282
trust fund) of the assets transferred to the
regulated investment company—
‘‘(I) notwithstanding paragraph
(1), gain shall be recognized to the
common trust fund on such transfer
in an amount equal to such excess,
‘‘(II) the basis of the assets re-
ceived by the regulated investment
company in such transfer shall be in-
creased by the amount so recognized,
and
‘‘(III) any adjustment to the
basis of a participant’s interest in the
common trust fund as a result of the
gain so recognized shall be treated as
occurring immediately before the ex-
change referred to in paragraph
(1)(B).
‘‘(ii) 
ASSUMED
LIABILITIES.—For
purposes of clause (i), the term ‘assumed
liabilities’ means the aggregate of—
‘‘(I) any liability of the common
trust fund assumed by the regulated
investment company in connection
283
with the transfer referred to in para-
graph (1)(A), and
‘‘(II) any liability to which prop-
erty so transferred is subject.
‘‘(4) COMMON TRUST FUND MUST MEET DIVER-
SIFICATION RULES.—This subsection shall not apply
to any common trust fund which would not meet the
requirements of section 368(a)(2)(F)(ii) if it were a
corporation. For purposes of the preceding sentence,
Government securities shall not be treated as securi-
ties of an issuer in applying the 25-percent and 50-
percent test and such securities shall not be excluded
for purposes of determining total assets under clause
(iv) of section 368(a)(2)(F).’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to transfers after the date of
the enactment of this Act.
Subtitle D—Tax-Exempt Bond
Provisions
SEC. 531. REPEAL OF $100,000 LIMITATION ON UNSPENT
PROCEEDS UNDER 1-YEAR EXCEPTION FROM
REBATE.
Subclause (I) of section 148(f)(4)(B)(ii) (relating to
additional period for certain bonds) is amended by striking
‘‘the lesser of 5 percent of the proceeds of the issue or
284
$100,000’’ and inserting ‘‘5 percent of the proceeds of the
issue’’.
SEC. 532. EXCEPTION FROM REBATE FOR EARNINGS ON
BONA FIDE DEBT SERVICE FUND UNDER
CONSTRUCTION BOND RULES.
Subparagraph (C) of section 148(f)(4) is amended by
adding at the end thereof the following new clause:
‘‘(xvii) TREATMENT
OF
BONA
FIDE
DEBT
SERVICE
FUNDS.—If the spending
requirements of clause (ii) are met with re-
spect to the available construction proceeds
of a construction issue, then paragraph (2)
shall not apply to earnings on a bona fide
debt service fund for such issue.’’
SEC. 533. REPEAL OF DEBT SERVICE-BASED LIMITATION
ON INVESTMENT IN CERTAIN NONPURPOSE
INVESTMENTS.
Subsection (d) of section 148 (relating to special
rules for reasonably required reserve or replacement fund)
is amended by striking paragraph (3).
SEC. 534. REPEAL OF EXPIRED PROVISIONS.
(a) Paragraph (2) of section 148(c) is amended by
striking subparagraph (B) and by redesignating subpara-
graphs (C), (D), and (E) as subparagraph (B), (C), and
(D), respectively.
285
(b) Paragraph (4) of section 148(f) is amended by
striking subparagraph (E).
SEC. 535. CLARIFICATION OF INVESTMENT–TYPE PROP-
ERTY.
Subparagraph (D) of section 148(b)(2) is amended
to read as follows:
‘‘(D) any investment-type property, or’’.
SEC. 536. EFFECTIVE DATES.
(a) IN GENERAL.—Except as provided in subsection
(b), the amendments made by this subtitle shall apply to
bonds issued after the date of the enactment of this Act.
(b) INVESTMENT-TYPE
PROPERTY.—The amend-
ment made by section 535 shall take effect as if included
in the amendments made by section 1301 of the Tax Re-
form Act of 1986.
Subtitle E—Insurance Provisions
SEC. 541. TREATMENT 
OF 
CERTAIN 
INSURANCE 
CON-
TRACTS ON RETIRED LIVES.
(a) GENERAL RULE.—
(1) Paragraph (2) of section 817(d) (defining
variable contract) is amended by striking ‘‘or’’ at the
end of subparagraph (A), by striking ‘‘and’’ at the
end of subparagraph (B) and inserting ‘‘or’’, and by
inserting after subparagraph (B) the following new
subparagraph:
286
‘‘(C) provides for funding of insurance on
retired lives as described in section 807(c)(6),
and’’.
(2) Paragraph (3) of section 817(d) is amended
by striking ‘‘or’’ at the end of subparagraph (A), by
striking the period at the end of subparagraph (B)
and inserting ‘‘, or’’, and by inserting after subpara-
graph (B) the following new subparagraph:
‘‘(C) in the case of funds held under a con-
tract described in paragraph (2)(C), the
amounts paid in, or the amounts paid out, re-
flect the investment return and the market
value of the segregated asset account.’’
(b) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
December 31, 1992.
SEC. 542. TREATMENT OF MODIFIED GUARANTEED CON-
TRACTS.
(a) GENERAL RULE.—Subpart E of part I of sub-
chapter L of chapter 1 (relating to definitions and special
rules) is amended by inserting after section 817 the follow-
ing new section:
287
‘‘SEC. 817A. SPECIAL RULES FOR MODIFIED GUARANTEED
CONTRACTS.
‘‘(a) COMPUTATION OF RESERVES.—In the case of
a modified guaranteed contract, clause (ii) of section
807(e)(1)(A) shall not apply.
‘‘(b) SEGREGATED ASSETS UNDER MODIFIED GUAR-
ANTEED CONTRACTS MARKED TO MARKET.—
‘‘(1) IN GENERAL.—In the case of any life in-
surance company, for purposes of this subtitle—
‘‘(A) Any gain or loss with respect to a
segregated asset shall be treated as ordinary in-
come or loss, as the case may be.
‘‘(B) If any segregated asset is held by
such company as of the close of any taxable
year—
‘‘(i) such company shall recognize
gain or loss as if such asset were sold for
its fair market value on the last business
day of such taxable year, and
‘‘(ii) any such gain or loss shall be
taken into account for such taxable year.
Proper adjustment shall be made in the amount
of any gain or loss subsequently realized for
gain or loss taken into account under the pre-
ceding sentence. The Secretary may provide by
regulations for the application of this subpara-
289
‘‘(C) is a pension plan contract which is
not a life, accident, or health, property, cas-
ualty, or liability contract,
‘‘(3) for which reserves are valued at market for
annual statement purposes, and
‘‘(4) which provides for a net surrender value or
a policyholder’s fund (as defined in section
807(e)(1)).
‘‘(e) REGULATIONS.—The Secretary may prescribe
regulations—
‘‘(1) to provide for the treatment of market
value adjustments under sections 72, 7702, 7702A,
and 807(e)(1)(B),
‘‘(2) to determine the interest rates applicable
under sections 807(c)(3), 807(d)(2)(B), and 812
with respect to a modified guaranteed contract an-
nually, in a manner appropriate for modified guar-
anteed contracts and, to the extent appropriate for
such a contract, to modify or waive the applicability
of section 811(d),
‘‘(3) to provide rules to limit ordinary gain or
loss treatment to assets constituting reserves for
modified guaranteed contracts (and not other assets)
of the company,
290
‘‘(4) to provide appropriate treatment of trans-
fers of assets to and from the segregated account,
and
‘‘(5) as may be necessary or appropriate to
carry out the purposes of this section.’’
(b) CLERICAL AMENDMENT.—The table of sections
for subpart E of part I of subchapter L of chapter 1 is
amended by inserting after the item relating to section
817 the following new item:
‘‘Sec. 817A. Special rules for modified guaranteed contracts.’’
(c) EFFECTIVE DATE.—
(1) IN GENERAL.—The amendments made by
this section shall apply to taxable years beginning
after December 31, 1992.
(2) TREATMENT
OF
NET
ADJUSTMENTS.—In
the case of any taxpayer required by the amend-
ments made by this section to change its calculation
of reserves to take into account market value adjust-
ments and to mark segregated assets to market for
any taxable year—
(A) such changes shall be treated as a
change in method of accounting initiated by the
taxpayer,
(B) such changes shall be treated as made
with the consent of the Secretary, and
291
(C) the adjustments required by reason of
section 481 of the Internal Revenue Code of
1986 shall be taken into account as ordinary in-
come or loss by the taxpayer for the taxpayer’s
first taxable year beginning after December 31,
1992.
Subtitle F—Other Provisions
SEC. 551. CLOSING OF PARTNERSHIP TAXABLE YEAR WITH
RESPECT TO DECEASED PARTNER, ETC.
(a) GENERAL RULE.—Subparagraph (A) of section
706(c)(2) (relating to disposition of entire interest) is
amended to read as follows:
‘‘(A) DISPOSITION
OF
ENTIRE
INTER-
EST.—The taxable year of a partnership shall
close with respect to a partner whose entire in-
terest in the partnership terminates (whether
by reason of death, liquidation, or otherwise).’’
(b) CLERICAL AMENDMENT.—The paragraph head-
ing for paragraph (2) of section 706(c) is amended to read
as follows:
‘‘(2) TREATMENT OF DISPOSITIONS.—’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to partnership taxable years begin-
ning after December 31, 1993.
292
SEC. 552. MODIFICATION OF CREDIT FOR PRODUCING
FUEL FROM A NONCONVENTIONAL SOURCE.
(a) IN GENERAL.—Subparagraph (A) of section
29(c)(2) (relating to gas from geopressured brine, etc.) is
amended by adding at the end the following new sentence:
‘‘If the Federal Energy Regulatory Commission ceases to
make the determinations described in the preceding sen-
tence, the Secretary shall make such determinations in ac-
cordance with section 503 of such Act.’’
(b) 
CONFORMING
AMENDMENT.—Section
29(c)(2)(A) is amended by inserting ‘‘(as in effect before
its repeal by the Natural Gas Wellhead Decontrol Act of
1989)’’ after ‘‘Natural Gas Policy Act of 1978’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect on January 1, 1993.
TITLE VI—ESTATE AND GIFT TAX
PROVISIONS
SEC. 601. CLARIFICATION OF WAIVER OF CERTAIN RIGHTS
OF RECOVERY.
(a) AMENDMENT TO SECTION 2207A.—Paragraph
(2) of section 2207A(a) (relating to right of recovery in
the case of certain marital deduction property) is amended
to read as follows:
‘‘(2) DECEDENT
MAY
OTHERWISE
DIRECT.—
Paragraph (1) shall not apply with respect to any
property to the extent that the decedent in his will
293
(or a revocable trust) specifically indicates an intent
to waive any right of recovery under this subchapter
with respect to such property.’’
(b) AMENDMENT TO SECTION 2207B.—Paragraph
(2) of section 2207B(a) (relating to right of recovery
where decedent retained interest) is amended to read as
follows:
‘‘(2) DECEDENT
MAY
OTHERWISE
DIRECT.—
Paragraph (1) shall not apply with respect to any
property to the extent that the decedent in his will
(or a revocable trust) specifically indicates an intent
to waive any right of recovery under this subchapter
with respect to such property.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply with respect to the estates of dece-
dents dying after the date of the enactment of this Act.
SEC. 602. ADJUSTMENTS FOR GIFTS WITHIN 3 YEARS OF
DECEDENT’S DEATH.
(a) GENERAL RULE.—Section 2035 is amended to
read as follows:
‘‘SEC. 2035. ADJUSTMENTS FOR CERTAIN GIFTS MADE
WITHIN 3 YEARS OF DECEDENT’S DEATH.
‘‘(a) INCLUSION OF CERTAIN PROPERTY IN GROSS
ESTATE.—If—
294
‘‘(1) the decedent made a transfer (by trust or
otherwise) of an interest in any property, or relin-
quished a power with respect to any property, during
the 3-year period ending on the date of the dece-
dent’s death, and
‘‘(2) the value of such property (or an interest
therein) would have been included in the decedent’s
gross estate under section 2036, 2037, 2038, or
2042 if such transferred interest or relinquished
power had been retained by the decedent on the date
of his death,
the value of the gross estate shall include the value of any
property (or interest therein) which would have been so
included.
‘‘(b) INCLUSION OF GIFT TAX ON GIFTS MADE DUR-
ING
3 YEARS
BEFORE
DECEDENT’S
DEATH.—The
amount of the gross estate (determined without regard to
this subsection) shall be increased by the amount of any
tax paid under chapter 12 by the decedent or his estate
on any gift made by the decedent or his spouse during
the 3-year period ending on the date of the decedent’s
death.
‘‘(c) OTHER
RULES
RELATING
TO
TRANSFERS
WITHIN 3 YEARS OF DEATH.—
‘‘(1) IN GENERAL.—For purposes of—
295
‘‘(A) section 303(b) (relating to distribu-
tions in redemption of stock to pay death
taxes),
‘‘(B) section 2032A (relating to special
valuation of certain farms, etc., real property),
and
‘‘(C) subchapter C of chapter 64 (relating
to lien for taxes),
the value of the gross estate shall include the value
of all property to the extent of any interest therein
of which the decedent has at any time made a trans-
fer, by trust or otherwise, during the 3-year period
ending on the date of the decedent’s death.
‘‘(2) COORDINATION WITH SECTION 6166.—An
estate shall be treated as meeting the 35 percent of
adjusted 
gross 
estate 
requirement 
of 
section
6166(a)(1) only if the estate meets such requirement
both with and without the application of paragraph
(1).
‘‘(3) SMALL TRANSFERS.—Paragraph (1) shall
not apply to any transfer (other than a transfer with
respect to a life insurance policy) made during a cal-
endar year to any donee if the decedent was not re-
quired by section 6019 (other than by reason of sec-
296
tion 6019(a)(2)) to file any gift tax return for such
year with respect to transfers to such donee.
