392 
that the employer would have been required to 
pay under section 3111 with respect to such 
partner if the partner’s self-employment income 
as reported by the partnership were wages sub-
ject to the FICA tax. A partner and partner-
ship can agree to treat no portion of a partner’s 
SECA tax as allocable to the partnership. 
‘‘(C) PROPRIETORSHIP.—In the case of an 
individual who is a proprietor or sole owner and 
provider of service to a business entity, the indi-
vidual shall allocate the portion of one-half of 
his SECA tax not allocated pursuant to sub-
paragraph (B) to his business entities in ac-
cordance with rules prescribed by the Secretary. 
‘‘(c) SPECIAL RULE.—Under rules prescribed by the 
Secretary, an individual subject to the self-employment tax 
shall pay half of the self-employment tax on an amount 
of self employment income not less than the amount of 
the individual’s self-employment income taken into ac-
count by partnerships under subparagraph (B) of sub-
section (b)(3). 
‘‘SEC. 283. CREDIT CARRYOVER. 
‘‘(a) CARRYOVER.—A current-year credit that is not 
applied in the taxable year in which earned shall constitute
393 
a credit carryover until applied but for no more than 15 
taxable years. 
‘‘(b) ORDER OF USE.—For purposes of determining 
which credits are applied under section 281, if the total 
credit allowable in a taxable year is less than the sum of 
the current-year payroll credit and the carryover credits, 
the current-year payroll credit shall be considered applied 
first and then credit carryovers shall be considered applied 
in the order earned. 
‘‘Subchapter M—Import Tax 
‘‘Sec. 286. Imposition of tax on property. 
‘‘Sec. 287. Imposition of tax on import of services. 
‘‘Sec. 288. General rules for the import tax. 
‘‘SEC. 286. IMPOSITION OF TAX ON PROPERTY. 
‘‘(a) GENERAL RULE.—There is hereby imposed a 
tax equal to 11 percent of the customs value of all prop-
erty entered into the United States for consumption, use 
or warehousing. 
‘‘(b) LIABILITY FOR TAX.—The tax imposed on the 
import of property by subsection (a) shall be paid by the 
person entering the property into the United States for 
consumption, use or warehousing. Such tax shall be due 
and payable at the time of import. 
‘‘(c) IMPORTS
OF PREVIOUSLY EXPORTED PROP-
ERTY.—In the case of any article that is classified under 
a heading or subheading of subchapter I or II of chapter 
98 of the Tariff Schedules of the United States, the tax
394 
under this section shall be imposed only on that portion 
of the customs value of such article that is dutiable under 
such heading or subheading. 
‘‘(d) IMPORTS FOR PERSONAL CONSUMPTION.—The 
import tax imposed by this section shall not apply to any 
article entered into the United States duty free under sub-
chapters I through VII of chapter 98 of the Tariff Sched-
ules of the United States. 
‘‘(e) EXCEPTION FOR CERTAIN COMMODITIES AND 
PRODUCTS.—The import tax imposed by this section shall 
not apply to petroleum, petroleum products or such com-
modities or products as the President shall by Executive 
Order determine to be in short supply and vital to national 
security. 
‘‘SEC. 287. IMPOSITION OF TAX ON IMPORT OF SERVICES. 
‘‘(a) GENERAL RULE.—There is hereby imposed a 
tax equal to 11 percent of the cost of all services treated 
as imported into the United States during the taxable year 
of the service recipient. 
‘‘(b) LIABILITY FOR THE TAX.—The tax on the im-
port of services imposed by subsection (a) shall be paid 
by the person who receives the imported services. The tax 
shall be payable as if it were an addition to the business 
tax imposed by section 201.
395 
‘‘(c) IMPORTED SERVICES.—For purposes of this sec-
tion, services shall be treated as imported if they are treat-
ed as imported under section 267 (general rules on import 
of services) or section 270 (related to insurance). 
‘‘(d) SPECIAL RULE FOR INSURANCE.—The seller of 
insurance that is treated as imported under section 270 
shall be liable for the collection of the tax imposed by sub-
section (a) on the insurance and for paying such tax to 
the Secretary. The first sentence of subsection (b) (relat-
ing to the person liable for the tax) shall apply to insur-
ance only to the extent that the seller of the insurance 
services does not collect such tax. 
