Text of JCT Tax Simplification Report Available -- Volume I (Part 2 of 3)
JCS-3-01 (Volume I)
- Institutional AuthorsJoint Committee on Taxation
- Cross-Reference
- Subject Area/Tax Topics
- Index Termsbudget, federallegislation, taxAMTIRC, complexitytax policy, simplificationincome tax, individualscorporate tax
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2001-12007 (473 original pages)
- Tax Analysts Electronic Citation2001 TNT 90-40
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APPENDIX B. --
Tax Policy Advisors to Joint Committee on Taxation
For Study of Overall State of the Federal Tax System
NAME TAX POLICY POSITION
1. Donald C. Alexander Commissioner of Internal Revenue
2. David H. Brockway Chief of Staff, Joint Committee on
Taxation
3. Mortimer M. Caplin Commissioner of Internal Revenue
4. John E. Chapoton Assistant Secretary of Treasury for
Tax Policy
5. O. Donaldson Chapoton Assistant Secretary of Treasury for
Tax Policy
6. N. Jerald Cohen Chief Counsel, Internal Revenue
Service
7. Sheldon S. Cohen Chief Counsel, Internal Revenue
Service and Commissioner of
Internal Revenue
8. Lawrence B. Gibbs Commissioner of Internal Revenue
9. Kenneth W. Gideon Chief Counsel, Internal Revenue
Service and Assistant Secretary of
Treasury for Tax Policy
10. David G. Glickman Assistant Secretary of Treasury for
Tax Policy
11. Fred T. Goldberg, Jr. Chief Counsel, Internal Revenue Service,
Assistant Secretary of Treasury for
Tax Policy and Commissioner
of Internal Revenue
12. Harry L. Gutman Chief of Staff, Joint Committee on
Taxation
13. Frederick W. Hickman Assistant Secretary of Treasury for Tax
Policy
14. Kenneth J. Kies Chief of Staff, Joint Committee on
Taxation
15. Jerome Kurtz Commissioner of Internal Revenue
16. Donald C. Lubick Assistant Secretary of Treasury for Tax
Policy
17. Mark L. McConaghy Chief of Staff, Joint Committee on
Taxation
18. J. Roger Mentz Assistant Secretary of Treasury for Tax
Policy
19. William F. Nelson Chief Counsel, Internal Revenue Service
20. Ronald A. Pearlman Assistant Secretary of Treasury for Tax
Policy and Chief of Staff, Joint
Committee on Taxation
21. Shirley D. Peterson Commissioner of Internal Revenue
22. Margaret M. Richardson Commissioner of Internal Revenue
23. Leslie B. Samuels Assistant Secretary of Treasury for Tax
Policy
24. Bernard M. Shapiro Chief of Staff, Joint Committee on
Taxation
25. Abraham N.M. Shashy Chief Counsel, Internal Revenue Service
[Appendix B continued]
NAME CURRENT AFFILIATION
1. Donald C. Alexander Akin, Gump, Strauss, Hauer, & Feld
2. David H. Brockway KPMG LLP
3. Mortimer M. Caplin Caplin and Drysdale, Chartered
4. John E. Chapoton Vinson and Elkins, LLP
5. O. Donaldson Chapoton Baker & Botts
6. N. Jerald Cohen Sutherland, Asbill & Brennan
7. Sheldon S. Cohen Morgan, Lewis & Bockius, LLP
8. Lawrence B. Gibbs Miller & Chevalier, Chartered
9. Kenneth W. Gideon Skadden, Arps, Slate, Meagher & Flom
LLP
10. David G. Glickman Baker & MeKenzie
11. Fred T. Goldberg, Jr. Skadden, Arps, Slate, Meagher & Flom,
LLP
12. Harry L. Gutman KPMG LLP
13. Frederick W. Hickman Retired
14. Kenneth J. Kies Pricewaterhouse Coopers, LLP
15. Jerome Kurtz New York University School of Law
16. Donald C. Lubick Retired
17. Mark L. McConaghy Pricewaterhouse Coopers, LLP
18. J. Roger Mentz White & Case, LLP
19. William F. Nelson McKee, Nelson, Ernst & Young
20. Ronald A. Pearlman Georgetown University Law Center
21. Shirley D. Peterson Retired
22. Margaret M. Richardson Ernst & Young, LLP
23. Leslie B. Samuels Cleary, Gottlieb, Steen & Hamilton
24. Bernard M. Shapiro Pricewaterhouse Coopers, LLP
25. Abraham N.M. Shashy KPMG LLP
APPENDIX C. --
Materials Provided by the General Accounting Office
to the Joint Committee in Connection with the
Study of the Overall State of the Federal Tax System
* * * * *
April 6, 2001
The Honorable William M. Thomas
Chairman
The Honorable Charles E. Grassley
Vice Chairman
Joint Committee on Taxation
Subject: Information Related to the Scope and Complexity of the
Federal Tax System
The Internal Revenue Service (IRS) Restructuring and Reform Act of 1998 requires the Joint Committee on Taxation (JCT) to report to Congress on the overall state of the federal tax system and on proposals to simplify it. The requirement for this study stems from a recommendation made in 1997 by the National Commission on Restructuring the IRS. The Commission concluded that the tax law should be simplified. The Commission reported a connection between the complexity of the Internal Revenue Code (IRC) and the difficulty of administering it and taxpayer frustration with the tax system. It reported that such complexity can lead to inadvertent noncompliance, increased costs to taxpayers, and complicated tax collection.
In a June 29, 2000 letter, we were asked to help the staff of the JCT in its study of the overall state of the federal tax system and proposals to simplify it. As agreed with the JCT, we obtained information on
1. the scope and size of the IRC, the number of
congressionally-mandated studies of the tax system, and
the amount of tax guidance and regulations issued by IRS;
2. the number and scope of IRS forms, schedules,
publications, and worksheets;
3. the number of tax returns filed and people claimed on
these returns, by various characteristics for selected
years;
4. the amount of assistance provided to taxpayers by IRS,
return preparers, and computerized software for selected
years;
5. the number and types of errors found by IRS when
processing or auditing tax returns, by various return
characteristics for selected years;
6. the number and types of taxpayer disputes with IRS in the
form of appeals and litigation in selected years; and
finally,
7. statistics associated with specific tax issues in the IRC.
These 7 areas relate to a list of 27 questions/topics that JCT staff provided us. During several subsequent meetings, JCT staff adjusted and clarified some of the questions and asked that we provide the answers in several installments by September 30, 2000, to help them draft the Committee's required report. We are issuing this letter to compile the information we had provided and to make it available to other interested parties. The questions, together with the relevant information that we obtained, form the substance of this correspondence and are included in the enclosures.
To summarize:
o The IRC had about 700 provisions that affected individuals and
over 1,500 provisions that affected businesses. The IRC also
had about 1.4 million words as of May 2000. As of June 2000,
the regulations implementing the IRC included close to 20,000
pages and about 8.6 million words. (See enclosure I for more
information.)
o For tax year 1999, the tax system included 649 forms,
schedules, and separate instructions; about 160 worksheets; and
about 340 publications with guidance on specific requirements
of the tax system. The forms and schedules included about
16,100 lines and the publications included about 13,400 pages.
(See enclosure II for more information.)
o The number of individuals listed as filers of tax returns rose
from about 152 million in 1990 to about 160 million in 1997. In
the same period, the number of people claimed on federal income
tax returns rose from about 228 million to 241 million. (See
enclosure III for more information.)
o Taxpayers contacted IRS for assistance on about 117 million
occasions in 1999, up from about 105 million contacts in 1996.
Taxpayers also have been relying more on tax return preparers
and tax return software to help prepare tax returns. (See
enclosure IV for more information.)
o In recent years, the most common errors IRS found when
processing individual income tax returns involved the Earned
Income Tax Credit and taxpayer identification numbers.
Similarly, IRS found errors (after returns were processed)
during audits of the returns. For individuals, errors varied by
income levels -- errors in determining gross income for lower
income levels and errors in passing through tax items to
shareholders for higher income levels. (See enclosure V for
more information.)
o IRS' recent data on the most frequent types of tax issues that
taxpayers appealed were limited to large corporations, with the
most frequent issue involving the deduction of business
expenses. The IRS data on issues litigated were limited to tax
court cases involving individual taxpayers, with the most
frequent issue in 1999 dealing with penalties. (See enclosure
VI for more information.)
o IRS had no data to answer a question about incentive stock
options. IRS had limited data on the "top-heavy" requirements
for pension plans, and we developed some relevant information
for a separate report. (See enclosure VII for more
information.)
Our scope and objectives were limited to answering the 27 questions posed by the Committee and did not include an overall assessment of the tax system's scope and complexity. While our responses quantify certain aspects of the tax system, such as the number of words and sections in the IRC, they do not address all the factors that might contribute to complexity or attempt to weigh the contributions of any factors. In addition, better understanding the relationship of the data to tax system complexity may often require additional analyses, including adjusting trends for other factors such as growth in the population or in the number of businesses. In addition, time did not permit us to verify the accuracy of the databases used in our tabulations and analyses, although we did attempt to obtain the best data available. 1 The enclosures discuss our data limitations in more detail. In answering the 27 questions, we
O interviewed officials from IRS, Department of the Treasury,
Securities and Exchange Commission, Library of Congress, and
National Archives and Records Administration;
O reviewed our prior tax reports as well as reports and studies
from IRS, Treasury, and the National Commission on
Restructuring the IRS;
O reviewed and categorized the contents of the IRC and summarized
other written data provided by IRS, Treasury, and the House
Ways and Means Committee; and
O analyzed computerized data extracted from IRS' Statistics of
Income database and electronic versions of the IRC and IRS
regulations published by Tax Analysts.
We did our work between June 2000 and October 2000 in accordance with generally accepted government auditing standards. On March 29, 2001, the Commissioner of IRS provided written comments on our draft correspondence (see enclosure VIII) that suggested two specific changes related to taxpayer assistance data. We changed the letter accordingly. We also received oral comments from the Department of the Treasury. Treasury's comments addressed the clarity or accuracy of certain passages and suggested adding some information to provide context. We made changes, where appropriate, based on these comments.
As agreed with your office, unless you publicly announce its contents earlier, we plan no further distribution of this correspondence until 30 days from the above date. At that time, we will send copies to the Honorable Paul H. O'Neill, Secretary of the Treasury, the Honorable Charles O. Rossotti, Commissioner of IRS, the Honorable Mitchell E. Daniels, Jr., Director, Office of Management and Budget, and interested congressional committees. The letter is also available on GAO's home page at http://www.gao.gov. If you have any questions about this correspondence, you may contact Tom Short or me on (202) 512-9110. Key contributors to this letter are listed in enclosure IX.
Sincerely yours,
Michael Brostek
Director, Tax Issues
[Editor's Note: Enclosures I-IX omitted.]
1 Also, we frequently relied on IRS' Statistics of Income (SOI) database as noted in the enclosures. The SOI data in this report, except for data on large corporations, are based on probability samples of taxpayer returns and thus subject to some imprecision due to sampling variability.
END OF FOOTNOTE
APPENDIX D. --
Materials Provided by the Congressional Research Service
to the Joint Committee in Connection with the
Study of the Overall State of the Federal Tax System
* * * * *
CONGRESSIONAL RESEARCH SERVICE
MEMORANDUM April 10, 2001
TO: Joint Committee on Taxation
Attention: Mary Schmitt
FROM: Richard Ehlke, Assistant Director
American Law Division
SUBJECT: Tax Simplification Project
We are pleased to submit the attached documents in connection with your project on complexity in the Internal Revenue Code. The attached documents have been prepared by 5 different CRS analysts: Robert Burdette, John Luckey, Eliot Maizels, Marie Morris, and Alan Talley.
The first document, prepared by Eliot Maizels, consists of a table analyzing tax bills introduced in the 105th and 106th Congress and a list of tax simplification bills introduced. This document shows that for these two Congresses, somewhere between 13 and 17 percent of all bills introduced each year were tax bills, but that only a very few tax bills were called simplification bills.
The second document, prepared by Alan Talley, is a compilation of amendments to the income tax laws enacted since 1954, listed by Congress and session.
The third document, prepared by Marie Morris, contains a list of the grants of regulatory authority to the Internal Revenue Service from 1991 to 2000. The fourth document, also prepared by Marie Morris, is an analysis of the regulatory guidance issued by the IRS during a single year, 2000. The analysis consists of two lists: the legislative authorities for the regulations and the frequency the particular statute was the basis for regulations proposed or finalized during 2000; and a chronological list of the guidance issued published in the IRS' Internal Revenue Bulletins during 2000. The table also indicates the effective date of the guidance and any previous or subsequent guidance issued on the same topic, according to the preamble of the guidance. This gives a picture of the time it takes for guidance to go from statute to proposed or temporary or final regulations.
The fifth document, prepared by John Luckey, lists the references to state law in the Internal Revenue Code and makes a brief determination as to whether the reference to state law adds to the complexity of the Code because of the necessity of consulting a source outside the Code or whether it simplifies the Code by permitting the Internal Revenue Service to ignore state law or creating uniformity.
The sixth document, prepared by Robert Burdette, contains two analyses. The first lists the references to foreign laws or treaties in the Internal Revenue Code and analyzes whether the particular provision of law adds to complexity by necessitating examination of foreign law. The second examines the Model Income Tax Treaty of September 20, 1996, for provisions that add complexity to the determination of tax liability by U.S. citizens and business enterprises.
We hope that these documents will assist you in preparing for the hearings on tax simplification.
* * * * *
Sept 18, 2000
TO: Rick Grafmeyer, Joint Committee on Taxation
FROM: Elliott Maizels, CRS Unit Supervisor
Subject: Tax Bill Statistics
The attached table contains the results of my analysis of tax bill statistics for the last two congresses. These numbers are different from those presented in the preliminary Aug. 4, memo from Rich Greenfield because at that time Rich had not spoken with anyone from your office concerning the request. Since then, I have spoken with you twice and Mary Schmitt once to clarify the request. Based on my conversations, the numbers differ because: (1) no resolutions are included; (2) only bills referred to either Finance or Ways and Means (with rare exceptions) are included; (3) for the most part, only bills which exclusively concern taxation are included and tangentially related bills have been excluded; and (4) a slightly different search strategy was used.
I have included, as you requested, a print-out of the official titles of the simplification bills for your perusal. Please note that some of the simplification bills do not entirely concern simplification, but do contain simplification provisions.
I can be reached at extension 7-6925 if you have questions.
Attachments: Tax legislation in the last two congresses table
105th Congress tax bills containing "simplification" language
106th Congress tax bills containing "simplification" language
Tax Legislation in the Last Two Congresses
______________________________________________________________________
Bills
Intro-
duced Tax
Year Bills /*/ by Bills % Tax Simplification
Introduced Chamber /**/ Bills Bills /***/
______________________________________________________________________
1997 4656 Senate Senate 12
1,568
780 16.75
House
3,088 House 14,
105th,
Congress 1998 2876 Senate Senate 4
1,090 456 15.85
House House 11
1,786
1999 5514 Senate 940 17.05 Senate 10
1,997
House House 16
3,517
106th
Congress 2000* 2,590 Senate Senate 7
*through 1,002
the July House 343 13.24 House 5
27th break 1,588
______________________________________________________________________
FOOTNOTES TO TABLE
/*/ No resolutions
/**/ Bills referred to Ways and Means or Finance which either
amend the Internal Revenue Code or are indexed under the term
"Taxation"
/***/ Those tax bills containing the word "simple" or its
variants: e.g. simplify, simplifying, or simplification
END OF FOOTNOTES TO TABLE
106TH CONGRESS TAX BILLS CONTAINING "SIMPLIFICATION" LANGUAGE
38 Items were found bill #
Items 1 through 20 of 38
1. H.R.134: To amend the Internal Revenue Code of 1986 to restructure and replace the income tax system of the United States to meet national priorities, and for other purposes.
Sponsor: Rep English, Phil - Latest Major Action: 1/6/1999 Referred to House committee
Committees: House Ways and Means
2. H.R.716: To amend the Internal Revenue Code of 1986 to simplify the method of payment of taxes on distilled spirits.
Sponsor: Rep Collins, Mac - Latest Major Action: 2/11/1999 Referred to House committee
Committees: House Ways and Means
3. H.R.1040: To promote freedom, fairness, and economic opportunity for families by reducing the power and reach of the Federal establishment.
Sponsor: Rep Armey, Richard K. - Latest Major Action: 3/9/1999 Referred to House committee
Committees: House Rules; House Ways and Means
4. H.R.1041: To terminate the Internal Revenue Code of 1986.
Sponsor: Rep Largent, Steve - Latest Major Action: 3/9/1999 Referred to House committee
Committees: House Ways and Means
5. H.R.1097: To amend the Internal Revenue Code of 1986 to simplify the $500 per child tax credit and other individual non-refundable credits by repealing the complex limitations on the allowance of those credits resulting from their interaction with the alternative minimum tax.
Sponsor: Rep Neal, Richard E. - Latest Major Action: 3/11/1999 Referred to House committee
Committees: House Ways and Means
6. H.R.1407: To amend the Internal Revenue Code of 1986 to simplify the individual capital gains tax for all individuals and to provide modest reductions in the capital gains tax for most individuals.
Sponsor: Rep Coyne, William J. - Latest Major Action: 4/14/1999 Referred to House committee
Committees: House Ways and Means
7. H.R.1420: To amend the Internal Revenue Code of 1986 of provide a revenue-neutral simplification of the individual income tax.
Sponsor: Rep Neal, Richard E. - Latest Major Action: 4/14/1999 Referred to House committee
Committees: House Ways and Means
8. H.R.1525: To amend the Internal Revenue Code of 1986 to provide simplified criteria, in lieu of the common law rules, for determining whether an individual is an employee or an independent contractor and to limit retroactive employment tax reclassifications.
Sponsor: Rep Kleczka, Gerald D. - Latest Major Action: 4/22/1999 Referred to House committee
Committees: House Ways and Means
9. H.R.1616: To amend the Internal Revenue Code of 1986 to simplify certain provisions applicable to real estate investment trusts.
Sponsor: Rep Thomas, William M. (Bill) - Latest Major Action: 4/28/1999 Referred to House committee
Committees: House Ways and Means
10. H.R.1708: To amend the Internal Revenue Code of 1986 to provide a simplified method for determining a partner's share of items of a partnership which is a qualified investment club.
Sponsor: Rep Ramstad, Jim - Latest Major Action: 5/5/1999 Referred to House committee
Committees: House Ways and Means
11. H.R.1928: To simplify certain provisions of the Internal Revenue Code of 1986.
Sponsor: Rep Houghton, Amo - Latest Major Action: 5/25/1999 Referred to House committee
Committees: House Ways and Means
12. H.R.2018: To amend the Internal Revenue Code of 1986 to simplify certain rules relating to the taxation of United States business operating abroad, and for other purposes.
Sponsor: Rep Houghton, Amo - Latest Major Action: 6/7/1999 Referred to House committee
Committees: House Ways and Means
13. H.R.2136: To amend the Internal Revenue Code of 1986 to provide that the capital gain treatment under section 631(b) of such Code shall apply to outright sales of timber held for more than 1 year.
Sponsor: Rep Collins, Mac - Latest Major Action: 6/10/1999 Referred to House committee
Committees: House Ways and Means
14. H.R.2190: To amend the Internal Revenue Code of 1986 to provide small business employees with a simple, secure, and fully portable defined benefit plan.
Sponsor: Rep Johnson, Nancy L. - Latest Major Action: 6/14/1999 Referred to House committee
Committees: House Ways and Means
15. H.R.2574: To amend the Internal Revenue Code of 1986 to provide comprehensive tax relief for American families and businesses to encourage family stability, economic growth, and tax simplification.
Sponsor: Rep Maloney, James H. - Latest Major Action: 7/20/1999 Referred to House committee
Committees: House Ways and Means
16. H.R.3127: To amend the Internal Revenue Code of 1986 to eliminate the complexities of the estate tax deduction for family- owned business and farm interests by increasing the unified estate and gift tax credit to $3,000,000 for all taxpayers.
Sponsor: Rep Moore, Dennis - Latest Major Action: 10/21/1999 Referred to House committee
Committees: House Ways and Means
17. H.R.3905: To amend the Internal Revenue Code of 1986 to repeal the provision taxing policyholder dividends of mutual life insurance companies and to repeal the policyholders surplus account provisions.
Sponsor: Rep Houghton, Amo - Latest Major Action: 3/13/2000 Referred to House committee
Committees: House Ways and Means
18. H.R.4199: To terminate the Internal Revenue Code of 1986.
Sponsor: Rep Largent, Steve - Latest Major Action: 5/2/2000 Referred to Senate committee
Committees: House Ways and Means; Senate Finance
19. H.R.4230: To terminate the Internal Revenue Code of 1986.
Sponsor: Rep Largent, Steve - Latest Major Action: 4/11/2000 Referred to the House Committee on Ways and Means. (On April 13, 2000, pursuant to H.Res. 473, an amendment in the nature of a substitute consisting of the text of H.R. 4230 was considered as adopted in H.R. 4199.) (CR 4/13/2000 D378)
Committees: House Ways and Means
20. H.R.4342: To amend the Internal Revenue Code of 1986 to simplify the excise tax on heavy truck tires.
Sponsor: Rep Watkins, Wes - Latest Major Action: 4/13/2000 Referred to House committee
Committees: House Ways and Means
Items 21 through 38 of 38
21. H.R.5027: To provide for the establishment of a commission to review and make recommendations to Congress on the reform and simplification of the Internal Revenue Code of 1986.
Sponsor: Rep DeMint, Jim - Latest Major Action: 7/27/2000 Referred to House committee
Committees: House Ways and Means
22. S.344: A biil to amend the Internal Revenue Code of 1986 to provide a safe harbor for determining that certain individuals are not employees.
Sponsor: Sen Bond, Christopher S. - Latest Major Action: 2/3/1999 Referred to Senate committee
Committees: Senate Finance
23. S.434: A bill to amend the Internal Revenue Code of 1986 to simplify the method of payment of taxes on distilled spirits.
Sponsor: Sen Breaux, John B. - Latest Major Action: 2/22/1999 Referred to Senate committee
Committees: Senate Finance
24. S.627: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Sen Hutchinson, Y. Tim - Latest Major Action: 3/16/1999 Referred to Senate committee
Committees: Senate Finance
25. S.1040: A bill to promote freedom, fairness, and economic opportunity for families by reducing the power and reach of the Federal establishment.
Sponsor: Sen Shelby, Richard C. - Latest Major Action: 5/13/1999 Referred to Senate committee
Committees: Senate Finance
26. S.1056: A bill to amend the Internal Revenue Code of 1986 to improve tax equity for the Highway Trust Fund and to reduce the number of separate taxes deposited into the Highway Trust Fund, and for other purposes.
Sponsor: Sen Chafee, John H. - Latest Major Action: 5/14/1999 Referred to Senate committee
Committees: Senate Finance
27. S.1057: A bill to amend the Internal Revenue Code of 1986 to simplify certain provisions applicable to real estate investment trusts.
Sponsor: Sen Mack, Connie - Latest Major Action: 5/14/1999 Referred to Senate committee
Committees: Senate Finance
28. S.1164: A bill to amend the Internal Revenue Code of 1986 to simplify certain rules relating to the taxation of United States business operating abroad, and for other purposes.
Sponsor: Sen Hatch, Orrin G. - Latest Major Action: 5/27/1999 Referred to Senate committee
Committees: Senate Finance
29. S.1289: A bill to amend the Internal Revenue Code of 1986 to provide that the capital gain treatment under section 631(b) of such Code shall apply to outright sales of timber held for more than 1 year.
Sponsor: Sen Sessions, Jeff - Latest Major Action: 6/28/1999 Referred to Senate committee
Committees: Senate Finance
30. S.1379: A bill to amend the Internal Revenue Code of 1986 to provide broad based tax relief for all taxpaying families, to mitigate the marriage penalty, to expand retirement savings, to phase out gift and estate taxes, and for other purposes.
Sponsor: Sen Domenici, Pete V. - Latest Major Action: 7/15/1999 Referred to Senate committee
Committees: Senate Finance
31. S.1952: A bill to amend the Internal Revenue Code of 1986 to provide a simplified method for determining a partner's share of items of a partnership which is a qualified investment club.
Sponsor: Sen Abraham, Spencer - Latest Major Action: 11/17/1999 Referred to Senate committee
Committees: Senate Finance
32. S.2246: A bill to amend the Internal Revenue code of 1986 to clarify that certain small businesses are permitted to use the cash method of accounting even if they use merchandise or inventory.
Sponsor: Sen Bond, Christopher S. - Latest Major Action: 3/9/2000 Referred to Senate committee
Committees: Senate Finance
33. S.2401: A bill to provide jurisdictional standards for imposition of State and local business activity, sales, and use tax obligations on interstate commerce, and for other purposes.
Sponsor: Sen Gregg, Judd - Latest Major Action: 4/11/2000 Referred to Senate committee
Committees: Senate Finance
34. S.2450: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Sen Hutchinson, Y. Tim - Latest Major Action: 4/13/2000 Referred to Senate committee
Committees: Senate Finance
35. S.2587: A bill to amend the Internal Revenue Code of 1986 to simplify the excise tax on heavy truck tires.
Sponsor: Sen Nickles, Don - Latest Major Action: 5/18/2000 Referred to Senate committee
Committees: Senate Finance
36. S.2642: A bill to amend the Internal Revenue Code of 1986 to provide major tax simplification.
Sponsor: Sen Hatch, Orrin G. - Latest Major Action: 5/25/2000 Referred to Senate committee
Committees: Senate Finance
37. S.2775: To foster innovation and technological advancement in the development of the Internet and electronic commerce, and to assist the States in simplifying their sales and use taxes.
Sponsor: Sen Dorgan, Byron L. - Latest Major Action: 6/22/2000 Referred to Senate committee
Committees: Senate Finance
38. S.2874: A bill to amend the Internal Revenue Code of 1986 to repeal the provision taxing policyholder dividends of mutual life insurance companies and to repeal the policyholders surplus account provisions.
Sponsor: Sen Moynihan, Daniel Patrick - Latest Major Action: 7/14/2000 Referred to Senate committee
Committees: Senate Finance
105th Congress Tax Bills Containing "Simplification" Language
41 Items were found bill #
Items 1 through 20 of 41
1. H.R.83: A bill to enhance and protect retirement savings.
Sponsor: Rep Schumer.
2. H.R.395: A bill to amend the Internal Revenue Code of 1986 to simplify the assessment and collection of the excise tax arrows.
Sponsor: Rep Barcia.
3. H.R.450: A bill to amend the Internal Revenue Code of 1986 to simplify the method of payment of taxes on distilled spirits.
Sponsor: Rep Ensign.
4. H.R.1040: A bill to promote freedom, fairness, and economic opportunity for families by reducing the power and reach of the Federal establishment.
Sponsor: Rep Armey.
5. H.R.1130: A bill to provide for retirement savings and security, and for other purposes.
Sponsor: Rep Gejdenson.
6. H.R.1150: A bill to amend the Internal Revenue Code of 1986 to simplify certain provisions applicable to real estate investment trusts.
Sponsor: Rep Shaw.
7. H.R.1656: A bill to amend the Internal Revenue Code of 1986 to provide small business employees with a simple, secure, and fully portable defined benefit plan.
Sponsor: Rep Johnson, N..
8. H.R.1783: A bill to amend the Internal Revenue Code of 1986 to simplify certain rules relating to the taxation of United States business operating abroad, and for other purposes.
Sponsor: Rep Houghton.
9. H.R.2292: A bill to restructure the Internal Revenue Service, and for other purposes.
Sponsor: Rep Portman.
10. H.R.2400: A bill to authorize funds for Federal-aid highways, highway safety programs, and transit programs, and for other purposes.
Sponsor: Rep Shuster.- LATEST ACTION: 06/09/98 Public Law 105-178.
11. H.R.2490: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Rep Largent.
12. H.R.2676: A bill to amend the Internal Revenue Code of 1986 to restructure and reform the Internal Revenue Service, and for other purposes.
Sponsor: Rep Archer.-LATEST ACTION: 07/22/98 Public Law 105-206.
13. H.R.3059: A bill to amend the Internal Revenue Code of 1986 to eliminate the marriage penalty, to establish a commission to simplify the tax code, to require the Internal Revenue Service to use alternative dispute resolution, and for other purposes.
Sponsor: Rep Jackson-Lee.
14. H.R.3063: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Rep Largent.
15. H.R.3097: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Rep Largent.-LATEST ACTION: 06/18/98 Referred to Senate Committee on Finance
16. H.R.3620: A bill to amend the Internal Revenue Code of 1986 to reduce individual income tax rates, simplify the tax code, eliminate the marriage penalty, provide for return-free filing of income taxes, prohibit income tax rates from increasing without a national referendum, eliminate corporate welfare, and for other purposes.
Sponsor: Rep Gephardt.
17. H.R.3623: A bill to amend the Internal Revenue Code of 1986 to simplify the individual capital gains tax for all individuals and to provide modest reductions in the capital gains tax for most individuals.
Sponsor: Rep Coyne.
18. H.R.3722: A bill to amend the Internal Revenue Code of 1986 to clarify the standards used for determining whether individuals are not employees.
Sponsor: Rep Christensen.
19. H.R.4038: A bill to establish the National Commission on Reforming and Simplifying the Federal Tax Code.
Sponsor: Rep Boswell.
20. H.R.4053: A bill to amend the Internal Revenue Code of 1986 to simplify the individual income tax by repealing the adjusted gross income limitations on itemized deductions and the personal exemption deduction, and for other purposes.
Sponsor: Rep Neal.
21. H.R.4173: A bill to amend the Internal Revenue Code of 1986 to simplify certain rules relating to the taxation of United States business operating abroad, and for other purposes.
Sponsor: Rep Houghton.
22. H.R.4454: A bill to amend the Internal Revenue Code of 1986 to simplify the individual capital gains tax for all individuals and to provide modest reductions in the capital gains tax for most individuals.
Sponsor: Rep Coyne.
23. H.R.4489: A bill to amend the Internal Revenue Code of 1986 to simplify the $500 per child tax credit and other individual nonrefundable credits by repealing the complex limitations on the allowance of those credits resulting from their interaction with the alternative minimum tax.
Sponsor: Rep Neal.
24. H.R.4622: A bill to amend the Internal Revenue Code of 1986 to clarify the standards used for determining whether individuals are not employees.
Sponsor: Rep Dunn.
25. H.R.4700: A bill to amend the Internal Revenue Code of 1986 to restructure and replace the income tax system of the United States to meet national priorities, and for other purposes.
Sponsor: Rep English.
26. S.14: A bill to provide for retirement savings and security, and for other purposes.
Sponsor: Sen Daschle.
27. S.395: A bill to amend the Internal Revenue Code of 1986 to simplify the method of payment of taxes on distilled spirits.
Sponsor: Sen Breaux.
28. S.711: A bill to amend the Internal Revenue Code of 1986 to simplify the method of payment of taxes on distilled spirits.
Sponsor: Sen Breaux.
29. S.843: A bill to amend the Internal Revenue Code of 1986 to simplify certain rules relating to the taxation of United States business operating abroad, and for other purposes.
Sponsor: Sen Hatch.
30. S.883: A bill to amend the Internal Revenue Code of 1986 to encourage savings and investment through individual retirement accounts, to provide pension security, portability, and simplification, and for other purposes.
Sponsor: Sen Gregg.
31. S.898: A bill to amend the Internal Revenue Code of 1986 to simplify certain provisions applicable to real estate investment trusts.
Sponsor: Sen Hatch.
32. S.949: An original bill to provide revenue reconciliation pursuant to section 104(b) of the concurrent resolution on the budget for fiscal year 1998.
Sponsor: Sen Roth.-LATEST ACTION: 06/27/97 Text inserted in H.R. 2014 as passed Senate.
33. S.1040: A bill to promote freedom, fairness, and economic opportunity for families by reducing the power and reach of the Federal establishment.
Sponsor: Sen Shelby.
34. S.1096: A bill to restructure the Internal Revenue Service, and for other purposes.
Sponsor: Sen Kerrey.
35. S.1225: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Sen Hutchinson.
36. S.1520: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Sen Hutchinson.
37. S.1555: A bill to amend the Internal Revenue Code of 1986 to restructure and reform the Internal Revenue Service, and for other purposes.
Sponsor: Sen Faircloth.
38. S.1673: A bill to terminate the Internal Revenue Code of 1986.
Sponsor: Sen Hutchinson.
39. S.1748: A bill to amend the Internal Revenue Code of 1986 to provide that the reduced capital gains tax rates apply to long-term capital gain from property with at least a 1-year holding period.
Sponsor: Sen Mack.
40. S.1989: A bill to amend the Internal Revenue Code of 1986 to increase the standard deduction amount to reduce the marriage penalty, simplify the filing of individual tax returns, and provide tax relief for lower and middle income individuals, and for other purposes.
Sponsor: Sen Ford.
41. S.2231: A bill to amend the Internal Revenue Code of 1986 to simplify certain rules relating to the taxation of United States business operating abroad, and for other purposes.
Sponsor: Sen Hatch.
Income Tax Laws Since 1954
This listing, prepared by the Congressional Research Service for the Joint Committee on Taxation, provides the laws that have amended the Internal Revenue Code (Title 26 USC) since 1954. The compilation is extensive in that it covers both major tax laws as well as laws that have provide only minor code changes. The listing covers the period from 1954 (just prior to the enactment of the 1954 code) through the 106th Congress. The title of each act is provided followed by the public law number, the bill number, and enactment date. The preamble is given so as to provide the reader with the bill's context.
While this complication is extensive, it is not designed to list every change made to the Internal Revenue Code. The listing does not include Social Security acts, those acts affecting the railroad retirement system, the unemployment compensation program, duties, the tariff schedules, or the public debt limit. Also not included are those public laws affecting the tax laws of the District of Columbia. However, when acts in these areas also include changes to the tax code, they have been included.
An index appears at the end of this document.
EIGHTY-THIRD CONGRESS, SECOND SESSION
EXCISE TAX REDUCTION ACT OF 1954
P.L. 83-324 [H.R. 8224] enacted March 31, 1954
Preamble To reduce excise taxes, and for other purposes.
COPPER
P.L. 83-452 [H.R. 7709] enacted June 30, 1954
Preamble To continue until the close of June 30, 1955, the suspension of certain import taxes on copper.
REVISED ORGANIC ACT OF THE VIRGIN ISLANDS
P.L. 83-517 [S.3378] enacted July 22, 1954
Preamble To revise the Organic Act of the Virgin Islands of the United States.
DISTRICT COURTS' JURISDICTION
P.L. 83-559 [S. 252] enacted July 30, 1954
Preamble To permit all civil actions against the United States for recovery of taxes erroneously or illegally assessed or collected to be brought in the district courts with right of trial by jury.
EMPLOYMENT SECURITY ADMINISTRATIVE FINANCING ACT OF 1954
P.L. 83-567 [H.R. 5173] enacted August 5, 1954
Preamble To provide that the excess of collections from the Federal unemployment tax over employment security administrative expenses shall be used to establish and maintain a $200,000,000 reserve in the Federal unemployment account which will be available for advances to the States, to provide that the remainder of such excess shall be returned to the States, and for other purposes.
INTERNAL REVENUE CODE OF 1954
P.L. 83-591 [H.R. 8300] enacted August 16, 1954
Preamble To revise the internal revenue laws of the United States.
ORAL PRESCRIPTIONS FOR NARCOTIC DRUGS
P.L. 83-729 [S. 3447] enacted August 31, 1954
Preamble To amend the Internal Revenue Code to permit the filling of oral prescriptions for certain drugs, and for other purposes.
RAILROAD RETIREMENT TAX AMENDMENTS
P.L. 83-746 [H.R. 7840] enacted August 31, 1954.
Preamble To amend the Railroad Retirement Act, the Railroad Retirement Tax Act, and the Railroad Unemployment Insurance Act.
SOCIAL SECURITY TAX AMENDMENTS OF 1954
P.L. 83-761 enacted September 1, 1954
Preamble To amend the Social Security Act and the Internal Revenue Code so as to extend coverage under the old-age and survivors insurance program, increase the benefits payable thereunder, preserve the insurance rights of disabled individuals, and increase the amount of earnings permitted without loss of benefits, and for other purposes.
FEDERAL UNEMPLOYMENT TAX AMENDMENTS
P.L. 83-767 [H.R. 9709] enacted September 1, 1954
Preamble To extend and improve the unemployment compensation program.
EIGHTY-FOURTH CONGRESS, FIRST SESSION
VIOLATION OF NARCOTIC DRUG LAWS
P.L. 84-1 [H.R. 2369] enacted January 20, 1955
Preamble To amend section 7237 of the Internal Revenue Code of 1954.
TAX COURT JUDGES AND CONGRESSIONAL SALARIES INCREASE
P.L. 84-9 [H.R. 3828] enacted March 2, 1955
Preamble To adjust the salaries of judges of United States courts, United States attorneys, members of Congress, and for other purposes.
TAX RATE EXTENSION ACT OF 1955
P.L. 84-18 [H.R. 4259] enacted March 30, 1955
Preamble To provide a one-year extension of the existing corporate normal-tax rate and of certain excise-tax rates.
METAL SCRAP
P.L. 84-66 [H.R. 5223] enacted June 8, 1955
Preamble To continue until the close of June 30, 1956, the suspension of duties and import taxes on metal scrap, and for other purposes.
ACCOUNTING METHOD AMENDMENTS
P.L. 84-74 [H.R. 4725] enacted June 15, 1955
Preamble To repeal sections 452 and 462 of the Internal Revenue Code of 1954.
SUSPENSION OF COPPER IMPORT TAXES
P.L. 84-91 [H.R. 5695] enacted June 21, 1955
Preamble To continue until the close of June 30, 1958, the suspension of certain import taxes on copper.
RENEGOTIATION ACT OF 1951, EXTENSION
P.L. 84-216 [H.R. 4904] enacted August 3, 1955
Preamble To extend the Renegotiation Act of 1951 for two years.
ARMED FORCES RETIREMENT INCOME TAX CREDIT
P.L. 84-299 [H.R. 291] enacted August 9, 1955
Preamble To extend the retirement income tax credit to members of the Armed Forces.
FLOOR STOCKS REFUNDS
P.L. 84-303 [H.R. 3712] enacted August 9, 1955
Preamble To extend the period during which claims for floor stocks refunds may be filed with respect to certain manufacturers' excise taxes which were reduced by the Excise Tax Reduction Act of 1954.
COLLECTION OF INCOME TAX AT SOURCE ON WAGES
P.L. 84-306 [H.R. 542] enacted August 9, 1955
Preamble To amend the Internal Revenue Code.
AMENDMENT OF REVENUE ACT OF 1951 FOR ARMED FORCES MEMBERS DYING IN SERVICE
P.L. 84-310 [H.R. 2619] enacted August 9, 1955
Preamble To amend section 345 of the Revenue Act of 1951.
LEASES OF CERTAIN TRAILERS
P.L. 84-317 [H.R. 3437] enacted August 9, 1955
Preamble To amend the Internal Revenue Code of 1954 to provide for a maximum manufacturers' excise tax on the leases of certain automobile utility trailers.
INCOME TAX, COLLECTION AT SOURCE ON WAGES
P.L. 84-321 [H.R. 4394) enacted August 9, 1955
Preamble To amend section 3401 of the Internal Revenue Code of 1954.
EXEMPTION FOR DEPENDENTS IN THE PHILIPPINES
P.L. 84-333 [H.R. 7148] enacted August 9, 1955
Preamble To amend the Internal Revenue Code so as to provide a personal exemption with respect to certain dependents in the Republic of the Philippines.
TAX ON ADMISSIONS-UNITED STATES OLYMPIC ASSOCIATION
P.L. 84-354 [H.R. 7095] enacted August 11, 1955
Preamble To provide that the tax on admissions shall not apply to certain athletic events held for the benefit of the United States Olympic Association.
IRC 1954 AMENDMENTS
P.L. 84-355 [H.R. 4581] enacted August 11, 1955
Preamble To amend the Internal Revenue Code of 1954 with respect to the tax on cutting oils.
SPIRITS AND WINES LOST IN 1954 HURRICANES
P.L. 84-363 [H.R. 5249] enacted August 11, 1955
Preamble To amend the Internal Revenue Code of 1954 to provide for refund or credit of internal revenue taxes and customs duties paid on distilled spirits and wines lost, rendered unmarketable, or condemned by health authorities as a result of the hurricanes of 1954.
TAX TREATMENT OF INCOME FROM PATENT INFRINGEMENT SUITS
P.L. 84-366 [H.R. 7300] enacted August 11, 1955
Preamble To amend the Internal Revenue Code of 1954 with respect to the tax treatment of income received from patent infringement suits.
MANUFACTURERS' EXCISE TAXES
P.L. 84-367 [H.R. 7024] enacted August 11, 1955
Preamble To remove the manufacturers' excise tax from the sales of certain component parts for use in other manufactured articles, to confine to entertainment-type equipment the tax on radio and television apparatus, and for other purposes.
USE OF CORPORATION PROPERTY BY A SHAREHOLDER
P.L. 84-370 [H.R. 4672] enacted August 11, 1955
Preamble To amend section 223 of the Revenue Act of 1950, relating to the use of corporation property by a shareholder.
MANUFACTURERS EXCISE TAX ON MOTORCYCLES
P.L. 84-379 [H.R. 5647] enacted August 12, 1955
Preamble To repeal the manufacturers excise tax on motorcycles.
RAILROAD RETIREMENT AND UNEMPLOYMENT INSURANCE
P.L. 84-383 [H.R. 4744] enacted August 12, 1955
Preamble To amend the Railroad Retirement Act of 1937, as amended, and the Railroad Unemployment Insurance Act.
RESIDENCES OF ARMED FORCES; RECOVERY INVOLVING PATENT INFRINGEMENT
P.L. 84-384 [H.R. 257] enacted August 12, 1955
Preamble To amend section 112(n)(8) of the Internal Revenue Code of 1939, relating to the suspension of certain periods of limitation while the taxpayer is on extended active duty with the Armed Forces, and to amend the Internal Revenue Code of 1954 with respect to tax treatment where the taxpayer recovers amounts held by another under claim of right.
INCOME TAXES ON ARBITRAGE OPERATIONS IN SECURITIES AND PERSONAL HOLDING COMPANIES
P.L. 84-385 [H.R. 6263] enacted August 12, 1955
Preamble To amend section 1233 and section 542(a)(2) of the Internal Revenue Code of 1954.
EIGHTY-FOURTH CONGRESS, SECOND SESSION
CARRYOVERS OF UNUSED PENSION TRUST DEDUCTIONS
P.L. 84-396 [H.R. 4582] enacted January 28, 1956
Preamble To amend the Internal Revenue Code of 1954 with respect to deductions from gross income of amounts contributed to employees trusts.
INTERNAL REVENUE CODE OF 1939, AMENDMENT
P.L. 84-397 [H.R. 5428 enacted January 28, 1956
Preamble To amend the Internal Revenue Code of 1939 with respect to the period of limitation for filing claims by certain transferees and fiduciaries for credit or refund of income taxes.
LIMITATION ON RETIREMENT INCOME TAX CREDIT
P.L. 84-398 [H.R. 7036] enacted January 28, 1956
Preamble To amend section 37 of the Internal Revenue Code of 1954 with respect to the earned income limitation on retirement income.
WESTERN HEMISPHERE TRADE CORPORATION
P.L. 84-399 [H.R. 7282] enacted January 28, 1956
Preamble Relating to the allowance of the credits for dividends received, for dividends paid, and for a Western Hemisphere trade corporation in computing the alternative tax of a corporation with respect to its capital gains.
DOCUMENTARY STAMP TAX
P.L. 84-400 [H.R. 7364] enacted January 28, 1956
Preamble Relating to the application of the documentary stamp tax to transfers of certain obligations paid for in installments.
TAXES; CHARITABLE CONTRIBUTIONS
P.L. 84-408 [H.R. 7094] enacted February 15, 1956
Preamble To amend section 120 of the Internal Revenue Code of 1939 (relating to unlimited deduction for charitable contributions).
TECHNICAL CHANGES ACT OF 1953, AMENDMENT
P.L. 84-414 [H.R. 2667] enacted February 20, 1956
Preamble To amend section 208(b) of the Technical Changes Act of 1953, and for other purposes.
ESTATE TAXES, CREDIT
P.L. 84-417 [H.R. 7054] enacted February 20, 1956
Preamble To amend the Internal Revenue Code of 1939 to provide a credit against the estate tax for Federal estate taxes paid on certain prior transfers.
LIFE INSURANCE COMPANY TAX ACT FOR 1955
P.L. 84-429 [H.R. 7201] enacted March 13, 1956
Preamble Relating to the taxation of income of insurance companies.
TAX RATE EXTENSION ACT OF 1956
P.L. 84-458 [H.R. 9166] enacted March 29, 1956
Preamble To provide a one-year extension of the existing corporate normal-tax rate and of certain excise-tax rates.
TAXES, GASOLINE AND SPECIAL FUELS USED FOR FARMING; TAX EXEMPTION
P.L. 84-466 [H.R. 8780] enacted April 2, 1956
Preamble To amend the Internal Revenue Code of 1954 to relieve farmers from excise taxes in the case of gasoline and special fuels used on the farm for farming purposes.
CAPITAL GAINS; REAL PROPERTY SUBDIVIDED FOR SALE
P.L. 84-495 [H.R. 6712] enacted April 27, 1956
Preamble To amend section 1237 of the Internal Revenue Code of 1954.
DISTRIBUTIONS PURSUANT TO BANK HOLDING COMPANY ACT OF 1956
P.L. 84-511 [H.R. 6227] enacted May 9, 1956
Preamble To define bank holding companies, control their future expansion, and require divestment of their nonbanking interests.
EXCISE TAXES ON SUGAR
P.L. 84-545 [H.R. 7030] enacted May 29, 1956
Preamble To amend and extend the Sugar Act of 1948, as amended, and for other purposes.
FEDERAL-AID HIGHWAY ACT OF 1956
TITLE II HIGHWAY REVENUE ACT OF 1956
P.L. 84-627 [H.R. 10660] enacted June 29, 1956
Preamble To amend and supplement the Federal-Aid Road Act approved July 11, 1916, to authorize appropriations for continuing the construction of highways; to amend the Internal Revenue Code of 1954 to provide additional revenue from the taxes on motor fuel, tires, and trucks and buses; and for other purposes.
RAILROAD REORGANIZATIONS; RECOGNITION OF GAIN OR LOSS
P.L. 84-628 [H.R. 7247] enacted June 29, 1956
Preamble Relating to recognition of gain or loss in certain railroad reorganizations and to amend section 108(b) of the Internal Revenue Code of 1954.
INCOME TAX DEDUCTIONS; TRADEMARK AND TRADE NAME EXPENDITURES
P.L. 84-629 [H.R. 61431 enacted June 29, 1956
Preamble To amend the Internal Revenue Codes of 1939 and 1954, and for other purposes.
DISTILLED SPIRTS, NATIONAL EMERGENCY TRANSFERS AND UNDISTRIBUTED CAPITAL GAINS OF REGULATED INVESTMENT COMPANIES
P.L. 84-700 [H.R. 11714] enacted July 11, 1956
Preamble To amend sections 5217(c) and 852(b)(3) of the Internal Revenue Code of 1954.
MUTUAL SECURITY ACT OF 1956
P.L. 84-726 [H.R. 11356] enacted July 18, 1956
Preamble To amend further the Mutual Security Act of 1954, as amended, and for other purposes.
NARCOTIC CONTROL ACT OF 1956
P.L. 84-728 [H.R. 11619] enacted July 18, 1956
Preamble To amend the Internal Revenue Code of 1954 and the Narcotic Drugs Import and Export Act to provide for a more effective control of narcotic drugs and marihuana, and for other related purposes.
LIFE INSURANCE COMPANIES; INCOME TAX
P.L. 84-784 [H.R. 11995] enacted July 24, 1956
Preamble To provide that the 1955 formula for taxing income of life insurance companies shall also apply to taxable years beginning in 1956.
TAXES, FOREIGN TRANSPORTATION EXEMPTION
P.L. 84-796 [H.R. 5265] enacted July 25, 1956
Preamble To exempt certain additional foreign travel from the tax on the transportation of persons.
SOCIAL SECURITY AMENDMENTS OF 1956
P.L. 84-880 [H.R. 7225] enacted August 1, 1956
Preamble To amend title II of the Social Security Act of provide disability insurance benefits for certain disabled individuals who have attained age fifty, to reduce to age sixty-two the age on the basis of which benefits are payable to certain women, to provide for child's insurance benefits for children who are disabled before attaining age eighteen, to extend coverage, and for other purposes.
SERVICEMEN'S AND VETERANS' SURVIVOR BENEFITS ACT
P.L. 84-881 [H.R. 7089] enacted August 1, 1956
Preamble To provide benefits for the survivors of servicemen and veterans, and for other purposes.
GUAM, APPLICATION OF FEDERAL LAWS, FEDERAL SEED ACT
P.L. 84-896 [H.R. 11522] enacted August 1, 1956
Preamble To implement section 25(b) of the Organic Act of Guam by carrying out the recommendations of the Commission on the Application of Federal Laws to Guam, and for other purposes.
ESTATE TAXES
P.L. 84-901 [H.R. 6595] enacted August 1, 1956
Preamble To amend certain provisions of law relating to the estate tax.
TAX ON ADMISSIONS
P.L. 84-1010 [H.R. 9875] enacted August 6, 1956
Preamble To amend the Internal Revenue Code of 1954 to provide that the tax on admissions shall apply only if the amount paid for the admission exceeds 90 cents.
ESTATE TAXES, BEQUESTS IN TRUST
P.L. 84-1011 [H.R. 11834] enacted August 6, 1956
Preamble To allow a charitable deduction for certain bequests.
TAX ON TRANSPORTATION
P.L. 1015 [H.R. 7634] enacted August 7, 1956
Preamble To provide that amounts which do not exceed 60 cents shall be exempt from the tax imposed upon amounts paid for the transportation of persons.
TAXES, CONTRIBUTIONS FOR MEDICAL RESEARCH
P.L. 1022 [H.R. 12152] enacted August 7, 1956
Preamble To amend the Internal Revenue Code of 1954 to provide for the allowance, as deductions, of contributions to medical research organizations.
EIGHTY-FIFTH CONGRESS, FIRST SESSION
TAX RATE EXTENSION ACT OF 1957
P.L. 85-12 [H.R. 4090] enacted March 29, 1957
Preamble To provide a fifteen-month extension of the existing corporate normal-tax rate and of certain excise tax rates.
VETERANS' BENEFITS ACT OF 1957
P.L. 85-56 [H.R. 53] enacted June 17, 1957
Preamble To consolidate into one Act, and to simplify and make more uniform, the laws administered by the Veterans' Administration relating to compensation, pension, hospitalization, and burial benefits, and to consolidate into one Act the laws pertaining to the administration of the laws administered by the Veterans' Administration.
EXEMPTION OF ARMED FORCES FURLOUGH TRAVEL FROM TRANSPORTATION TAX
P.L. 85-74 [H.R. 7954] enacted June 29, 1957
Preamble Relating to the exemption of furlough travel by service personnel from the tax on the transportation of persons.
ADJUSTMENT FOR BREACH OF CONTRACT DAMAGES; AMORTIZATION OF EMERGENCY FACILITIES
P.L. 85-165 [H.R. 232] enacted August 26, 1957
Preamble To amend the Internal Revenue Code of 1954 with respect to the readjustment of tax in the case of certain amounts received for breach of contract, and to restrict the issuance of certificates for rapid amortization of emergency facilities.
