II

106TH CONGRESS

1ST SESSION S. 593

To amend the Internal Revenue Code of 1986 to increase the maximum

taxable income for the 15 percent rate bracket, to provide a partial

exclusion from gross income for dividends and interest received by individuals, to provide a long-term capital gains deduction for individuals,

to increase the traditional IRA contribution limit, and for other purposes.

IN THE SENATE OF THE UNITED STATES

MARCH 11, 1999

Mr. COVERDELL (for himself, Mr. TORRICELLI, and Mr. ABRAHAM) introduced the following bill; which was read twice and referred to the Committee on Finance

A BILL

To amend the Internal Revenue Code of 1986 to increase

the maximum taxable income for the 15 percent rate

bracket, to provide a partial exclusion from gross income

for dividends and interest received by individuals, to provide a long-term capital gains deduction for individuals,

to increase the traditional IRA contribution limit, 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,
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1 SECTION 1. SHORT TITLE.

2 This Act may be cited as the ‘‘Small Savers Act of

3 1999’’.

4 SEC 2. INCREASE IN MAXIMUM TAXABLE INCOME FOR 15

5 PERCENT RATE BRACKET.

6 Section 1(f) of the Internal Revenue Code of 1986

7 (relating to adjustments in tax tables so that inflation will

8 not result in tax increases) is amended—

9 (1) in paragraph (2)—

10 (A) by redesignating subparagraphs (B)

11 and (C) as subparagraphs (C) and (D),

12 (B) by inserting after subparagraph (A)

13 the following:

14 ‘‘(B) in the case of the tables contained in

15 subsections (a), (b), (c), and (d), by increasing

16 the maximum taxable income level for the 15

17 percent rate bracket and the minimum taxable

18 income level for the 28 percent rate bracket

19 otherwise determined under subparagraph (A)

20 for taxable years beginning in any calendar year

21 after 1999, by the applicable dollar amount for

22 such calendar year,’’, and

23 (C) by striking ‘‘subparagraph (A)’’ in

24 subparagraph (C) (as so redesignated) and in25 serting ‘‘subparagraphs (A) and (B)’’, and

26 (2) by adding at the end the following:
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1 ‘‘(8) APPLICABLE DOLLAR AMOUNT.—For pur2 poses of paragraph (2)(B), the applicable dollar

3 amount for any calendar year shall be determined as

4 follows:

5 ‘‘(A) JOINT RETURNS AND SURVIVING

6 SPOUSES.—In the case of the table contained in

7 subsection (a)—

Applicable

‘‘Calendar year: Dollar Amount:

2000 ......................................................................................... $2,000

2001 ......................................................................................... $4,000

2002 ......................................................................................... $6,000

2003 ......................................................................................... $8,000

2004 and thereafter ................................................................. $10,000.

8 ‘‘(B) OTHER TABLES.—In the case of the

9 table contained in subsection (b), (c), or (d)—

Applicable

‘‘Calendar year: Dollar Amount:

2000 ......................................................................................... $1,000

2001 ......................................................................................... $2,000

2002 ......................................................................................... $3,000

2003 ......................................................................................... $4,000

2004 and thereafter ................................................................. $5,000.’’

10 SEC. 3. PARTIAL EXCLUSION OF DIVIDENDS AND INTEREST

11 RECEIVED BY INDIVIDUALS.

12 (a) IN GENERAL.—Part III of subchapter B of chap13 ter 1 of the Internal Revenue Code of 1986 (relating to

14 amounts specifically excluded from gross income) is

15 amended by inserting after section 115 the following new

16 section:
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1 ‘‘SEC. 116. PARTIAL EXCLUSION OF DIVIDENDS AND INTER2 EST RECEIVED BY INDIVIDUALS.

3 ‘‘(a) EXCLUSION FROM GROSS INCOME.—Gross in4 come does not include the sum of the amounts received

5 during the taxable year by an individual as—

6 ‘‘(1) dividends from domestic corporations, or

7 ‘‘(2) interest.

8 ‘‘(b) LIMITATIONS.—

9 ‘‘(1) MAXIMUM AMOUNT.—The aggregate

10 amount excluded under subsection (a) for any tax11 able year shall not exceed $250 ($500 in the case of

12 a joint return).