‘‘SEC. 288. GENERAL RULES FOR THE IMPORT TAX. 
‘‘(a) IMPORT TAX.—‘Import tax’ means the tax im-
posed by section 286 on the import of property and the 
tax imposed by section 287 on the import of services. 
‘‘(b) NO PAYROLL TAX CREDIT.—The payroll tax 
credit shall not be allowed against the import tax. 
‘‘Subchapter N—Transition Rules 
‘‘Sec. 290. Amortization of transition basis. 
‘‘Sec. 291. Sales of transition basis property. 
‘‘Sec. 292. Safe harbor leases. 
‘‘Sec. 293. Carryovers. 
‘‘Sec. 294. Section 481 adjustments. 
‘‘SEC. 290. AMORTIZATION OF TRANSITION BASIS. 
‘‘(a) TRANSITION BASIS DEDUCTION.—The ‘transi-
tion basis deduction’ for a taxable year is the sum of the
396 
amortization allowance determined under this section for 
the taxable year. 
‘‘(b) AMORTIZATION RULES.—The amortization al-
lowance for each category of amortizable basis shall be de-
termined by amortizing the amortizable basis of such cat-
egory ratably over the amortization period for the category 
beginning January 1, 2007. 
‘‘(c) AMORTIZATION PERIOD.—The amortization pe-
riods shall be determined in accordance with the following 
table: 
‘‘In the case of: 
The amortization period is: 
Category I basis ....................................................................... 15 years
Category II basis ...................................................................... 30 years
Category III basis .................................................................... 40 years
Unrecovered inventory costs .................................................... 5 years.
‘‘(d) CATEGORIES.— 
‘‘(1) CATEGORY I BASIS.—‘Category I basis’ is 
the sum of the unrecovered bases as of January 1, 
2007, of all depreciable property placed in service 
prior to January 1, 2007, and the unamortized por-
tion of amortizable costs incurred before January 1, 
2007, if— 
‘‘(A) cost recovery or amortization began 
before January 1, 2007, and 
‘‘(B) the remaining recovery period or am-
ortization period as of January 1, 2007, is less 
than 15 years.
397 
‘‘(2) CATEGORY II BASIS.—‘Category II basis’ 
is the sum of the unrecovered bases as of January 
1, 2007, of all depreciable property placed in service 
prior to January 1, 2007, and the unamortized por-
tion of amortizable costs incurred before January 1, 
2007, if— 
‘‘(A) cost recovery or amortization began 
before January 1, 2007, and 
‘‘(B) the remaining recovery period or am-
ortization period as of January 1, 2007, is 15 
years or more. 
‘‘(3) CATEGORY III BASIS.—‘Category III basis’ 
is the sum of the adjusted basis of each asset satis-
fying the following requirements: 
‘‘(A) The asset was placed in service prior 
to January 1, 2007. 
‘‘(B) The asset was used in a business ac-
tivity in 2007. 
‘‘(C) The cost of the asset was capitalized 
and not depreciable or otherwise recoverable 
under the Internal Revenue Code of 1986. 
‘‘(D) The cost of the asset would have con-
stituted deductible expenses under the business 
tax if such cost had been incurred after 2006.
398 
‘‘(4) UNRECOVERED INVENTORY COSTS.—‘Un-
recovered inventory costs’ means the cost of goods 
sold (as determined under the Internal Revenue 
Code of 1986) if a business entity sold all of its in-
ventory (including inventory being produced) on the 
effective date of the business tax. 
‘‘(e) RULES OF APPLICATION.— 
‘‘(1) REMAINING RECOVERY PERIOD.— 
‘‘(A) TIME OF MEASURE.—The remaining 
recovery period shall be determined as of De-
cember 31, 2006, and shall include each taxable 
year ending after such date in which a deduc-
tion would have been allowed under the Internal 
Revenue Code of 1986. 
‘‘(B) ACCOUNTING METHOD.—The remain-
ing recovery period shall be determined using 
the cost recovery method and rules applicable 
for determining taxable income under the Inter-
nal Revenue Code of 1986. 
‘‘(2) DEPLETABLE ASSETS.—Under rules pre-
scribed by the Secretary, this section shall apply to 
the remaining cost basis of depletable property and 
to other property for which a cost recovery method 
other than one based on time is used.
399 
‘‘SEC. 291. SALES OF TRANSITION BASIS PROPERTY. 
