I
106TH CONGRESS
2D SESSION
H. R. 4885
To provide tax and regulatory relief for farmers and to improve the competi-
tiveness of American agricultural commodities and products in global
markets.
IN THE HOUSE OF REPRESENTATIVES
JULY 19, 2000
Mr. BOEHNER (for himself, Mr. BARRETT of Nebraska, Mr. COOKSEY, Mr.
EWING, Mr. GUTKNECHT, Mr. LAHOOD, Mr. LATHAM, Mr. LUCAS of
Oklahoma, Mr. NETHERCUTT, Mr. NUSSLE, Mr. PETERSON of Min-
nesota, Mr. SCHAFFER, Mr. SIMPSON, Mr. THUNE, and Mr. WALDEN of
Oregon) introduced the following bill; which was referred to the Com-
mittee on Ways and Means, and in addition to the Committees on Agri-
culture, Rules, and Government Reform, for a period to be subsequently
determined by the Speaker, in each case for consideration of such provi-
sions as fall within the jurisdiction of the committee concerned
A BILL
To provide tax and regulatory relief for farmers and to
improve the competitiveness of American agricultural
commodities and products in global markets.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
SECTION 1. SHORT TITLE; TABLE OF CONTENTS.
(a) SHORT TITLE.—This Act may be cited as the
‘‘Rural America Prosperity Act of 2000’’.
(b) TABLE OF CONTENTS.—The table of contents of
this Act is as follows:
Sec. 1. Short title; table of contents.
TITLE I—TAX RELIEF FOR FARMERS
Subtitle A—General Tax Provisions
Sec. 101. Deduction for 100 percent of health insurance costs of self-employed
individuals.
Sec. 102. Exclusion of gain from sale of farmland.
Sec. 103. Income averaging for farmers not to increase alternative minimum
tax liability.
Sec. 104. Farm and ranch risk management accounts.
Subtitle B—Estate and Gift Tax Relief
Sec. 111. Repeal of estate, gift, and generation-skipping taxes.
Sec. 112. Termination of step up in basis at death.
Sec. 113. Carryover basis at death.
Sec. 114. Additional reductions of estate and gift tax rates.
Sec. 115. Unified credit against estate and gift taxes replaced with unified ex-
emption amount.
Sec. 116. Deemed allocation of GST exemption to lifetime transfers to trusts;
retroactive allocations.
Sec. 117. Severing of trusts.
Sec. 118. Modification of certain valuation rules.
Sec. 119. Relief provisions.
Sec. 120. Expansion of estate tax rule for conservation easements.
TITLE II—STUDY OF COSTS OF REGULATIONS ON FARMERS,
RANCHERS, AND FORESTERS
Sec. 201. Definitions.
Sec. 202. Comptroller General study of regulations.
Sec. 203. Response of Secretary of Agriculture.
TITLE III—EXTENSION OF TRADE AUTHORITIES PROCEDURES
FOR RECIPROCAL TRADE AGREEMENTS
Sec. 301. Short title.
Sec. 302. Trade negotiating objectives.
Sec. 303. Trade agreements authority.
Sec. 304. Consultations.
Sec. 305. Implementation of trade agreements.
Sec. 306. Treatment of certain trade agreements.
Sec. 307. Conforming amendments.
Sec. 308. Definitions.
TITLE IV—AGRICULTURAL TRADE FREEDOM
Sec. 401. Short title.
Sec. 402. Definitions.
Sec. 403. Agricultural commodities, livestock, and products exempt from unilat-
eral agricultural sanctions.
Sec. 404. Sale or barter of food assistance.
TITLE I—TAX RELIEF FOR
FARMERS
Subtitle A—General Tax Provisions
SEC. 101. DEDUCTION FOR 100 PERCENT OF HEALTH IN-
SURANCE COSTS OF SELF-EMPLOYED INDI-
VIDUALS.
(a) IN GENERAL.—Paragraph (1) of section 162(l)
of the Internal Revenue Code of 1986 (relating to special
rules for health insurance costs of self-employed individ-
uals) is amended to read as follows:
‘‘(1) ALLOWANCE OF DEDUCTION.—In the case
of an individual who is an employee within the
meaning of section 401(c)(1), there shall be allowed
as a deduction under this section an amount equal
to 100 percent of the amount paid during the tax-
able year for insurance which constitutes medical
care for the taxpayer, his spouse, and dependents.’’.
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to taxable years beginning after
December 31, 2000.
SEC. 102. EXCLUSION OF GAIN FROM SALE OF FARMLAND.
(a) IN GENERAL.—Part III of subchapter B of chap-
ter 1 of the Internal Revenue Code of 1986 (relating to
States if, during periods aggregating 3 years or
more of the 5-year period ending on the date of the
sale or exchange of such real property—
‘‘(A) such real property was used by the
taxpayer or a member of the family of the tax-
payer as a farm for farming purposes, and
‘‘(B) there was material participation by
the taxpayer (or such a member) in the oper-
ation of the farm.
‘‘(2) OTHER DEFINITIONS.—The terms ‘mem-
ber of the family’, ‘farm’, and ‘farming purposes’
have the respective meanings given such terms by
paragraphs (2), (4), and (5) of section 2032A(e).
‘‘(3) SPECIAL
RULES.—Rules similar to the
rules of paragraphs (4) and (5) of section 2032A(b)
and paragraphs (3) and (6) of section 2032A(e)
shall apply.
‘‘(d) OTHER RULES.—For purposes of this section,
rules similar to the rules of subsection (e) and subsection
(f) of section 121 shall apply.’’
(b) CONFORMING AMENDMENT.—The table of sec-
tions for part III of subchapter B of chapter 1 of the In-
ternal Revenue Code of 1986 is amended by inserting
after the item relating to section 121 the following:
‘‘Sec. 121A. Exclusion of gain from sale of qualified farm prop-
erty.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to any sale or exchange after the
date of the enactment of this Act in taxable years ending
after such date.
SEC. 103. INCOME AVERAGING FOR FARMERS NOT TO IN-
CREASE ALTERNATIVE MINIMUM TAX LIABIL-
ITY.
(a) IN GENERAL.—Section 55(c) of the Internal Rev-
enue Code of 1986 (defining regular tax) is amended by
redesignating paragraph (2) as paragraph (3) and by in-
serting after paragraph (1) the following:
‘‘(2) COORDINATION WITH INCOME AVERAGING
FOR FARMERS.—Solely for purposes of this section,
section 1301 (relating to averaging of farm income)
shall not apply in computing the regular tax.’’
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to taxable years beginning after
December 31, 1997.
SEC. 104. FARM AND RANCH RISK MANAGEMENT AC-
COUNTS.
(a) IN GENERAL.—Subpart C of part II of sub-
chapter E of chapter 1 of the Internal Revenue Code of
1986 (relating to taxable year for which deductions taken)
is amended by inserting after section 468B the following:
‘‘SEC. 468C. FARM AND RANCH RISK MANAGEMENT AC-
COUNTS.
‘‘(a) DEDUCTION ALLOWED.—In the case of an indi-
vidual engaged in an eligible farming business, there shall
be allowed as a deduction for any taxable year the amount
paid in cash by the taxpayer during the taxable year to
a Farm and Ranch Risk Management Account (herein-
after referred to as the ‘FARRM Account’).