‘‘(d) EXCEPTION.—Subsection (a) shall not apply to
any bona fide sale for an adequate and full consideration
in money or money’s worth.
‘‘(e) TREATMENT OF CERTAIN TRANSFERS FROM
REVOCABLE TRUSTS.—For purposes of this section and
section 2038, any transfer from any portion of a trust with
respect to which the decedent was the grantor during any
period when the decedent held the power to revest in the
decedent title to such portion shall be treated as a transfer
made directly by the decedent.’’
(b) CLERICAL AMENDMENT.—The table of sections
for part III of subchapter A of chapter 11 is amended
by striking ‘‘gifts’’ in the item relating to section 2035
and inserting ‘‘certain gifts’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to the estates of decedents dying
after the date of the enactment of this Act.
SEC. 603. CLARIFICATION OF QUALIFIED TERMINABLE IN-
TEREST RULES.
(a) GENERAL RULE.—
(1) ESTATE TAX.—Subparagraph (B) of section
2056(b)(7) (defining qualified terminable interest
297
property) is amended by adding at the end thereof
the following new clause:
‘‘(vi) TREATMENT
OF
CERTAIN
IN-
COME DISTRIBUTIONS.—An income inter-
est shall not fail to qualify as a qualified
income interest for life solely because in-
come for the period after the last distribu-
tion date and on or before the date of the
surviving spouse’s death is not required to
be distributed to the surviving spouse or to
the estate of the surviving spouse.’’
(2) GIFT
TAX.—Paragraph (3) of section
2523(f) is amended by striking ‘‘and (iv)’’ and in-
serting ‘‘(iv), and (vi)’’.
(b) CLARIFICATION OF SUBSEQUENT INCLUSIONS.—
Section 2044 is amended by adding at the end thereof the
following new subsection:
‘‘(d) CLARIFICATION OF INCLUSION OF CERTAIN IN-
COME.—The amount included in the gross estate under
subsection (a) shall include the amount of any income
from the property to which this section applies for the pe-
riod after the last distribution date and on or before the
date of the decedent’s death if such income is not other-
wise included in the decedent’s gross estate.’’
(c) EFFECTIVE DATE.—
298
(1) IN GENERAL.—The amendments made by
this section shall apply with respect to the estates of
decedents dying, and gifts made, after the date of
the enactment of this Act.
(2) APPLICATION OF SECTION 2044 TO TRANS-
FERS BEFORE DATE OF ENACTMENT.—In the case
of the estate of any decedent dying after the date of
the enactment of this Act, if there was a transfer of
property on or before such date—
(A) such property shall not be included in
the gross estate of the decedent under section
2044 of the Internal Revenue Code of 1986 if
no prior marital deduction was allowed with re-
spect to such a transfer of such property to the
decedent, but
(B) such property shall be so included if
such a deduction was allowed.
SEC. 604. TRANSITIONAL RULE UNDER SECTION 2056A.
(a) GENERAL RULE.—In the case of any trust cre-
ated under an instrument executed before the date of the
enactment of the Revenue Reconciliation Act of 1990,
such trust shall be treated as meeting the requirements
of paragraph (1) of section 2056A(a) of the Internal Reve-
nue Code of 1986 if the trust instrument requires that
299
all trustees of the trust be individual citizens of the United
States or domestic corporations.
(b) EFFECTIVE DATE.—The provisions of subsection
(a) shall take effect as if included in the provisions of sec-
tion 11702(g) of the Revenue Reconciliation Act of 1990.
SEC. 605. OPPORTUNITY TO CORRECT CERTAIN FAILURES
UNDER SECTION 2032A.
(a) GENERAL RULE.—Paragraph (3) of section
2032A(d) (relating to modification of election and agree-
ment to be permitted) is amended to read as follows:
‘‘(3) MODIFICATION OF ELECTION AND AGREE-
MENT TO BE PERMITTED.—The Secretary shall pre-
scribe procedures which provide that in any case in
which the executor makes an election under para-
graph (1) (and submits the agreement referred to in
paragraph (2)) within the time prescribed therefor,
but—
‘‘(A) the notice of election, as filed, does
not contain all required information, or
‘‘(B) signatures of 1 or more persons re-
quired to enter into the agreement described in
paragraph (2) are not included on the agree-
ment as filed, or the agreement does not con-
tain all required information,
300
the executor will have a reasonable period of time
(not exceeding 90 days) after notification of such
failures to provide such information or signatures.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to the estates of decedents dying
after the date of the enactment of this Act.
TITLE VII—EXCISE TAX
SIMPLIFICATION
Subtitle A—Provisions Related to
Distilled Spirits, Wines, and Beer
SEC. 701. CREDIT OR REFUND FOR IMPORTED BOTTLED
DISTILLED 
SPIRITS 
RETURNED 
TO 
DIS-
TILLED SPIRITS PLANT.
(a) IN GENERAL.—Paragraph (1) of section 5008(c)
(relating to distilled spirits returned to bonded premises)
is amended by striking ‘‘withdrawn from bonded premises
on payment or determination of tax’’ and inserting ‘‘on
which tax has been determined or paid’’.
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
301
SEC. 702. AUTHORITY TO CANCEL OR CREDIT EXPORT
BONDS WITHOUT SUBMISSION OF RECORDS.
(a) IN GENERAL.—Subsection (c) of section 5175
(relating to export bonds) is amended by striking ‘‘on the
submission of’’ and all that follows and inserting ‘‘if there
is such proof of exportation as the Secretary may by regu-
lations require.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
SEC. 703. REPEAL 
OF 
REQUIRED 
MAINTENANCE 
OF
RECORDS ON PREMISES OF DISTILLED SPIR-
ITS PLANT.
(a) IN GENERAL.—Subsection (c) of section 5207
(relating to records and reports) is amended by striking
‘‘shall be kept on the premises where the operations cov-
ered by the record are carried on and’’.
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
302
SEC. 704. FERMENTED MATERIAL FROM ANY BREWERY
MAY BE RECEIVED AT A DISTILLED SPIRITS
PLANT.
(a) IN GENERAL.—Paragraph (2) of section 5222(b)
(relating to production, receipt, removal, and use of distill-
ing materials) is amended to read as follows:
‘‘(2) beer conveyed without payment of tax
from brewery premises, beer which has been lawfully
removed from brewery premises upon determination
of tax, or’’.
(b) CLARIFICATION OF AUTHORITY TO PERMIT RE-
MOVAL OF BEER WITHOUT PAYMENT OF TAX FOR USE
AS DISTILLING MATERIAL.—Section 5053 (relating to ex-
emptions) is amended by redesignating subsection (f) as
subsection (i) and by inserting after subsection (e) the fol-
lowing new subsection:
‘‘(f) REMOVAL
FOR USE
AS DISTILLING MATE-
RIAL.—Subject to such regulations as the Secretary may
prescribe, beer may be removed from a brewery without
payment of tax to any distilled spirits plant for use as
distilling material.’’
(c) CLARIFICATION
OF REFUND
AND CREDIT
OF
TAX.—Section 5056 (relating to refund and credit of tax,
or relief from liability) is amended—
303
(1) by redesignating subsection (c) as sub-
section (d) and by inserting after subsection (b) the
following new subsection:
‘‘(c) BEER RECEIVED
AT
A DISTILLED SPIRITS
PLANT.—Any tax paid by any brewer on beer produced
in the United States may be refunded or credited to the
brewer, without interest, or if the tax has not been paid,
the brewer may be relieved of liability therefor, under reg-
ulations as the Secretary may prescribe, if such beer is
received on the bonded premises of a distilled spirits plant
pursuant to the provisions of section 5222(b)(2), for use
in the production of distilled spirits.’’, and
(2) by striking ‘‘or rendering unmerchantable’’
in subsection (d) (as so redesignated) and inserting
‘‘rendering unmerchantable, or receipt on the bond-
ed premises of a distilled spirits plant’’.
(d) EFFECTIVE DATE.—The amendments made by
this section shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
SEC. 705. REPEAL OF REQUIREMENT FOR WHOLESALE
DEALERS IN LIQUORS TO POST SIGN.
(a) IN GENERAL.—Section 5115 (relating to sign re-
quired on premises) is hereby repealed.
(b) CONFORMING AMENDMENTS.—
304
(1) Subsection (a) of section 5681 is amended
by striking ‘‘, and every wholesale dealer in liquors,’’
and by striking ‘‘section 5115(a) or’’.
(2) Subsection (c) of section 5681 is amend-
ed—
(A) by striking ‘‘or wholesale liquor estab-
lishment, on which no sign required by section
5115(a) or’’ and inserting ‘‘on which no sign
required by’’, and
(B) by striking ‘‘or wholesale liquor estab-
lishment, or who’’ and inserting ‘‘or who’’.
(3) The table of sections for subpart D of part
II of subchapter A of chapter 51 is amended by
striking the item relating to section 5115.
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect on the date of the enactment
of this Act.
SEC. 706. REFUND OF TAX TO WINE RETURNED TO BOND
NOT LIMITED TO UNMERCHANTABLE WINE.
(a) IN GENERAL.—Subsection (a) of section 5044
(relating to refund of tax on unmerchantable wine) is
amended by striking ‘‘as unmerchantable’’.
(b) CONFORMING AMENDMENTS.—
(1) Section 5361 is amended by striking
‘‘unmerchantable’’.
305
(2) The section heading for section 5044 is
amended by striking ‘‘UNMERCHANTABLE’’.
(3) The item relating to section 5044 in the
table of sections for subpart C of part I of sub-
chapter A of chapter 51 is amended by striking
‘‘unmerchantable’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
SEC. 707. USE OF ADDITIONAL AMELIORATING MATERIAL
IN CERTAIN WINES.
(a) IN GENERAL.—Subparagraph (D) of section
5384(b)(2) (relating to ameliorated fruit and berry wines)
is amended by striking ‘‘loganberries, currants, or goose-
berries,’’ and inserting ‘‘any fruit or berry with a natural
fixed acid of 20 parts per thousand or more (before any
correction of such fruit or berry)’’.
(b) EFFECTIVE DATE.—The amendment made by
this section shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
306
SEC. 708. DOMESTICALLY PRODUCED BEER MAY BE WITH-
DRAWN FREE OF TAX FOR USE OF FOREIGN
EMBASSIES, LEGATIONS, ETC.
(a) IN GENERAL.—Section 5053 (relating to exemp-
tions) is amended by inserting after subsection (f) the fol-
lowing new subsection:
‘‘(g) REMOVALS FOR USE OF FOREIGN EMBASSIES,
LEGATIONS, ETC.—
‘‘(1) IN GENERAL.—Subject to such regulations
as the Secretary may prescribe—
‘‘(A) beer may be withdrawn from the
brewery without payment of tax for transfer to
any customs bonded warehouse for entry pend-
ing withdrawal therefrom as provided in sub-
paragraph (B), and
‘‘(B) beer entered into any customs bonded
warehouse under subparagraph (A) may be
withdrawn for consumption in the United
States by, and for the official and family use of,
such foreign governments, organizations, and
individuals as are entitled to withdraw imported
beer from such warehouses free of tax.
Beer transferred to any customs bonded warehouse
under subparagraph (A) shall be entered, stored,
and accounted for in such warehouse under such
regulations and bonds as the Secretary may pre-
307
scribe, and may be withdrawn therefrom by such
governments, organizations, and individuals free of
tax under the same conditions and procedures as im-
ported beer.
‘‘(2) OTHER RULES TO APPLY.—Rules similar
to the rules of paragraphs (2) and (3) of section
5362(e) of such section shall apply for purposes of
this subsection.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
SEC. 709. BEER MAY BE WITHDRAWN FREE OF TAX FOR
DESTRUCTION.
(a) IN GENERAL.—Section 5053 is amended by in-
serting after subsection (g) the following new subsection:
‘‘(h) REMOVALS
FOR DESTRUCTION.—Subject to
such regulations as the Secretary may prescribe, beer may
be removed from the brewery without payment of tax for
destruction.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
308
SEC. 710. AUTHORITY 
TO 
ALLOW 
DRAWBACK 
ON 
EX-
PORTED BEER WITHOUT SUBMISSION OF
RECORDS.
(a) IN GENERAL.—The first sentence of section 5055
(relating to drawback of tax on beer) is amended by strik-
ing ‘‘found to have been paid’’ and all that follows and
inserting ‘‘paid on such beer if there is such proof of ex-
portation as the Secretary may by regulations require.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
SEC. 711. TRANSFER TO BREWERY OF BEER IMPORTED IN
BULK WITHOUT PAYMENT OF TAX.
(a) IN GENERAL.—Part II of subchapter G of chap-
ter 51 is amended by adding at the end thereof the follow-
ing new section:
‘‘SEC. 5418. BEER IMPORTED IN BULK.
‘‘Beer imported or brought into the United States in
bulk containers may, under such regulations as the Sec-
retary may prescribe, be withdrawn from customs custody
and transferred in such bulk containers to the premises
of a brewery without payment of the internal revenue tax
imposed on such beer. The proprietor of a brewery to
which such beer is transferred shall become liable for the
tax on the beer withdrawn from customs custody under
309
this section upon release of the beer from customs custody,
and the importer, or the person bringing such beer into
the United States, shall thereupon be relieved of the liabil-
ity for such tax.’’
(b) CLERICAL AMENDMENT.—The table of sections
for such part II is amended by adding at the end thereof
the following new item:
‘‘Sec. 5418. Beer imported in bulk.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect at the beginning of the first
calendar quarter beginning more than 180 days after the
date of the enactment of this Act.
Subtitle B—Other Excise Tax
Provisions
SEC. 721. AUTHORITY TO GRANT EXEMPTIONS FROM REG-
ISTRATION REQUIREMENTS.