‘‘(a) IN GENERAL.—Except as provided in subsection 
(b), for purposes of determining the tax consequences of 
a sale, retirement, casualty or conversion to personal use 
of an asset whose basis or cost is taken into account under 
section 90, the amount to be amortized shall be treated 
as fully deducted upon the adoption of the business tax. 
‘‘(b) SUBSTANTIAL SALES.— 
‘‘(1) IN GENERAL.—In the case of a substantial 
sale of assets to which the amortization rules of sec-
tion 90 apply, the purchaser and seller may jointly 
elect to have the purchaser assume the amortization 
deductions attributable to such assets, in which 
case— 
‘‘(A) the seller’s taxable receipts from such 
sale shall be reduced by the amount of 
unamortized basis or cost assumed by the pur-
chaser, 
‘‘(B) the purchaser may treat as a cost of 
a business purchase only the portion of the pur-
chase price in excess of the amount of 
unamortized basis or cost assumed, 
‘‘(C) the unamortized basis or cost as-
sumed shall continue to be amortized in the 
manner amortized by the seller.
400 
‘‘(2) SUBSTANTIAL SALE.—A sale of assets by 
a business entity to another business entity is a sub-
stantial sale if— 
‘‘(A) more than 20 percent (in fair market 
value or in original cost) of the assets of the 
seller are sold, 
‘‘(B) the total consideration for the sale 
exceeds $1 million or 20 percent of the taxable 
receipts of the seller for the taxable year pre-
ceding the year of the sale, or 
‘‘(C) the sale satisfies other criteria estab-
lished by the Secretary to prevent distortions in 
gross profits resulting from asset sales. 
‘‘SEC. 292. SAFE HARBOR LEASES. 
‘‘(a) IN GENERAL.—In the case of a safe harbor 
lease, rental payments deemed to occur under the lease 
and interest payments deemed to be made under the leases 
shall constitute costs of business purchases, and rental in-
come and interest income deemed to be earned under the 
lease shall constitute taxable receipts. The transition basis 
deduction rules shall apply to the lessor’s adjusted basis 
in assets subject to a safe harbor lease. 
‘‘(b) SAFE HARBOR LEASE.—‘Safe harbor lease’ 
means a sale and leaseback transaction entered into pur-
suant to section 168(f)(8) of the Internal Revenue Code,
401 
as added by the Economic Recovery Tax Act of 1981, 
when such provision was in effect but only if such trans-
action would not be treated as a sale and leaseback for 
tax purposes but for that provision. 
‘‘SEC. 293. CARRYOVERS. 
‘‘(a) NO LOSS CARRYOVERS.—No deduction shall be 
allowed under the business tax for net operating loss 
carryovers, capital loss carryovers, or any other loss 
carryovers from the income tax under the Internal Rev-
enue Code of 1986. 
‘‘(b) NO CREDIT CARRYOVERS.—No credits shall be 
allowed under the business tax for business credit 
carryovers, minimum tax credit carryovers, or any other 
credit carryovers from the income tax under the Internal 
Revenue Code of 1986. 
‘‘SEC. 294. SECTION 481 ADJUSTMENTS. 
‘‘(a) POSITIVE NET SECTION 481 ADJUSTMENT 
AMOUNT.—If, as of January 1, 2007, a business entity 
has a positive net section 481 adjustment amount, the 
amount shall be applied to reduce the transition basis in 
accounts (for purposes of section 290) in the following 
order: 
‘‘(1) First, to reduce the category I basis (but 
not below zero),
402 
‘‘(2) Second, to reduce the category II basis 
(but not below zero), 
‘‘(3) Third, to reduce the unrecovered inventory 
costs. 
‘‘(b) NEGATIVE NET SECTION 481 ADJUSTMENT 
AMOUNT.—If, as of January 1, 2007, a business entity 
has a negative net section 481 adjustment amount, the 
amount shall be applied to increase category I basis for 
purposes of section 290. 
‘‘(c) SECTION 481 ADJUSTMENT.—A business enti-
ty’s net section 481 adjustment is determined by sub-
tracting— 
‘‘(1) the sum of all additional deductions to 
which a business entity would be entitled by reason 
of section 481 of the Internal Revenue Code of 1986 
for periods beginning on or after the effective date 
of the business tax with respect to changes in ac-
counting methods made before such effective date, 
from 
‘‘(2) the sum of all additional income which a 
business entity would recognize by reason of section 
481 of the Internal Revenue Code of 1986 for peri-
ods beginning on or after the effective date of the 
business tax with respect to changes in accounting 
methods made before such effective date, in each
403 
case assuming that the income tax under the Inter-
nal Revenue Code of 1986 remained in effect. 
