 
          withheld as tax under paragraph (2) with respect to such 
          transaction.
              ``(2) Withholding by currency transaction facilitators.--
                      ``(A) In general.--Except as provided in 
                  subparagraph (B), each United States person which 
                  facilitates a currency transaction by, or on behalf of, 
                  a United States person shall deduct and withhold from 
                  the amount involved in such transaction a tax equal to 
                  the amount of the tax imposed under section 4475 with 
                  respect to such transaction.
                      ``(B) Amounts withheld only once.--The Secretary 
                  shall prescribe regulations or other guidance to ensure 
                  that only one United States person deducts and 
                  withholds the amount described in subparagraph (A) with 
                  respect to each currency transaction. Such regulations 
                  or other guidance shall (subject to such exceptions as 
                  the Secretary may prescribe) require--
                              ``(i) in the case of a currency transaction 
                          which is confirmed and matched by a United 
                          States person, that such person so deduct and 
                          withhold such amount, and
                              ``(ii) in the case of a currency 
                          transaction not described in clause (i) which 
                          is settled by a United States person, that such 
                          person so deduct and withhold such amount.
              ``(3) Coordination with other sections.--For purposes of so 
          much of subtitle F (other than section 7205) as relates to 
          chapter 24, amounts which are subject to withholding under 
          paragraph (2) shall be treated as if they were wages paid by an 
          employer to an employee (and amounts deducted and withheld 
          under paragraph (2) shall be treated as if deducted and 
          withheld under section 3402).
      ``(f) Application to Expanded Affiliated Groups.--
              ``(1) In general.--For purposes of this section, all 
          members of the same expanded affiliated group shall be treated 
          as one person for purposes of this section.
              ``(2) Expanded affiliated group.--For purposes of this 
          subsection, the term `expanded affiliated group' means an 
          affiliated group as defined in section 1504(a), determined--
                      ``(A) by substituting `more than 50 percent' for 
                  `at least 80 percent' each place it appears, and
                      ``(B) without regard to paragraphs (2) and (3) of 
                  section 1504(b).
          A partnership or any other entity (other than a corporation) 
          shall be treated as a member of an expanded affiliated group if 
          such entity is controlled (within the meaning of section 
          954(d)(3)) by members of such group (including any entity 
          treated as a member of such group by reason of this 
          sentence).''.
      (b) Clerical Amendment.--The table of subchapters for chapter 36 of 
  such Code is amended by inserting after the item relating to subchapter 
  B the following new item:
  
                  ``subchapter c. currency transactions''.
  
      (c) Effective Date.--The amendments made by this section shall 
  apply to transactions after December 31, 2011.
  
  SEC. 3. FUNDING FOR CHILD CARE.
  
      (a) Child Care Assistance Trust Fund.--
              (1) In general.--There is established in the Treasury of 
          the United States a trust fund to be known as the ``Child Care 
          Assistance Trust Fund'', consisting of such amounts as may be 
          appropriated or credited to the Child Care Assistance Trust 
          Fund as provided in this section.
              (2) Transfer to trust fund of amounts equivalent to certain 
          taxes.--There are hereby appropriated to the Child Care 
          Assistance Trust Fund, out of any money in the Treasury not 
          otherwise appropriated, amounts equivalent to 10 percent of the 
          taxes received in the Treasury under section 4475 of the 
          Internal Revenue Code of 1986.
              (3) Expenditures from trust fund.--Amounts in the Child 
          Care Assistance Trust Fund shall be available, as provided by 
          appropriation Acts, for making expenditures to carry out 
          subsection (b).
              (4) Management of trust fund.--For purposes of subchapter B 
          of chapter 98 of the Internal Revenue Code of 1986, the 
          provisions of this subsection shall be treated as provisions of 
          subchapter A of such chapter.
      (b) Child Care Assistance Grants.--
              (1) In general.--Any appropriation under subsection (a)(3) 
          from the Child Care Assistance Trust Fund shall be allocated 
          among the States as an increase in the amount determined under 
          section 418(a)(1) of the Social Security Act in the same 
          proportion as the amount determined under such section with 
          respect to such State (determined without regard to this 
          subsection) bears to the aggregate amounts so determined with 
          respect to all of the States.
              (2) Funding to be additional.--It is the sense of the 
          Congress that amounts made available under this subsection 
          shall be in addition to (and shall not be a replacement for) 
          other funding for child care assistance.
  
  SEC. 4. MULTILATERAL GLOBAL HEALTH PROGRAMS.
  