‘‘(b) LIMITATION.—The amount which a taxpayer
may pay into the FARRM Account for any taxable year
shall not exceed 20 percent of so much of the taxable in-
come of the taxpayer (determined without regard to this
section) which is attributable (determined in the manner
applicable under section 1301) to any eligible farming
business.
‘‘(c) ELIGIBLE FARMING BUSINESS.—For purposes
of this section, the term ‘eligible farming business’ means
any farming business (as defined in section 263A(e)(4))
which is not a passive activity (within the meaning of sec-
tion 469(c)) of the taxpayer.
‘‘(d) FARRM ACCOUNT.—For purposes of this
section—
‘‘(1) IN
GENERAL.—The term ‘FARRM Ac-
count’ means a trust created or organized in the
United States for the exclusive benefit of the tax-
payer, but only if the written governing instrument
creating the trust meets the following requirements:
‘‘(A) No contribution will be accepted for
any taxable year in excess of the amount al-
lowed as a deduction under subsection (a) for
such year.
‘‘(B) The trustee is a bank (as defined in
section 408(n)) or another person who dem-
onstrates to the satisfaction of the Secretary
that the manner in which such person will ad-
minister the trust will be consistent with the re-
quirements of this section.
‘‘(C) The assets of the trust consist en-
tirely of cash or of obligations which have ade-
quate stated interest (as defined in section
1274(c)(2)) and which pay such interest not
less often than annually.
‘‘(D) All income of the trust is distributed
currently to the grantor.
‘‘(E) The assets of the trust will not be
commingled with other property except in a
common trust fund or common investment
fund.
‘‘(2) ACCOUNT TAXED AS GRANTOR TRUST.—
The grantor of a FARRM Account shall be treated
for purposes of this title as the owner of such Ac-
count and shall be subject to tax thereon in accord-
ance with subpart E of part I of subchapter J of
this chapter (relating to grantors and others treated
as substantial owners).
‘‘(e) INCLUSION OF AMOUNTS DISTRIBUTED.—
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), there shall be includible in the gross in-
come of the taxpayer for any taxable year—
‘‘(A) any amount distributed from a
FARRM Account of the taxpayer during such
taxable year, and
‘‘(B) any deemed distribution under—
‘‘(i) subsection (f)(1) (relating to de-
posits not distributed within 5 years),
‘‘(ii) subsection (f)(2) (relating to ces-
sation in eligible farming business), and
‘‘(iii) subparagraph (A) or (B) of sub-
section (f)(3) (relating to prohibited trans-
actions and pledging account as security).
‘‘(2) EXCEPTIONS.—Paragraph (1)(A) shall not
apply to—
‘‘(A) any distribution to the extent attrib-
utable to income of the Account, and
‘‘(B) the distribution of any contribution
paid during a taxable year to a FARRM Ac-
count to the extent that such contribution ex-
ceeds the limitation applicable under subsection
(b) if requirements similar to the requirements
of section 408(d)(4) are met.
For purposes of subparagraph (A), distributions
shall be treated as first attributable to income and
then to other amounts.
‘‘(f) SPECIAL RULES.—
‘‘(1) TAX
ON
DEPOSITS
IN
ACCOUNT
WHICH
ARE NOT DISTRIBUTED WITHIN 5 YEARS.—
‘‘(A) IN GENERAL.—If, at the close of any
taxable year, there is a nonqualified balance in
any FARRM Account—
‘‘(i) there shall be deemed distributed
from such Account during such taxable
year an amount equal to such balance, and
‘‘(ii) the taxpayer’s tax imposed by
this chapter for such taxable year shall be
increased by 10 percent of such deemed
distribution.
The preceding sentence shall not apply if an
amount equal to such nonqualified balance is
distributed from such Account to the taxpayer
before the due date (including extensions) for
filing the return of tax imposed by this chapter
for such year (or, if earlier, the date the tax-
payer files such return for such year).
‘‘(B) NONQUALIFIED BALANCE.—For pur-
poses of subparagraph (A), the term ‘non-
qualified balance’ means any balance in the Ac-
count on the last day of the taxable year which
is attributable to amounts deposited in such Ac-
count before the 4th preceding taxable year.
‘‘(C) ORDERING RULE.—For purposes of
this paragraph, distributions from a FARRM
Account (other than distributions of current in-
come) shall be treated as made from deposits in
the order in which such deposits were made, be-
ginning with the earliest deposits.
‘‘(2) CESSATION
IN
ELIGIBLE
BUSINESS.—At
the close of the first disqualification period after a
period for which the taxpayer was engaged in an eli-
gible farming business, there shall be deemed dis-
tributed from the FARRM Account of the taxpayer
an amount equal to the balance in such Account (if
any) at the close of such disqualification period. For
purposes of the preceding sentence, the term ‘dis-
qualification period’ means any period of 2 consecu-
tive taxable years for which the taxpayer is not en-
gaged in an eligible farming business.
‘‘(3) CERTAIN RULES TO APPLY.—Rules similar
to the following rules shall apply for purposes of this
section:
‘‘(A) Section 220(f)(8) (relating to treat-
ment on death).
‘‘(B) Section 408(e)(2) (relating to loss of
exemption of account where individual engages
in prohibited transaction).
‘‘(C) Section 408(e)(4) (relating to effect
of pledging account as security).
‘‘(D) Section 408(g) (relating to commu-
nity property laws).
‘‘(E) Section 408(h) (relating to custodial
accounts).
‘‘(4) TIME WHEN PAYMENTS DEEMED MADE.—
For purposes of this section, a taxpayer shall be
deemed to have made a payment to a FARRM Ac-
count on the last day of a taxable year if such pay-
ment is made on account of such taxable year and
is made on or before the due date (without regard
to extensions) for filing the return of tax for such
taxable year.
‘‘(5) INDIVIDUAL.—For purposes of this sec-
tion, the term ‘individual’ shall not include an estate
or trust.
‘‘(6) DEDUCTION NOT ALLOWED FOR SELF-EM-
PLOYMENT TAX.—The deduction allowable by reason
of subsection (a) shall not be taken into account in
determining an individual’s net earnings from self-
employment (within the meaning of section 1402(a))
for purposes of chapter 2.
‘‘(g) REPORTS.—The trustee of a FARRM Account
shall make such reports regarding such Account to the
Secretary and to the person for whose benefit the Account
is maintained with respect to contributions, distributions,
and such other matters as the Secretary may require
under regulations. The reports required by this subsection
shall be filed at such time and in such manner and fur-
nished to such persons at such time and in such manner
as may be required by such regulations.’’.
(b) TAX ON EXCESS CONTRIBUTIONS.—
(1) Subsection (a) of section 4973 of the Inter-
nal Revenue Code of 1986 (relating to tax on excess
contributions to certain tax-favored accounts and an-
nuities) is amended by striking ‘‘or’’ at the end of
paragraph (3), by redesignating paragraph (4) as
paragraph (5), and by inserting after paragraph (3)
the following:
‘‘(4) a FARRM Account (within the meaning of
section 468C(d)), or’’.
(2) Section 4973 of such Code, is amended by
adding at the end the following:
‘‘(g) EXCESS
CONTRIBUTIONS
TO
FARRM AC-
COUNTS.—For purposes of this section, in the case of a
FARRM Account (within the meaning of section
468C(d)), the term ‘excess contributions’ means the
amount by which the amount contributed for the taxable
year to the Account exceeds the amount which may be con-
tributed to the Account under section 468C(b) for such
taxable year. For purposes of this subsection, any con-
tribution which is distributed out of the FARRM Account
in a distribution to which section 468C(e)(2)(B) applies
shall be treated as an amount not contributed.’’.
