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[House Report 106-90]
[From the U.S. Government Publishing Office]

106th Congress                                                   Report
  1st Session           HOUSE OF REPRESENTATIVES                 106-90

=======================================================================

 
TAX RELIEF FOR PERSONNEL IN THE FEDERAL REPUBLIC OF YUGOSLAVIA (SERBIA/
                  MONTENEGRO) AND CERTAIN OTHER AREAS

                                _______
                                

 April 13, 1999.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

                                _______

    Mr. Archer, from the Committee on Ways and Means, submitted the 
                               following

                              R E P O R T

                        [To accompany H.R. 1376]

      [Including cost estimate of the Congressional Budget Office]

    The Committee on Ways and Means to whom was referred the 
bill (H.R. 1376) 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, 
having considered the same, report favorably thereon with an 
amendment and recommend that the bill as amended do pass.

                                CONTENTS

                                                                   Page
 I.  Introduction................................................     2
        A. Purpose and Summary...................................     2
        B. Background and Need for Legislation...................     2
        C. Legislative History...................................     2
II. Explanation of the Bill......................................     2
III.Vote of the Committee........................................     8

IV. Budget Effects of the Bill...................................     8
        A. Committee Estimates of Budgetary Effects..............     8
        B. Statement Regarding New Budget Authority and Tax 
            Expenditures.........................................    10
        C. Cost Estimate Prepared by the Congressional Budget 
            Office...............................................    10
 V. Other Matters To Be Discussed Under Rules of the House.......    11
        A. Committee Oversight Findings and Recommendations......    11
        B. Summary of Findings and Recommendations of the 
            Committee on Government Reform.......................    11
        C. Constitutional Authority Statement....................    11
        D. Information Relating to Unfunded Mandates.............    11
        E. Applicability of House Rule XX15(c)...................    12
        F. Tax Complexity Analysis...............................    12

    The amendment if as follows:
    In section 1(b) insert ``(above the 39th parallel)'' after 
``the northern Ionian Sea''.

                            I. INTRODUCTION

                         A. Purpose and Summary

    The bill (H.R. 1376): (1) provides that service in a 
qualified hazardous duty area (Federal Republic of Yugoslavia 
(Serbia/Montenegro), Albania, the Adriatic Sea, and the 
Northern Ionian Sea) is to be treated as if it were a combat 
zone; and (2) makes the suspension of time provisions of Code 
section 7508 applicable to personnel serving as part of 
``Operation Allied Force'' outside those areas.

                 B. Background and Need for Legislation

    The bill is intended to treat service by United States 
Armed Forces (and support) personnel in the Federal Republic of 
Yugoslavia (Serbia/Montenegro), Albania, the Adriatic Sea, and 
the Northern Ionian Sea as if it were combat zone service for 
purposes of the Internal Revenue Code. The bill also makes the 
suspension of time provisions of Code section 7508 applicable 
to personnel serving as part of Operation Allied Force ourside 
those areas.

                         C. Legislative History

    H.R. 1376 was introduced by Mr. Archer and others on April 
13, 1999, and was marked up by the Committee on April 13, 1999. 
The bill was ordered favorably reported (by voice vote) with 
amendment on April 13, 1999.

                      II. EXPLANATION OF THE BILL

                              Present Law

General time limits for filing tax returns

    Present law provides that individuals generally must file 
their Federal income tax returns by April 15 of the year 
following the close of a taxable year (sec. 6072). Present law 
also provides that the Secretary may grant reasonable 
extensions of time for filing such returns (sec. 6081). 
Treasury regulations provide an additional automatic two-month 
extension (until June 15 for calendar-year individuals) for 
United States citizens and residents in military or naval 
service on duty on April 15 of the following year (the 
otherwise applicable due date of the return) outside the United 
States (Treas. Reg. sec. 1.6081-5(a)(6)). No action is 
necessary to apply for this extension, but taxpayers must 
indicate on their returns (when filed) that they are claiming 
this extension. Unlike most extensions of time to file, this 
extension applies to both filing returns and paying the tax 
due.
    Treasury regulations also provide, upon application on the 
proper form, an automatic four-month extension (until August 15 
for calendar-year individuals) for any individual timely filing 
that form and paying the amount of tax estimated to be due 
(Treas. Reg. sec. 1.6081-4).
    In general, individuals must make quarterly estimated tax 
payments by April 15, June 15, September 15, and January 15 of 
the following taxable year. Wage withholding is considered to 
be a payment of estimated taxes.