(a) IN GENERAL.—The first sentence of section 4222
(relating to registration) is amended to read as follows:
‘‘Except as provided in subsection (b), section 4221 shall
not apply with respect to the sale of any article by or to
any person who is required by the Secretary to be reg-
istered under this section and who is not so registered.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to sales after the 180th day
after the date of the enactment of this Act.
310
SEC. 722. REPEAL OF EXPIRED PROVISIONS.
(a) PIGGY-BACK TRAILERS.—Section 4051 is amend-
ed by striking subsection (d) and by redesignating sub-
section (e) as subsection (d).
(b) DEEP SEABED MINING.—
(1) Subchapter F of chapter 36 (relating to tax
on removal of hard mineral resources from deep sea-
bed) is hereby repealed.
(2) The table of subchapters for chapter 36 is
amended by striking the item relating to subchapter
F.
TITLE VIII—ADMINISTRATIVE
PROVISIONS
Subtitle A—General Provisions
SEC. 801. USE OF REPRODUCTIONS OF RETURNS STORED
IN DIGITAL IMAGE FORMAT.
(a) IN GENERAL.—Paragraph (2) of section 6103(p)
(relating to procedure and recordkeeping) is amended by
adding at the end thereof the following new subparagraph:
‘‘(D) REPRODUCTION
FROM
DIGITAL
IM-
AGES.—For purposes of this paragraph, the
term ‘reproduction’ includes a reproduction
from digital images.’’
(b) STUDY.—The Comptroller General of the United
States shall conduct a study of available digital image
technology for the purpose of determining the extent to
311
which reproductions of documents stored using that tech-
nology accurately reflect the data on the original document
and the appropriate period for retaining the original docu-
ment. Not later than 1 year after the date of the enact-
ment of this Act, a report on the results of such study
shall be submitted to the Committee on Ways and Means
of the House of Representatives and the Committee on
Finance of the Senate.
SEC. 802. REPEAL OF AUTHORITY TO DISCLOSE WHETHER
PROSPECTIVE JUROR HAS BEEN AUDITED.
(a) IN GENERAL.—Subsection (h) of section 6103
(relating to disclosure to certain Federal officers and em-
ployees for purposes of tax administration, etc.) is amend-
ed by striking paragraph (5) and by redesignating para-
graph (6) as paragraph (5).
(b) CONFORMING AMENDMENT.—Paragraph (4) of
section 6103(p) is amended by striking ‘‘(h)(6)’’ each
place it appears and inserting ‘‘(h)(5)’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to judicial proceedings pending on,
or commenced after, the date of the enactment of this Act.
312
SEC. 803. REPEAL OF SPECIAL AUDIT PROVISIONS FOR
SUBCHAPTER S ITEMS.
(a) GENERAL RULE.—Subchapter D of chapter 63
(relating to tax treatment of subchapter S items) is hereby
repealed.
(b) CONSISTENT TREATMENT REQUIRED.—Section
6037 (relating to return of S corporation) is amended by
adding at the end thereof the following new subsection:
‘‘(c) SHAREHOLDER’S RETURN MUST BE CONSIST-
ENT WITH CORPORATE RETURN OR SECRETARY NOTI-
FIED OF INCONSISTENCY.—
‘‘(1) IN GENERAL.—A shareholder of an S cor-
poration shall, on such shareholder’s return, treat a
subchapter S item in a manner which is consistent
with the treatment of such item on the corporate
return.
‘‘(2) NOTIFICATION OF INCONSISTENT TREAT-
MENT.—
‘‘(A) IN
GENERAL.—In the case of any
subchapter S item, if—
‘‘(i)(I) the corporation has filed a re-
turn but the shareholder’s treatment on
his return is (or may be) inconsistent with
the treatment of the item on the corporate
return, or
313
‘‘(II) the corporation has not filed a
return, and
‘‘(ii) the shareholder files with the
Secretary a statement identifying the in-
consistency,
paragraph (1) shall not apply to such item.
‘‘(B) SHAREHOLDER
RECEIVING
INCOR-
RECT
INFORMATION.—A shareholder shall be
treated as having complied with clause (ii) of
subparagraph (A) with respect to a subchapter
S item if the shareholder—
‘‘(i) demonstrates to the satisfaction
of the Secretary that the treatment of the
subchapter S item on the shareholder’s re-
turn is consistent with the treatment of the
item on the schedule furnished to the
shareholder by the corporation, and
‘‘(ii) elects to have this paragraph
apply with respect to that item.
‘‘(3) EFFECT OF FAILURE TO NOTIFY.—In any
case—
‘‘(A) described in subparagraph (A)(i)(I)
of paragraph (2), and
314
‘‘(B) in which the shareholder does not
comply with subparagraph (A)(ii) of paragraph
(2),
any adjustment required to make the treatment of
the items by such shareholder consistent with the
treatment of the items on the corporate return shall
be treated as arising out of mathematical or clerical
errors and assessed according to section 6213(b)(1).
Paragraph (2) of section 6213(b) shall not apply to
any assessment referred to in the preceding sen-
tence.
‘‘(4) SUBCHAPTER S ITEM.—For purposes of
this subsection, the term ‘subchapter S item’ means
any item of an S corporation to the extent that reg-
ulations prescribed by the Secretary provide that, for
purposes of this subtitle, such item is more appro-
priately determined at the corporation level than at
the shareholder level.
‘‘(5) ADDITION TO TAX FOR FAILURE TO COM-
PLY WITH SECTION.—
‘‘For addition to tax in the case of a shareholder’s
negligence in connection with, or disregard of, the
requirements of this section, see part II of sub-
chapter A of chapter 68.’’
(c) CONFORMING AMENDMENTS.—
(1) Section 1366 is amended by striking sub-
section (g).
315
(2) Subsection (b) of section 6233 is amended
to read as follows:
‘‘(b) SIMILAR RULES IN CERTAIN CASES.—If a part-
nership return is filed for any taxable year but it is deter-
mined that there is no entity for such taxable year, to the
extent provided in regulations, rules similar to the rules
of subsection (a) shall apply.’’
(3) The table of subchapters for chapter 63 is
amended by striking the item relating to subchapter
D.
(d) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years ending after the
date of the enactment of this Act.
SEC. 804. CLARIFICATION OF STATUTE OF LIMITATIONS.
(a) IN GENERAL.—Subsection (a) of section 6501
(relating to limitations on assessment and collection) is
amended by adding at the end thereof the following new
sentence: ‘‘For purposes of this chapter, the term ‘return’
means the return required to be filed by the taxpayer (and
does not include a return of any person from whom the
taxpayer has received an item of income, gain, loss, deduc-
tion, or credit).’’
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to taxable years beginning after
the date of the enactment of this Act.
316
SEC. 805. CERTAIN NOTICES DISREGARDED UNDER PROVI-
SION INCREASING INTEREST RATE ON LARGE
CORPORATE UNDERPAYMENTS.
(a) GENERAL RULE.—Subparagraph (B) of section
6621(c)(2) (defining applicable date) is amended by add-
ing at the end thereof the following new clause:
‘‘(iii) EXCEPTION
FOR
LETTERS
OR
NOTICES
INVOLVING
SMALL
AMOUNTS.—
For purposes of this paragraph, any letter
or notice shall be disregarded if the
amount of the deficiency or proposed defi-
ciency (or the assessment or proposed as-
sessment) set forth in such letter or notice
is not greater than $100,000 (determined
by not taking into account any interest,
penalties, or additions to tax).’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply for purposes of determining in-
terest for periods after December 31, 1993.
Subtitle B—Tax Court Procedures
SEC. 811. OVERPAYMENT 
DETERMINATIONS 
OF 
TAX
COURT.
(a) APPEAL OF ORDER.—Paragraph (2) of section
6512(b) (relating to jurisdiction to enforce) is amended
by adding at the end the following new sentence: ‘‘An
order of the Tax Court disposing of a motion under this
317
paragraph shall be reviewable in the same manner as a
decision of the Tax Court, but only with respect to the
matters determined in such order.’’
(b) DENIAL OF JURISDICTION REGARDING CERTAIN
CREDITS AND REDUCTIONS.—Subsection (b) of section
6512 (relating to overpayment determined by Tax Court)
is amended by adding at the end the following new
paragraph:
‘‘(4) DENIAL
OF
JURISDICTION
REGARDING
CERTAIN
CREDITS
AND
REDUCTIONS.—The Tax
Court shall have no jurisdiction under this sub-
section to restrain or review any credit or reduction
made by the Secretary under section 6402.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect on the date of the enactment
of this Act.
SEC. 812. AWARDING OF ADMINISTRATIVE COSTS.
(a) RIGHT TO APPEAL TAX COURT DECISION.—Sub-
section (f) of section 7430 (relating to right of appeal)
is amended by adding at the end the following new
paragraph:
‘‘(3) APPEAL
OF
TAX
COURT
DECISION.—An
order of the Tax Court disposing of a petition under
paragraph (2) shall be reviewable in the same man-
318
ner as a decision of the Tax Court, but only with re-
spect to the matters determined in such order.’’
(b) PERIOD FOR APPLYING TO IRS FOR COSTS.—
Subsection (b) of section 7430 (relating to limitations) is
amended by adding at the end the following new
paragraph:
‘‘(5) PERIOD FOR APPLYING TO IRS FOR AD-
MINISTRATIVE
COSTS.—An award may be made
under subsection (a) by the Internal Revenue Serv-
ice for reasonable administrative costs only if the
prevailing party files an application with the Inter-
nal Revenue Service for such costs before the 91st
day after the date on which the final decision of the
Internal Revenue Service as to the determination of
the tax, interest, or penalty is mailed to such party.’’
(c) PERIOD FOR PETITIONING OF TAX COURT FOR
REVIEW OF DENIAL OF COSTS.—Paragraph (2) of section
7430(f) (relating to right of appeal) is amended—
(1) by striking ‘‘appeal to’’ and inserting ‘‘the
filing of a petition for review with’’, and
(2) by adding at the end the following new sen-
tence: ‘‘If the Secretary sends by certified or reg-
istered mail a notice of such decision to the peti-
tioner, no proceeding in the Tax Court may be initi-
ated under this paragraph unless such petition is
319
filed before the 91st day after the date of such
mailing.’’
(d) EFFECTIVE DATE.—The amendments made by
this section shall apply to civil actions or proceedings com-
menced after the date of the enactment of this Act.
SEC. 813. REDETERMINATION OF INTEREST PURSUANT TO
MOTION.
(a) IN GENERAL.—Paragraph (3) of section 7481(c)
(relating to jurisdiction over interest determinations) is
amended by striking ‘‘petition’’ and inserting ‘‘motion’’.
(b) EFFECTIVE DATE.—The amendment made by
this section shall take effect on the date of the enactment
of this Act.
SEC. 814. APPLICATION OF NET WORTH REQUIREMENT
FOR AWARDS OF LITIGATION COSTS.
(a) IN GENERAL.—Paragraph (4) of section 7430(c)
(defining prevailing party) is amended by adding at the
end thereof the following new subparagraph:
‘‘(C) SPECIAL RULES FOR APPLYING NET
WORTH
REQUIREMENT.—In applying the re-
quirements of section 2412(d)(2)(B) of title 28,
United States Code, for purposes of subpara-
graph (A)(iii) of this paragraph—
‘‘(i) the net worth limitation in clause
(i) of such section shall apply to—
320
‘‘(I) an estate but shall be deter-
mined as of the date of the decedent’s
death, and
‘‘(II) a trust but shall be deter-
mined as of the last day of the taxable
year involved in the proceeding, and
‘‘(ii) individuals filing a joint return
shall be treated as 1 individual for pur-
poses of clause (i) of such section, except
in the case of a spouse relieved of liability
under section 6013(e).’’
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to proceedings commenced after
the date of the enactment of this Act.
Subtitle C—Authority for Certain
Cooperative Agreements
SEC. 821. COOPERATIVE AGREEMENTS WITH STATE TAX
AUTHORITIES.
(a) GENERAL RULE.—Chapter 77 (relating to mis-
cellaneous provisions) is amended by adding at the end
thereof the following new section:
‘‘SEC. 7524. COOPERATIVE AGREEMENTS WITH STATE TAX
AUTHORITIES.
‘‘(a) AUTHORIZATION OF AGREEMENTS.—The Sec-
retary is hereby authorized to enter into cooperative agree-
321
ments with State tax authorities for purposes of enhancing
joint tax administration. Such agreements may provide
for—
‘‘(1) joint filing of Federal and State income
tax returns,
‘‘(2) single processing of such returns,
‘‘(3) joint collection of taxes (other than Fed-
eral income taxes), and
‘‘(4) such other provisions as may enhance joint
tax administration.
‘‘(b) SERVICES
ON REIMBURSABLE BASIS.—Any
agreement under subsection (a) may require reimburse-
ment for services provided by either party to the
agreement.
‘‘(c) AVAILABILITY OF FUNDS.—Any funds appro-
priated for purposes of the administration of this title
shall be available for purposes of carrying out the Sec-
retary’s responsibility under an agreement entered into
under subsection (a). Any reimbursement received pursu-
ant to such an agreement shall be credited to the amount
so appropriated.
‘‘(d) STATE TAX AUTHORITY.—For purposes of this
section, the term ‘State tax authority’ means agency,
body, or commission referred to in section 6103(d)(1).’’
322
(b) CLERICAL AMENDMENT.—The table of sections
for chapter 77 is amended by adding at the end thereof
the following new item:
‘‘Sec. 7524. Cooperative agreements with State tax authorities.’’
Subtitle D—Administrative Prac-
tice and Procedural Simplifica-
tion
SEC. 831. NOTIFICATION OF REASONS FOR TERMINATION
OR DENIAL OF INSTALLMENT AGREEMENTS.