(3) The section heading for section 4973 of
such Code is amended to read as follows:
‘‘SEC. 4973. EXCESS CONTRIBUTIONS TO CERTAIN AC-
COUNTS, ANNUITIES, ETC.’’.
(4) The table of sections for chapter 43 of such
Code is amended by striking the item relating to sec-
tion 4973 and inserting the following:
‘‘Sec. 4973. Excess contributions to certain accounts, annuities,
etc.’’.
(c) TAX ON PROHIBITED TRANSACTIONS.—
(1) Subsection (c) of section 4975 of the Inter-
nal Revenue Code of 1986 (relating to tax on pro-
hibited transactions) is amended by adding at the
end the following:
‘‘(6) SPECIAL RULE FOR FARRM ACCOUNTS.—
A person for whose benefit a FARRM Account
(within the meaning of section 468C(d)) is estab-
lished shall be exempt from the tax imposed by this
section with respect to any transaction concerning
such account (which would otherwise be taxable
under this section) if, with respect to such trans-
action, the account ceases to be a FARRM Account
by reason of the application of section 468C(f)(3)(A)
to such account.’’.
(2) Paragraph (1) of section 4975(e) of such
Code is amended by redesignating subparagraphs
(E) and (F) as subparagraphs (F) and (G), respec-
tively, and by inserting after subparagraph (D) the
following:
‘‘(E) a FARRM Account described in sec-
tion 468C(d),’’.
(d) FAILURE TO PROVIDE REPORTS ON FARRM AC-
COUNTS.—Paragraph (2) of section 6693(a) of the Inter-
nal Revenue Code of 1986 (relating to failure to provide
reports on certain tax-favored accounts or annuities) is
amended by redesignating subparagraphs (C) and (D) as
subparagraphs (D) and (E), respectively, and by inserting
after subparagraph (B) the following:
‘‘(C) section 468C(g) (relating to FARRM
Accounts),’’.
(e) CLERICAL AMENDMENT.—The table of sections
for subpart C of part II of subchapter E of chapter 1 of
the Internal Revenue Code of 1986 is amended by insert-
ing after the item relating to section 468B the following:
‘‘Sec. 468C. Farm and Ranch Risk Management Accounts.’’.
(f) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
December 31, 2000.
Subtitle B—Estate and Gift Tax
Relief
SEC. 111. REPEAL OF ESTATE, GIFT, AND GENERATION-
SKIPPING TAXES.
(a) IN GENERAL.—Subtitle B of the Internal Rev-
enue Code of 1986 is hereby repealed.
(b) EFFECTIVE DATE.—The repeal made by sub-
section (a) shall apply to the estates of decedents dying,
and gifts and generation-skipping transfers made, after
December 31, 2009.
SEC. 112. TERMINATION OF STEP UP IN BASIS AT DEATH.
(a) TERMINATION
OF APPLICATION
OF SECTION
1014.—Section 1014 of the Internal Revenue Code of
1986 (relating to basis of property acquired from a dece-
dent) is amended by adding at the end the following:
‘‘(f) TERMINATION.—In the case of a decedent dying
after December 31, 2009, this section shall not apply to
property for which basis is provided by section 1022.’’.
(b) CONFORMING AMENDMENT.—Subsection (a) of
section 1016 of the Internal Revenue Code of 1986 (relat-
ing to adjustments to basis) is amended by striking ‘‘and’’
at the end of paragraph (26), by striking the period at
the end of paragraph (27) and inserting ‘‘, and’’, and by
adding at the end the following:
‘‘(28) to the extent provided in section 1022
(relating to basis for certain property acquired from
a decedent dying after December 31, 2009).’’.
SEC. 113. CARRYOVER BASIS AT DEATH.
(a) GENERAL RULE.—Part II of subchapter O of
chapter 1 of the Internal Revenue Code of 1986 (relating
to basis rules of general application) is amended by insert-
ing after section 1021 the following new section:
‘‘SEC. 1022. CARRYOVER BASIS FOR CERTAIN PROPERTY
ACQUIRED FROM A DECEDENT DYING AFTER
DECEMBER 31, 2009.
‘‘(a) CARRYOVER BASIS.—Except as otherwise pro-
vided in this section, the basis of carryover basis property
in the hands of a person acquiring such property from a
decedent shall be determined under section 1015.
‘‘(b) CARRYOVER BASIS PROPERTY DEFINED.—
‘‘(1) IN GENERAL.—For purposes of this sec-
tion, the term ‘carryover basis property’ means any
property—
‘‘(A) which is acquired from or passed
from a decedent who died after December 31,
2009, and
‘‘(B) which is not excluded pursuant to
paragraph (2).
The property taken into account under subpara-
graph (A) shall be determined under section 1014(b)
without regard to subparagraph (A) of the last sen-
tence of paragraph (9) thereof.
‘‘(2) CERTAIN
PROPERTY
NOT
CARRYOVER
BASIS PROPERTY.—The term ‘carryover basis prop-
erty’ does not include—
‘‘(A) any item of gross income in respect
of a decedent described in section 691,
‘‘(B) property of the decedent to the extent
that the aggregate adjusted fair market value
of such property does not exceed $1,300,000,
and
‘‘(C) property which was acquired from the
decedent by the surviving spouse of the dece-
dent (and which would be carryover basis prop-
erty without regard to this subparagraph) but
only if the value of such property would have
been deductible from the value of the taxable
estate of the decedent under section 2056, as in
effect on the day before the date of the enact-
ment of the Rural America Prosperity Act of
2000.
For purposes of this subsection, the term ‘adjusted
fair market value’ means, with respect to any prop-
erty, fair market value reduced by any indebtedness
secured by such property.
‘‘(3) LIMITATION
ON
EXCEPTION
FOR
PROP-
ERTY ACQUIRED BY SURVIVING SPOUSE.—The ad-
justed fair market value of property which is not
carryover basis property by reason of paragraph
(2)(C) shall not exceed $3,000,000.
‘‘(4) ALLOCATION OF EXCEPTED AMOUNTS.—
The executor shall allocate the limitations under
paragraphs (2)(B) and (3).
‘‘(5) INFLATION
ADJUSTMENT
OF
EXCEPTED
AMOUNTS.—In the case of decedents dying in a cal-
endar year after 2010, the dollar amounts in para-
graphs (2)(B) and (3) shall each be increased by an
amount equal to the product of—
‘‘(A) such dollar amount, and
‘‘(B) the cost-of-living adjustment deter-
mined under section 1(f)(3) for such calendar
year, determined by substituting ‘2009’ for
‘1992’ in subparagraph (B) thereof.
If any increase determined under the preceding sen-
tence is not a multiple of $10,000, such increase
shall be rounded to the nearest multiple of $10,000.
‘‘(c) REGULATIONS.—The Secretary shall prescribe
such regulations as may be necessary to carry out the pur-
poses of this section.’’.