INTERNAL REVENUE CODE OF 1954, AMENDMENTS FOR MINISTERS
P.L. 85-239 [H.R. 8892] enacted August 30, 1957
Preamble To amend the Internal Revenue Code of 1954 to extend the time within which a minister may elect coverage as a self-employed individual for Social Security purposes, the value of meals and lodging furnished him for the convenience of his employer and the rental value of the parsonage furnished to him, and for other purposes.
EIGHTY-FIFTH CONGRESS, SECOND SESSION
INCOMPETENT DECEDENTS
P.L. 85-318 [H.R. 5938] enacted February 11, 1958
Preamble To amend section 812(e)(1)(D) of the Internal Revenue Code of 1939 with respect to certain decedents who were adjudged incompetent before April 2, 1948.
USE OF CORPORATE PROPERTY BY SHAREHOLDER
P.L. 85-319 [H.R. 7762] enacted February 11, 1958
Preamble To amend section 223 of the Revenue Act of 1950 so that it will apply to taxable years ending in 1954 to which the Internal Revenue Code of 1939 applies.
INCOME TAXES; STOCK OPTIONS
P.L. 85-320 [H.R. 9035] enacted February 11, 1958
Preamble To amend the Internal Revenue Code of 1954 with respect to the basis of stock acquired by the exercise of restricted stock options after the death of the employee.
COLLECTED TAXES; ADMINISTRATION
P.L. 85-321 [H.R.8865] enacted February 11, 1958
Preamble Relating to the administration of certain collected taxes.
ALCOHOL AND TOBACCO TAX REFUND
P.L. 85-323 [H.R. 8216] enacted February 11, 1958
Preamble To amend the Internal Revenue Code of 1954 to prevent unjust enrichment by precluding refunds of alcohol and tobacco taxes to persons who have not borne the ultimate burden of the tax.
TAXES, LIFE-INSURANCE COMPANIES
P.L. 85-345 [H.R. 10021] enacted March 17, 1958
Preamble To provide that the 1955 formula for taxing income of life insurance companies shall also apply to taxable years beginning in 1957.
TAXES; UNRELATED BUSINESS TAXABLE INCOME
P.L. 85-367 [H.R. 8268] enacted April 7, 1958
Preamble To amend section 512 of the Internal Revenue Code of 1954.
ADMISSIONS TAX; EXEMPTIONS
P.L. 85-380 [H.R. 8794] enacted April 16, 1958
Preamble To provide exemptions from the tax imposed on admissions for admissions to certain musical and dramatic performances and certain athletic events.
TAX RATE EXTENSION ACT OF 1958
P.L. 85-475 [H.R. 12695] enacted June 30, 1958
Preamble To provide a one-year extension of the existing corporate normal-tax rate and of certain excise-tax rates, and to provide for the repeal of the taxes on the transportation of property.
DISTILLED SPIRITS; NATIONAL EMERGENCY TRANSFERS
P.L. 85-517 [H.R. 13130] enacted July 11, 1958
Preamble To extend for two years the existing authority of the Secretary of the Treasury with respect to transfers of distilled spirits for purposes deemed necessary to meet the requirements of the national defense.
INCOME TAX OFFENSES: JURISDICTION
P.L. 85-595 [H.R. 8252] enacted August 6, 1958
Preamble To amend section 3237 of title 18 of the United States Code to define the place at which certain offenses against the income tax laws tax place.
FEDERAL INCOME TAX APPLICABILITY: GUAM
P.L. 85-688 [H.R. 12569] enacted August 20, 1958
Preamble To amend section 31 of the Organic Act of Guam, and for other purposes.
SOCIAL SECURITY AMENDMENTS OF 1958
Title IV-Amendments to the Internal Revenue Code of 1954
P.L. 85-840 [H.R. 13549] enacted August 28, 1958
Preamble To increase benefits under the Federal Old-Age, Survivors, and Disability Insurance System, to improve the actuarial status of the Trust Funds of such System, and other wise improve such System,; to amend the public assistance and maternal and child health and welfare provisions of the Social Security Act; and for other purposes.
VETERANS' BENEFITS. ENACTMENTS AS TITLE 38, U.S. CODE
P.L. 85-857 [H.R. 9700] enacted September 2, 1958
Preamble To consolidate into one Act all of the laws administered by the Veterans' Administration, and for other purposes.
EXCISE TAX TECHNICAL CHANGES ACT OF 1958
P.L. 85-859 [H.R. 7125] enacted September 2, 1958
Preamble To make technical changes in the Federal excise tax laws, and for other purposes.
TECHNICAL AMENDMENTS ACT OF 1958
P.L. 85-866 [H.R. 8381] enacted September 2, 1958
Preamble To amend the Internal Revenue Code of 1954 to correct unintended benefits and hardships and to make technical amendments, and for other purposes.
ARMED FORCES, ARMY AND NAVY SURGEONS GENERAL, RESPONSIBILITIES
P.L. 85-881 [S. 2006] enacted September 2, 1958
Preamble To relieve the Surgeons General of the Army and Navy of certain responsibilities outside the Department of Defense.
CORPORATIONS: TAX REFUND SUITS
P.L. 85-920 [H.R. 9817] enacted September 2, 1958
Preamble An Act relating to venue in tax refund suits by corporations.
EIGHTY-SIXTH CONGRESS, FIRST SESSION
TAX SUSPENSION ON PALM OIL, ETC.
P.L. 86-37 [H.R. 147] enacted May 29, 1959
Preamble To suspend temporarily the tax on the processing of palm oil, palm-kernal oil, and fatty acids, salts, and combinations, or mixtures thereof.
LIFE INSURANCE COMPANY INCOME TAX ACT OF 1959
P.L. 86-69 [H.R. 4245] enacted June 25, 1959
Preamble Relating to the taxation of the income of life insurance companies.
ALASKA OMNIBUS ACT
P.L. 86-70 [H.R. 7120] enacted June 25, 1959
Preamble To amend certain laws of the United States in light of the admission of the State of Alaska into the Union, and for other purposes.
TAX RATE EXTENSION ACT OF 1959
P.L. 86-75 [H.R. 7523] enacted June 30, 1959
Preamble To provide a one-year extension of the existing corporate normal-tax rate and of certain excise tax rates, and for other purposes.
REVOCABLE TRANSFERS
P.L. 86-141 [H.R. 1219] enacted August 7, 1959
Preamble To amend section 2038 of the Internal Revenue Code of 1954 (relating to revocable transfers.
FARM CREDIT ACT OF 1959
P.L. 86-168 [S. 1512] enacted August 18, 1959
Preamble To amend the Federal Farm Loan Act to transfer responsibility for making appraisals from the Farm Credit Administration to the Federal land banks, and for other purposes.
ESTATE TAX DEDUCTION
P.L. 86-175 [H.R. 137] enacted August 21, 1959
Preamble To allow a deduction for Federal estate tax purposes, in the case of certain transfers to charities which are subjected to foreign death taxes.
TAXES; CLAIMS FOR CREDIT
P.L. 86-280 [H.R. 2906] enacted September 16, 1959
Preamble To extend the period for filing claims for credit or refund of overpayments of income taxes arising as a result of renegotiation of Government contracts.
ADMISSIONS TAX, ATHLETIC GAMES
P.L. 86-319 [H.R. 4857] enacted September 21, 1959
Preamble To amend section 4233 of the Internal Revenue Code of 1954 to provide that the exemptions from the admissions tax for athletic games benefitting crippled or retarded children shall apply where the participants have recently attended designated schools or colleges as well as where they are currently students.
FEDERAL-AID HIGHWAY ACT OF 1959
TITLE II-INTERNAL REVENUE CODE AND HIGHWAY TRUST FUND AMENDMENTS
P.L. 86-342 [H.R. 8678] enacted September 21, 1959
Preamble To amend the Federal-Aid Highway Acts of 1956 and 1958 to make certain adjustments in the Federal-aid highway program, and for other purposes.
EXCISE TAX LAWS, TECHNICAL CHANGES
P.L. 86-344 [H.R. 8725] enacted September 21, 1959
Preamble To amend the Internal Revenue Code of 1954 to make technical changes in certain excise tax laws, and for other purposes.
U.S. SAVINGS BONDS, INTEREST RATES INCREASE
P.L. 86-346 [H.R. 9035] enacted September 22, 1959
Preamble To permit the issuance of series E and H United States savings bonds at interest rates above the existing maximum, to permit the Secretary of the Treasury to designate certain exchanges of Government securities to be made without recognition of gain or loss, and for other purposes.
CHIEF COUNSEL FOR THE INTERNAL REVENUE SERVICE
P.L. 86-368 [H.R. 8685] enacted September 22, 1959
Preamble To amend the Internal Revenue Code of 1954 to provide for the Presidential appointment of a Chief Counsel for the Internal Revenue Service, and for other purposes.
INTERNAL REVENUE CODE OF 1954, ADOPTION AND SMALL BUSINESS CORPORATIONS ELECTION AMENDMENTS
P.L. 86-376 [H.R. 47] enacted September 23, 1959
Preamble To amend the Internal Revenue code of 1954 to provide a personal exemption for children placed for adoption and to clarify certain provisions relating to the election of small business corporations as to taxable status.
EIGHTY-SIXTH CONGRESS, SECOND SESSION
AROMATIC CACHOUS
P.L. 86-413 [H.R. 4586] enacted April 8, 1960
Preamble To amend section 4021 of the Internal Revenue Code of 1954.
DOCUMENTARY STAMP TAX RATE
P.L. 86-416 [H.R. 6132] enacted April 8, 1960
Preamble Relating to the rate of tax on the issuance of shares or certificates of stock by regulated investment companies.
TAXES, BICYCLE TIRES AND TUBES
P.L. 86-418 [H.R. 8318] enacted April 8, 1960
Preamble To amend the Internal Revenue Code of 1954 to exempt bicycle tires and tubes used in the manufacture or production of new bicycles from the manufacturers excise tax on tires and tubes.
CABARET TAX
P.L. 86-422 [H.R. 2164] enacted April 8, 1960
Preamble To reduce the cabaret tax from 20 percent to 10 percent.
TAX EXEMPTION, CREDIT UNIONS
P.L. 86-428 [H.R. 6155] enacted April 22, 1960
Preamble To amend the Internal Revenue Code of 1954 to exempt from taxation certain nonprofit corporations or associations organized after August 31, 1951.
NARCOTICS MANUFACTURING ACT OF 1960
P.L. 86-429 [H.R. 529] enacted April 22, 1960
Preamble To discharge more effectively obligations of the United States under certain conventions and protocols relating to the institution of controls over the manufacture of narcotic drugs, and for other purposes.
PERSONAL HOLDING COMPANY TAX, COPYRIGHT ROYALTIES
P.L. 86-435 [H.R. 7588] enacted April 22, 1960
Preamble To amend the Internal Revenue Code of 1954 with respect to the treatment of copyright royalties for purposes of the personal holding company tax.
TAXES, EMPLOYEES' TRUSTS, TAXABILITY
P.L. 86-437 [H.R. 135] enacted April 22, 1960
Preamble To amend the Internal Revenue Code of 1954 to exclude from gross income amounts paid by the United States to certain nonresident alien employees or their beneficiaries.
TAXES, LAMINATED TIRES
P.L. 86-440 [H.R. 6785] enacted April 22, 1960
Preamble To amend section 4071 of the Internal Revenue Code so as to fix a tax of 1 cent per pound for certain laminated tires produced from used tires.
DEALER RESERVE INCOME ADJUSTMENT ACT OF 1960
P.L. 86-459 [H.R. 8684] enacted May 13, 1960
Preamble To provide transitional provisions for the income tax treatment of dealer reserve income.
TAXES, ASSESSING ADDITIONS
P.L. 86-470 [H.R. 9660] enacted May 14, 1960.
Preamble To amend section 6659(b) of the Internal Revenue Code of 1954 with respect to the procedure for assessing certain additions to tax, and for other purposes.
TAXES, FIREARMS
P.L. 86-478 [H.R. 4029] enacted June 1, 1960
Preamble To amend the Internal Revenue Code of 1954 to eliminate the proration of the occupational tax on persons dealing in machine guns and certain other firearms, to reduce occupational and transfer taxes on certain weapons, to make the transferor and transferee jointly liable for the transfer tax on firearms, and to make certain changes in the definition of a firearm.
TAXES, RAILROAD CORPORATIONS
P.L. 86-496 [H.R. 11405] enacted June 8, 1960
Preamble To provide for the treatment of income from discharge of indebtedness of a railroad corporation in a receivership proceeding or in a proceeding under section 77 of the Bankruptcy Act commenced before January 1, 1960, and for other purposes.
PUBLIC DEBT AND TAX RATE EXTENSION ACT OF 1960
P.L. 86-564 [H.R. 12381] enacted June 30, 1960
Preamble To increase for a one-year period the public debt limit set forth in section 21 of the Second Liberty Bond Act and to extend for one year the existing corporate normal-tax rate and certain excise- tax rates, and for other purposes.
SUGAR ACT OF 1948, AMENDMENT
P.L. 86-592 [H.R. 12311] enacted July 6, 1960
Preamble To amend the Sugar Act of 1948, as amended.
EXPLORATION EXPENDITURES
P.L. 86-594 [H.R. 4251] enacted July 6, 1960
Preamble To amend the Internal Revenue Code of 1954 with respect to the limitation on the deduction of exploration expenditures.
HAWAII OMNIBUS ACT
P.L. 86-624 [H.R. 11602] enacted July 12, 1960
Preamble To amend certain laws of the United States in light of the admission of the State of Hawaii into the Union, and for other purposes.
SUPPLEMENTAL UNEMPLOYMENT BENEFIT TRUSTS, TAX EXEMPTIONS
P.L. 86-667 [H.R. 8229] enacted July 14, 1960
Preamble To amend the Internal Revenue Code of 1954 to provide an exemption from income tax for supplemental unemployment benefit trusts.
OVERSEAS DIFFERENTIALS AND ALLOWANCES ACT
P.L. 86-707 [H.R. 7758] enacted September 6, 1960
Preamble To improve the administration of overseas activities of the Government of the United States, and for other purposes.
TAXES, CIGARS
P.L. 86-779 [H.R. 10960] enacted September 14, 1960
Preamble To amend section 5701 of the Internal Revenue Code of 1954 with respect to the excise tax upon cigars, and for other purposes.
FOREIGN TAX CREDIT AMENDMENT
P.L. 86-780 [H.R. 10087] enacted September 14, 1960
Preamble To amend the Internal Pevenue Code of 1954 to permit taxpayers to elect an overall limitation on the foreign tax credit.
MANUFACTURERS EXCISE TAXES, ADVERTISING CHARGES
P.L. 86-781 [H.R. 12536] enacted September 14, 1960
Preamble Relating to the treatment of charges for local advertising for purposes of determining the manufacturers sale price.
EIGHTY-SEVENTH CONGRESS, FIRST SESSION
SUGAR ACT OF 1948: AMENDMENT
P.L. 87-15 [H.R. 5463] enacted March 31, 1961
Preamble To amend and extend the Sugar Act of 1948, as amended.
TAX EXEMPTION, FOREIGN CENTRAL BANK ISSUES
P.L. 87-29 [H.R. 5189] enacted May 4, 1961
Preamble To amend the Internal Revenue Code of 1954 to exempt from tax income derived by a foreign central bank of issue from obligations of the United States, and for other purposes.
REPORT ON RENEGOTIATION, TIME EXTENSION
P.L. 87-55 [H.J. Res. 437] enacted June 21, 1961
Preamble Relating to the time for filing a report on renegotiation by the Joint Committee on Internal Revenue Taxation.
PUBLIC DEBT, GIFTS
P.L. 87-58 [H.R. 311] enacted June 27, 1961
Preamble To authorize the acceptance by the Government of gifts to be used to reduce the public debt.
PLUMBERS UNION LOCAL NO. 12, PENSION FUND
P.L. 87-59 [H.R. 1877] enacted June 27, 1961
Preamble Relating to the effective date of the qualification of Plumbers Union Local Numbered 12 Pension Fund as a qualified trust under section 401(a) of the Internal Revenue Code of 1954, and for other purposes.
FEDERAL-AID HIGHWAY PROGRAM
TITLE II-INTERNAL REVENUE CODE AND HIGHWAY TRUST FUND AMENDMENTS
P.L. 87-61 [H.R. 6713] enacted June 29, 1961
Preamble To amend certain laws relating to Federal-aid highways to make certain adjustments in the Federal-aid highway program, and for other purposes.
TAX RATE EXTENSION ACT OF 1961
P.L. 87-72 [H.R. 7446] enacted June 30, 1961
Preamble To provide a one-year extension of the existing corporate normal-tax rate and of certain excise-tax rates.
INCOME TAXES, MEMBERSHIP ORGANIZATIONS
P.L. 87-109 [H.R. 929] enacted July 26, 1961
Preamble To amend the Internal Revenue Code of 1954 to permit the prepaid dues income of certain membership organizations to be included in gross income for the taxable years to which the dues relate.
MUTUAL EDUCATIONAL AND CULTURAL EXCHANGE ACT OF 1961
P.L. 87-256 [H.R. 8666] enacted September 21, 1961
Preamble To provide for the improvement and strengthening of the international relations of the United States by promoting better mutual understanding among the peoples of the world through educational and cultural exchanges.
PEACE CORPS ACT
P.L. 87-293 [H.R. 7500] enacted September 22, 1961
Preamble To provide for a Peace Corps to help the peoples of interested countries and areas in meeting their needs for skilled manpower.
INCOME TAX, CLAY PRODUCTS
P.L. 87-312 [H.R. 7057] enacted September 26, 1961
Preamble Relating to the determination of gross income from the property for taxable years prior to 1961 in the case of certain clays and shale which were used in the manufacture of certain clay products.
FEDERAL UNEMPLOYMENT TAX ACT, AMENDMENT
P.L. 87-321 [H.R. 2585] enacted September 26, 1961
Preamble Relating to the credits against the employment tax in the case of certain successor employers and to provide an election for past taxable years with respect to the determination of gross income from mining in the case of quartzite and clay used in the production of refractory products.
JUDGES, TAX COURT OF U.S., ANNUITIES TO WIDOWS AND CHILDREN
P.L. 87-370 [H.R. 4317] enacted October 4, 1961
Preamble To amend the Internal Revenue Code of 1954 and incorporate therein provisions for the payment of annuities to widows and certain dependents of the judges of the Tax Court of the United States, and for other purposes.
TAXES, ACCOUNT NUMBERS
P.L. 87-397 [H.R. 8876] enacted October 5, 1961
Preamble To amend the Internal Revenue Code of 1954 to permit the use of identifying numbers.
EIGHTY-SEVENTH CONGRESS, SECOND SESSION
STOCK, ANTITRUST DISTRIBUTION, INCOME TAX TREATMENT
P.L. 87-403 [H.R. 8847] enacted February 2, 1962
Preamble To amend the Internal Revenue Code of 1954 so as to provide that a distribution of stock made to an individual (or certain corporations) pursuant to an order enforcing the antitrust laws shall not be treated as a dividend distribution but shall be treated as a return of capital; and to provide that the amount of such a distribution made to a corporation shall be the fair market value of the distribution.
BETA-RAY SPECTROMETER (FREE ENTRY) AND DISASTER LOSSES: TAX TREATMENT
P.L. 87-426 [H.R. 641] enacted March 31, 1962
Preamble To provide for the free entry of an intermediate lens beta- ray spectrometer for the use of Tulane University, New Orleans, Louisiana, and to amend section 165 of the Internal Revenue Code of 1954 with respect to treatment of casualty losses in areas designated by the President as disaster areas.
TAX RATE EXTENSION ACT OF 1962
P.L. 87-508 [H.R. 11879] enacted June 28, 1962
Preamble To provide a one-year extension of the existing corporate normal-tax rate and of certain excise-tax rates, and for other purposes.
SUGAR ACT AMENDMENTS OF 1962
P.L. 535 [H.R. 12154] enacted July 13, 1962
Preamble To amend and extend the provisions of the Sugar Act of 1948, as amended.
TAXES, DECLARATION BY FISHERMEN
P.L. 87-682 [H.R. 6413] enacted September 25, 1962
Preamble To extend to fishermen the same treatment accorded farmers in relation to estimated income tax.
TAXES, OPERATING LOSS CARRYOVERS
P.L. 87-7 10 [H.R. 12526] enacted September 27, 1962
Preamble To amend section 172 of the Internal Revenue Code of 1954 to provide a seven-year net operating loss carryover for certain regulated transportation corporations.
CONSUMER FINANCE COMPANIES. PERSONAL HOLDING COMPANY TAX, EXCEPTION
P.L. 87-768 [H.R. 8824] enacted October 9, 1962
Preamble To modify the application of the personal holding company tax in the case of consumer finance companies.
DUTY-FREE ENTRIES AND TAX RELIEF. PERSONAL AND HOUSEHOLD EFFECTS
P.L. 87-790 [H.R. 12180] enacted October 10, 1962
Preamble To extend for a temporary period the existing provisions of law relating to the free importation of personal and household effects brought into the United States under Government orders, and for other purposes.
SELF-EMPLOYED INDIVIDUALS TAX RETIREMENT ACT OF 1962
P.L. 87-792 [H.R. 10] enacted October 10, 1962
Preamble To encourage the establishment of voluntary pension plans by self-employed individuals.
TRADE EXPANSION ACT OF 1962
P.L. 87-794 [H.R. 11970] enacted October 11, 1962
Preamble To promote the general welfare, foreign policy, and security of the United States through international trade agreements and through adjustment assistance to domestic industry, agriculture, and labor, and for other purposes.
REVENUE ACT OF 1962
P.L. 87-834 [H.R. 10650] enacted October 16, 1962
Preamble To amend the Internal Revenue Code of 1954 to provide a credit for investment in certain depreciable property, to eliminate certain defects and inequities, and for other purposes.
MANUFACTURERS EXCISE TAXES
P.L. 87-858 [H.R. 8952] enacted October 23, 1962
Preamble To amend the provisions of the Internal Revenue Code of 1954 relating to the conditions under which the special constructive sale price rule is to apply for purposes of certain manufacturers excise taxes and relating to the taxation of life insurance companies, and for other purposes.
COCONUT AND PALM OIL, TAX SUSPENSION, EXTENSION
P.L. 87-859 [H.R. 5260] enacted October 23, 1962
Preamble To continue for an additional three year period the existing suspensions of the tax on the first domestic processing of coconut oil, palm oil, palm-kernel oil, and fatty acids, salts, combinations, or mixtures thereof.
TAXES, MEDICAL EXPENSE DEDUCTIONS
P.L. 87-863 [H.R. 10620] enacted October 23, 1962
Preamble To amend section 213 of the Internal Revenue Code of 1954 to increase the maximum limitations on the amount allowable as a deduction for medical, dental, etc., expenses, and for other purposes.
TERMINAL RAILROAD CORPORATIONS, INCOME TAX
P.L. 87-870 [H.R. 12599] enacted October 23, 1962
Preamble Relating to the income tax treatment of terminal railroad corporations and their shareholders, and for other purposes.
INTERNAL REVENUE, RETIREMENT INCOME, LIMITATIONS
P.L. 87-876 [H.R. 6371] enacted October 24, 1962
Preamble To amend the Internal Revenue Code of 1954 with respect to the limitation on retirement income, and with respect to the taxable year for which the deduction for interest paid will be allowable to certain building and loan associations, mutual savings banks, and cooperative banks.
EIGHTY-EIGHTH CONGRESS, FIRST SESSION
CHILD CARE EXPENSES, DEDUCTION
P.L. 88-4 [H.R. 2085] enacted April 2, 1963
Preamble To amend the Internal Revenue Code of 1954 to provide that the deduction for child care expenses shall be available to a wife who has been deserted by and cannot locate her husband on the same basis as a single woman.
TAXES, REDEEMABLE GROUND RENTS
P.L. 88-9 [H.R. 1597] enacted April 10, 1963
Preamble Relating to the tax treatment of redeemable ground rents.
SILVER BULLION, SILVER CERTIFICATES, AND FEDERAL RESERVE NOTES TITLE II-REPEAL OF TAX ON TRANSFERS OF SILVER BULLION
P.L. 88-36 [H.R. 5389] enacted June 4, 1963
Preamble To repeal certain legislation relating to the purchase of silver, and for other purposes.
TAX RATE EXTENSION ACT OF 1963
P.L. 88-52 [H.R. 6755] enacted June 29, 1963
Preamble To provide a one-year extension of the existing corporate normal-tax rate and of certain excise-tax rates.
TREASURY DEPARTMENT, ASSISTANT SECRETARY
P.L. 88-58 [S. 1359] enacted July 8, 1963
Preamble To provide for an additional Assistant Secretary in the Treasury Department.
DEDUCTIBILITY OF ACCRUED VACATION PAY
P.L. 88-153 [H.R. 6246] enacted October 17, 1963
Preamble Relating to the deductibility of accrued vacation pay.
EIGHTY-EIGHTH CONGRESS, SECOND SESSION
REVENUE ACT OF 1964
P.L. 88-272 [H.R. 8363] enacted February 26, 1964
Preamble To amend the Internal Revenue Code of 1954 to reduce individual and corporate income taxes, to make certain structural changes with respect to the income tax, and for other purposes.
TOBACCO PRODUCTS TAX EXEMPTION
P.L. 88-342 [H.R. 8268] enacted June 30, 1964
Preamble To prevent double taxation in the case of certain tobacco products exported and returned unchanged to the United States for delivery to a manufacturer's bonded factory.
EXCISE TAX RATE EXTENSION ACT OF 1964
P.L. 88-348 [H.R. 11376] enacted June 30, 1964
Preamble To provide a one-year extension of certain excise-tax rates, and for other purposes.
UNRELATED BUSINESS TAXABLE INCOME
P.L. 88-380 [H.R. 6455] enacted July 17, 1964
Preamble To amend subsection (b) of section 512 of the Internal Revenue Code of 1954 (dealing with unrelated business taxable income).
TAXES, COLLAPSIBLE CORPORATIONS
P.L. 88-484 [H.R. 7301] enacted August 22, 1964
Preamble To amend section 341 of the Internal Revenue Code of 1954, relating to collapsible corporations, and to amend section 543(a)(2) of such Code, relating to the inclusion of rents in personal holding company income.
DISTILLED SPIRITS TAX REFUND
P.L. 88-539 [H.R. 98] enacted August 31, 1964
Preamble To amend the Internal Revenue Code of 1954 with respect to exportation of imported distilled spirits, wines, and beer, and with respect to the total contract price of sales of personal property on the installment plan.
TAXES, VACATION PAY DEDUCTIBILITY
P.L. 88-554 [H.R. 10467] enacted August 31, 1964
Preamble To continue for a temporary period certain existing rules relating to the deductibility of accrued vacation pay, and for other purposes.
INTEREST EQUALIZATION TAX ACT
P.L. 88-563 [H.R. 8000) enacted September 2, 1964
Preamble To amend the Internal Revenue Code of 1954 to impose a tax on acquisitions of certain foreign securities in order to equalize costs of longer-term financing in the United States and in markets abroad, and for other purposes.
TAXES, INSTALLMENT OBLIGATIONS
P.L. 88-570 [H.R. 4844] enacted September 2, 1964
Preamble Relating to the release of liability under bonds filed under section 44(d) of the Internal Revenue Code of 1939 with respect to certain installment obligations transmitted at death, and to amend the Internal Revenue Code of 1954 with respect to certain reacquisitions of real property.
TAXES, LIFE INSURANCE COMPANIES
P.L. 88-571 [H.R. 5739] enacted September 2, 1964
Preamble To amend the Internal Revenue Code of 1954 to correct certain inequities with respect to the taxation of life insurance companies, and for other purposes.
LAND AND WATER CONSERVATION FUND ACT OF 1965 TITLE II - MOTORBOAT FUEL TAX PROVISIONS
P.L. 88-578 [H.R. 38461 enacted September 3, 1964
Preamble To establish a land and water conservation fund to assist the States and Federal agencies in meeting present and future outdoor recreation demands and needs of the American people, and for other purposes.
WINE, USE OF FRUIT-FLAVORED CONCENTRATES
P.L. 88-653 [H.R. 4649] enacted October 13, 1964
Preamble To amend the Internal Revenue Code of 1954 to authorize the use of certain volatile fruit-flavor concentrates in the cellar treatment of wine, and for other purposes.
EIGHTY-NINTH CONGRESS, FIRST SESSION
EXCISE TAX REDUCTION ACT OF 1965
P.L. 89-44 [H.R. 8371] enacted June 21, 1965
Preamble To reduce excise taxes, and for other purposes.
SOCIAL SECURITY TAX AMENDMENTS OF 1965
(Provided an income tax deduction for health insurance, etc.)
P.L. 89-97 [H.R. 6675] enacted July 30, 1965
Preamble To provide a hospital insurance program for the aged under the Social Security Act with a supplementary medical benefits program and an expanded program of medical assistance, to increase benefits under the Old-Age, Survivors, and Disability Insurance System, to improve the Federal-State public assistance programs, and for other purposes.
INTEREST EQUALIZATION TAX EXTENSION ACT OF 1965
P.L. 89-243 [H.R. 4750] enacted October 9, 1965
Preamble To provide an extension of the interest equalization tax, and for other purposes.
SUGAR ACT AMENDMENTS OF 1965
P.L. 89-331 [H.R. 11135] enacted November 8, 1965
Preamble To amend and extend the provisions of the Sugar Act of 1948, as amended.
EIGHTY-NINTH CONGRESS, SECOND SESSION
NONPROFIT ORGANIZATIONS-TAX EXEMPTIONS
P.L. 89-352 [H.R. 327] enacted February 2, 1966
Preamble To amend section 501(c) of the Internal Revenue Code of 1954 to exempt from taxation certain nonprofit corporations and associations operated to provide reserve funds for domestic building and loan associations, and for other purposes.
U.S. TAX COURT JUDGES-RETIREMENT PAY
P.L. 89-354 [H.R. 8445] enacted February 2, 1966
Preamble To amend the Internal Revenue Code of 1939 and the Internal Revenue Code of 1954 to change the method of computing the retired pay of judges of the Tax Court of the United States.
IRC 1939-AMENDMENT
P.L. 89-359 [H.R. 10185] enacted March 7, 1966
Preamble Amending certain estate tax provisions of the Internal Revenue Code.
FAMILY PROTECTION PLAN-TAX TREATMENT
P.L. 89-365 [H.R. 10625] enacted March 8, 1966
Preamble Relating to the tax treatment of certain amounts paid to certain members and former members of the uniform services and to their survivors.
TAX ADJUSTMENT ACT OF 1966
P.L. 89-368 [H.R. 12752] enacted March 15, 1966
Preamble To provide for graduated withholding of income tax from wages, to require declarations of estimated tax with respect to self- employment income, to accelerate current payments of estimated income tax by corporations, to postpone certain excise tax rate reductions, and for other purposes.
FOREIGN EXPROPRIATIONS, MEDICAL INSURANCE; ENROLLMENT PERIOD
P.L. 89-384 [H.R. 6319] enacted April 8, 1966
Preamble To amend the Internal Revenue Code of 1954 to provide for treatment of the recovery of losses arising from expropriation, intervention, or confiscation of properties by governments of foreign countries, and to amend title XVIII of the Social Security Act to extend the initial enrollment period for supplementary medical insurance benefits.
SMALL BUSINESS CORPORATIONS-SPECIAL OPTIONS
P.L. 89-389 [H.R. 9883] enacted April 14, 1966
Preamble To amend subchapter S of chapter 1 of the Internal Revenue Code of 1954, and for other purposes.
RENEGOTIATION ACT-EXTENSION
P.L. 89-480 [H.R. 13431] enacted June 30, 1966
Preamble To extend the Renegotiation Act of 1951.
D.C. COURTS: TRANSFER OF FUNCTIONS
P.L. 89-493 [S. 1611] enacted July 5, 1966
Preamble To transfer certain functions from the United States District Court for the District of Columbia to the District of Columbia court of General Sessions and to certain other agencies of the municipal government of the District of Columbia, and for other purposes.
EXCISE TAXES-ON TIRES AND TUBES
P.L. 89-523 [H.R. 318] enacted August 1, 1966
Preamble To amend section 4071 of the Internal Revenue Code.
INCOME TAXES-MINING EXPLORATION EXPENDITURES
P.L. 89-570 [H.R. 4665] enacted September 12, 1966
Preamble Relating to the income tax treatment of exploration expenditures in the case of mining.
ESTATE TAX
P.L. 89-621 [H.R. 483] enacted October 4, 1966
Preamble To amend section 2056 of the Internal Revenue Code of 1954 relating to the effect of disclaimers on the allowance of the marital deduction for estate tax purposes, and for other purposes.
ACCRUED VACATION PAY
P.L. 89-692 [H.R. 16774] enacted October 15, 1966
Preamble To continue for a temporary period certain existing rules relating to the deductibility of accrued vacation pay.
TAXES-DIRECT FILING OF RETURNS
P.L. 89-713 [H.R. 6958] enacted November 2, 1966
Preamble To amend the Internal Revenue Code of 1954 to promote savings under the Internal Revenue Service's automatic data processing system.
FEDERAL TAX LIEN ACT OF 1966
P.L. 89-719 [H.R. 11256] enacted November 2, 1966
Preamble To amend the Internal Revenue Code of 1954 with respect to the priority and effect of Federal tax liens and levies, and for other purposes.
INTEREST ON REFUNDS
P.L. 89-721 [H.R. 11660] enacted November 2, 1966
Preamble Relating to interest on income tax refunds made within 45 days after the filing of the tax return, and for other purposes.
RESERVE FOR CERTAIN GUARANTEED DEBT OBLIGATIONS
P.L. 89-722 [H.R. 11782] enacted November 2, 1966
Preamble To amend the Internal Revenue Code of 1954 to allow a deduction for additions to a reserve for certain guaranteed debt obligations, and for other purposes.
COMBAT PAY EXCLUSION: INCREASE
P.L. 89-739 [H.R. 17271] enacted November 2, 1966
Preamble To amend section 112 of the Internal Revenue Code of 1954 to increase from $200 to $500 the monthly combat pay exclusion for commissioned officers serving in combat zones.
NARCOTIC ADDICT REHABILITATION ACT OF 1966
P.L. 89-793 [H.R. 9167] enacted November 8, 1966
Preamble To amend title 18 of the United States Code to enable the courts to deal more effectively with the problem of narcotic addiction, and for other purposes.
DEPRECIABLE PROPERTY, INVESTMENT CREDIT SUSPENSION
P.L. 89-800 [H.R. 17607] enacted November 8, 1966
Preamble To suspend the investment credit and the allowance of accelerated depreciation in the case of certain real property.
FOREIGN INVESTORS TAX ACT OF 1966; PRESIDENTIAL ELECTION CAMPAIGN FUND ACT OF 1966
P.L. 89-809 [H.R.13103] enacted November 13, 1966
Preamble To provide equitable tax treatment for foreign investment in the United States, to establish a Presidential Election Campaign Fund to assist in financing the costs of presidential election campaigns, and for other purposes.
NINETIETH CONGRESS, FIRST SESSION
INVESTMENT CREDIT RESTORATION AND ALLOWANCE OF ACCELERATED DEPRECIATION
P.L. 90-26 [H.R. 6950] enacted June 13, 1967
Preamble To restore the investment credit and the allowance of accelerated depreciation in the case of certain real property.
INTEREST EQUALIZATION TAX; EXTENSION ACT OF 1967
P.L. 90-59 [H.R. 6098] enacted July 31, 1967
Preamble To provide an extension of the interest equalization tax, and for other purposes.
TAXES, WINE UNFIT FOR BEVERAGE USE-TAX FREE WITHDRAWAL
P.L. 90-73 [H.R. 1282] enacted August 29, 1967
Preamble To provide for the withdrawal of wine from bonded wine cellars without payment of tax when rendered unfit for beverage use, and for other purposes.
EXEMPTIONS FOR CHILDREN OF DIVORCED PARENTS
P.L. 90-78 [H.R. 6056] enacted August 31, 1967
Preamble To amend the Internal Revenue Code of 1954 to provide rules relating to the deduction for personal exemptions for children of parents who are divorced or separated.
BANK HOLDING COMPANY DISTRIBUTIONS
P.L. 90-225 [H.R. 4765] enacted December 27, 1967
Preamble To amend the Internal Revenue Code of 1954 with respect to the income tax treatment of certain distributions pursuant to the Bank Holding Company Act of 1956, as amended, and for other purposes.
ARMED FORCES-GIFTS BY MEMBERS IN COMBAT ZONES AND DUTY-FREE ENTRY
P.L. 90-240 [H.R. 1141] enacted January 2, 1968
Preamble To continue the duty-free status of certain gifts by members of the Armed Forces serving in combat zones, and for other purposes.
NINETIETH CONGRESS, SECOND SESSION
EXCISE TAXES-EXTENSION
P.L. 90-285 [H.J. Res. 1223] enacted April 12, 1968
Preamble To continue for a temporary period the 7 percent excise tax rate on automobiles and the 10 percent excise tax rate on communication services.
POLITICAL ADVERTISING IN NATIONAL CONVENTION PROGRAM-INCOME TAX DEDUCTION
P.L. 90-346 [H.R. 17325] enacted June 18, 1968
Preamble To amend the Internal Revenue Code of 1954 with respect to advertising in a convention program of a national political convention.
REVENUE AND EXPENDITURE CONTROL ACT OF 1968
P.L. 90-364 [H.R. 15414] enacted June 28, 1968
Preamble To increase revenues, to limit expenditures and new obligational authority, and for other purposes.
SELF-EMPLOYED INDIVIDUALS-PENSION PLANS
P.L. 90-607 [H.R. 18253] enacted October 21, 1968
Preamble Relating to the effective date of the 1966 change in the definition of earned income for purposes of pension plans of self- employed individuals.
GUN CONTROL ACT OF 1968
TITLE II-MACHINE GUNS, DESTRUCTIVE DEVICES, AND CERTAIN OTHER FIREARMS
P.L. 90-618 [H.R. 17735] enacted October 22, 1968
Preamble To amend title 18, United States Code, to provide for better control of the interstate traffic in firearms.
TAXES-WINE SPIRITS
P.L. 90-619 [H.R. 14095] enacted October 22, 1968
Preamble To amend the Internal Revenue Code of 1954 so as to make certain changes to facilitate the production of wine, and for other purposes.
TAXES-CORPORATIONS-STATUTORY MERGERS
P.L. 90-621 [H.R. 18942] enacted October 22, 1968
Preamble Relating to the income tax treatment of certain statutory mergers of corporations.
TAXES-GLOBAL COMMUNICATIONS SATELLITE SYSTEM-TAX EXEMPTION
P.L. 90-622 [H.R. 18486] enacted October 22, 1968
Preamble To amend the Internal Revenue Code of 1954 with respect to the treatment of income from the operation of a communications satellite system.
TAXES-DEFINITION OF COMPENSATION
P.L. 90-624 [H.R. 7567] enacted October 22, 1968
Preamble To amend the Internal Revenue Code of 1954 with respect to the definition of compensation for purposes of tax under the Railroad Retirement Tax Act, and for other purposes.
TAXES-DISTILLED SPIRITS
P.L. 90-630 [H.R. 11394] enacted October 22, 1968
Preamble To amend certain provisions of the Internal Revenue Code of 1954 relating to distilled spirits, and for other purposes.
INDUSTRIAL DEVELOPMENT BONDS; EXEMPTION FOR CERTAIN SMALL ISSUES
P.L. 90-634 [H.R. 17324] enacted October 24, 1968
Preamble To extend and amend the Renegotiation Act of 1951, and for other purposes.
NINETY-FIRST CONGRESS, FIRST SESSION
INCOME WITHHOLDING RATES EXTENSION
P.L. 91-36 [H.R. 4229] enacted June 30, 1969
Preamble To continue for a temporary period the existing suspension of duty on heptanoic acid, and to continue for one month the existing rates of withholding of income tax.
INTEREST EQUALIZATION TAX-EXTENSION
P.L. 91-50 [H.R. 13079] enacted August 2, 1969
Preamble To continue for a temporary period the existing interest equalization tax.
FEDERAL UNEMPLOYMENT TAX; EMPLOYMENT SECURITY ADMINISTRATION ACCOUNT; INCOME TAX SURCHARGE
P.L. 91-53 [H.R. 9951] enacted August 7, 1969
Preamble To provide for the collection of the Federal unemployment tax in quarterly installments during each taxable year; to make status of employer depend on employment during preceding as well as current taxable year; to exclude from the computation of the excess the balance in the employment security administration account as of the close of fiscal years 1970 through 1972; to raise the limitation on the amount authorized to be made available for expenditure out of the employment security administration account by the amounts so excluded; and for other purposes.
ISTLE: DUTY SUSPENSION & INTEREST EQUALIZATION TAX: EXTENSION
P.L. 91-65 [H.R. 10107] enacted August 25, 1969
Preamble To continue for a temporary period the existing suspension of duty on certain istle and the existing interest equalization tax.
INTEREST EQUALIZATION TAX EXTENSION ACT OF 1969
P.L. 91-128 [H.R. 12829] enacted November 26, 1969
Preamble To provide an extension of the interest equalization tax, and for other purposes.
TAX REFORM ACT OF 1969
P.L. 91-172 [H.R. 13270] enacted December 30, 1969
Preamble To reform the income tax laws.
NINETY-FIRST CONGRESS, SECOND SESSION
TREATMENT OF CERTAIN INDIVIDUALS AS SERVING IN COMBAT ZONE
P.L. 91-235 [H.R. 8654] enacted April 24, 1970
Preamble To provide that, for purposes of the Internal Revenue Code of 1954, individuals who were illegally detained during 1968 by the Democratic People's Republic of Korea shall be treated as serving in a combat zone.
AIRPORT AND AIRWAY DEVELOPMENT ACT OF 1970
P.L. 91-258 [H.R. 14465] enacted May 21, 1970
Preamble To provide for the expansion and improvement of the Nation's airport and airway system, for the imposition of airport and airway user charges, and for other purposes.
UTE TRIBES: JUDGEMENT FUNDS, DISPOSITION
P.L. 91-420 [S. 3997] enacted September 25, 1970
Preamble To provide for the disposition of funds appropriated to pay a judgment in favor of the Confederated Bands of Ute Indians in Court of Claims case 47567, and a judgement in favor of the Ute Tribe of the Uintah and Ouray Reservation for and on behalf of the Uncompahgre Band of Ute Indians in Indian Claims Commission docket numbered 349, and for other purposes.
FEDERAL-AID HIGHWAY ACT OF 1970
TITLE III-EXTENSION OF HIGHWAY TRUST FUND AND CERTAIN RELATED PROVISIONS
P.L. 91-605 [H.R. 19504] enacted December 31, 1970
Preamble To authorize appropriations for the construction of certain highways in accordance with title 23 of the United States Code, and for other purposes.
EXCISE, ESTATE, AND GIFT TAX ADJUSTMENT ACT OF 1970
P.L. 91-614 [H.R. 16199] enacted December 31, 1970
Preamble To establish a working capital fund for the Department of the Treasury; to amend the Internal Revenue Code of 1954 to accelerate the collection of estate and gift taxes to continue excise taxes on passenger automobiles and communications services; and for other purposes.
CEMETERY CORPORATIONS-INCOME TAX EXEMPTION
P.L. 91-618 [H.R. 16506] enacted December 31, 1970
Preamble To amend the Internal Revenue Code of 1954 to clarify the applicability of the exemption from income taxation of cemetery corporations.
TAXES-FLOOR STOCK REFUNDS-CLAIMS-FILING EXTENSION
P.L. 91-642 [H.R. 17473] enacted December 31, 1970
Preamble To extend the period for filing certain manufacturers claims for floor stocks refunds under section 209(b) of the Excise Tax Reduction Act of 1965, and for other purposes.
DISTILLED SPIRITS TAXES
P.L. 91-659 [H.R. 10517] enacted January 8, 1971
Preamble To amend certain provisions of the Internal Revenue Code of 1954 relating to distilled spirits, and for other purposes.
BEER TAXES
P.L. 91-673 [H.R. 6562] enacted January 12, 1971
Preamble To amend certain provisions of the Internal Revenue Code of 1954 relating to beer, and for other purposes.
TAX REFORM ACT OF 1969-AMENDMENT
P.L. 91-675 [H.R. 17984] enacted January 12, 1971
Preamble To amend section 905 of the Tax Reform Act of 1969.
TAXES FOR LEASED AIRCRAFT-INVESTMENT CREDIT RECAPTURE
P.L. 91-676 [H.R. 17988] enacted January 12, 1971
Preamble To amend section 47 of the Internal Revenue Code of 1954 to allow aircraft to be leased for temporary use outside the United States without a recapture of the investment credit.
TAXES-EXPROPRIATION OF PROPERTY BY CUBA; PROPERTY LOSSES
P.L. 91-677 [H.R. 18693] enacted January 12, 1971
Preamble To amend provisions of the Internal Revenue Code of 1954 relating to the treatment of certain losses sustained by reason of the confiscation of property by the government of Cuba.
CEMENT MIXERS FLOOR STOCK REFUNDS
P.L. 91-678 [H.R. 17658] enacted January 12, 1971
Preamble To provide floor stock refunds in the case of cement mixers.
JOINT RETURNS-LIABILITY
P.L. 91-679 [H.R. 19774] enacted January 12, 1971
Preamble To amend the Internal Revenue Code of 1954 to provide that in certain cases a spouse will be relieved of liability arising from a joint income tax return.
ALMOND GROVE CAPITAL EXPENDITURES
P.L. 91-680 [H.R. 19242] enacted January 12, 1971
Preamble To amend section 278 of the Internal Revenue Code of 1954 to extend its application from citrus groves to almond groves.
FOREIGN CORPORATIONS; RECOGNITION OF GAINS ON EXCHANGES
P.L. 91-681 [H.R. 19686] enacted January 12, 1971
Preamble To amend section 367 of the Internal Revenue Code of 1954.
SMALL BUSINESS CORPORATIONS; PASSIVE INVESTMENT INCOME
P.L. 91-683 [H.R. 19627] enacted January 12, 1971
Preamble To amend section 1372 of the Internal Revenue Code of 1954, relating to passive investment income.
FOREIGN CORPORATIONS-FOREIGN TAX CREDIT
P.L. 91-684 [H.R. 18549] enacted January 12, 1971
Preamble To amend sections 902(b) and 902(c) of the Internal Revenue Code of 1954 to reduce the 50-percent requirement to 10 percent between first and second levels and to include third-level foreign corporations in the tax credit structure if the 10-percent test is met.
REAL PROPERTY SALES BY CORPORATIONS
P.L. 91-686 [H.R. 19790] enacted January 12, 1971
Preamble Relating to the income tax treatment of certain sales of real property by a corporation.
LOSSES ON WORTHLESS SECURITIES
P.L. 91-687 [H.R. 19369] enacted January 12, 1971
Preamble To amend section 165(g) of the Internal Revenue Code of 1954 which provides for treatment of losses on worthless securities.
TAX RETURNS OF LIFE INSURANCE COMPANIES
P.L. 91-688 [H.R. 19881] enacted January 12, 1971
Preamble Relating to consolidated returns of life insurance companies, and for other purposes.
UNION-NEGOTIATED PENSION PLANS-QUALIFICATION PERIOD
P.L. 91-691 [H.R. 17917] enacted January 12, 1971
Preamble To amend the Internal Revenue Code of 1954 with respect to the period of qualification of certain union-negotiated pension plans.
CORPORATIONS-STATUTORY MERGERS
P.L. 91-693 [H.R. 19562] enacted January 12, 1971
Preamble To amend the Internal Revenue Code of 1954 with respect to certain statutory mergers.
NINETY-SECOND CONGRESS, FIRST SESSION
INTEREST EQUALIZATION TAX EXTENSION ACT OF 1971
P.L. 92-9 [H.R. 5432] enacted April 1, 1971
Preamble To provide an extension of the interest equalization tax, and for other purposes.
RENEGOTIATION ACT OF 1951, AMENDMENTS; U.S. TAX COURT JUDGES
P.L. 92-41 [H.R. 8311] enacted July 1, 1971
Preamble To amend the Renegotiation Act of 1951 to extend the Act for two years, to modify the interest rate on excessive profits and on refunds, to provide that the Court of claims shall have jurisdiction of renegotiation cases, and for other purposes.
REVENUE ACT OF 1971
P.L. 92-178 [H.R. 10947] enacted December 10, 1971
Preamble To provide a job development investment credit, to reduce individual income taxes, to reduce certain excise taxes, and for other purposes.
NINETY-SECOND CONGRESS, SECOND SESSION
PRISONERS OF WAR, VIETNAM CONFLICT; INCOME TAX EXCLUSION
P.L. 92-279 [H.R. 9900] enacted April 26, 1972
Preamble To amend section 112 of the Internal Revenue Code of 1954 to exclude from gross income the entire amount of the compensation of members of the Armed Forces of the United States and of civilian employees who are prisoners of war, missing in action, or in a detained status during the Vietnam conflict.
TREASURY DEPARTMENT POSITIONS, ESTABLISHMENT
P.L. 92-302 [H.R. 13334] enacted May 18, 1972
Preamble To establish certain positions in the Department of the Treasury, to fix the compensation for those positions, and for other purposes.
FEDERAL PERSONNEL SURETY BONDS: ELIMINATION
P.L. 92-310 [H.R. 13150] enacted June 6, 1972
Preamble To provide that the Federal Government shall assume the risks of its fidelity losses, and for other purposes.
VETERANS' ORGANIZATIONS, TAX EXEMPT STATUS
P.L. 92-418 [H.R. 11185] enacted August 29, 1972
Preamble To amend the Internal Revenue Code of 1954 with regard to the exempt status of veterans' organizations, and for other purposes.
REVENUE SHARING ACT OF 1972
P.L. 92-512 [H.R. 14370] enacted October 20, 1972
Preamble To provide fiscal assistance to State and local governments, to authorize Federal collection of State individual income taxes, and for other purposes.
WILDLIFE RESTORATION FUND; BOWS AND ARROWS, TAX
P.L. 92-558 [H.R. 11091] enacted October 25, 1972
Preamble To provide additional funds for certain wildlife restoration projects, and for other purposes.
TAXES, AMERICAN SAMOANS
P.L. 92-580 [H.R. 1467] enacted October 27, 1972
Preamble To amend the Internal Revenue Code of 1954 with respect to personal exemptions in the case of American Samoans, and for other purposes.
COORDINATION OF UNITED STATES AND GUAM INDIVIDUAL INCOME TAXES
P.L. 92-606 [H.R. 14628] enacted October 31, 1972
Preamble To amend the Internal Revenue Code of 1954 with respect to the tax laws applicable to Guam, and for other purposes.
NINETY-THIRD CONGRESS, FIRST SESSION
INTEREST EQUALIZATION TAX EXTENSION ACT OF 1973
P.L. 93-17 [H.R. 3577] enacted April 10, 1973
Preamble To provide an extension of the interest equalization tax, and for other purposes.
PRESIDENTIAL ELECTION CAMPAIGN FUND
P.L. 93-53 [H.R. 8410] enacted July 1, 1973
Preamble To continue the existing temporary increase in the public debt limit through November 30, 1973, and for other purposes.
RENEGOTIATION ACT OF 1951, AND SOCIAL SECURITY ACT, AMENDMENTS
P.L. 93-66 [H.R. 7445] enacted July 9, 1973
Preamble To extend the Renegotiation Act of 1951 for one year, and for other purposes.
NINETY-THIRD CONGRESS, SECOND SESSION
COPYING SHOE LATHES. DUTY SUSPENSION, EXTENSION
P.L. 93-310 [H.R. 8215] enacted June 8, 1974
Preamble To provide for the suspension of duty on certain copying shoe lathes until the close of June 30, 1976, and for other purposes.
