# § 23. Adoption expenses
**(a)** **Allowance of credit**
**(1)** **In general** In the case of an individual, there shall be allowed as a credit against the tax imposed by this chapter the amount of the qualified adoption expenses paid or incurred by the taxpayer.
**(2)** **Year credit allowed** The credit under paragraph (1) with respect to any expense shall be allowed—
**(A)** in the case of any expense paid or incurred before the taxable year in which such adoption becomes final, for the taxable year following the taxable year during which such expense is paid or incurred, and
**(B)** in the case of an expense paid or incurred during or after the taxable year in which such adoption becomes final, for the taxable year in which such expense is paid or incurred.
**(3)** **$10,000 credit for adoption of child with special needs regardless of expenses** In the case of an adoption of a child with special needs which becomes final during a taxable year, the taxpayer shall be treated as having paid during such year qualified adoption expenses with respect to such adoption in an amount equal to the excess (if any) of $10,000 over the aggregate qualified adoption expenses actually paid or incurred by the taxpayer with respect to such adoption during such taxable year and all prior taxable years.
**(4)** **Portion of credit refundable** So much of the credit allowed under paragraph (1) as does not exceed $5,000 shall be treated as a credit allowed under subpart C and not as a credit allowed under this subpart.
**(b)** **Limitations**
**(1)** **Dollar limitation** The aggregate amount of qualified adoption expenses which may be taken into account under subsection (a) for all taxable years with respect to the adoption of a child by the taxpayer shall not exceed $10,000.
**(2)** **Income limitation**
**(A)** **In general** The amount allowable as a credit under subsection (a) for any taxable year (determined without regard to subsection (c)) shall be reduced (but not below zero) by an amount which bears the same ratio to the amount so allowable (determined without regard to this paragraph but with regard to paragraph (1)) as—
**(i)** the amount (if any) by which the taxpayer’s adjusted gross income exceeds $150,000, bears to
**(ii)** $40,000.
**(B)** **Determination of adjusted gross income** For purposes of subparagraph (A), adjusted gross income shall be determined without regard to sections 911, 931, and 933.
**(3)** **Denial of double benefit**
**(A)** **In general** No credit shall be allowed under subsection (a) for any expense for which a deduction or credit is allowed under any other provision of this chapter.
**(B)** **Grants** No credit shall be allowed under subsection (a) for any expense to the extent that funds for such expense are received under any Federal, State, or local program.
**(c)** **Carryforwards of unused credit**
**(1)** **In general** If the portion of the credit allowable under subsection (a) which is allowed under this subpart for any taxable year exceeds the limitation imposed by section 26(a) for such taxable year reduced by the sum of the credits allowable under this subpart (other than this section and section 25D), such excess shall be carried to the succeeding taxable year and added to the portion of the credit allowable under subsection (a) which is allowed under this subpart for such taxable year.
**(2)** **Limitation** No credit may be carried forward under this subsection to any taxable year following the fifth taxable year after the taxable year in which the credit arose. For purposes of the preceding sentence, credits shall be treated as used on a first-in first-out basis.
**(d)** **Definitions** For purposes of this section—
**(1)** **Qualified adoption expenses** The term “qualified adoption expenses” means reasonable and necessary adoption fees, court costs, attorney fees, and other expenses—
**(A)** which are directly related to, and the principal purpose of which is for, the legal adoption of an eligible child by the taxpayer,
**(B)** which are not incurred in violation of State or Federal law or in carrying out any surrogate parenting arrangement,
**(C)** which are not expenses in connection with the adoption by an individual of a child who is the child of such individual’s spouse, and
**(D)** which are not reimbursed under an employer program or otherwise.
**(2)** **Eligible child** The term “eligible child” means any individual who—
**(A)** has not attained age 18, or
**(B)** is physically or mentally incapable of caring for himself.
**(3)** **Child with special needs** The term “child with special needs” means any child if—
**(A)** a State or Indian tribal government has determined that the child cannot or should not be returned to the home of his parents,
**(B)** such State or Indian tribal government has determined that there exists with respect to the child a specific factor or condition (such as his ethnic background, age, or membership in a minority or sibling group, or the presence of factors such as medical conditions or physical, mental, or emotional handicaps) because of which it is reasonable to conclude that such child cannot be placed with adoptive parents without providing adoption assistance, and
**(C)** such child is a citizen or resident of the United States (as defined in section 217(h)(3)).
**(e)** **Special rules for foreign adoptions** In the case of an adoption of a child who is not a citizen or resident of the United States (as defined in section 217(h)(3))—
**(1)** subsection (a) shall not apply to any qualified adoption expense with respect to such adoption unless such adoption becomes final, and
**(2)** any such expense which is paid or incurred before the taxable year in which such adoption becomes final shall be taken into account under this section as if such expense were paid or incurred during such year.