(b) MISCELLANEOUS AMENDMENTS RELATED
TO
CARRYOVER BASIS.—
(1) CAPITAL GAIN TREATMENT FOR INHERITED
ART WORK OR SIMILAR PROPERTY.—
(A) IN
GENERAL.—Subparagraph (C) of
section 1221(a)(3) of the Internal Revenue
Code of 1986 (defining capital asset) is amend-
ed by inserting ‘‘(other than by reason of sec-
tion 1022)’’ after ‘‘is determined’’.
(B) COORDINATION WITH SECTION 170.—
Paragraph (1) of section 170(e) of such Code
(relating to certain contributions of ordinary in-
come and capital gain property) is amended by
adding at the end the following: ‘‘For purposes
of this paragraph, the determination of whether
property is a capital asset shall be made with-
out regard to the exception contained in section
1221(a)(3)(C) for basis determined under sec-
tion 1022.’’.
(2) 
DEFINITION
OF
EXECUTOR.—Section
7701(a) of such Code (relating to definitions) is
amended by adding at the end the following:
‘‘(47) EXECUTOR.—The term ‘executor’ means
the executor or administrator of the decedent, or, if
there is no executor or administrator appointed,
qualified, and acting within the United States, then
any person in actual or constructive possession of
any property of the decedent.’’.
(3) CLERICAL AMENDMENT.—The table of sec-
tions for part II of subchapter O of chapter 1 of
such Code is amended by adding at the end the fol-
lowing new item:
‘‘Sec. 1022. Carryover basis for certain property acquired from a
decedent dying after December 31, 2009.’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to estates of decedents dying after
December 31, 2009.
SEC. 114. ADDITIONAL REDUCTIONS OF ESTATE AND GIFT
TAX RATES.
(a) MAXIMUM RATE OF TAX REDUCED TO 50 PER-
CENT.—
(1) IN GENERAL.—The table contained in sec-
tion 2001(c)(1) of the Internal Revenue Code of
1986 is amended by striking the two highest brack-
ets and inserting the following:
‘‘Over $2,500,000 ..........................
$1,025,800, plus 50% of the excess
over $2,500,000.’’.
(2) PHASE-IN OF REDUCED RATE.—Subsection
(c) of section 2001 of such Code is amended by add-
ing at the end the following new paragraph:
‘‘(3) PHASE-IN
OF
REDUCED
RATE.—In the
case of decedents dying, and gifts made, during
2001, the last item in the table contained in para-
graph (1) shall be applied by substituting ‘53%’ for
‘50%’.’’.
(b) 
REPEAL
OF
PHASEOUT
OF
GRADUATED
RATES.—Subsection (c) of section 2001 of the Internal
Revenue Code of 1986 is amended by striking paragraph
(2) and redesignating paragraph (3), as added by sub-
section (a), as paragraph (2).
(c) ADDITIONAL REDUCTIONS OF RATES OF TAX.—
Subsection (c) of section 2001 of the Internal Revenue
Code of 1986, as so amended, is amended by adding at
the end the following new paragraph:
‘‘(3) PHASEDOWN OF TAX.—In the case of es-
tates of decedents dying, and gifts made, during any
calendar year after 2002 and before 2010—
‘‘(A) IN GENERAL.—Except as provided in
subparagraph (C), the tentative tax under this
subsection shall be determined by using a table
prescribed by the Secretary (in lieu of using the
table contained in paragraph (1)) which is the
same as such table; except that—
‘‘(i) each of the rates of tax shall be
reduced by the number of percentage
points determined under subparagraph
(B), and
‘‘(ii) the amounts setting forth the tax
shall be adjusted to the extent necessary to
reflect the adjustments under clause (i).
‘‘(B) PERCENTAGE
POINTS
OF
REDUC-
TION.—
The number of
‘‘For calendar year:
percentage points is:
2003 .............................................................................
1.0
2004 .............................................................................
2.0
2005 .............................................................................
3.0
2006 .............................................................................
4.0
2007 .............................................................................
5.5
2008 .............................................................................
7.5
2009 .............................................................................
9.5.
‘‘(C) COORDINATION
WITH
INCOME
TAX
RATES.—The reductions under subparagraph
(A)—
‘‘(i) shall not reduce any rate under
paragraph (1) below the lowest rate in sec-
tion 1(c), and
‘‘(ii) shall not reduce the highest rate
under paragraph (1) below the highest rate
in section 1(c).
‘‘(D) COORDINATION
WITH
CREDIT
FOR
STATE
DEATH
TAXES.—Rules similar to the
rules of subparagraph (A) shall apply to the
table contained in section 2011(b) except that
the Secretary shall prescribe percentage point
reductions which maintain the proportionate re-
lationship (as in effect before any reduction
under this paragraph) between the credit under
section 2011 and the tax rates under subsection
(c).’’.
(d) EFFECTIVE DATES.—
(1) SUBSECTIONS (a) AND (b).—The amend-
ments made by subsections (a) and (b) shall apply
to estates of decedents dying, and gifts made, after
December 31, 2000.
(2) SUBSECTION (c).—The amendment made by
subsection (c) shall apply to estates of decedents
dying, and gifts made, after December 31, 2002.
SEC. 115. UNIFIED CREDIT AGAINST ESTATE AND GIFT
TAXES REPLACED WITH UNIFIED EXEMPTION
AMOUNT.
(a) IN GENERAL.—
(1) ESTATE
TAX.—Subsection (b) of section
2001 of the Internal Revenue Code of 1986 (relating
to computation of tax) is amended to read as fol-
lows:
‘‘(b) COMPUTATION OF TAX.—
‘‘(1) IN GENERAL.—The tax imposed by this
section shall be the amount equal to the excess (if
any) of—
‘‘(A) the tentative tax determined under
paragraph (2), over
‘‘(B) the aggregate amount of tax which
would have been payable under chapter 12 with
respect to gifts made by the decedent after De-
cember 31, 1976, if the provisions of subsection
(c) (as in effect at the decedent’s death) had
been applicable at the time of such gifts.
‘‘(2) TENTATIVE TAX.—For purposes of para-
graph (1), the tentative tax determined under this
paragraph is a tax computed under subsection (c) on
the excess of—
‘‘(A) the sum of—
‘‘(i) the amount of the taxable estate,
and
‘‘(ii) the amount of the adjusted tax-
able gifts, over
‘‘(B) the exemption amount for the cal-
endar year in which the decedent died.
‘‘(3) EXEMPTION
AMOUNT.—For purposes of
paragraph (2), the term ‘exemption amount’ means
the amount determined in accordance with the fol-
lowing table:
‘‘In the case of
The exemption
calendar year:
amount is:
2001 ..........................................................................
$675,000
2002 and 2003 ..........................................................
$700,000
2004 ..........................................................................
$850,000
2005 ..........................................................................
$950,000
2006 or thereafter .....................................................
$1,000,000.
‘‘(4) ADJUSTED
TAXABLE
GIFTS.—For pur-
poses of paragraph (2), the term ‘adjusted taxable
gifts’ means the total amount of the taxable gifts
(within the meaning of section 2503) made by the
decedent after December 31, 1976, other than gifts
which are includible in the gross estate of the dece-
dent.’’.
(2) GIFT TAX.—Subsection (a) of section 2502
of such Code (relating to computation of tax) is
amended to read as follows:
‘‘(a) COMPUTATION OF TAX.—
‘‘(1) IN GENERAL.—The tax imposed by section
2501 for each calendar year shall be the amount
equal to the excess (if any) of—
‘‘(A) the tentative tax determined under
paragraph (2), over
‘‘(B) the tax paid under this section for all
prior calendar periods.
