or the controlled corporation is a "disqualified investment corporation", defined as having investment assets that are two-thirds or more (75 percent or more under a first-year transition rule) or the value of the corporation's total assets. Offers-In-Compromise Partial Payments The provision requires that a taxpayer make a good faith down payment of 20 percent of any lump sum offer-in-compromise with any application for an offer. For periodic payment offers, the taxpayer is required to comply with their own payment schedule while the offer is being considered. The provision also provides that an offer is deemed accepted if the IRS does not make a decision with respect to the offer within two years from the date that the offer was submitted. Taxation of Passive Income of Minors Under current law, minors under age 14 are taxed on their unearned income (i.e. passive income such as interest) at their parent's marginal tax rate. The provision increases the age of minors subject to this tax to those minors under age 18. The provision also provides an exception for distributions from certain qualified disability trusts. Conversions to Roth IRAs The provision allows more taxpayers to convert from Traditional IRA to Roth IRA by removing the modified adjusted gross income (MAGI) limitation on such rollovers starting in 2010. Taxpayers who convert in 2010 may, as a special case, elect to pay tax on amounts converted in equal installments in 2011 and 2012. Domestic Manufacturing Deduction Wage Limitation The domestic manufacturing deduction for a taxable year is limited to 50 percent of the wages by the taxpayer during the calendar year that ends in such taxable year. The provision clarifies that only wages allocable to domestic production gross receipts are included for purposes of this limitation. Changes to Foreign Earned Income Exclusion () The provision increases the Foreign Earned Income Exclusion (FEIE) and advances the inflation-adjustment provision that was set to begin in 2008. However, the Act also includes a "stacking provision" that requires the FEIE to be excluded against the lowest tax brackets first. Additionally, the Act limits the related Foreign Housing Exclusion to a figure based on the excess of 16% of the value of the FEIE, with a cap of 30% of the value of the exclusion. (Previously, the figure was the excess of 16% of the salary of a federal worker grade G-14 Step 1, with no cap.) The Treasury was given