Suspension of time periods

    In general, present law suspends the period of time for 
performing various acts under the Internal Revenue Code, such 
as filing tax returns, paying taxes, or filing a claim for 
credit or refund of tax, for any individual serving in the 
Armed Forces of the United States in an area designated as a 
``combat zone'' during the period of combatant activities (sec. 
7508). An individual who becomes a prisoner of war is 
considered to continue in active service and is therefore also 
eligible for these suspension of time provisions. The 
suspension of time also applies to an individual serving in 
support of such Armed Forces in the combat zone, such as Red 
Cross personnel, accredited correspondents, and civilian 
personnel acting under the direction of the Armed Forces in 
support of those Forces. The designation of a combat zone must 
be made by the President in an Executive Order. The President 
must also designate the period of combatant activities in the 
combat zone (the starting date and the termination date of 
combat).
    The suspension of time encompasses the period of service in 
the combat zone during the period of combatant activities in 
the zone, as well as (1) any time of continuous qualified 
hospitalization resulting from injury received in the combat 
zone \1\ or (2) time in missing in action status, plus the next 
180 days.
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    \1\ Two special rules apply to continuous hospitalization inside 
the United States. First, the suspension of time provisions based on 
continuous hospitalization inside the United States are applicable only 
to the hospitalized individual; they are not applicable to the spouse 
of such individual. Second, in no event do the suspension of time 
provisions based on continuous hospitalization inside the United States 
extend beyond five years from the date the individual returns to the 
United States. These two special rules do not apply to continuous 
hospitalization outside the United States.
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    The suspension of time applies to the following acts:
          (1) Filing any return of income, estate, or gift tax 
        (except employment and withholding taxes);
          (2) Payment of any income, estate, or gift tax 
        (except employment and withholding taxes);
          (3) Filing a petition with the Tax Court for 
        redetermination of a deficiency, or for review of a 
        decision rendered by the Tax Court;
          (4) Allowance of a credit or refund of any tax;
          (5) Filing a claim for credit or refund of any tax;
          (6) Bringing suit upon any such claim for credit or 
        refund;
          (7) Assessment of any tax;
          (8) Giving or making any notice or demand for the 
        payment of any tax, or with respect to any liability to 
        the United States in respect of any tax;
          (9) Collection of the amount of any liability in 
        respect of any tax;
          (10) Bringing suit by the United States in respect of 
        any liability in respect of any tax; and
          (11) Any other act required or permitted under the 
        internal revenue laws specified in regulations 
        prescribed under section 7508 by the Secretary of the 
        Treasury.
Individuals may, if they choose, perform any of these acts 
during the period of suspension.
    Spouses of qualifying individuals are entitled to the same 
suspension of time, except that the spouse is ineligible for 
this suspension for any taxable year beginning more than two 
years after the date of termination of combatant activities in 
the combat zone.

Exclusion for combat zone compensation

    Gross income does not include certain combat zone 
compensation of members of the Armed Forces (sec. 112). If 
enlisted personnel serve in a combat zone during any part of 
any month, military pay for that month is excluded from gross 
income. In addition, if enlisted personnel are hospitalized as 
a result of injuries, wounds, or disease incurred in a combat 
zone, military pay for that month is also excluded from gross 
income; this exclusion is limited, however, to hospitalization 
during any part of any month beginning not more than two years 
after the end of combat in the zone. In the case of 
commissioned officers, these exclusions from income are limited 
to the maximum enlisted amount \2\ of military pay.
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    \2\ This is defined as the highest rate of basic pay at the highest 
pay grade applicable for that month to any enlisted member of the Armed 
Forces of the United States, plus, in the case of an officer entitled 
to combat pay, the amount of combat pay payable to that officer for 
that month. (sec. 112(c)(5)).
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    Income tax withholding does not apply to military pay to 
the extent that an employee (whether enlisted personnel or 
commissioned officer) is entitled to the exclusion from income 
for combat pay (sec. 3401(a)(1)).