13 ‘‘(2) CERTAIN DIVIDENDS EXCLUDED.—Sub14 section (a)(1) shall not apply to any dividend from

15 a corporation which, for the taxable year of the cor16 poration in which the distribution is made, or for the

17 next preceding taxable year of the corporation, is a

18 corporation exempt from tax under section 501 (re19 lating to certain charitable, etc., organization) or

20 section 521 (relating to farmers’ cooperative associa21 tions).

22 ‘‘(c) INTEREST.—For purposes of this section, the

23 term ‘interest’ means—

24 ‘‘(1) interest on deposits with a bank (as de25 fined in section 581),
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1 ‘‘(2) amounts (whether or not designated as in2 terest) paid in respect of deposits, investment certifi3 cates, or withdrawable or repurchasable shares, by—

4 ‘‘(A) a mutual savings bank, cooperative

5 bank, domestic building and loan association,

6 industrial loan association or bank, or credit

7 union, or

8 ‘‘(B) any other savings or thrift institution

9 which is chartered and supervised under Fed10 eral or State law,

11 the deposits or accounts in which are insured under

12 Federal or State law or which are protected and

13 guaranteed under State law,

14 ‘‘(3) interest on—

15 ‘‘(A) evidences of indebtedness (including

16 bonds, debentures, notes, and certificates)

17 issued by a domestic corporation in registered

18 form, and

19 ‘‘(B) to the extent provided in regulations

20 prescribed by the Secretary, other evidences of

21 indebtedness issued by a domestic corporation

22 of a type offered by corporations to the public,

23 ‘‘(4) interest on obligations of the United

24 States, a State, or a political subdivision of a State
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1 (not excluded from gross income of the taxpayer

2 under any other provision of law), and

3 ‘‘(5) interest attributable to participation shares

4 in a trust established and maintained by a corpora5 tion established pursuant to Federal law.

6 ‘‘(d) SPECIAL RULES.—For purposes of this

7 section—

8 ‘‘(1) DISTRIBUTIONS FROM REGULATED IN9 VESTMENT COMPANIES AND REAL ESTATE INVEST10 MENT TRUSTS.—Subsection (a) shall apply with re11 spect to distributions by—

12 ‘‘(A) regulated investment companies to

13 the extent provided in section 854(c), and

14 ‘‘(B) real estate investment trusts to the

15 extent provided in section 857(c).

16 ‘‘(2) DISTRIBUTIONS BY A TRUST.—For pur17 poses of subsection (a), the amount of dividends and

18 interest properly allocable to a beneficiary under sec19 tion 652 or 662 shall be deemed to have been re20 ceived by the beneficiary ratably on the same date

21 that the dividends and interest were received by the

22 estate or trust.

23 ‘‘(3) CERTAIN NONRESIDENT ALIENS INELI24 GIBLE FOR EXCLUSION.—In the case of a non-
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1 resident alien individual, subsection (a) shall apply

2 only—

3 ‘‘(A) in determining the tax imposed for

4 the taxable year pursuant to section 871(b)(1)

5 and only in respect of dividends and interest

6 which are effectively connected with the conduct

7 of a trade or business within the United States,

8 or

9 ‘‘(B) in determining the tax imposed for

10 the taxable year pursuant to section 877(b).’’.

11 (b) CONFORMING AMENDMENTS.—

12 (1) The table of sections for part III of sub13 chapter B of chapter 1 of such Code is amended by

14 inserting after the item relating to section 115 the

15 following new item:

‘‘Sec. 116. Partial exclusion of dividends and interest received by

individuals.’’.

16 (2) Paragraph (2) of section 265(a) of such

17 Code is amended by inserting before the period at

18 the end the following: ‘‘, or to purchase or carry ob19 ligations or shares, or to make deposits, to the ex20 tent the interest thereon is excludable from gross in21 come under section 116’’.

22 (3) Subsection (c) of section 584 of such Code

23 is amended by adding at the end the following new

24 flush sentence:
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1 ‘‘The proportionate share of each participant in the

2 amount of dividends or interest received by the common

3 trust fund and to which section 116 applies shall be con4 sidered for purposes of such section as having been re5 ceived by such participant.’’.