‘‘(2) TENTATIVE TAX.—For purposes of para-
graph (1), the tentative tax determined under this
paragraph for a calendar year is a tax computed
under section 2001(c) on the excess of—
‘‘(A) the aggregate sum of the taxable gifts
for such calendar year and for each of the pre-
ceding calendar periods, over
‘‘(B) the exemption amount under section
2001(b)(3) for such calendar year.’’.
(b) REPEAL OF UNIFIED CREDITS.—
(1) Section 2010 of the Internal Revenue Code
of 1986 (relating to unified credit against estate
tax) is hereby repealed.
(2) Section 2505 of such Code (relating to uni-
fied credit against gift tax) is hereby repealed.
(c) CONFORMING AMENDMENTS.—
(1)(A) Subsection (b) of section 2011 of the In-
ternal Revenue Code of 1986 is amended—
(i) by striking ‘‘adjusted’’ in the table; and
(ii) by striking the last sentence.
(B) Subsection (f) of section 2011 of such Code
is amended by striking ‘‘, reduced by the amount of
the unified credit provided by section 2010’’.
(2) Subsection (a) of section 2012 of such Code
is amended by striking ‘‘and the unified credit pro-
vided by section 2010’’.
(3) Subparagraph (A) of section 2013(c)(1) of
such Code is amended by striking ‘‘2010,’’.
(4) Paragraph (2) of section 2014(b) of such
Code is amended by striking ‘‘2010, 2011,’’ and in-
serting ‘‘2011’’.
(5) Clause (ii) of section 2056A(b)(12)(C) of
such Code is amended to read as follows:
‘‘(ii) to treat any reduction in the tax
imposed by paragraph (1)(A) by reason of
the credit allowable under section 2010 (as
in effect on the day before the date of the
enactment of the Rural America Prosperity
Act of 2000) or the exemption amount al-
lowable under section 2001(b) with respect
to the decedent as a credit under section
2505 (as so in effect) or exemption under
section 2521 (as the case may be) allow-
able to such surviving spouse for purposes
of determining the amount of the exemp-
tion allowable under section 2521 with re-
spect to taxable gifts made by the sur-
viving spouse during the year in which the
spouse becomes a citizen or any subse-
quent year,’’.
(6) Subsection (a) of section 2057 of such Code
is amended by striking paragraphs (2) and (3) and
inserting the following new paragraph:
‘‘(2) MAXIMUM DEDUCTION.—The deduction al-
lowed by this section shall not exceed the excess of
$1,300,000 over the exemption amount (as defined
in section 2001(b)(3)).’’.
(7)(A) Subsection (b) of section 2101 of such
Code is amended to read as follows:
‘‘(b) COMPUTATION OF TAX.—
‘‘(1) IN GENERAL.—The tax imposed by this
section shall be the amount equal to the excess (if
any) of—
‘‘(A) the tentative tax determined under
paragraph (2), over
‘‘(B) a tentative tax computed under sec-
tion 2001(c) on the amount of the adjusted tax-
able gifts.
‘‘(2) TENTATIVE TAX.—For purposes of para-
graph (1), the tentative tax determined under this
paragraph is a tax computed under section 2001(c)
on the excess of—
‘‘(A) the sum of—
‘‘(i) the amount of the taxable estate,
and
‘‘(ii) the amount of the adjusted tax-
able gifts, over
‘‘(B) the exemption amount for the cal-
endar year in which the decedent died.
‘‘(3) EXEMPTION AMOUNT.—
‘‘(A) IN GENERAL.—The term ‘exemption
amount’ means $60,000.
‘‘(B) RESIDENTS OF POSSESSIONS OF THE
UNITED
STATES.—In the case of a decedent
who is considered to be a nonresident not a cit-
izen of the United States under section 2209,
the exemption amount under this paragraph
shall be the greater of—
‘‘(i) $60,000, or
‘‘(ii) that proportion of $175,000
which the value of that part of the dece-
dent’s gross estate which at the time of his
death is situated in the United States
bears to the value of his entire gross estate
wherever situated.
‘‘(C) SPECIAL RULES.—
‘‘(i) 
COORDINATION
WITH
TREA-
TIES.—To the extent required under any
treaty obligation of the United States, the
exemption amount allowed under this para-
graph shall be equal to the amount which
bears the same ratio to the exemption
amount under section 2001(b)(3) (for the
calendar year in which the decedent died)
as the value of the part of the decedent’s
gross estate which at the time of his death
is situated in the United States bears to
the value of his entire gross estate wher-
ever situated. For purposes of the pre-
ceding sentence, property shall not be
treated as situated in the United States if
such property is exempt from the tax im-
posed by this subchapter under any treaty
obligation of the United States.
‘‘(ii) COORDINATION WITH GIFT TAX
EXEMPTION AND UNIFIED CREDIT.—If an
exemption has been allowed under section
2521 (or a credit has been allowed under
section 2505 as in effect on the day before
the date of the enactment of the Rural
America Prosperity Act of 2000) with re-
spect to any gift made by the decedent,
each dollar amount contained in subpara-
graph (A) or (B) or the exemption amount
applicable under clause (i) of this subpara-
graph (whichever applies) shall be reduced
by the exemption so allowed under section
2521 (or, in the case of such a credit, by
the amount of the gift for which the credit
was so allowed).’’.
(8) Section 2102 of such Code is amended by
striking subsection (c).
(9)(A) Subsection (a) of section 2107 of such
Code is amended by adding at the end the following
new paragraph:
‘‘(3) LIMITATION
ON
EXEMPTION
AMOUNT.—
Subparagraphs (B) and (C) of section 2101(b)(3)
shall not apply in applying section 2101 for purposes
of this section.’’.
(B) Subsection (c) of section 2107 of such Code
is amended—
(i) by striking paragraph (1) and by redes-
ignating paragraphs (2) and (3) as paragraphs
(1) and (2), respectively, and
(ii) by striking the second sentence of
paragraph (2) (as so redesignated).
(10) Paragraph (1) of section 6018(a) of such
Code is amended by striking ‘‘the applicable exclu-
sion amount in effect under section 2010(c)’’ and in-
serting ‘‘the exemption amount under section
2001(b)(3)’’.
(11) Subparagraph (A) of section 6601(j)(2) of
such Code is amended to read as follows:
‘‘(A) the amount of the tentative tax which
would be determined under the rate schedule
set forth in section 2001(c) if the amount with
respect to which such tentative tax is to be
computed were $1,000,000, or’’.
(12) The table of sections for part II of sub-
chapter A of chapter 11 of such Code is amended by
striking the item relating to section 2010.
(13) The table of sections for subchapter A of
chapter 12 of such Code is amended by striking the
item relating to section 2505.
(d) EFFECTIVE DATE.—The amendments made by
this section—
(1) insofar as they relate to the tax imposed by
chapter 11 of the Internal Revenue Code of 1986,
shall apply to estates of decedents dying after De-
cember 31, 2000, and
(2) insofar as they relate to the tax imposed by
chapter 12 of such Code, shall apply to gifts made
after December 31, 2000.
SEC. 116. DEEMED ALLOCATION OF GST EXEMPTION TO
LIFETIME TRANSFERS TO TRUSTS; RETRO-
ACTIVE ALLOCATIONS.
