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termined without regard to this paragraph and
59D).
‘‘(b) SPECIAL RULES.—
‘‘(1) SURTAX
TO
APPLY
TO
ESTATES
AND
TRUSTS.—For purposes of this section, the term ‘in-
dividual’ includes any estate or trust taxable under
section 1.
‘‘(2) COORDINATION
WITH
OTHER
PROVI-
SIONS.—The provisions of this section shall be ap-
plied—
‘‘(A) shall be applied after the application
of section 1(h), but
‘‘(B) before the application of any other
provision of this title which refers to the
amount of tax imposed by section 1 or 55, as
the case may be.’’
(b) CLERICAL AMENDMENT.—The table of parts for
subchapter A of chapter 1 is amended by adding at the
end the following new item:
‘‘Part VIII. Health security premium.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
December 31, 1993.
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SEC. 814. SURTAX ON INDIVIDUALS WITH INCOMES OVER
$1,000,000.
(a) GENERAL RULE.—Subchapter A of chapter 1 (re-
lating to determination of tax liability) is amended by
adding at the end thereof the following new part:
‘‘PART IX—SURTAX ON INDIVIDUALS WITH
INCOMES OVER $1,000,000
‘‘Sec. 59C. Surtax on section 1 tax.
‘‘Sec. 59D. Surtax on minimum tax.
‘‘Sec. 59E. Special rules.
‘‘SEC. 59C. SURTAX ON SECTION 1 TAX.
‘‘In the case of an individual who has taxable income
for the taxable year in excess of $1,000,000, the amount
of the tax imposed under section 1 for such taxable year
shall be increased by 10 percent of the amount which
bears the same ratio to the tax imposed under section 1
(determined without regard to this section and section
59B) as—
‘‘(1) the amount by which the taxable income of
such individual for such taxable year exceeds
$1,000,000, bears to
‘‘(2) the total amount of such individual’s tax-
able income for such taxable year.
‘‘SEC. 59D. SURTAX ON MINIMUM TAX.
‘‘In the case of an individual who has alternative min-
imum taxable income for the taxable year in excess of
$1,000,000, the amount of the tentative minimum tax de-
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termined under section 55 for such taxable year shall be
increased by 2.8 percent of the amount by which the alter-
native minimum taxable income of such taxpayer for the
taxable year exceeds $1,000,000.
‘‘SEC. 59E. SPECIAL RULES.
‘‘(a) 
SURTAX
TO
APPLY
TO
ESTATES
AND
TRUSTS.—For purposes of this part, the term ‘individual’
includes any estate or trust taxable under section 1.
‘‘(b) TREATMENT OF MARRIED INDIVIDUALS FILING
SEPARATE RETURNS.—In the case of a married individual
(within the meaning of section 7703) filing a separate re-
turn for the taxable year, sections 59C and 59D shall be
applied by substituting ‘$500,000’ for ‘$1,000,000’.
‘‘(c) COORDINATION WITH OTHER PROVISIONS.—
The provisions of this part—
‘‘(1) shall be applied after the application of
sections 1(h) and 59B, but
‘‘(2) before the application of any other provi-
sion of this title which refers to the amount of tax
imposed by section 1 or 55, as the case may be.’’
(b) CLERICAL AMENDMENT.—The table of parts for
subchapter A of chapter 1 is amended by adding at the
end the following new item:
‘‘Part IX. Surtax on individuals with incomes over $1,000,000.’’
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(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
December 31, 1994.
Subtitle C—Employment Tax
Changes
SEC. 821. MODIFICATIONS OF CERTAIN EMPLOYMENT TAX
PROVISIONS.
(a) INCREASE IN EMPLOYER HOSPITAL INSURANCE
TAX; REPEAL OF DOLLAR LIMITATION ON AMOUNT OF
WAGES SUBJECT TO EMPLOYEE AND EMPLOYER HOS-
PITAL INSURANCE TAXES.—
(1) EMPLOYEE TAX.—Subsection (b) of section
3101 is amended by striking ‘‘equal to’’ and all that
follows and inserting ‘‘equal to 1.45 percent of the
wages (as defined in section 3121(a) without regard
to paragraph (1) thereof) received by him with re-
spect 
to 
employment 
(as 
defined 
in 
section
3121(b))’’.
(2) EMPLOYER TAX.—Subsection (b) of section
3111 is amended by striking ‘‘equal to’’ and all that
follows and inserting ‘‘equal to 7.9 percent of the
wages (as defined in section 3121(a) without regard
to paragraph (1) thereof) paid by him with respect
to employment (as defined in section 3121(b))’’.
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(3) SELF-EMPLOYMENT
TAX.—Subsection (b)
of section 1401 is amended by striking ‘‘a tax as fol-
lows:’’ and all that follows and inserting ‘‘a tax
equal to 8.35 percent of the amount of the self-em-
ployment income (as defined in section 1402(b)
without regard to paragraph (1) thereof) for such
taxable year’’.