6 (4) Subsection (a) of section 643 of such Code

7 is amended by redesignating paragraph (7) as para8 graph (8) and by inserting after paragraph (6) the

9 following new paragraph:

10 ‘‘(7) DIVIDENDS OR INTEREST.—There shall be

11 included the amount of any dividends or interest ex12 cluded from gross income pursuant to section 116.’’.

13 (5) Section 854 of such Code is amended by

14 adding at the end the following new subsection:

15 ‘‘(c) TREATMENT UNDER SECTION 116.—

16 ‘‘(1) IN GENERAL.—For purposes of section

17 116, in the case of any dividend (other than a divi18 dend described in subsection (a)) received from a

19 regulated investment company which meets the re20 quirements of section 852 for the taxable year in

21 which it paid the dividend—

22 ‘‘(A) the entire amount of such dividend

23 shall be treated as a dividend if the sum of the

24 aggregate dividends and the aggregate interest

25 received by such company during the taxable
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1 year equals or exceeds 75 percent of its gross

2 income, or

3 ‘‘(B) if subparagraph (A) does not apply,

4 there shall be taken into account under section

5 116 only the portion of such dividend which

6 bears the same ratio to the amount of such div7 idend as the sum of the aggregate dividends re8 ceived and aggregate interest received bears to

9 gross income.

10 For purposes of the preceding sentence, gross in11 come and aggregate interest received shall each be

12 reduced by so much of the deduction allowable by

13 section 163 for the taxable year as does not exceed

14 aggregate interest received for the taxable year.

15 ‘‘(2) NOTICE TO SHAREHOLDERS.—The amount

16 of any distribution by a regulated investment com17 pany which may be taken into account as a dividend

18 for purposes of the exclusion under section 116 shall

19 not exceed the amount so designated by the com20 pany in a written notice to its shareholders mailed

21 not later than 60 days after the close of its taxable

22 year.

23 ‘‘(3) DEFINITIONS.—For purposes of this

24 subsection—
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1 ‘‘(A) GROSS INCOME.—The term ‘gross in2 come’ does not include gain from the sale or

3 other disposition of stock or securities.

4 ‘‘(B) AGGREGATE DIVIDENDS.—The term

5 ‘aggregate dividends’ includes only dividends re6 ceived from domestic corporations other than

7 dividends described in section 116(b)(2). In de8 termining the amount of any dividend for pur9 poses of this subparagraph, the rules provided

10 in section 116(d)(1) (relating to certain dis11 tributions) shall apply.

12 ‘‘(C) INTEREST.—The term ‘interest’ has

13 the meaning given such term by section

14 116(c).’’.

15 (6) Subsection (c) of section 857 of such Code

16 is amended to read as follows:

17 ‘‘(c) LIMITATIONS APPLICABLE TO DIVIDENDS RE18 CEIVED FROM REAL ESTATE INVESTMENT TRUSTS.—

19 ‘‘(1) IN GENERAL.—For purposes of section

20 116 (relating to an exclusion for dividends and inter21 est received by individuals) and section 243 (relating

22 to deductions for dividends received by corpora23 tions), a dividend received from a real estate invest24 ment trust which meets the requirements of this

25 part shall not be considered as a dividend.
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1 ‘‘(2) TREATMENT AS INTEREST.—For purposes

2 of section 116, in the case of a dividend (other than

3 a capital gain dividend, as defined in subsection

4 (b)(3)(C)) received from a real estate investment

5 trust which meets the requirements of this part for

6 the taxable year in which it paid the dividend—

7 ‘‘(A) such dividend shall be treated as in8 terest if the aggregate interest received by the

9 real estate investment trust for the taxable year

10 equals or exceeds 75 percent of its gross in11 come, or

12 ‘‘(B) if subparagraph (A) does not apply,

13 the portion of such dividend which bears the

14 same ratio to the amount of such dividend as

15 the aggregate interest received bears to gross

16 income shall be treated as interest.

17 ‘‘(3) ADJUSTMENTS TO GROSS INCOME AND AG18 GREGATE INTEREST RECEIVED.—For purposes of

19 paragraph (2)—

20 ‘‘(A) gross income does not include the net

21 capital gain,

22 ‘‘(B) gross income and aggregate interest

23 received shall each be reduced by so much of

24 the deduction allowable by section 163 for the

25 taxable year (other than for interest on mort-
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1 gages on real property owned by the real estate

2 investment trust) as does not exceed aggregate

3 interest received by the taxable year, and

4 ‘‘(C) gross income shall be reduced by the

5 sum of the taxes imposed by paragraphs (4),

6 (5), and (6) of section 857(b).