Exemption from tax upon death in a combat zone

    An individual in active service as a member of the Armed 
Forces who dies while serving in a combat zone (or as a result 
of wounds, disease, or injury received while serving in a 
combat zone) is not subject to income tax for the year of death 
(as well as for any prior taxable year ending on or after the 
first day the individual served in the combat zone) (sec. 692). 
Special computational rules apply in the case of joint returns. 
A reduction in estate taxes is also provided with respect to 
individuals dying under these circumstances (sec. 2201).
    Special rules permit the filing of a joint return where a 
spouse is in missing status as a result of service in a combat 
zone (sec. 6013(f)(1)). Special rules for determining surviving 
spouse status apply where the deceased spouse was in missing 
status as a result of service in a combat zone (sec. 2(a)(3)).

Exemption from telephone excise tax

    The telephone excise tax is not imposed on ``any toll 
telephone service'' that originates in a combat zone (sec. 
4253(d)).

Operation Desert Storm: Executive Order designating Persian Gulf Area 
        as a combat zone

    On January 21, 1991, President Bush signed Executive Order 
12744, designating the Persian Gulf Area as a combat zone. This 
designation was retroactive to January 17, 1991, the date 
combat commenced in that area, and continues in effect until 
terminated by another Executive Order. An Executive Order 
terminating this combat zone designation has not been issued. 
Thus, individuals serving in the Persian Gulf Area are eligible 
for the suspension of time provisions and military pay 
exclusions (among other provisions) described above, beginning 
on January 17, 1991.
    The Executive Order specifies that the Persian Gulf Area is 
the Persian Gulf, the Red Sea, the Gulf of Oman, part of the 
Arabian Sea, the Gulf of Aden, and the entire land areas of 
Iraq, Kuwait, Saudi Arabia, Oman, Bahrain, Qatar, and the 
United Arab Emirates.

Operation Desert Shield: Legislative extension of time

    On January 30, 1991, President Bush signed Public Law 102-
2. This Act amended section 7508 by providing that any 
individual who performs Desert Shield services (and the spouse 
of such an individual) is entitled to the benefits of the 
suspension of time provisions of section 7508. Desert Shield 
services are defined as services in the Armed Forces of the 
United States (or in support of those Armed Forces) if such 
services are performed in the area designated by the President 
as the ``Persian Gulf Desert Shield area'' and such services 
are performed during the period beginning August 2, 1990, and 
ending on the date on which any portion of the area was 
designated by the President as a combat zone pursuant to 
section 112 (which was January 17, 1991).

Operation Joint Endeavor: Administrative extension of time

    On December 12, 1995, the Internal Revenue Service 
announced \3\ that it was administratively extending the time 
to file tax returns until December 15, 1996, for members of the 
Armed Forces ``departing `Operation Joint Endeavor' '' on or 
after March 1, 1996. In addition, the IRS stated that the 
penalties for failure to file tax returns and failure to pay 
taxes would not be assessed with respect to these individuals. 
Also, the IRS stated that it would administratively place any 
balance due accounts into suspense status and suspend 
examinations while the member is serving in ``Operation Joint 
Endeavor.''
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    \3\ Letter dated December 12, 1995, from John T. Lyons, Assistant 
Commissioner (International), Internal Revenue Service, to Lt. Col. 
David M. Pronchick, Armed Forces Tax Counsel, Department of Defense.
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Operation Joint Endeavor and Operation Able Sentry: Legislative 
        treatment as if a combat zone