(a) TERMINATIONS.—Subsection (b) of section 6159
(relating to extent to which agreements remain in effect)
is amended by adding at the end thereof the following new
paragraph:
‘‘(5) NOTICE REQUIREMENTS.—The Secretary
may not take any action under paragraph (2), (3),
or (4) unless—
‘‘(A) a notice of such action is provided to
the taxpayer not later than the day 30 days be-
fore the date of such action, and
‘‘(B) such notice includes an explanation
why the Secretary intends to take such action.
The preceding sentence shall not apply in any case
in which the Secretary believes that collection of any
tax to which an agreement under this section relates
is in jeopardy.’’
323
(b) DENIALS.—Section 6159 (relating to agreements
for payment of tax liability in installments) is amended
by adding at the end thereof the following new subsection:
‘‘(c) NOTICE REQUIREMENTS FOR DENIALS.—The
Secretary may not deny any request for an installment
agreement under this section unless—
‘‘(1) a notice of the proposed denial is provided
to the taxpayer not later than the day 30 days be-
fore the date of such denial, and
‘‘(2) such notice includes an explanation why
the Secretary intends to deny such request.
The preceding sentence shall not apply in any case in
which the Secretary believes that collection of any tax to
which a request for an agreement under this section re-
lates is in jeopardy.’’
(c) CONFORMING AMENDMENT.—Paragraph (3) of
section 6159(b) is amended to read as follows:
‘‘(3) SUBSEQUENT CHANGE IN FINANCIAL CON-
DITIONS.—If the Secretary makes a determination
that the financial condition of a taxpayer with whom
the Secretary has entered into an agreement under
subsection (a) has significantly changed, the Sec-
retary may alter, modify, or terminate such agree-
ment.’’
324
(d) EFFECTIVE DATE.—The amendments made by
this section shall take effect on the date 6 months after
the date of the enactment of this Act.
SEC. 832. JOINT RETURN MAY BE MADE AFTER SEPARATE
RETURNS WITHOUT FULL PAYMENT OF TAX.
(a) GENERAL RULE.—Paragraph (2) of section
6013(b) (relating to limitations on filing of joint return
after filing separate returns) is amended by striking sub-
paragraph (A) and redesignating the following subpara-
graphs accordingly.
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to taxable years beginning after
the date of the enactment of this Act.
SEC. 833. OFFERS-IN-COMPROMISE.
(a) GENERAL RULE.—Subsection (a) of section 7122
(relating to compromises) is amended by adding at the end
thereof the following new sentence: ‘‘The Secretary may
make such a compromise in any case where the Secretary
determines that such compromise would be in the best in-
terests of the United States.’’.
(b) REVIEW REQUIREMENTS.—Subsection (b) of sec-
tion 7122 (relating to records) is amended by striking
‘‘$500.’’ and inserting ‘‘$50,000. However, such com-
promise shall be subject to continuing quality review by
the Secretary.’’.
325
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect on the date of the enactment
of this Act.
SEC. 834. PRELIMINARY NOTICE REQUIREMENT.
(a) IN GENERAL.—Section 6672 (relating to failure
to collect and pay over tax, or attempt to evade or defeat
tax) is amended by redesignating subsection (b) as sub-
section (c) and by inserting after subsection (a) the follow-
ing new subsection:
‘‘(b) PRELIMINARY NOTICE REQUIREMENT.—
‘‘(1) IN
GENERAL.—No penalty shall be im-
posed under subsection (a) unless the Secretary noti-
fies the taxpayer in writing by mail to an address as
determined under section 6212(b) that the taxpayer
shall be subject to an assessment of such penalty.
‘‘(2) TIMING OF NOTICE.—The mailing of the
notice described in paragraph (1) shall precede any
notice and demand of any penalty under subsection
(a) by at least 60 days.
‘‘(3) STATUTE
OF
LIMITATIONS.—If a notice
described in paragraph (1) with respect to any pen-
alty is mailed before the expiration of the period
provided by section 6501 for the assessment of such
penalty (determined without regard to this para-
graph), the period provided by such section for the
326
assessment of such penalty shall not expire before
the date 90 days after the date on which such notice
was mailed.
‘‘(4) EXCEPTION
FOR
JEOPARDY.—This sub-
section shall not apply if the Secretary finds that the
collection of the penalty is in jeopardy.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to assessments made after June
30, 1995.
SEC. 835. PENALTIES UNDER SECTION 6672.
(a) PUBLIC INFORMATION REQUIREMENTS.—The
Secretary of the Treasury or the Secretary’s delegate
(hereafter in this section referred to as the ‘‘Secretary’’)
shall take such actions as may be appropriate to ensure
that employees are aware of their responsibilities under
the Federal tax depository system, the circumstances
under which employees may be liable for the penalty im-
posed by section 6672 of the Internal Revenue Code of
1986, and the responsibility to promptly report to the In-
ternal Revenue Service any failure referred to in sub-
section (a) of such section 6672. Such actions shall in-
clude—
(1) printing of a warning on deposit coupon
booklets and the appropriate tax returns that certain
327
employees may be liable for the penalty imposed by
such section 6672, and
(2) the development of a special information
packet.
(b) BOARD MEMBERS OF TAX-EXEMPT ORGANIZA-
TIONS.—
(1) VOLUNTARY BOARD MEMBERS.—
(A) IN GENERAL.—The penalty under sec-
tion 6672 of the Internal Revenue Code of 1986
shall not be imposed on unpaid, volunteer mem-
bers of any board of trustees or directors of an
organization referred to in section 501 of such
Code to the extent such members are solely
serving in an honorary capacity, do not partici-
pate in the day-to-day or financial operations of
the organization, and do not have actual knowl-
edge of the failure on which such penalty is
imposed.
(B) APPLICATION
OF
PARAGRAPH.—This
paragraph shall not apply if it results in no per-
son being held liable for the penalty described
in section 6672(a) of the Internal Revenue
Code of 1986.
(2) DEVELOPMENT
OF
EXPLANATORY
MATE-
RIALS.—The Secretary shall develop materials ex-
328
plaining the circumstances under which board mem-
bers of tax-exempt organizations (including vol-
untary and honorary members) may be subject to
penalty under section 6672 of such Code. Such ma-
terials shall be made available to tax-exempt organi-
zations.
(3) IRS INSTRUCTIONS.—The Secretary shall
clarify the instructions to Internal Revenue Service
employees on the application of the penalty under
section 6672 of such Code with regard to voluntary
members of boards of trustees or directors of tax-ex-
empt organizations.
(c) PROMPT NOTIFICATION.—To the maximum ex-
tent practicable, the Secretary shall notify all persons who
have failed to make timely and complete deposit of any
taxes described in section 6672 of the Internal Revenue
Code of 1986 of such failure within 30 days after the re-
turn was filed reflecting such failure or after the date on
which the Secretary is first aware of such failure. If the
person failing to make the deposit is not an individual,
the Secretary shall notify the entity subject to such deposit
requirement and that entity shall notify, within 15 days
of the notification by the Secretary, all officers, general
partners, trustees, or other managers of the failure.
329
SEC. 836. REQUIRED CONTENT OF CERTAIN NOTICES.
(a) GENERAL RULE.—Subsection (a) of section 7522
(relating to content of tax due, deficiency, and other no-
tices) is amended by striking ‘‘shall describe the basis for,
and identify’’ and inserting ‘‘shall set forth the adjust-
ments which are the basis for, and shall identify’’.
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to notices sent after the date
6 months after the date of the enactment of this Act.
SEC. 837. REQUIRED NOTICE OF CERTAIN PAYMENTS.
If any payment is received by the Secretary of the
Treasury or the Secretary’s delegate (hereafter in the sec-
tion referred to as the ‘‘Secretary’’) from any taxpayer
and the Secretary cannot associate such payment with any
outstanding tax liability of such taxpayer, the Secretary
shall make reasonable efforts to notify the taxpayer of
such inability within 60 days after the receipt of such
payment.
SEC. 838. IMPROVED PROCEDURES FOR NOTIFYING SERV-
ICE OF CHANGE OF ADDRESS OR NAME.
The Secretary of the Treasury shall provide improved
procedures for taxpayers to notify the Secretary of
changes in names and addresses. Not later than December
31, 1994, the Secretary shall institute procedures for
timely updating all Internal Revenue Service records with
330
change-of-address information provided to the Secretary
by taxpayers.
SEC. 839. RIGHTS AND RESPONSIBILITIES OF DIVORCED
INDIVIDUALS.
The Secretary of the Treasury shall include in the
Internal Revenue Service publication entitled ‘‘Your
Rights As A Taxpayer’’ a section on the rights and respon-
sibilities of divorced individuals.
TITLE IX—FINANCING
PROVISIONS
SEC. 901. CERTAIN AMOUNTS DERIVED FROM FOREIGN
CORPORATIONS TREATED AS UNRELATED
BUSINESS TAXABLE INCOME.
(a) GENERAL RULE.—Subsection (b) of section 512
(relating to modifications) is amended by adding at the
end thereof the following new paragraph:
‘‘(17) TREATMENT OF CERTAIN AMOUNTS DE-
RIVED FROM FOREIGN CORPORATIONS.—
‘‘(A) IN GENERAL.—Notwithstanding para-
graph (1), any disqualified amount derived by
an organization from a foreign corporation in
which such organization is a 10-percent share-
holder shall be included as an item of gross in-
come derived from an unrelated trade or busi-
ness. There shall be allowed all deductions di-
331
rectly connected with amounts included in gross
income under the preceding sentence.
‘‘(B) DISQUALIFIED
AMOUNT.—For pur-
poses of subparagraph (A), the term ‘disquali-
fied amount’ means any of the following:
‘‘(i) SUBPART
F
INCLUSION.—Any
amount included in gross income under
section 951(a)(1)(A) to the extent the
amount so included is attributable to in-
come which, if derived directly by the orga-
nization, would be treated as gross income
from an unrelated trade or business.
‘‘(ii) DIVIDENDS.—Any dividend paid
out of the earnings and profits of any for-
eign corporation in proportion to the ratio
of—
‘‘(I) the portion of the earnings
and profits attributable to income
which, if derived directly by the orga-
nization, would be treated as gross in-
come from an unrelated trade or busi-
ness, to
‘‘(II) the total amount of earn-
ings and profits.
332
For purposes of the preceding sentence,
earnings and profits accumulated in tax-
able years beginning before January 1,
1994, shall not be taken into account.
‘‘(C) 10-PERCENT
SHAREHOLDER.—The
term ‘10-percent shareholder’ means any orga-
nization who owns (within the meaning of sec-
tion 958(a)), or is considered as owning by ap-
plying the rules of section 958(b), 10 percent or
more of the combined voting power of all class
of stock entitled to vote of the foreign corpora-
tion.
‘‘(D) TREATMENT OF CERTAIN AMOUNTS
AS
DIVIDENDS.—The 
rules 
of 
section
904(d)(3)(G) shall apply for purposes of this
paragraph.
‘‘(E) REGULATIONS.—The Secretary shall
prescribe such regulations as may be necessary
or appropriate to carry out the purposes of this
paragraph, including regulations for the appli-
cation of this paragraph in the case of income
paid through 1 or more entities or between 2 or
more chains of entities.’’
(b) EFFECTIVE DATE.—The amendments made by
this section shall apply to—
333
(1) dividends paid out of earnings and profits
of foreign corporations for taxable years beginning
after December 31, 1993, and
(2) amounts included in gross income under
section 951(a)(1)(A) of the Internal Revenue Code
of 1986 in respect of any such taxable year.
SEC. 902. SPECIAL RULES FOR RENTAL USE OF DWELLING
FOR LESS THAN 15 DAYS PER YEAR.
(a) IN GENERAL.—Section 280A is amended by
striking subsection (g) and inserting:
‘‘(g) SPECIAL RULE FOR CERTAIN RENTAL USE.—
Notwithstanding any other provision of this section or sec-
tion 183, if the principal residence of the taxpayer is actu-
ally rented for less than 15 days during the taxable year
for the purpose of providing accommodations to visitors
to an event for which commercial rental accommodations
in the community holding the event are not sufficient to
reasonably provide more than one-half of the accommoda-
tions necessary (and the rental income received by the tax-
payer for any visitor is not greater than a reasonable rent-
al rate charged per individual guest by commercial rental
accommodations), then—
‘‘(1) no deduction otherwise allowable under
this chapter because of the rental use of such dwell-
ing unit shall be allowed, and
334
‘‘(2) the income derived from such use for the
taxable year shall not be included in the gross in-
come of such taxpayer under section 61.
‘‘(h) REGULATIONS.—The Secretary shall prescribe
such regulations as may be appropriate to carry out the
purposes of this section, including regulations providing
such de minimis rules as the Secretary may deem appro-
priate.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to taxable years beginning after
December 31, 1993.
SEC. 903. LOSS CARRYOVERS AND CARRYBACKS NOT EX-
CLUDED IN APPLYING TAXABLE INCOME LIM-
ITATION ON CERTAIN RESERVE DEDUCTIONS.
(a) GENERAL RULE.—Subparagraph (D) of section
593(b)(2) (relating to computation of taxable income) is
amended by adding at the end thereof the following new
sentence:
‘‘Except as providing in the preceding sentence,
for purposes of this paragraph, taxable income
shall be computed as provided in this chapter,
including the application of any carryover or
carryback.’’
335
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to losses incurred in taxable
years ending after December 31, 1993.
SEC. 904. EXTENSION OF WITHHOLDING TO CERTAIN GAM-
BLING WINNINGS.
(a) REPEAL
OF
EXEMPTION
FOR
BINGO
AND
KENO.—Paragraph (5) of section 3402(q) is amended to
read as follows:
‘‘(5) EXEMPTION FOR SLOT MACHINES.—The
tax imposed by paragraph (1) shall not apply to
winnings from a slot machine.’’
