6 percent and inserting 1/2 the credit percentage in effect under subparagraph (A) . (b) Modification of small business portion allowed against payroll tax (1) Increase in limitation Paragraphs (4)(B)(i) and (5)(B)(ii) of section 41(h) of such Code are each amended by striking $250,000 and inserting $500,000 . (2) Qualified small business gross receipts threshold Section 41(h)(3)(A)(i)(I) of such Code is amended by striking $5,000,000 and inserting the dollar amount in effect for the taxable year under section 448(c)(1) . (c) Effective dates (1) Subsection (a) The amendments made by subsection (a) shall apply to taxable years beginning after December 31, 2020. (2) Subsection (b) The amendments made by subsection (b) shall apply to taxable years beginning after December 31, 2019. 203. Special rules for transfers of intangible property from controlled foreign corporations to United States shareholders (a) In general Subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 966. Transfers of intangible property to United States shareholders (a) In general If a controlled foreign corporation holds intangible property on the date of the enactment of this section and thereafter distributes such property to a domestic corporation which is a United States shareholder with respect to such controlled foreign corporation— (1) for purposes of part I of subchapter C and any other provision of this title specified by the Secretary, the fair market value of such property on the date of such distribution shall be treated as not exceeding the adjusted basis of such property immediately before such distribution, and (2) if any portion of such distribution is not a dividend— (A) no gain shall be recognized by such United States shareholder with respect to such distribution, and (B) the adjusted basis of such property in the hands of such United States shareholder immediately after such distribution shall be the adjusted basis of such property