WILDLIFE RESTORATION PROJECTS FUNDS EXTENSION
P.L. 93-313 [H.R. 10972] enacted June 8, 1974
Preamble To delay for six months the taking effect of certain measures to provide additional funds for certain wildlife restoration projects.
RENEGOTIATION ACT OF 1951 EXTENSION
P.L. 93-329 [H.R. 14833] enacted June 30, 1974
Preamble To extend the Renegotiation Act of 1951 for eighteen months.
EMPLOYEE RETIREMENT INCOME SECURITY ACT OF 1974
P.L. 93-406 [H.R. 2] enacted September 2, 1974
Preamble An Act to provide for pension reform.
PRESIDENTIAL ELECTION CAMPAIGN FUND
P.L. 93-443 [S. 3044] enacted October 15, 1974
Preamble To impose overall limitations on campaign expenditures and political contributions; to provide that each candidate for Federal office shall designate a principal campaign committee; to provide for a single reporting responsibility with respect to receipts and expenditures by certain political committees; to change the times for the filing of reports regarding campaign expenditures and political contributions; to provide for public financing of Presidential nominating conventions and Presidential primary elections; and for other purposes.
CRUDE FEATHERS AND DOWNS, DUTY RATE; PERSONAL HOLDING COMPANY, INCOME EXCLUSION; HEALTH INSURANCE FOR THE AGED
P.L. 93-480 [H.R. 11452] enacted October 26, 1974
Preamble To correct an anomaly in the rate of duty applicable to crude feathers and downs, and for other purposes.
CORPORATIONS, QUALIFIED EXPORT ASSETS; EXPENDITURES OF LOW INCOME RENTAL HOUSING REHABILITATION
P.L. 93-482 [H.R. 11251] enacted October 26, 1974
Preamble To amend the Tariff Schedules of the United States to provide for the duty-free entry of methanol imported for use as fuel, and for other purposes.
CARBOXYMETHYL CELLULOSE SALTS, DUTY SUSPENSION; INTERNAL REVENUE CODE OF 1954, AMENDMENTS
P.L. 93-483 [H.R. 12035] enacted October 26, 1974
Preamble To suspend until the close of June 30, 1975, the duty on certain carboxymethyl cellulose salts, and for other purposes.
CERTAIN BICYCLE PARTS AND ACCESSORIES, DUTY SUSPENSION; INTERNAL REVENUE CODE OF 1954, AMENDMENTS
P.L. 93-490 [H.R. 6642] enacted October 26, 1974
Preamble To suspend the duties on certain bicycle parts and accessories until the close of December 31, 1976, and for other purposes.
PERCENTAGE DEPLETION AND WAGERING TAX AMENDMENTS
P.L. 93-499 [H.R. 7780] enacted October 29, 1974
Preamble To extend for an additional temporary period the existing suspension of duties on certain classifications of yarns of silk, and for other purposes.
TAX TREATMENT OF SERVICEMEN, PRISONERS OF WAR, ETC.
P.L. 93-597 [H.R. 8214] enacted January 2, 1975
Preamble To modify the tax treatment of members of the Armed Forces of the United States and civilian employees who are prisoners of war or missing in action, and for other purposes.
AMORTIZATION EXTENSION; ACCRUED VACATION PAY; CLASS LIFE SYSTEM FOR REALTY; REAL ESTATE INVESTMENT TRUSTS; INTEREST ON TAX DEFICIENCIES; STUDENT LOAN FUNDING; EXCLUSION OF INTEREST BY NON-RESIDENT ALIENS; INTEREST EQUALIZATION TAX; TAX TREATMENT OF POLITICAL ORGANIZATIONS
P.L. 93-625 [H.R. 421] enacted January 3, 1975
Preamble To amend the Tariff Schedules of the United States to permit the importation of upholstery regulators, upholsterer's regulating needles, and upholsterer's pins free of duty.
NINETY-FOURTH CONGRESS, FIRST SESSION
TAX REDUCTION ACT OF 1975
P.L. 94-12 [H.R. 2166] enacted February 18, 1975
Preamble An Act to amend the Internal Revenue Code of 1954 to provide for a refund of 1974 individual income taxes, to increase the low income allowance and the percentage standard deduction, to provide a credit for personal exemptions and a credit for certain earned income, to increase the investment credit and the surtax exemption, to reduce percentage depletion for oil and gas, and for other purposes.
EMERGENCY COMPENSATION AND SPECIAL UNEMPLOYMENT ASSISTANCE EXTENSION ACT OF 1975
P.L. 94-45 [H.R. 6900] enacted June 30, 1975
Preamble To provide an additional thirteen weeks of benefits under the emergency unemployment compensation program and the special unemployment assistance program, to extend the special unemployment assistance program for one year, and for other purposes.
INDIANS-KLAMATH TRIBE, GAINS FROM CONDEMNATION OF CERTAIN FOREST LANDS-TAX EXCLUSION
P.L. 94-81 [H.R. 83] enacted August 9, 1975
Preamble To exclude from gross income gains from the condemnation of certain forest lands held in trust for the Klamath Indian Tribe.
REVENUE ADJUSTMENT ACT OF 1975
P.L. 94-164 [H.R. 9968] enacted December 23, 1975
Preamble An Act to change certain income tax provisions of the Internal Revenue Code of 1954, and for other purposes.
NINETY-FOURTH CONGRESS, SECOND SESSION
NEW YORK-PUBLIC EMPLOYEE RETIREMENT SYSTEMS
P.L. 94-236 [H.R. 11700] enacted March 19, 1976
Preamble Relating to the application of certain provisions of the Internal Revenue Code of 1954 to specified transactions by certain public employee retirement systems created by the State of New York or any of its political subdivisions.
TAX TREATMENT OF CONRAIL EXCHANGES
P.L. 94-253 [H.R. 12490] enacted March 31, 1976
Preamble To provide tax treatment for exchanges under the final system plan for ConRail.
EMPLOYEE RETIREMENT PLANS; ROLLOVER OF DISTRIBUTIONS
P.L. 94-267 [H.R. 12725] enacted April 15, 1976
Preamble To amend the Internal Revenue Code of 1954 to permit tax- free rollovers of distributions from employee retirement plans in the event of plan termination.
FEDERAL-AID HIGHWAY ACT OF 1976
TITLE III-EXTENSION OF HIGHWAY TRUST FUND AND CERTAIN RELATED PROVISIONS
P.L. 94-280 [H.R. 8235] enacted May 5, 1976
Preamble To authorize appropriations for the construction of certain highways in accordance with title 23 of the United States Code, and for other purposes.
FEDERAL ELECTION CAMPAIGN ACT AMENDMENTS OF 1976
P.L. 94-283 [S. 3065] enacted May 11, 1976
Preamble To amend the Federal Election Campaign Act of 1971 to provide that members of the Federal Election Commission shall be appointed by the President, by and with the advice and consent of the Senate, and for other purposes.
LIFE INSURANCE COMPANIES-POLICYHOLDERS SURPLUS AMOUNT
P.L. 94-331 [H.R. 10051] enacted June 30, 1976
Preamble To amend section 815 of the Internal Revenue Code to allow a life insurance company to disregard (for purposes of that section) a distribution during the last month of its taxable year, determined to have been made out of the policyholders surplus account, if such distribution is returned to the company not later than the due date for filing its income tax return (including extensions thereof) for that year, and for other purposes.
AIRPORT AND AIRWAY DEVELOPMENT ACT AMENDMENTS OF 1976
P.L. 94-353 [H.R. 9771] enacted July 12, 1976
Preamble To amend the Airport and Airway Development Act of 1970.
TAXES-CERTAIN OPTION INCOME OF EXEMPT ORGANIZATIONS
P.L. 94-396 [H.R. 3052] enacted September 3, 1976
Preamble To amend section 512(b)(5) of the Internal Revenue Code of 1954 with respect to the tax treatment of the gain on the lapse of options to buy or sell securities.
SOCIAL SECURITY ACT, AMENDMENTS
P.L. 94-401 [H.R. 12455] enacted September 7, 1976
Preamble To amend title XX of the Social Security Act so as to permit greater latitude by the States in establishing criteria regarding eligibility for social services, to facilitate and encourage the implementation by States of child day care services programs conducted pursuant to such title, to promote the employment of welfare recipients in the provision of child day care services, and for other purposes.
TAXES-COMMON TRUST FUNDS-TREATMENT OF AFFILIATED BANKS
P.L. 94-414 [H.R. 5071] enacted September 17, 1976
Preamble To amend section 584 of the Internal Revenue Code of 1954 with respect to the treatment of affiliated banks for purposes of the common trust fund provisions of such Code.
BANK HOLDING COMPANY TAX ACT OF 1976
P.L. 94-452 [H.R. 11997] enacted October 2, 1976
Preamble To amend the Internal Revenue Code of 1954 with respect to the tax treatment of certain divestitures of assets by bank holding companies.
TAX REFORM ACT OF 1976
P.L. 94-455 [H.R. 10612] enacted October 4, 1976
Preamble An Act to reform the tax laws of the United States.
TAXES-INTEREST DEDUCTION ON CERTAIN CORPORATE INDEBTEDNESS
P.L. 94-514 [H.R. 7929] enacted October 15, 1976
Preamble Relating to the deduction of interest on certain corporate indebtedness to acquire stock or assets of another corporation.
TAXES-CEMETERY PERPETUAL CARE FUNDS
P.L. 94-528 [H.R. 1142] enacted October 17, 1976
Preamble To amend the Internal Revenue Code of 1954 to provide for a distribution deduction for certain cemetery perpetual care fund, to modify the effective dates of certain provision of the Tax Reform Act of 1976, and for other purposes.
BEER-SMALL BUSINESS TAX REDUCTION
P.L. 94-529 [H.R. 3605] enacted October 17, 1976
Preamble To amend section 5051 of the Internal Revenue Code of 1954 (relating to the Federal excise tax on beer).
TAXES-CERTAIN AIRCRAFT MUSEUMS-FUEL TAX EXEMPTIONS
P.L. 94-530 [H.R. 10101] enacted October 17, 1976
Preamble To amend the Internal Revenue Code of 1954 to exempt certain aircraft museums from Federal fuel taxes and the Federal tax on the use of civil aircraft, and for other purposes.
TITLE 17, USC, COPYRIGHTS
P.L. 94-553 [S. 22] enacted October 19, 1976
Preamble For the general revision of the Copyright Law, title 17 of the United States Code, and for other purposes.
TAXES-EXEMPT ORGANIZATIONS
P.L. 94-568 [H.R. 1144] enacted October 20, 1976
Preamble To amend the Internal Revenue Code of 1954 with respect to the tax treatment of social clubs and certain other membership organizations, to provide for a study of tax incentives for recycling, and for other purposes.
TAXES-DISTILLED SPIRITS-USE OF STAMPS ON CONTAINERS
P.L. 94-569 [H.R. 7228] enacted October 20, 1976
Preamble To amend the Internal Revenue Code of 1954 to permit the authorization of means other than stamp on containers of distilled spirits as evidence of tax payment, to provide an extension of certain provisions relating to members of the Armed Forces missing in action, and for other purposes.
NINETY-FIFTH CONGRESS, FIRST SESSION
TAX REDUCTION AND SIMPLIFICATION ACT OF 1977
P.L. 95-30 [H.R. 3477] enacted May 23, 1977
Preamble An Act to reduce individual and business income taxes and to provide tax simplification and reform.
SECRETARY OF THE TREASURY. PUBLIC MONEYS, INVESTMENT AUTHORITY
P.L. 95-147 [H.R. 5675] enacted October 28, 1977
Preamble To authorize the Secretary of the Treasury to invest public moneys, and for other purposes.
SOCIAL SECURITY ACT-AMENDMENTS
P.L. 95-171 [H.R. 3387] enacted November 12, 1977
Preamble To extend certain Social Security Act provisions, and for other purposes.
CERTAIN SILK YARDS DUTY SUSPENSION EXTENSION-INTERNAL REVENUE CODE OF 1954 AMENDMENT TO STATE AND LOCAL TAXES NOT INCLUDED IN DETERMINING AMOUNTS PAID FOR COMMUNICATIONS SERVICES
P.L. 95-172 [H.R. 3373] enacted November 12, 1977
Preamble To extend for an additional temporary period the existing suspension of duties on certain classifications of yarns of silk, and for other purposes.
TAXES-DISTILLED SPIRITS OR WINES
P.L. 95-176 [H.R. 4458] enacted November 14, 1977
Preamble To amend certain provisions of the Internal Revenue Code of 1954 relating to distilled spirits, and for other purposes.
SOCIAL SECURITY ACT, AMENDMENT
P.L. 95-210 [H.R. 8422] enacted December 13, 1977
Preamble To amend titles XVIII and XIX of the Social Security Act to provide payment for rural health clinic services, and for other purposes.
EMPLOYEE RETIREMENT INCOME SECURITY ACT OF 1974-AMENDMENT
P.L. 95-214 [H.R. 9378] enacted December 19, 1977
Preamble To amend title IV of the Employee Retirement Income Security Act of 1974 to postpone, for two years, the date on which the corporation first begins paying benefits under terminated multi- employer plans.
NINETY-FIFTH CONGRESS, SECOND SESSION
BLACK LUNG BENEFITS REVENUE ACT OF 1977
P.L. 95-227 [H.R. 5322] enacted February 10, 1978
Preamble To impose an excise tax on the sale of coal by the producer, to establish a Black Lung Disability Trust Fund, and for other purposes.
BLACK LUNG BENEFITS REFORM ACT OF 1977
P.L. 95-239 [H.R. 4544] enacted March 1, 1978
Preamble To amend the Federal Coal Mine Health and Safety Act to improve the black lung benefits program established under such Act, and for other purposes.
TAXES-CERTAIN CROP PAYMENTS; STATE LEGISLATORS' TRAVEL EXPENSES
P.L. 95-258 [H.R. 11055] enacted April 7, 1978
Preamble Relating to the year for including in income certain payments under the Agricultural Act of 1949 received in 1978 but attributable to 1977, and to extend for one year the existing treatment of State legislators' travel expenses away from home.
NEW YORK CITY LOAN GUARANTEE ACT OF 1978
P.L. 95-339 [H.R. 12426] enacted August 8, 1978
Preamble To authorize the Secretary of the Treasury to provide financial assistance for the city of New York.
INTERNAL REVENUE CODE TREATMENT OF INCOME FROM NONMEMBER TELEPHONE COMPANIES
P.L. 95-345 [H.R. 7581] enacted August 15, 1978
Preamble To amend the Internal Revenue Code of 1954 with respect to the treatment of mutual or cooperative telephone company income from nonmember telephone companies, and for other purposes.
TAXES-ALCOHOLIC BEVERAGES-EXCISE TAX REFUND-LOSSES RESULTING FROM DISASTER, VANDALISM, OR MALICIOUS MISCHIEF
P.L. 95-423 [H.R. 1920] enacted October 6, 1978
Preamble To amend section 5064 of the Internal Revenue Code of 1954 to provide for refund of tax on distilled spirits, wines, rectified products, and beer lost or rendered unmarketable due to fire, flood, casualty, or other disaster, or to breakage, destruction, or other damage (excluding theft) resulting from vandalism or malicious mischief while held for sale.
TAXES-REGULATIONS ON TAXATION OF FRINGE BENEFITS-PROHIBITION
P.L. 95-427 [H.R. 12841] enacted October 7, 1978
Preamble To prohibit the issuance of regulations on the taxation of fringe benefits, and for other purposes.
EXCISE TAXES ON TRUCKS, BUSES AND TRACTORS; HOME PRODUCTION OF BEER AND WINE; AERIAL APPLICATORS; ROLLOVER OF LUMP SUM DISTRIBUTIONS
P.L. 95-458 [H.R. 1337] enacted October 14, 1978
Preamble To amend the Internal Revenue Code of 1954 with respect to excise tax on certain trucks, buses, tractors, et cetera, home production of beer and wine, refunds of the taxes on gasoline and special fuels to aerial applicators, and partial rollovers of lump sum distributions.
U.S. TAX COURT-JUDGES' RETIREMENT PAY
P.L. 95-472 [H.R. 8811] enacted October 17, 1978
Preamble To amend section 7447 of the Internal Revenue Code of 1954 with respect to the revocation of an election to receive retired pay as a judge of the Tax Court.
BLACK LUNG BENEFIT TRUSTS
P.L. 95-488 [H.R. 13167] enacted October 20, 1978
Preamble To amend the Internal Revenue Code of 1954 to insure that the deduction for contributions to a black lung benefit trust be allowed for any such contributions which are made for the purpose of satisfying unfunded future liability, and for other purposes.
TAXES-NEW YORK PUBLIC EMPLOYEES RETIREMENT SYSTEMS
P.L. 95-497 [H.R. 12051] enacted October 21, 1978
Preamble Relating to the application of certain provisions of the Internal Revenue Code of 1954 to specified transactions by certain public employee retirement systems created by the State of New York or any of its political subdivisions.
INTERNAL REVENUE CODE OF 1954 -- AMENDMENT
TITLE II-INLAND WATERWAYS REVENUE ACT OF 1978
TITLE III-PROCEEDS FROM BINGO GAMES
P.L. 95-502 [H.R. 8533] enacted October 21, 1978
Preamble To amend the Internal Revenue Code of 1954 to provide that income from the conducting of certain bingo games by certain tax- exempt organizations will not be subject to tax, and for other purposes.
SURFACE TRANSPORTATION ASSISTANCE ACT OF 1978
TITLE V-HIGHWAY REVENUE ACT OF 1978
P.L. 95-599 [H.R. 11733] enacted November 6, 1978
Preamble To authorize appropriations for the construction of certain highways in accordance with title 23 of the United States Code, for highway safety, for mass transportation in urban and in rural areas, and for other purposes.
REVENUE ACT OF 1978
P.L. 95-600 [H.R. 13511] enacted November 6, 1978.
Preamble An Act to amend the Internal Revenue Code of 1954 to reduce income taxes, and for other purposes.
TAX TREATMENT EXTENSION ACT OF 1977
P.L. 95-615 [H.R. 9251] enacted November 8, 1978
Preamble To change the tax treatment of income earned abroad by United States citizens and residents, and for other purposes.
ENERGY TAX ACT OF 1978
P.L. 95-618 [H.R. 5263] enacted November 9, 1978
Preamble An Act to provide tax incentives for the production and conservation of energy, and for other purposes.
MISCELLANEOUS TIMING REQUIREMENTS
P.L. 95-628 [H.R. 7320] enacted November 10, 1978
Preamble To revise miscellaneous timing requirements of the revenue laws, and for other purposes.
NINETY-SIXTH CONGRESS, FIRST SESSION
DISTILLED SPIRITS TAX REVISION ACT OF 1979
P.L. 96-39 [H.R. 4537] enacted July 26, 1979
Preamble To approve and implement the trade agreements negotiated under the Trade Act of 1974, and for other purposes.
UNEMPLOYMENT COMPENSATION AMENDMENTS OF 1976, AMENDMENT
P.L. 96-84 [H.R. 3920] enacted October 10, 1979
Preamble To amend the Unemployment Compensation Amendments of 1976 with respect to the National Commission on Unemployment Compensation, and for other purposes.
PROHIBITION OF ISSUANCE OF FRINGE BENEFIT REGULATIONS
P.L. 96-167 [H.R. 5224] enacted December 29, 1979
Preamble To continue through May 31, 1981, the existing prohibition on the issuance of fringe benefit regulations, and for other purposes.
BUSINESS EXPENSES OF STATE LEGISLATORS
P.L. 96-178 [H.R. 3091] enacted January 2, 1980
Preamble To extend for one year the provisions of law relating to the business expenses of State legislators.
FEDERAL ELECTION CAMPAIGN ACT AMENDMENTS OF 1979
P.L. 96-187 [H.R. 5010] enacted January 8, 1980
Preamble To amend the Federal Election Campaign Act of 1971 to make certain changes in the reporting and disclosure requirements of such Act, and for other purposes.
NINETY-SIXTH CONGRESS, SECOND SESSION
TECHNICAL CORRECTIONS ACT OF 1979
P.L. 96-222 [H.R. 2797] enacted April 1, 1980
Preamble An Act to make technical corrections related to the Revenue Act of 1978.
CRUDE OIL WINDFALL PROFIT TAX ACT OF 1980
P.L. 96-223 [H.R. 3919] enacted April 2, 1980
Preamble An Act to impose a windfall profit tax on domestic crude oil, and for other purposes.
FOOD STAMP ACT AMENDMENTS OF 1980
P.L. 96-249 [S. 1309] enacted May 26, 1980
Preamble To amend the Food Stamp Act of 1977 to improve food stamp program fiscal accountability through reductions in inaccurate eligibility and benefit determinations; to improve the system of deductions; to increase the specific dollar limitations on appropriations for the fiscal years 1980 and 1981 food stamp programs; and for other purposes.
ADOPTION ASSISTANCE AND CHILD WELFARE ACT OF 1980
P.L. 96-272 [H.R. 3434] enacted June 17, 1980
Preamble An Act to establish a program of adoption assistance, to strengthen the program of foster care assistance for needy and dependent children, to improve the child welfare, social services, and aid to families with dependent children programs, and for other purposes.
DEEP SEABED HARD MINERAL RESOURCES ACT
P.L. 96-283 [H.R. 2759] enacted June 28, 1980
Preamble An Act to establish an interim procedure for the orderly development of hard mineral resources in the deep seabed, pending adoption of an international regime relating thereto, and for other purposes.
ENERGY SECURITY ACT
P.L. 96-294 [S. 932] enacted June 30, 1980
Preamble To extend the Defense Production Act of 1950, and for other purposes.
AIRPORT AND AIRWAY TRUST FUND-EXTENSION OF TAXES
P.L. 96-298 [H.R. 7477] enacted July 1, 1980
Preamble An act to amend the Internal Revenue Code of 1954 to provide a three-month extension of the taxes which are transferred to the Airport and Airway Trust Fund.
MULTI-EMPLOYER PENSION PLAN AMENDMENTS ACT OF 1980
P.L. 96-364 [H.R. 3904] enacted September 26, 1980
Preamble An Act to amend the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code of 1954 to improve retirement income security under private multi employer pension plans by strengthening the funding requirements for those plans, to authorize plan preservation measures for financially troubled multi employer pension plans, and to revise the manner in which the pension plan termination insurance provisions apply to multi employer plans, and for other purposes.
JOINT RESOLUTION PROVIDING CONTINUING APPROPRIATIONS FOR THE FISCAL YEAR 1981
P.L. 96-369 [H.J. Res. 610] enacted October 1, 1980
Preamble Making continuing appropriations for the fiscal year 1981, and for other purposes.
CUSTOMS COURTS ACT OF 1980
P.L. 96-417 [S. 1654] enacted October 10, 1980
Preamble An Act to improve the Federal judicial machinery by clarifying and revising certain provisions of title 28, United States Code, relating to the judiciary and judicial review of international trade matters, and for other purposes.
TAX COURT-ADDITIONAL JUDGES
P.L. 96-439 [H.R. 7779] enacted October 13, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 to authorize three additional judges for the Tax Court and to remove the age limitation on appointments to the Tax Court.
HOSTAGE RELIEF ACT OF 1980
P.L. 96-449 [H.R. 7085] enacted October 14, 1980
Preamble To provide certain benefits to individuals held hostage in Iran and to similarly situated individuals, and for other purposes.
RECREATIONAL BOATING SAFETY AND FACILITIES IMPROVEMENT ACT OF 1980
P.L. 96-451 [H.R. 4310] enacted October 14, 1980
Preamble An Act to amend the Federal Boat Safety Act of 1971 to promote recreational boating safety through the development, administration, and financing of a national recreational boating safety improvement program, and for other purposes.
INSTALLMENT SALES REVISION ACT OF 1980
P.L. 96-471 [H.R. 6883] enacted October 19, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 to revise the rules relating to certain installment sales.
OMNIBUS RECONCILIATION ACT OF 1980
P.L. 96-499 [H.R. 7765] enacted December 5, 1980
Preamble An Act to provide for reconciliation pursuant to section 3 of the First Concurrent Resolution on the Budget for the fiscal year 1981.
COMPREHENSIVE ENVIRONMENTAL RESPONSES, COMPENSATION, AND LIABILITY ACT OF 1980
TITLE II-HAZARDOUS SUBSTANCE RESPONSE REVENUE ACT OF 1980
P.L. 96-510 [H.R. 7020] enacted December 11, 1980
Preamble An Act to provide for liability, compensation, cleanup, and emergency response for hazardous substances released into the environment and the cleanup of inactive hazardous waste disposal sites.
TEMPORARY TAX PROVISIONS-EXTENSION
P.L. 96-541 [H.R. 6975] enacted December 17, 1980
Preamble An Act to extend certain temporary tax provisions, and for other purposes.
BANKRUPTCY TAX ACT OF 1980
P.L. 96-589 [H.R. 5043] enacted December 24, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 to provide for the tax treatment of bankruptcy, insolvency, and similar proceedings, and for other purposes.
UNITED STATES RETIREMENT BONDS-INTEREST RATES
P.L. 96-595 [H.R. 4868] enacted December 24, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 with respect to net operating loss carryovers of taxpayers who cease to be real estate investment trusts to increase interest rates on certain United States retirement bonds, and for other purposes.
DETERMINATION OF SECOND TIER TAXES
P.L. 96-596 [H.R. 5391] enacted December 24, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 with respect to the determination of second tier taxes, and for other purposes.
INTERNAL REVENUE CODE OF 1954-EXCISE TAX REFUNDS FOR CERTAIN USES
P.L. 96-598 [H.R. 3317] enacted December 24, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 with respect to excise tax refunds in the case of certain uses of tread rubber, and for other purposes.
INTERNAL REVENUE CODE OF 1954-SIMPLIFICATION
P.L. 96-601 [H.R. 5505] enacted December 24, 1980
Preamble An Act to simplify certain provisions of the Internal Revenue Code of 1954, and for other purposes.
SIMPLIFICATION OF PRIVATE FOUNDATION RETURN-REPORTING REQUIREMENTS
P.L. 96-603 [H.R. 4155] enacted December 28, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 to simplify private foundation return and reporting requirements, and for other purposes.
MISCELLANEOUS REVENUE ACT OF 1980
P.L. 96-605 [H.R. 7956] enacted December 28, 1980
Preamble An Act to make various changes in the tax law.
TAXATION-INDIVIDUAL LIVING ABROAD
P.L. 96-608 [H.R. 5973] enacted December 28, 1980
Preamble An Act to amend the Internal Revenue Code of 1954 to waive in certain cases the residency requirements for the deductions or exclusion of individuals living abroad, to allow the tax-free rollover of certain distributions from money purchase pension plans, and for other purposes.
SOCIAL SECURITY ACT, PARENTAL KIDNAPING
P.L. 96-611 [H.R. 8406] enacted December 28, 1980
Preamble An Act to amend title XVIII of the Social Security Act of provide for Medicare coverage of pneumococcal vaccine and its administration.
MISCELLANEOUS CHANGES-TAX LAWS
P.L. 96-613 [H.R.7171] enacted December 28, 1980
Preamble An Act to make certain miscellaneous changes in the tax law.
NINETY-SEVENTH CONGRESS, FIRST SESSION
ECONOMIC RECOVERY TAX ACT OF 1981
P.L. 97-34 [H.R. 4242] enacted August 13, 1981
Preamble An Act to amend the Internal Revenue Code of 1954 to encourage economic growth through reduction of the tax rates for individual taxpayers, acceleration of capital cost recovery of investment in plant, equipment, and real property, and incentives for savings, and for other purposes.
OMNIBUS BUDGET RECONCILIATION ACT OF 1981
P.L. 97-35 [H.R. 3982] enacted August 13, 1981
Preamble An Act to provide for reconciliation pursuant to section 301 of the first concurrent resolution on the budget for the fiscal year 1982.
APPROPRIATIONS-FISCAL YEAR 1982
P.L. 97-51 [H.J. Res. 325] enacted October 1, 1981
Preamble Joint Resolution making continuing appropriations for the fiscal year 1982, and for other purposes.
APPROPRIATIONS-FISCAL YEAR 1982
P.L. 97-92 [H.J. Res. 370] enacted December 15, 1981
Preamble Joint Resolution making further continuing appropriations for the fiscal year 1982, and for other purposes.
BLACK LUNG BENEFITS REVENUE ACT OF 1981
P.L. 97-119 [H.R. 5159] enacted December 29, 1981
Preamble An Act to amend the Internal Revenue Code of 1954 to provide a temporary increase in the tax imposed on producers of coal, and for other purposes.
OMNIBUS RECONCILIATION ACT OF 1981-SOCIAL SECURITY ACT BENEFITS
P.L. 97-123 [H.R. 4331] enacted December 29, 1981
Preamble An Act to amend the Omnibus Reconciliation Act of 1981 to restore minimum benefits under the Social Security Act.
NINETY-SEVENTH CONGRESS, SECOND SESSION
FEDERAL COURTS IMPROVEMENTS ACT OF 1982
P.L. 97-164 [H.R. 4482] enacted April 2, 1982
Preamble An Act to establish a United States Court of Appeals for the Federal Circuit, to establish a United States Claims Court, and for other purposes.
URGENT SUPPLEMENTAL APPROPRIATIONS ACT OF 1982
P.L. 97-216 [H.R. 6685] enacted July 18, 1982
Preamble An Act making urgent supplemental appropriations for the fiscal year ending September 30, 1982, and for other purposes.
TAX EQUITY AND FISCAL RESPONSIBILITY ACT OF 1982
P.L. 97-248 [H.R. 4961] enacted September 3, 1982
Preamble An Act to provide for tax equity and fiscal responsibility, and for other purposes.
MONEY AND FINANCE. ENACTMENT AS TITLE 31, UNITED STATES CODE
P.L. 97-258 [H.R. 6128] enacted September 13, 1982
Preamble To revise, codify, and enact without substantive change certain general and permanent laws, related to money and finance, as title 31, United States Code, "Money and Finance."
SUBCHAPTER S REVISION ACT OF 1982
P.L. 97-354 [H.R. 6055] enacted October 19, 1982
Preamble An Act to revise subchapter S of the Internal Revenue Code of 1954 (relating to small business corporations).
MISCELLANEOUS REVENUE ACT OF 1982
P.L. 97-362 [H.R. 4717] enacted October 25, 1982
Preamble An Act to reduce the amount of LIFO recapture in the case of certain plans of liquidation adopted during 1982, to make adjustments in the net operating loss carryback and carryforward rules for the Federal National Mortgage Association, and for other purposes.
DEBT COLLECTION ACT OF 1982
P.L. 97-365 [H.R. 4613] enacted October 25, 1982
Preamble An Act to increase the efficiency of Government-wide efforts to collect debts owed the United States and to provide additional procedures for the collection of debts owed the United States.
ORPHAN DRUG ACT
P.L. 97-414 [H.R. 5238] enacted January 4, 1983
Preamble An Act to amend the Federal Food, Drug, and Cosmetic Act to facilitate the development of drugs for rare diseases and conditions, and for other purposes.
SURFACE TRANSPORTATION ASSISTANCE ACT OF 1982
(Tax portion of act known as Highway Revenue Act of 1982)
P.L. 97-424 [H.R. 6211] enacted January 6, 1983
Preamble An Act to authorize appropriations for construction of certain highways in accordance with title 23, United States Code, for highway safety, for mass transportation in urban and rural areas, and for other purposes.
TECHNICAL CORRECTIONS ACT OF 1982
P.L. 97-448 [H.R. 6056] enacted January 12, 1983
Preamble An Act to make technical corrections in the Economic Recovery Tax Act of 1981 and certain other recent tax legislation.
DEPARTMENT OF TRANSPORTATION AND MOTOR CARRIER SAFETY
(Included conforming cross-reference changes to the code.)
P.L. 97-449 [H.R. 6993] enacted January 12, 1983
Preamble To revise, codify, and enact without substantive change certain general and permanent laws related to transportation as subtitle I and chapter 31 of subtitle II of title 49, United States Code, "Transportation."
VIRGIN ISLANDS SOURCE INCOME
P.L. 97-455 [H.R. 7093] enacted January 12, 1983
Preamble An Act to amend the Internal Revenue Code of 1954 to reduce the rate of certain taxes paid to the Virgin Islands on Virgin Islands source income, to amend the Social Security Act to provide for a temporary period that payment of disability benefits may continue through the hearing stage of the appeals process, and for other purposes.
PERIODIC PAYMENTS SETTLEMENT
Also known as the Miscellaneous Tax and ERISA Provisions
P.L. 97-473 [H.R. 5470] enacted January 14, 1983
Preamble An Act to amend the Internal Revenue Code of 1954 with respect to the tax treatment of periodic payments for damages received on account of personal injury or sickness, and for other purposes.
NINETY-EIGHTH CONGRESS, FIRST SESSION
PAYMENT-IN-KIND TAX TREATMENT ACT OF 1983
P.L. 98-4 [H.R. 1296] enacted March 11, 1983
Preamble An Act relating to the treatment for income and estate tax purposes of commodities received under 1983 payment-in-kind programs, and for other purposes.
SOCIAL SECURITY AMENDMENTS OF 1983
P.L. 98-21 [H.R. 1900] enacted April 20, 1983
Preamble An Act to assure the solvency of the Social Security Trust Funds, to reform the Medicare reimbursement of hospitals, to extend the Federal supplemental compensation program, and for other purposes.
INTEREST AND DIVIDEND TAX COMPLIANCE ACT OF 1983-CARIBBEAN BASIN ECONOMIC RECOVERY ACT
P.L. 98-67 [H.R. 2973] enacted August 5, 1983
Preamble An Act to promote economic revitalization and facilitate expansion of economic opportunities in the Caribbean Basin region, to provide for backup withholding of tax from interest and dividends, and for other purposes.
RAILROAD RETIREMENT SOLVENCY ACT OF 1983
TITLE II -- RAILROAD RETIREMENT REVENUE ACT OF 1983
P.L. 98-76 [H.R. 1646] enacted August 12, 1983
Preamble An Act to amend the Railroad Retirement Act of 1974 and the Railroad Retirement Tax Act to assure sufficient resources to pay current and future benefits under the Railroad Retirement Act of 1974, to make technical changes, and for other purposes.
UNEMPLOYMENT AND SOCIAL SECURITY BENEFITS, EXTENSIONS
P.L. 98-118 [H.R. 4101] enacted October 11, 1983
Preamble An Act to extend the Federal Supplemental Compensation Act of 1982, and for other purposes.
GUAM, CAPITAL IMPROVEMENT PROJECTS
P.L. 98-213 [S. 589] enacted December 8, 1983
Preamble To authorize $15,500,000 for capital improvement projects on Guam, and for other purposes.
NINETY-EIGHTH CONGRESS, SECOND SESSION
MONEY AND FINANCE
P.L. 98-216 [H.R. 2727] enacted February 14, 1984
Preamble To codify without substantive change recent laws related to money and finance and transportation and to improve the United State Code.
NATIONAL FISH AND WILDLIFE FOUNDATION ESTABLISHMENT ACT
P.L. 98-244 [H.R. 2809] enacted March 26, 1984
Preamble To establish a National Fish and Wildlife Foundation.
FEDERAL INCOME TAX FORGIVENESS FOR CERTAIN U.S. MILITARY AND CIVILIAN EMPLOYEES KILLED OVERSEAS
P.L. 98-259 [H.R. 4206] enacted April 10, 1984
Preamble An Act to amend the Internal Revenue Code of 1954 to exempt from Federal income taxes certain military and civilian employees of the United States dying as a result of injuries sustained overseas.
QUADRENNIAL POLITICAL PARTY PRESIDENTIAL NATIONAL NOMINATING CONVENTIONS
P.L. 98-355 [H.R. 5950] enacted July 11, 1984
Preamble To increase the Federal contribution for the Quadrennial Political Party Presidential National Nominating Conventions.
DEFICIT REDUCTION ACT OF 1984
Also known as the Tax Reform Act of 1984
P.L. 98-369 [H.R. 4170] enacted July 18, 1984
Preamble An Act to provide for tax reform, and for deficit reduction.
CHILD SUPPORT ENFORCEMENT AMENDMENTS OF 1984
P.L. 98-378 [H.R. 4325] enacted August 16, 1984
Preamble An Act to amend part D of title IV of the Social Security Act to assure, through mandatory income withholding, incentive payments to States, and other improvements in the child support enforcement program, that all children in the United States who are in need of assistance in securing financial support from their parents will receive such assistance regardless of their circumstances, and for other purposes.
RETIREMENT EQUITY ACT OF 1984
P.L. 98-397 [H.R. 4280] enacted August 23, 1984
Preamble An Act to amend the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code of 1954 to improve the delivery of retirement benefits and provide for greater equity under private pension plans for workers and their spouses and dependents by taking into account changes in work patterns, the status of marriage as an economic partnership, and the substantial contribution to that partnership of spouses who work both in and outside the home, and for other purposes.
CIVIL AERONAUTICS BOARD SUNSET ACT OF 1984
P.L. 98-443 [H.R. 5297] enacted October 4, 1984
Preamble To amend the Federal Aviation Act of 1958 to terminate certain functions of the Civil Aeronautics Board, to transfer certain functions of the Board to the Secretary of Transportation, and for other purposes.
TRADE AND TARIFF ACT OF 1984
P.L. 98-573 [H.R. 3398] enacted October 30, 1984
Preamble An Act to amend the trade laws, authorize the negotiation of trade agreements, extend trade preferences, change the tariff treatment with respect to certain articles and for other purposes.
EDUCATION ASSISTANCE PROGRAMS
P.L. 98-611 [H.R. 2508] enacted October 31, 1984
Preamble An Act to amend the Internal Revenue Code of 1954 to extend for 2 years the exclusion from gross income with respect to educational assistance programs, and for other purposes.
INTERNAL REVENUE CODE, AMENDMENTS: GROUP LEGAL SERVICES PLANS; FRINGE BENEFITS; IMPUTED INTEREST
P.L. 98-612 [H.R. 5361] enacted October 31, 1984
Preamble An Act to amend the Internal Revenue Code of 1954 to extend for one year the exclusion from gross income with respect to group legal services plans, and for other purposes.
NINETY-NINTH CONGRESS, FIRST SESSION
CONTEMPORANEOUS RECORDKEEPING REQUIREMENTS, REPEAL
P.L. 99-44 [H.R. 1869] enacted May 24, 1985
Preamble An Act to amend the Internal Revenue Code of 1954 to repeal the contemporaneous recordkeeping requirements added by the Tax Reform Act of 1984, and for other purposes.
EMERGENCY EXTENSION ACT OF 1985
P.L. 99-107 [H.R. 3452] enacted September 30, 1985
Preamble An Act to extend for 45 days the application of tobacco excise taxes, trade adjustment assistance, certain Medicare reimbursement provisions, and borrowing authority under the railroad unemployment insurance program.
IMPUTED INTEREST RULES
P.L. 99-121 [H.R. 2475] enacted October 11, 1985
Preamble An Act to amend the Internal Revenue Code of 1954 to simplify the imputed interest rules of sections 1274 and 483, and for other purposes.
PUBLIC DEBT LIMIT, TEMPORARY INCREASE
P.L. 99-155 [H.R. 3721] enacted November 14, 1985
Preamble An Act to temporarily increase the limit on the public debt and to restore the investments of the Social Security Trust Funds and other trust funds.
TEMPORARY EXTENSION OF MISCELLANEOUS PROVISIONS
P.L. 99-181 [H.R. 3918] enacted December 13, 1985
Preamble An Act to extend until December 18, 1985, the application of certain tobacco excise taxes, trade adjustment assistance, certain Medicare reimbursement provisions and borrowing authority under the railroad unemployment insurance program.
TEMPORARY EXTENSION OF CERTAIN TAX AUTHORITIES
P.L. 99-189 [H.R. 3981] enacted December 18, 1985
Preamble An Act to extend until December 19, 1985, the application of certain tobacco excise taxes, trade adjustment assistance, certain Medicare reimbursement provisions, and borrowing authority under the railroad unemployment insurance program.
TEMPORARY EXTENSION OF VARIOUS AUTHORITIES
P.L. 99-201 [H.R. 4006] enacted December 23, 1985
Preamble An Act to extend until March 15, 1986, the application of certain tobacco excise taxes and certain Medicare reimbursement provisions.
NINETY-NINTH CONGRESS, SECOND SESSION
CONSOLIDATED OMNIBUS BUDGET RECONCILIATION ACT OF 1985
P.L. 99-272 [H.R. 3128] enacted April 7, 1986
Preamble An Act to provide for reconciliation pursuant to section 2 of the first concurrent resolution on the budget for fiscal year 1986 (S. Con. Res. 32, Ninety-ninth Congress).
FEDERAL EMPLOYEES' RETIREMENT SYSTEM ACT OF 1986
P.L. 99-335 [H.R. 2672] enacted June 6, 1986
Preamble To amend title 5, United States Code, to establish a new retirement and disability plan for Federal employees, postal employees, and members of Congress, and for other purposes.
CONGRESSIONAL REPORTS ELIMINATION ACT OF 1986
P.L. 99-386 [S. 992] enacted August 22, 1986
Preamble To discontinue or amend certain requirements for agency reports to Congress.
SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986
P.L. 99-499 [H.R. 2005] enacted August 22, 1986
Preamble An Act to extend and amend the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, and for other purposes.
OMNIBUS BUDGET RECONCILIATION ACT OF 1986
P.L. 99-509 [H.R. 5300] enacted October 21, 1986
Preamble An Act to provide for reconciliation pursuant to section 2 of the concurrent resolution on the budget for fiscal year 1987.
TAX REFORM ACT OF 1986
P.L. 99-514 [H.R. 3838] enacted October 22, 1986
Preamble An Act to reform the internal revenue laws of the United States.
COAST GUARD AUTHORIZATION ACT OF 1986; UNIFORMED SERVICES; MARITIME AFFAIRS
P.L. 99-640 [H.R. 4208] enacted November 10, 1986
Preamble To authorize appropriations for the Coast Guard for fiscal year 1987, and for other purposes.
TRUST TERRITORY OF THE PACIFIC ISLANDS; MICRONESIA; MARSHALL ISLANDS; INTERNATIONAL AGREEMENTS
P.L. 99-658 [H. J. Res. 626] enacted November 14, 1986
Preamble To approve the "Compact of Free Association" between the United States and the Government of Palau, and for other purposes.
WATER RESOURCES DEVELOPMENT ACT OF 1986 TITLE XIV-HARBOR MAINTENANCE REVENUE ACT OF 1986
P.L. 99-662 [H.R. 6] enacted November 17, 1986
Preamble An Act to provide for the conservation and development of water and related resources and the improvement and rehabilitation of the Nation's water resources infrastructure.
ONE HUNDREDTH CONGRESS, FIRST SESSION
SURFACE TRANSPORTATION & UNIFORM RELOCATION ASSISTANCE ACT OF 1987
TITLE V -- HIGHWAY REVENUE ACT OF 1987
P.L. 100-17 [H.R. 2] enacted April 2, 1987
Preamble An Act to authorize funds for construction of highways, for highway safety programs, and for mass transportation programs, to expand and improve the relocation assistance program, and for other purposes.
DEPARTMENTS OF COMMERCE, JUSTICE, AND STATE, THE JUDICIARY, AND RELATED AGENCIES APPROPRIATION ACT, 1988; DEPARTMENT OF COMMERCE APPROPRIATIONS ACT, 1988
P.L. 100-202 [H.J. Res. 395] enacted December 22, 1987
Preamble Making appropriations for the Departments of Commerce, Justice, and State, the Judiciary, and related agencies for the fiscal year ending September 30, 1988, and for other purposes.
OMNIBUS BUDGET RECONCILIATION ACT OF 1987
P.L. 100-203 [H.R. 3545] enacted December 22, 1987
Preamble An Act to provide for reconciliation pursuant to section 4 of the concurrent resolution on the budget for the fiscal year 1988.
AIRPORT AND AIRWAY SAFETY AND CAPACITY EXPANSION ACT OF 1987
P.L. 100-223 [H.R. 2310] enacted December 30, 1987
Preamble An Act to amend the Airport and Airway Improvement Act of 1982 for the purpose of extending the authorization of appropriations for airport and airway improvements, and for other purposes.
ONE HUNDREDTH CONGRESS, SECOND SESSION
MEDICARE CATASTROPHIC COVERAGE ACT OF 1988
P.L. 100-360 [H.R. 2470] enacted July 1, 1988
Preamble An Act to amend title XVIII of the Social Security Act to provide protection against catastrophic medical expenses under the Medicare program, and for other purposes.
OMNIBUS TRADE AND COMPETITIVENESS ACT OF 1988
P.L. 100-418 [H.R. 4848] enacted August 23, 1988
Preamble An Act to enhance the competitiveness of American industry, and for other purposes.
COAST GUARD AUTHORIZATION ACT OF 1988; MARITIME AFFAIRS
P.L. 100-448 [H.R. 2342] enacted September 28, 1988
Preamble To authorize appropriations for the Coast Guard for fiscal year 1988, and for other purposes.
FAMILY SUPPORT ACT OF 1988
P.L. 100-485 [H.R. 1720] enacted October 13, 1988
Preamble An Act to revise the AFDC program to emphasize work, child support, and family benefits, to amend title IV of the Social Security Act to encourage and assist needy children and parents under the new program to obtain the education, training, and employment needed to avoid long-term welfare dependence, and to make other necessary improvements to assure that the new program will be more effective in achieving its objectives.
TECHNICAL AND MISCELLANEOUS REVENUE ACT OF 1988
P.L. 100-647 [H.R. 4333] enacted November 10, 1988
Preamble An Act to make technical corrections relating to the Tax Reform Act of 1986, and for other purposes.
ANTI DRUG ABUSE ACT OF 1988
P.L. 100-690 [H.R. 5210] enacted November 18, 1988
Preamble An Act to prevent the manufacturing, distribution, and use of illegal drugs, and for other purposes.
DISASTER RELIEF AND EMERGENCY ASSISTANCE AMENDMENTS OF 1988
P.L. 100-707 [H.R. 2707] enacted November 23, 1988.
Preamble An Act to amend the Disaster Relief Act of 1974 to provide for more effective assistance in response to major disasters and emergencies, and for other purposes.
ONE-HUNDRED FIRST CONGRESS, FIRST SESSION
FINANCIAL INSTITUTIONS REFORM, RECOVERY, & ENFORCEMENT ACT OF 1989
P.L. 101-73 [H.R. 1278] enacted August 9, 1989
Preamble An Act to reform, recapitalize, and consolidate the Federal deposit insurance system, to enhance the regulatory and enforcement powers of Federal financial institutions regulatory agencies, and for other purposes.
INCREASE IN THE PUBLIC DEBT LIMIT
P.L. 101-140 [H.J. Res. 280] enacted November 8, 1989
Preamble Joint Resolution increasing the statutory limit on the public debt.
ETHICS REFORM ACT OF 1989
P.L. 101-194 [H.R. 3660] enacted November 30, 1989
Preamble To amend the Rules of the House of Representatives and the Ethics in Government Act of 1978 to provide for Government-wide ethics reform, and for other purposes.
STEEL TRADE LIBERALIZATION PROGRAM IMPLEMENTATION ACT
P.L. 101-221 [H.R. 3275] enacted December 12, 1989
Preamble To implement the steel trade liberalization program.
MEDICARE CATASTROPHIC COVERAGE REPEAL ACT OF 1989
P.L. 101-234 [H.R. 3607] enacted December 13, 1989
Preamble An Act to repeal Medicare provisions in the Medicare Catastrophic Coverage Act of 1988.
ONE HUNDRED FIRST CONGRESS, SECOND SESSION
OMNIBUS BUDGET RECONCILIATION ACT OF 1989
P.L. 101-239 [H.R. 3299] enacted December 19, 1989
Preamble An Act to provide for reconciliation pursuant to section 5 of the concurrent resolution on the budget for fiscal year 1990.
GOVERNMENT ORGANIZATION AND EMPLOYEES
P.L. 101-280 [H.J. Res. 553] enacted May 4, 1990
Preamble To make technical changes in the Ethics Reform Act of 1989.
OIL POLLUTION ACT OF 1990
P.L. 101-380 [H.R. 1465] August 20, 1990
Preamble To establish limitation on liability for damages resulting from oil pollution, to establish a fund for the payment of compensation for such damages, and for other purposes.
OMNIBUS BUDGET RECONCILIATION ACT OF 1990
P.L. 101-508 [H.R. 5835] enacted November 5, 1990
Preamble An Act to provide for reconciliation pursuant to section 4 of the concurrent resolution on the budget for fiscal year 1991.
FOOD, AGRICULTURE, CONSERVATION, AND TRADE ACT OF 1990
P.L. 101-624 [S/ 2830] enacted November 28, 1990
Preamble To extend and revise agricultural price support and related programs, to provide for agricultural export, resource conservation, farm credit, and agricultural research and related programs, to ensure consumers an abundance of food and fiber at reasonable prices, and for other purposes.
CRIME CONTROL ACT OF 1990
P.L. 101-647 [S. 3266] enacted November 29, 1990
Preamble An Act to control crime.
IMMIGRATION ACT OF 1990
P.L. 101-649 [S. 358] enacted November 29, 1990
Preamble To amend the Immigration and Nationality Act to change the level, and preference system for admission, of immigrants to the United States, and to provide for administrative naturalization, and for other purposes.
ONE HUNDRED SECOND CONGRESS, FIRST SESSION
TAXATION: TIME EXTENSION FOR INDIVIDUALS IN DESERT SHIELD OPERATIONS
P.L. 102-2 [H.R. 4] enacted January 30, 1991
Preamble An Act to extend the time for performing certain acts under the internal revenue laws for individuals performing services as part of the Desert Shield Operation.
DEPARTMENT OF VETERANS AFFAIRS HEALTH-CARE PERSONNEL ACT OF 1991
P.L. 102-40 [H.R. 598] enacted May 7, 1991
Preamble An Act to amend title 38, United States Code, to improve the capability of the Department of Veterans Affairs to recruit and retain physicians and dentists through increases in special pay authorities, to authorize collective bargaining over conditions of employment for health-care employees of the Department of Veterans Affairs, and for other purposes.
VETERANS PROGRAMS FOR HOUSING AND MEMORIAL AFFAIRS
P.L. 102-54 [H.R. 232] enacted June 13, 1991
Preamble An Act to amend title 38, United States Code, with respect to veterans programs for housing and memorial affairs, and for other purposes.
DEPARTMENT OF VETERANS AFFAIRS CODIFICATION ACT
P.L. 102-83 [H.R. 2525] enacted August 6, 1991
Preamble An Act to amend title 38 United States Code, to codify the provisions of law relating to the establishment of the Department of Veterans Affairs, to restate and reorganize certain provisions of that title, and for other purposes.
LEGISLATIVE BRANCH APPROPRIATIONS
P.L. 102-90 [H.R. 2506] enacted August 14, 1991
Preamble An Act making appropriations for the Legislative Branch for the fiscal year ending September 30, 1992, and for other purposes.
EMERGENCY UNEMPLOYMENT COMPENSATION ACT OF 1991
P.L. 102-107 [H.R. 3201] enacted August 17, 1991
Preamble An Act to provide emergency unemployment compensation, and for other purposes.
TREASURY, POSTAL SERVICE AND GENERAL GOVERNMENT APPROPRIATIONS ACT, 1992
P.L. 102-141 [H.R. 2622] enacted October 28, 1991
Preamble An Act making appropriations for the Treasury Department, the United States Postal Service, the Executive Office of the President, and certain Independent Agencies, for the fiscal year ending September 30, 1992, and for other purposes.
EMERGENCY UNEMPLOYMENT COMPENSATION ACT OF 1991
P.L. 102-164 [H.R. 3575] enacted November 15, 1991
Preamble An Act to provide a program of emergency unemployment compensation, and for other purposes.
MISCELLANEOUS FOREIGN AFFAIRS
P.L. 102-182 [H.R. 1724] enacted December 4, 1991
Preamble An Act to provide for the termination of the application of title IV of the Trade Act of 1974 to Czechoslovakia and Hungary.
TAX EXTENSION ACT OF 1991
P.L. 102-227 [H.R. 3909] enacted December 11, 1991
Preamble An Act to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes.
INTERMODAL SURFACE TRANSPORTATION EFFICIENCY ACT OF 1991 TITLE VIII- SURFACE TRANSPORTATION REVENUE ACT OF 1991
P.L. 102-240 [H.R. 2950] enacted December 18, 1991
Preamble An Act to develop a national intermodal surface transportation system, to authorize funds for construction of highways, for highway safety programs, and for mass transit programs, and for other purposes.
ONE HUNDRED SECOND CONGRESS, SECOND SESSION
EMERGENCY UNEMPLOYMENT BENEFITS: EXTENSION
P.L. 102-244 [H.R. 4095] enacted February 7, 1992
Preamble An Act to increase the number of weeks for which benefits are payable under the Emergency Unemployment Compensation Act of 1991, and for other purposes.
UNEMPLOYMENT COMPENSATION AMENDMENTS OF 1992
P.L. 102-318 [H.R. 5260] enacted July 3, 1992
Preamble An Act to extend the emergency unemployment compensation program, to revise the trigger provisions contained in the extended unemployment compensation program, and for other purposes.
TREASURY, POSTAL SERVICE, AND GENERAL GOVERNMENT APPROPRIATIONS ACT, 1993
P.L. 102-393 [H.R. 5488] enacted October 6, 1992
Preamble An Act making appropriations for the Treasury Department, the United States Postal Service, the Executive Office of the President, and certain Independent Agencies, for the fiscal year ending September 30, 1993, and for other purposes.
ENERGY POLICY ACT OF 1992
P.L. 102-486 [H.R. 776] enacted October 24, 1992
Preamble An Act to provide for improved energy efficiency.
VETERANS' BENEFITS ACT OF 1992
P.L. 102-568 [H.R. 5008] enacted October 29, 1992
Preamble An Act to amend title 38, United States Code, to reform the formula for payment of dependency and indemnity compensation to survivors of veterans dying from service-connected causes, to increase the rate of payments for benefits under the Montgomery GI bill, and for other purposes.
FEDERAL COURTS ADMINISTRATION ACT OF 1992
P.L. 102-572 [S. 1569] enacted October 29, 1992
Preamble An Act to implement the recommendations of the Federal Courts Study Committee, and for other purposes.
WATER RESOURCES DEVELOPMENT ACT OF 1992
P.L. 102-580 [H.R. 6167] enacted October 31, 1992
Preamble An Act to provide for the conservation and development of water and related resources, to authorize the United States Army Corps of Engineers civil works program to construct various projects for improvements to the Nation's infrastructure, and for other purposes.
AIRPORT AND AIRWAY SAFETY, CAPACITY, NOISE IMPROVEMENT, AND INTERMODAL TRANSPORTATION ACT OF 1992
P.L. 102-581 [H.R. 6168] enacted October 31, 1992
Preamble An Act to amend the Airport and Airway Improvement Act of 1982 to authorize appropriations, and for other purposes.
ONE HUNDRED THIRD CONGRESS, FIRST SESSION
EMERGENCY UNEMPLOYMENT COMPENSATION AMENDMENTS OF 1993
P.L. 103-6 [H.R. 920] enacted March 4, 1993
Preamble An Act to extend the emergency unemployment compensation program, and for other purposes.
OMNIBUS BUDGET RECONCILIATION ACT OF 1993
P.L. 103-66 [H.R. 2264] enacted August 10, 1993
Preamble An Act to provide for reconciliation pursuant to section 7 of the concurrent resolution on the budget for fiscal year 1994. D- 73 58
TREASURY, POSTAL SERVICE, AND GENERAL GOVERNMENT APPROPRIATIONS ACT, 1994
P.L. 103-123 [H.R. 2403] enacted October 23, 1993
Preamble An Act making appropriations for the Treasury Department, the United States Postal Service, the Executive Office of the President, and certain Independent Agencies, for the fiscal year ending September 30, 1994, and for other purposes.
SOUTH AFRICAN DEMOCRATIC TRANSITION SUPPORT ACT OF 1993
P.L. 103-149 [H.R. 3225] enacted November 23, 1993
Preamble An Act to support the transition to nonracial democracy in South Africa.
UNEMPLOYMENT COMPENSATION AMENDMENTS OF 1993
P.L. 103-152 [H.R. 3167] enacted November 24, 1993.
Preamble An Act to extend the emergency unemployment compensation program, to establish a system of worker profiling, and for other purposes.
INTELLIGENCE AUTHORIZATION ACT FOR FISCAL YEAR 1994
P.L. 103-178 [H.R. 2330] enacted December 3, 1993.
Preamble An Act to authorize appropriations for fiscal year 1994 for the intelligence and intelligence-related activities of the United States Government, the Community Management Account, and the Central Intelligence Agency Retirement and Disability System, and for other purposes.
NORTH AMERICAN FREE TRADE AGREEMENT IMPLEMENTATION ACT
P.L. 103-182 [H.R. 3450] enacted December 8, 1993.
Preamble An Act to implement the North American Free Trade Agreement.
ONE HUNDRED THIRD CONGRESS, SECOND SESSION
AIRPORT IMPROVEMENT PROGRAM TEMPORARY EXTENSION ACT OF 1994
P.L. 103-260 [S. 2024] enacted May 26, 1994.
Preamble An Act to provide temporary obligational authority for the airport improvement program and to provide for certain airport fees to be maintained at existing levels for up to 60 days, and for other purposes.
REVISION OF TITLE 49, TRANSPORTATION, UNITED STATES CODE
P.L. 103-272 [H.R. 1758] enacted July 5, 1994.
Preamble An Act to revise, codify, and enact without substantive change certain general and permanent laws, related to transportation, as subtitles II, III, and V-X of title 49, United States Code, "Transportation", and to make other technical improvements in the Code.
SOCIAL SECURITY INDEPENDENCE AND PROGRAM IMPROVEMENTS ACT OF 1994
P.L. 103-296 [H.R. 4277] enacted August 15, 1994.
Preamble An Act to establish the Social Security Administration as an independent agency and to make other improvements in the old-age, survivors, and disability insurance program.
FEDERAL AVIATION ADMINISTRATION AUTHORIZATION ACT OF 1994
P.L. 103-305 [H.R. 2739] enacted August 23, 1994.
Preamble An Act to amend the Airport and Airway Improvement Act of 1982 to authorize appropriations for fiscal years 1994, 1995, and 1996, and for other purposes.
VIOLENT CRIME CONTROL AND LAW ENFORCEMENT ACT OF 1994
P.L. 103-322 [H.R. 3355] enacted September 13, 1994.
Preamble An Act to control and prevent crime.
TREASURY, POSTAL SERVICE AND GENERAL GOVERNMENT APPROPRIATIONS ACT OF 1995
P.L. 103-329 [H.R. 4539] enacted September 30, 1994.
Preamble An Act making appropriations for the Treasury Department, the United States Postal Service, the Executive Office of the President, and certain Independent Agencies, for the fiscal year ending September 30, 1995, and for other purposes.
SOCIAL SECURITY DOMESTIC EMPLOYMENT REFORM ACT OF 1994
P.L. 103-387 [H.R. 4278] enacted October 22, 1994.
Preamble An Act to make improvements in the old-age, survivors, and disability insurance program under title II of the Social Security Act.
CODIFICATION AMENDMENTS
P.L. 103-429 [H.R. 4778] enacted October 31, 1994
Preamble To codify without substantive change recent laws related to transportation and to improve the United States Code.
URUGUAY ROUND AGREEMENTS ACT
P.L. 103-465 [H.R. 5110] enacted December 8, 1994.
Preamble To approve and implement the trade agreements concluded in the Uruguay Round of multilateral trade negotiations.
ONE HUNDRED FOURTH CONGRESS, FIRST SESSION
PERMANENT EXTENSION OF DEDUCTION FOR HEALTH INSURANCE COSTS OF SELF- EMPLOYED INDIVIDUALS
P.L. 104-7 [H.R. 831] enacted April 11, 1995.
Preamble An Act to amend the Internal Revenue Code of 1986 to permanently extend the deduction for the health insurance costs of self-employed individuals, to repeal the provision permitting nonrecognition of gain on sales and exchanges effectuating policies of the Federal Communication Commission, and for other purposes.
TREASURY, POSTAL SERVICE, AND GENERAL GOVERNMENT APPROPRIATIONS ACT, 1996
P.L. 104-52 [H.R. 2020] enacted November 19, 1995.
Preamble An Act making appropriations for the Treasury Department, the United States Postal Service, the Executive Office of the President, and certain independent Agencies, for the fiscal year ending September 30, 1996, and for other purposes.
FEDERAL REPORTS ELIMINATION AND SUNSET ACT OF 1995
P.L. 104-66 [S. 790] enacted December 21, 1995
Preamble An Act to provide for the modification or elimination of Federal reporting requirements.
ICC TERMINATION ACT OF 1995
P.L. 104-88 [H.R. 2539] enacted December 29, 1995.
Preamble An Act to abolish the Interstate Commerce Commission, to amend subtitle IV of title 49, United States Code, to reform economic regulation of transportation, and for other purposes.
ONE HUNDRED FOURTH CONGRESS, SECOND SESSION
STATE TAXATION OF PENSION INCOME ACT OF 1995
P.L. 104-95 [H.R. 394] enacted January 10, 1996.
Preamble To amend title 4 of the United States Code to limit State taxation of certain pension income.
TAX BENEFITS FOR INDIVIDUALS PERFORMING SERVICES IN CERTAIN HAZARDOUS DUTY AREAS
P.L. 104-117 [H.R. 2778] enacted March 20, 1996.
Preamble To provide that members of the Armed Forces performing services for the peacekeeping efforts in Bosnia and Herzegovina, Croatia, and Macedonia shall be entitled to tax benefits in the same manner as if such services were performed in a combat zone, and for other purposes.
TAXPAYER BILL OF RIGHTS 2
P.L. 104-168 [H.R. 2337] enacted July 30, 1996
Preamble To amend the Internal Revenue Code of 1986 to provide for increased taxpayer protections.
SMALL BUSINESS JOB PROTECTION ACT OF 1996
P.L. 104-188 [H.R. 3448] enacted August 20, 1996
Preamble An Act to provide tax relief for small businesses, to protect jobs, to create opportunities, to increase the take home pay of workers, to amend the Portal-to Portal Act of 1947 relating to the payment of wages to employees who use employer owned vehicles, and to amend the Fair Labor Standards Act of 1938 to increase the minimum wage rate and to prevent job loss by providing flexibility to employers in complying with minimum wage and overtime requirements under that Act.
HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996
P.L. 104-191 [H.R. 3103] enacted August 21, 1996
Preamble An Act to amend the Internal Revenue Code of 1986 to improve portability and continuity of health insurance coverage in the group and individual markets, to combat waste, fraud, and abuse in health insurance and health care delivery, to promote the use of medical savings accounts, to improve access to long-term care services and coverage, to simplify the administration of health insurance, and for other purposes.
PERSONAL RESPONSIBILITY AND WORK OPPORTUNITY RECONCILIATION ACT OF 1996
P.L. 104-193 [H.R. 3734] enacted August 22, 1996
Preamble To provide for reconciliation pursuant to section 201(a))1) of the concurrent resolution on the budget for fiscal year 1997.
OMNIBUS CONSOLIDATED APPROPRIATIONS ACT, 1997
P.L. 104-208 [H.R. 3610] enacted September 30, 1996
Preamble Making omnibus consolidated appropriations for the fiscal year ending September 30, 1997, and for other purposes.
FEDERAL AVIATION REAUTHORIZATION ACT OF 1996
P.L. 104-264 [H.R. 3539] enacted October 9, 1996
Preamble To amend title 49, United States Code, to reauthorize programs of the Federal Aviation Administration, and for other purposes.
WATER RESOURCES DEVELOPMENT ACT OF 1996
P.L. 104-303 [S. 640] enacted October 12, 1996
Preamble To provide for the conservation and development of water and related resources, to authorize the Secretary of the Army to construct various projects for improvements to rivers and harbors of the United States, and for other purposes.
GENERAL ACCOUNTING OFFICE ACT OF 1996
P.L. 104-316 [H.R. 3864] enacted October 19, 1996
Preamble To amend laws authorizing auditing, reporting, and other functions by the General Accounting Office.
ONE HUNDRED FIFTH CONGRESS, FIRST SESSION
AIRPORT AND AIRWAY TRUST FUND TAX REINSTATEMENT ACT OF 1997
P.L. 105-2 [H.R. 668] enacted February 28, 1997
Preamble An Act to amend the Internal Revenue Code of 1986 to reinstate the Airport and Airway Trust Fund excise taxes, and for other purposes.
BALANCED BUDGET ACT OF 1997
P.L. 105-33 [H.R. 2015] enacted August 5, 1997
Preamble An Act to provide for reconciliation pursuant to subsections (b)(1) and (c) of section 105 of the concurrent resolution on the budget for fiscal year 1998.
TAXPAYER RELIEF ACT OF 1997
P.L. 105-34 [H.R. 2014] enacted August 5, 1997
Preamble An Act to provide for reconciliation pursuant to subsections (b)(2) and (d) of section 105 of the concurrent resolution on the budget for fiscal year 1998.
TAXPAYER BROWSING PROTECTION ACT
P.L. 105-35 [H.R. 1226] enacted August 5, 1997
Preamble An Act to amend the Internal Revenue Code of 1986 to prevent the unauthorized inspection of tax returns or tax return information.
TREASURY AND GENERAL GOVERNMENT APPROPRIATIONS ACT, 1998
P.L. 105-61 [H.R. 2378] enacted October 10, 1997
Preamble An Act making appropriations for the Treasury Department, the United States Postal Service, the Executive Office of the President, and certain independent Agencies, for the fiscal year ending September 30, 1998, and for other purposes.
DEPARTMENTS OF LABOR, HEALTH AND HUMAN SERVICES AND EDUCATION, AND RELATED AGENCIES APPROPRIATIONS ACT, 1998
P.L. 105-78 [H.R. 2264] enacted November 13, 1997
Preamble Making appropriations for the Departments of Labor, Health and Human Services, and Education, and related agencies for the fiscal year ending September 30, 1998, and for other purposes.
CODIFICATION AMENDMENTS, 1997
P.L. 105-102 [H.R. 1086] enacted November 20, 1997
Preamble To codify without substantive change laws related to transportation and to improve the United States Code.
FOOD AND DRUG ADMINISTRATION MODERNIZATION ACT OF 1997
P.L. 105-115 [S. 830] enacted November 21, 1997
Preamble To amend the Federal Food, Drug, and Cosmetic Act and the Public Health Service Act to improve the regulation of food, drugs, devices, and biological products, and for other purposes.
SURFACE TRANSPORTATION EXTENSION ACT OF 1997
P.L. 105-130 [S. 1519] enacted December 1, 1997
Preamble To provide a 6-month extension of highway, highway safety, and transit programs pending enactment of a law reauthorizing the Intermodal Surface Transportation Efficiency Act of 1991.
ONE HUNDRED FIFTH CONGRESS, SECOND SESSION
TRANSPORTATION EQUITY ACT FOR THE 21ST CENTURY
P.L. 105-178 [H.R. 2400] enacted June 9, 1998
Preamble To authorize funds for Federal-aid highways, highway safety programs, and transit programs, and for other purposes.
INTERNAL REVENUE SERVICE RESTRUCTURING AND REFORM ACT OF 1997
P.L. 105-206 [H.R. 2676] enacted July 22, 1998.
Preamble To amend the Internal Revenue Code of 1986 to restructure and reform the Internal Revenue Service, and for other purposes.
OMNIBUS CONSOLIDATED AND EMERGENCY SUPPLEMENTAL APPROPRIATIONS ACT, 1999
P.L. 105-277 [H.R. 4328] enacted October 21, 1998
Preamble Making omnibus consolidated and emergency appropriations for the fiscal year ending September 30, 1999, and for other purposes.
ONE HUNDRED SIXTH CONGRESS, FIRST SESSION
EXTENSION OF TAX BENEFITS-OPERATION ALLIED FORCE
P.L. 106-21 [H.R. 1376] enacted April 19, 1999
Preamble An Act to extend the tax benefits available with respect to services performed in a combat zone to services performed in the Federal Republic of Yugoslavia (Serbia/Montenegro) and certain other areas, and for other purposes.
MISCELLANEOUS TRADE AND TECHNICAL CORRECTIONS ACT OF 1999
P.L. 106-36 [H.R. 435] enacted June 25, 1999
Preamble An act to make miscellaneous and technical changes to various trade laws, and for other purposes.
APPROPRIATIONS, 2000-TREASURY, POSTAL SERVICE, EXECUTIVE OFFICE OF THE PRESIDENT, AND GENERAL GOVERNMENT
P.L. 106-58 [H.R. 2490] enacted September 29, 1999
Preamble An Act Making appropriations for the Treasury Department, the United States Postal Service, the Executive Office of the President, and certain Independent Agencies, for the fiscal year ending September 30, 2000, and for other purposes.
NATIONAL DEFENSE AUTHORIZATION ACT FOR FISCAL YEAR 2000
P.L. 106-65 [S. 1059] enacted on October 5, 1999
Preamble An Act to authorize appropriations for fiscal year 2000 for military activities of the Department of Defense, for military construction, and for defense activities of the Department of Energy, to prescribe personnel strengths for such fiscal year for the Armed Forces, and for other purposes.
TICKET TO WORK AND WORK INCENTIVES IMPROVEMENT ACT OF 1999
P.L. 106-170 [H.R. 1180] enacted December 17, 1999
Preamble An Act to amend the Social Security Act to expand the availability of health care coverage for working individuals with disabilities, to establish a Ticket to Work and Self-Sufficiency Program in the Social Security Administration to provide such individuals with meaningful opportunities to work, and for other purposes.
ONE HUNDRED SIXTH CONGRESS, SECOND SESSION
TRADE AND DEVELOPMENT ACT OF 2000
P.L. 106-200 [H.R. 434] enacted May 18, 2000
Preamble An act to authorize a new trade and investment policy for sub-Saharan Africa, expand trade benefits to the countries in the Caribbean Basin, renew the generalized system of preferences, and reauthorize the trade adjustment assistance programs.
FSC REPEAL AND EXTRATERRITORIAL INCOME EXCLUSION BILL OF 2000
P.L. 106-519 [H.R. 4986] enacted November 15, 2000
Preamble An act to amend the Internal Revenue Code of 1986 to repeal the provisions relating to foreign sales corporations (FSCs) and to exclude extraterritorial income from gross income.
CONSOLIDATED APPROPRIATIONS ACT, 2001
P.L. 106-554 [H.R. 4577] enacted December 21, 2000
Preamble An act making consolidated appropriations for the fiscal year ending September 30, 2001, and for other purposes.
INSTALLMENT TAX CORRECTION ACT OF 2000
P.L. 106-573 [H.R. 3594] enacted December 28, 2000
Preamble An act to repeal the installment method.
Contents
Eighty-Third Congress, Second Session
Excise Tax Reduction Act of 1954
Copper
Revised Organic Act of the Virgin Islands
District Courts' Jurisdiction
Employment Security Administrative Financing Act of 1954
Internal Revenue Code of 1954
Oral Prescriptions for Narcotic Drugs
Railroad Retirement Tax Amendments
Social Security Tax Amendments of 1954
Federal Unemployment Tax Amendments
Eighty-Fourth Congress, First Session
Violation of Narcotic Drug Laws
Tax Court Judges and Congressional Salaries Increase
Tax Rate Extension Act of 1955
Metal Scrap
Accounting Method Amendments
Suspension of Copper Import Taxes
Renegotiation Act of 1951, Extension
Armed Forces Retirement Income Tax Credit
Floor Stocks Refunds
Collection of Income Tax at Source on Wages
Amendment of Revenue Act of 1951 for Armed Forces Members
Dying in Service
Leases of Certain Trailers
Income Tax, Collection at Source on Wages
Exemption for Dependents in the Philippines
Tax on Admissions-United States Olympic Association
IRC 1954 Amendments
Spirits and Wines Lost in 1954 Hurricanes
Tax Treatment of Income from Patent Infringement Suits
Manufacturers' Excise Taxes
Use of Corporation Property By a Shareholder
Manufacturers Excise Tax on Motorcycles
Railroad Retirement and Unemployment Insurance
Residences of Armed Forces; Recovery Involving Patent
Infringement
Income Taxes on Arbitrage Operations in Securities and
Personal Holding Companies
Eighty-Fourth Congress, Second Session
Carryovers of Unused Pension Trust Deductions
Internal Revenue Code of 1939, Amendment
Limitation on Retirement Income Tax Credit
Western Hemisphere Trade Corporation
Documentary Stamp Tax
Taxes; Charitable Contributions
Technical Changes Act of 1953, Amendment
Estate Taxes, Credit
Life Insurance Company Tax Act for 1955
Tax Rate Extension Act of 1956
Taxes, Gasoline and Special Fuels Used for Farming;
Tax Exemption
Capital Gains; Real Property Subdivided For Sale
Distributions Pursuant to Bank Holding Company Act of 1956
Excise Taxes on Sugar
Federal-Aid Highway Act of 1956
Railroad Reorganizations; Recognition of Gain or Loss
Income Tax Deductions; Trademark and Trade Name Expenditures
Distilled Spirts, National Emergency Transfers and
Undistributed Capital Gains of Regulated Investment Companies
Mutual Security Act of 1956
Narcotic Control Act of 1956
Life Insurance Companies; Income Tax
Taxes, Foreign Transportation Exemption
Social Security Amendments of 1956
Servicemen's and Veterans' Survivor Benefits Act
Guam, Application of Federal Laws, Federal Seed Act
Estate Taxes
Tax on Admissions
Estate Taxes, Bequests in Trust
Tax on Transportation
Taxes, Contributions for Medical Research
Eighty-Fifth Congress, First Session
Tax Rate Extension Act of 1957
Veterans' Benefits Act of 1957
Exemption of Armed Forces Furlough Travel from
Transportation Tax
Adjustment for Breach of Contract Damages; Amortization
of Emergency Facilities
Internal Revenue Code of 1954, Amendments for Ministers
Eighty-Fifth Congress, Second Session
Incompetent Decedents
Use of Corporate Property by Shareholder
Income Taxes; Stock Options
Collected Taxes; Administration
Alcohol and Tobacco Tax Refund
Taxes, Life-Insurance Companies
Taxes; Unrelated Business Taxable Income
Admissions Tax; Exemptions
Tax Rate Extension Act of 1958
Distilled Spirits; National Emergency Transfers
Income Tax Offenses: Jurisdiction
Federal Income Tax Applicability: Guam
Social Security Amendments of 1958
Veterans' Benefits. Enactments as Title 38, U.S. Code
Excise Tax Technical Changes Act of 1958
Technical Amendments Act of 1958
Armed Forces, Army and Navy Surgeons General, Responsibilities
Corporations: Tax Refund Suits
Eighty-Sixth Congress, First Session
Tax Suspension on Palm Oil, Etc
Life Insurance Company Income Tax Act of 1959
Alaska Omnibus Act
Tax Rate Extension Act of 1959
Revocable Transfers
Farm Credit Act of 1959
Estate Tax Deduction
Taxes; Claims for Credit
Admissions Tax, Athletic Games
Federal-Aid Highway Act of 1959
Excise Tax Laws, Technical Changes
U.S. Savings Bonds, Interest Rates Increase
Chief Counsel for the Internal Revenue Service
Internal Revenue Code of 1954, Adoption and Small Business
Corporations Election Amendments
Eighty-Sixth Congress, Second Session
Aromatic Cachous
Documentary Stamp Tax Rate
Taxes, Bicycle Tires and Tubes
Cabaret Tax
Tax Exemption, Credit Unions
Narcotics Manufacturing Act of 1960
Personal Holding Company Tax, Copyright Royalties
Taxes, Employees' Trusts, Taxability
Taxes, Laminated Tires
Dealer Reserve Income Adjustment Act of 1960
Taxes, Assessing Additions
Taxes, Firearms
Taxes, Railroad Corporations
Public Debt and Tax Rate Extension Act of 1960
Sugar Act of 1948, Amendment
Exploration Expenditures
Hawaii Omnibus Act
Supplemental Unemployment Benefit Trusts, Tax Exemptions
Overseas Differentials and Allowances Act
Taxes, Cigars
Foreign Tax Credit Amendment
Manufacturers Excise Taxes, Advertising Charges
Eighty-Seventh Congress, First Session
Sugar Act of 1948: Amendment
Tax Exemption, Foreign Central Bank Issues
Report on Renegotiation, Time Extension
Public Debt, Gifts
Plumbers Union Local No. 12, Pension Fund
Federal-Aid Highway Program
Tax Rate Extension Act of 1961
Income Taxes, Membership Organizations
Mutual Educational and Cultural Exchange Act of 1961
Peace Corps Act
Income Tax, Clay Products
Federal Unemployment Tax Act, Amendment
Judges, Tax Court of U.S., Annuities to Widows and Children
Taxes, Account Numbers
Eighty-Seventh Congress, Second Session
Stock, Antitrust Distribution, Income Tax Treatment
Beta-Ray Spectrometer (Free Entry) and Disaster Losses:
Tax Treatment
Tax Rate Extension Act of 1962
Sugar Act Amendments of 1962
Taxes, Declaration by Fishermen
Taxes, Operating Loss Carryovers
Consumer Finance Companies. Personal Holding Company Tax,
Exception
Duty-Free Entries and Tax Relief. Personal and Household Effects
Self-Employed Individuals Tax Retirement Act of 1962
Trade Expansion Act of 1962
Revenue Act of 1962
Manufacturers Excise Taxes
Coconut and Palm Oil, Tax Suspension, Extension
Taxes, Medical Expense Deductions
Terminal Railroad Corporations, Income Tax
Internal Revenue, Retirement Income, Limitations
Eighty-Eighth Congress, First Session
Child Care Expenses, Deduction
Taxes, Redeemable Ground Rents
Silver Bullion, Silver Certificates, and Federal Reserve Notes
Tax Rate Extension Act of 1963
Treasury Department, Assistant Secretary
Deductibility of Accrued Vacation Pay
Eighty-Eighth Congress, Second Session
Revenue Act of 1964
Tobacco Products Tax Exemption
Excise Tax Rate Extension Act of 1964
Unrelated Business Taxable Income
Taxes, Collapsible Corporations
Distilled Spirits Tax Refund
Taxes, Vacation Pay Deductibility
Interest Equalization Tax Act
Taxes, Installment Obligations
Taxes, Life Insurance Companies
Land and Water Conservation Fund Act of 1965
Wine, Use of Fruit-Flavored Concentrates
Eighty-Ninth Congress, First Session
Excise Tax Reduction Act of 1965
Social Security Tax Amendments of 1965
Interest Equalization Tax Extension Act of 1965
Sugar Act Amendments of 1965
Nonprofit Organizations-Tax Exemptions
U.S. Tax Court Judges-Retirement Pay
IRC 1939-Amendment
Family Protection Plan-Tax Treatment
Tax Adjustment Act of 1966
Eighty-Ninth Congress, Second Session
Foreign Expropriations, Medical Insurance; Enrollment Period
Small Business Corporations-Special Options
Renegotiation Act-Extension
D.C. Courts: Transfer of Functions
Excise Taxes-On Tires and Tubes
Income Taxes-Mining Exploration Expenditures
Estate Tax
Accrued Vacation Pay
Taxes-Direct Filing of Returns
Federal Tax Lien Act of 1966
Interest on Refunds
Reserve for Certain Guaranteed Debt Obligations
Combat Pay Exclusion: Increase
Narcotic Addict Rehabilitation Act of 1966
Depreciable Property, Investment Credit Suspension
Foreign Investors Tax Act of 1966; Presidential Election
Campaign Fund Act of 1966
Ninetieth Congress, First Session
Investment Credit Restoration and Allowance of Accelerated
Depreciation
Interest Equalization Tax; Extension Act of 1967
Taxes, Wine Unfit for Beverage Use-Tax Free Withdrawal
Exemptions for Children of Divorced Parents
Bank Holding Company Distributions
Armed Forces-Gifts by Members in Combat Zones and
Duty-Free Entry
Ninetieth Congress, Second Session
Excise Taxes-Extension
Political Advertising in National Convention Program-Income
Tax Deduction
Revenue and Expenditure Control Act of 1968
Self-Employed Individuals-Pension Plans
Gun Control Act of 1968
Taxes-Wine Spirits
Taxes-Corporations-Statutory Mergers
Taxes-Global Communications Satellite System-Tax Exemption
Taxes-Definition of Compensation
Taxes-Distilled Spirits
Industrial Development Bonds; Exemption for
Certain Small Issues
Ninety-First Congress, First Session
Income Withholding Rates Extension
Interest Equalization Tax-Extension
Federal Unemployment Tax; Employment Security Administration
Account; Income Tax Surcharge
Istle: Duty Suspension & Interest Equalization Tax: Extension
Interest Equalization Tax Extension Act of 1969
Tax Reform Act of 1969
Ninety-First Congress, Second Session
Treatment of Certain Individuals as Serving in Combat Zone
Airport and Airway Development Act of 1970
Ute Tribes: Judgement Funds, Disposition
Federal-Aid Highway Act of 1970
Excise, Estate, and Gift Tax Adjustment Act of 1970
Cemetery Corporations-Income Tax Exemption
Taxes-Floor Stock Refunds -- Claims -- Filing Extension
Distilled Spirits Taxes
Beer Taxes
Tax Reform Act of 1969-Amendment
Taxes for Leased Aircraft-Investment Credit Recapture
Taxes-Expropriation of Property by Cuba; Property Losses
Cement Mixers Floor Stock Refunds
Joint Returns-Liability
Almond Grove Capital Expenditures
Foreign Corporations; Recognition of Gains on Exchanges
Small Business Corporations; Passive Investment Income
Foreign Corporations-Foreign Tax Credit
Real Property Sales by Corporations
Losses on Worthless Securities
Tax Returns of Life Insurance Companies
Union-Negotiated Pension Plans-Qualification Period
Corporations-Statutory Mergers
Ninety-Second Congress, First Session
Interest Equalization Tax Extension Act of 1971
Renegotiation Act of 1951, Amendments; U.S. Tax Court Judges
Revenue Act of 1971
Ninety-Second Congress, Second Session
Prisoners of War, Vietnam Conflict; Income Tax Exclusion
Treasury Department Positions, Establishment
Federal Personnel Surety Bonds: Elimination
Veterans' Organizations, Tax Exempt Status
Revenue Sharing Act of 1972
Wildlife Restoration Fund; Bows and Arrows, Tax
Taxes, American Samoans
Coordination of United States and Guam
Individual Income Taxes
Ninety-Third Congress, First Session
Interest Equalization Tax Extension Act of 1973
Presidential Election Campaign Fund
Renegotiation Act of 1951, and Social
Security Act, Amendments
Ninety-Third Congress, Second Session
Copying Shoe Lathes. Duty Suspension, Extension
Wildlife Restoration Projects Funds Extension
Renegotiation Act of 1951 Extension
Employee Retirement Income Security Act of 1974
Presidential Election Campaign Fund
Crude Feathers and Downs, Duty Rate; Personal Holding
Company, Income Exclusion; Health Insurance for the Aged
Corporations, Qualified Export Assets; Expenditures of
Low Income Rental Housing Rehabilitation
Carboxymethyl Cellulose Salts, Duty Suspension; Internal Revenue
Code of 1954, Amendments
Certain Bicycle Parts and Accessories, Duty Suspension; Internal
Revenue Code of 1954, Amendments
Percentage Depletion and Wagering Tax Amendments
Tax Treatment of Servicemen, Prisoners of War, Etc
Amortization Extension; Accrued Vacation Pay; Class
Life System for Realty; Real Estate Investment Trusts;
Interest on Tax Deficiencies; Student Loan Funding;
Exclusion of Interest by Non-Resident Aliens; Interest
Equalization Tax; Tax Treatment of Political Organizations
Ninety-Fourth Congress, First Session
Tax Reduction Act of 1975
Emergency Compensation and Special Unemployment Assistance
Extension Act of 1975
Indians-Klamath Tribe, Gains from Condemnation of Certain Forest
Lands-Tax Exclusion
Revenue Adjustment Act of 1975
Ninety-Fourth Congress, Second Session
New York-Public Employee Retirement Systems
Tax Treatment of ConRail Exchanges
Employee Retirement Plans; Rollover of Distributions
Federal-Aid Highway Act of 1976
Federal Election Campaign Act Amendments of 1976
Life Insurance Companies-Policyholders Surplus Amount
Airport and Airway Development Act Amendments of 1976
Taxes-Certain Option Income of Exempt Organizations
Social Security Act, Amendments
Taxes-Common Trust Funds-Treatment of Affiliated Banks
Bank Holding Company Tax Act of 1976
Tax Reform Act of 1976
Taxes-Interest Deduction on Certain Corporate Indebtedness
Taxes-Cemetery Perpetual Care Funds
Beer-Small Business Tax Reduction
Taxes-Certain Aircraft Museums-Fuel Tax Exemptions
Title 17, USC, Copyrights
Taxes-Exempt Organizations
Taxes-Distilled Spirits-Use of Stamps on Containers
Ninety-Fifth Congress, First Session
Tax Reduction and Simplification Act of 1977
Secretary of the Treasury. Public Moneys,
Investment Authority
Social Security Act-Amendments
Certain Silk Yards Duty Suspension Extension-Internal
Revenue Code of 1954 Amendment to State and Local Taxes Not
Included in Determining Amounts Paid for Communications
Services
Taxes-Distilled Spirits or Wines
Social Security Act, Amendment
Employee Retirement Income Security Act of 1974-Amendment
Ninety-Fifth Congress, Second Session
Black Lung Benefits Revenue Act of 1977
Black Lung Benefits Reform Act of 1977
Taxes-Certain Crop Payments; State legislators' Travel Expenses
New York City Loan Guarantee Act of 1978
Internal Revenue Code Treatment of Income from Nonmember
Telephone Companies
Taxes-Alcoholic Beverages-Excise Tax Refund-Losses
Resulting from Disaster, Vandalism, or Malicious Mischief
Taxes-Regulations on Taxation of Fringe Benefits-Prohibition
Excise Taxes on Trucks, Buses and Tractors; Home
Production of Beer and Wine; Aerial Applicators;
Rollover of Lump Sum Distributions
U.S. Tax Court-Judges' Retirement Pay
Black Lung Benefit Trusts
Taxes-New York Public Employees Retirement Systems
Internal Revenue Code of 1954-Amendment
Surface Transportation Assistance Act of 1978
Revenue Act of 1978
Tax Treatment Extension Act of 1977
Energy Tax Act of 1978
Miscellaneous Timing Requirements
Ninety-Sixth Congress, First Session
Distilled Spirits Tax Revision Act of 1979
Unemployment Compensation Amendments of 1976, Amendment
Prohibition of Issuance of Fringe Benefit Regulations
Business Expenses of State Legislators
Federal Election Campaign Act Amendments of 1979
Ninety-Sixth Congress, Second Session
Technical Corrections Act of 1979
Crude Oil Windfall Profit Tax Act of 1980
Food Stamp Act Amendments of 1980
Adoption Assistance and Child Welfare Act of 1980
Deep Seabed Hard Mineral Resources Act
Energy Security Act
Airport and Airway Trust Fund-Extension of Taxes
Multi-Employer Pension Plan Amendments Act of 1980
Joint Resolution Providing Continuing Appropriations
for the Fiscal Year 1981
Customs Courts Act of 1980
Tax Court-Additional Judges
Hostage Relief Act of 1980
Recreational Boating Safety and Facilities
Improvement Act of 1980
Installment Sales Revision Act of 1980
Omnibus Reconciliation Act of 1980
Comprehensive Environmental Responses, Compensation,
and Liability Act of 1980
Temporary Tax Provisions-Extension
Bankruptcy Tax Act of 1980
United States Retirement Bonds-Interest Rates
Determination of Second Tier Taxes
Internal Revenue Code of 1954-Excise Tax Refunds
for Certain Uses
Internal Revenue Code of 1954-Simplification
Simplification of Private Foundation Return-Reporting
Requirements
Miscellaneous Revenue Act of 1980
Taxation-Individual Living Abroad
Social Security Act, Parental Kidnaping
Miscellaneous Changes-Tax Laws
Ninety-Seventh Congress, First Session
Economic Recovery Tax Act of 1981
Omnibus Budget Reconciliation Act of 1981
Appropriations-Fiscal Year 1982
Appropriations-Fiscal Year 1982
Black Lung Benefits Revenue Act of 1981
Omnibus Reconciliation Act of 1981-Social Security Act Benefits
Ninety-Seventh Congress, Second Session
Federal Courts Improvements Act of 1982
Urgent Supplemental Appropriations Act of 1982
Tax Equity and Fiscal Responsibility Act of 1982
Money and Finance. Enactment as Title 31, United States Code
Subchapter S Revision Act of 1982
Miscellaneous Revenue Act of 1982
Debt Collection Act of 1982
Orphan Drug Act
Surface Transportation Assistance Act of 1982
Technical Corrections Act of 1982
Department of Transportation and Motor Carrier Safety
Virgin Islands Source Income
Periodic Payments Settlement
Ninety-Eighth Congress, First Session
Payment-In-Kind Tax Treatment Act of 1983
Social Security Amendments of 1983
Interest and Dividend Tax Compliance Act of 1983-Caribbean
Basin Economic Recovery Act
Railroad Retirement Solvency Act of 1983
Unemployment and Social Security Benefits, Extensions
Guam, Capital Improvement Projects
Ninety-Eighth Congress, Second Session
Money and Finance
National Fish and Wildlife Foundation Establishment Act
Federal Income Tax Forgiveness for Certain U.S. Military
and Civilian Employees Killed Overseas
Quadrennial Political Party Presidential National
Nominating Conventions
Deficit Reduction Act of 1984
Child Support Enforcement Amendments of 1984
Retirement Equity Act of 1984
Civil Aeronautics Board Sunset Act of 1984
Trade and Tariff Act of 1984
Education Assistance Programs
Internal Revenue Code, Amendments: Group Legal Services
Plans; Fringe Benefits; Imputed Interest
Ninety-Ninth Congress, First Session
Contemporaneous Recordkeeping Requirements, Repeal
Emergency Extension Act of 1985
Imputed Interest Rules
Public Debt Limit, Temporary Increase
Temporary Extension of Miscellaneous Provisions
Temporary Extension of Certain Tax Authorities
Temporary Extension of Various Authorities
Ninety-Ninth Congress, Second Session
Consolidated Omnibus Budget Reconciliation Act of 1985
Federal Employees' Retirement System Act of 1986
Congressional Reports Elimination Act of 1986
Superfund Amendments and Reauthorization Act of 1986
Omnibus Budget Reconciliation Act of 1986
Tax Reform Act of 1986
Coast Guard Authorization Act of 1986; Uniformed
Services; Maritime Affairs
Trust Territory of the Pacific Islands; Micronesia
Marshall Islands. International Agreements
Water Resources Development Act of 1986
One Hundredth Congress, First Session
Surface Transportation & Uniform Relocation
Assistance Act of 1987
Departments of Commerce, Justice, and State, the Judiciary,
and Related Agencies Appropriation Act, 1988; Department of
Commerce Appropriations Act, 1988
Omnibus Budget Reconciliation Act of 1987
Airport and Airway Safety and Capacity Expansion Act of 1987
One Hundredth Congress, Second Session
Medicare Catastrophic Coverage Act of 1988
Omnibus Trade and Competitiveness Act of 1988
Coast Guard Authorization Act of 1988; Maritime Affairs
Family Support Act of 1988
Technical and Miscellaneous Revenue Act of 1988
Anti Drug Abuse Act of 1988
Disaster Relief and Emergency Assistance Amendments of 1988
One-Hundred First Congress, First Session
Financial Institutions Reform, Recovery, &
Enforcement Act of 1989
Increase in the Public Debt Limit
Ethics Reform Act of 1989
Steel Trade Liberalization Program Implementation Act
Medicare Catastrophic Coverage Repeal Act of 1989
One Hundred First Congress, Second Session
Omnibus Budget Reconciliation Act of 1989
Government Organization and Employees
Oil Pollution Act of 1990
Omnibus Budget Reconciliation Act of 1990
Food, Agriculture, Conservation, and Trade Act of 1990
Crime Control Act of 1990
Immigration Act of 1990
One Hundred Second Congress, First Session
Taxation: Time Extension for Individuals in Desert
Shield Operations
Department of Veterans Affairs Health-Care Personnel
Act of 1991
Veterans Programs for Housing and Memorial Affairs
Department of Veterans Affairs Codification Act
Legislative Branch Appropriations
Emergency Unemployment Compensation Act of 1991
Treasury, Postal Service and General Government
Appropriations Act, 1992
Emergency Unemployment Compensation Act of 1991
Miscellaneous Foreign Affairs
Tax Extension Act of 1991
Intermodal Surface Transportation Efficiency Act of 1991
One Hundred Second Congress, Second Session
Emergency Unemployment Benefits: Extension
Unemployment Compensation Amendments of 1992
Treasury, Postal Service, and General Government
Appropriations Act, 1993
Energy Policy Act of 1992
Veterans' Benefits Act of 1992
Federal Courts Administration Act of 1992
Water Resources Development Act of 1992
Airport and Airway Safety, Capacity, Noise
Improvement, and Intermodal Transportation Act of 1992
One Hundred Third Congress, First Session
Emergency Unemployment Compensation Amendments of 1993
Omnibus Budget Reconciliation Act of 1993
Treasury, Postal Service, and General Government
Appropriations Act, 1994
South African Democratic Transition Support Act of 1993
Unemployment Compensation Amendments of 1993
Intelligence Authorization Act for Fiscal Year 1994
North American Free Trade Agreement Implementation Act
One Hundred Third Congress, Second Session
Airport Improvement Program Temporary Extension Act of 1994
Revision of Title 49, Transportation, United States Code
Social Security Independence and Program
Improvements Act of 1994
Federal Aviation Administration Authorization Act of 1994
Violent Crime Control and Law Enforcement Act of 1994
Treasury, Postal Service and General Government
Appropriations Act of 1995
Social Security Domestic Employment Reform Act of 1994
Codification Amendments
Uruguay Round Agreements Act
One Hundred Fourth Congress, First Session
Permanent Extension of Deduction for Health Insurance
Costs of Self-Employed Individuals
Treasury, Postal Service, and General Government
Appropriations Act, 1996
Federal Reports Elimination and Sunset Act of 1995
ICC Termination Act of 1995
One Hundred Fourth Congress, Second Session
State Taxation of Pension Income Act of 1995
Tax Benefits for Individuals Performing Services in
Certain Hazardous Duty Areas
Taxpayer Bill of Rights 2
Small Business Job Protection Act of 1996
Health Insurance Portability and Accountability Act of 1996
Personal Responsibility and Work Opportunity
Reconciliation Act of 1996
Omnibus Consolidated Appropriations Act, 1997
Federal Aviation Reauthorization Act of 1996
Water Resources Development Act of 1996
General Accounting Office Act of 1996
One Hundred Fifth Congress, First Session
Airport and Airway Trust Fund Tax Reinstatement Act of 1997
Balanced Budget Act of 1997
Taxpayer Relief Act of 1997
Taxpayer Browsing Protection Act
Treasury and General Government Appropriations Act, 1998
Departments of Labor, Health and Human Services and
Education, and Related Agencies Appropriations Act, 1998
Codification Amendments, 1997
Food and Drug Administration Modernization Act of 1997
Surface Transportation Extension Act of 1997
One Hundred Fifth Congress, Second Session
Transportation Equity Act for the 21st Century
Internal Revenue Service Restructuring and Reform Act of 1997
Omnibus Consolidated and Emergency Supplemental Appropriations
Act, 1999
One Hundred Sixth Congress, First Session
Extension of Tax Benefits-Operation Allied Force
Miscellaneous Trade and Technical Corrections Act of 1999
Appropriations, 2000-Treasury, Postal Service,
Executive Office of the President, and General Government
National Defense Authorization Act for Fiscal Year 2000
Ticket to Work and Work Incentives Improvement Act of 1999
One Hundred Sixth Congress, Second Session
Trade and Development Act of 2000
FSC Repeal and Extraterritorial Income Exclusion Bill of 2000
Consolidated Appropriations Act, 2001
Installment Tax Correction Act of 2000
Congressional Research Service
Memorandum February 5, 2001
TO: Joint Committee on Taxation
Attention: Mary Schmitt
FROM: Marie B. Morris
Legislative Attorney
American Law Division
SUBJECT: Frequency of Grants of Regulatory Authority to Internal
Revenue Service in Past Ten Years
[384] The attached list is an attempt to capture the times that Congress has specifically granted the Internal Revenue Service regulatory authority over some aspect of the Internal Revenue Code from 1991-2000. Generally omitted from the list are authorizations to adjust for inflation or prescribe forms, requirements to issue reports, and authority to waive certain requirements for individuals on certain grounds.
[385] There does not appear to be a pattern to the number of times that regulations are authorized, or to the language used for the authorization, but the more technical or complex the area, the more likely that the statute will grant authority to make additions, exceptions, or rules "necessary to carry out the purposes" of the statute. Excise taxes on fuels and chemicals, foreign income, expatriation, capital gains, financial transactions, attribution rules, and taxation of pass-through entities (S corporations, partnerships, etc.) are examples of the areas in which Congress frequently delegated some authority in the past 10 years.
[386] The attached list is divided by year, public law, section of the public law, and Internal Revenue Code section, if applicable. Each section is followed by a brief description or quotation to give a sense of what kind of authority was granted by the specific provision.
1991
None
1992
UNEMPLOYMENT COMPENSATION AMENDMENTS OF 1992, P.L. 102-318
o section 521(a) amending IRC section 402(d)(2)(E) [re
taxation of lump sum distributions]: "The Secretary shall
prescribe such regulations as may be necessary to carry out
the purposes of this paragraph."
o section 521(a) amending IRC section 402(d)(6) [re
recalculation of tax on lump sum distributions in certain
cases when retiree is subsequently reemployed]: "[U]nder
regulations prescribed by the Secretary, the tax imposed by
this chapter for the taxable year (in which the increase in
vesting first occurs) shall be increased by the reduction
in tax which resulted from the special lump sum treatment
(and an election under paragraph (4)(B) shall not be taken
into account for purposes of determining whether the
employee may make another election under paragraph
(4)(B))."
o section 521(a) amending IRC section 402(e)(4)(B) to permit
taxpayer election in accordance with rules prescribed by
the Secretary.
o section 521(d) creating note following IRC section 402:
"The Secretary or his delegate shall develop a model
explanation which a plan administrator may provide to a
recipient in order to meet the requirements of IRC section
402(f)."
ENERGY POLICY ACT OF 1992 P.L. 102-486
o section 1912, creating IRC section 136(c)(2) to permit
Secretary to specify "any other property" which meets
definition of specially defined energy property.
o section 1913(a) creating new IRC section 179A(e)(4)
[deduction for clean fuel vehicles] to require Secretary to
provide for recapture of the benefit of any deduction, with
respect to any property which ceases to be eligible for the
deduction.
o section 1913(b) creating a new IRC section 30(d)(2) [credit
for qualified electric vehicles]: "The Secretary shall, by
regulations, provide for recapturing the benefit of any
credit allowable under subsection (a) with respect to any
property which ceases to be property eligible for such
credit."
o section 1914 creating a new IRC section 45 [renewable
electricity production credit] containing (1) an inflation-
adjustment requirement, (2) a requirement that the
Secretary determine an annual average contract price per
kilowatt hour of electricity generated in the previous year
in the U.S., (3) a requirement that the Secretary determine
allocation of ownership interests, and (4) a requirement
to prescribe regulations for pass-through in the case of
estates and trusts.
o section 1920 amending IRC section 4081(c) [relating to
alcohol fuels excise taxes] to require regulations to apply
special rates of tax on gasoline used in producing gasohol.
o section 1932 amending IRC section 4682(g)(4) [re chemicals
used for sterilizing medical instruments and as propellants
in metered-dose inhalers] to require certain parties to
meet "registration requirements as may be prescribed by the
Secretary."
o section 1936 amending IRC section 385(c)(3) [relating to
treatment of certain interests as stock or indebtedness] to
authorize the Secretary to require such information as the
Secretary determines to be necessary to carry out the
provisions of the subsection.
1993
OMNIBUS BUDGET RECONCILIATION ACT OF 1993 P.L. 103-66
o section 13113(a) adding IRC section 1202(k) [re 50%
exclusion for gain from certain small business stock]: "The
Secretary shall prescribe such regulations as may be
appropriate to carry out the purposes of this section,
including regulations to prevent the avoidance of the
purposes of this section through split-ups, shell
corporations, partnerships, or otherwise."
o section 13144 amending IRC section 514(c)(9)(G) and (H) [re
debt-financed income of tax-exempt organizations]: "Except
as otherwise provided by regulations. . .."
o section 13150 adding IRC section 108(c)(5) [re exclusion of
income from discharge of qualified real property
indebtedness]: "The Secretary shall issue such regulations
as are necessary to carry out this subsection, including
regulations preventing the abuse of this subsection
through cross-collateralization or other means."
o section 13161(a) adding IRC section 4003(a) [re special
rules for separate purchase of vehicle and parts and
accessories]: "Under regulations prescribed by the
Secretary. . ." and IRC section 4003(a)(3)(C) ". . . (or
such other amount or amounts as the Secretary may by
regulation prescribe)."
o section 13172 adding IRC section 170(f)(8)(E) [re
substantiation of certain charitable contributions]: "The
Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of this
paragraph, including regulations that may provide that some
or all of the requirements of this paragraph do not apply
in appropriate cases."
o section 13206(a) adding IRC section 1258(b) and (c) [re
recharacterization of gain from certain financial
transactions]: "The Secretary shall by regulations provide
for such reductions in the applicable imputed income
amount as may be appropriate by reason of amounts
capitalized under section 263(g), ordinary income
received, or otherwise"; [re definition of conversion
transaction] ". . . any other transaction specified in
regulations prescribed by the Secretary."
o section 13223 adding IRC section 475((e) [re mark to market
accounting method for dealers in securities]: "The
Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of this
section, including rules -- . . ."
o section 13227 amending IRC section 936(a)(4) and 936(i) [re
Puerto Rico and possessions tax credit]: "The Secretary may
prescribe regulations to prevent the avoidance of this
subclause through deconsolidation or otherwise"; "[Credit
shall be] allocated among such possession corporations in
such manner as the Secretary may prescribe."
o section 13228(a) amending IRC section 163(j) [re limitation
on deduction for certain interest]: "The term 'disqualified
guarantee' shall not include a guarantee in any
circumstances identified by the Secretary by regulation
. . ."
o section 13231(b) added IRC section 956A(f) [re earnings of a
controlled foreign corporation invested in excess passive
assets]: "The Secretary shall prescribe such regulations
as may be necessary to carry out the purposes of this
section, including regulations to prevent the avoidance of
the provisions of this section through reorganizations or
otherwise."
o section 13231(d) amended IRC section 1297(d)(2)(A) and (B)
[re determination of adjusted basis]: "The adjusted basis of
any asset to which paragraph (1) applies shall be the
unamortized portion (as determined under regulations
prescribed by the Secretary) of the present value of the
payments under the lease for the use of such property. . ..
"[P]resent value . . . shall be determined in the manner
provided in regulations prescribed by the Secretary."
o section 13232(b) adding IRC section 956(e) [re investment
of earnings in United States property]: "The Secretary
shall prescribe such regulations as may be necessary to
carry out the purposes of this section, including
regulations to prevent the avoidance of the provisions of
this section through reorganizations or otherwise."
o section 13234(b) amending IRC section 864(f)(5) [re
allocation of research and experimental expenditures]: "The
Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of this
subsection, including regulations relating to the
determination of whether any expenses are attributable to
activities conducted in the United States or outside the
United States and regulations providing such adjustments to
the provisions of this subsection as may be appropriate in
the case of cost-sharing arrangements and contract
research."
o section 13237 amending IRC section 871(a)(4)(A)(ii) and
(C)(vi) and IRC section 2015(b) [re definition of portfolio
interest]: ". . . any other type of contingent interest
that is identified by the Secretary by regulation, where a
denial of the portfolio interest exemption is necessary or
appropriate to prevent avoidance of Federal income tax";
". . . any other type of interest identified by the
Secretary by regulation"; ". . . an appropriate portion (as
determined in a manner prescribed by the Secretary) of the
value . . . shall be deemed property within the United
States."
o section 13238 adding IRC section 7701(1) [re regulations
relating to conduit arrangements]: "The Secretary may
prescribe regulations recharacterizing any multiple-party
financing transaction as a transaction directly among any 2
or more of such parties where the Secretary determines that
such recharacterization is appropriate to prevent avoidance
of any tax imposed by this title."
o section 13241(h)(2)(B) and (h)(6)(C)(ii) [re excise taxes
on transportation fuels] adding a note following IRC
section 4081 [re method of payment]: "The tax imposed by
paragraph (1) shall be paid in such manner as the Secretary
shall prescribe . . .. Under regulations prescribed by the
Secretary, principles similar to the principles of clause
(i) shall apply to a group of persons under common control
where 1 or more of such persons is not a corporation."
o section 13242(a) amended IRC section 4081(c) [re taxable
fuels mixed with alcohol]: "Under regulations prescribed by
the Secretary [prescribing how to set the tax rate
reduction]. . . ."
o section 13242(a) amended IRC section 4081(e) [re refunds in
certain cases]: "Under regulations prescribed by the
Secretary, if any person who paid the tax imposed by this
section with respect to any taxable fuel establishes to the
satisfaction of the Secretary that a prior tax was paid
(and not credited or refunded) with respect to such
taxable fuel, then an amount equal to the tax paid by such
person shall be allowed as a refund (without interest) to
such person in the same manner as if it were an
overpayment of tax imposed by this section."
o section 13242(a) amended IRC section 4082(a) and (c) [re
exemptions for diesel fuel]: "The Secretary shall prescribe
such regulations as may be necessary to carry out this
section, including regulations requiring the conspicuous
labeling of retail diesel fuel pumps and other delivery
facilities to assure that persons are aware of which fuel
is available only for nontaxable uses."
o section 13242(a) amended IRC section 4091(c) [re tax on
aviation fuel] "Under regulations prescribed by the
Secretary [providing for reduced tax when part of fuel is
alcohol] . . .."
o section 13242(a) amended IRC section 4092(c) [re tax on
aviation fuel sales to producer]: "Under regulations
prescribed by the Secretary, the tax imposed by section
4091 shall not apply to aviation fuel sold to a producer of
such fuel."
o section 13243(c) [re application of floor stocks tax]
(uncodified provision): "The tax imposed by this section
shall be paid in such manner as the Secretary shall
prescribe."
o section 13245(b) and (e)(3)(B) [re application of floor
stocks tax to commercial aviation fuel]: "The tax imposed
by this section shall be paid in such manner as the
Secretary, principles similar to the principles of
subparagraph (A) shall apply to a group of persons under
common control where 1 or more of such persons is not a
corporation."
o section 13252 adding IRC section 6050P(a) [re returns
relating to the cancellation of indebtedness by certain
financial entities]: ". . . shall make a return (at such
time and in such form as the Secretary may be regulations
prescribe). . ."
o section 13261(a) adding IRC section 197(f)(9) [re
amortization of goodwill and other intangibles]: "For
purposes of this subparagraph, the determination of whether
the user of property changes as part of a transaction shall
be determined in accordance with regulations prescribed by
the Secretary."
o section 13261(a) adding IRC section 197(g): "The Secretary
shall prescribe such regulations as may be appropriate to
carry out the purposes of this section, including such
regulations as may be appropriate to prevent avoidance of
the purposes of this section through related persons or
otherwise."
o section 13261(e) amending IRC section 1060(b) to authorize
regulations, under prior law, to substitute the term "197
intangibles" in place of "goodwill or going concern value
(or similar items)."
o section 13301 added IRC section 1396(d) [re qualified zone
employee]: ". . . the aggregate value of assets leased by
the employer which are used in such a trade or business (as
determined under regulations prescribed by the Secretary)
. . ."
o section 13302(a) added IRC section 1397D [re regulations
for enterprise communities and empowerment zones]: "The
Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of
parts II and III including -- (1) regulations limiting the
benefit of parts II and III . . . [to prevent] an activity
being 100 percent or more subsidized by the Federal
Government, (2) regulations preventing abuse . . . [, and]
(3) regulations dealing with inadvertent failures of
entities to be enterprise zone businesses."
o section 13421 adding note following IRC section 4131 [re
floor stocks tax on vaccines]: "The tax imposed by
paragraph (1) shall be paid in such manner as the Secretary
shall prescribe by regulations."
1994
VIOLENT CRIME CONTROL ACT P.L. 103-322
o section 20415 amending 60501 (g) to require clerks of
criminal courts who receive more than $10,000 in cash as
bail for any individual to make a return (at such time as
the Secretary may by regulations prescribe) and in such
form as the Secretary may prescribe and give a copy to each
person named in the return (at the time such time as the
Secretary may prescribe).
SOCIAL SECURITY DOMESTIC EMPLOYMENT REFORM ACT OF 1994 P.L. 103-387
o section 2 creating IRC section 3510(e) and (f) to give the
Secretary authority to prescribe such regulations as may be
necessary or appropriate to carry out the purposes of the
section. The regulations may treat domestic service
employment taxes as taxes imposed by chapter 1 for
purposes of coordinating the assessment and collection of
the employment taxes with the employer's income taxes. The
Secretary is authorized to enter into agreements with
states to collect such state's unemployment taxes.
URUGUAY ROUND AGREEMENTS ACT P.L. 103-465
o section 136(b) amending IRC section 5007(b): "The internal
revenue tax imposed by section 5001(a)(1) and (2) upon
imported distilled spirits shall be collected by the
Secretary and deposited as internal revenue collections,
under such regulations as the Secretary may prescribe."
o section 701 amending IRC section 3402(r) to provide for
regulations specifying alternate withholding procedures on
Indian casino profits.
o section 702 amending IRC section 3402(p)(1) and (3) to
provide for regulations prescribed by the Secretary for
voluntary withholding on certain federal payments, certain
non-wage payments, and unemployment compensation.
o section 732 amending IRC section 401(a)(17)(B) and 415(d)
and 415(c)(1)(A) and 402(g)(5) and 408(k)(8) re cost of
living adjustments.
o section 741 amending IRC section 731(c)(2)(B)(iv), (v), and
(vi) to permit the regulations to alter the definition of
marketable securities; also section 731(c)(3)(A)(ii),
(c)(3)(B), (c)(3)(C)(i)(VII), (c)(3)(C)(ii)(II); (c)(7) to
prevent avoidance.
o section 751 amending IRC section 412(1)(7)(C)(ii) to
prescribe for plan years beginning after December 31, 1999,
mortality tables to be used in determining current
liability under 2this subsection; and to periodically
review (at least every 5 years) any tables in effect and
update the tables to reflect the actual experience of
pension plans and projected trends in such experience.
o section 751 amending IRC section 412(1)(7)(C)(iii) to
requiring separate mortality tables for the disabled for
plan years beginning after December 31, 1995.
o section 751 adding IRC section 412(1)(9)(F): "The Secretary
may prescribe such regulations as are necessary to carry
out this paragraph [re liquidity requirements and
definition of liquid assets and adjusted disbursements]."
1995
None
1996
OMNIBUS CONSOLIDATED RESCISSIONS AND APPROPRIATIONS ACT OF 1996, P.L. 104-134,
o section 31001 (Debt Collection Improvement Act) adding IRC
section 6050P(e), which provided an alternative procedure
for executive, judicial, or legislative agencies to submit
to the IRS (at such time and in such form as the Secretary
may be regulations prescribe) information sufficient for
the Secretary to complete such a return on behalf of such
agency.
TAXPAYER BILL OF RIGHTS 2, P.L. 104-168,
o section 202, amending IRC section 6159 to require the
Secretary to establish procedures for an independent
administrative review of terminations of installment
agreements for taxpayers who request such a review.
o section 904 amending IRC section 6672 to require the
Secretary to take such actions as may be appropriate to
ensure that employees are aware of their responsibilities
under the federal tax depository system, the circumstances
under which employees may be liable for the penalty imposed
by IRC section 6672, and the responsibility to promptly
report to the IRS any failure to comply, including printing
a warning on deposit coupon booklets and development of a
special information packet, and instructions to IRS
employees about the application of the penalty to
voluntary board members.
o section 1101(a) amending IRC section 7805(b) to permit
Secretary to apply regulations retroactively to prevent
abuse or to correct procedural defects.
o section 1209 amending IRC section 7623 to authorize the
Secretary, under regulations, to pay such sums as deemed
necessary for detecting underpayments of tax and detecting
and bringing to trial and punishment persons guilty of
violating the internal revenue laws or conniving at the
same in cases where such expenses are not otherwise
provided for by law.
o section 1210 amending IRC section 7502 to permit the
Secretary to specify "designated delivery services" for
purposes of the timely-mailing-as timely-filing rule.
o section 1311 adding IRC section 4958(c)(2) to permit the
Secretary to prescribe regulations defining "excess benefit
transaction" to include any transaction in which the
economic benefit provided to or for the use of a
disqualified person is determined in whole or in part by
the revenues of 1 or more activities of the organization
but only if such transaction results in inurement not
permitted under IRC section 501(c)(3) or (4).
o section 1312 adding IRC section 6033(b)(11) and (12) to
permit IRS to require information on excess benefit
transactions and disqualified persons on annual information
returns of exempt organizations.
o section 1313 amending IRC section 6104(e)(1) to require
regulations about what constitutes making a return widely
available and what constitutes a harassment campaign.
SMALL BUSINESS JOB PROTECTION ACT OF 1996, P.L. 104-188
o section 1116 adding IRC section 6050R to require a return
in the form the Secretary may prescribe; section 1120(c)
permits election in the form and manner Secretary may
prescribe re IRC section 168(e)(3); section 1201 amends IRC
section 51 (Work Opportunity Tax Credit) to require the
Secretary to prescribe the form of the prescreening notice
to be used by employers.
o section 1302(d) adding IRC section 641(d)(3) [re special
rules for taxation of electing small business trusts] to
permit only certain deductions "to the extent provided in
regulations, State or local income taxes or administrative
expenses to the extent allocable to items described in
clauses (i) and (ii)."
o section 1306 amending IRC section 1377(a)(2) [re taxation
of S corporations]: "Under regulations prescribed by the
Secretary, if any shareholder terminates the shareholder's
interest in the corporation during the taxable year and
all affected shareholders and the corporation agree to the
application of this paragraph, paragraph (1) shall be
applied to the affected shareholders as if the taxable
year consisted of 2 taxable years the first of which ends
on the date of the termination."
o section 1307(a) amending IRC section 6037(c)(4) [re
definition of subchapter S item]: "The term 'subchapter S
item' means any item of an S corporation to the extent that
regulations prescribed by the Secretary provide that, for
purposes of this subtitle, such item is more appropriately
determined at the corporation level than at the
shareholder level."
o section 1307(b): "If a partnership return is filed for any
taxable year but it is determined that there is no entity
for such taxable year, to the extent provided in
regulations, rules similar to the rules of subsection (a)
shall apply."
o section 1316 adding IRC section 512(e) [re rules for
exempt-organizations holding S corporation stock]: "Except
as provided in regulations, for purposes of paragraph (1),
the basis of any stock acquired by purchase (within the
meaning of section 1012) shall be reduced by the amount of
any dividends received by the organization with respect to
the stock."
o section 1451 amending IRC section 417(a)(7) to permit IRS
to limit the application of the general rule (which permits
a plan to provide an explanation of joint and survivor
annuities after the annuity starting date), except that the
regulations may not limit the period of time by which the
annuity starting date precedes the provision of the
written explanation other than by providing that the
annuity starting date may not be earlier than termination
of employment.
o section 1457 requiring the Secretary (1) to develop sample
language for inclusion in a form' for spousal consent
required under IRC section 417(a)(2) and ERISA section
205(c)(2) written in a manner to be understood by the
average person and disclosing whether the waiver is
irrevocable or may be revoked by a qualified domestic
relations order and (2) to develop sample language for
inclusion in a QDRO described in IRC section 414(p)(1)(A)
and (3) publicity for the sample language.
o section 1461(a) adding IRC section 415(e)(5)(C) to add
rules about ministers participating in non-denominational
plans. The Secretary is to prescribe regulations as may be
necessary or appropriate to carry out the purpose of, and
prevent the abuse of, the subparagraph.
o section 1462(b) permitting the Secretary of the Treasury to
design nondiscrimination and coverage safe harbors for
church plans.
o section 1603 amending IRC section 512(b)(17)(C) to require
the Secretary to prescribe such regulations as may be
necessary or appropriate to carry out the purposes of UBIT
rules relating to foreign income, including regulations
for the application of the rules in the case of income
paid through 1 or more entities or between 2 or more
chains of entities.
o section 1604 adding IRC section 167(g) [re depreciation
under the income forecast method]: "For purposes of this
subsection, except as provided in regulations, the term
'recomputation year' means. . ."
o section 1609(h)(2) codifying as a note following IRC
section 4091 [re floor stocks tax on aviation fuel]: "The
tax imposed by paragraph (1) shall be paid in such manner
as the Secretary shall prescribe"; section 1609(h)(5)(A)
requiring the Secretary to prescribe form for applying for
exemption; section 1609h)(5)(C) requiring the Secretary to
prescribe rules for nonincorporated persons under common
control.
o section 1612 adding IRC section 817A(e): "The Secretary may
prescribe regulations -- (1) to provide for the treatment of
market value adjustments under sections 72, 7702, 7702A,
and 807(e)(1)(B), (2) to determine the interest rates
applicable under sections 807(c)(3), 807(d)(2)(B), and 812
with respect to a modified guaranteed contract annually,
in a manner appropriate for modified guaranteed contracts
and, to the extent appropriate for such a contract, to
modify or waive the applicability of section 811(d), (3)
to provide rules to limit ordinary gain or loss treatment
to assets constitution reserves for modified guaranteed
contracts (and not other assets) of the company, (4) to
provide appropriate treatment of transfers of assets to
and from the segregated account, and (5) as may be
necessary or appropriate to carry out the purposes of this
section."
o section 1613 amending IRC section 118(c) [re contributions
in aid of construction]: "The term 'contribution in aid of
construction' shall be defined by regulations prescribed
by the Secretary, except that such term shall not include
amounts paid as service charges for starting or stopping
services."
o section 1616 amending IRC section 593(g)(8) [relating to
repeal of bad debt loss reserve method for thrift savings
associations]: "The Secretary shall prescribe such
regulations as may be necessary to carry out this
subsection and subsection (e), including regulations
providing for the application of such subsections in the
case of acquisitions, mergers, spin-offs, and other
reorganizations."
o section 1621 [relating to financial asset securitization
investment trusts] adding new IRC section 8601(c): "The
Secretary may prescribe regulations which -- (1) provide
that gain otherwise recognized before the earliest date on
which such property supports any regular interest in which
such FASIT or any indebtedness of the holder of the
ownership interest (or of any person related to such
holder), and (2) provide such adjustments to the other
provisions of this part to the extent appropriate in the
context of the treatment provided under paragraph (1)";
section 8601(d)(1)(A) requires valuation of certain debt
instruments shall be determined in the manner provided by
regulations prescribed by the Secretary; section 860K(e)
provides that "the yield to maturity of any equity
interest shall be determined under regulations prescribed
by the Secretary"; section 860L(a)(6): "Except as provided
in regulations prescribed by the Secretary, any asset which
is a permitted asset at the time acquired by a FASIT shall
not be treated at any time as an interest in such FASIT";
section 860L(b) permits the Secretary to add to definition
of "regular interest" with a variable rate and maturity
date; section 860L(c) permits the Secretary to add to
definition of "permitted asset"; section 860L(c) permits
the Secretary to reduce grace period on foreclosure
property; section 860L(f) [coordination with other
provisions] permits the Secretary to provide exceptions by
regulation; section 860L(h): "Secretary shall prescribe
such regulations as may be necessary or appropriate to
carry out the purposes of this part, including regulations
to prevent the abuse of the purposes of this party through
transactions which are not primarily related to
securitization of debt instruments by a FASIT."; section
1621(e) [treatment of existing securitization entities]:
"Property shall be allocated to a pre-FASIT interest in
such manner as the Secretary of the Treasury may prescribe
. . ."
TECHNICAL CORRECTIONS AMENDMENTS RELATED TO REVENUE RECONCILIATION ACT OF 1990
o section 1702(b)(7) permitting Secretary to prescribe
regulations to carry out purposes of IRC section 5041(c)
including regulations "to prevent the credit from
benefitting any person who produces more than 250,000 wine
gallons of wine during a calendar year. . .."
o section 1702(e)(11)(A) amending IRC section 2702(a)(3)(A)
to add "to the extent that regulations provide that such
transfer is not inconsistent with the purposes of this
section. . . ."
o section 1702(f)(2) amending IRC section 2701(a)(4)(B)(i) to
insert "(or, to the extent provided in regulations, the
rights as to either income or capital)" after "income and
capital."
o section 1702(f)(11)(A) amending IRC section 2702(a)(3)(A):
". . . to the extent that regulations provide that such
transfer is not inconsistent with the purposes of this
section."
o section 1703(i)(3) amending IRC section 956A(f) to require
"regulations coordinating the provisions of subsections
(c)(3)(A) and (d)."
o section 1704(h) amending IRC section 860E: "The preceding
sentence shall not apply to any organization to which
section 592 applies, except to the extent provided in
regulations prescribed by the Secretary under paragraph
(2)."
o section 1801 amending IRC section 4082(c)(2) (exemptions
from diesel fuel dyeing requirement): ". . . the use of
which is certified pursuant to regulations issued by the
Secretary."
o section 1803 amending IRC section 4682(d)(1) to add as a
note: "The Secretary of the Treasury, after consultation
with the Administrator of the Environmental Protection
Agency, shall develop a certification system to ensure
compliance with the recycling requirement for imported
halon under section 4682(d)(1) of the Internal Revenue Code
of 1986, as amended by paragraph 1."
o section 1806 adding IRC section 529(c)(3)(D) [re Qualified
State Tuition Programs]: "For purposes of applying section
72, (i) to the extent provided by the Secretary, all
qualified State tuition programs of which an individual is
a designated beneficiary shall be treated as one program,
(ii) all distributions during a taxable year shall be
treated as one distribution, and (iii) the value of the
contract, income on the contract, and investment in the
contract shall be computed as of the close of the calendar
year in which the taxable year begins."
o section 1806 adding IRC section 529(d): "Each officer or
employee having control of the qualified State tuition
program or their designee shall make such reports as the
Secretary may require regarding such distribution to the
Secretary and to the designated beneficiary or the
individual to whom the distribution was made. Any such
report shall include such information as the Secretary may
prescribe." Reports are to be filed at the time and in the
manner the Secretary prescribes.
o section 1807 adding IRC section 23(f)(2)(B) [re credit for
adoption expenses]: "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 any agent assisting with the
adoption"; section 23(h): "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 limitation in subsection
(b)(1) of this section and in section 137(b)(1)."
o section 1901 adding IRC section 6048 (returns of foreign
trusts): IRC section 6048(b)(1) requires U.S. grantors of
foreign trusts to make a return containing specified
information "and such other information as the Secretary
may prescribe"; IRC section 6048(c)(2): "To the extent
provided in regulations, the preceding sentence [re failure
to provide adequate records to determine proper tax
treatment of distributions] shall not apply if the foreign
trust elects to be subject to rules similar to the rules of
subsection (b)(2)(B)."
o IRC section 6048(d)(2): "To the extent provided in
regulations, a trust which is a United States person shall
be treated as a foreign trust for purposes of this section
and section 6677 if such trust has substantial activities,
or holds substantial property, outside the United States."
o IRC section 6048(d)(3): ". . . at such time and in such
manner as the Secretary shall prescribe." IRC section
6048(d)(4): "The Secretary is authorized to suspend or
modify any requirement of this section if the Secretary
determines that the United State has no significant tax
interest in obtaining the required information."
o section 1903 amending IRC section 679(d) (re foreign trusts
having U.S. beneficiaries): "The Secretary shall prescribe
such regulations as may be necessary or appropriate to
carry out the purposes of this section." [also references
to regulations in IRC section 679(a)(3)].
o section 1904 amending IRC section 672(f)(2) and (f)(3):
"Except as otherwise provided in regulations prescribed by
the Secretary . . ."; (f)(4): "The Secretary may
recharacterize such transfer in such circumstances as the
Secretary determines to be appropriate to prevent the
avoidance of the purposes of this subsection"; (f)(6): "The
Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of this
subsection, including regulations providing that paragraph
(1) shall not apply in appropriate cases." [re foreign
persons not treated as owners under grantor trust rules].
o section 1904(b)(1) [re credit for certain taxes] amending
IRC section 665(d)(2): "Under regulations prescribed by the
Secretary, in the case of any foreign trust of which the
settlor or another person would be treated as owner of any
portion of the trust under subpart E but for section
672(f), the term 'taxes imposed on the trust' includes the
allocable amount of any income, war profits, and excess
profits taxes imposed by any foreign country or possession
of the United States on the settlor or such other person in
respect of trust income."
o section 1904(b)(2) amending IRC section 901(b)(5): "Under
rules or regulations prescribed by the Secretary, in the
case of any foreign trust of which the settlor or another
person would be treated as owner of any portion of the
trust under subpart E but for section 672(f), the allocable
amount of any income, war profits, and excess profits
taxes imposed by any foreign country or possession of the
United States on the settlor or such other person in
respect of trust income."
o section 1905 adding IRC section 6039F [re notice of large
gifts received from foreign persons]. IRC section 6039F(a):
"Such United States person shall furnish (at such time and
in such manner as the Secretary shall prescribe) such
information as the Secretary may prescribe regarding each
foreign gift received during such year"; IRC section
6039F(c): "[Penalty for failure to file information] the
tax consequences of the receipt of such gift shall be
determined by the Secretary"; IRC section 6039F(e): "The
Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of this
section."
o section 1906 [re foreign trusts which are not grantor
trusts] amending IRC section 643(a)(7): "The Secretary
shall prescribe such regulations as may be necessary or
appropriate to carry out the purposes of this part,
including regulations to prevent avoidance of such
purposes."
o IRC section 643(i)(1) [re loans from foreign trusts]:
"Except as provided in regulations, if a foreign trust
makes a loan of cash or marketable securities directly or
indirectly to -- . . . the amount of such loan shall be
treated as a distribution by such trust to such grantor or
beneficiary (as the case may be)." IRC section 643(i)(2)(B)
[re family allocation rules]: "If any person described in
paragraph (1)(B) is related to more than one person, the
grantor or beneficiary to whom the treatment under this
subsection applies shall be determined under regulations
prescribed by the Secretary."
P.L. 104-191 HEALTH INSURANCE PORTABILITY ACT
o section 321 adding IRC section 7702B [re treatment of
long-term care insurance]: IRC section 7702B(c)(2)(ii)
(definition of chronically ill individual) "having a level
of disability similar (as determined under regulations
prescribed by the Secretary in consultation with the
Secretary of Health and Human Services) to the level of
disability described in clause (i)." IRC section 7702B(c)(4)
(definition of licensed health care practitioner) "or other
individual who meets such requirements as may be prescribed
by the Secretary." IRC section 7702B(d)(3) (aggregation
rules) "any remaining limitation shall be allocated among
the other such persons in such manner as the Secretary
shall prescribe." IRC section 7702B(e) (coverage provided
as part of a life insurance contract) "Except as otherwise
provided in regulations prescribed by the Secretary.
o section 323 adding IRC section 6050Q (reporting requirement
for long-term care benefits) "Any person who pays long term
care benefits shall make a return, according to the forms or
regulations prescribed by the Secretary,. . ."
o section 401(a) adding IRC section 9801(e)(3) [re increased
portability of group health plans through limitations on
preexisting conditions]: "The Secretary shall establish
rules to prevent an entity's failure to provide information
under paragraph (1) or (2) with respect to previous
coverage of an individual from adversely affecting any
subsequent coverage of the individual under another group
health plan or health insurance coverage."
o section 401 adding IRC section 9806 [re group health plan
portability, access, and renewability requirements]: "The
Secretary, consistent with section 104 of the Health Care
Portability and Accountability Act of 1996, may promulgate
such regulations as may be necessary or appropriate to carry
out the provisions of this chapter. The Secretary may
promulgate any interim final rules as the Secretary
determines are appropriate to carry out this chapter."
o section 401(c)(4) [re group health plan portability,
access, and renewability requirements]: "The Secretary of
the Treasury, consistent with section 104, shall first issue
by not later than April 1, 1997, such regulations as may
be necessary to carry out the amendments made by this
section."
o section 511 amending IRC section 877 [re tax treatment of
expatriates]. IRC section 877(b)(2)(D): "An individual is
described in this subparagraph if the individual is
described in a category of individuals prescribed by
regulation by the Secretary." IRC section 877(c)(2)(D):
"To the extent provided in regulations prescribed by the
Secretary, subparagraph (B) shall be applied by
substituting the 15-year period beginning 5 years before
the loss of United States citizenship for the 10-year
period referred to therein." IRC section 877(c)(2)(E): "To
the extent provided in regulations prescribed by the
Secretary -- (i) the removal of appreciated tangible
personal property from the United States, and (ii) any
other occurrences which (without recognition of gain)
results in a change in the source of the income or gain
from property from sources within the United States to
sources outside the United States, shall be treated as an
exchange to which this paragraph applies." IRC section
877(d)(4)(D) [re anti-abuse regulations]: "The Secretary
shall prescribe such regulations as may be necessary to
prevent the avoidance of the purposes of this paragraph,
including where -- (i) the property is sold to the
corporation, and (ii) the property taken into account under
subparagraph (A) is sold by the corporation." IRC section
877(d)(4)(E): "The Secretary shall require such information
reporting as is necessary to carry out the purposes of this
paragraph." IRC section 877(e)(4) and (5) [treatment of
permanent residents as expatriates]: "(4)This subsection
shall not apply to an individual who is described in a
category of individuals prescribed by regulation by the
Secretary. . . . (5) The Secretary shall prescribe such
regulations as may be appropriate to carry out this
subsection, including regulations providing for the
application of this subsection in cases where an alien
individual becomes a resident of the United States during
the 10-year period after being treated as provided in
paragraph (1)."
o section 512 adding IRC section 6039F(b) [re information on
individuals losing U.S. citizenship]: ". . . such other
information as the Secretary may prescribe." IRC section
6039F(g): "The Secretary may by regulations exempt any
class of individuals from the requirements of this section
if he determines that applying this section to such
individuals is not necessary to carry out the purposes of
this section."
1997
BALANCEUDGET ACT OF 1997, P.L. 105-33
o section 9302 amending IRC section 5704(b) [re tobacco
products labeling for export]: "Tobacco products and
cigarette papers and tubes may not be transferred or
removed under this subsection unless such products or
papers and tubes bears such marks, labels, or notices as
the Secretary shall by regulations prescribe." Also adding
IRC section 5754 [re restriction on importation of
previously exported tobacco products]: "For purposes of
this section, section 5704(d), section 5761, and such other
provisions as the Secretary may specify by regulations,
references to exportation shall be treated as including a
reference to shipment to the Commonwealth of Puerto Rico."
Also adding note following IRC section 5701 [re exempting
cigarettes held in vending machines from tax]: "To the
extent provided in regulations prescribed by the Secretary,
no tax shall be imposed by paragraph (1) on cigarettes held
for retail sale on any tax increase date, by any person in
any vending machine." Also adding [re method of payment]:
"The tax imposed by paragraph (1) shall be paid in such
manner as the Secretary shall prescribe by regulations."
o section 11024(c) adding a note to IRC section 6103 [re
exchange of information for verification of D.C. retirement
benefits]: "The Secretary may issue regulations governing
the confidentiality of the information obtained pursuant to
subsection (a) and the provisions of law amended by
subsection (b)."
TAXPAYER RELIEF ACT OF 1997, P.L. 105-34
o section 201 adding IRC section 25A(i) [re Hope and Lifetime
Learning credits]: "The Secretary may prescribe such
regulations as may be necessary or appropriate to carry out
this section, including regulations providing for recapture
of the credit allowed under this section in cases where
there is a refund in a subsequent taxable year of any
amount which was taken into account in determining the
amount of such credit." Also adding IRC section 6050S(g)
[re returns relating to higher education tuition and
related expenses]: "The Secretary shall prescribe such
regulations as may be necessary to carry out the provisions
of this section. No penalties shall be imposed under
part II of subchapter B of chapter 68 with respect to any
return or statement required under this section until such
time as such regulations are issued." [also references to
regulations in IRC section 6050S(a), (e), and (f)].
o section 311(a) amending IRC section 1(h)(11) [re treatment
of pass-thru entities and capital gains]: "The Secretary may
prescribe such regulations as are appropriate (including
regulations requiring reporting) to apply this subsection
in the case of sales and exchanges by pass-thru entities
(as defined in paragraph (10)(C) and of interests in such
entities."
o section 311(c) amending IRC section 904(b)(2) [re
coordination with capital gains rates]: "The Secretary may
by regulations modify the application of this paragraph and
paragraph (3) to the extent necessary to properly reflect
any capital gain rate differential under 1(h) or 1201(a) and
the computation of net capital gain."
o section 312 amending IRC section 121 [re exclusion of gain
from sale of principal residence]: "This subsection shall
apply to any sale or exchange if -- . . . such sale or
exchange is by reason of a change in place of employment,
health, or, to the extent provided in regulations,
unforeseen circumstances."
o section 312 amending IRC section 6045(e) [re nonrecognition
of gain on sales of certain principal residences]: "The
Secretary may by regulation increase the dollar amounts
under this subparagraph if the Secretary determines that
such an increase will not materially reduce revenues to the
Treasury."
o section 312 amending IRC section 1038(e) [re reacquisition
of a principal residence]: "If. . .(2) within 1 year after
the date of the reacquisition of such property by the
seller, such property is resold by him, then under
regulations prescribed by the Secretary, subsections (b),
(c), and (d) of this section shall not apply to the
reacquisition of such property and, for purposes of
applying section 121, the resale of such property shall be
treated as a part of the transaction constituting the
original sale of such property."
o section 502 amending IRC section 2033A(g) [re noncitizen
heirs]: "The term 'qualified trust' means a trust -- . . .
except as otherwise provided in regulations, with respect
to which the trust instrument requires that at least 1
trustee of the trust be an individual citizen of the United
States or a domestic corporation."
o section 507 [re repeal of throwback rules applicable to
certain domestic trusts] amending IRC section 655(c)(2):
"For purposes of this subsection, the term 'qualified
trust' means any trust other than -- (A) a foreign trust
(or, except as provided in regulations, a domestic trust
which at any time was a foreign trust), or. . . ."
o section 911 adding IRC section 7508A(a) [re authority to
postpone certain tax-related deadlines by reason of
presidentially declared disaster]: "In the case of a
taxpayer determined by the Secretary to be affected by a
Presidentially declared disaster (as defined by section
1033(h)(3)), the Secretary may prescribe regulations under
which a period of up to 90 days may be disregarded in
determining, under the internal revenue laws, in respect of
any tax liability (including any penalty, additional amount,
or addition to the tax) of such taxpayer -- (1) whether any
of the acts described in paragraph (1) of section 7508(a)
were performed within the time prescribed therefor, and (2)
the amount of any credit or refund."
o section 912 amending IRC section 165(i)(4): "Nothing in
this title shall be construed to prohibit the Secretary from
prescribing regulations or other guidance under which an
appraisal for the purpose of obtaining a loan of Federal
funds or a loan guarantee from the Federal Government as a
result of a Presidentially declared disaster (as defined
by section 1033(h)(3)) may be used to establish the amount
of any loss described in paragraph (1) or (2)."
o section 933 adding IRC section 1301(c) [re averaging of farm
income]: "The Secretary shall prescribe such regulations as
may be appropriate to carry out the purposes of this section,
including regulations regarding -- (1) the order and manner
in which items of income, gain, deduction, or loss, or
limitations on tax, shall be taken into account in
computing the tax imposed by this chapter on the income of
any taxpayer to whom this section applies for any taxable
year, and (2) the treatment of any short taxable year."
o section 935 [re moratorium on regulations]: "No temporary or
final regulation with respect to the definition of a
limited partner under section 1402(a)(13) of the Internal
Revenue Code of 1986 may be issued or made effective
before July 1, 1998."
o section 941 adding IRC section 198(g) [re expensing of
environmental remediation costs]: "The Secretary shall
prescribe such regulations as may be necessary or
appropriate to carry out the purposes of this section."
o section 1001 adding IRC section 1259(c)(1)(E) [re
constructive sales treatment for appreciated financial
positions]: "A taxpayer shall be treated as having made a
constructive sale of an appreciated financial position if
the taxpayer (or a related person) -- . . .(E) to the
extent prescribed by the Secretary in regulations, enters
into 1 or more other transactions (or acquires 1 or more
positions) that have substantially the same effect as a
transaction described in any of the preceding
subparagraphs." IRC section 1259(f): "The Secretary shall
prescribe such regulations as may be necessary or
appropriate to carry out the purposes of this section."
o section 1001 amending IRC section 475(e)(2)(D) [re election
to mark to market for securities dealers]: ". . . or such
other time as the Secretary may be regulations prescribe";
IRC section 475(f)(1) [re election of mark to market for
traders in securities or commodities]: "The Secretary may
provide by regulations for the application of this
subparagraph at times other than the times provided in this
subparagraph."
o section 1002 amending IRC section 351(e)(1)(B) [re
determination of whether a company is an investment
company]: "The Secretary may prescribe regulations that,
under appropriate circumstances, treat any asset described
in clauses (i) through (v) as not so listed." (Clauses (v)
through (viii) also provide "to the extent provided in
regulations" or "except as otherwise provided").
o section 1003 amending IRC section 1233(h) [re treatment of
short sales where property has become substantially
worthless]: "To the extent provided in regulations prescribed
by the Secretary, the preceding sentence also shall apply with
respect to any option with respect to property, any
offsetting notional principal contract with respect to
property, any futures or forward contract to deliver any
property, and any other similar transaction"; [re
notification]: ". . . the date which is 3 years after the
date the Secretary is notified by the taxpayer (in such
manner as the Secretary may by regulations prescribe). . ."
o section 1004 amending IRC section 1272(a)(6) [re
determination of original issue discount where pooled debt
obligations subject to acceleration]: "To the extent
provided in regulations prescribed by the Secretary, in the
case of a small business engaged in the trade or business of
selling tangible personal property at retail, clause (iii)
shall not apply to . . .."
o section 1005 adding IRC section 163(1)(5) [re disallowance
of deduction on certain debt instruments of corporations]:
"The Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of this
subsection, including regulations preventing avoidance of
this subsection through the use of an issuer other than a
corporation."
o section 1011 amending IRC section 1059(e)(1) [re treatment of
partial liquidations and certain redemptions]: "Except as
otherwise provided in regulations -- . . ."
o section 1012 adding IRC section 355(e)(3)(A) [re recognition
of gain on certain distributions of stock or securities in
connection with acquisitions]: "Except as provided in
regulations, the following acquisitions shall not be
treated as described in paragraph (2)(A)(ii):. . ."; section
355(e)(3)(B): "Except as provided in regulations, . . .or
any other transaction specified in regulations by the
Secretary, the shareholders . . . shall be treated as
acquiring stock in the corporation from which the assets
were acquired"; section 355(e)(4)(C) [re attribution rules]:
"Except as provided in regulations, section 318(a)(2)(C)
shall be applied without regard to the phrase '50 percent
or more in value' for purposes of the preceding sentence";
section 355(e)(4)(E) [re statute of limitations]: "The
statutory period for the assessment of any deficiency
attributable to any part of the gain recognized under this
subsection by reason of such distribution shall not expire
before the expiration of 3 years from the date the Secretary
is notified by the taxpayer (in such manner as the Secretary
may by regulations prescribe) that such distribution
occurred,. . ."; section 355(e)(5) [re recognition of
gain]: "The Secretary shall prescribe such regulations as
may be necessary to carry out the purposes of this
subsection, including regulations -- . . . where there is
more than 1 controlled corporation. . . where necessary to
prevent the avoidance of such purposes, and (C) providing
for the application of rules similar to the rules of
subsection (d)(6) where appropriate for purposes of
paragraph (2)(B)"; section 355(f): "Except as provided in
regulations. . . ."
o section 1013 amending IRC section 304(b)(5)(A) and (B) and
(C) [re acquisitions by foreign corporations]: "The
Secretary shall prescribe such regulations as are
appropriate to carry out the purposes of this paragraph."
o section 1014 adding IRC section 355(g)(4) [re preferred
stock treated as boot]: "The Secretary may prescribe such
regulations as
may be necessary or appropriate to carry out the purposes
of this subsection and sections 354(a)(2)(C),
355(a)(3)(D), and 356(e). The Secretary may also prescribe
regulations, consistent with the treatment under this
subsection and such sections, for the treatment of non
qualified preferred stock under other provisions of this
title."
o section 1014 adding IRC section 354(a)(2)(C)(ii) [re
recapitalizations of family-owned corporations]: "For
purposes of this clause, except as provided in regulations,
the term family-owned corporation' means any corporation
which is described. . ."
o section 1021 [re reporting certain payments made to
attorneys] noncodified provision following IRC section
6045: "The regulations providing an exception under section
6041 of the Internal Revenue Code of 1986 for payments made
to corporations shall not apply to payments of attorneys'
fees."
o section 1022 adding IRC section 6041A(d)(3) [re decrease of
threshold for reporting payments to corporations performing
services for federal agencies]: ". . . such other services
as the Secretary may specify in regulations prescribed
after the date of the enactment of this paragraph."
o section 1031 adding IRC section 4261(e)(3)(C) [airport and
airway trust fund taxes]: "The Secretary shall prescribe
rules which reallocate items of income, deduction, credit,
exclusion, or other allowance to the extent necessary to
prevent the avoidance of tax imposed by reason of this
paragraph. The Secretary may prescribe rules which exclude
from the tax imposed by subsection (a) amounts
attributable to mileage awards which are used other than
for transportation of persons by air."
o section 1032 amending IRC section 4082(d)(1) and (2) and
(3) [re exemption of aviation grade kerosene from dyeing
requirements]: "Subsection (a)(2) shall not apply to a
removal, entry, or sale of aviation-grade kerosene (as
determined under regulations prescribed by the Secretary)
if the person receiving the kerosene is registered. . ."
[similar provisions for use for non-fuel feedstock
purposes, for wholesale distributors, for sales not for
use in motor fuels, for blending with heating oil].
o section 1034 adding IRC section 4251(d) [re application of
communications tax to prepaid telephone cards]: "In the
case of any prepaid telephone card which entitles the user
other than to a specified dollar amount of use, the face
amount shall be determined under regulations prescribed by
the Secretary."
o section 1042 setting out as a note following IRC section
833 [re termination of exceptions from rules about exempt
organizations providing commercial-type insurance]: "The
Secretary of the Treasury or his delegate may prescribe
rules for providing proper adjustments for organizations
described in subsection (b) with respect to short taxable
years which begin during 1998 by reason of section 843 of
the Internal Revenue Code of 1986."
o section 1051 amending IRC section 954(c)(2)(C) [re
definition of foreign personal holding company exception
for dealers]: "Except as provided in subparagraph (A), (E),
or (G) of paragraph (1) or by regulations, in the case of
a regular dealer in property (within the meaning of
paragraph (1)(B)), forward contracts, option contracts, or
similar financial instruments (including notional principal
contracts and all instruments referenced to commodities),
there shall not be taken into account in computing foreign
personal holding income any item of income, gain,
deduction, or loss from any transaction (including hedging
transactions) entered into in the ordinary course of such
dealer's trade or business as such a dealer."
o section 1053 adding IRC section 901(k)(4)(C) [re holding
period requirement for certain foreign taxes]: "The
Secretary may prescribe such regulations as may be
appropriate to carry out this paragraph, including
regulations to prevent the abuse of the exception provided
by this paragraph and to treat other taxes as qualified
taxes."
o section 1054 adding IRC section 894(c)(2) [re denial of
treaty benefits for certain payments through hybrid
entities]: "The Secretary shall prescribe such regulations
as may be necessary or appropriate to determine the extent
to which a taxpayer to which paragraph (1) does not apply
shall not be entitled to benefits under any income tax
treaty of the United States with respect to any payment
received by, or income attributable to any activities of,
an entity organized in any jurisdiction (including the
United States) that is treated as a partnership or is
otherwise treated as fiscally transparent for purposes of
this title . . . ."
o section 1084 amending IRC section 805(a)(4)(F) [re adjusted
cash value definition for life insurance companies]: "(ii)
For purposes of clause (i), the term 'adjusted cash value'
means . . . or charges specified in regulations prescribed
by the Secretary. . ."
o section 1085 adding IRC section 6695(g) [re penalty for
income tax preparers failing due diligence test with
respect to earned income tax credit]: "Any person who is an
income tax return preparer with respect to any return or
claim for refund who fails to comply with due diligence
requirements imposed by the Secretary by regulations with
respect to determining eligibility for, or the amount of,
the credit allowable by section 32 shall pay a penalty of
$100 for each such failure."
o section 1086 amending IRC section 167(g)(6)(E) [re
limitation on property for which income forecast method of
depreciation may be used]: ". . . other property specified
in regulations."
o section 1089 amending IRC section 664(d)(4)(B) [re
charitable remainder trusts]: "If. . . such contribution
would. . . result in the such trust ceasing to be a
charitable unitrust by reason of paragraph (2)(D), such
contribution shall be treated as a transfer to a separate
trust under regulations prescribed by the Secretary."
o section 1102 amending IRC section 986(a)(3) [re authority
to use average exchange rates in translating foreign
taxes]: "To the extent prescribed in regulations, the
average exchange rate for the period (specified in such
regulations) during which the taxes or adjustment is paid
may be used instead of the exchange rate as of the time of
such payment."
o section 1105 amending IRC section 904(d)(4)(C)(ii)(II) [re
foreign tax credit for certain dividends]: "The Secretary
may prescribe regulations regarding the treatment of
distributions out of earnings and profits for periods
prior to the taxpayer's acquisition of such stock."
o section 1112 adding IRC section 961(c) [re basis
adjustments in stock held by foreign corporations]: "Under
regulations prescribed by the Secretary, if a United States
shareholder is treated under section 958(a)(2) as owing
any stock in a controlled foreign corporation which is
actually owned by another controlled foreign corporation,
adjustments similar to the adjustments provided by
subsections (a) and (b) shall be made to the basis of such
stock . . . but only to the extent of such portion, and
subject to such proof of identity of such interest as the
Secretary may prescribe by regulations."
o section 1113 amending IRC section 960(a)(1) [re deemed paid
credit]: ". . . except to the extent provided in
regulations, section 902 shall be applied as if the amount
so included were a dividend paid by such foreign
corporation. . ."
o section 1122 adding IRC section 1296 [re election of mark
to market for marketable stock]. section 1296(e)(1): "To
the extent provided in regulations" marketable stock can
include foreign stock and certain options . . ."; section
1296(g): "Except as provided in regulations" stock owned in
or through foreign entities will be treated as owned
directly; IRC section 852(b)(10) [re treatment of losses on
stock in passive foreign investment companies]: ". . . to
the extent provided in regulations."
o section 1131 adding IRC section 684(a) [re recognition of
gain on certain transfers to certain foreign trusts and
estates]: "Except as provided in regulations, in the case
of any transfer of property by a United States person to a
foreign estate or trust, for purposes of this subtitle,
such transfer shall be treated as a sale or exchange. . ."
o section 1131 adding IRC section 1135(c): "To the extent
provided in regulations, subsection (a) shall not apply to
any exchange having the effect of transferring property to
any person other than a United States person."
o section 1131 adding IRC section 721(c): "The Secretary may
provide by regulations that subsection (a) shall not apply
to gain realized on the transfer of property to a
partnership if such gain, when recognized, will be
includible in the gross income of a person other than a
United States person."
o section 1131 amending IRC section 367(d)(3) [re regulations
relating to transfers of intangibles to partnerships]: "The
Secretary may provide by regulations that the rules of
paragraph (2) also apply to the transfer of intangible
property by a United States person to a partnership in
circumstances consistent with the purposes of this
subsection." IRC section 367(f): "To the extent provided in
regulations, if a United States person transfers property
to a foreign corporation as paid-in surplus or as a
contribution to capital (in a transaction not otherwise
described in this section), such transfer shall be treated
as a sale or exchange. . ."
o section 1141 adding IRC section 6031(e)(2) [re certain foreign
partnerships required to file returns]: "Except as
provided in regulations prescribed by the Secretary. . ."
o section 1142 amending IRC section 6038(b)(3) [re
information reporting with respect to certain foreign
corporations and partnerships]: ". . . to the extent
provided in regulations" (definition of 50% interest in
partnership).
o section 1144 amending IRC section 6038B(a) [re transfers of
property to foreign partnerships subject to information
reporting]: ". . . or in any other contribution described
in regulations prescribed by the Secretary."
o section 1151 amending IRC section 7701(a)(4) [re
determination of foreign or domestic status of
partnerships]: ". . . unless, in the case of a partnership,
the Secretary provides otherwise by regulations."
o section 1161 amending transition rule in section 1907(a) of
the Small Business Job Protection Act of 1996, a note
following IRC section 7701 [re transition rule for certain
trusts]: "To the extent prescribed in regulations by the
Secretary of the Treasury or his delegate, a trust which
was in existence on August 20, 1996 (other than a trust
treated as owned by the grantor under subpart E of part I
of subchapter J of chapter 1 of the Internal Revenue Code
of 1986), and which was treated as a United States person
on the day before the date of the enactment of this Act may
elect to continue to be treated as a United States person
notwithstanding section 7701(a)(30)(E) of such Code."
o section 1175 amending IRC section 954(h)(2)((C) [re
exemption for income derived in the active conduct of
banking, financing, or similar businesses]: "The Secretary
shall prescribe regulations consistent with the principles
of section 904(d)(3) which provide that dividends,
interest, income equivalent to interest, rent, or royalties
received or accrued from a related person. . . shall be
subject to look-thru treatment for purposes of this
subsection."
o section 1205 amending IRC section 6311(a) [re accepting
payment by credit cards]: "It shall be lawful for the
Secretary to receive for internal revenue taxes . . . any
commercially acceptable means that the Secretary deems
appropriate to the extent and under the conditions provided
in regulations prescribed by the Secretary." section
6311(d): "The Secretary shall prescribe such regulations as
the Secretary deems necessary to receive payment by
commercially acceptable means. . ."
o section 1213 adding IRC section 110(d) [re qualified lessee
construction allowances for short-term leases]: "Under
regulations, the lessee and lessor described in subsection
(a) shall, at such times and in such manner as may be
provided in such regulations, furnish to the Secretary --
(1) information concerning the amounts received (or
treated as a rent reduction) and expended as described in
subsection (a), and (2) any other information which the
Secretary deems necessary to carry out the provisions of
this section."
o section 1221 adding IRC section 772(c)(5) [ re minimum tax
treatment of large electing partnerships]: "Except as
provided in regulations, the applicable net AMT adjustment
shall be treated, for purposes of section 53, as an
adjustment or item of tax preference not specified in
section 53(d)(1)(B)(ii)."
o section 1221 adding IRC section 773(a)(3)(B)(iv) [re
limitations applied at partner level] "Any other provision
specified in regulations."
o section 1221 adding IRC section 775 [re electing large
partnership defined]: "To the extent provided in
regulations, a partnership shall cease to be treated as an
electing large partnership for any partnership taxable year
if in such taxable year fewer than 100 persons were
partners in such partnership."
o section1221 adding IRC section 777 [re simplification
provisions for electing large partnerships]: "The Secretary
shall prescribe such regulations as may be appropriate to
carry out the purposes of this part."
o section 1222 [re simplified audit procedures for electing
large partnerships] adding IRC section 6242(d)(5) [re
procedures for taking partnership adjustments into
account]: "Under regulations, appropriate adjustments in
the application of this section shall be made for purposes
of taking into account partnership adjustments which
involve a change in the character of any item of income,
gain, loss, or deduction."
o section 1222 adding IRC section 6255(d) [re audit
procedures for electing large partnerships]: "If a
partnership ceases to exist before a partnership adjustment
under this subchapter takes effect, such adjustment shall
be taken into account by the former partners of such
partnership under regulations prescribed by the Secretary."
o section 1222 adding IRC section 6255(g): "The Secretary shall
prescribe such regulations as may be necessary to carry
out the provisions of this subchapter, including
regulations -- (1) to prevent abuse through manipulation of
the provisions of this subchapter, and (2) providing that
this subchapter shall not apply to any case described in
section 6231(c)(1) (or the regulations prescribed
thereunder) where the application of this subchapter to
such a case would interfere with the effective and
efficient enforcement of this title."
o section 1224 amending IRC section 6011(e)(2) [re
partnerships returns]: "Notwithstanding the preceding
sentence, the Secretary shall require partnerships having
more than 100 partners to file returns on magnetic media."
o section 1233 amending IRC section 6229(b)(2) [re
partnerships in bankruptcy]: "Such agreement shall be
binding on all partners in the partnership unless the
Secretary has been notified of the bankruptcy proceeding in
accordance with regulations prescribed by the Secretary."
o section 1251 amending IRC section 857(f) [re taxation of
real estate investment trusts]: "Each real estate
investment trust shall each taxable year comply with
regulations prescribed by the Secretary for the purposes of
ascertaining the actual ownership of the outstanding
shares, or certificates of beneficial interest, of such
trust."
o section 1254 amending IRC section 857(b)(3)(D) [re
treatment of shareholders of real estate investment trusts
of undistributed capital gains]: "(v) The earnings and
profits of such real estate investment trust, and the
earnings and profits of any such shareholder which is a
corporation, shall be appropriately adjusted in accordance
with regulations prescribed by the Secretary."
o section 1258 [re treatment of hedging instruments] adding
IRC section 856(c)(5)(G): "Except to the extent provided by
regulations,. . ." (hedging income qualifies as real estate
investment income).
o section 1312 amending IRC section 2056A(c)(3) [re qualified
domestic trust rules]: "To the extent provided in
regulations prescribed by the Secretary, the term 'trust'
includes other arrangements which have substantially the
same effect as a trust."
o section 1314 amending IRC section 2056A(a)(1) (A) [re
authority to waive requirement of United States trustee of
qualified domestic trust]: "Except as provided in
regulations prescribed by the Secretary. . . ."
o section 1412 amending IRC section 5175(c) [re authority to
cancel or credit export bonds without submission of
records]: ". . . if there is such proof of exportation as
the Secretary may be regulations require."
o section 1414 amending IRC section 5053(f) [re removal for
use as distilling material]: "Subject to such regulations
as the Secretary may prescribe, beer may be removed from a
brewery without payment of tax to any distilled spirits
plant for use as distilling material."
o section 1414 amending IRC section 5056(c) [re beer received
at a distilled spirits plant]: "The brewer may be relieved
of liability therefor, under regulations as the Secretary
may prescribe, if such beer is received on the bonded
premises of a distilled spirits plan pursuant to the
provisions of section 5222(b)(2), for use in the production
of distilled spirits."
o section 1418 added IRC section 5053(g)(1) [re withdrawal of
beer for use of foreign embassies]: "Subject to such
regulations as the Secretary may prescribe-beer may be
withdrawn. . . ."
o section 1419 added IRC section 5053(h) [re removal for
destruction]: "Subject to such regulations as the Secretary
may prescribe, beer may be removed from the brewery without
payment of tax for destruction."
o section 1420 amending IRC section 5055 [re drawback of tax
on beer]: ". . . if there is such proof of exportation as
the Secretary may by regulations require."
o section 1421 adding IRC section 5418 [re beer imported in
bulk]: "Beer imported or brought into the United States in
bulk containers may, under such regulations as the
Secretary may prescribe, be withdrawn from customs custody
and transferred in such bulk containers to the premises of
a brewery without payment of the internal revenue tax
imposed on such beer."
o section 1422 adding IRC section 5364 [re wine imported in
bulk]: "Wine imported or brought into the United States in
bulk containers may, under such regulations as the
Secretary may prescribe, be withdrawn from customs custody
and transferred in such bulk containers to the premises of
a bonded wine cellar without payment of the internal
revenue tax imposed on such wine."
o section 1434 adding IRC section4052(g) [re retail tax on
heavy trucks]: "The Secretary shall prescribe regulations
which permit, in lieu of any other certification, persons
who are purchasing articles taxable under this subchapter
for resale or leasing in a long-term lease to execute a
statement (made under penalties of perjury) on the sale
invoice that such sale is for resale. The Secretary shall
not impose any registration requirement as a condition of
using such procedure."
o section 1504 adding note following IRC section 403 [re repeal
of rules in IRC section 415(e)]; "The Secretary of the
Treasury shall modify the regulations regarding the exclusion
allowance under section 403(b)(2) of the Internal Revenue Code
of 1986 to reflect the amendment made by section 1452(a) of
the Small Business Job Protection Act of 1996. Such
modification shall take effect for years beginning after
December 31, 1999."
o section 1509 adding uncodified provision [re clarification of
disqualification rules relating to acceptance of rollover
contributions]: "The Secretary of the Treasury or his
delegate shall clarify that, under the Internal Revenue
Service regulations protecting pension plans from
disqualification by reason of the receipt of invalid
rollover contributions under section 402(c) of the
Internal Revenue Code of 1986, in order for the
administrator of the plan receiving any such contribution
to reasonably conclude that the contribution is a valid
rollover contribution it is not necessary for the
distributing plan to have a determination letter with
respect to its status as a qualified plan under section
401 of such Code."
o section 1510 [re new technologies in retirement plans]: "Not
later than December 31, 1998, the Secretary of the
Treasury and the Secretary of Labor shall each issue
guidance which is designed to -- (1) interpret the notice,
election, consent, disclosure, and time requirements (and
related recordkeeping requirements) under the Internal
Revenue Code of 1986 and the Employee Retirement Income
Security Act of 1974 relating to retirement plans as
applied to the use of new technologies by plan sponsors
and administrators while maintaining the protection of the
rights of participants and beneficiaries, and (2) clarify
the extent to which writing requirements under the
Internal Revenue Code of 1986 relating to retirement plans
shall be interpreted to permit paperless transactions."
TECHNICAL CORRECTIONS TO SMALL BUSINESS JOBS PROTECTION ACT
o section 1601(a) amending IRC section 1361(b)(3) [re definition
of S corporation]: "Except as provided in regulations
prescribed by the Secretary, for purposes of this
title. . ."
o section 1601(i) adding note following IRC section 7701 [re
effective date related to subtitle I of SBJPA]: "The Secretary
of the Treasury may by regulations or other administrative
guidance provide that the amendments made by section
1907(a) of the Small Business Job Protection Act of 1996
shall not apply to a trust with respect to a reasonable
period beginning on the date of the enactment of such Act,
if. . . and such trust meets such other conditions as the
Secretary may require."
1998
P.L. 105-206 INTERNAL REVENUE SERVICE RESTRUCTURING AND REFORM ACT OF 1998
o section 1102 amending IRC section 7811(a) [re authority to
issue taxpayer assistance orders]: "Upon application filed
by a taxpayer with the Office of the Taxpayer Advocate (in
such form, manner, and at such time as the Secretary shall by
regulations prescribe), the National Taxpayer Advocate may
issue a Taxpayer Assistance Order if -- . . . the taxpayer
meets such other requirements as are set forth in
regulations prescribed by the Secretary."
o section 2003 amending IRC section7502(c)(2) [re alternative
methods for filing returns]: "The Secretary is authorized to
provide by regulations the extent to which the provisions
of paragraph (1) with respect to prima facie evidence of
delivery and the postmark date shall apply to certified
mail and electronic filing."
o section 2003 adding a note following IRC section 6011 [re
electronic filing of other information]: "In the case of
taxable period beginning after December 31,1999, the
Secretary of the Treasury or the Secretary's delegate shall,
to the extent practicable, establish procedures to accept,
in electronic form, any other information, statements,
elections, or schedules, from taxpayers filing returns
electronically, so that such taxpayers will not be
required to file any paper."
o section 2004 adding note following IRC section 6012 [re
return-free system]: "The Secretary of the Treasury or the
Secretary's delegate shall develop procedures for the
implementation of a return-free tax system under which
appropriate individuals would be permitted to comply with
the Internal Revenue Code of 1986 without making the return
required under section 6012 of the such Code for taxable years
beginning after 2007."
o section 2005 adding note following IRC section 6103 [re
electronic access to account information]: "Not later than
December 31, 2006, the Secretary of the Treasury or the
Secretary's delegate shall develop procedures under which a
taxpayer filing returns electronically . . . would be able to
review the taxpayer's account electronically. . ."
o section 3201 adding IRC section 6105(d)(3)(B) [re innocent
spouse rules]: "Under rules prescribed by the Secretary, an
item otherwise allocable to an individual under subparagraph
(A) shall be allocated to the other individual filing the
joint return to the extent the item gave rise to a tax
benefit on the joint return to the other individual." section
6105(g): "The Secretary shall prescribe such regulations
as are necessary to carry out the provisions of this
section, including -- (1) regulations providing methods for
allocation of items other than the methods under
subsection (d)(3); and (2) regulations providing the
opportunity for an individual to have notice of, and an
opportunity to participate in, any administrative
proceeding with respect to an election made under
subsection (b) or (c) by the other individual filing the
joint return."
o section 3509 amending IRC section 6110(i)(2) [re chief counsel
advice]: "The Secretary may by regulation provide that
this section shall apply to any advice or instruction
prepared and issued by the Office of Chief Counsel which
is not described in paragraph (1)."
o section 3703 adding note re IRC section 6311 [re payment of
taxes]: "The Secretary . . . shall establish such rules,
regulations, and procedures as are necessary to allow
payment of taxes by check or money order made payable to
the United States Treasury."
o section 3711 adding IRC section 6402(e)(6) and (7) [re offsets
of federal overpayments against state income tax
underpayments]: "The Secretary shall issue regulations
prescribing the time and manner in which States must
submit notices of past-due, legally enforceable State
income tax obligations and the necessary information that
must be contained in or accompany such notices. The
regulations shall specify the types of State income taxes
and the minimum amount of debt to which the reduction
procedure established by paragraph (1) may be applied. The
regulations may require States to pay a fee to reimburse
the Secretary for the cost of applying such procedure. Any
fee paid the Secretary. . . Any State receiving notice from
the Secretary that an erroneous payment has been made to
such State . . . shall pay promptly to the Secretary, in
accordance with such regulations as the Secretary may
prescribe. . ."
o section 6004 amending IRC section 6050S [re reporting
requirements for Hope and Lifetime Learning credits]: "Any
person. . . except as provided in regulations, which is
engaged in a trade or business and, in the course of which,
receives from any individual interest aggregating $600 or
more for any calendar year on one or more qualified
education loans, shall make the return described in
subsection (b) with respect to the individual at such time
as the Secretary may by regulations prescribe."
o section 6005 amending IRC section 1(h)(11) [re maximum
capital gains rate]: "The Secretary may prescribe such
regulations as are appropriate (including regulations
requiring reporting) to apply this subsection in the case
of sales and exchanges by pass-thru entities and of
interests in such entities."
o section 6010(d) adding IRC section 304(b)(6) [re
redemptions through related corporations]: "In the case of
any acquisition to which subsection (a) applies i which the
acquiring corporation or the issuing corporation is a
foreign corporation, the Secretary shall prescribe such
regulations as are appropriate in order to eliminate a
multiple inclusion of any item in income by reason of this
subpart and to provide appropriate basis adjustments. . ."
o section 6010(h) amending IRC section 4082(d)(1) [re
aviation-grade kerosene]: "Subsection (a)(2) shall not
apply to aviation-grade kerosene (as determined under
regulations prescribed by the Secretary) which the
Secretary determines is destined for use as a fuel in an
aircraft."
o section 7003 amending IRC section 475(g)(3) [re mark to
market]: "REGULATIONS. -- . . . to prevent the use by
taxpayers of subsection (c)(4) to avoid the application
of this section to a receivable that is inventory in the
hands of the taxpayer (or a person who bears a relationship
to the taxpayer described in sections 267(b) of 707(b))."
P.L. 105-277 OMNIBUS CONSOLIDATED AND EMERGENCY SUPPLEMENTAL APPROPRIATIONS A 1999 [TAX AND TRADE RELIEF EXTENSION ACT OF 1998]
o section 1004 amending IRC section 6104(d)(4)[re expanded
inspection of private foundation's annual returns]:
"Paragraph (1)(B) shall not apply to any request if, in
accordance with regulations promulgated by the Secretary,
the organization has made the requested documents widely
available, or the Secretary determines, upon application by
an organization, that such request is part of a harassment
campaign and that compliance with such request is not in
the public interest."
o section 1005 amending IRC section 954(h) [re subpart F
exemption for active financing income] There are references
to regulations in definitions of "predominantly engaged"and
"located." Paragraph 9 states, "The Secretary shall
prescribe such regulations as may be necessary or
appropriate to carry out the purposes of this subsection,
subsection (c)(1)(B)(i), subsection (c)(2)(C)(ii), and the
last sentence of subsection (e)(2).
o section 1005 adding IRC section 953(e)(6) [re definition of
home country]: "For purposes of this subsection, except as
provided in regulations -- . . . . -- The term 'home
country' means,. . ."
o section 1005 adding IRC section 953(e)(7)(E) [re income
derived from the insurance business]: "The Secretary may
prescribe rules for the allocation of contracts (and income
from contracts) among 2 or more qualifying insurance
company branches of a qualifying insurance company in order
to clearly reflect the income of such branches. . .." IRC
section 953(e)(9) [re income derived from the insurance
business]: "The Secretary shall prescribe such regulations
as may be necessary or appropriate to carry out the
purposes of this subsection and section 954(i)."
o section 1005 adding IRC section 954(c)(2)(C) [re exception
for dealers]: "Except as provided by regulations, in the
case of a regular dealer in property which is property
described in paragraph (1)(B), forward contracts, option
contracts, or similar financial instruments (including
notional principal contracts and all instruments
referenced to commodities), there shall not be taken into
account in computing foreign personal holding company
income. . ."
o section 4006 amending IRC section 6103(j)(5) [re disclosure
to the Secretary of Agriculture]: "Upon request in writing
by the Secretary of Agriculture, the Secretary shall
furnish such returns, or return information reflected
thereon, as the Secretary may prescribe by regulation to
officers and employees of the Department of Agriculture
whose official duties require access to such returns or
information for the purpose of, . . . structuring,
preparing, and conducting the census of agriculture
pursuant to the Census of Agriculture Act of 1997. . ."
o section 5301 adding IRC section 451(h) [re tax treatment of
cash option for qualified prizes]: "The Secretary shall
provide for the application of this subsection in the case
of a partnership or other passthrough entity consisting
entirely of individuals described in paragraph (1)."
1999
P.L. 106-36 MISCELLANEOUS TRADE AND TECHNICAL CORRECTIONS ACT OF 1999
o section 3001(a) amending IRC section 357(d)(3) [re
clarification of assumption of liability]: "The Secretary
shall prescribe such regulations as may be necessary to
carry out the purposes of this subsection and section
362(d). The Secretary may also prescribe regulations which
provide that the manner in which a liability is treated as
assumed under this subsection is applied, where
appropriate, elsewhere in this title."
o section 3001(b) amending IRC section 362(d) [re treatment
of gain not subject to tax]: "Except as provided in
regulations, if -- (A) gain is recognized to the transferor
as a result of an assumption of a nonrecourse liability by
a transferee which is also secured by assets not
transferred to such transferee; and (B) no person is
subject to tax under this title on such gain, then, for
purposes of determining basis under subsections (a) and
(b), the amount of gain recognized by the transferor as a
result of the assumption of the liability shall be
determined as if the liability assumed by the transferee
equaled such transferee's ratable portion of such liability
determined on the basis of the relative fair market values
(determined without regard to section 7701(g)) of all of
the assets subject to such liability."
P.L. 106-58 TREASURY, POSTAL SERVICE, ETC. APPROPRIATIONS, 2000
o section 650(f) [establishment of an interactive program on
the Internet where taxpayers can figure out how much of
their tax money is going to certain government programs]:
"The Secretary of the Treasury may prescribe such
regulations as may be necessary to carry out this section."
P.L. 106-170 TICKET TO WORK AND WORK INCENTIVES IMPROVEMENT ACT OF 1999 TITLE V -- TAX RELIEF EXTENSION ACT OF 1999
o section 521(c) [relating to advance pricing agreements]:
"The Secretary of the Treasury or the Secretary's delegate
shall prescribe such regulations as may be necessary or
appropriate to carry out the purposes of section
6103(b(2)(C), and the last sentence of section 6110(b)(1),
of the Internal Revenue Code of 1986, as added by this
section."
o section 532(a) amending IRC section 1221(b)(3) [re
clarification of tax treatment of gain or loss on
derivatives]: "The Secretary shall prescribe such
regulations as are appropriate to carry out the purposes of
paragraph (6) and (7) of subsection (a) in the case of
transactions involving related parties." [Those paragraphs
also have references to regulations.]
o section 532(b) amending IRC section1256(e)(2) [re
definition of hedging transaction]: "For purposes of this
subsection, the term 'hedging transaction' means any
hedging transaction (as defined in section 1221(b)(2)(A))
if, before the close of the day on which such transaction
was entered into (or such earlier time as the Secretary may
prescribe by regulations), the taxpayer clearly identifies
such transaction as being a hedging transaction."
o section 534 adding IRC section 1260(c), (d), (f), and (g)
[re gains from constructive ownership] to authorize the
Secretary to prescribe regulations to provide exceptions to
the general definition of "financial asset" and
"constructive ownership" and the rules about when a
taxpayer takes delivery: "The Secretary shall prescribe
such regulations as may be necessary or appropriate to
carry out the purposes of this section, including
regulations -- (1) to permit taxpayers to mark to market
constructive ownership transactions in lieu of applying
this section, and (2) to exclude certain forward contracts
which do not convey substantially all of the economic
return with respect to a financial asset."
o section 535 amending IRC section 420(c)(3)(E) [re use of
excess pension assets for retiree health coverage]: "The
Secretary shall prescribe such regulations as may be
necessary to prevent an employer who significantly reduces
retiree health coverage during the cost maintenance period
from being treated as satisfying the minimum cost
requirement of this subsection."
o section 537 amending IRC section 170(f)(10)(I) [re denial
of charitable contribution deduction for transfers
associated with split-dollar insurance arrangements]: "The
Secretary shall prescribe such regulations as may be
necessary or appropriate to carry out the purposes of this
paragraph, including regulations to prevent the avoidance
of such purposes."
o section 538 amending IRC section 732(f)(8) [re basis of
stock in another corporation distributed to a partner if
the distributed corporation is controlled by a corporate
partner]: "The Secretary shall prescribe such regulations
as may be necessary to carry out the purposes of this
subsection, including regulations to avoid double counting
and to prevent the abuse of such purposes."
o section 545 amending IRC section 857(b)(7)(F) [re 100% tax
on improperly allocated amounts by REITs]: "The Secretary
shall prescribe such regulations as may be necessary to
carry out the purposes of this paragraph."
2000
P.L. 106-230 TO REQUIRE 527 ORGANIZATIONS TO DISCLOSE THEIR POLITICAL ACTIVITIES
o section 2(b) amending IRC section 6104(d) [re disclosure of
exempt organization returns by the Internal Revenue
Service]: "Any report filed by an organization under
section 527(j) (relating to required disclosure of
expenditures and contributions) shall be made available to
the public at such times and in such places as the
Secretary may prescribe."
P.L. 106-519 FSC REPEAL AND EXTRATERRITORIAL INCOME EXCLUSION ACT OF 2000
o section 3(b) adding IRC sections 941(a)(4) [re
qualifying foreign trade income rules for marginal
costing]: "The Secretary shall prescribe regulations
setting forth rules for the allocation of expenditures in
computing foreign trade income under paragraph (1)(C) in
those cases where a taxpayer is seeking to establish or
maintain a market for qualifying foreign trade property."
o section3(b) adding IRC sections 941(a)(5) [re
qualifying trade income rules for participation in
international boycotts, etc]: "Under regulations prescribed
by the Secretary, the qualifying foreign trade income of a
taxpayer for any taxable year shall be reduced but not
below zero) by the sum of -- (A) an amount equal to such
income multiplied by the international boycott factor
determined under section 999, and (B) any illegal bribe,
kickback, or other payment (within the meaning of section
162(c)) paid by or on behalf of the taxpayer directly or
indirectly to an official, employee, or agent in fact of a
government."
o section 3(b) adding IRC section 941(c)(2)(B) [re foreign
trade income special rules for leased property]: "Except as
provided in regulations, in the case of property which --
(i) was manufactured, produced, grown, or extracted by the
taxpayer, or (ii) was acquired by the taxpayer from a
related person for a price which was not determined in
accordance with the rules of section 482, the amount of
foreign trade income which may be treated as foreign sale
and leasing income under paragraph (1)(B) or subparagraph
(A) of this paragraph with respect to any transaction
involving such property shall not exceed the amount which
would have been determined if the taxpayer had acquired
such property for the price determined in accordance with
the rules of section 482."
o section 3(b) adding IRC section 942(c)(2) [re foreign
trading company gross receipts]: "All related persons shall
be treated as one person for purposes of paragraph (1), and
the limitation under paragraph (1) shall be allocated among
such persons in a manner provided in regulations
prescribed by the Secretary."
o section3(b) adding IRC section 943(b)(1)(B) [re grouping of
transactions]: "To the extent provided in regulations, any
provision of this subpart which, but for this
subparagraph, would be applied on a transaction-by-
transaction basis may be applied by the taxpayer on the
basis of groups of transactions based on product lines or
recognized industry or trade usage. Such regulations may
permit different groupings for different purposes."
o section3(b) adding IRC section 943(c) [re source rule]:
"Under regulations, in the case of qualifying foreign trade
property manufactured, produced, grown, or extracted
within the United States, the amount of income of a
taxpayer from any sales transaction with respect to such
property which is treated as from sources without the
United States shall not exceed -- . . ."
o section 3(b) adding IRC section 943(e)(4)(A) and (e)(4)(C)
[re definitions and special rules]: "(A) This subsection
shall not apply to an applicable foreign corporation if
such corporation fails to meet the requirements (if any)
the Secretary may prescribe to ensure that the taxes
imposed by this chapter on such corporation are paid."
(C): "The Secretary may by regulation designate one or
more classes of corporations which may not make the
election under this subsection."
o section 3(b) adding IRC section 943(f)(1)(C) [re rules
relating to allocations of qualifying foreign trade income
from shared partnerships]: ". . . such partnership meets
such other requirements as the Secretary may by regulations
prescribe."
P.L. 106-554 COMMUNITY RENEWAL TAX RELIEF ACT OF 2000
o section 101(a) added IRC section 1400F(e) [re community
renewal capital gain]: "The Secretary shall prescribe such
regulations as may be appropriate to carry out the
purposes of this section, including regulations to prevent
the abuse of the purposes of this section."
o section121(a) adding a new IRC section 45D(d) [re qualified
low income community investments]: ". . . financial
counseling and other services specified in regulations
prescribed by the Secretary to businesses located in, and
residents of, low-income communities, and. . ."
o section 121(a) adding new IRC section 45D(i) [re new
markets tax credit]: "The Secretary shall prescribe such
regulations as may be appropriate to carry out this
section, including regulations -- (1) which limit the
credit for investments which are directly or indirectly
subsidized by other Federal tax benefits (including the
credit under section 42 and the exclusion from gross income
under section 103), (2) which prevent the abuse of the
purposes of this section, (3) which provide rules for
determining whether the requirement of subsection (b)(1)(B)
is treated as met, (4) which impose appropriate reporting
requirements, and (5) which apply the provisions of this
section to newly formed entities."
o section 121(f) added noncodified language: "Not later than
120 days after the date of the enactment of this Act, the
Secretary of the Treasury or the Secretary's delegate
shall issue guidance which specifies -- (1) how entities
shall apply for an allocation under section 45D(f)(2) of
the Internal Revenue Code of 1986, as added by this
section; (2) the competitive procedure through which such
allocations are made; and (3) the actions that such
Secretary or delegate shall take to ensure that such
allocations are properly made to appropriate entities."
o section 309(c) adding noncodified provision [re application
of comparable rules to partnerships and s corporations]:
"The Secretary of the Treasury or his delegate -- (1) shall
prescribe rules which provide appropriate adjustments
under subchapter K of chapter 1 of the Internal Revenue
Code of 1986 to prevent the acceleration or duplication of
losses through the assumption of (or transfer of assets
subject to) liabilities described in section 358(h)(3) of
such Code (as added by subsection (a)) in transactions
involving partnerships, and (2) may prescribe rules which
provide appropriate adjustments under subchapter S of
chapter 1 of such Code in transactions described in
paragraph (1) involving S corporations rather than
partnerships."
o section 401(a) added IRC section 1234B(b) and (e) [re gains
or losses from securities futures contracts]: "Except as
provided in the regulations under section 1092(b) or this
section, if gain or loss on the sale or exchange of a
securities futures contract to sell property is considered
as gain loss from the sale or exchange of a capital asset,
such gain or loss shall be treated as short-term capital
gain or loss . . .. The Secretary shall prescribe such
regulations as may be appropriate to provide for the
proper treatment of securities futures contracts under
this title."
o section 401(i) added IRC section 7701(m) [re designation of
contract markets]: "Any designation by the Commodity
Futures Trading Commission of a contract market which could
not have been made under the law in effect on the day
before the date of the enactment of the Commodity Futures
Modernization Act of 2000 shall apply for purposes of this
title except to the extent provided in regulations
prescribed by the Secretary."
Examples of things not listed:
non-IRC regulations, such as customs regulations, regulations under
title 31
studies and reports
inflation adjustments
form development
permitted waivers
individual determinations
Congressional Research Service y Library of Congress y Washington, D.C. 20540
Memorandum January 25, 2000
TO : Joint Committee on Taxation
Attention: Mary Schmitt
FROM : Marie Morris
Legislative Attorney
American Law Division
SUBJECT : Types of Regulatory Guidance Issued During 2000
This memorandum looks at the types of regulations issued during calendar year 2000 by the Internal Revenue Service as reported in Internal Revenue Bulletins 2000-1 (dated January 3, 2000) through 2000-52 (dated December 26, 2000). Although this represents an entire year of Internal Revenue Bulletins, some of the work collected in these bulletins actually appeared in the Federal Register or other publications in December 1999, and some of the work published in the Federal Register in December 2000 will not appear in an Internal Revenue Bulletin until January 2001. Nevertheless, we believe that a year's worth of Internal Revenue Bulletins fairly represents a year's worth of regulations from the Internal Revenue Service.
During calendar year 2000 the Internal Revenue Service published 60 Treasury Decisions [TD], containing temporary and final regulations; 45 sets of proposed regulations; 64 notices; 100 announcements; 49 revenue procedures; and 58 revenue rulings. Notices and announcements are often in the nature of press releases. When they related to regulations, we tried to capture that information in the enclosed chart. Revenue procedures generally inform taxpayers about procedures for complying with the law; e.g., the first eight revenue procedures published in 2000 dealt with how to apply for rulings and/or technical advice on certain topics, user fees for making such requests, and areas where the IRS refuses to grant advance rulings. With one exception, revenue procedures and revenue rulings are not reported on the enclosed chart.
During calendar year 2000, most of the regulations or proposed regulations published were effective as of the date they were filed or published in the Federal Register. Since the Federal Register is published earlier than the Internal Revenue Bulletin, the effective date noted on the chart is often a week or two earlier than the date of the Internal Revenue Bulletin. Most of the proposed regulations had future effective dates. A few of the effective dates were retroactive for a long period. The earliest effective date we found was June 10, 1987 in Temporary and Proposed Regulations TD 8872 relating to transfers to RICs and REITs. The underlying legislative authority was the Tax Reform Act of 1986, and subsequent amendments.
Most of the regulations and proposed regulations published during 2000 derived from legislation passed during 1996 and 1997, but some related back to 1976 and 1982. Table 1 identifies the legislation to which various abbreviations relate, and identifies the number of times that legislation was referred to as a source of the guidance. We did not go outside the Internal Revenue Bulletins. For example, if the Internal Revenue Bulletin cited only the Internal Revenue Code section as the authority for the guidance, we did not do a legislative history to determine the underlying legislation.
A few of the projects went from proposed to final during the year, but most final regulations projects appeared to be one to three years old. Some of the issues have been being addressed in various forms since the 1970's and 1980's.
Table of Sources of Regulations in 2000
Tax Reform Act of 1976 TRA 1976 11
Subchapter S Revision Act of 1982 SSRA 1982 1
Tax Equity and Fiscal Responsibility TEFRA 1982 1
Act of 1982
Technical Corrections Act of 1982 TCA 1982 1
Tax Reform Act of 1984/Deficit DRA 1984 11
Reduction Act of 1984
Retirement Equity Act of 1984 REA 1984 11
Tax Reform Act of 1986 TRA 1986 111111111
Technical and Miscellaneous Revenue TAMRA 1988 11111111
Act of 1988
Revenue Reconciliation Act of RRA 1989 11
1989/Omnibus Budget Reconciliation OBRA 1989
Act of 1989
Energy Policy Act of 1992 EPA 1992 1
Unemployment Compensation UCA 1992 111
Amendments of 1992
Omnibus Reconciliation Act of 1993 OBRA 1993 111
Small Business Jobs Protection
Act of 1996 SBJPA 1996 1111111111
Health Insurance Portability and HIPAA 1996 1
Accountability Act of 1996
Taxpayer Relief Act of 1997 TRA 1997 111111111111111111111
Internal Revenue Service
Restructuring and Reform IRS RRA 1998 111111
Act of 1998
Transportation Equity Act for
the 21st Century TEA 21 1998 1
Tax and Trade Relief Extension
Act of 1998 TTREA 1998 11
Ticket to Work and Work
Incentives Improvement TW&WIIA 1999 1
Act of 1999
Regulations Published in Internal Revenue Bulletins
2000-1 to 2000-52
(Listed by Internal Revenue Bulletin Date)
Type of Guidance Code Section/ Date of
Legislative Internal
Authority Revenue
Bulletin
Final Regs TD 8849: Separate
Share Rules Applicable to IRC section 663(c); 1-10-2000
Estates TRA 1997
Final Regs TD 8850: IRC section 6308, 1-10-2000
Information Reporting with 6308B
respect to Certain Foreign
Partnerships and Certain
Foreign Corporations
Final Regs TD 8851: Return IRC section 6046A 1-10-2000
Requirement for U.S. Persons
Acquiring or Disposing of an
Interest in a Foreign Partnership,
or Whose Proportional Interest
in a Foreign Partnership
Changes
Final Regs TD 8852: Pass-Thru IRC section 1366, 1-10-2000
of Items to Shareholders 1367, 1368;
SSRA 1982,
DRA 1984, TRA
1986, TAMRA
1988, SBJPA
1996
Proposed Regs REG-106012-98: IRC section 118(c); 1-10-2000
Definition of Contribution in SBJPA 1996
Aid of Construction
Effective Date of Proposed Regs IRC section 368 1-10-2000
section1.368-2(d)(4) Notice 2000-1
Corrections to TD 8846 IRC section 2055- 1-10-2000
Announcement 2000-3 2056
Temporary and Proposed Regs IRC section 1-18-2000
TD 8854 REG-116704: 6103(j)(5);
Authorizing Disclosure of TTREA 1998
Return Information to the Dept.
of Agriculture to Conduct the
Census of Agriculture
Final Regs TD 8856: IRC section 1441- 1-18-2000
Withholding Tax on Certain 1443, and many
U.S. Source Income Paid to others
Foreign Persons
Proposed Reg REG-101492-98: IRC section 7508, 1-18-2000
Relief for Service in Combat 7508A; TRA
Zone and for Presidentially 1997
Declared Disaster
Notice 2000-4: Exchange of IRC sections 168, 1-18-2000
MACRS Property for MACRS 1031, 1033
Property (Notice prior to regs,
request for comments)
Final Reg TD 8853: IRC section 7701(l) 1-24-2000
Recharacterizing Fast-Pay Stock
Arrangements
Final Reg TD 8855: Prepaid IRC section 4251 1-24-2000
Telephone Cards
Final Regs TD 8857: IRC section 832(b); 1-24-2000
Determination of Underwriting TRA 1986
Income
Temporary Regs TD 8858: IRC section 338, 1-24-2000
Purchase Price Allocations in 1060
Deemed and Actual Asset
Acquisitions
Proposed Regs REG-105606-99: IRC section 41(f); 1-24-2000
Credit for Increasing Research RRA 1989
Activities
Correction to Final Regs IRC section 6501 1-24-2000
Announcement 2000-6:
Adequate Disclosure of Gifts
Final Regs TD 8859: IRC section 42 1-31-2000
Compliance Monitoring Low
Income Housing Credit
Final Regs TD 8860: Treatment IRC section 988 1-31-2000
of Income and Expense from
Certain Hyperinflationary,
Nonfunctional Currency
Transactions
Final Regs TC 8861: Private IRC section 6104(d); 1-31-2000
Foundation Disclosure Rules TTREA 1998
Proposed Regs REG-103831-99: 26 CFR 1-31-2000
Allocation of Partnership Debt sections 1.752-3
and 5
Proposed Regs REG-111119-99: IRC sections 708, 1-31-2000
Partnership Mergers and 743, 752
Acquisitions
Proposed Reg REG-116567-99: IRC section 988 1-31-2000
Definition of Hyperinflationary
Currency
Final and Temporary Regs TD IRC section 367(b) 2-7-2000
8862: Foreign Corporations
Stock Transfer Rules
Temporary Regs TD 8863: IRC section 367(b) 2-7-2000
Foreign Corporations
Supplemental Stock Transfer
Rules
Final Regs TD 8866: IRC section 1092 2-7-2000
Straddles-Equity Options with
Flexible Terms
Final Regs TD 8868: IRC section 936; 2-7-2000
Termination of Puerto Rico and SBJPA 1996
Possession Tax Credit
Final Regs TD 8869: IRC section 1361; 2-7-2000
S Corporation Subsidiaries SBJPA 1996,
TRA 1997
Proposed Regs REG-208254-90: IRC section 861 2-7-2000
Source of Compensation for
Labor or Personal Services
Proposed Regs REG-105089-99: IRC sections354-356, 2-7-2000
Treatment of Nonqualified 1036; TRA 1997
Preferred Stock and Other in
Certain Exchanges and
Distributions
Proposed Regs REG-116048-99: IRC section 367(b) 2-7-2000
Stock Transfer Rules -
Supplemental Rules
Final and Temporary Regs TD IRC section 274 2-14-2000
8864: Substantiation of Business
Expenses
Final Regs TD 8865: IRC sections 167(f), 2-14-2000
Amortization of Intangible 197
Property
Final Regs TD 8867: Passive IRC section 1296 2-14-2000
Foreign Investment Companies;
Definition of Marketable Stock
Proposed Regs REG-113572-99: IRC section 132(f); 2-14-2000
Qualified Transportation Fringe EPA 1992, TRA
Benefits 1997, TEA 21
1998
Proposed Regs REG-100163-00: IRC section 197 2-14-2000
Applying Section 197 to
Partnerships
Final Regs TD 8870: General IRC section 1295; 2-22-2000
Rules for Making and TRA 1986,
Maintaining Qualified Electing TAMRA 1988,
Fund Elections OBRA 1993,
SBJPA 1996,
TRA 1997
Final and Temporary Regs TD IRC section 401(b) 2-22-2000
8871: Remedial Amendment
Period for Qualified Plans
Temporary Regs TD 8872 IRC section 337; TRA 2-22-2000
Proposed Regs REG-209135-88: 1986, TAMRA
Certain Asset Transfers to RICs 1988
and REITs
Final Regs TD 8874: Travel and IRC section 513 2-22-2000
Tour Activities of Tax-Exempt
Organizations
Proposed Regs REG-208280-86: IRC section 883(a) 2-22-2000
Exclusions from Gross Income and (c); TRA
of Foreign Corporations 1986, TAMRA
1988, OBRA
1989
Proposed Regs REG-100276-97: IRC section 860H- 2-22-2000
Financial Asset Securitization 860L; SBJPA
Investment Trusts; Real Estate 1996
Mortgage Investment Conduits
Proposed Regs REG-103882-99: IRC section 612, 2-22-2000
Depletion; Treatment of Delay 263A; TRA
1986, TAMRA
1988
Proposed Regs REG-105279-99: IRC section 6071(b), 2-22-2000
Extension of Due Date for 6651(h); IRS
Electronically Filed Information RRA 1998
Returns; Limitation of Failure to
Pay Penalty for Individuals
During Period of Installment
Agreement
Final Regs TD 8873: New IRC sections 402(f), 2-28-2000
Technologies in Retirement 411(a)(11),
Plans 3405(e); TRA
1997
Proposed and Temporary Regs IRC section 6112 3-13-2000
TD 8875 and REG-103736-00:
Requirements to Maintain List
of Investors in Potentially
Abusive Tax Shelters
Proposed and Temporary Regs IRC section 6111(d); 3-13-2000
TD 8876 and REG-110311-98: TRA 1997
Corporate Tax Shelter
Registration
Proposed and Temporary Regs IRC section 6011(a) 3-13-2000
TC 8877 and REG-103735-00:
Tax Shelter Disclosure
Statements
Correction to Final Regs IRC sections 743, 3-13-2000
Announcement 2000-13 754, 755
Proposed Regs REG-209601-92: IRC section 513; TRA 3-20-2000
Taxation of Tax-Exempt 1997
Organizations' Income from
Corporate Sponsorship
Corrections to Proposed Regs IRC section 7508A 3-20-2000
Announcement 2000-16: Relief
for Service in Combat Zone and
for Presidentially Declared
Disaster
Corrections to Final Regs IRC section 1366 3-27-2000
Announcement 2000-18:
Passthrough of Items of S
Corporation to its Shareholders
Corrections to Final Regs IRC section 367 4-3-2000
Announcement 2000-24:
Treatment of Distributions to
Foreign Persons under section
367(e)(1) and (e)(2)
Corrections to Final Regs IRC section 7520 4-3-2000
Announcement 2000-25: Use of
Actuarial Table in Valuing
Annuities, etc.
Proposed and Final Regs TD IRC section 125; 4-10-2000
8878 and REG-117162-99: Tax HIPAA 1996
Treatment of Cafeteria Plans
after 2000
Corrections to Final Regs various 4-10-2000
Announcements 2000-26, 2000-
27, 2000-28, 2000-29, 2000-30,
2000-31,2000-32, 2000-33,
2000-34
Final Regs TD 8879: Kerosene IRC sections 4041, 4-17-2000
Tax; Aviation Fuel Tax; Taxable 4052, 4081,
Fuel Measurement and 4091, 4101,
Reporting; Tax on Heavy Trucks 4482, 4483,
and Trailers; Highway Vehicle 6011, 6081,
Use Tax 6420, 6421,
6427; TRA
1997, IRS RRA
1998
Proposed Regs REG-100291-00: IRC sections 170, 4-17-2000
Lifetime Charitable Lead Trusts 2522, 2055
Proposed Regs REG-107872-99: IRC sections 755, 4-17-2000
Coordination of Sections 755 1060(d); TRA
and 1060 Relating to Allocation 1986, TAMRA
of Basis Adjustments Among 1988, OBRA
Partnership Assets 1993
Proposed Regs REG-109101-98: IRCsection411(d)(6); 4-17-2000
Special Rules Regarding REA 1984, UCA
Optional Forms of Benefit 1992
Under Qualified Retirement
Plans
Corrections to Final Regs 4-17-2000
Announcements 2000-36,
2000-37
Corrections to Proposed Regs 4-17-2000
Announcements 2000-38, 2000-
40, 2000-41, 2000-42
Correction to Proposed Regs 4-24-2000
REG-103736-00
Final Regs TD 8880: Relief IRC section 5-15-2000
from Disqualification for Plans 401(a)(31);
Accepting Rollovers UCA 1992, TRA
1997
Advance Notice of Proposed 31 U.S.C. 5-30-2000
Regs REG-111835-99: section 330;
Regulations Governing Practice Circular 230
Before the IRS
Corrections to Final Regs 5-30-2000
Announcement 2000-53
Amendments to Final Regs TD IRC sections 1441- 6-5-2000
8881: Withholding Tax on 1443, 1461-
Nonresident Aliens 1463, 6041,
6041A, 6042,
6045, 6049,
3406
Final Regs TD 8882: IRC section 356; 6-5-2000
Reorganizations; Nonqualified TRA 1997
Preferred Stock
Final Regs TD 8883: Guidance IRC section 1032 6-5-2000
Under Section 1032 Relating to
the Treatment of a Disposition
by an Acquiring Entity of the
Stock of a Corporation in a
Taxable Transaction
Proposed Regs REG-106186-98: IRC section 368 6-5-2000
Certain Corporate
Reorganizations Involving
Disregarded Entities
Proposed Regs REG-107644-98: IRC section 472 6-5-2000
Dollar-Value LIFO Regulations;
Inventory Price Index
Computation Method
Final Regs TD 8884: IRC section 1502 6-12-2000
Consolidated Returns-
Limitations on the Use of
Certain Credits
Final Regs TD 8885: Solely for IRC section 6-19-2000
Voting Stock Requirement in 368(a)(1)(C)
Certain Corporate
Reorganizations
Final Regs TD 8887: Deposits of IRC section 6302; 6-26-2000
Excise Taxes SBJPA 1996;
Airport &
Airway Trust
Fund Tax
Reinstatement
Act of 1997
Final Regs TD 8886: Use of IRC section 7520; 7-3-2000
Actuarial Table in Valuing TAMRA 1988
Annuities, Interest for Life or
Terms of Years, and Remainder
or Reversionary Interest
Final Regs TD 8888: Real Estate IRC section 6049 7-3-2000
Mortgage Investment Conduits -
Reporting Requirements and
Other Administrative Matters
Proposed Regs REG-105316-98: IRC section 6050S; 7-3-2000
Information Reporting for TRA 1997, IRS
Payments of Qualified Tuition RRA 1998
and Payments of Interest on
Qualified Education Loans -
Magnetic Media Filing
Requirement for Information
Returns
Corrections to final regulations IRC section 1032 7-10-2000
Announcement 2000-57
Final Regs TD 8889: Guidance IRC section 894 7-24-2000
Regarding Claims for Certain
Income Tax Convention
Benefits
Final Regs TD 8890: Definition IRC section 671 7-24-2000
of Grantor
Final Regs TD 8893: Retention IRC section 6695 7-31-2000
of Income Tax Return Preparers'
Signatures
Withdraw Proposed Regs IRC section 593 7-31-2000
Announcement 2000-63: Bad
Debt Reserves of Thrift
Institutions
Final Regs TD 8891: Increase in IRC sections 411, 8-7-2000
Cash-Out Limit under Sections 417; TRA 1997
411(a)(7), 411(a)(11), and
417(e)(1) for Qualified
Retirement Plans
Remove Temporary Regs TD IRC section 6012, 8-7-2000
8892, Withdraw Proposed Regs 6061, 6065
Announcement 2000-68 Telefile
Voice Signature Test
Corrections to Proposed Regs IRC section 472 8-7-2000
Announcement 2000-66: Dollar-
Value LIFO Regs; Inventory
Price Index Computation
Method; Correction
Final and Proposed Regs TD IRC section 72(p); 8-14-2000
8894: Loans from a Qualified TEFRA 1982,
Employer Plan to Plan TCA 1982, DRA
Participants or Beneficiaries 1984, TRA
1986, TAMRA
1988
Proposed Regs REG-116495-99: IRC section 72(p); 8-14-2000
Loans from a Qualified 414(u); SBJPA
Employer Plan to Plan 1996
Participants or Beneficiaries
Proposed Regs REG-108522-00: IRC section 684; TRA 8-21-2000
Recognition of Gain on Certain 1997
Transfers to Certain Foreign
Trusts and Estates
Proposed Regs REG-209038-89: IRC sections 679, 8-21-2000
Foreign Trusts that Have U.S. 958; TRA 1976,
Beneficiaries SBJPA 1996
Corrections to Final Regs IRC section 1502 8-28-2000
Announcement 2000-73:
Consolidated Returns -
Limitations on the Use of
Certain Credits; Correction
Corrections to Final Regs IRC section 402(f), 8-28-2000
Announcement 2000-74: New 411(a)(11),
Technologies in Retirement 3405(e)(10(B)
Plans - Correction
Proposed and Temporary Regs IRC sections 6011, 9-5-2000
TD 8896 REG-103735-00 REG- 6111, 6112
110311-98 REG-103736-00:
Modifications of Tax Shelter
Rules
Final Regs TD 8897: Rules for IRC section 263A 9-5-2000
Property Produced in a Farming
Business (Capitalization Rules)
Final Regs TD 8898: Continuity IRC section 368 9-18-2000
of Interest
Final Regs TD 8899: Definition IRC section 2702 9-18-2000
of a Qualified Interest in a
Grantor Retained Annuity Trust
and a Grantor Retained Unitrust
Final Regs TD 8900: Special IRC section 411; REA 9-18-2000
Rules Regarding Optional Forms 1984, UCA 1992
of Benefit Under Qualified
Retirement Plans
Final Regs TD 8901: Qualified IRC section 110 9-18-2000
Lessee Construction Allowances
for Short-Term Leases
Intent to issue regulations Notice IRC section 1502 9-18-2000
2000-53: SRLY Election
Final Regs TD 8895: Extension IRC sections6701(b), 10-2-2000
of Due Date for Electronically 6651(h); IRS
Filed Information Returns; RRA 1998
Limitation of Failure to Pay
Penalty for Individuals During
Period of Installment Agreement
Proposed Regs REG-112502-00: Subpart F; IRC 10-2-2000
Guidance Under Subpart F section954; Brown
Relating to Partnerships Group, Inc. v.
Commissioner,
77 F.3d 217
(8thCir. 1996)
Final Regs TD 8902: Capital IRC sections 1(h), 10-10-2000
Gains, Partnership, Subchapter 741, 1223, 1250;
S, and Trust Provisions TRA 1997, IRS
RRA 1998
Corrections to Final Regs IRC section 6012, 10-10-2000
Announcement 2000-81 6061, 6065
Final Regs TD 8903: Qualified IRC section 1397E; 10-16-2000
Zone Academy Bonds; TRA 1997and
Obligations of States and TW & WIIA
Political Subdivisions 1999
Final Regs TD 8904: Treatment IRC sections 351, 10-16-2000
of Nonqualified Preferred Stock 354, 355, 356
and Other Preferred Stock in
Certain Exchanges and
Distributions
Proposed Regs and Withdrawal IRC section 1502; 10-16-2000
of Proposed Regs REG-103805- Interlake Corp v.
99: Agent for Consolidate Group Commissioner,
112 T.C. 103
(1999); Union
Oil Co. v.
Commissioner,
101 T.C. 130
(1993); Southern
Pacific Co. V.
Commissioner,
84 T.C. 395
(1985)
Proposed Regs REG-114697-00: IRC section 401(a)(4) 10-23-2000
Nondiscrimination Requirement
for Certain Defined Contribution
Retirement Plans
Notice 2000-56 Rabbi Trusts IRC section 1032 10-23-2000
Corrections to Proposed Regs IRC section 684 10-23-2000
Announcement 2000-85: Gain
on Transfers to Certain Foreign
Trusts
Final Regs TD 8905: Preparer IRC section 6695(g); 10-30-2000
Due Diligence Requirements for TRA 1997
Determining Earned Income
Credit Eligibility
Proposed Regs REG-246249-96: IRC sections 6041 10-30-2000
Information Reporting and 6045
Requirements for Certain
Payments Made on Behalf of
Another Person, Payments to
Joint Payees, and Payments of
Gross Proceeds from Sales
Involving Investment Advisers
Proposed Regs REG-105235-99: IRC sections 121, 10-30-2000
Exclusion of Gain from Sale or 1398; TRA
Exchange of Principal Residence 1997 and IRS
RRA 1998
Proposed Regs REG-108553-00: IRC sections 401(a), 10-30-2000
Classification of Certain Pension 7701; SBJPA
and Employee Benefit Trusts, 1996 and TRA
and Other Trusts 1997
Rev. Rul 2000-49: Reporting IRC section 527; P.L. 10-30-2000
Requirements for Section 527 106-230
Organizations (7-1-2000)
Correction to Removal of Final IRC section 263A 10-30-2000
Regs Announcement 2000-88:
Rules for Property Produced in
a Farming Business
Proposed Regs REG-106511-00 IRC sections 6075, 11-6-2000
Estate Tax Return; Form 706, 6081
Extension to File
Final Regs TD 8906: Allocation IRC section 752 11-13-2000
of Partnership Debt
Correction to Proposed Regs IRC section 125 11-13-2000
Announcement 2000-92
Proposed Regs REG-116050-99: IRC section 367(b) 11-27-2000
Stock Transfer Rules; Carryover
of Earnings and Taxes
Corrections to Proposed Regs IRC section 679 11-27-2000
Announcement 2000-96:
Foreign Trusts that Have U.S.
Beneficiaries
Final Regs TD 8907: IRC section 197; 12-4-2000
Application of the Anti- OBRA 1993
Churning Rules for
Amortization of Intangibles in
Partnerships
Final Regs TD 8908: Disclosure IRC section 6103 12-18-2000
of Return Information to the
Bureau of the Census
Proposed Regs REG-107279-00: IRC section 152 12-18-2000
Rules Relating to General
Definition of Dependent
Corrections to Regs IRC section 2702 12-18-2000
Announcement 2000-100
Final, Temporary. and Proposed IRC section 6302 12-26-2000
Regs TD 8909, REG-114423-
00: Federal Employment Tax
Deposits - De Minimis Rule
[table continued]
Type of Guidance Effective Previous/
Date of Subsequent
Guidance Guidance
Final Regs TD 8849: Separate
Share Rules Applicable to 12-28-99 Proposed Regs
Estates (1-6-99); Ann.
2000-28
(3-23-2000)
Final Regs TD 8850: 12-29-99/ Proposed Regs
Information Reporting with 1-1-2000 (9-9-98); Final
respect to Certain Foreign Regs (2-5-99)
Partnerships and Certain
Foreign Corporations
Final Regs TD 8851: Return 12-29-99 Proposed Regs
Requirement for U.S. Persons (9-9-98)
Acquiring or Disposing of an
Interest in a Foreign Partnership,
or Whose Proportional Interest
in a Foreign Partnership
Changes
Final Regs TD 8852: Pass-Thru 8-18-1998 Proposed Regs
of Items to Shareholders (8-18-98); Ann.
2000-18
(3-27-2000);
Ann. 2000-32
(3-28-2000)
Proposed Regs REG-106012-98: when final
Definition of Contribution in
Aid of Construction
Effective Date of Proposed Regs actions Proposed Regs
section1.368-2(d)(4) Notice 2000-1 after (6-14-99)
12-31-99
Corrections to TD 8846 12-3-99 Final Regs
Announcement 2000-3 (12-3-99)
Temporary and Proposed Regs 1-4-2000
TD 8854 REG-116704: through
Authorizing Disclosure of 1-3-2003
Return Information to the Dept.
of Agriculture to Conduct the
Census of Agriculture
Final Regs TD 8856: 1-1-2001 Final Regs
Withholding Tax on Certain (10-14-97,
U.S. Source Income Paid to 12-31-1998); Ann.
Foreign Persons 2000-31 (4-10-2000);
TD 8881 (6-5-2000)
Proposed Reg REG-101492-98: 12-30-99 Ann. 2000-16
Relief for Service in Combat (3-20-2000)
Zone and for Presidentially
Declared Disaster
Notice 2000-4: Exchange of 1-3-2000
MACRS Property for MACRS
Property (Notice prior to regs,
request for comments)
Final Reg TD 8853: 2-27-97 Notice 97-21
Recharacterizing Fast-Pay Stock (2-27-97);
Arrangements Proposed Regs
(1-6-99); Ann.
2000-33 (4-10-200
Final Reg TD 8855: Prepaid 1-7-2000 Proposed Regs
Telephone Cards (12-27-98)
Final Regs TD 8857: 1-5-2000 Proposed Regs
Determination of Underwriting (1-2-97)
Income
Temporary Regs TD 8858: 1-6-2000 Proposed Regs
Purchase Price Allocations in (8-10-99)
Deemed and Actual Asset
Acquisitions
Proposed Regs REG-105606-99: 12-30-99 and Final Regs
Credit for Increasing Research retroactive (5-17-89)
Activities to prevent
abuse
Correction to Final Regs 12-3-99 TD 8845
Announcement 2000-6: (12-3-99)
Adequate Disclosure of Gifts
Final Regs TD 8859: 1-1-2001(earlier Proposed Regs
Compliance Monitoring Low dates for some (1-8-99); Ann.
Income Housing Credit sections) 2000-27
(4-10-2000)
Final Regs TD 8860: Treatment 2-14-2000 Proposed Regs
of Income and Expense from (3-17-92)
Certain Hyperinflationary,
Nonfunctional Currency
Transactions
Final Regs TC 8861: Private 3-13-2000 Proposed Regs
Foundation Disclosure Rules (8-10-99)
Proposed Regs REG-103831-99: date of Final Regs TD
Allocation of Partnership Debt final regs 8906
(10-31-2000)
Proposed Regs REG-111119-99: date of
Partnership Mergers and final regs
Acquisitions
Proposed Reg REG-116567-99: date of
Definition of Hyperinflationary final regs
Currency
Final and Temporary Regs TD 2-23-2000 Proposed and
8862: Foreign Corporations Temporary
Stock Transfer Rules Regs (12-27-77);
Proposed Regs
(8-26-91);
Final Regs (6-98)
Temporary Regs TD 8863: 2-23-2000 same as above
Foreign Corporations
Supplemental Stock Transfer
Rules
Final Regs TD 8866: 1-25-2000 Proposed Regs
Straddles-Equity Options with (6-25-98)
Flexible Terms
Final Regs TD 8868: 1-25-2000 Temporary and
Termination of Puerto Rico and Proposed Regs
Possession Tax Credit (8-19-98)
Final Regs TD 8869: 1-20-2000 Proposed Regs
S Corporation Subsidiaries (4-22-98);
Notice 97-4
(1-13-97); Ann.
2000-36
(4-17-2000)
Proposed Regs REG-208254-90: when final Final Regs (1967
Source of Compensation for and 1975)
Labor or Personal Services
Proposed Regs REG-105089-99: when final Temp Reg TD
Treatment of Nonqualified 8753 (1-6-98);
Preferred Stock and Other in Final Regs TD
Certain Exchanges and 8904
Distributions (10-16-2000)
Proposed Regs REG-116048-99: 1-24-2000 TD 8863
Stock Transfer Rules - (2-7-2000)
Supplemental Rules
Final and Temporary Regs TD 1-26-2000 Temporary and
8864: Substantiation of Business Proposed Regs
Expenses (11-6-85;
3-25-97;
10-1-98) Ann.
2000-26
(4-10-2000)
Final Regs TD 8865: 1-25-2000 Proposed Regs
Amortization of Intangible (1-6-97); Ann.
Property 2000-37
(4-17-2000)
Final Regs TD 8867: Passive 1-25-2000 Proposed Regs
Foreign Investment Companies; (2-2-99); Ann.
Definition of Marketable Stock 2000-30
(4-10-2000)
Proposed Regs REG-113572-99: Notice 94-3;
Qualified Transportation Fringe Ann. 2000-41
Benefits (4-17-2000)
Proposed Regs REG-100163-00: when final Proposed Regs
Applying Section 197 to (1-16-97);
Partnerships Final Regs TD
8907
(11-20-2000)
Final Regs TD 8870: General 2-7-2000 Temporary
Rules for Making and Regs (1-2-98);
Maintaining Qualified Electing Ann. 2000-34
Fund Elections (4-10-2000)
Final and Temporary Regs TD 2-4-2000 Temporary and
8871: Remedial Amendment Proposed Regs
Period for Qualified Plans (8-1-97)
Temporary Regs TD 8872 6-10-87 Notice 88-19
Proposed Regs REG-209135-88: (2-4-88)
Certain Asset Transfers to RICs
and REITs
Final Regs TD 8874: Travel and 2-7-2000 Proposed Regs
Tour Activities of Tax-Exempt (4-23-98); Ann.
Organizations 2000-29
(4-10-2000)
Proposed Regs REG-208280-86: 30 days
Exclusions from Gross Income after final
of Foreign Corporations rule
Proposed Regs REG-100276-97: when final Ann. 2000-38,
Financial Asset Securitization (4-17-2000)
Investment Trusts; Real Estate
Mortgage Investment Conduits
Proposed Regs REG-103882-99:
Depletion; Treatment of Delay
Proposed Regs REG-105279-99: returns Final Regs TD
Extension of Due Date for required to 8895
Electronically Filed Information be filed (10-2-2000)
Returns; Limitation of Failure to after
Pay Penalty for Individuals 12-31-99
During Period of Installment
Agreement
Final Regs TD 8873: New 1-1-2001 Proposed Regs
Technologies in Retirement (12-18-98);
Plans Notice 99-1,
Ann. 99-6;
Ann. 2000-74
(8-28-2000)
Proposed and Temporary Regs 2-28-2000 Ann. 2000-44
TD 8875 and REG-103736-00: (4-24-2000)
Requirements to Maintain List
of Investors in Potentially
Abusive Tax Shelters
Proposed and Temporary Regs 2-28-2000
TD 8876 and REG-110311-98:
Corporate Tax Shelter
Registration
Proposed and Temporary Regs returns Proposed and
TC 8877 and REG-103735-00: filed after Temporary
Tax Shelter Disclosure 2-28-2000 Regs TD 8896
Statements (9-5-2000)
Correction to Final Regs 12-15-99 Final Regs TD
Announcement 2000-13 8847 (12-15-99)
Proposed Regs REG-209601-92: when final Proposed Regs
Taxation of Tax-Exempt (1-22-93)
Organizations' Income from (withdrawn);
Corporate Sponsorship Ann. 2000-40
(4-17-2000)
Corrections to Proposed Regs Disasters Proposed Regs
Announcement 2000-16: Relief declared (1-18-2000)
for Service in Combat Zone and after 12-30-99
for Presidentially Declared
Disaster
Corrections to Final Regs 12-22-99 Final Regs TD
Announcement 2000-18: 8852 (12-22-99)
Passthrough of Items of S
Corporation to its Shareholders
Corrections to Final Regs 8-9-99 Final Regs TD
Announcement 2000-24: 8834(8-9-99)
Treatment of Distributions to
Foreign Persons under section
367(e)(1) and (e)(2)
Corrections to Final Regs 5-1-99 Final Regs TD
Announcement 2000-25: Use of 8819 (4-30-99)
Actuarial Table in Valuing
Annuities, etc.
Proposed and Final Regs TD 3-23-2000 Proposed Regs
8878 and REG-117162-99: Tax Plan years (5-7-84; 3-7-89);
Treatment of Cafeteria Plans beginning Temporary and
after 2000 Proposed Regs
(11-7-97); Ann.
2000-92 (11-13-2000)
Corrections to Final Regs Final Regs TD 8864
Announcements 2000-26, 2000- (2-14-2000); TD
27, 2000-28, 2000-29, 2000-30, 8859 (1-31-2000); TD
2000-31,2000-32, 2000-33, 8849 (1-10-2000); TD
2000-34 8874 (2-22-2000); TD
8867 (2-14-2000); TD
8856 (1-18-2000);
Ann. 2000-18
(3-27-2000); TD
8853 (1-24-2000); TD
8870 (2-22-2000)
Final Regs TD 8879: Kerosene 3-31-2000 Temporary and
Tax; Aviation Fuel Tax; Taxable Proposed Regs
Fuel Measurement and TD 8774 (7-1-98);
Reporting; Tax on Heavy Trucks Proposed Regs
and Trailers; Highway Vehicle (3-14-96);
Use Tax Ann. 2000-53
(5-30-2000)
Proposed Regs REG-100291-00: transfers on
Lifetime Charitable Lead Trusts or after
4-4-2000
Proposed Regs REG-107872-99: when final Temporary and
Coordination of Sections 755 Proposed Regs
and 1060 Relating to Allocation TD 8215 (7-88)
of Basis Adjustments Among
Partnership Assets
Proposed Regs REG-109101-98: when final Final Regs
Special Rules Regarding (7-8-88); Notice
Optional Forms of Benefit 98-29; Final
Under Qualified Retirement Regs, TD 8900
Plans (9-18-2000)
Corrections to Final Regs Final Regs TD
Announcements 2000-36, 8869 (2-7-2000);
2000-37 TD 8865
(2-14-2000)
Corrections to Proposed Regs Proposed Regs
Announcements 2000-38, 2000- REG-100276-97
40, 2000-41, 2000-42 (2-22-2000);
REG-209601-92
(3-20-2000);
REG-113572-99
(2-14-2000);
REG-209753-95
(3-14-96)
Correction to Proposed Regs Proposed Regs
REG-103736-00 REG-103736-00
(3-13-2000)
Final Regs TD 8880: Relief 4-21-2000 Final Regs TD
from Disqualification for Plans 8619 9-22-95;
Accepting Rollovers Proposed Regs
REG-245562-96
(9-19-96);
Amendment to
Proposed Regs
(12-17-98)
Advance Notice of Proposed Many, e.g., Notice
Regs REG-111835-99: 84-4 (2-23-84);
Regulations Governing Practice Notice 85-18
Before the IRS (10-17-85); Regs TD
8545 (6-20-94);
Notice (6-15-99)
Corrections to Final Regs Final Regs TD
Announcement 2000-53 8879 (4-17-2000)
Amendments to Final Regs TD 1-1-2001 Final Regs TD
8881: Withholding Tax on 8734 (1997);
Nonresident Aliens Final Regs TD
8804 (1999);
TD 8856
(1-18-2000)
Final Regs TD 8882: 5-16-2000 Temporary and
Reorganizations; Nonqualified Proposed Regs
Preferred Stock TD 8753 (1-6-98)
Final Regs TD 8883: Guidance 5-16-2000 Rev. Rul 80-76;
Under Section 1032 Relating to Proposed Regs
the Treatment of a Disposition (9-23-98); Ann.
by an Acquiring Entity of the 2000-57 (7-10-2000);
Stock of a Corporation in a Notice 2000-56
Taxable Transaction (10-23-2000)
Proposed Regs REG-106186-98: when final
Certain Corporate
Reorganizations Involving
Disregarded Entities
Proposed Regs REG-107644-98: Regulations TD
Dollar-Value LIFO Regulations; 7814 (1982);
Inventory Price Index Rev. Proc. 84-57;
Computation Method Rev. Proc 98-49;
Ann. 2000-66
(8-7-2000)
Final Regs TD 8884: 5-25-2000; Temporary and
Consolidated Returns- parts apply Proposed Regs
Limitations on the Use of to returns TD 8751 (1-12-98);
Certain Credits after 3-13- Temporary
98 Regs TD 8766
(1998); Final
Regs TD 8833
(8-11-99); TD
8823 (7-2-99);
Ann. 2000-73
(8-28-2000)
Final Regs TD 8885: Solely for 12-31-1999 Proposed Regs
Voting Stock Requirement in (6-14-99);
Certain Corporate Notice 2000-1
Reorganizations
Final Regs TD 8887: Deposits of 6-8-2000 Temporary and
Excise Taxes Proposed Regs
TD 8740
(12-29-97)
Final Regs TD 8886: Use of 6-12-2000 Temporary and
Actuarial Table in Valuing Proposed Regs
Annuities, Interest for Life or TD 8819
Terms of Years, and Remainder (4-30-99)
or Reversionary Interest
Final Regs TD 8888: Real Estate 6-16-2000 Proposed Regs
Mortgage Investment Conduits - REG-100905-97
Reporting Requirements and (May 19, 1999)
Other Administrative Matters
Proposed Regs REG-105316-98: returns Notices 97-73,
Information Reporting for filed after 98-46, 98-59,
Payments of Qualified Tuition 12-31-2001 99-37, 98-7,
and Payments of Interest on 98-54
Qualified Education Loans -
Magnetic Media Filing
Requirement for Information
Returns
Corrections to final regulations 5-16-2000 TD8883 (5-16-2000)
Announcement 2000-57
Final Regs TD 8889: Guidance 6-30-2000 Temporary
Regarding Claims for Certain Regs TD 8722
Income Tax Convention (6-30-97)
Benefits
Final Regs TD 8890: Definition 7-5-2000 Proposed Regs
of Grantor (6-5-97);
Proposed and
Temporary
Regs
(8-10-99)
Final Regs TD 8893: Retention 7-18-2000 Final and
of Income Tax Return Preparers' Temporary
Signatures Regs TD 8803
(12-31-98)
Withdraw Proposed Regs 7-12-2000 Proposed Regs
Announcement 2000-63: Bad (1-13-92)
Debt Reserves of Thrift
Institutions
Final Regs TD 8891: Increase in 10-17-2000 Proposed,
Cash-Out Limit under Sections Temporary and
411(a)(7), 411(a)(11), and Final Regs TD
417(e)(1) for Qualified 8794 (12-21-98)
Retirement Plans
Remove Temporary Regs TD 7-18-2000 Temporary Regs
8892, Withdraw Proposed Regs (12-27-93);
Announcement 2000-68 Telefile Proposed Regs
Voice Signature Test (12-27-93); Ann.
2000-81 (10-
(10-10-2000)
Corrections to Proposed Regs Proposed Regs
Announcement 2000-66: Dollar- REG-107644-98
Value LIFO Regs; Inventory (5-19-2000)
Price Index Computation
Method; Correction
Final and Proposed Regs TD 7-31-2000 Proposed Regs
8894: Loans from a Qualified (12-21-95; 1-2-98)
Employer Plan to Plan
Participants or Beneficiaries
Proposed Regs REG-116495-99: Jan. 1 of Proposed Regs
Loans from a Qualified year after (12-21-95; 1-2-98);
Employer Plan to Plan final regs Final Regs TD 8894
Participants or Beneficiaries (7-31-2000)
Proposed Regs REG-108522-00: 8-7-2000 Ann. 2000-85
Recognition of Gain on Certain (10-23-2000)
Transfers to Certain Foreign [correction]
Trusts and Estates
Proposed Regs REG-209038-89: 8-7-2000 Ann. 2000-96
Foreign Trusts that Have U.S. (11-27-2000)
Beneficiaries
Corrections to Final Regs 5-25-2000 TD 8884
Announcement 2000-73: (5-25-2000)
Consolidated Returns -
Limitations on the Use of
Certain Credits; Correction
Corrections to Final Regs 2-8-2000 TD 8873
Announcement 2000-74: New (2-8-2000)
Technologies in Retirement
Plans - Correction
Proposed and Temporary Regs 8-11-2000 Temporary and
TD 8896 REG-103735-00 REG- Proposed Regs
110311-98 REG-103736-00: TD 8877
Modifications of Tax Shelter (2-28-2000)
Rules
Final Regs TD 8897: Rules for 8-21-2000 Proposed and
Property Produced in a Farming Temporary Regs TD
Business (Capitalization Rules) 8131 (3-30-87;
8-7-87; 8-22-97);
Notice 88-24,
Notice 88-86;
Ann. 2000-88
(10-30-2000)
Final Regs TD 8898: Continuity 8-30-2000 Final, Temporary
of Interest and Proposed Regs
TD 8760 and
8761 (1-28-98)
Final Regs TD 8899: Definition 9-5-2000 Proposed Regs
of a Qualified Interest in a (6-22-99); Ann.
Grantor Retained Annuity Trust 2000-100
and a Grantor Retained Unitrust (11-28-2000)
Final Regs TD 8900: Special 9-6-2000 Final Regs (7-8-88);
Rules Regarding Optional Forms Notice 98-29;
of Benefit Under Qualified Proposed Regs
Retirement Plans REG-109101-98
(3-29-2000);
Ann. 2000-71
Final Regs TD 8901: Qualified 10-5-2000/ Proposed Regs
Lessee Construction Allowances can elect (9-20-99)
for Short-Term Leases retroactive
application
to 8-5-97
Intent to issue regulations Notice immediate Final Regs
2000-53: SRLY Election (6-25-99)
Final Regs TD 8895: Extension 8-18-2000/ Proposed Regs
of Due Date for Electronically returns REG-105279-99
Filed Information Returns; filed after (1-27-2000)
Limitation of Failure to Pay 12-31-99
Penalty for Individuals During
Period of Installment Agreement
Proposed Regs REG-112502-00: when final Proposed and
Guidance Under Subpart F Temporary Regs TD
Relating to Partnerships 8767 (3-26-98);
Notice 98-35
(7-6-98); Proposed
and Temporary
Regs TD 8827
(7-13-99)
Final Regs TD 8902: Capital 9-21-2000 Proposed Regs
Gains, Partnership, Subchapter (9-9-99)
S, and Trust Provisions
Corrections to Final Regs 7-18-2000 TD 8892 (7-18-2000)
Announcement 2000-81
Final Regs TD 8903: Qualified 9-26-2000 Temporary
Zone Academy Bonds; Regs (1-7-98,
Obligations of States and 7-1-99)
Political Subdivisions
Final Regs TD 8904: Treatment 10-2-2000 Proposed Regs
of Nonqualified Preferred Stock REG-105089-99
and Other Preferred Stock in (1-26-2000)
Certain Exchanges and
Distributions
Proposed Regs and Withdrawal when final Proposed Regs
of Proposed Regs REG-103805- (7-31-84);
99: Agent for Consolidate Group Final, Temporary
and Proposed Regs
(9-8-88)
Proposed Regs REG-114697-00: 1-1-2002 26 CFR
Nondiscrimination Requirement section
for Certain Defined Contribution 1.401(a)(4)-8
Retirement Plans and -9
Notice 2000-56 Rabbi Trusts 6-15-2000/ Rev. Proc. 92-64;
5-16-2001 TD 8883
(5-16-2000)
Corrections to Proposed Regs REG-108522
Announcement 2000-85: Gain (8-7-2000)
on Transfers to Certain Foreign
Trusts
Final Regs TD 8905: Preparer 10-17-2000 Notice 97-65;
Due Diligence Requirements for Temporary and
Determining Earned Income Proposed Regs
Credit Eligibility TD 8798
(12-21-98)
Proposed Regs REG-246249-96: first of Proposed Regs
Information Reporting calendar (5-29-84) (many
Requirements for Certain year after Rev. Rules)
Payments Made on Behalf of final regs
Another Person, Payments to
Joint Payees, and Payments of
Gross Proceeds from Sales
Involving Investment Advisers
Proposed Regs REG-105235-99: when final
Exclusion of Gain from Sale or
Exchange of Principal Residence
Proposed Regs REG-108553-00: after 8-20- Final Regs
Classification of Certain Pension 96/ when (2-2-99)
and Employee Benefit Trusts, final
and Other Trusts 1997
Rev. Rul 2000-49: Reporting
Requirements for Section 527
Organizations
Correction to Removal of Final 8-21-2000 TD 8897 (9-5-2000)
Regs Announcement 2000-88:
Rules for Property Produced in
a Farming Business
Proposed Regs REG-106511-00 when final Final Regs 26 CFR
Estate Tax Return; Form 706, section 20.6075-1
Extension to File 20.6081-1
Final Regs TD 8906: Allocation 10-31-2000 Proposed Regs
of Partnership Debt REG-1038311-99
(1-13-2000)
Correction to Proposed Regs Proposed Regs
Announcement 2000-92 REG-117162-99
(4-10-2000)
Proposed Regs REG-116050-99: 30 days Proposed and
Stock Transfer Rules; Carryover after final Temporary Regs
of Earnings and Taxes regs (12-27-77); Proposed
Regs (8-26-91);
Final Regs (6-98,
1-2000)
Corrections to Proposed Regs REG-209038-89
Announcement 2000-96: (8-7-2000)
Foreign Trusts that Have U.S.
Beneficiaries
Final Regs TD 8907: 11-20-2000 Proposed Regs
Application of the Anti- with (1-16-97) and
Churning Rules for retroactive REG-100163-00
Amortization of Intangibles in elections to (1-25-2000)
Partnerships 8-10-93 or
7-25-91
Final Regs TD 8908: Disclosure 11-30-2000 Temporary and
of Return Information to the Proposed Regs
Bureau of the Census TD 8811 (1-25-99)
Proposed Regs REG-107279-00: taxable Final Regs TD 8839
Rules Relating to General years after (10-12-99)
Definition of Dependent 2000
Corrections to Regs Final Regs TD 8899
Announcement 2000-100 (9-5-2000)
Final, Temporary. and Proposed 12-6-2000 Temporary Regs TD
Regs TD 8909, REG-114423- 8771 (6-18-98);
00: Federal Employment Tax Final Regs TD
Deposits - De Minimis Rule 8822 (6-17-99)
Explicit references to State law in the Internal Revenue Code:
[387] In searching the Internal Revenue Code, we have located 116 sections which contain one or more references to State law. Many of these references are definitional, for instance bank means an institution chartered under State law, which might require some examination of State law if there were a question involving the definition, but in most instances would not tend to add to the complexity of the tax law. Some of the references are for purposes of even or uniform treatment. For instance, most of the references to community property laws are for the purpose of applying the tax provision in the same manner in community property States and common law States. Often, any need for examination of the State law would be concerning an issue which is secondary to the main concern of the particular section. Other times the reference to State law would require examination of that law by the IRS as opposed to the taxpayer. In either of these two situations, the complexity of the tax laws for the taxpayer is not greatly affected. Many of the references are to Federal or State law or a specific Federal law and any similar State law. With this type of reference, examination of State law would only be necessary when it is the basis for the taxpayer's action as opposed to the Federal statute. Finally, it should be noted that many, if not most, usages of State law in the Internal Revenue Code are not explicit and therefore not covered by the summary. For instance, most property, trust, and corporate law is State law. Therefore, reference in the Code to a trust or a corporation or a property interest of some type could require examination of State law and affect the complexity of the tax law even more than the explicit references described below.
Citations of references to State law in the Internal Revenue Code:
section21(b)(2)(C)(i), section23(d)((1)(B), section32(c)(2)(B)(i), section42(h)(6)(B)(vi) & (E), section45A(d)(3)(A)(iii), section51A(c)(1)(C)(i), section66(d)(3), section72(t)(2)(D)(i)(I) & (iii), section85(b), section101(f)(3)(A) & (G)(i), 104(a)(1) & (c), section105(e)(2), section108(f)(2)(C)(iii), section119(d)(4)(A)(i), section130(d), section144(a)(4)(C)(ii) & (c)(2)(A)(i), section146(e)(1) & (3), section147(f)(2)(E)(i)(II), section149(e)(2)(F), section150(d)(2)(B), section162(c)(2) & (n), section165(j)(3)(B) & (1)(3)(A) & (C) & (D) & (5)(B)(ii); section170(f)(10)(G), section172(f)(B)(ii), section192(e), section219(f)(2), section220(b)(4)(C) & (c)(2)(B)(ii) & (d)(2)(B)(ii)(III), section273), section280A(c)(4)(B), section280E, section303(b)(2)(B), section401(a)(33)(A), section402(e)(4)(D)(iii), section403(b)(2)(D)(ii), section408(g) & (m)(3)(A)(iv) & (n), section412(c)(4), section414(d) & (p), section415(b)(2)(F) & (H) & (10) & (11) & (m) & (n), section416(e), section448(d)(4)(A), section457(b) & (e)(1) & (7), section460(c)(2), section468(d)(2)(A)(ii) & (B), section501(c)(16) & (21)(D)(i) & (27) & (n)(3), section507(g)(2), section513(d)(2)(B), section514(c)(2)(C), section521(b)(3), section530(f), section581, section584(a)(1)(B)(i), section591, section594(a), section816(b)(3)(A), section817(d)(1), section817A(d)(1), section832(b)(7)(E) & (e)(1), section833(c)(3)(B) & (4)(B). section851(f), section864(e)(5)(C)(iii) & (D)(ii), section871(i)3)(B), section879(c)(2), section911(b)(2)(C), section932(d), section992(a)(1), section 1014(b)(6), section 1055(c)(2), section 1250(a)(1)(B) & (2)(B), section 1396(d)(3)(A)(ii), section 1402(a)(5), section2032A(e)(10), section2053((a) & (d), section2057(i)(3)(I), section2652(d)(3), section2701(a)(2), section2704(b)(3)(B), section3121(b)(13), section3123, section3302, section3303, section3304, 3305, section3306, 3307, section3309, section3402(q)(3)(B), section3405(e)(6), section4401(a)(1), section4402(1) & (2), section4422, section4481(b), section4483(d)(5)(B)(i)(II) & (6) & (e)(2), section4906, section4980(d)(6), section5145, section5551(b)(2), section6015(a), section6049(b)(4)(H), section6103, section6104(c), section6111(c)(1)(B)(i), section6166(b)(2)(B), section6311(d)(3), section6323(f), section6334(a)(4) & (7), section6338(b), section6408, section6421(e)(2)(A)(i), section7507(a), section7604(b)(2)(A), section7622(b), section7701(a)(19)(C)(iii), section9002(11)(C), section9032(2) & (9)(B), section9811(e), section9832(b)(2) & (3).
Descriptions:
[388] Sec. 21 allows a tax credit for household and dependent care services necessary for gainful employment. For payments to a day care center to qualify for the credit the center must comply with all applicable state and local laws and regulations (section21(b)(2)(C)(i)). This rule would require some examination of State law.
[389] Sec. 23 allows a tax credit for certain adoption expenses. Qualified adoption expenses must not be incurred in violation of State law (section 23(d)(1)(B)). This rule would require some examination of State law and could result in forum shopping.
[390] Sec. 32 provides for an earned income tax credit. Earned income is to be computed without regard to any community property laws (section32(c)(2)(B)(i)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[391] Sec. 42 allows a low-income housing income tax credit. A low-income housing commitment must be recorded as a restrictive covenant pursuant to State law (section42(h)(6)(B)(vi)). State law may provide for more stringent requirements than provided in section 42 to qualify for exception in case of foreclosure or if no buyer is willing to maintain the low-income status of the property (section42(h)(6)(E)). These provisions would require examination of State law.
[392] Sec. 45A allows an Indian employment income tax credit. The credit is not allowed if the qualified employee is terminated prior to one year of service unless the termination comes under one the exceptions which include termination for misconduct as determined under the applicable State law (section45A(d)(3)(A)(iii)). This provision could require examination of State law if a termination had occurred in the one year period.
[393] Sec. 51A allows an income tax credit for employing certain recipients of long-term assistance. Among eligible employees are those who are members of a family which ceased to be eligible for such assistance by reason of any limitation imposed by State law on the maximum period of eligibility for such assistance (section51A(c)(1)(C)(i)). This provision could require the examination of State law.
[394] Sec. 66 specifies the tax treatment of "community income" in certain instances where it might be unfair to attribute such income to one spouse. The term community property laws includes State laws (section66(d)(3)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[395] Sec. 72 provides that certain amounts received as an annuity are to be included in gross income. There is an additional tax on early distributions from qualified retirement plans. There is an exception from this additional tax for distributions to unemployed individuals for health insurance premiums if such individuals received unemployment compensation for twelve consecutive weeks under State law (section72(t)(2)(D)(i)(I)) or if they would have received such compensation under State law but for the fact that they were self-employed (section72(t)(2)(D)(iii)). This provision could require the examination of State law.
[396] Sec. 85 provides that unemployment compensation is included in gross income. Unemployment compensation is defined to include such payments received under State law (section85(b)). This provision could require the examination of State law.
[397] Sec. 101 provides for the exclusion of certain death benefits from gross income. The term flexible premium life insurance contract does not include any portion of a contract which is treated under State law as providing annuity benefits other than as a settlement option (section101(f)(3)(A)). This provision could require the examination of State law. In computing the net single premium, the mortality basis shall be determined under the mortality tables allowed under all State laws (section101(f)(3)(G)(i)). While this provision would require examination of State law, it would not add to complexity because it uses a table recognized by all States.
[398] Sec. 104 provides for the exclusion from gross income of compensation for sickness or injuries. Amounts received under workmen's compensation acts as compensation for personal injuries or sickness qualify for this exclusion (section104(a)(1)). This provision would require the examination of State law. This exclusion does not apply to punitive damages unless a State law effective on September 13, 1995 provides that only punitive damages may be awarded in such action (104(c)). This provision would require the examination of State law.
[399] Sec. 105 provides the rules governing the exclusion or inclusion in gross income of amounts received under accident and health plans. For purposes of this section and section 104 (see above), amounts received from a sickness and disability fund for employees maintained under the law of a State shall be treated as amounts received through accident or health insurance (section105(e)(2)). This provision would require the examination of State law.
[400] Sec. 108 provides the rules governing the exclusion or inclusion in gross income of amounts received in discharge of indebtedness. One of the listed organization which may make a qualified student loan is a public benefit corporation whose employees have been deemed public employees under State law (section108(f)(2)(C)(ii)). This provision could require the examination of State law.
[401] Sec. 119 provides the rules governing the exclusion or inclusion in gross income of amounts received for meals or lodging furnished for the convenience of the employer. Certain lodging furnished by educational institutions is not included in gross income. Educational institution includes those organized under State law (section119(d)(4)(A)(i)). This provision could require the examination of State law.
[402] Sec. 130 provides the rules governing the exclusion or inclusion in gross income of amounts received as personal injury liability assignments. Under this provision, a qualified funding asset may only be issued by an insurance company licensed under State law (section130(d)). This is a definitional section which might require examination of State law.
[403] Sec. 144 governs the qualification certain small issue bonds. In determining the aggregate face amount of an issue, capital expenditures required by a change in State law are not taken into account (section144(a)(4)(C)(ii)). This provision could require the examination of State law. A qualified redevelopment bond is required to be authorized as such by State law (section144(c)(2)(A)(i)). This is a definitional section which might require examination of State law.
[404] Sec. 146 establishes the volume cap for private activity bonds. A State may provide by law a different formula for allocating the State ceiling among governmental units (section146(e)(1)). This provision would require the examination of State law. A State may not alter the allocation to a Constitutional Home Rule City unless the State Constitution so provides or the city agrees (section146(e)(3)). This provision could require the examination of State law.
[405] Sec. 147 provides other requirements applicable to certain private activity bonds. Under this provision, State law may designate "any other elected official" (as opposed to the official listed in the section) as the proper official to approve a private bond activity (section147(f)(2)(E)(i)(II)). This is a definitional section which might require examination of State law.
[406] Sec. 149 provides for registration and other requirements for tax exempt bonds. The information which an issuer must supply to the IRS includes a certification by a State official designated by State law that the bonds meet the requirements of the volume cap (section149(e)(2)(F)). This provision could require the examination of State law.
[407] Sec. 150 provides definitions and special rules concerning tax exempt bonds. A qualified scholarship funding bond must be issued by a corporation which is required by State law to devote any income to the purchase of student loan notes (section150(d)(2)(B)). This is a definitional section which might require examination of State law.
[408] Sec. 162 provides the rules for deductibility of business expenses. No deduction is allowed for a payment which constitutes under State law an illegal bribe, illegal kickback, or other illegal payment (section162(c)(2)). This provision could require the examination of State law. The section has a special rule for deductibility of certain employer health plan expenses in New York State (section162(n)). This provision could require the examination of New York State law.
[409] Sec. 165 provides the rules for deductibility of uncompensated losses. This provisions uses several State law definitions: broker dealer registered under State law (section165(j)(3)(B)); any credit union whose accounts are insured or guaranteed under State law (section165(l)(3)(C)); institution chartered and supervised under State law (section165(l)(3)(D)); insurance proceeds under any State law (section165(l)(5)(B)(ii)). The definition of bank in section581 (discussed below) is incorporated by reference (section165(l)(3)(A)). These are definitional provisions which might require examination of State law.
[410] Sec. 170 provides the rules for deductibility of charitable contributions. Under gifts of annuities, special rules are provided where there is an obligation of an organization to pay a charitable gift annuity which is required to meet certain State insurance and residency requirements (section170(f)(10)(G)). This provision could require the examination of State law.
[411] Sec. 172 provides the rules for deductibility of net operating losses. The term "specified liability loss" includes deductible amounts which are in satisfaction of liabilities under State laws requiring reclamation of land, decommissioning of a nuclear power plant, remediation of environmental contamination, or payment under any workmen's compensation act (section172(f)(B)(ii)). This provision could require the examination of State law.
[412] Sec. 192 provides the rules for deductibility of contributions to the Black Lung Benefit Trust. This provision defines black lung benefit claim to be a claim for compensation for disability or death due to pneumoconiosis under a specified Federal act or any State law providing for such compensation. (section192(e)). This provision could require the examination of State law.
[413] Sec. 219 provides the rules for deductibility of qualified retirement contributions. The maximum deduction for married individuals is figured without regard to any community property laws (section219(f)(2)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[414] Sec. 220 provides the rules for deductibility of medical savings account contributions. The limitations on this deduction are to be figured without regard to any community property laws (section220(b)(4)C)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same. A plan shall not fail to be treated as a high deductible health plan by reason of failing to have a deductible for preventive care if the absence of such deductible is required by State law (section220(c)(2)(B)(ii)). This provision could require the examination of State law. Qualified medical expense does not include any payment for insurance unless made under a health plan while receiving workmen's compensation under State law (section220(d)(2)(B)(ii)(III)). This provision could require the examination of State law.
[415] Sec. 273 provides the rule that amounts paid under the laws of a State as income to the holder of a life or terminable interest acquired by gift, bequest or inheritance shall not be reduced by shrinkage in value due to the lapse of time (section273). This provision would require the examination of State law.
[416] Sec. 280A disallows certain deductions with respect to the business use of residences. This disallowance is not effective if the business use is providing day care if the day care centers is licensed, certified or approved under State. Law. (section280A(c)(4)(B)). This rule would require some examination of State law
[417] Sec. 280E denies trade or business deductions if the activity involved is trafficking in controlled substances which are prohibited under State law (section280E). This provision would require the examination of State law.
[418] Sec. 303 provides the rules for inclusion in the gross estate of distributions in redemption of stock to pay death taxes. Certain property held by the decedent and their spouse as community property, joint tenant, tenants in the entireties, and tenants in common are used in making certain percentage ownership tests (section303(b)(2)(B)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[419] Sec. 401 provides the rule governing qualified pension, profit-sharing and stock bonus plans. There is a prohibition on benefit increases when the sponsor is in bankruptcy under 11 U.S.C. or similar State law (section401(a)(33)(A)). This provision might require the examination of State law.
[420] Sec. 402 provides the rules governing the taxability of beneficiaries of employees' trusts. In applying the rules of subsection (e) to exempt trusts, no regard is to be given to community property laws (section402(e)(4)(D)(iii)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[421] Sec. 403 governs the taxation of employee annuities. The exclusion allowance is not permitted for individuals whose adjusted gross income exceeds $17,000 per year determined without regard to community property laws (section403(b)(2)(D)(ii)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[422] Sec. 408 provides the rules governing individual retirement accounts. These rules are to be applied without regard to any community property laws (section408(g)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same. For purposes of this section, investment collectibles does not include a coin issued under the laws of any State (section408(m)(3)(A)(iv)). This provision might require the examination of State law. A trustee bank must be a bank defined in section581 (discussed below) or a corporation under the laws of a State which is subject to the supervision of the Banking Commissioner (section408(n)). These are definitional provisions which might require examination of State law.
[423] Sec. 412 provides the minimum funding standards for 401 or 403 retirement plans. For purposes of these standards, a change in benefits under the Social Security Act or in other retirement benefits created under Federal or State law results in an increase or decrease in accrued liability under a plan, such change shall be treated as an experience loss or gain (section412(c)(4)). This provision might require the examination of State law.
[424] Sec. 414 provides definitions and special rules for the retirement plan sections. A governmental plan includes a plan established and maintained by the government of any State (section414(d)). This is a definitional section which might require examination of State law. A domestic relations order must be made pursuant to a State domestic relations law which includes community property law (section414(p)). This is a definitional section which might require examination of State law.
[425] Sec. 415 provides limitations on benefits and contributions under qualified plans. There are several special rules for governmental plans as defined in section414(d) (discussed above) (section415(b)(2)(F) & (H) & (10) & (11) & (m) & (n)). These provisions might require examination of State law to see if the plan was a governmental plan under section414 but would not require additional examination.
[426] Sec. 416 provides special rules for top-heavy plans. The requirements of the provision must be met without taking into account contributions under several specified Federal laws or any State law (section416(e)). This provision might require the examination of State law.
[427] Sec. 448 provides limitations on the use of the cash method of accounting. For purposes of qualifying as a personal service corporation, community property laws are to be disregarded (section448(d)(4)(A)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[428] Sec. 457 provides the rules for deferred compensation plans of State and local governments. An Eligible plan is a plan established and maintained by a State or local government (section457(b) & (e)(1)). This is a definitional section which might require examination of State law. The amount of includable compensation under these plans shall be determined without regard to any community property law (section457(e)(7)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[429] Sec. 460 provides the accounting rules for long-term contracts. One of the allocation rules is that costs will be allocated to a contract if required by State law (section460(c)(2)). This provision would require the examination of State law.
[430] Sec. 468 provides special rules for mining and solid waste reclamation and closing costs. Qualified reclamation or closing costs include expenses submitted pursuant to any State law which imposes surface mining reclamation and permit requirements. (section468(d)(2)(A)(ii)). Solid waste disposal and closing costs include any expenses incurred for land reclamation or closing activity in connection with a waste disposal site in accordance with a permit issued pursuant to any State law similar to the Solid Waste Disposal Act (section468(d)(2)(B). These provisions would require the examination of State law.
[431] Sec. 501 describes the organization exempt from taxation. An association which is a farmers cooperative shall not be denied exemption by reason of accumulation of a reserve mandated by State law (section501(c)(16)). This provision might require the examination of State law by the IRS. The term Black Lung Acts includes any State law providing compensation for disability or death due too pneumoconiosis (section501(c)(21)(D)(i)). This provision is definitional and might require the examination of State law by the IRS. Certain workmen's compensation organizations created by State law or organized and operated under State law are tax-exempt (section501(c)(27)). This provision is definitional and might require the examination of State law by the IRS. A risk pool to qualify for tax-exempt status must be organized under State law and be exempt from State taxes (section501(n)(3)). This provision is definitional and might require the examination of State law by the IRS.
[432] Sec. 507 provides the termination rule for private foundation status. The termination taxes imposed by the provision may be abated if corrective action has been initiated pursuant to State law to insure the assets of the private foundation are preserved for charitable purposes (section507(g)(2)). This provision might require the examination of State law by the IRS.
[433] Sec. 513 generally defines unrelated trade or business activity for exempt organization. Qualified public entertainment activity means an activity conducted in accordance with State law under State license (section513(d)(2)(B)) and is not unrelated trade or business. This provision might require the examination of State law by the IRS.
[434] Sec. 514 provides the rules for the treatment of unrelated debt-financed income of exempt organizations. Where State law provides for attachment of liens for taxes or assessments they are generally treated similar to a mortgage for purposes of acquisition indebtedness (section514(c)(2)(C)). This provision might require the examination of State law.
[435] Sec. 521 grants tax-exempt status to farm cooperatives. A farmers cooperative shall not be denied exemption by reason of accumulation of a reserve mandated by State law (section521(b)(3)). This provision might require the examination of State law by the IRS.
[436] Sec. 530 provides the rules governing education IRAs. The rules of the provisions are be applied without regard to any community property laws (section530(f)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[437] Sec. 581 defines the term bank to include a bank or trust company incorporated and doing business under the laws of any State, a substantial part of the business of which consists of receiving deposits and making loans and discounts, or of exercising fiduciary powers and which is subject to supervision and examination by the State (section581). This provision might require the examination of State law.
[438] Sec. 584 provides the rules for definition and exemption of common trust funds. One qualifying fund is one formed for the collective investment of custodial accounts established under a Uniform Gift To Minors type of State law (section584(a)(1)(B)(i)).This provision might require the examination of State law by the IRS.
[439] Sec. 591 provides for the deduction of dividends paid on deposits by mutual savings banks which include savings institutions chartered under State law (section591). This provision might require the examination of State law by the IRS.
[440] Sec. 594 provides an alternative tax for mutual savings banks conducting life insurance business. Such a bank must be authorized by State law to conduct this type of business (section594(a)). This provision might require the examination of State law.
[441] Sec. 816 defines life insurance company and related terms. In the case of an assessment life insurance company or association, the term life insurance reserves includes sums actually deposited by such company with State officers pursuant to law as guaranty or reserve fund (section816(b)(3)(A)). This provision might require the examination of State law.
[442] Sec. 817 provides the rules for variable life insurance contracts. A variable contract must provide for the allocation of all or part of the amounts receive under the contract to an account which, pursuant to State law is segregated from the general assets of the company (section817(d)((1)). This provision might require the examination of State law.
[443] Sec. 817A provides special rules for modified guaranteed life insurance contracts. A modified guaranteed contract must provide for the allocation of all or part of the amounts received under the contract to an account which, pursuant to State law is segregated from the general assets of the company(section817A(d)(1)). This provision might require the examination of State law.
[444] Sec. 832 provides the definition of taxable income for insurance companies other than life insurance companies. Special rules are provided for reciprocal insurers who are required by State law to report reserves on unearned premiums net of premium acquisition expenses (section832(B)(7)(E)). A special deduction is granted to companies that write mortgage guaranty insurance of an amount representing the amount required by State law to be set aside in reserve for mortgage guaranty insurance losses resulting from adverse economic cycles (section832(e)(1)). These provisions would require the examination of State law.
[445] Sec. 833 provides for the tax treatment of Blue Cross and Blue Shield and similar organizations. Under the definition of other organizations to which this provision applies, small group is defined to mean the lesser of 15 individuals or the number of individuals required for such a group under State law (section833(c)(3)(B)). An existing Blue Cross or Blue Shield organization must be organized under and governed by State laws which are specifically and exclusively applicable to not-for-profit health insurance or health service type organizations (section833(c)(4)(B)). These provisions are definitional and might require examination of State law.
[446] Sec. 851 provides the rules governing taxation of regulated investment companies. The rules for unit investment trusts under paragraph (f) do not apply to such a trust which is a segregated asset account under the insurance laws of a State (section851(f)). This provision is definitional and might require examination of State law.
[447] Sec. 864 provides definitional and special rules for determining sources of income. The definition of affiliated group looks to see if a financial institution is required by State law to be operated separately from any non-financial institution (section864(e)(5)(C)(iii)) and if a bank holding company is a subsidiary of a financial institution defined in section581 (discussed above) (section864(e)(5)(D)(ii)). These provisions are definitional and might require examination of State law.
[448] Sec. 871 provides for an income tax on nonresident alien individuals. The tax imposed by this provision does not apply to interest and dividends from certain deposits including deposits with saving institutions chartered and supervised as savings and loan or similar associations under State law (section871(i)(3)(B)). This provision is definitional and might require examination of State law.
[449] Sec. 879 provides for treatment of community income when either or both of the spouses are nonresident aliens. Community property law includes such laws of a State (section879(c)(2)). This provision would require the examination of State law.
[450] Sec. 911 provides for the tax treatment of citizens or residents of the United States living abroad. A rule is provided to give similar treatment to residents of community property States as residents of common law states when figuring the limitation on foreign earned income (section911(b)(2)(C)). This provision would require the examination of State law.
[451] Sec. 932 provides rules for the coordination of United States and Virgin Islands income taxes. In the case of a joint return, this provision is to be applied on the basis of the residence of the spouse who has the greater adjusted gross income (determined without regard to community property laws) (section932(d)). This rule does not require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[452] Sec. 992 provides the requirements of a domestic international sales corporation (DISC). A DISC must be incorporated under the laws of any State (section992(a)(1)). This provision might require the examination of State law to determine corporate status.
[453] Sec. 1014 provides the basis rules for property acquired from a decedent. Only one half share of community property is considered to have been received from a decedent by a spouse (section1014(b)(6)). This rule does require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[454] Sec. 1055 provides special rules concerning redeemable ground rents. To be a redeemable ground rent the leaseholder must have a present or future right to terminate, and acquire the entire interest of the lessor, by payment of a determined or determinable amount, which exists by virtue of State law (section1055(c)(2)). This provision would require the examination of State law.
[455] Sec. 1250 provides the rules for determining gain from dispositions of certain depreciable realty. The applicable percentage utilized in the provision comes from certain Federal housing Acts or "similar State laws" (section1250(a)(1)(B) & (2)(B)). This provision could require the examination of State law.
[456] Sec. 1396 provides the rules governing the empowerment zone employment credit. The credit is not allowed if the qualified employee is terminated, unless the termination comes under termination for misconduct as determined under the applicable State law (section1396(d)(3)(A)(ii)). This provision could require examination of State law if a termination had occurred.
[457] Sec. 1402 sets out the definition concerning self- employment. Any income derived from a trade or business which is community property under State law shall be treated as income of the spouse which materially participated in the trade or business. Any portion of a partner's distributive share which is community property under State law shall be treated as income of the spouse who is the partner (section1402(a)(5)). This rule might require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[458] Sec. 2032A provides special valuation rules for estate tax purposes for valuing family farms and closely-held businesses. If the property in question was community property, the interest of the surviving spouse is to be taken into account in a manner to give a result consistent with this section had the property not been community property (section2032A(e)(10)). This rule might require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[459] Sec. 2053 provides for certain deductions from the gross estate for purposes of the estate tax. To the extent permitted by State law, funeral expenses, administrative expenses, claims against the estate, and unpaid mortgages are deductible (section2053(a)). State death taxes are deductible (section2053(d)). These provisions would require examination of State law.
[460] Sec. 2057 provides for a special deduction for estates which have qualified family-owned business interests. If the property in question was community property, the interest of the surviving spouse is to be taken into account in a manner to give a result consistent with this section had the property not been community property (section2057(i)(3)(I))which incorporates section2032A(e)(10) (discussed above) by reference). This rule might require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[461] Sec. 2652 provides some of the definitions for the generation-skipping transfer tax. The fact that income or corpus of the trust may be used to satisfy an obligation of support arising under State shall be disregarded in determining whether a person has an interest in a trust if such use is pursuant to a Uniform Gifts to Minors type act (section2652(d)(3)). This provision would require examination of State law.
[462] Sec. 2701 provides special valuation rules for valuation- freeze transfers. When looking at non-lapsing differences in management and limitations in liability, lapses by reason of State law shall be treated as non-lapsing differences (section2701(a)(2)). This provision would require examination of State law.
[463] Sec. 2704 provides rules for treatment of lapsed voting or liquidation rights under the valuation rules for valuation-freeze transfers. A restriction on liquidation imposed by State law is to be disregarded for purposes of the provision (section2704(b)(3)(B)). This provision would require examination of State law.
[464] Sec. 3121 provides the definitions for the employment tax. Employment does not include service provided as a student nurse in a nurses training school chartered or approved by State law (section3121(b)(13)). This provision could require examination of State law to ascertain the statue of the school.
[465] Sec. 3123 provides that when a State law requires an employer to deduct a payment from an employee, the employee shall be considered to have constructively paid to the employee (section3123). This provision could require examination of State law.
[466] Sections 3301 through 3311 make up the Federal Unemployment Tax Act. This tax is designed to work in conjunction with State unemployment acts and, therefore, contains numerous references to State laws. Section 3302 provides for credits against the Federal tax for contributions to State unemployment funds and, therefore, is replete with references to what is permitted and required by State law. Section 3303 provides conditions of additional credit allowance which contains several references to State law definitions. Section 3304 requires the approval of State unemployment compensation laws by the Secretary of labor and has many references to State law. Section 3305 provides the rules for applicability of State law to interstate commerce and certain Federal entities. These State laws must contain certain requirements to be so applicable. Section 3306 is a general definitional provision and references State law in several of its definitions. Section 3307 provides that when a State law requires an employer to deduct a payment from an employee, the employee shall be considered to have constructively paid to the employee. Section 3309 provides for State law coverage of services performed by non-profit or governmental entities. All of these provision would require examination of State law.
[467] Sec. 3402 provides the general rules for income tax collection from the source. Winnings which are subject to withholding include proceeds of more than $5,000 from a wager in a lottery conducted under the authority of State law (section3402(q)(3)(B)). This provision might require examination of State law.
[468] Sec. 3405 provides rules for withholding for pensions, annuities and certain other deferred income. Commercial annuity is defined to include an annuity, endowment, or life insurance contract issued by an insurance company licensed to do business under the laws of any State (section3405(e)(6)). This provision might require examination of State law to determine the status of the life insurance company.
[469] Sec. 4401 imposes an excise tax on wagers. Wagers authorized by State law are taxed at a lower rate than unauthorized wagers (section4401(a)(1)). This provision might require examination of State law.
[470] Sec. 4402 provides the exemptions to the excise tax on wagers. Parimutuels and lotteries authorized by State law are exempted (section4402(1) & (2)). These provisions might require examination of State law.
[471] Sec. 4422 provides that the payment of the wagers excise tax does not exempt a person from any State penalty or tax for the same activity (section4422). This provision might require examination of State law, but not for Federal tax purposes.
[472] Sec. 4481 imposes an excise tax on vehicles over 55,000 pounds. The tax is to be paid by the registered owner under State law (section4481(b)). This provision might require examination of State law.
[473] Sec. 4483 provides the exemptions to the excise tax on vehicles over 55,000 pounds. State registration and vehicle type designations are used in this provision (section4483(d)(5)(B)(i)(II) & (6) & (e)(2)). This provision might require examination of State law.
[474] Sec. 4906 provides that the payment of the excise tax on certain occupations does not exempt a person from any State penalty or tax for the same activity (section4906). This provision might require examination of State law, but not for Federal tax purposes.
[475] Sec. 4980 provides for a tax on reversion of qualified plan assets to an employer. The increase in the tax for failure to establish a replacement plan does not apply to an employer is in bankruptcy under 11 U.S.C. or similar State law (section4980(d)(6)). This provision might require the examination of State law.
[476] Sec. 5145 provides that the payment of the excise tax on certain alcohol related occupations does not exempt a person from any State penalty or tax for the same activity (section5145). This provision might require examination of State law, but not for Federal tax purposes.
[477] Sec. 5551 provides for the bonding of certain occupations involved in the production of alcohol. Such bonds are to be disapproved if the entity or individual has been convicted of a State felony prohibiting the manufacture, sale, importation, or transportation of distilled spirits, wine, beer, or other intoxicating liquor (section5551(b)(2)). This provision would require examination of State law, by the Secretary of the Treasury.
[478] Sec. 6015 provides for relief from joint and several liability on joint returns in specified circumstances. All determinations under the provision are to be made without regard to community property laws (section6015(a)). This rule might require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[479] Sec. 6049 provides for returns to be filed by certain payers of interest. A dealer in securities required to register under State law is one of the persons required to file these returns (section6049(b)(4)((H)). This a definitional provision which would be unlikely to require examination of State law.
[480] Sec. 6103 provides the rules governing confidentiality and disclosure of returns and return information. The provision has several references to State law as to who is authorized to receive such information, what uses such information may be allowed, etc. (section6103). This provision would require examination of State law by the IRS to determine if returns and return information may be released and to whom it may be released.
[481] Sec. 6104 provides rules for publication of certain documents by tax-exempt organizations and certain trusts. Certain information required for determinations required by State law is to be supplied by the Secretary of the Treasury to appropriate State Officials (section6104(c)). This provision would require examination of State law by the Secretary of the Treasury.
[482] Sec. 6111 provides for the registration of tax shelters. Tax shelter is defined in part to mean any investment required to be registered under a State law regulating securities (section6111(c)(1)(B)(i)). This provision might require the examination of State law.
[483] Sec. 6166 provides for the extension of time for payment of estate taxes where the estate consists primarily of interests in closely held business. Stock or partnership interests held by husband and wife either as community property or as joint tenants shall be treated as being held by one individual (section6166(b)(2)(B)). This rule might require examination of State law and is one of those provided to treat taxpayers in community property and common law States the same.
[484] Sec. 6311 provides for paying taxes by commercially acceptable means. A payment of taxes by credit card is not subject certain provisions of the Federal Truth in Lending Act or Electronic Transfer Act or other similar State laws (section6311(d)(3)). This provision might require the examination of State law, but is likely designed to permit the IRS to ignore State law.
[485] Sec. 6323 provide for the validity and priority of Federal tax liens. State law provides the place and manner for filing such liens (section6323(f)). This provision might require the examination of State law.
[486] Sec. 6334 provides what property shall be exempt from levy. Amounts payable under State unemployment laws and workmen's compensation are exempt from levy (section6334(a)(4) & (7)). This provision might require the examination of State law.
[487] Sec. 6338 provides for the tax sale of reality. The deed to the property shall be executed in accordance with State law (section6338(b)). This provision would require examination of State law by the Secretary of the Treasury.
[488] Sec. 6408 provides that State escheat laws do not apply to Federal tax refunds. An affirmative showing that a refund won't escheat may be required in some circumstances (section6408). This provision might require the examination of State law.
[489] Sec. 6421 provides for the refund of certain gasoline taxes if the vehicle is used for nonhighway purposes. Off-highway business use may not include use in a vehicle required to be registered for highway use under State law (section6421(e)(2)(A)(i)). This provision is definitional and would not require the examination of State law.
[490] Sec. 7507 provides for the exemption from taxation of insolvent banks. Banks and trust companies organized under State law are covered by this provision (section7507(a)). This provision is definitional and would not require the examination of State law.
[491] Sec. 7603 provides for the service of summons. Third-party record keepers include savings and loan associations organized under State law and banks defined in section581 (discussed above) (section7603(b)(2)(A)). This provision is definitional and would not require the examination of State law.
[492] Sec. 7622 provides for the authority to administer oaths and certifications. An oath or affirmation may be administered by any person so authorized by State law (section7622(b)). This provision might require the examination of State law.
[493] Sec. 7701 provides the general definitions for the Internal Revenue Code. A domestic building and loan association must have certain assets including certificates of deposit in, or obligations of a corporation organized under State law which specifically authorizes such corporation to insure the deposits or share accounts of member associations (section7701(a)(19)(C)(iii)). This provision is definitional and might require the examination of State law.
[494] Sec. 9002 provides the definitions for the Presidential Campaign Fund. To be a qualified campaign expense neither the incurring or the payment may be a violation of State law (section9002(11)(C)). This provision would require the examination of State law.
[495] Sec. 9032 provides the definitions for the Presidential Primary Matching Payment Account Act. A candidate must take the action necessary under State law to qualify for nomination (section9032(2)). To be a qualified campaign expense neither the incurring or the payment may be a violation of State law (section9032(9)(B)) These provisions would require the examination of State law.
[496] Sec. 9811 provides health care plan requirements relating to benefits for mothers and newborns. The requirements of the provision preempt State law unless State law meets certain listed minimum requirements (section9811(e)). This provision would require the examination of State law.
[497] Sec. 9832 provides definitions for the health care plan requirement provisions. A health insurance issuer must be subject to the State law which regulates insurance (section9832(b)(2)). A health maintenance organization must be recognized as such an organization by State law (section9832(b)(3)). These provisions would require the examination of State law.
Complexity Attributable To Statutory References In The Internal Revenue Code To Foreign Laws Or Attributable Generally To Treaties With Foreign Countries (As Implied By Examination Of The United States Model Income Tax Treaty Of 1996)
Statutory References
[498] The complexity of tax law applicable to citizens and residents of the United States is not coextensive with the complexity of the Internal Revenue Code. Generally applicable U.S. tax law is a much larger body of law and is far more complex than the Internal Revenue Code. This is particularly true for U.S. citizens and residents who have contacts through business or family relationships with foreign countries. There are 123 statutory rules in the Internal Revenue Code which explicitly refer to foreign countries. Not all of such references are consequential from the point of view of tax liability. For example, some simply refer to registration of a vehicle under the laws of a foreign country. Of the 123 instances in which statutory rules set out in the Internal Revenue Code explicitly refer to foreign law, only 72 are consequential. Seventeen do not necessitate actual examination of foreign law. Of the remaining fifty-five rules, two necessitate examination of foreign law by foreign persons subject to taxation by the United States; two necessitate examination of foreign law by the Secretary of State; two by the Secretary of the Treasury; seven by the President; one refers to regulations under which an affected US taxpayer may be required to examine foreign law; thirty-eight necessitate examination of foreign law by affected US taxpayers; and three necessitate examination by affected US taxpayers of special international agreements concerning social security systems in other countries. Furthermore, there are two rules which necessitate examination of complex treaty language reducing rates of tax applicable to interest received in certain cases by partnerships. Apart from instances in which US citizens must examine foreign law in order to comply properly with US tax law, US citizens obviously must also do so in order to comply with foreign tax laws to whatever extent they may have jurisdiction-conferring contacts with foreign countries.
[499] Citations to the statutory rules in the Internal Revenue Code which consequentially defer to the laws of foreign countries or to international agreements are, as follows: section27; section56(g)(4)(C)(iii)(I); section56(g)(4)(C)(iii)(II); section66(d)(3); section163(j)(4)(B)(ii); section163(j)(5)(B); section168(g)(6)(A); section273; section275(a)(4); section404A(d)(2)(B); section404A(g)(2)(A)(i); section404A(g)(2)(A)(ii); section461(f); section515; section535(b)(1); section545(b)(1); section552; section556(b)(1); section642(a); section665(d)(2); section702(a)(6); section703(a)(2)(B); section703(b)(3); section772(d)(6); section807(e)(4)(A); section807(e)(4)(B); section814(f)(1)(A); section814(f)(1)(B); section841; section842; section853(a); section853(b)(2)(B); section853(c); section853(f); section861(e)(3); section864(d)(7)(A); section872(b)(1); section872(b)(2); section877(b); section879(c)(2); section883(a)(1); section883(a)(2); section883(a)(3); section883(a)(5); section891; section893; section894(c); section896; section901; section902; section903; section904(c); section904(d)(2)(B)(i)(I); section904(d)(2)(F); section907(b); section911(d)(8)(A); section927(e)(3); section954(b)(4); section964(b); section999; section1014(b)(6); section1014(b)(7); section1293(g)(1)(B)(i); section1401(c); section1503(d)(2)(A); section1503(d)(2)(B); section2014(a); section2014(b); section2014(c); section2014(d); section2014(f); section2014(h); section2108; section3101(c); section3111(c); section3121(b)(12)(B); section3306(c)(12)(B); section3401(a)(8)(A)(i); section3401(a)(8)(A)(ii); and section4221(e)(1).
Descriptions:
[500] Sec. 27 allows a tax credit for the "amount of taxes imposed by foreign countries" to the extent provided in section 901. Claiming the credit implicitly assumes the taxpayer has examined foreign tax law sufficiently thoroughly to have accurately determined the extent of liability thereunder. Thus, this rule does implicitly necessitate examination of foreign law.
[501] Sec. 66(d)(3). Section 66 specifies the tax treatment of so-called "community income." For purposes of this section, the term "community property laws" is defined under subsection (d)(3) to mean, inter alia, "the community property laws of. . . a foreign country." This rule does necessitate examination of foreign law but only to the limited extent of ascertaining whether or not a particular foreign country recognizes community property.
[502] Sec. 163(j)(4)(B)(ii). Section 163 allows a deduction for interest paid by the taxpayer during the taxable year. Subsection (j) disallows any deduction to a corporation for "disqualified interest." Paragraph (3) of subsection (j) defines the term "disqualified interest" to mean, inter alia, interest paid to a related person if "no tax is imposed by this subtitle with respect to such interest." Paragraph (4) defines the term "related person" and in connection with that definition, subparagraph (B) sets out a special rules with regard to certain partnerships. One of those special rules, set out under clause (ii) relates specifically to situations where a treaty between the United States and a foreign country reduces the rate of tax imposed under U.S. law on a partner's share of interest paid to (i.e., received by) a partnership. The special rule declares, in essence, that the portion of the interest that effectively escapes taxation by virtue of the treaty limitation is treated as if it was tax-exempt. Then, according to section 163(j)(5)(B), in any case where a treaty between the United States and a foreign country does in fact reduce the rate of tax imposed on interest paid or accrued by the taxpayer, the interest in question is treated as interest on which "no tax is imposed by this subtitle" to the extent of the same proportion of such interest as the rate of tax imposed without regard to the treaty (i.e., the non-treaty rate) reduced by the rate of tax imposed by the treaty (i.e., the treaty rate) bears to the rate of tax without regard to the treaty (i.e., the non-treaty rate). The complexity of these rules is self-evident. These rules do not necessitate examination of foreign law but they do necessitate examination of treaty language.
[503] Sec. 168(g)(6)(A). Section 168 generally specifies rules for use of the accelerated cost recovery system. The noted rule, however, allows the President, after determining that a particular foreign country maintains trade restrictions or engages in discriminatory acts against the United States, to issue an Executive Order under which any designated article or class of articles can only be depreciated using any alternative (and less generous) depreciation system. This rule does necessitate examination of foreign law but by the President, not by any taxpayer. A computer- based search uncovered no relevant Executive Order.
[504] Sec. 273. This strange little provision declares that amounts paid under the laws of any foreign country as income to a holder of a life estate acquired by gift or inheritance may not be reduced because of "shrinkage" (by whatever name called) in the value of the life estate due to the lapse of time. This provision does not actually require examination of foreign law; it simply nullifies the effect of such law for U.S. income-tax purposes.
[505] Sec. 275(a)(4). Under the terms of this provision, if a taxpayer claims the foreign tax credit described under IRC section 901 for any taxable year, then no deduction is allowed for income (or similar) taxes "imposed by the authority of a foreign country." This is another provision which does not actually require examination of foreign law. Rather, it simply specifies the U.S. tax treatment of taxes imposed thereunder.
[506] Sec. 404A(d)(2)(B). Section 404A generally allows a deduction for amounts paid by an employer under a qualified foreign deferred compensation plan. The amount allowed as a deduction equals the lesser of the so-called "cumulative US amount" or the so-called "cumulative foreign amount" over all prior contributions. For purposes of the allowance, the term "cumulative foreign amount" is defined by the provisions noted to mean the amount that is deductible "under the appropriate foreign tax laws" for the taxable year and all prior taxable years. Consequently, this rule does require examination of foreign tax laws.
[507] Sec. 461(f). Section 461 sets out rules for determining the taxable year with respect to which certain deductions are allowed (to assure proper tax accounting). Subsection (f) describes a special rule applicable to certain contested liabilities. However, a proviso indicates that this special rule does not apply in the case of contested liability for income (and similar) taxes "imposed by the authority of any foreign country." This language does not necessitate actual examination of foreign law but simply excepts contested tax liability thereunder from the contemplated scope of the special rule.
[508] Sec. 515 allows the amount of taxes "imposed by foreign countries" as a credit against the tax on unrelated business taxable income imposed under section 511 on otherwise tax-exempt organizations. This provision does necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[509] Sec. 535(b)(1). This rule specifies that, for purposes of the accumulated earnings tax, income (and similar) taxes "of foreign countries" are deductible. This provision does necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[510] Sec. 545(b)(1). This rule specifies that, for purposes of the tax on personal holding companies, income (and similar) taxes "of foreign countries" are deductible from "undistributed personal holding company income." This provision does necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[511] Sec. 552 supplies a statutory definition for the term "foreign personal holding company." While it does refer to "the banking and credit laws of a foreign country," it does not ordinarily necessitate examination of such laws.
[512] Sec. 556(b)(1) allows income (and similar) taxes "of foreign countries" to be deducted in calculating the amount of "undistributed foreign personal holding company income." This rule does not necessitate examination of foreign laws.
[513] Sec. 642(a). Section 642 sets out various special rules concerning credits and deductions allowed in the case of estates and trusts. Subsection (a) declares that the foreign tax credit is allowed "for taxes imposed by foreign countries" to the extent allowed by section 901 but "only in respect of so much of the taxes described in such section as is not properly allocable under such section to the beneficiaries." This provision does necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[514] Sec. 665(d)(2) supplies a statutory definition for the term "taxes imposed on the trust" in the case of any foreign trust. This definition refers to income (and similar) taxes "imposed by any foreign country" and may necessitate examination of foreign law. This same paragraph also specifies that, under Treasury regulations, in the case of any foreign trust "of which the settlor or another person would be treated as the owner of any portion of the trust under subpart E [of the Internal Revenue Code] but for section 672(f)," relevant taxes include those imposed on "the settlor or such other person in respect of trust income." The regulations alluded to may necessitate examination of foreign law.
[515] Sec. 702(a)(6) specifies the items of income and the credits of partners and, inter alia, declares that, in determining income tax, each partner must take into account separately his distributive share of the partnership's "taxes, described in section 901, paid or accrued to foreign countries." This provision does necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[516] Sec. 703(a)(2)(B) does not allow a partnership the deduction described under section 164(a) "with respect to taxes, described in section 901, paid or accrued to foreign countries." This provision does necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[517] Sec. 703(b)(3) specifies that, while elections affecting the computation of taxable income derived from a partnership are generally to be made by the partnership, elections under section 901 are to be made by each partner separately. This rule does not necessitate examination of foreign law.
[518] Sec. 772(d)(6). Sections 771 et seq. set out special rules for electing large partnerships. However, even in the case of such partnerships, elections under section 901 are to be made by each partner separately. See section 772(a)(9) and 772(d)(6). These rules do necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[519] Sec. 807(e)(4)(A) and (B). Section 807 specifies rules for the income-tax treatment of changes in the amounts of a life insurance company's reserves (i.e., net increases in reserves are deductible and net decreases in reserves are considered gross income). Subsection (e) sets out special rules for calculating the amounts of such reserves and paragraph (4) thereof concerns certain contracts issued (i.e., life insurance policies sold) by foreign branches of U.S. life insurance companies. Both subparagraph (A) and subparagraph (B) refer to laws of foreign countries that regulate the operation of insurance companies within their territorial jurisdictions. These rules do necessitate examination of foreign laws.
[520] Sec. 814 specifies the income-tax treatment of branches of US life insurance companies that operate in contiguous countries. The rules set out in this section do not necessitate examination of foreign laws.
[521] Sec. 841 allows the foreign tax credit to be claimed by both US life insurance companies and US property/casualty insurance companies. This provision does necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[522] Sec. 842 specifies rules for the tax treatment of foreign insurance companies carrying on insurance business within the United States. This section does not necessitate examination of foreign law.
[523] Sec. 853(a); (b)(2)(B); (c); and (f). Section 853 specifies rules for the application of the foreign tax credit to a regulated investment company (i.e., a mutual fund) at least half of the assets of which consist of stock or securities of foreign corporations. These rules do necessitate examination of foreign law to the same extent it is implicitly necessitated by the rules of sections 901 et seq.
[524] Sec. 861(e)(3). Section 861 is one of the sections in the portion of the Code devoted to sourcing rules. Subsection (e)(3) itself specifies that the foreign tax credit is not allowed for amounts paid to foreign countries that are allocable to any sum received by the taxpayer with respect to certain railroad rolling stock. This rule does not necessitate examination of foreign law.
[525] Sec. 864(d)(7)(A) involves another sourcing rule and excepts certain related persons doing business in the same foreign country from a special rule set out under section 864(d)(1) specifying the treatment of related person factoring income (i.e., income derived from trade or service receivables). This exception does not necessitate examination of foreign law.
[526] Sec. 872(b)(1) and (2). These rules exclude from the US gross income of nonresident aliens (and thus render US-tax-exempt) amounts received from the international operation of ships and aircraft, respectively, if the foreign country in which the individual resides grants an equivalent exemption to individual residents of the United States. This rule does necessitate examination of foreign law.
[527] Sec. 877(b). Section 877 relates generally to expatriation undertaken in order to avoid US taxes. The alternative tax on expatriates that is imposed under subsection (b) is reduced by income (and similar) taxes "paid to any foreign country . . . on any income of the taxpayer on which tax is imposed solely by reason of this section." This rule does not necessitate examination of foreign law.
[528] Sec. 879(c)(2). Section 879 specifies how community income is treated when either or both of the spouses are nonresident aliens. Subsection (c)(2) defines "community property laws" by reference to foreign law and, by implication, does necessitate examination of foreign law but only to determine whether the country in question is in fact a community-property jurisdiction.
[529] Sec. 883(a)(1); (2); (3); and (5).In the context of US taxation of foreign corporations, section 883 sets out rules concerning various exclusions from gross income. Paragraphs (a)(1),(2), and (3) exclude a foreign corporation's income from international operation of ships, international operation of aircraft, and from rental of railroad rolling stock, respectively, if the foreign country where the corporation is organized grants an equivalent exclusion for US corporations. These rules do necessitate examination of foreign law but only to determine requisite reciprocity. Paragraph (a)(5) declares that a lack of reciprocity is, in effect, irrelevant if US corporations are subject to tax by the foreign country concerned "on a residence basis pursuant to provisions of foreign law" meeting such standards (if any) as the Secretary may prescribe. Once again, this rule does necessitate examination of foreign law but only to determine whether relevant US corporations are subject to tax in the foreign country concerned "on a residence basis."
[530] Sec. 891 authorizes the President, after finding that a particular foreign country subjects US citizens or corporations to discriminatory or extraterritorial taxes, to issue a relevant proclamation doubling the rates of taxes imposed under IRC sections 1, 3, 11, 801, 831, 852, 871, and 881 that apply to citizens or corporations of such foreign country. This rule does require the President, but not a US taxpayer, to examine foreign law. A computer- based search uncovered no relevant presidential finding.
[531] Sec. 893 exempts wages and salaries paid by a foreign government to its employees who are physically within the territorial jurisdiction of the United States if the foreign government concerned accords an equivalent exemption to employees of the US government who are within its territorial jurisdiction. This rule does necessitate examination of foreign law but that burden is imposed on an employee of the foreign country concerned, not a US taxpayer.
[532] Sec. 894(c) specifies that a foreign person is not entitled under any income tax treaty of the US with a foreign country to any reduced rate of withholding on an item of income derived through a partnership or other fiscally transparent entity if the item is not taxed in such foreign country and no provision of the treaty addresses the question. This rule does necessitate examination of foreign law but that burden is imposed on a foreign person, not a US taxpayer.
[533] Sec. 896 provides that, if, inter alia, the President determines that a particular foreign country imposes "more burdensome" taxes on US citizens who are not residents of that foreign country than the US imposes on income from sources within the US received by residents of that foreign country, then the President can, by proclamation, impose pre-1967 tax law on such residents of the foreign country concerned. This rule does necessitate examination of foreign law but that burden is imposed on the President, not any taxpayer. A computer-based search uncovered no relevant presidential findings.
[534] Sec. 901(c); (e); (i); and (j). In general, section 901 allows a credit for income (and similar) taxes paid to foreign countries. Subsection (c) requires reciprocity from a foreign country in allowing a credit against its relevant taxes on citizens of the US who reside there and who pay relevant taxes to the US. This rule does necessitate examination of foreign law but that burden is imposed on the President, not any individual taxpayer. Subsection (e) limits the extent of the credit if the foreign country concerned taxes "foreign mineral income" at rates higher than those at which such income is taxed in the US. This rule does necessitate examination of foreign law. Subsection (i) disallows the credit to whatever extent a foreign country's tax is used to provide a subsidy to the taxpayer. This rule does necessitate examination of foreign law. Subsection (j) disallows the credit for taxes paid to a foreign country whose government is not recognized by the US, with which the US has severed diplomatic relations, with which the US does not conduct diplomatic relations, or which has been designated by the Secretary of State as a supporter of international terrorism. This rule does not necessitate examination of foreign law.
[535] Sec. 903 declares that the credit applies to taxes paid to a foreign country "in lieu of" income (and similar) taxes. This rule does necessitate examination of foreign law.
[536] Sec. 904(d)(2)(B)(i)(I); and (d)(2)(F). These two rules supply definitions for the terms "high withholding tax interest" and "high-taxed income," respectively, in a fashion which does necessitate examination of foreign law.
[537] Sec. 907(b). In general, section 907 sets out special rules for application of the foreign tax credit in the case of foreign oil and gas income. For the specialized purposes of relevant law, subsection (b) excludes from the meaning of the term "income, war profits, and excess profits taxes" (i.e., referred to herein simply as "income (and similar) taxes") any amounts paid after 12/31/82 to whatever extent the Secretary of the Treasury determines that the rate exacted with respect to foreign oil related income will generally be materially greater than the rate generally imposed on income that is neither foreign oil related income nor foreign oil and gas extraction income. This rule does necessitate examination of foreign law but the burden of examination is imposed on the Secretary of the Treasury rather than any taxpayer. A computer-based search uncovered no relevant determination by the Secretary of the Treasury.
[538] Sec. 911(d)(8)(A). Section 911 ordinarily accords a sizeable exclusion to US citizens living abroad for their "foreign earned income." However, a special rule set out at subparagraph (d)(8)(A), in effect, disallows the exclusion in the case of income earned from sources within any foreign country to which travel by US citizens is restricted by regulations prescribed under either the Trading with the Enemy Act (50 USC App sections 1 et seq.) or the International Emergency Economic Powers Act (50 USC sections 1701 et seq.). This rule does not necessitate examination of foreign law.
[539] Sec. 927(e)(3). Various rules concerning the tax treatment of foreign sales corporations are set out in sections 921 et seq. For purposes of such sections, some definitions and special rules are set out in section 927 that impose requirements with respect to the laws of a foreign country which must be satisfied in order for a corporation created or organized in that country to be a qualified FSC. Paragraph (e)(3) requires that an income-tax treaty making provision for exchange of fiscal information be in force between the US and the particular foreign country concerned. This rule does not necessitate examination of foreign law.
[540] Sec. 954(b)(4). Sections 951 et seq. relate to controlled foreign corporations. For purposes of these sections, a definition for the term "foreign base company income" is supplied under section 954. Subsection (b) sets out various exclusions and special rules. One exclusion, noted under paragraph (4), declares that neither "insurance income" nor "foreign base company income" (other than "foreign base company oil-related income") includes any item of income received by a cfc if the taxpayer demonstrates (to the satisfaction of the Secretary of the Treasury) that item was taxed by a foreign country at an effective rate of tax more than 90% of the highest rate specified under IRC section 11 (i.e., the US regular corporate income tax). This rule does necessitate examination of foreign law.
[541] Sec. 964(b). Section 964 specifies miscellaneous rules regarding controlled foreign corporations. Subsection (b) declares that no part of a cfc's earnings and profits will be included in its e&p for US tax purposes if the cfc demonstrates (to the satisfaction of the Secretary of the Treasury) that such part could not be distributed to US shareholders "because of currency or other restrictions or limitations imposed under the laws of any foreign country." This rule does necessitate examination of foreign law.
[542] Sec. 999 relates generally to international boycott determinations. Subsection (a)(2) obligates the Secretary of the Treasury to maintain and publish a list of countries that do or may require participation in an international boycott. This provision may necessitate examination of foreign law but the burden imposed is on the Secretary of the Treasury, not any taxpayer. A computer-based search uncovered several lists, the most recent of which appeared in volume 65 of the Federal Register, beginning at page 43084 (dated July 12, 2000) and which designated the following countries: Bahrain, Iraq, Kuwait, Lebanon, Libya, Oman, Qatar, Saudi Arabia, Syria, United Arab Emirates, and Yemen.
[543] Sec. 1014(b)(6); (7). For purposes of determining capital gain or loss, a taxpayer's basis in relevant property must be ascertained. Section 1014 specifies rules for determining the basis of property acquired from a decedent and paragraph (b)(6) applies in the case of community property acquired from a decedent spouse. This rule does necessitate examination of foreign law but only to determine whether or not the particular foreign country concerned is a community-property jurisdiction. Paragraph (b)(7) is similar but applies in the case of decedents whose deaths occurred during a different time period. It likewise does necessitate examination of foreign law but again only to determine whether or not the particular foreign country concerned is a community-property jurisdiction.
[544] Sec. 1293(g)(1)(B)(i). Sections 1291 et seq. relate to passive foreign investment companies (so-called "PFICs"). Section 1293 sets out rules relating to "qualified electing funds" and subsection (g)(1)(B)(i) specifically declares that, for purposes of determining the amount which must be included in the gross income of a person who owns stock in a qualified electing fund, the ordinary earnings and net capital gain of the qualified electing fund in question does not include, inter alia, any item of income if such person demonstrates (to the satisfaction of the Secretary of the Treasury) that the income in question was taxed by a foreign country at a rate more than 90% of the maximum rate of tax under IRC section 11 (i.e., the US regular corporate income tax). This rule does necessitate examination of foreign law.
[545] Sec. 1401(c) exempts from the US self-employment tax the self-employment income of any individual to the extent such income is, under an agreement entered into pursuant to section 223 of the Social Security Act with any foreign country, subject to taxes or contributions for similar purposes under the social security system of the foreign country in question. This rule does not necessitate examination of foreign law but does, of course, necessitate examination of any relevant international agreement.
[546] Sec. 1503(d)(2)(A) and (B). Sections 1501 et seq. relate to consolidated returns. Section 1503 specifies how tax is computed when consolidated returns are filed. Subsection (d) specifies that any particular corporation's "dual consolidated loss" cannot reduce the taxable income of any other member of the affiliated group for any taxable year. Subparagraph (2)(A) defines the term "dual consolidated loss" to mean a net operating loss of a domestic corporation that happens to be subject to an income tax of a foreign country on its income regardless of where that income is sourced or is subject to tax on a residence basis (thus giving rise to the possibility that the loss is attributable to some degree to the foreign income tax). An exception to this rule, set out under subparagraph (2)(B), declares that, under regulations, if a foreign corporation would not be permitted to reduce its income by a relevant loss under the tax laws of the foreign country concerned, then such a loss will not be considered a "dual consolidated loss." Both the basic definition and the exception do necessitate examination of foreign law.
[547] Sec. 2014(a); (b); (c); (d); (f); and (h). In the context of estate and gift taxation, section 2014 relates generally to the credit for foreign death taxes. At least some of the various rules noted do necessitate examination of foreign law.
[548] Sec. 2108 sets out rules regarding the application of pre- 1967 estate tax provisions where a foreign country imposes "more burdensome" taxes on the estates of US citizens. This provision does necessitate examination of foreign law but the burden is imposed on the President not any taxpayer. A computer-based search uncovered no relevant presidential findings.
[549] Sec. 3101(c) providers that, if there is an agreement with any foreign country in effect pursuant to section 233 of the Social Security Act, wages paid to an individual are exempt from FECA taxes to the extent they are subject to taxes or contributions for similar purposes under the social security system of the foreign country concerned. This rule does not necessitate examination of foreign law but it does require the individual concerned to determine if a relevant agreement is in effect.
[550] Sec. 3111(c) likewise providers that, if there is an agreement with any foreign country in effect pursuant to section 233 of the Social Security Act, wages paid to an individual are exempt from FECA taxes to the extent they are subject to taxes or contributions for similar purposes under the social security system of the foreign country concerned. This rule does not necessitate examination of foreign law but it does require the individual concerned to determine if a relevant agreement is in effect.
[551] Sec. 3121(b)(12)(B). Section 3121 defines the term "employment" for purposes of US employment taxes. Subparagraph (b)(12)(B) excludes from the meaning of the term any services performed for an instrumentality of a foreign government if the foreign country concerned likewise excludes services performed for instrumentalities of the US government. This rule does necessitate examination of foreign law but the burden is imposed on the Secretary of State, not any individual affected thereby. A computer-based search uncovered no relevant determinations by the Secretary of State.
[552] Sec. 3306(c)(12)(B). Sections 3301 et seq. relate to the federal unemployment tax (FUTA). For purposes thereof, section 3306(c) supplies a definition for the term "employment" and subparagraph (12)(B) excludes from the meaning of the term any services performed for an instrumentality of a foreign government if the foreign country concerned likewise excludes services performed for instrumentalities of the US government. This rule does necessitate examination of foreign law but the burden is imposed on the Secretary of State, not any individual affected thereby. A computer-based search uncovered no relevant determinations by the Secretary of State.
[553] Sec. 3401(a)(8)(A)(i) and (ii). Sections 3401 et seq. relate to withholding of federal income taxes at source. The term "wages" is defined for withholding purposes under section 3401(a). Exclusions from this definition are set out under clauses (8)(A)(i) and (ii), respectively, for remuneration paid for services performed for an employer (i) by a US citizen that are reasonably believed to be excluded from gross income under IRC section 911 (i.e., the "foreign earned income" and "housing cost amount" exclusions) or (ii) in a foreign country and subject to income tax withholding by that foreign country. These rules do not necessitate examination of foreign law.
[554] Sec. 4221(e)(1) conditions certain privileges accorded with respect to excise taxes in the case of aircraft registered in a foreign country on reciprocity of treatment by the foreign country concerned. This rule does not necessitate examination of foreign law by any owner of US-registered aircraft.
Tax Law Complexity Attributable To Tax Treaties
[555] The discussion which follows examines tax law complexity attributable to tax treaties between the United States and various foreign countries. The focus is on complexity confronting US citizens and business enterprises having jurisdiction-conferring contacts with foreign countries. Various types of information of interest to those nonresident aliens from foreign countries with which the United States has tax treaties who have income from sources within the United States can be found in IRS Publication 901, entitled "U.S. Tax Treaties."
[556] Detailed examination of every provision of every tax treaty to which the United States is a party is simply beyond the scope of this discussion. Rather, what is presented here is an overview of the policy positions taken in the U.S. Model Income Tax Treaty of September 20, 1996. Brief attention is also accorded to estate tax treaties between the United States and a few foreign countries.
[557] The U.S. Model Income Tax Treaty is comprised of twenty- nine articles. As a general rule, the first three, relating respectively to "general scope," "taxes covered," and "general definitions," do not contribute significant complexity to U.S. tax law. The same can also be said for the last two articles, relating respectively to "entry into force" and "termination." To the extent treaties do add significant complexity to U.S. tax law, they do so through the substantive provisions akin to those set out in the Model Treaty's articles 4 through 27. It should be noted with some emphasis that relevant articles of actual treaties of the United States are not generally identical to the corresponding articles of the model treaty. Each treaty is negotiated separately and U.S. treaty policy does vary somewhat over time. Thus, the commentary below should be understood as reflecting only an approximation of the complexity attributable to actual treaty language. Furthermore, it should be noted that several treaties include special articles that are either unique or uncommon and not included in the model treaty. The articles discussed below appear in the same order in which they appear in the model treaty.
Article 4 - Residence
[558] All of the income tax treaties are described as intended to prevent double taxation and most are described as also intended to prevent fiscal evasion. Service of both of those objectives necessitates careful definition of "residence" for treaty purposes. One important role of any tax treaty is to specify which of the contracting parties will have jurisdiction to tax certain items of income received by persons who have jurisdiction-conferring contacts with both contracting parties. The article relating to residence is one which helps settle such matters. In recent years, the article relating to residence has also been used to help to exclude certain persons from whatever benefits may be accorded under a specific treaty. That is, this article helps to prohibit certain persons from engaging in so-called "treaty shopping." In other words, it helps to prevent persons who are not genuinely residents of either contracting party from deriving benefits under the treaty through subterfuge. Typically, the article relating to "limitation of benefits" operates in conjunction with the article relating to residence to achieve this result.
[559] The rules set out in article 4 of the model treaty for determining which persons are residents are not complex.
Article 5 - Permanent Establishment
[560] This article sets out rules regarding what does or does not constitute a "permanent establishment." A permanent establishment must exist in the other country in order for that country to tax the business profits of a U.S. resident. The rules set out in article 4 of the model treaty are only modestly complex.
Article 6 - Income From Real Property (Immovable Property)
[561] This article of the model treaty is divided into seven paragraphs. The first sets out the general rule that, when real property is owned by a resident of one contracting party but situated in the other, the country where the property is situated may tax income derived from it (including from agricultural use of it). Conceivably, direct use of relevant property by its owner (e.g., simple occupation of a dwelling) could give rise to imputed income under the laws of some foreign countries. This article does not confer an exclusive right to tax income from real property on the situs country. Nor does the article impose limits on the rate of form of tax the situs country can impose, except that a subsequent paragraph (number five) obliges the situs country to allow a taxpayer an election to be taxed on a net basis.
[562] The second paragraph of this article defines the terms "real property" and "immovable property" as interchangeable and, in the case of property sited in the United States, the terms are assigned the meaning given the term "real Property" under a Treasury regulation prescribed under IRC section897 (i.e., Reg. section1.897- 1(b)). The third paragraph of the article specifies that the article applies to income from the use of real property but income from a disposition of real property is covered by the article of the treaty relating to "gains." The fourth paragraph of this article clarifies that the general rule allowing the situs country to tax income from the use of real property applies even in cases where the income is received by a business enterprise (i.e., in lieu of the rules regarding "business profits" under article 7 of the treaty) or by someone performing independent personal services (i.e., in lieu of the rules concerning such services under article 14 of the treaty). The Fifth paragraph of this article declares that a resident of one contracting State with real property income derived from the other contracting State must be accorded an election to be subject to tax in the situs country exclusively on a net basis (i.e., as if the income was attributable to a permanent establishment in the situs country). Such an election is only terminable with permission of the competent authority in the country concerned. In the U.S., termination must be in accordance with Reg. section1.871-10(d)(2). The rules noted above are modestly complex.
Article 7 - Business Profits
[563] The purpose of this article is to set out rules under which the business profits of an enterprise resident in one contracting State are allowed to be taxed by the other contracting State (e.g., where the business profits of a business resident in the United States may be taxed in a foreign country which has entered into an income tax treaty with the U.S.). This article is divided into eight paragraphs. The first states the general rule that a business profits of an enterprise resident in one contracting State may be taxed in the other contracting State only if the enterprise carries on business in the other State through a permanent establishment and then only on net income attributable to that permanent establishment. While this general rule may seem simple on its face, considerable complexity can arise in practice from its application.
[564] Paragraph 2 of this article attributes income to a permanent establishment under an arm's length standard under which the permanent establishment is viewed as an independent entity. The concept of attribution of income to a permanent establishment is said to be analogous, but not identical, to the "effectively connected" concept employed under IRC section864(c). To the extent there is a difference, of course, complexity is intensified. The source of attributed income (i.e., whether from sources within the United states, the other contracting State, or some third State) is not relevant. Unlike the OECD model income tax treaty, the U.S. model does not provide for formulaic apportionment of worldwide income (the method also used by States within the United States to determine how much income of a multi-jurisdictional business is appropriately taxed in any one jurisdiction).
[565] Paragraph 3 of the article provides that deductions are to be allowed in determining the business profits of a permanent establishment in order to assure that it is net profits that will be subject to tax. Relevant expenses are to include allocated portions of any expenses incurred with respect to operations in more than one country. No uniform rule is specified for how such allocations are to be determined. This absence of uniformity makes possible added complexity for an enterprise operating in multiple foreign countries.
[566] Paragraph 4 declares that no business profit is attributed to a permanent establishment because of purchasing it does on behalf of the enterprise of which it is apart. Paragraph 6 coordinates Article 7 with other articles of the treaty. Paragraph 7 defines "business profits" in special cases. Paragraph 8 incorporates the substance of IRC section864(c)(6) into the treaty. It specifies that, if a permanent establishment (or other fixed base) ceases to exist, payment of income or gain which accrued during its existence but that was not received until thereafter is still taxable in the contracting State where the former permanent establishment was situated. The interrelationship of this rule with other articles of the treaty can give rise to significant complexity.
Article 8 - Shipping and Air Transport
[567] This article is divided into several paragraphs. The first specifies a rule to the effect that profits derived by an enterprise which is a resident of one of the contracting States from the international operation of ships or aircraft is only taxable by that State, not by the other State -- even if the enterprise maintains a permanent establishment in the other State. This overrides the general rule for business profits set out under article 7. Paragraph 2 defines what is meant by "income from the operation of ships or aircraft in international traffic." Paragraph 3 specifies a rule to the effect that profits derived by a resident enterprise of one contracting State from the use, rental, etc., of containers that are used to transport goods in international traffic are exempt from tax in the other State -- even if the recipient is not engaged in the international operation of ships or aircraft and even if the recipient has a permanent establishment in the other State. Paragraph 4 specifies that the rules under paragraphs 1 and 3 apply to profits derived from participation in a pool, joint business, or international operating agency.
Article 9 - Associated Enterprises
[568] This article consists of just two paragraphs. It deals with some of the most complex matters addressed in the treaty. In general, it employs the arm's-length principle employed in U.S. domestic law regarding transfer pricing (see for example IRC section482). If related enterprises engage in a transaction otherwise than on an arm's length basis (e.g., if a higher-than-market price is "charged" a related enterprise for a component of a product), then the contracting State with jurisdiction to tax may adjust the taxable income and the tax liability of the related enterprises in order to reconstruct what would have been the correct income and tax attributable to the transaction had there been an arm's length relationship between the related enterprises. Why would a related enterprise charge a higher-than-market price in a transaction with one of its related enterprises? Since article 7 (business profits) guarantees that the situs country can only tax a permanent establishment on net income and must allow it to deduct expenses in arriving at that amount, the higher the prices it pays to a related enterprise not taxable by the situs country (and consequently the higher the "expenses" it incurs in generating net income in the situs country) the lower its net income and thus the lower the tax it must pay to the situs country. While abuses in the case of the business profits of manufacturing enterprises can be extraordinarily difficult to prevent in a regime grounded on the arm's length principle, those associated with business profits generated by currency transactions, futures contracts, and financial derivatives (especially those incorporating synthetic elements) are next to impossible to prevent. There clearly is a chicken-and-egg issue. On the one hand, some underlying international business activity is extremely complex and that complexity reflects, at least in part, efforts to minimize the overall tax liability of the international conglomerate of associated enterprises. On the other hand, a fundamental objective of relevant tax law must be fairness. If the United States (like its constituent States) relied on formulary allocation of the worldwide income of business enterprises engaged in international operations, relevant tax law (including treaty law) might theoretically be comparatively simpler. However, if the United States remains committed to reliance on the arm's length principle in an effort to achieve comparatively "fairer" tax liability, then the prevention of whatever abuses can be prevented necessitates significant complexity in relevant law.
[569] Paragraph 1 of the article specifies circumstances under which adjustments are to be made by a contracting State. Paragraph 2 obligates the other contracting State to make corresponding adjustments.
Articles 10, 11, 12, 13, 18, and 21
These articles specify rules for various categories of income.
Article 10 - Dividends
[570] This article specifies rules for taxing dividends paid by a resident of one contracting State to a beneficial owner that is a resident of the other contracting State. While demonstrating their own logic, these rules can be quite complicated. The first paragraph acknowledges the right of a dividend recipient's State of residence to tax dividends received. The second acknowledges the right of the State which is the source of the dividends to tax recipients thereof that are residents of the other State, subject to limitations: generally, the rate of tax may not exceed 15% of the gross amount of the dividends but, if the recipient is a company that is a resident of the other State and that owns 10% or more of the dividend payer, then the rate of tax the source State may impose may not exceed 5% of the gross amount of the dividends. Generally speaking, indirectly held shares are not counted in determining eligibility for the lower rate of tax, However, an exception applies in the case of shares held through a fiscally transparent entity (such as a partnership). The third paragraph sets out rules under which the maximum rates of tax at source which are specified in paragraph 2 are modified. Thus, the lower rate is denied for dividends paid by US RICs and REITs and, in certain cases, both special rates are denied in the case of dividends paid by US REITs (thus allowing the US to impose its generally applicable statutory 30% rate of withholding). However, the 15% rate limit does apply to dividends paid by a US REIT to an individual who is a resident of the other State and whose ownership interest in the REIT is less than 10%. These rules regarding the special treaty rates of tax are obviously somewhat complex but they are intended to foreclose certain fairly obvious opportunities for abusively claiming the benefits of the lower rates. Paragraph 4 sets out rules applicable to a dividend recipient which is a governmental entity. Paragraph 5 specifies the various equivalents of dividends under US law. Paragraph 6 provides an exclusion from the limitations of paragraph 2 for dividends paid on shares held essentially as inventory (for example, shares held for sale by a securities dealer).
[571] As noted above, paragraph 1 of article 10 allows a dividend recipient's State to tax those dividends and paragraph 2 allows the State where a permanent establishment pays dividends to tax them. However, paragraph 7 restricts the right of a State otherwise to tax dividends paid by an enterprise that is a resident of the other State. Consequently, for example, the US is prohibited from "secondary" withholding on dividends paid by a nonresident enterprise out of US-sourced earnings and profits (i.e., paragraph 7 overrides taxes which would otherwise be imposed under IRC sections 871 and 882(a)). Except for taxes on branch profits, paragraph 7 also restricts a State's right to impose corporate level taxes on undistributed profits. Since article 2 of the treaty (relating to taxes covered) specifically mentions the US accumulated earnings tax and the personal holding company taxes, the US is thus prohibited from imposing such taxes on a resident of a treaty partner except to the extent the earnings are attributable to a permanent establishment in the U.S. This paragraph does not, however, restrict a State's right (e.g., the right of the US) to tax its own residents in their capacity as shareholders on undistributed earnings of a corporation which is a resident of the other State. Consequently, the US is allowed to impose its foreign personal holding company tax, taxes on Subpart F income, tax on any increase in earnings invested in U.S. property, and its tax on any Passive Foreign Investment Company (PFIC) that is a Qualified Electing Fund.
[572] Paragraph 8 allows a State to impose a branch profits tax on a "corporation" resident in the other State. The model treaty does not define the term "corporation." Therefore, that term is defined under the law of the State imposing the tax. Paragraph 8 specifies the base of a permissible branch profits tax (i.e., a so-called "dividend equivalent amount") which is specifically defined in the paragraph). Paragraph 9 limits the rate of a relevant branch profits tax to 5%.
Article 11 - Interest
[573] Paragraph 1 of this article declares that, as a general rule subject to some exceptions, the State of residence of the recipient (i.e., the "beneficial owner") has an exclusive right to tax interest arising in the other State.
[574] Paragraph 2 defines the term "interest," inter alia, to include income paid under the terms of a debt obligation that carries a right to participate in profits but not to include any amount treated as "dividends" under Article 10. Thus, the treaty preserves a debt-equity distinction which bedeviled the IRS for many years and which no-one has ever been able to articulate. In light of the fact that this article of the treaty does not include rate limitations comparable to those imposed under the article relating to dividends, the distinction has financial significance. Various types of interest equivalents (such as OID) are also specifically included within the contemplated meaning of "interest."
[575] Paragraph 3 specifies an exception to the general exclusivity rule of paragraph 1. This exception applies in a situation where the recipient of the interest maintains a permanent establishment in the other State and the interest is attributed to that permanent establishment or a situation where the recipient of the interest is an individual and that individual is self-employed using a "fixed base" in the other State and the interest is attributable to that fixed base. In such situations, the rules of either article 7 (business profits) or article 14 (independent services) apply and the other State (rather than the State where the recipient of the interest resides) retains the right to tax the interest. Should a permanent establishment or fixed base have ceased to exist, backward-looking accrual rules apply.
[576] Paragraph 4 sets out another special rule. It applies only in a case where a "special relationship" exists between the juridical person paying the interest and the juridical person receiving it. The model treaty does not define what is meant by the expression "special relationship" but the relationships specified in article 9 and, by implication, the definition of "control" supplied for purposes of IRC section482 are evidently intended to apply. When a relevant special relationship exists, if the amount of payments characterized by the parties as "interest" is larger than would be paid absent any special relationship (i.e., where there is more "interest" than would be paid in an arm's length arrangement), paragraph 4 specifies that the excess remains taxable under the domestic laws of the US and the other State, respectively, in accordance with other articles of the treaty. For example, if the State in which the interest arises would treat the excess amount as a distribution of profits by a corporation, then that excess could be taxed as specified under article 10 as dividends. Of course, the rate limitations of article 10 could apply in such an instance. How such an eventuality would work to the disadvantage of a taxpayer is not immediately clear. The paragraph does not deal with situations where payments reflect a below-market rate of "interest." In such cases, the contracting States would apparently be free to recharacterize the transaction to reflect its substance and the amount of shortfall would evidently be taxed (at least in the case of the US) as imputed interest.
[577] Paragraph 5 sets out two exceptions to the general exclusivity rule of paragraph 1 to combat perceived abuses. The first exception relates to so-called "contingent interest" (that is, interest the amount of which is determined by reference to receipts, sales, income, profits, or other cash flow of the debtor or a related person or interest the amount of which is determined by reference to any change in the value of any property of the debtor or a related person or interest the amount of which is determined by reference to any dividend, partnership distribution, or similar payment made by the debtor or a related person) arising in one State and paid to a resident of the other State. In keeping with the general rule of paragraph 1, such contingent interest may be taxed by the State where the recipient resides-subject to the rate limitations imposed under article 10 with respect to dividends. Such contingent may also be taxed by the State where it arises according to the laws of that State. The second subparagraph essentially incorporates by reference the rules of IRC sections 860E(e) and 860G(b) taxing fully excess inclusions with respect to a real estate mortgage investment conduit (REMIC).
[578] The precise contemplated advantage of taxing interest received differently from the way dividends received are taxed is not immediately obvious. However, that perceived advantage is evidently the justification for this special rule (as well, of course, as for the different rules set out under article 10 as compared to those under article 11). The complexity of the foregoing rules seems self- evident.
Article 12 - Royalties
[579] Subject to certain exceptions, paragraph 1 accords the State where the beneficial owner of royalties resides the exclusive right to tax their receipt. Paragraph 2 defines the term "royalties" to mean, in essence, payments received as consideration for the use of (or the right to use) a copyright, patent, trademark, design of model, plan, secret formula or process, "know-how," or other like right or property (but not rental income from the lease of personal property). Paragraph 3 sets out an exception to the general rule of paragraph 1 which applies in a situation where the beneficial owner carries on a business through a permanent establishment (or fixed base) in the State where the royalties arise. In such a situation, either the rules of article 7 (business profits) or article 14 (independent personal services) apply. Paragraph 4 specifies rules where a "special relationship" exists between the person paying the royalties and the person receiving them. Article 12 only applies to the extent the royalties would have been paid absent the existence of the special relationship (i.e., again reflecting the application of the arm's-length principle favored by the United States). Any excess (or shortfall?) Is taxable in accordance with other articles of the treaty and the domestic laws of the contracting States. Reliance on the arm's-length principle implicates the complexity alluded to earlier.
Article 13 - Gains
[580] By comparison to those under some of the other articles of the model treaty, the rules under this article are relatively uncomplicated. Paragraph 1 sets out a general rule to the effect that gains from the alienation (i.e., sale or exchange) of real estate are taxable (but not exclusively) by the State where the real estate is situated. Thus, for example, the United States may apply IRC section897 to tax gains derived from the sale of real estate located in the U.S. that is owned by a resident of a treaty partner. A definition under paragraph 2 of the treaty makes a cross-reference t IRC section897(c) which defines the term "United States real property interest" to include shares in a US corporation if it owns a sufficient amount of US-situated real estate on specified test dates to satisfy an asset-ratio test. Certain electing foreign corporations are also treated this way under IRC section897(i). Distributions by a REIT are taxed under article 13 of the treaty rather than article 10 (dividends) if they are attributable to gains from sales of real estate. Paragraph 3 relates to gains from dispositions of certain movable property (not real estate under US domestic law). Paragraph 4, in effect, reiterates the general rule of article 8 (and thereby fosters simplicity through uniformity of treatment) with respect to gains from the sale of ships, aircraft, and containers (and appurtenant movable property) operated in international traffic by according the State where the seller resides exclusive taxing jurisdiction. Paragraph 5, in effect, accords exclusive taxing jurisdiction to the State where the seller resides in all cases not contemplated by the preceding paragraphs of the article.
Article 18 - Pensions, Social Security, Annuities, Alimony, and Child Support
[581] Paragraph 1 of this article specifies that the State where a recipient of a pension or similar remuneration resides has the exclusive right to tax it. [Note: This article does not cover pensions for government service.] Paragraph 2 specifies that social security benefits are taxable by the State which pays such benefits. Under paragraph 3, annuities for adequate and full consideration (not annuities for past services performed) are only taxable by the State where the recipient resides. [Note: Annuities for past services performed are considered deferred compensation and are subject to the rules under article 15 relating to dependent personal services.] Paragraph 4 specifies that alimony (if deductible by the individual paying it) paid by a resident of one State to a resident of the other State is taxable only in the State where the recipient resides. Paragraph 5 specifies that child support not covered by paragraph 4 (i.e., neither deductible by the person paying it nor taxable to the recipient) is not taxable by either State.
[582] Paragraph 6 is new to the U.S. model treaty. No corresponding provision is included in any of the other model treaties. It is quite detailed and somewhat complex. It is divided into three subparagraphs. Subparagraph (a) provides that, under certain conditions, employee contributions made in one State to a pension plan in the other State are deductible or excludable. Also, contributions by an employer are deductible in the State where relevant services are performed. However, where services are performed in the United States, the exclusion of employee contributions is limited as specified under IRC section402(g) and deductions for employer contributions are limited as specified under IRC sections 415 and 404. Subparagraph (b) specifies that income earned by a pension plan is not taxable in the other State until distributed. Subparagraph (c) allows an individual to rollover funds from the State where that individual resides to a plan in the other State without being taxed in the other State. Several restrictions apply to the benefit conferred under this subparagraph.
Article 21 - Other Income
[583] The general rule set out in paragraph 1 of this article specifies that items of income not dealt with in other articles of the treaty are only taxable in the State where the recipient (i.e., the "beneficial owner") resides. An exception is noted in paragraph 2.
Articles 14, 15, 16, 17, 19, and 20 - Overview
[584] These articles specify rules concerning various categories of personal services for which individuals receive remuneration. Articles 14 and 15, respectively, apply broadly to self-employed income and income received in the capacity of an employee. Then articles 16, 17, 19, and 20 set out special rules which apply to certain particular categories of individuals or to particular types of income typically received by individuals but not by purely juridical persons. By comparison to the articles discussed above, those relating primarily to individuals are much less complex.
Article 14 - Independent Personal Services
[585] The general rule stated in paragraph I of this article is simply that self-employed income is taxable by the State where the individual concerned resides and is exempt from taxation by the other State. However, if relevant services are performed in the other State and are attributable to a fixed base there that is regularly available to (though not necessarily actually used by) the individual concerned, then that other State is allowed to tax such income. Paragraph 2 recognizes the right of relevant individuals to deduct expenses associated with the performance of relevant services.
Article 15 - Dependent Personal Services
[586] Paragraph 1 states the general rule that income which individuals receive in their respective capacities as employees may be taxed by the State where they reside as well as by the other State if they earn it there. Paragraph 2 sets out an exception under which the source State is not allowed to tax relevant income if (1) the income earner is present in it for 183 days or fewer; (2) the employee is not a resident of the source State; and (3) the amount concerned is not a deductible expense by a permanent establishment (or fixed base) of the employer in the source State. Paragraph 3 accords the State of residence exclusive jurisdiction to tax if the employee works as a member of the regular complement aboard a ship or aircraft operated in international traffic.
Article 16 - Directors' Fees
[587] Under this article, the State where a company resides may tax fees paid to directors of the company even if they reside in the other State.
Article 17 - Artistes and Sportsmen
[588] This article concerns the taxation by one State of the income earned within its territory by performers and entertainers ("artistes") and professional athletes ("sportsmen") who reside in the other State. The rules of this article supersede those of articles 14 (independent personal services) and 15 (dependent personal services). This article does not apply however to persons who perform ancillary services (e.g., producers, directors, managers, coaches, etc.), who remain subject to articles 14 and 15. Paragraph 1 specifies that the income of a relevant individual is subject to tax by the State where performance occurs only if gross receipts annually exceed $20,000 (or currency equivalent). Paragraph 2 is intended to prevent circumvention of rules otherwise applicable when remuneration for performance is paid to an agent or other intermediary. Thus, the State where the performance occurs may tax the recipient of the income attributable to that performance (if that is not the actual performer or athlete).
Article 19 - Government Service
[589] Subparagraph (a) of paragraph 1 specifies that current compensation for government service paid by one State is generally exempt from tax by the other State. However, subparagraph (b) specifies that, if the employee is a resident of the other State and is either a national of that other State or did not become a resident of that other State solely for purposes of rendering relevant services, then, if the services are rendered in the other State, they are taxable exclusively by the other State. Paragraph 2 is likewise divided into two subparagraphs. Subparagraph (a) sets out a general rule to the effect that a pension paid by one State to an individual that is attributable to past government service in that State is taxable only in that State. An exception is set out, however, in subparagraph (b), according to which, if the recipient of a pension resides in the other State or is a national of the other State, then the pension is taxable only by that other State. [Note: Social security benefits payable to former government employees are subject to paragraph 2 of article 18, relating to pensions.]
Article 20 - Students and Trainees
[590] This article specifies that the host State generally may tax visiting students, apprentices., and business trainees but that such individuals are exempt from tax on certain amounts they receive (for maintenance expenses and the costs of education or training). However, entitlement to the benefits of this article hinges on satisfaction of several conditions.
Remaining Articles of the Model Treaty
[591] While some of the remaining articles of the treaty (especially article 22 imposing limitations on the benefits of the treaty (e.g., anti-treaty-shopping rules) and article 23 supplying relief from double taxation) involve extraordinarily complex rules, the complexity primarily affects the competent authorities of the contracting States rather than taxpayers directly. Others of the remaining articles (e.g., provisions regarding mutual agreement procedures) involve no complexity at all from the point of view of taxpayers.
- Institutional AuthorsJoint Committee on Taxation
- Cross-Reference
- Subject Area/Tax Topics
- Index Termsbudget, federallegislation, taxAMTIRC, complexitytax policy, simplificationincome tax, individualscorporate tax
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2001-12007 (473 original pages)
- Tax Analysts Electronic Citation2001 TNT 90-40