(b) THRESHOLD AMOUNT.—Paragraph (3) of section
3402(q) is amended—
(1) by striking ‘‘(B) and (C)’’ in subparagraph
(A) and inserting ‘‘(B), (C), and (D)’’, and
(2) by adding at the end thereof the following
new subparagraph:
‘‘(D) BINGO
AND
KENO.—Proceeds of
more than $10,000 from a wager placed in a
bingo or keno game.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect on January 1, 1994.
336
TITLE X—TECHNICAL
CORRECTIONS
Subtitle A—Revenue Provisions
SEC. 1001. AMENDMENTS RELATED TO REVENUE REC-
ONCILIATION ACT OF 1990.
(a) AMENDMENTS RELATED TO SUBTITLE A.—
(1) Subparagraph (B) of section 59(j)(3) is
amended by striking ‘‘section 1(i)(3)(B)’’ and insert-
ing ‘‘section 1(g)(3)(B)’’.
(2) Clause (i) of section 151(d)(3)(C) is amend-
ed by striking ‘‘joint of a return’’ and inserting
‘‘joint return’’.
(3) Subsection (b) of section 1 (as in effect on
the day before the date of the enactment of the Rev-
enue Reconciliation Act of 1993) is amended by
striking ‘‘$26,500’’ in the table contained therein
and inserting ‘‘$26,050’’.
(b) AMENDMENTS RELATED TO SUBTITLE B.—
(1) Paragraph (1) of section 11212(e) of the
Revenue Reconciliation Act of 1990 is amended by
striking ‘‘Paragraph (1) of section 6724(d)’’ and in-
serting ‘‘Subparagraph (B) of section 6724(d)(1)’’.
(2)(A) Subparagraph (B) of section 4093(c)(2),
as in effect before the amendments made by the
Revenue Reconciliation Act of 1993, is amended by
337
inserting before the period ‘‘unless such fuel is sold
for exclusive use by a State or any political subdivi-
sion thereof’’.
(B) Paragraph (4) of section 6427(l), as in ef-
fect before the amendments made by the Revenue
Reconciliation Act of 1993, is amended by inserting
before the period ‘‘unless such fuel was used by a
State or any political subdivision thereof’’.
(3) Paragraph (1) of section 6416(b) is amend-
ed by striking ‘‘chapter 32 or by section 4051’’ and
inserting ‘‘chapter 31 or 32’’.
(4) Section 7012 is amended—
(A) by striking ‘‘production or importation
of gasoline’’ in paragraph (3) and inserting
‘‘taxes on gasoline and diesel fuel’’, and
(B) by striking paragraph (4) and redesig-
nating paragraphs (5) and (6) as paragraphs
(4) and (5), respectively.
(5) Subsection (c) of section 5041 is amended
by striking paragraph (6) and by inserting the fol-
lowing new paragraphs:
‘‘(6) CREDIT FOR TRANSFEREE IN BOND.—If—
‘‘(A) wine produced by any person would
be eligible for any credit under paragraph (1)
338
if removed by such person during the calendar
year,
‘‘(B) wine produced by such person is re-
moved during such calendar year by any other
person (hereafter in this paragraph referred to
as the ‘transferee’) to whom such wine was
transferred in bond and who is liable for the tax
imposed by this section with respect to such
wine, and
‘‘(C) such producer holds title to such wine
at the time of its removal and provides to the
transferee such information as is necessary to
properly determine the transferee’s credit under
this paragraph,
then, the transferee (and not the producer) shall be
allowed the credit under paragraph (1) which would
be allowed to the producer if the wine removed by
the transferee had been removed by the producer on
that date.
‘‘(7) REGULATIONS.—The Secretary may pre-
scribe such regulations as may be necessary to carry
out the purposes of this subsection, including regula-
tions—
‘‘(A) to prevent the credit provided in this
subsection from benefiting any person who pro-
339
duces more than 250,000 wine gallons during a
calendar year, and
‘‘(B) to assure proper reduction of such
credit for persons producing more than 150,000
wine gallons of wine during a calendar year.’’
(6) Paragraph (3) of section 5061(b) is amend-
ed to read as follows:
‘‘(3) section 5041(f),’’.
(7) Section 5354 is amended by inserting ‘‘(tak-
ing into account the appropriate amount of credit
with respect to such wine under section 5041(c))’’
after ‘‘any one time’’.
(8) Effective on the date of the enactment of
this Act, paragraph (7) of section 11202(i) of the
Revenue Reconciliation Act of 1990 is amended by
adding at the end thereof the following: ‘‘The Sec-
retary may treat any person who bore the ultimate
burden of the tax imposed by this subsection as the
person to whom a credit or refund under such provi-
sions may be allowed or made.’’.
(c) AMENDMENTS RELATED TO SUBTITLE C.—
(1) Paragraph (4) of section 56(g) is amended
by redesignating subparagraphs (I) and (J) as sub-
paragraphs (H) and (I), respectively.
340
(2) Subparagraph (B) of section 6724(d)(1) is
amended—
(A) by striking ‘‘or’’ at the end of clause
(xii), and
(B) by striking the period at the end of
clause (xiii) and inserting ‘‘, or’’.
(3) Subsection (g) of section 6302 is amended
by inserting ‘‘, 22,’’ after ‘‘chapters 21’’.
(4) The earnings and profits of any insurance
company to which section 11305(c)(3) of the Reve-
nue Reconciliation Act of 1990 applies shall be de-
termined without regard to any deduction allowed
under such section; except that, for purposes of ap-
plying sections 56 and 902, and subpart F of part
III of subchapter N of chapter 1 of the Internal
Revenue Code of 1986, such deduction shall be
taken into account.
(5) Subparagraph (D) of section 6038A(e)(4) is
amended—
(A) by striking ‘‘any transaction to which
the summons relates’’ and inserting ‘‘any af-
fected taxable year’’, and
(B) by adding at the end thereof the fol-
lowing new sentence: ‘‘For purposes of this sub-
paragraph, the term ‘affected taxable year’
341
means any taxable year if the determination of
the amount of tax imposed for such taxable
year is affected by the treatment of the trans-
action to which the summons relates.’’.
(6) Subparagraph (A) of section 6621(c)(2) is
amended by adding at the end thereof the following
new sentence: ‘‘The preceding sentence shall be ap-
plied without regard to any such letter or notice
which is withdrawn by the Secretary.’’.
(7) Clause (i) of section 6621(c)(2)(B) is
amended by striking ‘‘this subtitle’’ and inserting
‘‘this title’’.
(d) AMENDMENTS RELATED TO SUBTITLE D.—
(1) Notwithstanding section 11402(c) of the
Revenue Reconciliation Act of 1990, the amendment
made by section 11402(b)(1) of such Act shall apply
to taxable years ending after December 31, 1989.
(2) Clause (ii) of section 143(m)(4)(C) is
amended—
(A) by striking ‘‘any month of the 10-year
period’’ and inserting ‘‘any year of the 4-year
period’’,
(B) by striking ‘‘succeeding months’’ and
inserting ‘‘succeeding years’’, and
342
(C) by striking ‘‘over the remainder of
such period (or, if lesser, 5 years)’’ and insert-
ing ‘‘to zero over the succeeding 5 years’’.
(e) AMENDMENTS RELATED TO SUBTITLE E.—
(1)(A) Clause (ii) of section 56(d)(1)(B) is
amended to read as follows:
‘‘(ii) appropriate adjustments in the
application of section 172(b)(2) shall be
made to take into account the limitation of
subparagraph (A).’’
(B) For purposes of applying sections 56(g)(1)
and 56(g)(3) of the Internal Revenue Code of 1986
with respect to taxable years beginning in 1991 and
1992, the reference in such sections to the alter-
native tax net operating loss deduction shall be
treated as including a reference to the deduction
under section 56(h) of such Code as in effect before
the amendments made by section 1915 of the En-
ergy Policy Act of 1992.
(2) Clause (i) of section 613A(c)(3)(A) is
amended by striking ‘‘the table contained in’’.
(3) Section 6501 is amended—
(A) by striking subsection (m) (relating to
deficiency attributable to election under section
343
44B) and by redesignating subsections (n) and
(o) as subsections (m) and (n), respectively, and
(B) by striking ‘‘section 40(f) or 51(j)’’ in
subsection (m) (as redesignated by subpara-
graph (A)) and inserting ‘‘section 40(f), 43, or
51(j)’’.
(4) Subparagraph (C) of section 38(c)(2) (as in
effect on the day before the date of the enactment
of the Revenue Reconciliation Act of 1990) is
amended by inserting before the period at the end
of the first sentence the following: ‘‘and without re-
gard to the deduction under section 56(h)’’.
(5) 
The 
amendment 
made 
by 
section
1913(b)(2)(C)(i) of the Energy Policy Act of 1992
shall apply to taxable years beginning after Decem-
ber 31, 1990.
(f) AMENDMENTS RELATED TO SUBTITLE F.—
(1)(A) Section 2701(a)(3) is amended by add-
ing at the end thereof the following new subpara-
graph:
‘‘(C) VALUATION OF QUALIFIED PAYMENTS
WHERE NO LIQUIDATION, ETC. RIGHTS.—In the
case of an applicable retained interest which is
described in subparagraph (B)(i) but not sub-
paragraph (B)(ii), the value of the distribution
344
right shall be determined without regard to this
section.’’
(B) Section 2701(a)(3)(B) is amended by in-
serting ‘‘CERTAIN’’ before ‘‘QUALIFIED’’ in the head-
ing thereof.
(C) Sections 2701 (d)(1) and (d)(4) are each
amended by striking ‘‘subsection (a)(3)(B)’’ and in-
serting ‘‘subsection (a)(3) (B) or (C)’’.
(2) Clause (i) of section 2701(a)(4)(B) is
amended by inserting ‘‘(or, to the extent provided in
regulations, the rights as to either income or cap-
ital)’’ after ‘‘income and capital’’.
(3)(A) Section 2701(b)(2) is amended by add-
ing at the end thereof the following new subpara-
graph:
‘‘(C) APPLICABLE FAMILY MEMBER.—For
purposes of this subsection, the term ‘applicable
family member’ includes any lineal descendant
of any parent of the transferor or the transfer-
or’s spouse.’’
(B) Section 2701(e)(3) is amended—
(i) by striking subparagraph (B), and
(ii) by striking so much of paragraph (3)
as precedes ‘‘shall be treated as holding’’ and
inserting:
345
‘‘(3) ATTRIBUTION
OF
INDIRECT
HOLDINGS
AND TRANSFERS.—An individual’’.
(C) Section 2704(c)(3) is amended by striking
‘‘section 2701(e)(3)(A)’’ and inserting ‘‘section
2701(e)(3)’’.
(4) Clause (i) of section 2701(c)(1)(B) is
amended to read as follows:
‘‘(i) a right to distributions with re-
spect to any interest which is junior to the
rights of the transferred interest,’’.
(5)(A) Clause (i) of section 2701(c)(3)(C) is
amended to read as follows:
‘‘(i) IN
GENERAL.—Payments under
any interest held by a transferor which
(without regard to this subparagraph) are
qualified payments shall be treated as
qualified payments unless the transferor
elects not to treat such payments as quali-
fied payments. Payments described in the
preceding sentence which are held by an
applicable family member shall be treated
as qualified payments only if such member
elects to treat such payments as qualified
payments.’’
346
(B) 
The 
first 
sentence 
of 
section
2701(c)(3)(C)(ii) is amended to read as follows: ‘‘A
transferor or applicable family member holding any
distribution right which (without regard to this sub-
paragraph) is not a qualified payment may elect to
treat such right as a qualified payment, to be paid
in the amounts and at the times specified in such
election.’’.
(C) The time for making an election under the
second sentence of section 2701(c)(3)(C)(i) of the
Internal Revenue Code of 1986 (as amended by sub-
paragraph (A)) shall not expire before the due date
(including extensions) for filing the transferor’s re-
turn of the tax imposed by section 2501 of such
Code for the first calendar year ending after the
date of enactment.
(6) Section 2701(d)(3)(A)(iii) is amended by
striking ‘‘the period ending on the date of’’.
(7) Subclause (I) of section 2701(d)(3)(B)(ii) is
amended by inserting ‘‘or the exclusion under sec-
tion 2503(b),’’ after ‘‘section 2523,’’.
(8) Section 2701(e)(5) is amended—
(A) by striking ‘‘such contribution to cap-
ital or such redemption, recapitalization, or
347
other change’’ in subparagraph (A) and insert-
ing ‘‘such transaction’’, and
(B) by striking ‘‘the transfer’’ in subpara-
graph (B) and inserting ‘‘such transaction’’.
(9) Section 2701(d)(4) is amended by adding at
the end thereof the following new subparagraph:
‘‘(C) TRANSFER
TO
TRANSFERORS.—In
the case of a taxable event described in para-
graph (3)(A)(ii) involving a transfer of an ap-
plicable retained interest from an applicable
family member to a transferor, this subsection
shall continue to apply to the transferor during
any period the transferor holds such interest.’’
(10) Section 2701(e)(6) is amended by insert-
ing ‘‘or to reflect the application of subsection (d)’’
before the period at the end thereof.
(11)(A) Section 2702(a)(3)(A) is amended—
(i) by striking ‘‘to the extent’’ and insert-
ing ‘‘if’’ in clause (i),
(ii) by striking ‘‘or’’ at the end of clause
(i),
(iii) by striking the period at the end of
clause (ii) and inserting ‘‘, or’’, and
(iv) by adding at the end thereof the fol-
lowing new clause:
348
‘‘(iii) to the extent that regulations
provide that such transfer is not inconsist-
ent with the purposes of this section.’’
(B)(i) Section 2702(a)(3) is amended by strik-
ing ‘‘incomplete transfer’’ each place it appears and
inserting ‘‘incomplete gift’’.
(ii) The heading for section 2702(a)(3)(B) is
amended by striking ‘‘INCOMPLETE TRANSFER’’ and
inserting ‘‘INCOMPLETE GIFT’’.