    Pursuant to Public Law 104-117,\4\ a qualified hazardous 
duty area is treated in the same manner as if it were a combat 
zone for purposes of the following provisions of the Code:
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    \4\ 110 Stat. 827 (March 20, 1996).
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          (1) the special rule for determining surviving spouse 
        status where the deceased spouse was in missing status 
        as a result of service in a combat zone (sec. 2(a)(3));
          (2) the exclusions from income for combat pay (sec. 
        112);
          (3) forgiveness of income taxes of members of the 
        Armed Forces dying in the combat zone or by reason of 
        combat-zone incurred wounds (sec. 692);
          (4) the reduction in estate taxes for members of the 
        Armed Forces dying in the combat zone or by reason of 
        combat-zone incurred wounds (sec. 2201);
          (5) the exemption from income tax withholding for 
        military pay for any month in which an employee is 
        entitled to the exclusion from income (sec. 
        3401(a)(1));
          (6) the exemption from the telephone excise tax for 
        toll telephone service that originates in a combat zone 
        (sec. 4253(d));
          (7) the special rule permitting filing of a joint 
        return where a spouse is in missing status as a result 
        of service in a combat zone (sec. 6013(f)(1)); and
          (8) the suspension of time provisions (sec. 7508).
    A qualified hazardous duty area means Bosnia and 
Herzegovina, Croatia, or Macedonia, if, as of the date of 
enactment, any member of the Armed Forces is entitled to 
hostile fire/imminent danger pay for services performed in such 
country. Members of the Armed Forces are in Bosnia and 
Herzegovina and Croatia as part of ``Operation Joint Endeavor'' 
(the NATO operation).\5\ Members of the Armed Forces are in 
Macedonia as part of ``Operation Able Sentry'' (the United 
Nations operation). In addition, persons other than Members of 
the Armed Forces who are serving in support of these operations 
of the Armed Forces are eligible for the suspension of time 
provisions in section 7508 of the Code.\6\ This provision was 
effective on November 21, 1995 (the date the Dayton Accord was 
initialed).
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    \5\ Operation Joint Endeavor has been replaced by Operation Joint 
Forge. The IRS has stated that personnel serving under Operation Joint 
Forge will be treated the same as personnel under Operation Joint 
Endeavor because Joint Forge is ``the substantive continuation'' of 
Joint Endeavor. Letter dated July 17, 1998, from Tommy G. DeWeese, 
District Director for the International District, Internal Revenue 
Service, to LTC Thomas K. Emswiler, Armed Forces Tax Council, 
Department of Defense.
    \6\ In addition, persons other than Members of the Armed Forces are 
eligible for some of the other seven provisions listed above, under 
specified circumstances. For example, civilian employees of the United 
States are eligible for the forgiveness of income tax provisions of 
section 692 if they die as a result of injuries sustained overseas in 
specified terroristic or military actions.
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Suspension of time provisions for other Operation Joint Endeavor 
        personnel

    An individual who is performing services as part of 
Operation Joint Endeavor outside the United States while 
deployed away from the individual's permanent duty station will 
qualify for the suspension of time provisions in section 7508 
of the Code during the period that hostile fire/imminent danger 
pay is paid in Bosnia and Herzegovina, Croatia, or Macedonia.

Announcement of Intention to Issue Executive Order Designating Kosovo 
        Area of Operations as a Combat Zone

    On April 12, 1999, President Clinton announced his 
intention to issue an Executive Order designating the Federal 
Republic of Yugoslavia (Serbia/Montenegro), Albania, the 
Adriatic Sea, and the northern Ionian Sea (including all of 
their air spaces) as a combat zone for purposes of the Internal 
Revenue Code.

                           Reasons for Change

    The Committee believes that it is appropriate to apply the 
special tax rules applicable to combat zones to service in the 
Federal Republic of Yugoslavia (Serbia/Montenegro), Albania, 
the Adriatic Sea, and the Northern Ionian Sea in the same 
manner as if those areas were a combat zone. In addition, the 
Committee believes that it is appropriate to provide that 
military personnel performing services outside of those areas 
but still a part of Operation Allied Force qualify for the 
suspension of time provisions in section 7508 of the Code 
during the period that hostile fire/imminent danger pay is paid 
with respect to those areas, provided that those services are 
performed both outside the United States and while deployed 
away from that individual's duty station.

                        Explanation of Provision

    The bill contains two elements. First, the bill treats the 
Federal Republic of Yugoslavia (Serbia/Montenegro), Albania, 
the Adriatic Sea, and the northern Ionian Sea above the 39th 
parallel (including all of their air spaces) as a qualified 
hazardous duty area. Consequently, military personnel serving 
in those areas are entitled to relief under all eight of the 
hazardous duty area provisions listed above. Several special 
rules apply to civilian personnel. Civilian personnel serving 
in those areas in support of the Armed Forces are entitled to 
the suspension of time provisions in section 7508 of the Code. 
In addition, civilian employees of the United States serving in 
those areas are entitled to (a) the special rule for 
determining surviving spouse status where the deceased spouse 
was in missing status as a result of service in a combat zone 
(sec. 2(a)(3)); (b) forgiveness of income taxes of employees 
dying in the combat zone or by reason of combat-zone incurred 
wounds (sec. 692); and (c) the special rule permitting filing 
of a joint return where a spouse is in missing status as a 
result of service in a combat zone (sec. 6013(f)(1)).
    Second, the bill also provides that military personnel 
performing services outside of those areas but still a part of 
Operation Allied Force qualify for the suspension of time 
provisions in section 7508 of the Code during the period that 
hostile fire/imminent danger pay is paid with respect to those 
areas, provided that those services are performed both outside 
the United States and while deployed away from that 
individual's duty station.
    Accordingly, the bill provides the same treatment for those 
serving in (or in support of) Operation Allied Force as is 
provided under present law to those serving in (or in support 
of) Operation Joint Endeavor.