**(f)** **Filing requirements**
**(1)** **Married couples must file joint returns** Rules similar to the rules of paragraphs (2), (3), and (4) of section 21(e) shall apply for purposes of this section.
**(2)** **Taxpayer must include TIN**
**(A)** **In general** No credit shall be allowed under this section with respect to any eligible child unless the taxpayer includes (if known) the name, age, and TIN of such child on the return of tax for the taxable year.
**(B)** **Other methods** The Secretary may, in lieu of the information referred to in subparagraph (A), require other information meeting the purposes of subparagraph (A), including identification of an agent assisting with the adoption.
**(g)** **Basis adjustments** For purposes of this subtitle, if a credit is allowed under this section for any expenditure with respect to any property, the increase in the basis of such property which would (but for this subsection) result from such expenditure shall be reduced by the amount of the credit so allowed.
**(h)** **Adjustments for inflation**
**(1)** **In general** In the case of a taxable year beginning after December 31, 2002, each of the dollar amounts in paragraphs (3) and (4) of subsection (a) and paragraphs (1) and (2)(A)(i) of subsection (b) shall be increased by an amount equal to—
**(A)** such dollar amount, multiplied by
**(B)** the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting “calendar year 2001” for “calendar year 2016” in subparagraph (A)(ii) thereof.
**(2)** **Rounding** If any amount as increased under paragraph (1) is not a multiple of $10, such amount shall be rounded to the nearest multiple of $10.
**(3)** **Special rule for refundable portion** In the case of the dollar amount in subsection (a)(4), paragraph (1) shall be applied—
**(A)** by substituting “2025” for “2002” in the matter preceding subparagraph (A), and
**(B)** by substituting “calendar year 2024” for “calendar year 2001” in subparagraph (B) thereof.
**(i)** **Regulations** The Secretary shall prescribe such regulations as may be appropriate to carry out this section and section 137, including regulations which treat unmarried individuals who pay or incur qualified adoption expenses with respect to the same child as 1 taxpayer for purposes of applying the dollar amounts in subsections (a)(3) and (b)(1) of this section and in section 137(b)(1).
---
**Source Credit**: (Added Pub. L. 104–188, title I, § 1807(a), Aug. 20, 1996, 110 Stat. 1899, § 23; amended Pub. L. 105–34, title XVI, § 1601(h)(2)(A), (B), Aug. 5, 1997, 111 Stat. 1092; Pub. L. 105–206, title VI, §§ 6008(d)(6), 6018(f)(1), July 22, 1998, 112 Stat. 812, 823; Pub. L. 107–16, title II, §§ 201(b)(2)(E), 202(a)(1), (b)(1)(A), (2)(A), (c), (d)(1), (e)(1), (f)(1), (2)(A), June 7, 2001, 115 Stat. 46–49; Pub. L. 107–147, title IV, §§ 411(c)(1)(A)–(E), 418(a)(1), Mar. 9, 2002, 116 Stat. 45, 57; Pub. L. 109–58, title XIII, § 1335(b)(1), Aug. 8, 2005, 119 Stat. 1036; Pub. L. 109–135, title IV, § 402(i)(3)(A), (4), Dec. 21, 2005, 119 Stat. 2612, 2615; Pub. L. 110–343, div. B, title I, § 106(e)(2)(A), Oct. 3, 2008, 122 Stat. 3817; renumbered § 36C, amended, and renumbered § 23, Pub. L. 111–148, title X, § 10909(a)(1), (b)(1), (2)(I), (c), Mar. 23, 2010, 124 Stat. 1021, 1022, 1023; Pub. L. 111–312, title I, § 101(b)(1), Dec. 17, 2010, 124 Stat. 3298; Pub. L. 112–240, title I, § 104(c)(2)(A), Jan. 2, 2013, 126 Stat. 2321; Pub. L. 115–97, title I, § 11002(d)(1)(A), Dec. 22, 2017, 131 Stat. 2060; Pub. L. 115–141, div. U, title IV, § 401(d)(4)(B)(i), Mar. 23, 2018, 132 Stat. 1209; Pub. L. 119–21, title VII, §§ 70402(a)–(c), 70403(a), July 4, 2025, 139 Stat. 213, 214.)