(g) AMENDMENTS RELATED TO SUBTITLE G.—
(1)(A) Subsection (a) of section 1248 is amend-
ed—
(i) by striking ‘‘, or if a United States per-
son receives a distribution from a foreign cor-
poration which, under section 302 or 331, is
treated as an exchange of stock’’ in paragraph
(1), and
(ii) by adding at the end thereof the follow-
ing new sentence: ‘‘For purposes of this section,
a United States person shall be treated as hav-
ing sold or exchanged any stock if, under any
provision of this subtitle, such person is treated
as realizing gain from the sale or exchange of
such stock.’’.
349
(B) Paragraph (1) of section 1248(e) is amend-
ed by striking ‘‘, or receives a distribution from a
domestic corporation which, under section 302 or
331, is treated as an exchange of stock’’.
(C) Subparagraph (B) of section 1248(f)(1) is
amended by striking ‘‘or 361(c)(1)’’ and inserting
‘‘355(c)(1), or 361(c)(1)’’.
(D) Paragraph (1) of section 1248(i) is amend-
ed to read as follows:
‘‘(1) IN GENERAL.—If any shareholder of a 10-
percent corporate shareholder of a foreign corpora-
tion exchanges stock of the 10-percent corporate
shareholder for stock of the foreign corporation,
such 10-percent corporate shareholder shall recog-
nize gain in the same manner as if the stock of the
foreign corporation received in such exchange had
been—
‘‘(A) issued to the 10-percent corporate
shareholder, and
‘‘(B) then distributed by the 10-percent
corporate shareholder to such shareholder in re-
demption or liquidation (whichever is appro-
priate).
The amount of gain recognized by such 10-percent
corporate shareholder under the preceding sentence
350
shall not exceed the amount treated as a dividend
under this section.’’
(2) Section 897 is amended by striking sub-
section (f).
(3) Paragraph (13) of section 4975(d) is
amended by striking ‘‘section 408(b)’’ and inserting
‘‘section 408(b)(12)’’.
(4) Clause (iii) of section 56(g)(4)(D) is amend-
ed by inserting ‘‘, but only with respect to taxable
years beginning after December 31, 1989’’ before
the period at the end thereof.
(5)(A) Paragraph (11) of section 11701(a) of
the Revenue Reconciliation Act of 1990 (and the
amendment made by such paragraph) are hereby re-
pealed, and section 7108(r)(2) of the Revenue Rec-
onciliation Act of 1989 shall be applied as if such
paragraph (and amendment) had never been en-
acted.
(B) Subparagraph (A) shall not apply to any
building if the owner of such building establishes to
the satisfaction of the Secretary of the Treasury or
his delegate that such owner reasonably relied on the
amendment made by such paragraph (11).
(h) AMENDMENTS RELATED TO SUBTITLE H.—
351
(1)(A) Clause (vi) of section 168(e)(3)(B) is
amended by striking ‘‘or’’ at the end of subclause
(I), by striking the period at the end of subclause
(II) and inserting ‘‘, or’’, and by adding at the end
thereof the following new subclause:
‘‘(III) 
is 
described 
in 
section
48(l)(3)(A)(ix) (as in effect on the day be-
fore the date of the enactment of the Reve-
nue Reconciliation Act of 1990).’’
(B) Subparagraph (K) of section 168(g)(4) is
amended by striking ‘‘section 48(a)(3)(A)(iii)’’ and
inserting ‘‘section 48(l)(3)(A)(ix) (as in effect on the
day before the date of the enactment of the Revenue
Reconciliation Act of 1990)’’.
(2) Clause (ii) of section 172(b)(1)(E) is
amended by striking ‘‘subsection (m)’’ and inserting
‘‘subsection (h)’’.
(3) Sections 805(a)(4)(E), 832(b)(5)(C)(ii)(II),
and 832(b)(5)(D)(ii)(II) are each amended by strik-
ing ‘‘243(b)(5)’’ and inserting ‘‘243(b)(2)’’.
(4) Subparagraph (A) of section 243(b)(3) is
amended by inserting ‘‘of’’ after ‘‘In the case’’.
(5) The subsection heading for subsection (a) of
section 280F is amended by striking ‘‘INVESTMENT
TAX CREDIT AND’’.
352
(6) Clause (i) of section 1504(c)(2)(B) is
amended by inserting ‘‘section’’ before ‘‘243(b)(2)’’.
(7) Paragraph (3) of section 341(f) is amended
by striking ‘‘351, 361, 371(a), or 374(a)’’ and in-
serting ‘‘351, or 361’’.
(8) Paragraph (2) of section 243(b) is amended
to read as follows:
‘‘(2) AFFILIATED GROUP.—For purposes of this
subsection:
‘‘(A) IN
GENERAL.—The term ‘affiliated
group’ has the meaning given such term by sec-
tion 1504(b), except that for such purposes sec-
tions 1504(b)(2), 1504(b)(4), and 1504(c) shall
not apply.
‘‘(B) GROUP
MUST
BE
CONSISTENT
IN
FOREIGN TAX TREATMENT.—The requirements
of paragraph (1)(A) shall not be treated as
being met with respect to any dividend received
by a corporation if, for any taxable year which
includes the day on which such dividend is re-
ceived—
‘‘(i) 1 or more members of the affili-
ated group referred to in paragraph (1)(A)
choose to any extent to take the benefits of
section 901, and
354
(13) Subparagraph (B) of section 424(c)(3) is
amended by striking ‘‘a qualified stock option, an in-
centive stock option, an option granted under an em-
ployee stock purchase plan, or a restricted stock op-
tion’’ and inserting ‘‘an incentive stock option or an
option granted under an employee stock purchase
plan’’.
(14) Subparagraph (E) of section 1367(a)(2) is
amended by striking ‘‘section 613A(c)(13)(B)’’ and
inserting ‘‘section 613A(c)(11)(B)’’.
(15) Subparagraph (B) of section 460(e)(6) is
amended by striking ‘‘section 167(k)’’ and inserting
‘‘section 168(e)(2)(A)(ii)’’.
(16) Subparagraph (C) of section 172(h)(4) is
amended by striking ‘‘subsection (b)(1)(M)’’ and in-
serting ‘‘subsection (b)(1)(E)’’.
(17) Section 6503 is amended—
(A) by redesignating the subsection relat-
ing to extension in case of certain summonses
as subsection (j), and
(B) by redesignating the subsection relat-
ing to cross references as subsection (k).
(18) Paragraph (4) of section 1250(e) is hereby
repealed.
355
(19) Subsection (c) of section 2104 is amended
by striking ‘‘subparagraph (A), (C), or (D)’’ and in-
serting ‘‘subparagraph (A)’’.
(i) EFFECTIVE DATE.—Except as otherwise expressly
provided—
(1) the amendments made by this section shall
be treated as amendments to the Internal Revenue
Code of 1986 as amended by the Revenue Reconcili-
ation Act of 1993; and
(2) any amendment made by this section shall
apply to periods before the date of the enactment of
this section in the same manner as if it had been in-
cluded in the provision of the Revenue Reconciliation
Act of 1990 to which such amendment relates.
SEC. 1002. AMENDMENTS RELATED TO REVENUE REC-
ONCILIATION ACT OF 1993.
(a) AMENDMENT RELATED TO SECTION 13114.—
Paragraph (2) of section 1044(c) is amended to read as
follows:
‘‘(2) PURCHASE.—The taxpayer shall be consid-
ered to have purchased any property if, but for sub-
section (d), the unadjusted basis of such property
would be its cost within the meaning of section
1012.’’
(b) AMENDMENTS RELATED TO SECTION 13142.—
356
(1) Subparagraph (B) of section 13142(b)(6) of
the Revenue Reconciliation Act of 1993 is amended
to read as follows:
‘‘(B) FULL-TIME STUDENTS, WAIVER AU-
THORITY, AND PROHIBITED DISCRIMINATION.—
The amendments made by paragraphs (2), (3),
and (4) shall take effect on the date of the en-
actment of this Act.’’
(2) Subparagraph (C) of section 13142(b)(6) of
such Act is amended by striking ‘‘paragraph (2)’’
and inserting ‘‘paragraph (5)’’.
(c) AMENDMENT RELATED TO SECTION 13161.—
(1) IN
GENERAL.—Subsection (e) of section
4001 (relating to inflation adjustment) is amended
to read as follows:
‘‘(e) INFLATION ADJUSTMENT.—
‘‘(1) IN GENERAL.—In the case of any calendar
year after 1993, the $30,000 amount in subsection
(a) and section 4003(a) shall be increased by an
amount equal to—
‘‘(A) $30,000, multiplied by
‘‘(B) the cost-of-living adjustment under
section 1(f)(3) for such calendar year, deter-
mined by substituting ‘calendar year 1990’ for
357
‘calendar year 1992’ in subparagraph (B)
thereof.
‘‘(2) ROUNDING.—If any amount as adjusted
under paragraph (1) is not a multiple of $2,000,
such amount shall be rounded to the next lowest
multiple of $2,000.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall take effect on January 1,
1994.
(d) AMENDMENT RELATED TO SECTION 13201.—
Clause (ii) of section 135(b)(2)(B) is amended by insert-
ing before the period at the end thereof the following: ‘‘,
determined by substituting ‘calendar year 1989’ for ‘cal-
endar year 1992’ in subparagraph (B) thereof’’.
(e) AMENDMENTS RELATED TO SECTION 13203.—
Subsection (a) of section 59 is amended—
(1) by striking ‘‘the amount determined under
section 55(b)(1)(A)’’ in paragraph (1)(A) and
(2)(A)(i) and inserting ‘‘the pre-credit tentative min-
imum tax’’,
(2) 
by 
striking 
‘‘specified 
in 
section
55(b)(1)(A)’’ in paragraph (1)(C) and inserting
‘‘specified in subparagraph (A)(i) or (B)(i) of section
55(b)(1) (whichever applies)’’,
358
(3) by striking ‘‘which would be determined
under section 55(b)(1)(A)’’ in paragraph (2)(A)(ii)
and inserting ‘‘which would be the pre-credit ten-
tative minimum tax’’, and
(4) by adding at the end thereof the following
new paragraph:
‘‘(4) PRE-CREDIT TENTATIVE MINIMUM TAX.—
For purposes of this subsection, the term ‘pre-credit
tentative minimum tax’ means—
‘‘(A) in the case of a taxpayer other than
a corporation, the amount determined under the
first sentence of section 55(b)(1)(A)(i), or
‘‘(B) in the case of a corporation, the
amount 
determined 
under 
section
55(b)(1)(B)(i).’’
(f) AMENDMENT RELATED TO SECTION 13212.—
Subparagraph (B) of section 401(a)(17) is amended to
read as follows:
‘‘(B) COST-OF-LIVING ADJUSTMENT.—The
Secretary shall adjust annually the $150,000
amount in subparagraph (A) for increases in
the cost-of-living at the same time and in the
same manner as under section 415(d), except
that the base period for purposes of section
359
415(d)(1)(A) shall be the calendar quarter be-
ginning October 1, 1993.’’
(g) AMENDMENT RELATED TO SECTION 13221.—
Subparagraph (A) of section 7518(g)(6) is amended by
striking ‘‘34 percent’’ and inserting ‘‘35 percent’’.
(h) AMENDMENTS RELATED TO SECTION 13222.—
(1) Subparagraph (B) of section 6033(e)(1) is
amended by adding at the end thereof the following
new clause:
‘‘(iii) COORDINATION
WITH
SECTION
527(f).—This subsection shall not apply to
any amount on which tax is imposed by
reason of section 527(f).’’.
(2) Clause (i) of section 6033(e)(1)(B) is
amended by striking ‘‘this subtitle’’ and inserting
‘‘section 501’’.
(i) AMENDMENT RELATED TO SECTION 13225.—
Paragraph (3) of section 6655(g) is amended by striking
all that follows ‘‘ ‘3rd month’ ’’ in the sentence following
subparagraph (C) and inserting ‘‘, subsection (e)(2)(A)
shall be applied by substituting ‘2 months’ for ‘3 months’
in clause (i)(I), the election under clause (i) of subsection
(e)(2)(C) may be made separately for each installment,
and clause (ii) of subsection (e)(2)(C) shall not apply.’’.
(j) AMENDMENTS RELATED TO SECTION 13231.—
360
(1) Paragraph (1) of section 956A(b) is amend-
ed to read as follows:
‘‘(1) the amount (not including a deficit) re-
ferred to in section 316(a)(1) to the extent such
amount was accumulated in prior taxable years be-
ginning after September 30, 1993, and’’.
(2) Subsection (f) of section 956A is amended
by inserting before the period at the end thereof:
‘‘and regulations coordinating the provisions of sub-
sections (c)(3)(A) and (d)’’.
(3)(A) Subparagraph (A) of section 1297(d)(2)
is amended by striking ‘‘The adjusted basis of any
asset’’ and inserting ‘‘The amount taken into ac-
count under section 1296(a)(2) with respect to any
asset’’.
(B) The paragraph heading of paragraph (2) of
section 1297(d) is amended to read as follows:
‘‘(2) AMOUNT TAKEN INTO ACCOUNT.—’’.
(4) Subsection (e) of section 1297 is amended
by inserting ‘‘For purposes of this part—’’ after the
subsection heading.
(k) AMENDMENT RELATED TO SECTION 13241.—
Subparagraph (B) of section 40(e)(1) is amended to read
as follows:
361
‘‘(B) for any period before January 1,
2001, during which the rates of tax under sec-
tion 4081(a)(2)(A) are 4.3 cents per gallon.’’
(l) AMENDMENT RELATED TO SECTION 13261.—
Clause (iii) of section 13261(g)(2)(A) of the Revenue Rec-
onciliation Act of 1993 is amended by striking ‘‘by the
taxpayer’’ and inserting ‘‘by the taxpayer or a related per-
son’’.