                             Effective Date

    The provision is effective on March 24, 1999 (the date on 
which Operation Allied Force commenced).

                       III. VOTE OF THE COMMITTEE

    In compliance with clause 3(b) of rule XIII of the Rules of 
the House of Representatives, the following statement is made 
concerning the vote of the Committee in its consideration of 
the bill, H.R. 1376.
    The bill, H.R. 1376, was ordered favorably reported by 
voice vote on April 13, 1999, with a quorum present.

                     IV. BUDGET EFFECTS OF THE BILL

               A. Committee Estimate of Budgetary Effects

    In compliance with clause 3(d)(2) of rule XIII of the Rules 
of the House of Representatives, the following statement is 
made concerning the effects on the budget of the bill, H.R. 
1376, as reported.
    The bill is estimated to have the following effects on 
budget receipts for fiscal years 1999-2003:

  ESTIMATED BUDGET EFFECTS OF H.R. 1376, RELATING TO TAX RELIEF FOR PERSONNEL IN YUGOSLAVIA, ALBANIA, THE ADRIATIC SEA, AND THE NORTHERN IONIAN SEA, AS
                                              APPROVED BY THE COMMITTEE ON WAYS AND MEANS ON APRIL 13, 1999
                                                    [Fiscal years 1999-2009, in millions of dollars]
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          Provision             Effective    1999    2000    2001    2002    2003    2004    2005    2006    2007    2008    2009   1999-2004  1999-2009
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1. Designate ``qualified       3/24/99         -22     -47     -23     -16     -10      -5      -1   (\1\)   (\1\)   (\1\)   (\1\)      -123       -125
 hazardous duty area'' to
 include Yugoslavia, Albania,
 the Adriatic Sea, and the
 Northern Ionian Sea.
2. Provide section 7508        3/24/99                                                Negligible Revenue Effect
 suspensions to certain
 military personnel outside
 of hazardous duty area.
                              --------------------------------------------------------------------------------------------------------------------------
      Net total..............  ...........     -22     -47     -23     -16     -10      -5      -1   (\1\)   (\1\)   (\1\)   (\1\)      -123       -125
                                ....
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\1\ Loss of less than $500,000.

Note.--Details may not add to totals due to rounding.

Source: Joint Committee on Taxation.

    B. Statement Regarding New Budget Authority and Tax Expenditures

    In compliance with clause 3(c)(2) of rule XIII of the Rules 
of the House of Representatives, the Committee states that the 
bill involves no new or increased budget authority. The bill 
involves increased tax expenditures for the income tax benefit 
provisions related to combat pay (for amounts, see Part IV.A., 
above).

      C. Cost Estimate Prepared by the Congressional Budget Office

    In compliance with clause 3(c)(3) of rule XIII of the Rules 
of the House of Representatives, requiring a cost estimate 
prepared by the Congressional Budget Office (CBO), the 
following statement by CBO is provided.

                                     U.S. Congress,
                               Congressional Budget Office,
                                    Washington, DC, April 13, 1999.
Hon. Bill Archer,
Chairman, Committee on Ways and Means,
House of Representatives, Washington, DC.
    Dear Mr. Chairman: The Congressional Budget Office has 
prepared the enclosed cost estimate for a bill to extend the 
tax benefits available 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.
    If you wish further details on this estimate, we will be 
pleased to provide them. The CBO staff contact is Hester 
Grippando.
            Sincerely,
                                          Barry B. Anderson
                                    (For Dan L. Crippen, Director).
    Enclosure.