(a) IN GENERAL.—Section 2632 of the Internal Rev-
enue Code of 1986 (relating to special rules for allocation
of GST exemption) is amended by redesignating sub-
section (c) as subsection (e) and by inserting after sub-
section (b) the following new subsections:
‘‘(c) DEEMED ALLOCATION TO CERTAIN LIFETIME
TRANSFERS TO GST TRUSTS.—
‘‘(1) IN GENERAL.—If any individual makes an
indirect skip during such individual’s lifetime, any
unused portion of such individual’s GST exemption
shall be allocated to the property transferred to the
extent necessary to make the inclusion ratio for such
property zero. If the amount of the indirect skip ex-
ceeds such unused portion, the entire unused portion
shall be allocated to the property transferred.
‘‘(2) UNUSED PORTION.—For purposes of para-
graph (1), the unused portion of an individual’s
GST exemption is that portion of such exemption
which has not previously been—
‘‘(A) allocated by such individual,
‘‘(B) treated as allocated under subsection
(b) with respect to a direct skip occurring dur-
ing or before the calendar year in which the in-
direct skip is made, or
‘‘(C) treated as allocated under paragraph
(1) with respect to a prior indirect skip.
‘‘(3) DEFINITIONS.—
‘‘(A) INDIRECT
SKIP.—For purposes of
this subsection, the term ‘indirect skip’ means
any transfer of property (other than a direct
skip) subject to the tax imposed by chapter 12
made to a GST trust.
‘‘(B) GST TRUST.—The term ‘GST trust’
means a trust that could have a generation-
skipping transfer with respect to the transferor
unless—
‘‘(i) the trust instrument provides that
more than 25 percent of the trust corpus
must be distributed to or may be with-
drawn by one or more individuals who are
non-skip persons—
‘‘(I) before the date that the indi-
vidual attains age 46,
‘‘(II) on or before one or more
dates specified in the trust instrument
that will occur before the date that
such individual attains age 46, or
‘‘(III) upon the occurrence of an
event that, in accordance with regula-
tions prescribed by the Secretary, may
reasonably be expected to occur before
the date that such individual attains
age 46;
‘‘(ii) the trust instrument provides
that more than 25 percent of the trust cor-
pus must be distributed to or may be with-
drawn by one or more individuals who are
non-skip persons and who are living on the
date of death of another person identified
in the instrument (by name or by class)
who is more than 10 years older than such
individuals;
‘‘(iii) the trust instrument provides
that, if one or more individuals who are
non-skip persons die on or before a date or
event described in clause (i) or (ii), more
than 25 percent of the trust corpus either
must be distributed to the estate or estates
of one or more of such individuals or is
subject to a general power of appointment
exercisable by one or more of such individ-
uals;
‘‘(iv) the trust is a trust any portion
of which would be included in the gross es-
tate of a non-skip person (other than the
transferor) if such person died immediately
after the transfer;
‘‘(v) the trust is a charitable lead an-
nuity trust (within the meaning of section
2642(e)(3)(A)) or a charitable remainder
annuity trust or a charitable remainder
unitrust (within the meaning of section
664(d)); or
‘‘(vi) the trust is a trust with respect
to which a deduction was allowed under
section 2522 for the amount of an interest
in the form of the right to receive annual
payments of a fixed percentage of the net
fair market value of the trust property (de-
termined yearly) and which is required to
pay principal to a non-skip person if such
person is alive when the yearly payments
for which the deduction was allowed termi-
nate.
For purposes of this subparagraph, the value of
transferred property shall not be considered to
be includible in the gross estate of a non-skip
person or subject to a right of withdrawal by
reason of such person holding a right to with-
draw so much of such property as does not ex-
ceed the amount referred to in section 2503(b)
with respect to any transferor, and it shall be
assumed that powers of appointment held by
non-skip persons will not be exercised.
‘‘(4) AUTOMATIC
ALLOCATIONS
TO
CERTAIN
GST TRUSTS.—For purposes of this subsection, an
indirect skip to which section 2642(f) applies shall
be deemed to have been made only at the close of
the estate tax inclusion period. The fair market
value of such transfer shall be the fair market value
of the trust property at the close of the estate tax
inclusion period.
‘‘(5) APPLICABILITY AND EFFECT.—
‘‘(A) IN GENERAL.—An individual—
‘‘(i) may elect to have this subsection
not apply to—
‘‘(I) an indirect skip, or
‘‘(II) any or all transfers made
by such individual to a particular
trust, and
‘‘(ii) may elect to treat any trust as a
GST trust for purposes of this subsection
with respect to any or all transfers made
by such individual to such trust.
‘‘(B) ELECTIONS.—
‘‘(i) ELECTIONS
WITH
RESPECT
TO
INDIRECT SKIPS.—An election under sub-
paragraph (A)(i)(I) shall be deemed to be
timely if filed on a timely filed gift tax re-
turn for the calendar year in which the
transfer was made or deemed to have been
made pursuant to paragraph (4) or on
such later date or dates as may be pre-
scribed by the Secretary.
‘‘(ii) OTHER ELECTIONS.—An election
under clause (i)(II) or (ii) of subparagraph
(A) may be made on a timely filed gift tax
return for the calendar year for which the
election is to become effective.
‘‘(d) RETROACTIVE ALLOCATIONS.—
‘‘(1) IN GENERAL.—If—
‘‘(A) a non-skip person has an interest or
a future interest in a trust to which any trans-
fer has been made,
‘‘(B) such person—
‘‘(i) is a lineal descendant of a grand-
parent of the transferor or of a grand-
parent of the transferor’s spouse or former
spouse, and
‘‘(ii) is assigned to a generation below
the generation assignment of the trans-
feror, and
‘‘(C) such person predeceases the trans-
feror,
then the transferor may make an allocation of any
of such transferor’s unused GST exemption to any
previous transfer or transfers to the trust on a
chronological basis.
‘‘(2) SPECIAL RULES.—If the allocation under
paragraph (1) by the transferor is made on a gift
tax return filed on or before the date prescribed by
section 6075(b) for gifts made within the calendar
year within which the non-skip person’s death
occurred—
‘‘(A) the value of such transfer or trans-
fers for purposes of section 2642(a) shall be de-
termined as if such allocation had been made
on a timely filed gift tax return for each cal-
endar year within which each transfer was
made,
‘‘(B) such allocation shall be effective im-
mediately before such death, and
‘‘(C) the amount of the transferor’s unused
GST exemption available to be allocated shall
be determined immediately before such death.
‘‘(3) FUTURE INTEREST.—For purposes of this
subsection, a person has a future interest in a trust
if the trust may permit income or corpus to be paid
to such person on a date or dates in the future.’’.
(b) CONFORMING AMENDMENT.—Paragraph (2) of
section 2632(b) of the Internal Revenue Code of 1986 is
amended by striking ‘‘with respect to a direct skip’’ and
inserting ‘‘or subsection (c)(1)’’.
(c) EFFECTIVE DATES.—
(1) DEEMED ALLOCATION.—Section 2632(c) of
the Internal Revenue Code of 1986 (as added by
subsection (a)), and the amendment made by sub-
section (b), shall apply to transfers subject to chap-
ter 11 or 12 made after December 31, 1999, and to
estate tax inclusion periods ending after December
31, 1999.