(m) AMENDMENT RELATED TO SECTION 13301.—
Subparagraph (B) of section 1397B(d)(5) is amended by
striking ‘‘preceding’’.
(n) CLERICAL AMENDMENTS.—
(1) Subsection (d) of section 39 is amended—
(A) by striking ‘‘45’’ in the heading of
paragraph (5) and inserting ‘‘45A’’, and
(B) by striking ‘‘45’’ in the heading of
paragraph (6) and inserting ‘‘45B’’.
(2) Subparagraph (A) of section 108(d)(9) is
amended by striking ‘‘paragraph (3)(B)’’ and insert-
ing ‘‘paragraph (3)(C)’’.
(3) Subparagraph (C) of section 143(d)(2) is
amended by striking the period at the end thereof
and inserting a comma.
(4) Clause (ii) of section 163(j)(6)(E) is amend-
ed by striking ‘‘which is a’’ and inserting ‘‘which is’’.
362
(5) Subparagraph (A) of section 1017(b)(4) is
amended by striking ‘‘subsection (b)(2)(D)’’ and in-
serting ‘‘subsection (b)(2)(E)’’.
(6) So much of section 1245(a)(3) as precedes
subparagraph (A) thereof is amended to read as fol-
lows:
‘‘(3) SECTION 1245 PROPERTY.—For purposes
of this section, the term ‘section 1245 property’
means any property which is or has been property
of a character subject to the allowance for deprecia-
tion provided in section 167 and is either—’’.
(7) Paragraph (2) of section 1394(e) is amend-
ed—
(A) by striking ‘‘(i)’’ and inserting ‘‘(A)’’,
and
(B) by striking ‘‘(ii)’’ and inserting ‘‘(B)’’.
(8) Subsection (m) of section 6501 (as redesig-
nated by section 1001) is amended by striking ‘‘or
51(j)’’ and inserting ‘‘45B, or 51(j)’’.
(9)(A) The section 6714 added by section
13242(b)(1) of the Revenue Reconciliation Act of
1993 is hereby redesignated as section 6715.
(B) The table of sections for part I of sub-
chapter B of chapter 68 is amended by striking
363
‘‘6714’’ in the item added by such section
13242(b)(2) of such Act and inserting ‘‘6715’’.
(10) Paragraph (2) of section 9502(b) is
amended by inserting ‘‘and before’’ after ‘‘1982,’’.
(11) Subsections (a)(2) and (a)(3) of section
13206 of the Revenue Reconciliation Act of 1993
are each amended by striking ‘‘this section’’ and in-
serting ‘‘this subsection’’.
(12) Paragraph (1) of section 13215(c) of the
Revenue Reconciliation Act of 1993 is amended by
striking ‘‘Public Law 92–21’’ and inserting ‘‘Public
Law 98–21’’.
(13) Paragraph (2) of section 13311(e) of the
Revenue Reconciliation Act of 1993 is amended by
striking ‘‘section 1393(a)(3)’’ and inserting ‘‘section
1393(a)(2)’’.
(14) Subparagraph (B) of section 117(d)(2) is
amended by striking ‘‘section 132(f)’’ and inserting
‘‘section 132(h)’’.
(o) EFFECTIVE DATE.—Any amendment made by
this section shall take effect as if included in the provision
of the Revenue Reconciliation Act of 1993 to which such
amendment relates.
364
SEC. 1003. MISCELLANEOUS PROVISIONS.
(a) APPLICATION OF AMENDMENTS MADE BY TITLE
XII OF OMNIBUS BUDGET RECONCILIATION ACT
OF
1990.—Except as otherwise expressly provided, whenever
in title XII of the Omnibus Budget Reconciliation Act of
1990 an amendment or repeal is expressed in terms of
an amendment to, or repeal of, a section or other provi-
sion, the reference shall be considered to be made to a
section or other provision of the Internal Revenue Code
of 1986.
(b) TREATMENT
OF CERTAIN AMOUNTS UNDER
HEDGE BOND RULES.—
(1) Clause (iii) of section 149(g)(3)(B) is
amended to read as follows:
‘‘(iii) AMOUNTS HELD PENDING REIN-
VESTMENT
OR
REDEMPTION.—Amounts
held for not more than 30 days pending re-
investment or bond redemption shall be
treated as invested in bonds described in
clause (i).’’
(2) The amendment made by paragraph (1)
shall take effect as if included in the amendments
made by section 7651 of the Omnibus Budget Rec-
onciliation Act of 1989.
(c) 
TREATMENT
OF
CERTAIN
DISTRIBUTIONS
UNDER SECTION 1445.—
365
(1) IN
GENERAL.—Paragraph (3) of section
1445(e) is amended by adding at the end thereof
the following new sentence: ‘‘Rules similar to the
rules of the preceding provisions of this paragraph
shall apply in the case of any distribution to which
section 301 applies and which is not made out of the
earnings and profits of such a domestic corpora-
tion.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall apply to distributions after
the date of the enactment of this Act.
(d) TREATMENT OF CERTAIN CREDITS UNDER SEC-
TION 469.—
(1) IN GENERAL.—Subparagraph (B) of section
469(c)(3) is amended by adding at the end thereof
the following new sentence: ‘‘If the preceding sen-
tence applies to the net income from any property
for any taxable year, any credits allowable under
subpart B (other than section 27(a)) or D of part
IV of subchapter A for such taxable year which are
attributable to such property shall be treated as
credits not from a passive activity to the extent the
amount of such credits does not exceed the regular
tax liability of the taxpayer for the taxable year
which is allocable to such net income.’’
366
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall apply to taxable years begin-
ning after December 31, 1986.
(e) TREATMENT OF DISPOSITIONS UNDER PASSIVE
LOSS RULES.—
(1) IN GENERAL.—Subparagraph (A) of section
469(g)(1) is amended to read as follows:
‘‘(A) IN GENERAL.—If all gain or loss real-
ized on such disposition is recognized, the ex-
cess of—
‘‘(i) any loss from such activity for
such taxable year (determined after the ap-
plication of subsection (b)), over
‘‘(ii) any net income or gain for such
taxable year from all other passive activi-
ties (determined after the application of
subsection (b)),
shall be treated as a loss which is not from a
passive activity.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall apply to taxable years begin-
ning after December 31, 1986.
(f) MISCELLANEOUS AMENDMENTS
TO FOREIGN
PROVISIONS.—
367
(1) COORDINATION OF UNIFIED ESTATE TAX
CREDIT WITH TREATIES.—Subparagraph (A) of sec-
tion 2102(c)(3) is amended by adding at the end
thereof the following new sentence: ‘‘For purposes
of the preceding sentence, property shall not be
treated as situated in the United States if such
property is exempt from the tax imposed by this
subchapter under any treaty obligation of the United
States.’’
(2) TREATMENT OF CERTAIN INTEREST PAID
TO RELATED PERSON.—
(A) IN
GENERAL.—Subparagraph (B) of
section 163(j)(1) is amended by inserting before
the period at the end thereof the following:
‘‘(and clause (ii) of paragraph (2)(A) shall not
apply for purposes of applying this subsection
to the amount so treated)’’.
(B) EFFECTIVE
DATE.—The amendment
made by subparagraph (A) shall apply as if in-
cluded in the amendments made by section
7210(a) of the Revenue Reconciliation Act of
1989.
(3) TREATMENT OF INTEREST ALLOCABLE TO
EFFECTIVELY CONNECTED INCOME.—
(A) IN GENERAL.—
368
(i) Subparagraph (B) of section
884(f)(1) is amended by striking ‘‘to the
extent’’ and all that follows down through
‘‘subparagraph (A)’’ and inserting ‘‘to the
extent that the allocable interest exceeds
the interest described in subparagraph
(A)’’.
(ii) The second sentence of section
884(f)(1) is amended by striking ‘‘reason-
ably expected’’ and all that follows down
through the period at the end thereof and
inserting ‘‘reasonably expected to be alloca-
ble interest.’’
(iii) Paragraph (2) of section 884(f) is
amended to read as follows:
‘‘(2) ALLOCABLE INTEREST.—For purposes of
this subsection, the term ‘allocable interest’ means
any interest which is allocable to income which is ef-
fectively connected (or treated as effectively con-
nected) with the conduct of a trade or business in
the United States.’’
(B) EFFECTIVE DATE.—The amendments
made by subparagraph (A) shall take effect as
if included in the amendments made by section
1241(a) of the Tax Reform Act of 1986.
369
(4) CLARIFICATION OF SOURCE RULE.—
(A) IN GENERAL.—Paragraph (2) of sec-
tion 865(b) is amended by striking ‘‘863(b)’’
and inserting ‘‘863’’.
(B) EFFECTIVE
DATE.—The amendment
made by subparagraph (A) shall take effect as
if included in the amendments made by section
1211 of the Tax Reform Act of 1986.
(5) REPEAL OF OBSOLETE PROVISIONS.—
(A) Paragraph (1) of section 6038(a) is
amended by striking ‘‘, and’’ at the end of sub-
paragraph (E) and inserting a period, and by
striking subparagraph (F).
(B) Subsection (b) of section 6038A is
amended by adding ‘‘and’’ at the end of para-
graph (2), by striking ‘‘, and’’ at the end of
paragraph (3) and inserting a period, and by
striking paragraph (4).
(g) TREATMENT OF ASSIGNMENT OF INTEREST IN
CERTAIN BOND-FINANCED FACILITIES.—
(1) IN GENERAL.—Subparagraph (A) of section
1317(3) of the Tax Reform Act of 1986 is amended
by adding at the end thereof the following new sen-
tence: ‘‘A facility shall not fail to be treated as de-
scribed in this subparagraph by reason of an assign-
370
ment (or an agreement to an assignment) by the
governmental unit on whose behalf the bonds are is-
sued of any part of its interest in the property fi-
nanced by such bonds to another governmental
unit.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall take effect as if included in
such section 1317 on the date of the enactment of
the Tax Reform Act of 1986.
(h) CLARIFICATION OF TREATMENT OF MEDICARE
ENTITLEMENT UNDER COBRA PROVISIONS.—
(1) IN GENERAL.—
(A) 
Subclause 
(V) 
of 
section
4980B(f)(2)(B)(i) is amended to read as fol-
lows:
‘‘(V) MEDICARE
ENTITLEMENT
FOLLOWED BY QUALIFYING EVENT.—
In the case of a qualifying event de-
scribed in paragraph (3)(B) that oc-
curs less than 18 months after the
date the covered employee became en-
titled to benefits under title XVIII of
the Social Security Act, the period of
coverage for qualified beneficiaries
other than the covered employee shall
371
not terminate under this clause before
the close of the 36-month period be-
ginning on the date the covered em-
ployee became so entitled.’’
(B) Clause (v) of section 602(2)(A) of the
Employee Retirement Income Security Act of
1974 is amended to read as follows:
‘‘(v) MEDICARE
ENTITLEMENT
FOL-
LOWED
BY
QUALIFYING
EVENT.—In the
case of a qualifying event described in sec-
tion 603(2) that occurs less than 18
months after the date the covered em-
ployee became entitled to benefits under
title XVIII of the Social Security Act, the
period of coverage for qualified bene-
ficiaries other than the covered employee
shall not terminate under this subpara-
graph before the close of the 36-month pe-
riod beginning on the date the covered em-
ployee became so entitled.’’
(C) Clause (iv) of section 2202(2)(A) of
the Public Health Service Act is amended to
read as follows:
‘‘(iv) MEDICARE ENTITLEMENT FOL-
LOWED
BY
QUALIFYING
EVENT.—In the
372
case of a qualifying event described in sec-
tion 2203(2) that occurs less than 18
months after the date the covered em-
ployee became entitled to benefits under
title XVIII of the Social Security Act, the
period of coverage for qualified bene-
ficiaries other than the covered employee
shall not terminate under this subpara-
graph before the close of the 36-month pe-
riod beginning on the date the covered em-
ployee became so entitled.’’
(2) EFFECTIVE DATE.—The amendments made
by this subsection shall apply to plan years begin-
ning after December 31, 1989.
(i) TREATMENT OF CERTAIN REMIC INCLUSIONS.—
(1) IN
GENERAL.—Subsection (a) of section
860E is amended by adding at the end thereof the
following new paragraph:
‘‘(6) COORDINATION WITH MINIMUM TAX.—For
purposes of part VI of subchapter A of this chap-
ter—
‘‘(A) the reference in section 55(b)(2) to
taxable income shall be treated as a reference
to taxable income determined without regard to
this subsection,
373
‘‘(B) the alternative minimum taxable in-
come of any holder of a residual interest in a
REMIC for any taxable year shall in no event
be less than the excess inclusion for such tax-
able year, and
‘‘(C) any excess inclusion shall be dis-
regarded for purposes of computing the alter-
native tax net operating loss deduction.
The preceding sentence shall not apply to any orga-
nization to which section 593 applies, except to the
extent provided in regulations prescribed by the Sec-
retary under paragraph (2).’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall take effect as if included in
the amendments made by section 671 of the Tax Re-
form Act of 1986 unless the taxpayer elects to apply
such amendment only to taxable years beginning
after the date of the enactment of this Act.
(j) EXEMPTION FROM HARBOR MAINTENANCE TAX
FOR CERTAIN PASSENGERS.—
(1) IN GENERAL.—Subparagraph (D) of section
4462(b)(1) (relating to special rule for Alaska, Ha-
waii, and possessions) is amended by inserting be-
fore the period the following: ‘‘, or passengers trans-
ported on United States flag vessels operating solely
374
within the State waters of Alaska or Hawaii and ad-
jacent international waters’’.
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall take effect as if included in
the amendments made by section 1402(a) of the
Harbor Maintenance Revenue Act of 1986.