H.R.   --To extend the tax benefits available 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

    This bill would provide tax benefits to the members of the 
Armed Forces who are receiving special pay while subject to 
hostile fire or imminent danger while serving in the Federal 
Republic of Yugoslavia, Albania, the Adriatic Sea, or the 
northern Ionic Sea. They would receive the same tax benefits 
available to services performed in a combat zone. The bill 
would also allow those service members outside the United 
States who are deployed away from their permanent duty station 
as part of Operation Allied Force to delay filing income tax 
returns without penalty. The Joint Committee on Taxation (JCT) 
has estimated that this bill would reduce governmental receipts 
by $22 million in fiscal year 1999, and by $123 million over 
the 1999-2009 period. The President currently has the authority 
to declare the area designated by this bill a combat zone. If 
the President does so before this bill is enacted, the revenue 
loss of the bill would be negligible.
    JCT has determined that this bill contains no private-
sector or intergovernmental mandates as defined in the Unfunded 
Mandates Reform Act (UMRA) and would not affect the budgets of 
state, local, or tribal governments.
    The Balanced Budget and Emergency Deficit Control Act sets 
up pay-as-you-go procedures for legislation affecting direct 
spending or receipts. The net changes in governmental receipts 
that are subject to pay-as-you-go procedures are shown in the 
following table. For the purposes of enforcing pay-as-you-go 
procedures, only the effects in the current year, the budget 
year, and the succeeding four years are counted.

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                                                                                         By fiscal years, in millions of dollars--
                                                                 ---------------------------------------------------------------------------------------
                                                                   1999    2000    2001    2002    2003    2004    2005    2006    2007    2008    2009
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Changes in receipts.............................................     -22     -47     -23     -16     -10      -5      -1       0       0       0       0
--------------------------------------------------------------------------------------------------------------------------------------------------------

    This estimate was prepared by Hester Grippando and approved 
by G. Thomas Woodward, Assistant Director for Tax Analysis.

     V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE

          A. Committee Oversight Findings and Recommendations

    With respect to clause 3(c)(1) of rule XIII of the Rules of 
the House of Representatives (relating to oversight findings), 
the Committee advises that it was a result of the Committee's 
oversight activities concerning the tax treatment of military 
(and support) personnel serving in ``Operation Allied Force'' 
that the Committee concluded that it is appropriate to enact 
the provisions contained in the bill as reported.

    B. Summary of Findings and Recommendations of the Committee on 
                           Government Reform

    With respect to clause 3(c)(4) of rule XIII of the Rules of 
the House of Representatives, the Committee advises that no 
oversight findings or recommendations have been submitted to 
this Committee by the Committee on Government Reform with 
respect to the provisions contained in the bill.

                 C. Constitutional Authority Statement

    With respect to clause 3(d)(1) of rule XIII of the Rules of 
the House of Representatives (relating to Constitutional 
Authority), the Committee states that the Committee's action in 
reporting this bill is derived from Article I of the 
Constitution, Section 8 (``The Congress shall have Power To lay 
and collect Taxes, Duties, Imposts and Excises * * * ''), and 
from the 16th Amendment to the Constitution.

              D. Information Relating to Unfunded Mandates

    This information is provided in accordance with section 423 
of the Unfunded Mandates Act of 1995 (P.L. 104-4).
    The Committee has determined that the bill does not involve 
any Federal mandate on the private sector nor does it involve 
any Federal intergovernmental mandate on State, local, or 
tribal governments.

                 E. Applicability of House Rule XXI5(b)

    Rule XXI5(b) of the Rules of the House of Representatives 
provides, in part, that ``No bill or joint resolution, 
amendment, or conference report carrying a Federal income tax 
rate increase shall be considered as passed or agreed to unless 
determined by a vote of not less than three-fifths of the 
Members.'' The Committee has carefully reviewed the provisions 
of the bill, and states that the provisions of the bill do not 
involve any Federal income tax rate increase within the meaning 
of the rule.

                       F. Tax Complexity Analysis

    Section 4022(b) of the Internal Revenue Service Reform and 
Restructuring Act of 1998 (the ``IRS Reform Act'') requires the 
Joint Committee on Taxation (in consultation with the Internal 
Revenue Service and the Department of the Treasury) to provide 
a tax complexity analysis. The complexity analysis is required 
for all legislation reported by the Senate Committee on 
Finance, the House Committee on Ways and Means, or any 
committee of conference if the legislation includes a provision 
that directly or indirectly amends the Internal Revenue Code 
(the ``Code'') and has widespread applicability to individuals 
or small businesses.
    The staff of the Joint Committee on Taxation has determined 
that a complexity analysis is not required under section 
4022(b) of the IRS Reform Act because the bill contains no 
provisions that amend the Internal Revenue Code and that have 
widespread applicability to individuals or small businesses.

                                
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