### Inflation Adjusted Items for Certain Years
For inflation adjustment of certain items in this section, see Revenue Procedures listed in a table under .
## Editorial Notes
### Prior Provisions
A prior section 23, added , , , § 44C; amended , §§ 201, 202(a)–(d), 203(a), , , 258; renumbered § 23 and amended , §§ 471(c), 474(e), title VI, § 612(e)(2), , , 831, 912, related to residential energy credit, prior to repeal by , , .
### Amendments
2025—Subsec. (a)(4). , added par. (4).
Subsec. (c)(1). , which directed substitution of “portion of the credit allowable under subsection (a) which is allowed under this subpart” for “credit allowable under subsection (a)”, was executed by making the substitution both places appearing, to reflect the probable intent of Congress.
Subsec. (d)(3)(A). , inserted “or Indian tribal government” after “a State”.
Subsec. (d)(3)(B). , inserted “or Indian tribal government” after “such State”.
Subsec. (h). , amended subsec. (h) generally. Prior to amendment, text read as follows: “In the case of a taxable year beginning after , each of the dollar amounts in subsection (a)(3) and paragraphs (1) and (2)(A)(i) of subsection (b) shall be increased by an amount equal to—
“(1) such dollar amount, multiplied by
“(2) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting ‘calendar year 2001’ for ‘calendar year 2016’ in subparagraph (A)(ii) thereof.
If any amount as increased under the preceding sentence is not a multiple of $10, such amount shall be rounded to the nearest multiple of $10.”
2018—Subsec. (c)(1). substituted “section 25D” for “sections 25D and 1400C”.
2017—Subsec. (h)(2). substituted “for ‘calendar year 2016’ in subparagraph (A)(ii)” for “for ‘calendar year 1992’ in subparagraph (B)”.
2013—Subsec. (b)(4). , struck out par. (4). Prior to amendment, text read as follows: “In the case of a taxable year to which section 26(a)(2) does not apply, the credit allowed under subsection (a) for any taxable year shall not exceed the excess of—
“(A) the sum of the regular tax liability (as defined in section 26(b)) plus the tax imposed by section 55, over
“(B) the sum of the credits allowable under this subpart (other than this section and section 25D) and section 27 for the taxable year.”
Subsec. (c). , (iii), added par. (1), redesignated par. (3) as (2), and struck out former pars. (1) and (2) which related to rule for years in which all personal credits allowed against regular and alternative minimum tax and rule for other years, respectively.
2010—Subsec. (a)(3). , (c), as amended by , temporarily substituted “$13,170” for “$10,000” in heading and text. See Effective and Termination Dates of 2010 Amendment note below.
Subsec. (b)(1). , (c), as amended by , temporarily substituted “$13,170” for “$10,000”. See Effective and Termination Dates of 2010 Amendment note below.
Subsec. (b)(4). , (c), as amended by , temporarily struck out par. (4). Text read as follows: “In the case of a taxable year to which section 26(a)(2) does not apply, the credit allowed under subsection (a) for any taxable year shall not exceed the excess of—
“(A) the sum of the regular tax liability (as defined in section 26(b)) plus the tax imposed by section 55, over
“(B) the sum of the credits allowable under this subpart (other than this section and section 25D) and section 27 for the taxable year.”
See Effective and Termination Dates of 2010 Amendment note below.
Subsec. (c). , (c), as amended by , temporarily struck out subsec. (c) which related to carryforwards of unused credit. See Effective and Termination Dates of 2010 Amendment note below.
Subsec. (h). , (c), as amended by , temporarily amended subsec. (h) generally. Prior to amendment, subsec. (h) related to adjustments for inflation. See Effective and Termination Dates of 2010 Amendment note below.
2008—Subsec. (b)(4)(B). inserted “and section 25D” after “this section”.