(k) AMENDMENTS RELATED TO REVENUE PROVI-
SIONS OF ENERGY POLICY ACT OF 1992.—
(1) Effective with respect to taxable years be-
ginning after December 31, 1990, subclause (II) of
section 53(d)(1)(B)(iv) is amended to read as fol-
lows:
‘‘(II) the adjusted net minimum
tax for any taxable year is the amount
of the net minimum tax for such year
increased in the manner provided in
clause (iii).’’
(2) Subsection (g) of section 179A is redesig-
nated as subsection (f).
(l) TREATMENT OF QUALIFIED FOOTBALL COACHES
PLAN.—
(1) IN GENERAL.—Section 1022 of title II of
the Employee Retirement Income Security Act of
1974 is amended by adding at the end thereof the
following new subsection:
375
‘‘(i) QUALIFIED FOOTBALL COACHES PLAN.—For
purposes of determining the qualified plan status of a
qualified football coaches plan, section 3(37)(F) shall be
treated as part of this title and a qualified football coaches
plan shall be treated as a multiemployer collectively bar-
gained plan for purposes of the Internal Revenue Code
of 1986.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall apply to years beginning
after the date of the enactment of Public Law 100–
202.
(m) MISCELLANEOUS CLERICAL AMENDMENTS.—
(1) Subclause (II) of section 56(g)(4)(C)(ii) is
amended by striking ‘‘of the subclause’’ and insert-
ing ‘‘of subclause’’.
(2) Paragraph (2) of section 72(m) is amended
by inserting ‘‘and’’ at the end of subparagraph (A),
by striking subparagraph (B), and by redesignating
subparagraph (C) as subparagraph (B).
(3) Paragraph (2) of section 86(b) is amended
by striking ‘‘adusted’’ and inserting ‘‘adjusted’’.
(4)(A) The heading for section 112 is amended
by striking ‘‘COMBAT PAY’’ and inserting ‘‘COM-
BAT ZONE COMPENSATION’’.
376
(B) The item relating to section 112 in the
table of sections for part III of subchapter B of
chapter 1 is amended by striking ‘‘combat pay’’ and
inserting ‘‘combat zone compensation’’.
(C) Paragraph (1) of section 3401(a) is amend-
ed by striking ‘‘combat pay’’ and inserting ‘‘combat
zone compensation’’.
(5) Clause (i) of section 172(h)(3)(B) is amend-
ed by striking the comma at the end thereof and in-
serting a period.
(6) Clause (ii) of section 543(a)(2)(B) is
amended by striking ‘‘section 563(c)’’ and inserting
‘‘section 563(d)’’.
(7) Paragraph (1) of section 958(a) is amended
by 
striking 
‘‘sections 
955(b)(1)(A) 
and 
(B),
955(c)(2)(A)(ii), and 960(a)(1)’’ and inserting ‘‘sec-
tion 960(a)(1)’’.
(8) Subsection (g) of section 642 is amended by
striking ‘‘under 2621(a)(2)’’ and inserting ‘‘under
section 2621(a)(2)’’.
(9) Section 1463 is amended by striking ‘‘this
subsection’’ and inserting ‘‘this section’’.
(10) Subsection (k) of section 3306 is amended
by inserting a period at the end thereof.
377
(11) The item relating to section 4472 in the
table of sections for subchapter B of chapter 36 is
amended by striking ‘‘and special rules’’.
(12) Paragraph (2) of section 4978(b) is
amended by striking the period at the end of sub-
paragraph (A) and inserting a comma, and by strik-
ing the period and quotation marks at the end of
subparagraph (B) and inserting a comma.
(13) Paragraph (3) of section 5134(c) is
amended by striking ‘‘section 6662(a)’’ and inserting
‘‘section 6665(a)’’.
(14) Paragraph (2) of section 5206(f) is
amended by striking ‘‘section 5(e)’’ and inserting
‘‘section 105(e)’’.
(15) Paragraph (1) of section 6050B(c) is
amended by striking ‘‘section 85(c)’’ and inserting
‘‘section 85(b)’’.
(16) Subsection (k) of section 6166 is amended
by striking paragraph (6).
(17) Subsection (e) of section 6214 is amended
to read as follows:
378
‘‘(e) CROSS REFERENCE.—
‘‘For provision giving Tax Court jurisdiction to
order a refund of an overpayment and to award
sanctions, see section 6512(b)(2).’’
(18) The section heading for section 6043 is
amended by striking the semicolon and inserting a
comma.
(19) The item relating to section 6043 in the
table of sections for subpart B of part III of sub-
chapter A of chapter 61 is amended by striking the
semicolon and inserting a comma.
(20) The table of sections for part I of sub-
chapter A of chapter 68 is amended by striking the
item relating to section 6662.
(21)(A) Section 7232 is amended—
(i) by striking ‘‘LUBRICATING OIL,’’ in
the heading, and
(ii) by striking ‘‘lubricating oil,’’ in the
text.
(B) The table of sections for part II of sub-
chapter A of chapter 75 is amended by striking ‘‘lu-
bricating oil,’’ in the item relating to section 7232.
(22) Paragraph (1) of section 6701(a) of the
Omnibus Budget Reconciliation Act of 1989 is
amended by striking ‘‘subclause (IV)’’ and inserting
‘‘subclause (V)’’.
379
(23) Clause (ii) of section 7304(a)(2)(D) of
such Act is amended by striking ‘‘subsection (c)(2)’’
and inserting ‘‘subsection (c)’’.
(24) Paragraph (1) of section 7646(b) of such
Act is amended by striking ‘‘section 6050H(b)(1)’’
and inserting ‘‘section 6050H(b)(2)’’.
(25) Paragraph (10) of section 7721(c) of
such 
Act 
is 
amended 
by 
striking 
‘‘section
6662(b)(2)(C)(ii)’’ 
and 
inserting 
‘‘section
6661(b)(2)(C)(ii)’’.
(26) Subparagraph (A) of section 7811(i)(3) of
such Act is amended by inserting ‘‘the first place it
appears’’ before ‘‘in clause (i)’’.
(27) Paragraph (10) of section 7841(d) of
such Act is amended by striking ‘‘section 381(a)’’
and inserting ‘‘section 381(c)’’.
(28) Paragraph (2) of section 7861(c) of such
Act is amended by inserting ‘‘the second place it ap-
pears’’ before ‘‘and inserting’’.
(29) Paragraph (1) of section 460(b) is amend-
ed by striking ‘‘the look-back method of paragraph
(3)’’ and inserting ‘‘the look-back method of para-
graph (2)’’.
380
(30) Subparagraph (C) of section 50(a)(2) is
amended by striking ‘‘subsection (c)(4)’’ and insert-
ing ‘‘subsection (d)(5)’’.
(31) Subparagraph (B) of section 172(h)(4) is
amended by striking the material following the head-
ing and preceding clause (i) and inserting ‘‘For pur-
poses of subsection (b)(2)—’’.
(32) Subparagraph (A) of section 355(d)(7) is
amended by inserting ‘‘section’’ before ‘‘267(b)’’.
(33) Subparagraph (C) of section 420(e)(1) is
amended by striking ‘‘mean’’ and inserting ‘‘means’’.
(34) Paragraph (4) of section 537(b) is amend-
ed by striking ‘‘section 172(i)’’ and inserting ‘‘sec-
tion 172(f)’’.
(35) Subparagraph (B) of section 613(e)(1) is
amended by striking the comma at the end thereof
and inserting a period.
(36) Paragraph (4) of section 856(a) is amend-
ed by striking ‘‘section 582(c)(5)’’ and inserting
‘‘section 582(c)(2)’’.
(37) 
Sections 
904(f)(2)(B)(i) 
and
907(c)(4)(B)(iii) are each amended by inserting ‘‘(as
in effect on the day before the date of the enactment
of the Revenue Reconciliation Act of 1990)’’ after
‘‘section 172(h)’’.
381
(38) Subsection (b) of section 936 is amended
by striking ‘‘subparagraphs (D)(ii)(I)’’ and inserting
‘‘subparagraphs (D)(ii)’’.
(39) Subsection (c) of section 2104 is amended
by striking ‘‘subparagraph (A), (C), or (D) of sec-
tion 
861(a)(1)’’ 
and 
inserting 
‘‘section
861(a)(1)(A)’’.
(40) Paragraph (1) of section 5002(b) is
amended by striking ‘‘section 5041(c)’’ and inserting
‘‘section 5041(d)’’.
(41) Section 6038 is amended by redesignating
the subsection relating to cross references as sub-
section (f).
(42) Clause (iv) of section 6103(e)(1)(A) is
amended by striking all that follows ‘‘provisions of’’
and inserting ‘‘section 1(g) or 59(j);’’.
(43) The subsection (f) of section 6109 of the
Internal Revenue Code of 1986 which was added by
section 2201(d) of Public Law 101–624 is redesig-
nated as subsection (g).
(44) Subsection (b) of section 7454 is amended
by striking ‘‘section 4955(e)(2)’’ and inserting ‘‘sec-
tion 4955(f)(2)’’.
(45) Subsection (d) of section 11231 of the
Revenue Reconciliation Act of 1990 shall be applied
382
as if ‘‘comma’’ appeared instead of ‘‘period’’ and as
if the paragraph (9) proposed to be added ended
with a comma.
(46) Paragraph (1) of section 11303(b) of the
Revenue Reconciliation Act of 1990 shall be applied
as if ‘‘paragraph’’ appeared instead of ‘‘subpara-
graph’’ in the material proposed to be stricken.
(47) Subsection (f) of section 11701 of the Rev-
enue Reconciliation Act of 1990 is amended by in-
serting ‘‘(relating to definitions)’’ after ‘‘section
6038(e)’’.
(48) Subsection (i) of section 11701 of the Rev-
enue Reconciliation Act of 1990 shall be applied as
if ‘‘subsection’’ appeared instead of ‘‘section’’ in the
material proposed to be stricken.
(49) Subparagraph (B) of section 11801(c)(2)
of the Revenue Reconciliation Act of 1990 shall be
applied as if ‘‘section 56(g)’’ appeared instead of
‘‘section 59(g)’’.
(50) Subparagraph (C) of section 11801(c)(8)
of the Revenue Reconciliation Act of 1990 shall be
applied as if ‘‘reorganizations’’ appeared instead of
‘‘reorganization’’ in the material proposed to be
stricken.
383
(51) Subparagraph (H) of section 11801(c)(9)
of the Revenue Reconciliation Act of 1990 shall be
applied as if ‘‘section 1042(c)(1)(B)’’ appeared in-
stead of ‘‘section 1042(c)(2)(B)’’.
(52) Subparagraph (F) of section 11801(c)(12)
of the Revenue Reconciliation Act of 1990 shall be
applied as if ‘‘and (3)’’ appeared instead of ‘‘and
(E)’’.
(53) Subparagraph (A) of section 11801(c)(22)
of the Revenue Reconciliation Act of 1990 shall be
applied as if ‘‘chapters 21’’ appeared instead of
‘‘chapter 21’’ in the material proposed to be strick-
en.
(54) Paragraph (3) of section 11812(b) of the
Revenue Reconciliation Act of 1990 shall be applied
by not executing the amendment therein to the
heading of section 42(d)(5)(B).
(55) Clause (i) of section 11813(b)(9)(A) of the
Revenue Reconciliation Act of 1990 shall be applied
as if a comma appeared after ‘‘(3)(A)(ix)’’ in the
material proposed to be stricken.
(56) Subparagraph (F) of section 11813(b)(13)
of the Revenue Reconciliation Act of 1990 shall be
applied as if ‘‘tax’’ appeared after ‘‘investment’’ in
the material proposed to be stricken.
389
(A) IN
GENERAL.—Section 206(b)(1) of
such Act (42 U.S.C. 406(b)(1)) is amended—
(i) by inserting ‘‘(A)’’ after ‘‘(b)(1)’’;
and
(ii) by adding at the end the following
new subparagraph:
‘‘(B) For purposes of this paragraph—
‘‘(i) the term ‘past-due benefits’ excludes any
benefits with respect to which payment has been
continued pursuant to subsection (g) or (h) of sec-
tion 223, and
‘‘(ii) amounts of past-due benefits shall be
taken into account to the extent provided under the
rules applicable in cases before the Secretary.’’.
(B) PROTECTION
FROM
OFFSETTING
SSI
BENEFITS.—The 
last 
sentence 
of 
section
1127(a) of such Act (as added by section
5106(b) of the Omnibus Budget Reconciliation
Act of 1990) (42 U.S.C. 1320a–6(a)) is amend-
ed by striking ‘‘section 206(a)(4)’’ and inserting
‘‘subsection (a)(4) or (b) of section 206’’.
(3) APPLICATION OF SINGLE DOLLAR AMOUNT
CEILING TO CONCURRENT CLAIMS UNDER TITLES II
AND XVI.—
390
(A) IN
GENERAL.—Section 206(a)(2) of
such Act (as amended by section 5106(a)(1) of
the Omnibus Budget Reconciliation Act of
1990) (42 U.S.C. 406(a)(2)) is amended—
(i) by redesignating subparagraph (C)
as subparagraph (D); and
(ii) by inserting after subparagraph
(B) the following new subparagraph:
‘‘(C) In any case involving—
‘‘(i) an agreement described in subparagraph
(A) with any person relating to both a claim of enti-
tlement to past-due benefits under this title and a
claim of entitlement to past-due benefits under title
XVI, and
‘‘(ii) a favorable determination made by the
Secretary with respect to both such claims,
the Secretary may approve such agreement only if the
total fee or fees specified in such agreement does not ex-
ceed, in the aggregate, the dollar amount in effect under
subparagraph (A)(ii)(II).’’.
(B) CONFORMING
AMENDMENT.—Section
206(a)(3)(A) of such Act (as amended by sec-
tion 5106(a)(1) of the Omnibus Budget Rec-
onciliation 
Act 
of 
1990) 
(42 
U.S.C.
406(a)(3)(A)) is amended by striking ‘‘para-