7 ‘‘(4) INTEREST.—The term ‘interest’ has the

8 meaning given such term by section 116(c).

9 ‘‘(5) NOTICE TO SHAREHOLDERS.—The amount

10 of any distribution by a real estate investment trust

11 which may be taken into account as interest for pur12 poses of the exclusion under section 116 shall not

13 exceed the amount so designated by the trust in a

14 written notice to its shareholders mailed not later

15 than 60 days after the close of its taxable year.’’.

16 (c) EFFECTIVE DATE.—The amendments made by

17 this section shall apply to taxable years beginning after

18 December 31, 1999.

19 SEC. 4. LONG-TERM CAPITAL GAINS DEDUCTION FOR INDI20 VIDUALS.

21 (a) GENERAL RULE.—Part I of subchapter P of

22 chapter 1 of the Internal Revenue Code of 1986 (relating

23 to treatment of capital gains) is amended by redesignating

24 section 1202 as section 1203 and by inserting after section

25 1201 the following new section:
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1 ‘‘SEC. 1202. CAPITAL GAINS DEDUCTION FOR INDIVIDUALS.

2 ‘‘(a) IN GENERAL.—In the case of an individual,

3 there shall be allowed as a deduction for the taxable year

4 an amount equal to the lesser of—

5 ‘‘(1) the net capital gain of the taxpayer for the

6 taxable year, or

7 ‘‘(2) $5,000.

8 ‘‘(b) SALES BETWEEN RELATED PARTIES.—Gains

9 from sales and exchanges to any related person (within

10 the meaning of section 267(b) or 707(b)(1)) shall not be

11 taken into account in determining net capital gain.

12 ‘‘(c) SPECIAL RULE FOR SECTION 1250 PROP13 ERTY.—Solely for purposes of this section, in applying sec14 tion 1250 to any disposition of section 1250 property, all

15 depreciation adjustments in respect of the property shall

16 be treated as additional depreciation.

17 ‘‘(d) SECTION NOT TO APPLY TO CERTAIN TAX18 PAYERS.—No deduction shall be allowed under this section

19 to—

20 ‘‘(1) an individual with respect to whom a de21 duction under section 151 is allowable to another

22 taxpayer for a taxable year beginning in the cal23 endar year in which such individual’s taxable year

24 begins,
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1 ‘‘(2) a married individual (within the meaning

2 of section 7703) filing a separate return for the tax3 able year, or

4 ‘‘(3) an estate or trust.

5 ‘‘(e) SPECIAL RULE FOR PASS-THRU ENTITIES.—

6 ‘‘(1) IN GENERAL.—In applying this section

7 with respect to any pass-thru entity, the determina8 tion of when the sale or exchange occurs shall be

9 made at the entity level.

10 ‘‘(2) PASS-THRU ENTITY DEFINED.—For pur11 poses of paragraph (1), the term ‘pass-thru entity’

12 means—

13 ‘‘(A) a regulated investment company,

14 ‘‘(B) a real estate investment trust,

15 ‘‘(C) an S corporation,

16 ‘‘(D) a partnership,

17 ‘‘(E) an estate or trust, and

18 ‘‘(F) a common trust fund.’’

19 (b) COORDINATION WITH MAXIMUM CAPITAL GAINS

20 RATE.—Paragraph (3) of section 1(h) of the Internal Rev21 enue Code of 1986 (relating to maximum capital gains

22 rate) is amended to read as follows:

23 ‘‘(3) COORDINATION WITH OTHER PROVI24 SIONS.—For purposes of this subsection, the amount
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1 of the net capital gain shall be reduced (but not

2 below zero) by the sum of—

3 ‘‘(A) the amount of the net capital gain

4 taken into account under section 1202(a) for

5 the taxable year, plus

6 ‘‘(B) the amount which the taxpayer elects

7 to take into account as investment income for

8 the taxable year under section

9 163(d)(4)(B)(iii).’’