2005—Subsec. (b)(4). , substituted “In the case of a taxable year to which section 26(a)(2) does not apply, the credit” for “The credit” in introductory provisions.
Subsec. (c). , reenacted heading without change and amended text generally. Prior to amendment, text read as follows: “If the credit allowable under subsection (a) for any taxable year exceeds the limitation imposed by subsection (b)(4) for such taxable year, such excess shall be carried to the succeeding taxable year and added to the credit allowable under subsection (a) for such taxable year. No credit may be carried forward under this subsection to any taxable year following the fifth taxable year after the taxable year in which the credit arose. For purposes of the preceding sentence, credits shall be treated as used on a first-in first-out basis.”
, which directed amendment of subsec. (c) by substituting “this section, section 25D, and section 1400C” for “this section and section 1400C”, was repealed by . See Effective and Termination Dates of 2005 Amendment notes below.
2002—Subsec. (a)(1). , reenacted heading without change and amended text of par. (1) generally. Prior to amendment, text read as follows: “In the case of an individual, there shall be allowed as a credit against the tax imposed by this chapter—
“(A) in the case of an adoption of a child other than a child with special needs, the amount of the qualified adoption expenses paid or incurred by the taxpayer, and
“(B) in the case of an adoption of a child with special needs, $10,000.”
Subsec. (a)(2). , struck out concluding provisions which read as follows: “In the case of the adoption of a child with special needs, the credit allowed under paragraph (1) shall be allowed for the taxable year in which the adoption becomes final.”
Subsec. (a)(3). , added par. (3).
Subsec. (b)(1). , substituted “subsection (a)” for “subsection (a)(1)(A)”.
Subsec. (h). , substituted “subsection (a)(3)” for “subsection (a)(1)(B)” in introductory provisions and inserted concluding provisions.
Subsec. (i). , substituted “the dollar amounts in subsections (a)(3) and (b)(1)” for “the dollar limitation in subsection (b)(1)”.
2001—Subsec. (a)(1). , amended heading and text of par. (1) generally. Prior to amendment, text read as follows: “In the case of an individual, there shall be allowed as a credit against the tax imposed by this chapter the amount of the qualified adoption expenses paid or incurred by the taxpayer.”
Subsec. (a)(2). , inserted concluding provisions.
Subsec. (b)(1). , substituted “subsection (a)(1)(A)” for “subsection (a)” and “$10,000” for “$5,000” and struck out “($6,000, in the case of a child with special needs)” before period at end.
Subsec. (b)(2)(A)(i). , substituted “$150,000” for “$75,000”.
Subsec. (b)(4). , added par. (4).
Subsec. (c). , substituted “subsection (b)(4)” for “section 26(a)” and struck out “reduced by the sum of the credits allowable under this subpart (other than this section and sections 24 and 1400C)” before “, such excess”.
, substituted “and sections 24 and 1400C” for “and section 1400C”.
Subsec. (d)(2). , amended heading and text of par. (2) generally. Prior to amendment, text read as follows: “The term ‘eligible child’ means any individual—
“(A) who—
“(i) has not attained age 18, or
“(ii) is physically or mentally incapable of caring for himself, and
“(B) in the case of qualified adoption expenses paid or incurred after , who is a child with special needs.”
Subsecs. (h), (i). , added subsec. (h) and redesignated former subsec. (h) as (i).
1998—Subsec. (b)(2)(A). , inserted “(determined without regard to subsection (c))” after “for any taxable year” in introductory provisions.
Subsec. (c). , inserted “and section 1400C” after “other than this section”.
1997—Subsec. (a)(2). , amended heading and text of par. (2) generally. Prior to amendment, text read as follows: “The credit under paragraph (1) with respect to any expense shall be allowed—
“(A) for the taxable year following the taxable year during which such expense is paid or incurred, or
“(B) in the case of an expense which is paid or incurred during the taxable year in which the adoption becomes final, for such taxable year.”
Subsec. (b)(2)(B). , substituted “determined without regard to sections 911, 931, and 933.” for “determined—
“(i) without regard to sections 911, 931, and 933, and
“(ii) after the application of sections 86, 135, 137, 219, and 469.”
## Statutory Notes and Related Subsidiaries
### Effective Date of 2025 Amendment
> “The amendments made by this section [amending this section] shall apply to taxable years beginning after
>
> .”