(2) 
RETROACTIVE
ALLOCATIONS.—Section
2632(d) of the Internal Revenue Code of 1986 (as
added by subsection (a)) shall apply to deaths of
non-skip persons occurring after December 31,
1999.
SEC. 117. SEVERING OF TRUSTS.
(a) IN GENERAL.—Subsection (a) of section 2642 of
the Internal Revenue Code of 1986 (relating to inclusion
ratio) is amended by adding at the end the following new
paragraph:
‘‘(3) SEVERING OF TRUSTS.—
‘‘(A) IN GENERAL.—If a trust is severed in
a qualified severance, the trusts resulting from
such severance shall be treated as separate
trusts thereafter for purposes of this chapter.
‘‘(B) QUALIFIED
SEVERANCE.—For pur-
poses of subparagraph (A)—
‘‘(i) IN GENERAL.—The term ‘quali-
fied severance’ means the division of a sin-
gle trust and the creation (by any means
available under the governing instrument
or under local law) of two or more trusts
if—
‘‘(I) the single trust was divided
on a fractional basis, and
‘‘(II) the terms of the new trusts,
in the aggregate, provide for the same
succession of interests of beneficiaries
as are provided in the original trust.
‘‘(ii) TRUSTS WITH INCLUSION RATIO
GREATER THAN ZERO.—If a trust has an
inclusion ratio of greater than zero and
less than 1, a severance is a qualified sev-
erance only if the single trust is divided
into two trusts, one of which receives a
fractional share of the total value of all
trust assets equal to the applicable fraction
of the single trust immediately before the
severance. In such case, the trust receiving
such fractional share shall have an inclu-
sion ratio of zero and the other trust shall
have an inclusion ratio of 1.
‘‘(iii) 
REGULATIONS.—The 
term
‘qualified severance’ includes any other
severance permitted under regulations pre-
scribed by the Secretary.
‘‘(C) 
TIMING
AND
MANNER
OF
SEVERANCES.—A severance pursuant to this
paragraph may be made at any time. The Sec-
retary shall prescribe by forms or regulations
the manner in which the qualified severance
shall be reported to the Secretary.’’.
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to severances after December 31,
1999.
SEC. 118. MODIFICATION OF CERTAIN VALUATION RULES.
(a) GIFTS FOR WHICH GIFT TAX RETURN FILED OR
DEEMED ALLOCATION MADE.—Paragraph (1) of section
2642(b) of the Internal Revenue Code of 1986 (relating
to valuation rules, etc.) is amended to read as follows:
‘‘(1) GIFTS
FOR
WHICH
GIFT
TAX
RETURN
FILED OR DEEMED ALLOCATION MADE.—If the allo-
cation of the GST exemption to any transfers of
property is made on a gift tax return filed on or be-
fore the date prescribed by section 6075(b) for such
transfer or is deemed to be made under section 2632
(b)(1) or (c)(1)—
‘‘(A) the value of such property for pur-
poses of subsection (a) shall be its value as fi-
nally determined for purposes of chapter 12
(within the meaning of section 2001(f)(2)), or,
in the case of an allocation deemed to have been
made at the close of an estate tax inclusion pe-
riod, its value at the time of the close of the es-
tate tax inclusion period, and
‘‘(B) such allocation shall be effective on
and after the date of such transfer, or, in the
case of an allocation deemed to have been made
at the close of an estate tax inclusion period, on
and after the close of such estate tax inclusion
period.’’.
(b) TRANSFERS AT DEATH.—Subparagraph (A) of
section 2642(b)(2) of the Internal Revenue Code of 1986
is amended to read as follows:
‘‘(A) TRANSFERS AT DEATH.—If property
is transferred as a result of the death of the
transferor, the value of such property for pur-
poses of subsection (a) shall be its value as fi-
nally determined for purposes of chapter 11; ex-
cept that, if the requirements prescribed by the
Secretary respecting allocation of post-death
changes in value are not met, the value of such
property shall be determined as of the time of
the distribution concerned.’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to transfers subject to chapter 11
or 12 of the Internal Revenue Code of 1986 made after
December 31, 1999.
SEC. 119. RELIEF PROVISIONS.
(a) IN GENERAL.—Section 2642 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the
following new subsection:
‘‘(g) RELIEF PROVISIONS.—
‘‘(1) RELIEF FROM LATE ELECTIONS.—
‘‘(A) IN GENERAL.—The Secretary shall by
regulation prescribe such circumstances and
procedures under which extensions of time will
be granted to make—
‘‘(i) an allocation of GST exemption
described in paragraph (1) or (2) of sub-
section (b), and
‘‘(ii) an election under subsection
(b)(3) or (c)(5) of section 2632.
Such regulations shall include procedures for
requesting comparable relief with respect to
transfers made before the date of the enactment
of this paragraph.
‘‘(B) BASIS
FOR
DETERMINATIONS.—In
determining whether to grant relief under this
paragraph, the Secretary shall take into ac-
count all relevant circumstances, including evi-
dence of intent contained in the trust instru-
ment or instrument of transfer and such other
factors as the Secretary deems relevant. For
purposes of determining whether to grant relief
under this paragraph, the time for making the
allocation (or election) shall be treated as if not
expressly prescribed by statute.
‘‘(2) SUBSTANTIAL
COMPLIANCE.—An alloca-
tion of GST exemption under section 2632 that
demonstrates an intent to have the lowest possible
inclusion ratio with respect to a transfer or a trust
shall be deemed to be an allocation of so much of
the transferor’s unused GST exemption as produces
the lowest possible inclusion ratio. In determining
whether there has been substantial compliance, all
relevant circumstances shall be taken into account,
including evidence of intent contained in the trust
instrument or instrument of transfer and such other
factors as the Secretary deems relevant.’’.
(b) EFFECTIVE DATES.—
(1) RELIEF FROM LATE ELECTIONS.—Section
2642(g)(1) of the Internal Revenue Code of 1986
(as added by subsection (a)) shall apply to requests
pending on, or filed after, December 31, 1999.
(2) 
SUBSTANTIAL
COMPLIANCE.—Section
2642(g)(2) of such Code (as so added) shall apply
to transfers subject to chapter 11 or 12 of the Inter-
nal Revenue Code of 1986 made after December 31,
1999. No implication is intended with respect to the
availability of relief from late elections or the appli-
cation of a rule of substantial compliance on or be-
fore such date.
SEC. 120. EXPANSION OF ESTATE TAX RULE FOR CON-
SERVATION EASEMENTS.
(a) WHERE LAND IS LOCATED.—
(1) 
IN
GENERAL.—Clause 
(i) 
of 
section
2031(c)(8)(A) of the Internal Revenue Code of 1986
(defining land subject to a conservation easement) is
amended—
(A) by striking ‘‘25 miles’’ both places it
appears and inserting ‘‘50 miles’’; and
(B) striking ‘‘10 miles’’ and inserting ‘‘25
miles’’.
(2) EFFECTIVE DATE.—The amendments made
by this subsection shall apply to estates of decedents
dying after December 31, 1999.
(b) CLARIFICATION
OF DATE
FOR DETERMINING
VALUE OF LAND AND EASEMENT.—
(1) IN
GENERAL.—Section 2031(c)(2) of the
Internal Revenue Code of 1986 (defining applicable
percentage) is amended by adding at the end the fol-
lowing new sentence: ‘‘The values taken into account
under the preceding sentence shall be such values as
of the date of the contribution referred to in para-
graph (8)(B).’’.