10 (c) DEDUCTION ALLOWABLE IN COMPUTING AD11 JUSTED GROSS INCOME.—Subsection (a) of section 62

12 (defining adjusted gross income) is amended by inserting

13 after paragraph (17) the following new paragraph:

14 ‘‘(18) LONG-TERM CAPITAL GAINS.—The de15 duction allowed by section 1202.’’

16 (d) TREATMENT OF COLLECTIBLES.—

17 (1) IN GENERAL.—Section 1222 of the Internal

18 Revenue Code of 1986 (relating to other terms relat19 ing to capital gains and losses) is amended by in20 serting after paragraph (11) the following new para21 graph:

22 ‘‘(12) SPECIAL RULE FOR COLLECTIBLES.—

23 ‘‘(A) IN GENERAL.—Any gain or loss from

24 the sale or exchange of a collectible shall be

25 treated as a short-term capital gain or loss (as
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1 the case may be), without regard to the period

2 such asset was held. The preceding sentence

3 shall apply only to the extent the gain or loss

4 is taken into account in computing taxable in5 come.

6 ‘‘(B) TREATMENT OF CERTAIN SALES OF

7 INTEREST IN PARTNERSHIP, ETC.—For pur8 poses of subparagraph (A), any gain from the

9 sale or exchange of an interest in a partnership,

10 S corporation, or trust which is attributable to

11 unrealized appreciation in the value of collect12 ibles held by such entity shall be treated as gain

13 from the sale or exchange of a collectible. Rules

14 similar to the rules of section 751(f) shall apply

15 for purposes of the preceding sentence.

16 ‘‘(C) COLLECTIBLE.—For purposes of this

17 paragraph, the term ‘collectible’ means any cap18 ital asset which is a collectible (as defined in

19 section 408(m) without regard to paragraph (3)

20 thereof).’’

21 (2) CHARITABLE DEDUCTION NOT AF22 FECTED.—

23 (A) Paragraph (1) of section 170(e) of

24 such Code is amended by adding at the end the

25 following new sentence: ‘‘For purposes of this
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1 paragraph, section 1222 shall be applied with2 out regard to paragraph (12) thereof (relating

3 to special rule for collectibles).’’

4 (B) Clause (iv) of section 170(b)(1)(C) of

5 such Code is amended by inserting before the

6 period at the end the following: ‘‘and section

7 1222 shall be applied without regard to para8 graph (12) thereof (relating to special rule for

9 collectibles)’’.

10 (e) CONFORMING AMENDMENTS.—

11 (1) Section 57(a)(7) of the Internal Revenue

12 Code of 1986 is amended by striking ‘‘1202’’ and in13 serting ‘‘1203’’.

14 (2) Clause (iii) of section 163(d)(4)(B) of such

15 Code is amended to read as follows:

16 ‘‘(iii) the sum of—

17 ‘‘(I) the portion of the net capital

18 gain referred to in clause (ii)(II) (or,

19 if lesser, the net capital gain referred

20 to in clause (ii)(I)) taken into account

21 under section 1202, reduced by the

22 amount of the deduction allowed with

23 respect to such gain under section

24 1202, plus
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1 ‘‘(II) so much of the gain de2 scribed in subclause (I) which is not

3 taken into account under section 1202

4 and which the taxpayer elects to take

5 into account under this clause.’’

6 (3) Subparagraph (B) of section 172(d)(2) of

7 such Code is amended to read as follows:

8 ‘‘(B) the deduction under section 1202 and

9 the exclusion under section 1203 shall not be

10 allowed.’’

11 (4) Section 642(c)(4) of such Code is amended

12 by striking ‘‘1202’’ and inserting ‘‘1203’’.

13 (5) Section 643(a)(3) of such Code is amended

14 by striking ‘‘1202’’ and inserting ‘‘1203’’.

15 (6) Paragraph (4) of section 691(c) of such

16 Code is amended inserting ‘‘1203,’’ after ‘‘1202,’’.

17 (7) The second sentence of section 871(a)(2) of

18 such Code is amended by inserting ‘‘or 1203’’ after

19 ‘‘section 1202’’.

20 (8) The last sentence of section 1044(d) of such

21 Code is amended by striking ‘‘1202’’ and inserting

22 ‘‘1203’’.