      (a) Multilateral Global Health Trust Fund.--
              (1) In general.--There is established in the Treasury of 
          the United States a trust fund to be known as the 
          ``Multilateral Global Health Trust Fund'', consisting of such 
          amounts as may be appropriated or credited to the Multilateral 
          Global Health Trust Fund as provided in this section.
              (2) Transfer to trust fund of amounts equivalent to certain 
          taxes.--There are hereby appropriated to the Multilateral 
          Global Health Trust Fund, out of any money in the Treasury not 
          otherwise appropriated, amounts equivalent to 25 percent of the 
          taxes received in the Treasury under section 4475 of the 
          Internal Revenue Code of 1986.
              (3) Expenditures from trust fund.--Amounts in the 
          Multilateral Global Health Trust Fund shall be available, as 
          provided by appropriation Acts, for making expenditures to 
          carry out subsection (b).
              (4) Management of trust fund.--For purposes of subchapter B 
          of chapter 98 of the Internal Revenue Code of 1986, the 
          provisions of this subsection shall be treated as provisions of 
          subchapter A of such chapter.
      (b) Multilateral Global Health Grant Program.--
              (1) In general.--The Secretary of State shall make grants 
          to assist developing countries in addressing HIV/AIDS, 
          tuberculosis, malaria, maternal mortality, family planning, 
          neglected diseases, and other health issues affecting 
          developing countries.
              (2) Eligibility for grants.--Grants under paragraph (1) may 
          be made to--
                      (A) the Global Fund to Fight AIDS, Tuberculosis and 
                  Malaria to provide grants described in paragraph (1), 
                  and
                      (B) other multilateral health funding mechanisms 
                  which the Secretary certifies--
                              (i) provide a significant majority of their 
                          total funding to programs in the form of 
                          grants,
                              (ii) include independent and external 
                          technical review of programs in the awarding of 
                          funding,
                              (iii) include governance structures that 
                          involve donor governments, implementing 
                          governments, civil society, and affected 
                          communities as equal decisionmakers,
                              (iv) provide funding based on plans 
                          developed by implementing countries through 
                          country-level processes that include equal and 
                          meaningful involvement of civil society and 
                          impacted communities,
                              (v) require measures of performance of all 
                          projects and formal mechanisms that condition 
                          continued financing on successful performance 
                          and outcomes, and
                              (vi) include mechanisms for strict 
                          financial accountability and provides 
                          transparency of all decisions, evaluations, and 
                          finances through publically accessible 
                          documents.
              (3) Funding to be additional.--It is the sense of the 
          Congress that grants made under this subsection shall be in 
          addition to (and shall not be a replacement for) other funding 
          for global health initiatives in developing countries.
  
  SEC. 5. GLOBAL CLIMATE CHANGE ADAPTATION AND MITIGATION.
  
      (a) Global Climate Change Adaptation and Mitigation Trust Fund.--
              (1) In general.--There is established in the Treasury of 
          the United States a trust fund to be known as the ``Global 
          Climate Change Adaptation and Mitigation Trust Fund'', 
          consisting of such amounts as may be appropriated or credited 
          to the Global Climate Change Adaptation and Mitigation Trust 
          Fund as provided in this section.
              (2) Transfer to trust fund of amounts equivalent to certain 
          taxes.--There are hereby appropriated to the Global Climate 
          Change Adaptation and Mitigation Trust Fund, out of any money 
          in the Treasury not otherwise appropriated, amounts equivalent 
          to 25 percent of the taxes received in the Treasury under 
          section 4475 of the Internal Revenue Code of 1986.
              (3) Expenditures from trust fund.--Amounts in the Global 
          Climate Change Adaptation and Mitigation Trust Fund shall be 
          available, as provided by appropriation Acts, for making 
          expenditures to carry out subsection (b).
              (4) Management of trust fund.--For purposes of subchapter B 
          of chapter 98 of the Internal Revenue Code of 1986, the 
          provisions of this subsection shall be treated as provisions of 
          subchapter A of such chapter.
      (b) Global Climate Change Adaptation and Mitigation Program.--
              (1) In general.--Any appropriation under subsection (a)(3) 
          from the Global Climate Change Adaptation and Mitigation Trust 
          Fund shall be made for contributions to the Green Climate Fund, 
          and the Adaptation Fund, established pursuant to the United 
          Nations Framework Convention on Climate Change (UNFCCC).
              (2) Funding to be additional.--It is the sense of the 
          Congress that contributions made under this subsection shall be 
          in addition to (and shall not be a replacement for) other 
          funding for global climate change adaptation and mitigation 
          initiatives in developing countries.
  
  SEC. 6. DEFICIT REDUCTION.
  
      The amount of taxes received in the Treasury under section 4475 of 
  the Internal Revenue Code of 1986 (reduced by amounts appropriated 
  under sections 3, 4, and 5) shall be used for deficit reduction, except 
  that in the case of a fiscal year for which there is no Federal budget 
  deficit, such amount shall be used to reduce the Federal debt (in such 
  manner as the Secretary of the Treasury considers appropriate).
target: Investing in Our Future Act of 2011- Amends the Internal Revenue Code to impose an excise tax on currency transactions exceeding $10,000 equal to 0.005% of the value of the currency acquired in the transaction (currency transaction tax).
  
  Establishes in the Treasury: (1) the Child Care Assistance Trust Fund, which shall be funded with 10% of the revenues from the currency transactions tax and which shall be used to provide increased allocations to states for child care assistance; (2) the Multilateral Global Health Trust Fund, which shall be funded with 25% of the revenues from such tax and from which the Secretary of State shall make grants to assist developing countries in addressing HIV/AIDS, tuberculosis, malaria, maternal mortality, family planning, neglected diseases, and other health issues; and (3) the Global Climate Change Adaptation and Mitigation Trust Fund, which shall be funded with 25% of the revenues from such tax and which shall be used for contributions to the Green Climate Fund, and the Adaptation Fund, established pursuant to the United Nations Framework Convention on Climate Change. Requires remaining tax revenues to be used for federal budget deficit reduction or reduction of the federal debt.
feat_title: To amend the Internal Revenue Code of 1986 to impose an excise tax on currency transactions.