, , , provided that:
> “The amendments made by this section [amending this section] shall apply to taxable years beginning after
>
> .”
, , , provided that:
### Effective Date of 2017 Amendment
Amendment by applicable to taxable years beginning after , see , set out as a note under .
### Effective Date of 2013 Amendment
> “The amendments made by this section [amending this section and sections 24, 25, 25A, 25B, 25D, 26, 30, 30B, 30D, 55, 904, and 1400C of this title] shall apply to taxable years beginning after
>
> .”
, , , provided that:
### Effective and Termination Dates of 2010 Amendment
Amendment by terminated applicable to taxable years beginning after , and section is amended to read as if such amendment had never been enacted, see , set out as a note under .
Amendment by applicable to taxable years beginning after , see , set out as a note under .
### Effective and Termination Dates of 2008 Amendment
> **“(1)** **In general.—** Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 24, 25B, 25D, 26, and 45 of this title] shall apply to taxable years beginning after December 31, 2007.
>
> **“(2)** **Solar electric property limitation.—** The amendments made by subsection (b) [amending section 25D of this title] shall apply to taxable years beginning after December 31, 2008.
>
> **“(3)** **Application of egtrra sunset.—** The amendments made by subparagraphs (A) and (B) of subsection (e)(2) [amending this section and section 24 of this title] shall be subject to title IX of the Economic Growth and Tax Relief Reconciliation Act of 2001 [Pub. L. 107–16, § 901, which was repealed by Pub. L. 112–240, title I, § 101(a)(1), Jan. 2, 2013, 126 Stat. 2315, was formerly set out as an Effective and Termination Dates of 2001 Amendment note under section 1 of this title] in the same manner as the provisions of such Act to which such amendments relate.”
, , , provided that:
### Effective and Termination Dates of 2005 Amendment
> “The amendments made by this paragraph [amending this section and sections 24, 25, 25B, 25D, 904, and 1400C of this title] (and each part thereof) shall be subject to title IX of the Economic Growth and Tax Relief Reconciliation Act of 2001 [
>
> , which was repealed by
>
> ,
>
> ,
>
> , was formerly set out as an Effective and Termination Dates of 2001 Amendment note under
>
> ] in the same manner as the provisions of such Act to which such amendment (or part thereof) relates.”
, , , provided that:
> “The Internal Revenue Code of 1986 shall be applied and administered as if the amendments made [by] such paragraphs [amending this section and sections 25 and 1400C of this title] had never been enacted.”
, , , struck out –(3), and provided in part that:
> **“(1)** **In general.—** Except as provided in paragraphs (2) and (3), the amendments made by this section [see Tables for classification] shall take effect as if included in the provisions of the Energy Policy Act of 2005 [Pub. L. 109–58] to which they relate.
>
> **“(2)** **Repeal of public utility holding company act of 1935.—** The amendments made by subsection (a) [amending sections 121, 246, 247, 1223, 1245, and 1250 of this title and repealing sections 1081 to 1083 of this title] shall not apply with respect to any transaction ordered in compliance with the Public Utility Holding Company Act of 1935 [15 U.S.C. 79 et seq.] before its repeal.
>
> **“(3)** **Coordination of personal credits.—** The amendments made by subsection (i)(3) [amending this section and sections 24, 25, 25B, 25D, 904, and 1400C of this title] shall apply to taxable years beginning after December 31, 2005.”
, , , provided that:
> “The amendments made by this section [enacting
>
> and amending this section and sections 25, 1016, and 1400C of this title] shall apply to property placed in service after
>
> , in taxable years ending after such date.”
, , , provided that:
### Effective Date of 2002 Amendment
> “The amendments made by this subsection [amending this section and
>
> ] shall apply to taxable years beginning after
>
> ; except that the amendments made by paragraphs (1)(C), (1)(D) [amending this section], and (2)(B) [amending
>
> ] shall apply to taxable years beginning after
>
> .”
, , , provided that:
Amendment by effective as if included in the provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001, , to which such amendment relates, see , set out as a note under .
### Effective Date of 2001 Amendment
> “The amendments made by sections 201(b), 202(f), and 618(b) of the Economic Growth and Tax Relief Reconciliation Act of 2001 [
>
> , amending this section and sections 24, 25, 25B, 26, 904, and 1400C of this title] shall not apply to taxable years beginning during 2004 or 2005.”
