I
106TH CONGRESS
1ST SESSION
H. R. 2318
To amend the Internal Revenue Code of 1986 to provide corporate alternative
minimum tax reform.
IN THE HOUSE OF REPRESENTATIVES
JUNE 23, 1999
Mr. HAYWORTH (for himself, Mr. SAM JOHNSON of Texas, Mr. LEWIS of Ken-
tucky, Ms. DUNN, Mr. ENGLISH, Mr. CRANE, Mr. MCCRERY, Mr. WAT-
KINS, and Mrs. JOHNSON of Connecticut) introduced the following bill;
which was referred to the Committee on Ways and Means
A BILL
To amend the Internal Revenue Code of 1986 to provide
corporate alternative minimum tax reform.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ‘‘Alternative Minimum
Tax Reform Act of 1999.’’.
SEC. 2. LONG-TERM UNUSED CREDITS ALLOWED AGAINST
MINIMUM TAX.
(a) IN GENERAL.—Subsection (c) of section 53 of the
Internal Revenue Code of 1986 (relating to limitation) is
amended by adding at the end the following new para-
graph:
‘‘(2) SPECIAL RULE FOR CORPORATIONS WITH
LONG-TERM UNUSED CREDITS.—
‘‘(A) IN
GENERAL.—If a corporation to
which section 56(g) applies has a long-term un-
used minimum tax credit for a taxable year, the
credit allowable under subsection (a) for the
taxable year shall not exceed the greater of—
‘‘(i) the limitation determined under
paragraph (1) for the taxable year, or
‘‘(ii) the least of the following for the
taxable year:
‘‘(I) The sum of the tax imposed
by section 55 and the regular tax re-
duced by the sum of the credits al-
lowed under subparts A, B, D, E, and
F of this part.
‘‘(II) The long-term unused min-
imum tax credit.
‘‘(III) The sum of—
‘‘(aa) the excess (if any) of
the amount under paragraph
(1)(A) over the amount under
paragraph (1)(B), plus
‘‘(bb) 50 percent of the ten-
tative minimum tax (determined
under section 55(b)(1)(B)).
‘‘(B) LONG-TERM UNUSED MINIMUM TAX
CREDIT.—For purposes of this paragraph—
‘‘(i) IN GENERAL.—The long-term un-
used minimum tax credit for any taxable
year is the portion of the minimum tax
credit determined under subsection (b) at-
tributable to the adjusted net minimum tax
for taxable years beginning after 1986 and
ending before the 3rd taxable year imme-
diately preceding the taxable year for
which the determination is being made.
‘‘(ii) FIRST-IN, FIRST-OUT ORDERING
RULE.—For purposes of clause (i), credits
shall be treated as allowed under sub-
section (a) on a first-in, first-out basis.’’.
(b) CONFORMING AMENDMENTS.—Section 53(c) of
such Code is amended—
(1) by striking ‘‘The’’ and inserting the fol-
lowing:
‘‘(1) IN GENERAL.—The’’; and
(2) by redesignating paragraphs (1) and (2) as
subparagraphs (A) and (B), respectively.
SEC. 3. 10-YEAR CARRYBACK OF CERTAIN NET OPERATING
LOSSES.
Section 56(d) of the Internal Revenue Code of 1986
(relating to definition of alternative tax net operating loss
deduction) is amended by inserting at the end thereof the
following new paragraph:
‘‘(3) SPECIAL RULE.—In the case of a corpora-
tion to which section 56(g) applies which has a net
operating loss under this part for 3 or more consecu-
tive taxable years which includes a taxable year be-
ginning after the date of enactment of this para-
graph, the loss for each such year shall be a net op-
erating loss carryback for purposes of this part to
each of the 10 years preceding the taxable year of
such loss.’’.
SEC. 4. EFFECTIVE DATE.
The amendments made by this Act shall apply to tax-
able years beginning after December 31, 1998.
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