‘‘Subchapter O—Rules for Administration, 
Consolidated Returns 
‘‘Sec. 301. Returns, due dates, etc. 
‘‘Sec. 302. Consolidated returns. 
‘‘SEC. 301. RETURNS, DUE DATES, ETC. 
‘‘(a) IN GENERAL.—Until subtitle F is amended to 
reflect the adoption of this chapter, the rules of subtitle 
F relating to C corporations shall apply to business enti-
ties with respect to— 
‘‘(1) returns and records; 
‘‘(2) time and place for paying tax; 
‘‘(3) assessment of taxes; 
‘‘(4) collections and liens; 
‘‘(5) abatements, credits, and refunds; 
‘‘(6) interest on underpayments and overpay-
ments; 
‘‘(7) additions to tax and penalties; 
‘‘(8) closing agreements and compromises; 
‘‘(9) crimes; 
‘‘(10) judicial proceedings; 
‘‘(11) discovery of liability and enforcement; 
and 
‘‘(12) estimated taxes.
404 
‘‘(b) INDIVIDUALS ENGAGING IN BUSINESS ACTIVI-
TIES.—Under rules prescribed by the Secretary, individ-
uals engaging in business activities on their own or with 
their spouses shall be permitted to file their business tax 
returns with their individual tax returns and shall be sub-
ject to estimated tax rules for individual income tax re-
turns. 
‘‘SEC. 302. CONSOLIDATED RETURNS. 
‘‘(a) IN GENERAL.—Business entities may file con-
solidated returns of business tax if they would have been 
permitted to file consolidated returns under section 1501 
of the Internal Revenue Code and such section were ap-
plied by treating each business entity as a corporation and 
its owners or partners as shareholders. 
‘‘(b) FINANCIAL
INSTITUTIONS.—Financial inter-
mediation businesses may be included in consolidated re-
turns, but each financial intermediation business must 
compute its gross profits separately. 
‘‘(c) INTERCOMPANY TRANSACTIONS.—In computing 
the gross profits of a consolidated group, intercompany 
transactions can be taken into account, or at the election 
of the filer, be disregarded (except in the case of trans-
actions with financial intermediation businesses).
405 
‘‘Subchapter P—Definitions and Rules of 
Application 
‘‘Sec. 310. Definitions. 
‘‘Sec. 311. Rules of application. 
‘‘SEC. 310. DEFINITIONS. 
‘‘(a) IN GENERAL.—When used in this chapter, 
where not otherwise distinctly expressed or manifestly in-
compatible with the intent thereof— 
‘‘(1) USA INCOME
TAX.—‘USA Income Tax’ 
and ‘Simplified USA Tax’ for individuals mean the 
tax imposed by chapter 1. 
‘‘(2) INTERNAL REVENUE CODE OF 1986.—‘In-
ternal Revenue Code of 1986’ means the Internal 
Revenue Code of 1986 as in effect immediately be-
fore the enactment of the Simplified USA Tax. 
‘‘(3) UNITED STATES.—‘United States’ means 
the States and the District of Columbia. 
‘‘(b) TERMS DEFINED IN CHAPTER 2.—If a term 
that is used but not defined in this chapter or in section 
7701 is defined in chapter 1, the definition in chapter 1 
shall apply except if manifestly incompatible with the in-
tent of the provision in which the term is used. 
‘‘SEC. 311. RULES OF APPLICATION. 
‘‘(a) DEFINITIONS.—Any definition included in this 
chapter shall apply for all purposes of this chapter un-
less—
406 
‘‘(1) such definition is limited to the purposes 
of a particular chapter, section, or subsection, or 
‘‘(2) the definition clearly would not be applica-
ble in a particular context. 
‘‘(b) INTERPRETATIONS CONSISTENT WITH INTER-
NAL REVENUE CODE OF 1986.—Terms not defined in this 
chapter or elsewhere in this title, but defined in the Inter-
nal Revenue Code of 1986, shall be interpreted in a man-
ner consistent with the Internal Revenue Code of 1986, 
except to the extent such interpretation would be incon-
sistent with the principles and purposes of this chapter.’’ 