, , , provided that:
> “The amendments made by sections 201(b), 202(f), and 618(b) of the Economic Growth and Tax Relief Reconciliation Act of 2001 [
>
> , amending this section and sections 24, 25, 25B, 26, 904, and 1400C of this title] shall not apply to taxable years beginning during 2002 and 2003.”
, , , provided that:
Amendment by applicable to taxable years beginning after , see , set out as a note under .
> **“(1)** **In general.—** Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 24, 26, 137, 904, and 1400C of this title] shall apply to taxable years beginning after December 31, 2001.
>
> **“(2)** **Subsection (a).—** The amendments made by subsection (a) [amending this section and section 137 of this title] shall apply to taxable years beginning after December 31, 2002.”
, , , provided that:
### Effective Date of 1998 Amendment
> “The amendments made by this section [amending this section and sections 219, 408, 414, and 679 of this title and amending provisions set out as notes under sections 167 and 4091 of this title] shall take effect as if included in the provisions of the Small Business Job Protection Act of 1996 [
>
> ] to which they relate.”
, , , provided that:
Amendment by effective, except as otherwise provided, as if included in the provisions of the Taxpayer Relief Act of 1997, , to which such amendment relates, see , set out as a note under .
### Effective Date of 1997 Amendment
> **“(1)** **In general.—** Except as provided in paragraph (2), the amendments made by this section [amending this section, sections 30A, 52, 55, 137, 401, 403, 404, 408, 414, 512, 529, 593, 641, 679, 860L, 956, 1361, 1374, 4001, 4041, 4092, 4261, 6039D, 6048, 6050R, 6501, 6693, 7701, and 9503 of this title, section 1055 of Title 29, Labor, and provisions set out as notes under sections 529 and 4091 of this title] shall take effect as if included in the provisions of the Small Business Job Protection Act of 1996 [Pub. L. 104–188] to which they relate.
>
> **“(2)** **Certain administrative requirements with respect to certain pension plans.—** The amendment made by subsection (d)(2)(D) [amending section 401 of this title] shall apply to calendar years beginning after the date of the enactment of this Act [Aug. 5, 1997].”
, , , provided that:
### Effective Date
> “The amendments made by this section [enacting this section and
>
> , renumbering former
>
> as section 138, and amending sections 25, 86, 135, 219, 469, and 1016 of this title] shall apply to taxable years beginning after
>
> .”
, , , provided that:
### Savings Provision
Amendment by not applicable to certain obligations issued, DC Zone assets acquired, or principal residences acquired before , see , set out as a note under former .
> “If—
>
> **“(1)** any provision amended or repealed by the amendments made by subsection (b) or (d) [see Tables for classification] applied to—
>
> **“(A)** any transaction occurring before the date of the enactment of this Act [Mar. 23, 2018],
>
> **“(B)** any property acquired before such date of enactment, or
>
> **“(C)** any item of income, loss, deduction, or credit taken into account before such date of enactment, and
>
> **“(2)** the treatment of such transaction, property, or item under such provision would (without regard to the amendments or repeals made by such subsection) affect the liability for tax for periods ending after such date of enactment,
>
> nothing in the amendments or repeals made by this section [see Tables for classification] shall be construed to affect the treatment of such transaction, property, or item for purposes of determining liability for tax for periods ending after such date of enactment.”
, , , provided that:
### Expenses Paid or Incurred Before 2002
> “Expenses paid or incurred during any taxable year beginning before
>
> , may be taken into account in determining the credit under section 23 of the Internal Revenue Code of 1986 only to the extent the aggregate of such expenses does not exceed the applicable limitation under section 23(b)(1) of such Code as in effect on the day before the date of the enactment of the Economic Growth and Tax Relief Reconciliation Act of 2001 [
>
> ].”
, , , provided that:
### Tax Credit and Gross Income Exclusion Study and Report
> “The Secretary of the Treasury shall study the effect on adoptions of the tax credit and gross income exclusion established by the amendments made by this section [enacting this section and
>
> , renumbering former
>
> as section 138, and amending sections 25, 86, 135, 219, 469, and 1016 of this title] and shall submit a report regarding the study to the Committee on Finance of the Senate and the Committee on Ways and Means of the House of Representatives not later than
>
> .”
, , , provided that: