I

104TH CONGRESS

1ST SESSION H. R. 1121

To make technical corrections relating to the Revenue Reconciliation Act

of 1990 and the Revenue Reconciliation Act of 1993, and for other purposes.

IN THE HOUSE OF REPRESENTATIVES

MARCH 3, 1995

Mr. ARCHER (for himself and Mr. GIBBONS) introduced the following bill;

which was referred to the Committee on Ways and Means

A BILL

To make technical corrections relating to the Revenue Reconciliation Act of 1990 and the Revenue Reconciliation

Act of 1993, and for other purposes.

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled,

3 SECTION 1. SHORT TITLE; ETC.

4 (a) SHORT TITLE.—This Act may be cited as the

5 ‘‘Tax Technical Corrections Act of 1995’’.

6 (b) AMENDMENT OF 1986 CODE.—Except as other7 wise expressly provided, whenever in this Act an amend8 ment or repeal is expressed in terms of an amendment

9 to, or repeal of, a section or other provision, the reference
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1 shall be considered to be made to a section or other provi2 sion of the Internal Revenue Code of 1986.

3 SEC. 2. AMENDMENTS RELATED TO REVENUE RECONCILI4 ATION ACT OF 1990.

5 (a) AMENDMENTS RELATED TO SUBTITLE A.—

6 (1) Subparagraph (B) of section 59(j)(3) is

7 amended by striking ‘‘section 1(i)(3)(B)’’ and insert8 ing ‘‘section 1(g)(3)(B)’’.

9 (2) Clause (i) of section 151(d)(3)(C) is amend10 ed by striking ‘‘joint of a return’’ and inserting

11 ‘‘joint return’’.

12 (3) Subsection (b) of section 1 (as in effect on

13 the day before the date of the enactment of the Rev14 enue Reconciliation Act of 1993) is amended by

15 striking ‘‘$26,500’’ in the table contained therein

16 and inserting ‘‘$26,050’’.

17 (b) AMENDMENTS RELATED TO SUBTITLE B.—

18 (1) Paragraph (1) of section 11212(e) of the

19 Revenue Reconciliation Act of 1990 is amended by

20 striking ‘‘Paragraph (1) of section 6724(d)’’ and in21 serting ‘‘Subparagraph (B) of section 6724(d)(1)’’.

22 (2)(A) Subparagraph (B) of section 4093(c)(2),

23 as in effect before the amendments made by the

24 Revenue Reconciliation Act of 1993, is amended by

25 inserting before the period ‘‘unless such fuel is sold
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1 for exclusive use by a State or any political subdivi2 sion thereof’’.

3 (B) Paragraph (4) of section 6427(l), as in ef4 fect before the amendments made by the Revenue

5 Reconciliation Act of 1993, is amended by inserting

6 before the period ‘‘unless such fuel was used by a

7 State or any political subdivision thereof’’.

8 (3) Paragraph (1) of section 6416(b) is amend9 ed by striking ‘‘chapter 32 or by section 4051’’ and

10 inserting ‘‘chapter 31 or 32’’.

11 (4) Section 7012 is amended—

12 (A) by striking ‘‘production or importation

13 of gasoline’’ in paragraph (3) and inserting

14 ‘‘taxes on gasoline and diesel fuel’’, and

15 (B) by striking paragraph (4) and redesig16 nating paragraphs (5) and (6) as paragraphs

17 (4) and (5), respectively.

18 (5) Subsection (c) of section 5041 is amended

19 by striking paragraph (6) and by inserting the fol20 lowing new paragraphs:

21 ‘‘(6) CREDIT FOR TRANSFEREE IN BOND.—If—

22 ‘‘(A) wine produced by any person would

23 be eligible for any credit under paragraph (1)

24 if removed by such person during the calendar

25 year,
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1 ‘‘(B) wine produced by such person is re2 moved during such calendar year by any other

3 person (hereafter in this paragraph referred to

4 as the ‘transferee’) to whom such wine was

5 transferred in bond and who is liable for the tax

6 imposed by this section with respect to such

7 wine, and

8 ‘‘(C) such producer holds title to such wine

9 at the time of its removal and provides to the

10 transferee such information as is necessary to

11 properly determine the transferee’s credit under

12 this paragraph,

13 then, the transferee (and not the producer) shall be

14 allowed the credit under paragraph (1) which would

15 be allowed to the producer if the wine removed by

16 the transferee had been removed by the producer on

17 that date.

18 ‘‘(7) REGULATIONS.—The Secretary may pre19 scribe such regulations as may be necessary to carry

20 out the purposes of this subsection, including regula21 tions—

22 ‘‘(A) to prevent the credit provided in this

23 subsection from benefiting any person who pro24 duces more than 250,000 wine gallons during a

25 calendar year, and
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1 ‘‘(B) to assure proper reduction of such

2 credit for persons producing more than 150,000

3 wine gallons of wine during a calendar year.’’

4 (6) Paragraph (3) of section 5061(b) is amend5 ed to read as follows:

6 ‘‘(3) section 5041(f),’’.

7 (7) Section 5354 is amended by inserting ‘‘(tak8 ing into account the appropriate amount of credit

9 with respect to such wine under section 5041(c))’’

10 after ‘‘any one time’’.

11 (c) AMENDMENTS RELATED TO SUBTITLE C.—

12 (1) Paragraph (4) of section 56(g) is amended

13 by redesignating subparagraphs (I) and (J) as sub14 paragraphs (H) and (I), respectively.

15 (2) Subparagraph (B) of section 6724(d)(1) is

16 amended—

17 (A) by striking ‘‘or’’ at the end of clause

18 (xii), and

19 (B) by striking the period at the end of

20 clause (xiii) and inserting ‘‘, or’’.

21 (3) Subsection (g) of section 6302 is amended

22 by inserting ‘‘, 22,’’ after ‘‘chapters 21’’.

23 (4) The earnings and profits of any insurance

24 company to which section 11305(c)(3) of the Reve25 nue Reconciliation Act of 1990 applies shall be de-
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1 termined without regard to any deduction allowed

2 under such section; except that, for purposes of ap3 plying sections 56 and 902, and subpart F of part

4 III of subchapter N of chapter 1 of the Internal

5 Revenue Code of 1986, such deduction shall be

6 taken into account.

7 (5) Subparagraph (D) of section 6038A(e)(4) is

8 amended—

9 (A) by striking ‘‘any transaction to which

10 the summons relates’’ and inserting ‘‘any af11 fected taxable year’’, and

12 (B) by adding at the end thereof the fol13 lowing new sentence: ‘‘For purposes of this sub14 paragraph, the term ‘affected taxable year’

15 means any taxable year if the determination of

16 the amount of tax imposed for such taxable

17 year is affected by the treatment of the trans18 action to which the summons relates.’’.

19 (6) Subparagraph (A) of section 6621(c)(2) is

20 amended by adding at the end thereof the following

21 new sentence: ‘‘The preceding sentence shall be ap22 plied without regard to any such letter or notice

23 which is withdrawn by the Secretary.’’.
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1 (7) Clause (i) of section 6621(c)(2)(B) is

2 amended by striking ‘‘this subtitle’’ and inserting

3 ‘‘this title’’.

4 (d) AMENDMENTS RELATED TO SUBTITLE D.—

5 (1) Notwithstanding section 11402(c) of the

6 Revenue Reconciliation Act of 1990, the amendment

7 made by section 11402(b)(1) of such Act shall apply

8 to taxable years ending after December 31, 1989.

9 (2) Clause (ii) of section 143(m)(4)(C) is

10 amended—

11 (A) by striking ‘‘any month of the 10-year

12 period’’ and inserting ‘‘any year of the 4-year

13 period’’,

14 (B) by striking ‘‘succeeding months’’ and

15 inserting ‘‘succeeding years’’, and

16 (C) by striking ‘‘over the remainder of

17 such period (or, if lesser, 5 years)’’ and insert18 ing ‘‘to zero over the succeeding 5 years’’.

19 (e) AMENDMENTS RELATED TO SUBTITLE E.—

20 (1)(A) Clause (ii) of section 56(d)(1)(B) is

21 amended to read as follows:

22 ‘‘(ii) appropriate adjustments in the

23 application of section 172(b)(2) shall be

24 made to take into account the limitation of

25 subparagraph (A).’’
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1 (B) For purposes of applying sections 56(g)(1)

2 and 56(g)(3) of the Internal Revenue Code of 1986

3 with respect to taxable years beginning in 1991 and

4 1992, the reference in such sections to the alter5 native tax net operating loss deduction shall be

6 treated as including a reference to the deduction

7 under section 56(h) of such Code as in effect before

8 the amendments made by section 1915 of the En9 ergy Policy Act of 1992.

10 (2) Clause (i) of section 613A(c)(3)(A) is

11 amended by striking ‘‘the table contained in’’.

12 (3) Section 6501 is amended—

13 (A) by striking subsection (m) (relating to

14 deficiency attributable to election under section

15 44B) and by redesignating subsections (n) and

16 (o) as subsections (m) and (n), respectively, and

17 (B) by striking ‘‘section 40(f) or 51(j)’’ in

18 subsection (m) (as redesignated by subpara19 graph (A)) and inserting ‘‘section 40(f), 43, or

20 51(j)’’.

21 (4) Subparagraph (C) of section 38(c)(2) (as in

22 effect on the day before the date of the enactment

23 of the Revenue Reconciliation Act of 1990) is

24 amended by inserting before the period at the end
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1 of the first sentence the following: ‘‘and without re2 gard to the deduction under section 56(h)’’.

3 (5) The amendment made by section

4 1913(b)(2)(C)(i) of the Energy Policy Act of 1992

5 shall apply to taxable years beginning after Decem6 ber 31, 1990.

7 (f) AMENDMENTS RELATED TO SUBTITLE F.—

8 (1)(A) Section 2701(a)(3) is amended by add9 ing at the end thereof the following new subpara10 graph:

11 ‘‘(C) VALUATION OF QUALIFIED PAYMENTS

12 WHERE NO LIQUIDATION, ETC. RIGHTS.—In the

13 case of an applicable retained interest which is

14 described in subparagraph (B)(i) but not sub15 paragraph (B)(ii), the value of the distribution

16 right shall be determined without regard to this

17 section.’’

18 (B) Section 2701(a)(3)(B) is amended by in19 serting ‘‘CERTAIN’’ before ‘‘QUALIFIED’’ in the head20 ing thereof.

21 (C) Sections 2701 (d)(1) and (d)(4) are each

22 amended by striking ‘‘subsection (a)(3)(B)’’ and in23 serting ‘‘subsection (a)(3) (B) or (C)’’.

24 (2) Clause (i) of section 2701(a)(4)(B) is

25 amended by inserting ‘‘(or, to the extent provided in
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1 regulations, the rights as to either income or cap2 ital)’’ after ‘‘income and capital’’.

3 (3)(A) Section 2701(b)(2) is amended by add4 ing at the end thereof the following new subpara5 graph:

6 ‘‘(C) APPLICABLE FAMILY MEMBER.—For

7 purposes of this subsection, the term ‘applicable

8 family member’ includes any lineal descendant

9 of any parent of the transferor or the transfer10 or’s spouse.’’

11 (B) Section 2701(e)(3) is amended—

12 (i) by striking subparagraph (B), and

13 (ii) by striking so much of paragraph (3)

14 as precedes ‘‘shall be treated as holding’’ and

15 inserting:

16 ‘‘(3) ATTRIBUTION OF INDIRECT HOLDINGS

17 AND TRANSFERS.—An individual’’.

18 (C) Section 2704(c)(3) is amended by striking

19 ‘‘section 2701(e)(3)(A)’’ and inserting ‘‘section

20 2701(e)(3)’’.

21 (4) Clause (i) of section 2701(c)(1)(B) is

22 amended to read as follows:

23 ‘‘(i) a right to distributions with re24 spect to any interest which is junior to the

25 rights of the transferred interest,’’.
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1 (5)(A) Clause (i) of section 2701(c)(3)(C) is

2 amended to read as follows:

3 ‘‘(i) IN GENERAL.—Payments under

4 any interest held by a transferor which

5 (without regard to this subparagraph) are

6 qualified payments shall be treated as

7 qualified payments unless the transferor

8 elects not to treat such payments as quali9 fied payments. Payments described in the

10 preceding sentence which are held by an

11 applicable family member shall be treated

12 as qualified payments only if such member

13 elects to treat such payments as qualified

14 payments.’’

15 (B) The first sentence of section

16 2701(c)(3)(C)(ii) is amended to read as follows: ‘‘A

17 transferor or applicable family member holding any

18 distribution right which (without regard to this sub19 paragraph) is not a qualified payment may elect to

20 treat such right as a qualified payment, to be paid

21 in the amounts and at the times specified in such

22 election.’’.

23 (C) The time for making an election under the

24 second sentence of section 2701(c)(3)(C)(i) of the

25 Internal Revenue Code of 1986 (as amended by sub-
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1 paragraph (A)) shall not expire before the due date

2 (including extensions) for filing the transferor’s re3 turn of the tax imposed by section 2501 of such

4 Code for the first calendar year ending after the

5 date of enactment.

6 (6) Section 2701(d)(3)(A)(iii) is amended by

7 striking ‘‘the period ending on the date of’’.

8 (7) Subclause (I) of section 2701(d)(3)(B)(ii) is

9 amended by inserting ‘‘or the exclusion under sec10 tion 2503(b),’’ after ‘‘section 2523,’’.

11 (8) Section 2701(e)(5) is amended—

12 (A) by striking ‘‘such contribution to cap13 ital or such redemption, recapitalization, or

14 other change’’ in subparagraph (A) and insert15 ing ‘‘such transaction’’, and

16 (B) by striking ‘‘the transfer’’ in subpara17 graph (B) and inserting ‘‘such transaction’’.

18 (9) Section 2701(d)(4) is amended by adding at

19 the end thereof the following new subparagraph:

20 ‘‘(C) TRANSFER TO TRANSFERORS.—In

21 the case of a taxable event described in para22 graph (3)(A)(ii) involving a transfer of an ap23 plicable retained interest from an applicable

24 family member to a transferor, this subsection
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1 shall continue to apply to the transferor during

2 any period the transferor holds such interest.’’

3 (10) Section 2701(e)(6) is amended by insert4 ing ‘‘or to reflect the application of subsection (d)’’

5 before the period at the end thereof.

6 (11)(A) Section 2702(a)(3)(A) is amended—

7 (i) by striking ‘‘to the extent’’ and insert8 ing ‘‘if’’ in clause (i),

9 (ii) by striking ‘‘or’’ at the end of clause

10 (i),

11 (iii) by striking the period at the end of

12 clause (ii) and inserting ‘‘, or’’, and

13 (iv) by adding at the end thereof the fol14 lowing new clause:

15 ‘‘(iii) to the extent that regulations

16 provide that such transfer is not inconsist17 ent with the purposes of this section.’’

18 (B)(i) Section 2702(a)(3) is amended by strik19 ing ‘‘incomplete transfer’’ each place it appears and

20 inserting ‘‘incomplete gift’’.

21 (ii) The heading for section 2702(a)(3)(B) is

22 amended by striking ‘‘INCOMPLETE TRANSFER’’ and

23 inserting ‘‘INCOMPLETE GIFT’’.

24 (g) AMENDMENTS RELATED TO SUBTITLE G.—
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1 (1)(A) Subsection (a) of section 1248 is amend2 ed—

3 (i) by striking ‘‘, or if a United States per4 son receives a distribution from a foreign cor5 poration which, under section 302 or 331, is

6 treated as an exchange of stock’’ in paragraph

7 (1), and

8 (ii) by adding at the end thereof the follow9 ing new sentence: ‘‘For purposes of this section,

10 a United States person shall be treated as hav11 ing sold or exchanged any stock if, under any

12 provision of this subtitle, such person is treated

13 as realizing gain from the sale or exchange of

14 such stock.’’.

15 (B) Paragraph (1) of section 1248(e) is amend16 ed by striking ‘‘, or receives a distribution from a

17 domestic corporation which, under section 302 or

18 331, is treated as an exchange of stock’’.

19 (C) Subparagraph (B) of section 1248(f)(1) is

20 amended by striking ‘‘or 361(c)(1)’’ and inserting

21 ‘‘355(c)(1), or 361(c)(1)’’.

22 (D) Paragraph (1) of section 1248(i) is amend23 ed to read as follows:

24 ‘‘(1) IN GENERAL.—If any shareholder of a 10-

25 percent corporate shareholder of a foreign corpora-
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1 tion exchanges stock of the 10-percent corporate

2 shareholder for stock of the foreign corporation,

3 such 10-percent corporate shareholder shall recog4 nize gain in the same manner as if the stock of the

5 foreign corporation received in such exchange had

6 been—

7 ‘‘(A) issued to the 10-percent corporate

8 shareholder, and

9 ‘‘(B) then distributed by the 10-percent

10 corporate shareholder to such shareholder in re11 demption or liquidation (whichever is appro12 priate).

13 The amount of gain recognized by such 10-percent

14 corporate shareholder under the preceding sentence

15 shall not exceed the amount treated as a dividend

16 under this section.’’

17 (2) Section 897 is amended by striking sub18 section (f).

19 (3) Paragraph (13) of section 4975(d) is

20 amended by striking ‘‘section 408(b)’’ and inserting

21 ‘‘section 408(b)(12)’’.

22 (4) Clause (iii) of section 56(g)(4)(D) is amend23 ed by inserting ‘‘, but only with respect to taxable

24 years beginning after December 31, 1989’’ before

25 the period at the end thereof.
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1 (5)(A) Paragraph (11) of section 11701(a) of

2 the Revenue Reconciliation Act of 1990 (and the

3 amendment made by such paragraph) are hereby re4 pealed, and section 7108(r)(2) of the Revenue Rec5 onciliation Act of 1989 shall be applied as if such

6 paragraph (and amendment) had never been en7 acted.

8 (B) Subparagraph (A) shall not apply to any

9 building if the owner of such building establishes to

10 the satisfaction of the Secretary of the Treasury or

11 his delegate that such owner reasonably relied on the

12 amendment made by such paragraph (11).

13 (h) AMENDMENTS RELATED TO SUBTITLE H.—

14 (1)(A) Clause (vi) of section 168(e)(3)(B) is

15 amended by striking ‘‘or’’ at the end of subclause

16 (I), by striking the period at the end of subclause

17 (II) and inserting ‘‘, or’’, and by adding at the end

18 thereof the following new subclause:

19 ‘‘(III) is described in section

20 48(l)(3)(A)(ix) (as in effect on the day be21 fore the date of the enactment of the Reve22 nue Reconciliation Act of 1990).’’

23 (B) Subparagraph (K) of section 168(g)(4) is

24 amended by striking ‘‘section 48(a)(3)(A)(iii)’’ and

25 inserting ‘‘section 48(l)(3)(A)(ix) (as in effect on the
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1 day before the date of the enactment of the Revenue

2 Reconciliation Act of 1990)’’.

3 (2) Clause (ii) of section 172(b)(1)(E) is

4 amended by striking ‘‘subsection (m)’’ and inserting

5 ‘‘subsection (h)’’.

6 (3) Sections 805(a)(4)(E), 832(b)(5)(C)(ii)(II),

7 and 832(b)(5)(D)(ii)(II) are each amended by strik8 ing ‘‘243(b)(5)’’ and inserting ‘‘243(b)(2)’’.

9 (4) Subparagraph (A) of section 243(b)(3) is

10 amended by inserting ‘‘of’’ after ‘‘In the case’’.

11 (5) The subsection heading for subsection (a) of

12 section 280F is amended by striking ‘‘INVESTMENT

13 TAX CREDIT AND’’.

14 (6) Clause (i) of section 1504(c)(2)(B) is

15 amended by inserting ‘‘section’’ before ‘‘243(b)(2)’’.

16 (7) Paragraph (3) of section 341(f) is amended

17 by striking ‘‘351, 361, 371(a), or 374(a)’’ and in18 serting ‘‘351, or 361’’.

19 (8) Paragraph (2) of section 243(b) is amended

20 to read as follows:

21 ‘‘(2) AFFILIATED GROUP.—For purposes of this

22 subsection:

23 ‘‘(A) IN GENERAL.—The term ‘affiliated

24 group’ has the meaning given such term by sec25 tion 1504(b), except that for such purposes sec-
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1 tions 1504(b)(2), 1504(b)(4), and 1504(c) shall

2 not apply.

3 ‘‘(B) GROUP MUST BE CONSISTENT IN

4 FOREIGN TAX TREATMENT.—The requirements

5 of paragraph (1)(A) shall not be treated as

6 being met with respect to any dividend received

7 by a corporation if, for any taxable year which

8 includes the day on which such dividend is re9 ceived—

10 ‘‘(i) 1 or more members of the affili11 ated group referred to in paragraph (1)(A)

12 choose to any extent to take the benefits of

13 section 901, and

14 ‘‘(ii) 1 or more other members of such

15 group claim to any extent a deduction for

16 taxes otherwise creditable under section

17 901.’’

18 (9) The amendment made by section

19 11813(b)(17) of the Revenue Reconciliation Act of

20 1990 shall be applied as if the material stricken by

21 such amendment included the closing parenthesis

22 after ‘‘section 48(a)(5)’’.

23 (10) Paragraph (1) of section 179(d) is amend24 ed—
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1 (A) by striking ‘‘in a trade or business’’

2 and inserting ‘‘a trade or business’’, and

3 (B) by adding at the end thereof the fol4 lowing new sentence: ‘‘Such term shall not in5 clude any property described in section 50(b)

6 and shall not include air conditioning or heating

7 units and horses’’.

8 (11) Subparagraph (E) of section 50(a)(2) is

9 amended by striking ‘‘section 48(a)(5)(A)’’ and in10 serting ‘‘section 48(a)(5)’’.

11 (12) The amendment made by section

12 11801(c)(9)(G)(ii) of the Revenue Reconciliation Act

13 of 1990 shall be applied as if it struck ‘‘Section

14 422A(c)(2)’’ and inserted ‘‘Section 422(c)(2)’’.

15 (13) Subparagraph (B) of section 424(c)(3) is

16 amended by striking ‘‘a qualified stock option, an in17 centive stock option, an option granted under an em18 ployee stock purchase plan, or a restricted stock op19 tion’’ and inserting ‘‘an incentive stock option or an

20 option granted under an employee stock purchase

21 plan’’.

22 (14) Subparagraph (E) of section 1367(a)(2) is

23 amended by striking ‘‘section 613A(c)(13)(B)’’ and

24 inserting ‘‘section 613A(c)(11)(B)’’.
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1 (15) Subparagraph (B) of section 460(e)(6) is

2 amended by striking ‘‘section 167(k)’’ and inserting

3 ‘‘section 168(e)(2)(A)(ii)’’.

4 (16) Subparagraph (C) of section 172(h)(4) is

5 amended by striking ‘‘subsection (b)(1)(M)’’ and in6 serting ‘‘subsection (b)(1)(E)’’.

7 (17) Section 6503 is amended—

8 (A) by redesignating the subsection relat9 ing to extension in case of certain summonses

10 as subsection (j), and

11 (B) by redesignating the subsection relat12 ing to cross references as subsection (k).

13 (18) Paragraph (4) of section 1250(e) is hereby

14 repealed.

15 (19) Subsection (c) of section 2104 is amended

16 by striking ‘‘subparagraph (A), (C), or (D)’’ and in17 serting ‘‘subparagraph (A)’’.

18 (i) EFFECTIVE DATE.—Except as otherwise expressly

19 provided—

20 (1) the amendments made by this section shall

21 be treated as amendments to the Internal Revenue

22 Code of 1986 as amended by the Revenue Reconcili23 ation Act of 1993; and

24 (2) any amendment made by this section shall

25 apply to periods before the date of the enactment of
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1 this section in the same manner as if it had been in2 cluded in the provision of the Revenue Reconciliation

3 Act of 1990 to which such amendment relates.

4 SEC. 3. AMENDMENTS RELATED TO REVENUE RECONCILI5 ATION ACT OF 1993.

6 (a) AMENDMENT RELATED TO SECTION 13114.—

7 Paragraph (2) of section 1044(c) is amended to read as

8 follows:

9 ‘‘(2) PURCHASE.—The taxpayer shall be consid10 ered to have purchased any property if, but for sub11 section (d), the unadjusted basis of such property

12 would be its cost within the meaning of section

13 1012.’’

14 (b) AMENDMENTS RELATED TO SECTION 13142.—

15 (1) Subparagraph (B) of section 13142(b)(6) of

16 the Revenue Reconciliation Act of 1993 is amended

17 to read as follows:

18 ‘‘(B) FULL-TIME STUDENTS, WAIVER AU19 THORITY, AND PROHIBITED DISCRIMINATION.—

20 The amendments made by paragraphs (2), (3),

21 and (4) shall take effect on the date of the en22 actment of this Act.’’

23 (2) Subparagraph (C) of section 13142(b)(6) of

24 such Act is amended by striking ‘‘paragraph (2)’’

25 and inserting ‘‘paragraph (5)’’.
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1 (c) AMENDMENT RELATED TO SECTION 13161.—

2 (1) IN GENERAL.—Subsection (e) of section

3 4001 (relating to inflation adjustment) is amended

4 to read as follows:

5 ‘‘(e) INFLATION ADJUSTMENT.—

6 ‘‘(1) IN GENERAL.—The $30,000 amount in

7 subsection (a) and section 4003(a) shall be increased

8 by an amount equal to—

9 ‘‘(A) $30,000, multiplied by

10 ‘‘(B) the cost-of-living adjustment under

11 section 1(f)(3) for the calendar year in which

12 the vehicle is sold, determined by substituting

13 ‘calendar year 1990’ for ‘calendar year 1992’ in

14 subparagraph (B) thereof.

15 ‘‘(2) ROUNDING.—If any amount as adjusted

16 under paragraph (1) is not a multiple of $2,000,

17 such amount shall be rounded to the next lowest

18 multiple of $2,000.’’

19 (2) EFFECTIVE DATE.—The amendment made

20 by paragraph (1) shall take effect on the date of the

21 enactment of this Act.

22 (d) AMENDMENT RELATED TO SECTION 13201.—

23 Clause (ii) of section 135(b)(2)(B) is amended by insert24 ing before the period at the end thereof the following: ‘‘,
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1 determined by substituting ‘calendar year 1989’ for ‘cal2 endar year 1992’ in subparagraph (B) thereof’’.

3 (e) AMENDMENTS RELATED TO SECTION 13203.—

4 Subsection (a) of section 59 is amended—

5 (1) by striking ‘‘the amount determined under

6 section 55(b)(1)(A)’’ in paragraph (1)(A) and

7 (2)(A)(i) and inserting ‘‘the pre-credit tentative min8 imum tax’’,

9 (2) by striking ‘‘specified in section

10 55(b)(1)(A)’’ in paragraph (1)(C) and inserting

11 ‘‘specified in subparagraph (A)(i) or (B)(i) of section

12 55(b)(1) (whichever applies)’’,

13 (3) by striking ‘‘which would be determined

14 under section 55(b)(1)(A)’’ in paragraph (2)(A)(ii)

15 and inserting ‘‘which would be the pre-credit ten16 tative minimum tax’’, and

17 (4) by adding at the end thereof the following

18 new paragraph:

19 ‘‘(4) PRE-CREDIT TENTATIVE MINIMUM TAX.—

20 For purposes of this subsection, the term ‘pre-credit

21 tentative minimum tax’ means—

22 ‘‘(A) in the case of a taxpayer other than

23 a corporation, the amount determined under the

24 first sentence of section 55(b)(1)(A)(i), or
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1 ‘‘(B) in the case of a corporation, the

2 amount determined under section

3 55(b)(1)(B)(i).’’

4 (f) AMENDMENTS RELATED TO SECTION 13221.—

5 (1) Subparagraph (A) of section 7518(g)(6) is

6 amended by striking ‘‘34 percent’’ and inserting ‘‘35

7 percent’’.

8 (2) Sections 1201(a) and 1561(a) are each

9 amended by striking ‘‘last sentence’’ each place it

10 appears and inserting ‘‘last 2 sentences’’.

11 (g) AMENDMENTS RELATED TO SECTION 13222.—

12 (1) Subparagraph (B) of section 6033(e)(1) is

13 amended by adding at the end thereof the following

14 new clause:

15 ‘‘(iii) COORDINATION WITH SECTION

16 527(f).—This subsection shall not apply to

17 any amount on which tax is imposed by

18 reason of section 527(f).’’.

19 (2) Clause (i) of section 6033(e)(1)(B) is

20 amended by striking ‘‘this subtitle’’ and inserting

21 ‘‘section 501’’.

22 (h) AMENDMENT RELATED TO SECTION 13225.—

23 Paragraph (3) of section 6655(g) is amended by striking

24 all that follows ‘‘ ‘3rd month’ ’’ in the sentence following

25 subparagraph (C) and inserting ‘‘, subsection (e)(2)(A)
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1 shall be applied by substituting ‘2 months’ for ‘3 months’

2 in clause (i)(I), the election under clause (i) of subsection

3 (e)(2)(C) may be made separately for each installment,

4 and clause (ii) of subsection (e)(2)(C) shall not apply.’’.

5 (i) AMENDMENTS RELATED TO SECTION 13231.—

6 (1) Subparagraph (G) of section 904(d)(3) is

7 amended by striking ‘‘section 951(a)(1)(B)’’ and in8 serting ‘‘subparagraph (B) or (C) of section

9 951(a)(1)’’.

10 (2) Paragraph (1) of section 956A(b) is amend11 ed to read as follows:

12 ‘‘(1) the amount (not including a deficit) re13 ferred to in section 316(a)(1) to the extent such

14 amount was accumulated in prior taxable years be15 ginning after September 30, 1993, and’’.

16 (3) Subsection (f) of section 956A is amended

17 by inserting before the period at the end thereof:

18 ‘‘and regulations coordinating the provisions of sub19 sections (c)(3)(A) and (d)’’.

20 (4) Subsection (b) of section 958 is amended by

21 striking ‘‘956(b)(2)’’ each place it appears and in22 serting ‘‘956(c)(2)’’.

23 (5)(A) Subparagraph (A) of section 1297(d)(2)

24 is amended by striking ‘‘The adjusted basis of any

25 asset’’ and inserting ‘‘The amount taken into ac-
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1 count under section 1296(a)(2) with respect to any

2 asset’’.

3 (B) The paragraph heading of paragraph (2) of

4 section 1297(d) is amended to read as follows:

5 ‘‘(2) AMOUNT TAKEN INTO ACCOUNT.—’’.

6 (6) Subsection (e) of section 1297 is amended

7 by inserting ‘‘For purposes of this part—’’ after the

8 subsection heading.

9 (j) AMENDMENT RELATED TO SECTION 13241.—

10 Subparagraph (B) of section 40(e)(1) is amended to read

11 as follows:

12 ‘‘(B) for any period before January 1,

13 2001, during which the rates of tax under sec14 tion 4081(a)(2)(A) are 4.3 cents per gallon.’’

15 (k) AMENDMENT RELATED TO SECTION 13261.—

16 Clause (iii) of section 13261(g)(2)(A) of the Revenue Rec17 onciliation Act of 1993 is amended by striking ‘‘by the

18 taxpayer’’ and inserting ‘‘by the taxpayer or a related per19 son’’.

20 (l) AMENDMENT RELATED TO SECTION 13301.—

21 Subparagraph (B) of section 1397B(d)(5) is amended by

22 striking ‘‘preceding’’.

23 (m) CLERICAL AMENDMENTS.—

24 (1) Subsection (d) of section 39 is amended—
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1 (A) by striking ‘‘45’’ in the heading of

2 paragraph (5) and inserting ‘‘45A’’, and

3 (B) by striking ‘‘45’’ in the heading of

4 paragraph (6) and inserting ‘‘45B’’.

5 (2) Subparagraph (A) of section 108(d)(9) is

6 amended by striking ‘‘paragraph (3)(B)’’ and insert7 ing ‘‘paragraph (3)(C)’’.

8 (3) Subparagraph (C) of section 143(d)(2) is

9 amended by striking the period at the end thereof

10 and inserting a comma.

11 (4) Clause (ii) of section 163(j)(6)(E) is amend12 ed by striking ‘‘which is a’’ and inserting ‘‘which is’’.

13 (5) Subparagraph (A) of section 1017(b)(4) is

14 amended by striking ‘‘subsection (b)(2)(D)’’ and in15 serting ‘‘subsection (b)(2)(E)’’.

16 (6) So much of section 1245(a)(3) as precedes

17 subparagraph (A) thereof is amended to read as fol18 lows:

19 ‘‘(3) SECTION 1245 PROPERTY.—For purposes

20 of this section, the term ‘section 1245 property’

21 means any property which is or has been property

22 of a character subject to the allowance for deprecia23 tion provided in section 167 and is either—’’.

24 (7) Paragraph (2) of section 1394(e) is amend25 ed—
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1 (A) by striking ‘‘(i)’’ and inserting ‘‘(A)’’,

2 and

3 (B) by striking ‘‘(ii)’’ and inserting ‘‘(B)’’.

4 (8) Subsection (m) of section 6501 (as redesig5 nated by section 2) is amended by striking ‘‘or

6 51(j)’’ and inserting ‘‘45B, or 51(j)’’.

7 (9)(A) The section 6714 added by section

8 13242(b)(1) of the Revenue Reconciliation Act of

9 1993 is hereby redesignated as section 6715.

10 (B) The table of sections for part I of sub11 chapter B of chapter 68 is amended by striking

12 ‘‘6714’’ in the item added by such section

13 13242(b)(2) of such Act and inserting ‘‘6715’’.

14 (10) Paragraph (2) of section 9502(b) is

15 amended by inserting ‘‘and before’’ after ‘‘1982,’’.

16 (11) Subsections (a)(2) and (a)(3) of section

17 13206 of the Revenue Reconciliation Act of 1993

18 are each amended by striking ‘‘this section’’ and in19 serting ‘‘this subsection’’.

20 (12) Paragraph (1) of section 13215(c) of the

21 Revenue Reconciliation Act of 1993 is amended by

22 striking ‘‘Public Law 92–21’’ and inserting ‘‘Public

23 Law 98–21’’.

24 (13) Paragraph (2) of section 13311(e) of the

25 Revenue Reconciliation Act of 1993 is amended by
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1 striking ‘‘section 1393(a)(3)’’ and inserting ‘‘section

2 1393(a)(2)’’.

3 (14) Subparagraph (B) of section 117(d)(2) is

4 amended by striking ‘‘section 132(f)’’ and inserting

5 ‘‘section 132(h)’’.

6 (n) EFFECTIVE DATE.—Any amendment made by

7 this section shall take effect as if included in the provision

8 of the Revenue Reconciliation Act of 1993 to which such

9 amendment relates.

10 SEC. 4. MISCELLANEOUS PROVISIONS.

11 (a) APPLICATION OF AMENDMENTS MADE BY TITLE

12 XII OF OMNIBUS BUDGET RECONCILIATION ACT OF

13 1990.—Except as otherwise expressly provided, whenever

14 in title XII of the Omnibus Budget Reconciliation Act of

15 1990 an amendment or repeal is expressed in terms of

16 an amendment to, or repeal of, a section or other provi17 sion, the reference shall be considered to be made to a

18 section or other provision of the Internal Revenue Code

19 of 1986.

20 (b) TREATMENT OF CERTAIN AMOUNTS UNDER

21 HEDGE BOND RULES.—

22 (1) Clause (iii) of section 149(g)(3)(B) is

23 amended to read as follows:

24 ‘‘(iii) AMOUNTS HELD PENDING REIN25 VESTMENT OR REDEMPTION.—Amounts
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1 held for not more than 30 days pending re2 investment or bond redemption shall be

3 treated as invested in bonds described in

4 clause (i).’’

5 (2) The amendment made by paragraph (1)

6 shall take effect as if included in the amendments

7 made by section 7651 of the Omnibus Budget Rec8 onciliation Act of 1989.

9 (c) TREATMENT OF CERTAIN DISTRIBUTIONS

10 UNDER SECTION 1445.—

11 (1) IN GENERAL.—Paragraph (3) of section

12 1445(e) is amended by adding at the end thereof

13 the following new sentence: ‘‘Rules similar to the

14 rules of the preceding provisions of this paragraph

15 shall apply in the case of any distribution to which

16 section 301 applies and which is not made out of the

17 earnings and profits of such a domestic corpora18 tion.’’

19 (2) EFFECTIVE DATE.—The amendment made

20 by paragraph (1) shall apply to distributions after

21 the date of the enactment of this Act.

22 (d) TREATMENT OF CERTAIN CREDITS UNDER SEC23 TION 469.—

24 (1) IN GENERAL.—Subparagraph (B) of section

25 469(c)(3) is amended by adding at the end thereof
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1 the following new sentence: ‘‘If the preceding sen2 tence applies to the net income from any property

3 for any taxable year, any credits allowable under

4 subpart B (other than section 27(a)) or D of part

5 IV of subchapter A for such taxable year which are

6 attributable to such property shall be treated as

7 credits not from a passive activity to the extent the

8 amount of such credits does not exceed the regular

9 tax liability of the taxpayer for the taxable year

10 which is allocable to such net income.’’

11 (2) EFFECTIVE DATE.—The amendment made

12 by paragraph (1) shall apply to taxable years begin13 ning after December 31, 1986.

14 (e) TREATMENT OF DISPOSITIONS UNDER PASSIVE

15 LOSS RULES.—

16 (1) IN GENERAL.—Subparagraph (A) of section

17 469(g)(1) is amended to read as follows:

18 ‘‘(A) IN GENERAL.—If all gain or loss real19 ized on such disposition is recognized, the ex20 cess of—

21 ‘‘(i) any loss from such activity for

22 such taxable year (determined after the ap23 plication of subsection (b)), over

24 ‘‘(ii) any net income or gain for such

25 taxable year from all other passive activi-
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1 ties (determined after the application of

2 subsection (b)),

3 shall be treated as a loss which is not from a

4 passive activity.’’

5 (2) EFFECTIVE DATE.—The amendment made

6 by paragraph (1) shall apply to taxable years begin7 ning after December 31, 1986.

8 (f) MISCELLANEOUS AMENDMENTS TO FOREIGN

9 PROVISIONS.—

10 (1) COORDINATION OF UNIFIED ESTATE TAX

11 CREDIT WITH TREATIES.—Subparagraph (A) of sec12 tion 2102(c)(3) is amended by adding at the end

13 thereof the following new sentence: ‘‘For purposes

14 of the preceding sentence, property shall not be

15 treated as situated in the United States if such

16 property is exempt from the tax imposed by this

17 subchapter under any treaty obligation of the United

18 States.’’

19 (2) TREATMENT OF CERTAIN INTEREST PAID

20 TO RELATED PERSON.—

21 (A) IN GENERAL.—Subparagraph (B) of

22 section 163(j)(1) is amended by inserting before

23 the period at the end thereof the following:

24 ‘‘(and clause (ii) of paragraph (2)(A) shall not
33

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1 apply for purposes of applying this subsection

2 to the amount so treated)’’.

3 (B) EFFECTIVE DATE.—The amendment

4 made by subparagraph (A) shall apply as if in5 cluded in the amendments made by section

6 7210(a) of the Revenue Reconciliation Act of

7 1989.

8 (3) TREATMENT OF INTEREST ALLOCABLE TO

9 EFFECTIVELY CONNECTED INCOME.—

10 (A) IN GENERAL.—

11 (i) Subparagraph (B) of section

12 884(f)(1) is amended by striking ‘‘to the

13 extent’’ and all that follows down through

14 ‘‘subparagraph (A)’’ and inserting ‘‘to the

15 extent that the allocable interest exceeds

16 the interest described in subparagraph

17 (A)’’.

18 (ii) The second sentence of section

19 884(f)(1) is amended by striking ‘‘reason20 ably expected’’ and all that follows down

21 through the period at the end thereof and

22 inserting ‘‘reasonably expected to be alloca23 ble interest.’’

24 (iii) Paragraph (2) of section 884(f) is

25 amended to read as follows:
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•HR 1121 IH

1 ‘‘(2) ALLOCABLE INTEREST.—For purposes of

2 this subsection, the term ‘allocable interest’ means

3 any interest which is allocable to income which is ef4 fectively connected (or treated as effectively con5 nected) with the conduct of a trade or business in

6 the United States.’’

7 (B) EFFECTIVE DATE.—The amendments

8 made by subparagraph (A) shall take effect as

9 if included in the amendments made by section

10 1241(a) of the Tax Reform Act of 1986.

11 (4) CLARIFICATION OF SOURCE RULE.—

12 (A) IN GENERAL.—Paragraph (2) of sec13 tion 865(b) is amended by striking ‘‘863(b)’’

14 and inserting ‘‘863’’.

15 (B) EFFECTIVE DATE.—The amendment

16 made by subparagraph (A) shall take effect as

17 if included in the amendments made by section

18 1211 of the Tax Reform Act of 1986.

19 (5) REPEAL OF OBSOLETE PROVISIONS.—

20 (A) Paragraph (1) of section 6038(a) is

21 amended by striking ‘‘, and’’ at the end of sub22 paragraph (E) and inserting a period, and by

23 striking subparagraph (F).

24 (B) Subsection (b) of section 6038A is

25 amended by adding ‘‘and’’ at the end of para-
35

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1 graph (2), by striking ‘‘, and’’ at the end of

2 paragraph (3) and inserting a period, and by

3 striking paragraph (4).

4 (g) TREATMENT OF ASSIGNMENT OF INTEREST IN

5 CERTAIN BOND-FINANCED FACILITIES.—

6 (1) IN GENERAL.—Subparagraph (A) of section

7 1317(3) of the Tax Reform Act of 1986 is amended

8 by adding at the end thereof the following new sen9 tence: ‘‘A facility shall not fail to be treated as de10 scribed in this subparagraph by reason of an assign11 ment (or an agreement to an assignment) by the

12 governmental unit on whose behalf the bonds are is13 sued of any part of its interest in the property fi14 nanced by such bonds to another governmental

15 unit.’’

16 (2) EFFECTIVE DATE.—The amendment made

17 by paragraph (1) shall take effect as if included in

18 such section 1317 on the date of the enactment of

19 the Tax Reform Act of 1986.

20 (h) CLARIFICATION OF TREATMENT OF MEDICARE

21 ENTITLEMENT UNDER COBRA PROVISIONS.—

22 (1) IN GENERAL.—

23 (A) Subclause (V) of section

24 4980B(f)(2)(B)(i) is amended to read as fol25 lows:
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•HR 1121 IH

1 ‘‘(V) MEDICARE ENTITLEMENT

2 FOLLOWED BY QUALIFYING EVENT.—

3 In the case of a qualifying event de4 scribed in paragraph (3)(B) that oc5 curs less than 18 months after the

6 date the covered employee became en7 titled to benefits under title XVIII of

8 the Social Security Act, the period of

9 coverage for qualified beneficiaries

10 other than the covered employee shall

11 not terminate under this clause before

12 the close of the 36-month period be13 ginning on the date the covered em14 ployee became so entitled.’’

15 (B) Clause (v) of section 602(2)(A) of the

16 Employee Retirement Income Security Act of

17 1974 is amended to read as follows:

18 ‘‘(v) MEDICARE ENTITLEMENT FOL19 LOWED BY QUALIFYING EVENT.—In the

20 case of a qualifying event described in sec21 tion 603(2) that occurs less than 18

22 months after the date the covered em23 ployee became entitled to benefits under

24 title XVIII of the Social Security Act, the

25 period of coverage for qualified bene-
37

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1 ficiaries other than the covered employee

2 shall not terminate under this subpara3 graph before the close of the 36-month pe4 riod beginning on the date the covered em5 ployee became so entitled.’’

6 (C) Clause (iv) of section 2202(2)(A) of

7 the Public Health Service Act is amended to

8 read as follows:

9 ‘‘(iv) MEDICARE ENTITLEMENT FOL10 LOWED BY QUALIFYING EVENT.—In the

11 case of a qualifying event described in sec12 tion 2203(2) that occurs less than 18

13 months after the date the covered em14 ployee became entitled to benefits under

15 title XVIII of the Social Security Act, the

16 period of coverage for qualified bene17 ficiaries other than the covered employee

18 shall not terminate under this subpara19 graph before the close of the 36-month pe20 riod beginning on the date the covered em21 ployee became so entitled.’’

22 (2) EFFECTIVE DATE.—The amendments made

23 by this subsection shall apply to plan years begin24 ning after December 31, 1989.

25 (i) TREATMENT OF CERTAIN REMIC INCLUSIONS.—
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1 (1) IN GENERAL.—Subsection (a) of section

2 860E is amended by adding at the end thereof the

3 following new paragraph:

4 ‘‘(6) COORDINATION WITH MINIMUM TAX.—For

5 purposes of part VI of subchapter A of this chap6 ter—

7 ‘‘(A) the reference in section 55(b)(2) to

8 taxable income shall be treated as a reference

9 to taxable income determined without regard to

10 this subsection,

11 ‘‘(B) the alternative minimum taxable in12 come of any holder of a residual interest in a

13 REMIC for any taxable year shall in no event

14 be less than the excess inclusion for such tax15 able year, and

16 ‘‘(C) any excess inclusion shall be dis17 regarded for purposes of computing the alter18 native tax net operating loss deduction.

19 The preceding sentence shall not apply to any orga20 nization to which section 593 applies, except to the

21 extent provided in regulations prescribed by the Sec22 retary under paragraph (2).’’

23 (2) EFFECTIVE DATE.—The amendment made

24 by paragraph (1) shall take effect as if included in

25 the amendments made by section 671 of the Tax Re-
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1 form Act of 1986 unless the taxpayer elects to apply

2 such amendment only to taxable years beginning

3 after the date of the enactment of this Act.

4 (j) EXEMPTION FROM HARBOR MAINTENANCE TAX

5 FOR CERTAIN PASSENGERS.—

6 (1) IN GENERAL.—Subparagraph (D) of section

7 4462(b)(1) (relating to special rule for Alaska, Ha8 waii, and possessions) is amended by inserting be9 fore the period the following: ‘‘, or passengers trans10 ported on United States flag vessels operating solely

11 within the State waters of Alaska or Hawaii and ad12 jacent international waters’’.

13 (2) EFFECTIVE DATE.—The amendment made

14 by paragraph (1) shall take effect as if included in

15 the amendments made by section 1402(a) of the

16 Harbor Maintenance Revenue Act of 1986.

17 (k) AMENDMENTS RELATED TO REVENUE PROVI18 SIONS OF ENERGY POLICY ACT OF 1992.—

19 (1) Effective with respect to taxable years be20 ginning after December 31, 1990, subclause (II) of

21 section 53(d)(1)(B)(iv) is amended to read as fol22 lows:

23 ‘‘(II) the adjusted net minimum

24 tax for any taxable year is the amount

25 of the net minimum tax for such year
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1 increased in the manner provided in

2 clause (iii).’’

3 (2) Subsection (g) of section 179A is redesig4 nated as subsection (f).

5 (3) Subparagraph (E) of section 6724(d)(3) is

6 amended by striking ‘‘section 6109(f)’’ and inserting

7 ‘‘6109(h)’’.

8 (4)(A) Subsection (d) of section 30 is amend9 ed—

10 (i) by inserting ‘‘(determined without re11 gard to subsection (b)(3))’’ before the period at

12 the end thereof, and

13 (ii) by adding at the end thereof the follow14 ing new paragraph:

15 ‘‘(4) ELECTION TO NOT TAKE CREDIT.—No

16 credit shall be allowed under subsection (a) for any

17 vehicle if the taxpayer elects to not have this section

18 apply to such vehicle.’’

19 (B) Subsection (m) of section 6501 (as redesig20 nated by section 101) is amended by striking ‘‘sec21 tion 40(f)’’ and inserting ‘‘section 30(d)(4), 40(f)’’.

22 (5) Subclause (III) of section 501(c)(21)(D)(ii)

23 is amended by striking ‘‘section 101(6)’’ and insert24 ing ‘‘section 101(7)’’ and by striking ‘‘1752(6)’’ and

25 inserting ‘‘1752(7)’’.
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1 (6) Paragraph (1) of section 1917(b) of the En2 ergy Policy Act of 1992 shall be applied as if ‘‘at a

3 rate’’ appeared instead of ‘‘at the rate’’ in the mate4 rial proposed to be stricken.

5 (7) Paragraph (2) of section 1921(b) of the En6 ergy Policy Act of 1992 shall be applied as if a

7 comma appeared after ‘‘(2)’’ in the material pro8 posed to be stricken.

9 (8) Subsection (a) of section 1937 of the En10 ergy Policy Act of 1992 shall be applied as if ‘‘Sub11 part B’’ appeared instead of ‘‘Subpart C’’.

12 (l) TREATMENT OF QUALIFIED FOOTBALL COACHES

13 PLAN.—

14 (1) IN GENERAL.—Section 1022 of title II of

15 the Employee Retirement Income Security Act of

16 1974 is amended by adding at the end thereof the

17 following new subsection:

18 ‘‘(i) QUALIFIED FOOTBALL COACHES PLAN.—For

19 purposes of determining the qualified plan status of a

20 qualified football coaches plan, section 3(37)(F) shall be

21 treated as part of this title and a qualified football coaches

22 plan shall be treated as a multiemployer collectively bar23 gained plan for purposes of the Internal Revenue Code

24 of 1986.’’
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1 (2) EFFECTIVE DATE.—The amendment made

2 by paragraph (1) shall apply to years beginning

3 after the date of the enactment of Public Law 100–

4 202.

5 (m) DETERMINATION OF UNRECOVERED INVEST6 MENT IN ANNUITY CONTRACT.—

7 (1) IN GENERAL.—Subparagraph (A) of section

8 72(b)(4) is amended by inserting ‘‘(determined with9 out regard to subsection (c)(2))’’ after ‘‘contract’’.

10 (2) EFFECTIVE DATE.—The amendment made

11 by paragraph (1) shall take effect as if included in

12 the amendments made by section 1122(c) of the Tax

13 Reform Act of 1986.

14 (n) MODIFICATIONS TO ELECTION TO INCLUDE

15 CHILD’S INCOME ON PARENT’S RETURN.—

16 (1) ELIGIBILITY FOR ELECTION.—Clause (ii) of

17 section 1(g)(7)(A) (relating to election to include

18 certain unearned income of child on parent’s return)

19 is amended to read as follows:

20 ‘‘(ii) such gross income is more than

21 the amount described in paragraph

22 (4)(A)(ii)(I) and less than 10 times the

23 amount so described,’’.
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1 (2) COMPUTATION OF TAX.—Subparagraph (B)

2 of section 1(g)(7) (relating to income included on

3 parent’s return) is amended—

4 (A) by striking ‘‘$1,000’’ in clause (i) and

5 inserting ‘‘twice the amount described in para6 graph (4)(A)(ii)(I)’’, and

7 (B) by amending subclause (II) of clause

8 (ii) to read as follows:

9 ‘‘(II) for each such child, 15 per10 cent of the lesser of the amount de11 scribed in paragraph (4)(A)(ii)(I) or

12 the excess of the gross income of such

13 child over the amount so described,

14 and’’.

15 (3) MINIMUM TAX.—Subparagraph (B) of sec16 tion 59(j)(1) is amended by striking ‘‘$1,000’’ and

17 inserting ‘‘twice the amount in effect for the taxable

18 year under section 63(c)(5)(A)’’.

19 (4) EFFECTIVE DATE.—The amendments made

20 by this subsection shall apply to taxable years begin21 ning after December 31, 1994.

22 (o) MISCELLANEOUS CLERICAL AMENDMENTS.—

23 (1) Subclause (II) of section 56(g)(4)(C)(ii) is

24 amended by striking ‘‘of the subclause’’ and insert25 ing ‘‘of subclause’’.
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1 (2) Paragraph (2) of section 72(m) is amended

2 by inserting ‘‘and’’ at the end of subparagraph (A),

3 by striking subparagraph (B), and by redesignating

4 subparagraph (C) as subparagraph (B).

5 (3) Paragraph (2) of section 86(b) is amended

6 by striking ‘‘adusted’’ and inserting ‘‘adjusted’’.

7 (4)(A) The heading for section 112 is amended

8 by striking ‘‘COMBAT PAY’’ and inserting ‘‘COM9 BAT ZONE COMPENSATION’’.

10 (B) The item relating to section 112 in the

11 table of sections for part III of subchapter B of

12 chapter 1 is amended by striking ‘‘combat pay’’ and

13 inserting ‘‘combat zone compensation’’.

14 (C) Paragraph (1) of section 3401(a) is amend15 ed by striking ‘‘combat pay’’ and inserting ‘‘combat

16 zone compensation’’.

17 (5) Clause (i) of section 172(h)(3)(B) is amend18 ed by striking the comma at the end thereof and in19 serting a period.

20 (6) Clause (ii) of section 543(a)(2)(B) is

21 amended by striking ‘‘section 563(c)’’ and inserting

22 ‘‘section 563(d)’’.

23 (7) Paragraph (1) of section 958(a) is amended

24 by striking ‘‘sections 955(b)(1)(A) and (B),
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1 955(c)(2)(A)(ii), and 960(a)(1)’’ and inserting ‘‘sec2 tion 960(a)(1)’’.

3 (8) Subsection (g) of section 642 is amended by

4 striking ‘‘under 2621(a)(2)’’ and inserting ‘‘under

5 section 2621(a)(2)’’.

6 (9) Section 1463 is amended by striking ‘‘this

7 subsection’’ and inserting ‘‘this section’’.

8 (10) Subsection (k) of section 3306 is amended

9 by inserting a period at the end thereof.

10 (11) The item relating to section 4472 in the

11 table of sections for subchapter B of chapter 36 is

12 amended by striking ‘‘and special rules’’.

13 (12) Paragraph (2) of section 4978(b) is

14 amended by striking the period at the end of sub15 paragraph (A) and inserting a comma, and by strik16 ing the period and quotation marks at the end of

17 subparagraph (B) and inserting a comma.

18 (13) Paragraph (3) of section 5134(c) is

19 amended by striking ‘‘section 6662(a)’’ and inserting

20 ‘‘section 6665(a)’’.

21 (14) Paragraph (2) of section 5206(f) is

22 amended by striking ‘‘section 5(e)’’ and inserting

23 ‘‘section 105(e)’’.
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1 (15) Paragraph (1) of section 6050B(c) is

2 amended by striking ‘‘section 85(c)’’ and inserting

3 ‘‘section 85(b)’’.

4 (16) Subsection (k) of section 6166 is amended

5 by striking paragraph (6).

6 (17) Subsection (e) of section 6214 is amended

7 to read as follows:

8 ‘‘(e) CROSS REFERENCE.—

‘‘For provision giving Tax Court jurisdiction to

order a refund of an overpayment and to award

sanctions, see section 6512(b)(2).’’

9 (18) The section heading for section 6043 is

10 amended by striking the semicolon and inserting a

11 comma.

12 (19) The item relating to section 6043 in the

13 table of sections for subpart B of part III of sub14 chapter A of chapter 61 is amended by striking the

15 semicolon and inserting a comma.

16 (20) The table of sections for part I of sub17 chapter A of chapter 68 is amended by striking the

18 item relating to section 6662.

19 (21)(A) Section 7232 is amended—

20 (i) by striking ‘‘LUBRICATING OIL,’’ in

21 the heading, and

22 (ii) by striking ‘‘lubricating oil,’’ in the

23 text.
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1 (B) The table of sections for part II of sub2 chapter A of chapter 75 is amended by striking ‘‘lu3 bricating oil,’’ in the item relating to section 7232.

4 (22) Paragraph (1) of section 6701(a) of the

5 Omnibus Budget Reconciliation Act of 1989 is

6 amended by striking ‘‘subclause (IV)’’ and inserting

7 ‘‘subclause (V)’’.

8 (23) Clause (ii) of section 7304(a)(2)(D) of

9 such Act is amended by striking ‘‘subsection (c)(2)’’

10 and inserting ‘‘subsection (c)’’.

11 (24) Paragraph (1) of section 7646(b) of such

12 Act is amended by striking ‘‘section 6050H(b)(1)’’

13 and inserting ‘‘section 6050H(b)(2)’’.

14 (25) Paragraph (10) of section 7721(c) of

15 such Act is amended by striking ‘‘section

16 6662(b)(2)(C)(ii)’’ and inserting ‘‘section

17 6661(b)(2)(C)(ii)’’.

18 (26) Subparagraph (A) of section 7811(i)(3) of

19 such Act is amended by inserting ‘‘the first place it

20 appears’’ before ‘‘in clause (i)’’.

21 (27) Paragraph (10) of section 7841(d) of

22 such Act is amended by striking ‘‘section 381(a)’’

23 and inserting ‘‘section 381(c)’’.
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1 (28) Paragraph (2) of section 7861(c) of such

2 Act is amended by inserting ‘‘the second place it ap3 pears’’ before ‘‘and inserting’’.

4 (29) Paragraph (1) of section 460(b) is amend5 ed by striking ‘‘the look-back method of paragraph

6 (3)’’ and inserting ‘‘the look-back method of para7 graph (2)’’.

8 (30) Subparagraph (C) of section 50(a)(2) is

9 amended by striking ‘‘subsection (c)(4)’’ and insert10 ing ‘‘subsection (d)(5)’’.

11 (31) Subparagraph (B) of section 172(h)(4) is

12 amended by striking the material following the head13 ing and preceding clause (i) and inserting ‘‘For pur14 poses of subsection (b)(2)—’’.

15 (32) Subparagraph (A) of section 355(d)(7) is

16 amended by inserting ‘‘section’’ before ‘‘267(b)’’.

17 (33) Subparagraph (C) of section 420(e)(1) is

18 amended by striking ‘‘mean’’ and inserting ‘‘means’’.

19 (34) Paragraph (4) of section 537(b) is amend20 ed by striking ‘‘section 172(i)’’ and inserting ‘‘sec21 tion 172(f)’’.

22 (35) Subparagraph (B) of section 613(e)(1) is

23 amended by striking the comma at the end thereof

24 and inserting a period.
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1 (36) Paragraph (4) of section 856(a) is amend2 ed by striking ‘‘section 582(c)(5)’’ and inserting

3 ‘‘section 582(c)(2)’’.

4 (37) Sections 904(f)(2)(B)(i) and

5 907(c)(4)(B)(iii) are each amended by inserting ‘‘(as

6 in effect on the day before the date of the enactment

7 of the Revenue Reconciliation Act of 1990)’’ after

8 ‘‘section 172(h)’’.

9 (38) Subsection (b) of section 936 is amended

10 by striking ‘‘subparagraphs (D)(ii)(I)’’ and inserting

11 ‘‘subparagraphs (D)(ii)’’.

12 (39) Subsection (c) of section 2104 is amended

13 by striking ‘‘subparagraph (A), (C), or (D) of sec14 tion 861(a)(1)’’ and inserting ‘‘section

15 861(a)(1)(A)’’.

16 (40) Paragraph (1) of section 5002(b) is

17 amended by striking ‘‘section 5041(c)’’ and inserting

18 ‘‘section 5041(d)’’.