23 (9) Paragraph (1) of section 1402(i) of such

24 Code is amended by inserting ‘‘, and the deduction

25 provided by section 1202 and the exclusion provided
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1 by section 1203 shall not apply’’ before the period

2 at the end.

3 (10) Section 121 of such Code is amended by

4 adding at the end the following new subsection:

5 ‘‘(h) CROSS REFERENCE.—

‘‘For treatment of eligible gain not excluded under

subsection (a), see section 1202.’’

6 (11) Section 1203 of such Code, as redesig7 nated by subsection (a), is amended by adding at the

8 end the following new subsection:

9 ‘‘(l) CROSS REFERENCE.—

‘‘For treatment of eligible gain not excluded under

subsection (a), see section 1202.’’

10 (12) The table of sections for part I of sub11 chapter P of chapter 1 of such Code is amended by

12 striking the item relating to section 1202 and by in13 serting after the item relating to section 1201 the

14 following new items:

‘‘Sec. 1202. Capital gains deduction.

‘‘Sec. 1203. 50-percent exclusion for gain from certain small

business stock.’’

15 (f) EFFECTIVE DATES.—

16 (1) IN GENERAL.—Except as provided in para17 graph (2), the amendments made by this section

18 shall apply to taxable years beginning after Decem19 ber 31, 1999.
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1 (2) COLLECTIBLES.—The amendments made by

2 subsection (d) shall apply to sales and exchanges

3 after December 31, 1999.

4 SEC. 5. INCREASE IN CONTRIBUTION LIMITS FOR TRADI5 TIONAL IRAS.

6 (a) INCREASE IN CONTRIBUTION LIMIT.—Paragraph

7 (1)(A) of section 219(b) of the Internal Revenue Code of

8 1986 (relating to maximum amount of deduction) is

9 amended by striking ‘‘$2,000’’ and inserting ‘‘$3,000’’.

10 (b) INFLATION ADJUSTMENT.—Section 219 of the

11 Internal Revenue Code of 1986 (relating to deduction for

12 retirement savings) is amended by redesignating sub13 section (h) as subsection (i) and by inserting after sub14 section (g) the following new subsection:

15 ‘‘(h) COST-OF-LIVING ADJUSTMENT.—

16 ‘‘(1) DEDUCTIBLE AMOUNTS.—In the case of

17 any taxable year beginning in a calendar year after

18 2009, the $3,000 amount under subsection (b)(1)(A)

19 shall be increased by an amount equal to—

20 ‘‘(A) such dollar amount, multiplied by

21 ‘‘(B) the cost-of-living adjustment deter22 mined under section 1(f)(3) for the calendar

23 year in which the taxable year begins, deter24 mined by substituting ‘calendar year 2008’ for
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1 ‘calendar year 1992’ in subparagraph (B)

2 thereof.

3 ‘‘(2) ROUNDING RULES.—If any amount after

4 adjustment under paragraph (1) is not a multiple of

5 $100, such amount shall be rounded to the next

6 lower multiple of $100.’’

7 (c) CONFORMING AMENDMENTS.—

8 (1) Section 408(a)(1) is amended by striking

9 ‘‘in excess of $2,000 on behalf of any individual’’

10 and inserting ‘‘on behalf of any individual in excess

11 of the amount in effect for such taxable year under

12 section 219(b)(1)(A)’’.

13 (2) Section 408(b)(2)(B) is amended by strik14 ing ‘‘$2,000’’ and inserting ‘‘the dollar amount in

15 effect under section 219(b)(1)(A)’’.

16 (3) Section 408(b) is amended by striking

17 ‘‘$2,000’’ in the matter following paragraph (4) and

18 inserting ‘‘the dollar amount in effect under section

19 219(b)(1)(A)’’.

20 (4) Section 408(j) is amended by striking

21 ‘‘$2,000’’.

22 (5) Section 408(p)(8) is amended by striking

23 ‘‘$2,000’’ and inserting ‘‘the dollar amount in effect

24 under section 219(b)(1)(A)’’
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1 (6) Section 408A(c)(2)(A) of such Code is

2 amended to read as follows:

3 ‘‘(A) $2,000, over’’.

4 (d) EFFECTIVE DATE.—The amendments made by

5 this section shall apply to taxable years beginning after

6 December 31, 1999.

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