(2) EFFECTIVE DATE.—The amendment made
by this subsection shall apply to estates of decedents
dying after December 31, 1997.
TITLE II—STUDY OF COSTS OF
REGULATIONS ON FARMERS,
RANCHERS, AND FORESTERS
SEC. 201. DEFINITIONS.
In this title:
(1) REGULATION.—
(A) IN GENERAL.—The term ‘‘regulation’’
means the whole or a part of an agency state-
ment of general or particular applicability and
future effect designed to implement, interpret,
or prescribe law or policy.
(B) EXCLUSION.—The term ‘‘regulation’’
does not include—
(i) the approval or prescription, on a
case-by-case or consolidated case basis, for
the future of rates, wages, corporations, or
financial 
structures 
or 
reorganizations
thereof, prices, facilities, appliances, serv-
ices or allowances therefor, or of valu-
ations, costs, or accounting, or practices
bearing on activities described in this
clause; or
(ii) the granting of an application for
a license, registration, or similar authority,
granting or recognizing an exemption,
granting a variance or petition for relief
from a regulatory requirement, or other
action relieving a restriction or taking any
action necessary to permit new or im-
proved applications of technology.
(2) LICENSE.—The term ‘‘license’’ means the
whole or part of an agency permit, certificate, ap-
proval, registration, charter, membership, statutory
exemption, or other form of permission.
SEC. 202. COMPTROLLER GENERAL STUDY OF REGULA-
TIONS.
(a) DATA REVIEW AND COLLECTION.—The Comp-
troller General of the United States shall—
(1) conduct a review of existing Federal and
non-Federal studies and data regarding the cost to
farmers, ranchers, and foresters of complying with
existing or proposed Federal regulations directly af-
fecting farmers, ranchers, and foresters; and
(2) as necessary, obtain and analyze new data
concerning the costs to farmers, ranchers, and for-
esters of complying with Federal regulations pro-
posed as of June 30, 2000, directly affecting farm-
ers, ranchers, and foresters.
(b) USE OF DATA.—Using the studies and data re-
viewed and collected under subsection (a), the Comptroller
General shall—
(1) assess the overall costs to farmers, ranch-
ers, and foresters of complying with existing and
proposed Federal regulations directly affecting farm-
ers, ranchers, and foresters; and
(2) identify and recommend reasonable alter-
natives to those regulations that will achieve the ob-
jectives of the regulations at less cost to farmers,
ranchers, and foresters.
(c) SUBMISSION OF RESULTS.—Not later than June
30, 2001, the Comptroller General shall submit to the Sec-
retary of Agriculture, the Committee on Agriculture, Nu-
trition, and Forestry of the Senate, and the Committee
on Agriculture of the House of Representatives the results
of the assessment conducted under subsection (b)(1) and
the recommendations prepared under subsection (b)(2).
SEC. 203. RESPONSE OF SECRETARY OF AGRICULTURE.
Not later than September 30, 2001, the Secretary of
Agriculture shall submit to the Committee on Agriculture,
Nutrition, and Forestry of the Senate, and the Committee
on Agriculture of the House of Representatives a report
responding to the recommendations of the Comptroller
General under section 202 regarding reasonable alter-
natives that could achieve the objectives of Federal regula-
tions at less cost to farmers, ranchers, and foresters.
TITLE 
III—EXTENSION 
OF
TRADE AUTHORITIES PROCE-
DURES 
FOR 
RECIPROCAL
TRADE AGREEMENTS
SEC. 301. SHORT TITLE.
This title may be cited as the ‘‘Reciprocal Trade
Agreement Authorities Act of 2000’’.
SEC. 302. TRADE NEGOTIATING OBJECTIVES.
(a) OVERALL TRADE NEGOTIATING OBJECTIVES.—
The overall trade negotiating objectives of the United
States for agreements subject to the provisions of section
303 are—
(1) to obtain more open, equitable, and recip-
rocal market access;
(2) to obtain the reduction or elimination of
barriers and distortions that are directly related to
trade and that decrease market opportunities for
United States exports or otherwise distort United
States trade;
(3) to further strengthen the system of inter-
national trading disciplines and procedures, includ-
ing dispute settlement; and
(4) to foster economic growth, raise living
standards, and promote full employment in the
United States and to enhance the global economy.
(b) PRINCIPAL TRADE NEGOTIATING OBJECTIVES.—
(1) TRADE BARRIERS AND DISTORTIONS.—The
principal negotiating objectives of the United States
regarding trade barriers and other trade distortions
are—
(A) to expand competitive market opportu-
nities for United States exports and to obtain
fairer and more open conditions of trade by re-
ducing or eliminating tariff and nontariff bar-
riers and policies and practices of foreign gov-
ernments directly related to trade that decrease
market opportunities for United States exports
or otherwise distort United States trade; and
(B) to obtain reciprocal tariff and non-
tariff barrier elimination agreements, with par-
ticular attention to those tariff categories cov-
ered in section 111(b) of the Uruguay Round
Agreements Act (19 U.S.C. 3521(b)).
(2) TRADE IN SERVICES.—The principal negoti-
ating objective of the United States regarding trade
in services is to reduce or eliminate barriers to inter-
national trade in services, including regulatory and
other barriers that deny national treatment or un-
reasonably restrict the establishment or operations
of service suppliers.
(3) FOREIGN INVESTMENT.—The principal ne-
gotiating objective of the United States regarding
foreign investment is to reduce or eliminate artificial
or trade-distorting barriers to trade related foreign
investment by—
(A) reducing or eliminating exceptions to
the principle of national treatment;
(B) freeing the transfer of funds relating
to investments;
(C) reducing or eliminating performance
requirements and other unreasonable barriers
to the establishment and operation of invest-
ments;
(D) seeking to establish standards for ex-
propriation and compensation for expropriation,
consistent with United States legal principles
and practice; and
(E) providing meaningful procedures for
resolving investment disputes.
(4) INTELLECTUAL PROPERTY.—The principal
negotiating objectives of the United States regarding
trade-related intellectual property are—
(A) to further promote adequate and effec-
tive protection of intellectual property rights,
including through—
(i)(I) ensuring accelerated and full
implementation of the Agreement on
Trade-Related 
Aspects 
of 
Intellectual
Property Rights referred to in section
101(d)(15) of the Uruguay Round Agree-
ments Act (19 U.S.C. 3511(d)(15)), par-
ticularly with respect to United States in-
dustries whose products are subject to the
lengthiest transition periods for full com-
pliance by developing countries with that
Agreement, and
(II) ensuring that the provisions of
any multilateral or bilateral trade agree-
ment entered into by the United States
provide protection at least as strong as the
protection afforded by chapter 17 of the
North American Free Trade Agreement
and the annexes thereto;
(ii) providing strong protection for
new and emerging technologies and new
methods of transmitting and distributing
products embodying intellectual property;
(iii) preventing or eliminating dis-
crimination with respect to matters affect-
ing the availability, acquisition, scope,
maintenance, use, and enforcement of in-
tellectual property rights; and
(iv) providing strong enforcement of
intellectual 
property 
rights, 
including
through accessible, expeditious, and effec-
tive civil, administrative, and criminal en-
forcement mechanisms; and