19 (41) Section 6038 is amended by redesignating

20 the subsection relating to cross references as sub21 section (f).

22 (42) Clause (iv) of section 6103(e)(1)(A) is

23 amended by striking all that follows ‘‘provisions of’’

24 and inserting ‘‘section 1(g) or 59(j);’’.
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•HR 1121 IH

1 (43) The subsection (f) of section 6109 of the

2 Internal Revenue Code of 1986 which was added by

3 section 2201(d) of Public Law 101–624 is redesig4 nated as subsection (g).

5 (44) Subsection (b) of section 7454 is amended

6 by striking ‘‘section 4955(e)(2)’’ and inserting ‘‘sec7 tion 4955(f)(2)’’.

8 (45) Subsection (d) of section 11231 of the

9 Revenue Reconciliation Act of 1990 shall be applied

10 as if ‘‘comma’’ appeared instead of ‘‘period’’ and as

11 if the paragraph (9) proposed to be added ended

12 with a comma.

13 (46) Paragraph (1) of section 11303(b) of the

14 Revenue Reconciliation Act of 1990 shall be applied

15 as if ‘‘paragraph’’ appeared instead of ‘‘subpara16 graph’’ in the material proposed to be stricken.

17 (47) Subsection (f) of section 11701 of the Rev18 enue Reconciliation Act of 1990 is amended by in19 serting ‘‘(relating to definitions)’’ after ‘‘section

20 6038(e)’’.

21 (48) Subsection (i) of section 11701 of the Rev22 enue Reconciliation Act of 1990 shall be applied as

23 if ‘‘subsection’’ appeared instead of ‘‘section’’ in the

24 material proposed to be stricken.
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1 (49) Subparagraph (B) of section 11801(c)(2)

2 of the Revenue Reconciliation Act of 1990 shall be

3 applied as if ‘‘section 56(g)’’ appeared instead of

4 ‘‘section 59(g)’’.

5 (50) Subparagraph (C) of section 11801(c)(8)

6 of the Revenue Reconciliation Act of 1990 shall be

7 applied as if ‘‘reorganizations’’ appeared instead of

8 ‘‘reorganization’’ in the material proposed to be

9 stricken.

10 (51) Subparagraph (H) of section 11801(c)(9)

11 of the Revenue Reconciliation Act of 1990 shall be

12 applied as if ‘‘section 1042(c)(1)(B)’’ appeared in13 stead of ‘‘section 1042(c)(2)(B)’’.

14 (52) Subparagraph (F) of section 11801(c)(12)

15 of the Revenue Reconciliation Act of 1990 shall be

16 applied as if ‘‘and (3)’’ appeared instead of ‘‘and

17 (E)’’.

18 (53) Subparagraph (A) of section 11801(c)(22)

19 of the Revenue Reconciliation Act of 1990 shall be

20 applied as if ‘‘chapters 21’’ appeared instead of

21 ‘‘chapter 21’’ in the material proposed to be

22 stricken.

23 (54) Paragraph (3) of section 11812(b) of the

24 Revenue Reconciliation Act of 1990 shall be applied
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•HR 1121 IH

1 by not executing the amendment therein to the

2 heading of section 42(d)(5)(B).

3 (55) Clause (i) of section 11813(b)(9)(A) of the

4 Revenue Reconciliation Act of 1990 shall be applied

5 as if a comma appeared after ‘‘(3)(A)(ix)’’ in the

6 material proposed to be stricken.

7 (56) Subparagraph (F) of section 11813(b)(13)

8 of the Revenue Reconciliation Act of 1990 shall be

9 applied as if ‘‘tax’’ appeared after ‘‘investment’’ in

10 the material proposed to be stricken.

11 (57) Paragraph (19) of section 11813(b) of the

12 Revenue Reconciliation Act of 1990 shall be applied

13 as if ‘‘Paragraph (20) of section 1016(a), as redesig14 nated by section 11801,’’ appeared instead of ‘‘Para15 graph (21) of section 1016(a)’’.

16 (58) Paragraph (5) section 8002(a) of the Sur17 face Transportation Revenue Act of 1991 shall be

18 applied as if ‘‘4481(e)’’ appeared instead of

19 ‘‘4481(c)’’.

20 (59) Section 7872 is amended—

21 (A) by striking ‘‘foregone’’ each place it

22 appears in subsections (a) and (e)(2) and in23 serting ‘‘forgone’’, and

24 (B) by striking ‘‘FOREGONE’’ in the head25 ing for subsection (e) and the heading for para-
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•HR 1121 IH

1 graph (2) of subsection (e) and inserting ‘‘FOR2 GONE’’.

3 (60) Paragraph (7) of section 7611(h) is

4 amended by striking ‘‘appropriate’’ and inserting

5 ‘‘appropriate’’.

6 (61) The heading of paragraph (3) of section

7 419A(c) is amended by striking ‘‘SEVERENCE’’ and

8 inserting ‘‘SEVERANCE’’.

9 (62) Clause (ii) of section 807(d)(3)(B) is

10 amended by striking ‘‘Commissioners’ ’’ and insert11 ing ‘‘Commissioners’ ’’.

12 (63) Subparagraph (B) of section 1274A(c)(1)

13 is amended by striking ‘‘instrument’’ and inserting

14 ‘‘instrument’’.

15 (64) Subparagraph (B) of section 724(d)(3) by

16 striking ‘‘Subparagraph’’ and inserting ‘‘Subpara17 graph’’.

18 (65) The last sentence of paragraph (2) of sec19 tion 42(c) is amended by striking ‘‘of 1988’’.

20 (66) Paragraph (1) of section 9707(d) is

21 amended by striking ‘‘diligence,’’ and inserting ‘‘dili22 gence’’.

23 (67) Subsection (c) of section 4977 is amended

24 by striking ‘‘section 132(g)(2)’’ and inserting ‘‘sec25 tion 132(h)’’.
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•HR 1121 IH

1 (68) The last sentence of section 401(a)(20) is

2 amended by striking ‘‘section 211’’ and inserting

3 ‘‘section 521’’.

4 (69) Subparagraph (A) of section 402(g)(3) is

5 amended by striking ‘‘subsection (a)(8)’’ and insert6 ing ‘‘subsection (e)(3)’’.

7 (70) The last sentence of section 403(b)(10) is

8 amended by striking ‘‘an direct’’ and inserting ‘‘a di9 rect’’.

10 (71) Subparagraph (A) of section 4973(b)(1) is

11 amended by striking ‘‘sections 402(c)’’ and inserting

12 ‘‘section 402(c)’’.

13 (72) Paragraph (12) of section 3405(e) is

14 amended by striking ‘‘(b)(3)’’ and inserting

15 ‘‘(b)(2)’’.

16 (73) Paragraph (41) of section 521(b) of the

17 Unemployment Compensation Amendments of 1992

18 shall be applied as if ‘‘section’’ appeared instead of

19 ‘‘sections’’ in the material proposed to be stricken.

20 (74) Paragraph (27) of section 521(b) of the

21 Unemployment Compensation Amendments of 1992

22 shall be applied as if ‘‘Section 691(c)(5)’’ appeared

23 instead of ‘‘Section 691(c)’’.
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•HR 1121 IH

1 (75) Paragraph (5) of section 860F(a) is

2 amended by striking ‘‘paragraph (1)’’ and inserting

3 ‘‘paragraph (2)’’.

4 (76) Paragraph (1) of section 415(k) is amend5 ed by adding ‘‘or’’ at the end of subparagraph (C),

6 by striking subparagraphs (D) and (E), and by re7 designating subparagraph (F) as subparagraph (D).

8 (77) Paragraph (2) of section 404(a) is amend9 ed by striking ‘‘(18),’’.

10 (78) Clause (ii) of section 72(p)(4)(A) is

11 amended to read as follows:

12 ‘‘(ii) SPECIAL RULE.—The term

13 ‘qualified employer plan’ shall not include

14 any plan which was (or was determined to

15 be) a qualified employer plan or a govern16 ment plan.’’

17 (79) Sections 461(i)(3)(C) and

18 1274(b)(3)(B)(i) are each amended by striking ‘‘sec19 tion 6662(d)(2)(C)(ii)’’ and inserting ‘‘section

20 6662(d)(2)(C)(iii)’’.

21 (80) Subsection (a) of section 164 is amended

22 by striking the paragraphs relating to the genera23 tion-skipping tax and the environmental tax imposed

24 by section 59A and by inserting after paragraph (3)

25 the following new paragraphs:
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•HR 1121 IH

1 ‘‘(4) The GST tax imposed on income distribu2 tions.

3 ‘‘(5) The environmental tax imposed by section

4 59A.’’

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