(b) The amendments made by this section shall be 
effective on January 1, 2007, except to the extent other-
wise specifically provided in the text of such amendments. 
SEC. 302. REPEAL OF CHAPTER 6. 
Chapter 6 of the Code (relating to consolidated re-
turns) is repealed as of January 1, 2007. 
TITLE IV—DEFERRED 
COMPENSATION PLANS 
SEC. 401. PROVISIONS SAVED. 
(a) IN GENERAL.—Except as otherwise provided in 
this title, the sections contained in subchapter D of chap-
ter 1 of the Code (relating to deferred compensation, etc.) 
are hereby saved as chapter 3.
407 
(b) LIMITATIONS
ON CHAPTER 3.—The following 
new section is inserted before section 401 of the Code (as 
saved by subsection (a)): 
‘‘SEC. 400. EFFECT OF CHAPTER 3. 
‘‘(a) IN GENERAL.—The provisions of chapter 3 (sec-
tions 401 through 420) are included in this subtitle for 
purposes of cross-reference and for purposes of deter-
mining whether plans are exempt from the business tax 
and whether contributions to plans are deductible or ex-
cludable from gross income under chapter 1. 
‘‘(b) EFFECT
ON BUSINESS TAX DEDUCTIONS.— 
Notwithstanding any provision to the contrary in this 
chapter, no provision of this chapter shall cause any 
amount to be treated as a cost of business purchase or 
to otherwise be deducted from gross receipts for purposes 
of computing the Simplified USA for Tax Businesses 
under chapter 2. 
‘‘(c) NO CREDITS.—Notwithstanding any provision 
to the contrary in this chapter, no provision of this chapter 
shall result in a tax credit against any tax imposed by 
chapter 1 or chapter 2. 
‘‘(d) EFFECT OF FAILURE TO COMPLY WITH PROVI-
SIONS.—A failure to comply with applicable provisions in 
this chapter could cause a plan to lose its exemption from 
the business tax and, thereby subject certain business ac-
408 
tivities of the plan to the business tax and/or result in 
the constructive distribution of plan assets to plan partici-
pants.’’ 
(c) SECTION 408A SUSPERSEDED BY SECTION 30.— 
Section 408A is repealed. 
SEC. 402. CLERICAL AMENDMENTS. 
(a) TABLE OF SECTIONS.—The table of sections for 
subpart A of part 1 of chapter 3 of the USA Tax Code 
(formerly subchapter D of chapter 1 of the Code) is 
amended by inserting at the beginning of the table: 
‘‘CHAPTER 3—DEFERRED COMPENSATION, 
ETC’’. 
(b) RENUMBERING OF CHAPTERS.— 
(1) RENUMBER CHAPTERS.—Chapters 2 and 3 
of the Code are renumbered 4 and 5 respectively. 
Such renumbering shall be reflected in all tables and 
headings in the Code. 
(2) CROSS REFERENCES.—Any cross reference 
to chapter 2 or 3 of the Code contained in any provi-
sion of the Code that is not amended by this Act or 
in any other statute shall be treated as a reference 
to such chapter as renumbered by paragraph (1).
409 
TITLE V—REPEAL OF ESTATE 
AND GIFT TAXES 
SEC. 501. REPEAL OF GRATUITOUS TRANSFER TAXES. 
Subtitle B of the Code (relating to estate and gift 
taxes) is repealed. 
SEC. 502. EFFECTIVE DATE. 
Section 501 shall apply to— 
(1) gifts made after December 31, 2006; 
(2) the estates of decedents dying after Decem-
ber 31, 2006; and 
(3) generating skipping transfers (within the 
meaning of subchapter B of chapter 13 as in effect 
before its repeal by this Act) occurring after Decem-
ber 31, 2006. 
TITLE VI—TECHNICAL AND AD-
MINISTRATIVE CHANGES: EF-
FECTIVE DATES 
SEC. 601. USA TAX CODE. 
(a) REDESIGNATION OF THE CODE.—The Internal 
Revenue Title enacted August 16, 1954, and as heretofore 
and hereby amended may be cited as the ‘‘USA Tax 
Code’’. The USA Tax Code, as hereinafter amended, may 
be cited as the ‘‘USA Tax Code, as amended’’.
410 
(b) REFERENCES IN LAWS, ETC.—Except where in-
appropriate, any reference in any law, Executive order, or 
other document— 
(1) to the Internal Revenue Code of 1954 or 
the Internal Revenue Code of 1986 shall include a 
reference to the USA Tax Code or the USA Tax 
Code, as amended, 
(2) to the USA Tax Code or the USA Tax 
Code, as amended, shall include a reference, with re-
spect to periods before January 1, 2007, to the In-
ternal Revenue Code of 1954 or the Internal Rev-
enue Code of 1986. 
SEC. 602. REVISIONS TO THE CODE. 
Not later than January 1, 2008, the Secretary shall 
submit to Congress proposed changes in the USA Tax 
Code that— 
(1) eliminate cross-references to the Internal 
Revenue Code of 1986 (except with respect to tran-
sition issues) and insert provisions similar to the 
cross-referenced sections of the Internal Revenue 
Code of 1986, 
(2) revise subtitles C through J of the USA 
Tax Code to fully reflect the amendments to subtitle 
A of the Code made by this Act and the repeal of 
subtitle B,
411 
(3) include statutory definitions or rules in 
cases where the Secretary concludes that the defini-
tions or rules cannot or should not be addressed by 
regulation, 
(4) revise chapter 4 of the USA Tax Code (as 
renumbered by section 402 of this Act) (relating to 
the self-employment tax) to conform to changes 
made by this Act, and 
(5) revise chapter 5 of the USA Tax Code (as 
renumbered by section 402 of this Act) (relating to 
withholding on nonresident aliens and foreign cor-
porations) to reflect changes made in this Act. 
SEC. 603. APPLICATION OF SUBTITLE F. 
Until such time as subtitle F of the Code is amended 
to reflect the amendments made by this Act, the provisions 
of subtitle F shall be treated as generally applying to the 
Simplified USA Tax— 
(1) without regard to specific cross references, 
(2) without regard to provisions relating to 
partnerships, and 
(3) as if the business tax under chapter 2 were 
the corporate income tax and all business entities 
were corporations (except for purposes of collection, 
in which case the owners of noncorporate entities 
shall be obligated for taxes owned by the entities to
412 
the same extent as they would if the entity owed the 
tax prior to the amendment of the Code). 
SEC. 604. CLERICAL AMENDMENT. 
The portion of the table at the beginning of the Code 
listing subtitles and chapters of subtitle A is amended to 
read as follows: 
‘‘Subtitle A. Simplified USA Tax 
‘‘Subtitle B. [deleted] 
‘‘Subtitle C. Employment taxes 
‘‘Subtitle D. Miscellaneous excise taxes 
‘‘Subtitle E. Alcohol, tobacco and certain other excise taxes 
‘‘Subtitle F. Procedure and administration 
‘‘Subtitle G. The joint committee on taxation 
‘‘Subtitle H. Financing of presidential election campaigns 
‘‘Subtitle I. Trust fund code 
‘‘Subtitle K. Group health plan requirements 
‘‘Subtitle A—Simplified USA Tax 
‘‘CHAPTER 1. SIMPLIFIED USA TAX FOR INDIVIDUALS 
‘‘CHAPTER 2. SIMPLIFIED USA TAX FOR BUSINESSES 
‘‘CHAPTER 3. DEFERRED COMPENSATION PLANS 
‘‘CHAPTER 4. TAX ON SELF-EMPLOYMENT INCOME 
‘‘CHAPTER 5. WITHHOLDING OF TAX ON NONRESIDENT ALIENS AND FOREIGN 
CORPORATIONS’’. 
SEC. 605. EFFECTIVE DATES. 
(a) IN GENERAL.—Except as otherwise provided in 
this Act, the amendments made by this Act shall be effec-
tive on January 1, 2007, with respect to tax years begin-
ning on such date.
413 
(b) SPECIAL RULES FOR BUSINESSES WITH 52–53 
WEEK YEAR.—If a business uses a 52–53 week taxable 
year the amendments made by this Act shall apply to the 
business with respect to its tax year beginning in the last 
week in December except with respect to any transactions 
occurring during 2006 that were structured to take advan-
tage of the application of this Act to such business at a 
time when this Act did not apply to other businesses or 
to individuals. 
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