(4) RAILROAD RETIREMENT TAXES.—Subpara-
graph (A) of section 3231(e)(2) is amended by add-
ing at the end thereof the following new clause:
‘‘(iii) LIMITATION NOT TO APPLY TO
TAXES EQUIVALENT TO HOSPITAL INSUR-
ANCE TAXES.—Clause (i) shall not apply
to—
‘‘(I) so much of the rate applica-
ble under section 3201(a) or 3221(a)
(as the case may be) as does not ex-
ceed the rate of tax in effect under
section 3101(b), and
‘‘(II) so much of the rate of tax
applicable under section 3211(a)(1) as
does not exceed the rate of tax in ef-
fect under section 1401(b).’’
(5) TECHNICAL AMENDMENTS.—
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(A) Subsection (b) of section 1402 is
amended by striking ‘‘the applicable contribu-
tion base (as determined under subsection (k))’’
and inserting ‘‘the contribution and benefit base
(as determined under section 231 of the Social
Security Act)’’.
(B) Section 1402 is amended by striking
subsection (k).
(C) Paragraph (1) of section 3121(a) is
amended—
(i) by striking ‘‘applicable contribution
base (as determined under subsection (x))’’
each place it appears and inserting ‘‘con-
tribution and benefit base (as determined
under section 230 of the Social Security
Act)’’, and
(ii) by striking ‘‘such applicable con-
tribution base’’ and inserting ‘‘such con-
tribution and benefit base’’.
(D) Section 3121 is amended by striking
subsection (x).
(E) Clause (i) of section 3231(e)(2)(B) is
amended to read as follows:
‘‘(i) TIER 1 TAXES.—Except as pro-
vided in clause (ii), the term ‘applicable
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base’ means for any calendar year the con-
tribution and benefit base determined
under section 230 of the Social Security
Act for such calendar year.’’
(F) Paragraph (3) of section 6413(c) is
amended to read as follows:
‘‘(3) SEPARATE
APPLICATION
FOR
HOSPITAL
INSURANCE TAXES.—Paragraphs (1) and (2) shall
not apply to—
‘‘(A) the tax imposed by section 3101(b)
(or any amount equivalent to such tax), and
‘‘(B) so much of the tax imposed by sec-
tion 3201 as is determined at a rate not greater
than the rate in effect under section 3101(b).’’
(G) Sections 3122 and 3125 are each
amended—
(i) by striking ‘‘section 3111’’ each
place it appears and inserting ‘‘section
3111(a)’’, and
(ii) by striking ‘‘applicable contribu-
tion base limitation’’ and inserting ‘‘con-
tribution and benefit base limitation’’.
(6) EFFECTIVE DATE.—The amendments made
by this subsection shall apply to 1994 and later cal-
endar years.
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(b) ADDITIONAL STATE
AND LOCAL EMPLOYEES
SUBJECT TO HOSPITAL INSURANCE TAX.—
(1) IN
GENERAL.—Paragraph (2) of section
3121(u) is amended by striking subparagraphs (C)
and (D).
(2) EFFECTIVE DATE.—The amendment made
by this subsection shall apply to remuneration paid
after December 31, 1994.
Subtitle 
D—Other 
Revenue 
In-
creases Primarily Affecting In-
dividuals
SEC. 831. OVERALL LIMITATION ON ITEMIZED DEDUCTIONS
FOR HIGH-INCOME TAXPAYERS MADE PER-
MANENT.
Subsection (f) of section 68 (relating to overall limita-
tion on itemized deductions) is hereby repealed.
SEC. 832. PHASEOUT OF PERSONAL EXEMPTION OF HIGH-
INCOME TAXPAYERS MADE PERMANENT.
Section 151(d)(3) (relating to phaseout of personal
exemption) is amended by striking subparagraph (E).
SEC. 833. MODIFICATIONS TO DEDUCTIONS FOR CERTAIN
MOVING EXPENSES.
(a) REPEAL OF DEDUCTION FOR QUALIFIED RESI-
DENCE SALE, ETC., EXPENSES.—
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(1) IN
GENERAL.—Paragraph (1) of section
217(b) (defining moving expenses) is amended by in-
serting ‘‘or’’ at the end of subparagraph (C), by
striking ‘‘, or’’ at the end of subparagraph (D) and
inserting a period, and by striking subparagraph
(E).
(2) CONFORMING AMENDMENTS.—
(A) Subsection (b) of section 217 is
amended by striking paragraph (2) and redesig-
nating paragraph (3) as paragraph (2).
(B) Section 217 is amended by striking
subsection (e).
(b) DEDUCTION
DISALLOWED
FOR
MEAL
EX-
PENSES.—Paragraph (1) of section 217(b) is amended—
(1) by striking ‘‘meals and lodging’’ in subpara-
graphs (B), (C) and (D) and inserting ‘‘lodging’’,
and
(2) by adding at the end thereof the following
new sentence:
‘‘Such term shall not include any expenses for
meals.’’.
(c) OVERALL LIMITATION.—
(1) IN GENERAL.—Subparagraph (A) of section
217(b)(2) (as redesignated by subsection (a)) is
amended to read as follows:
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‘‘(II) subsection (a)(2) would
have applied if the security were held
as of the close of the taxable year,
such gain or loss shall be treated as ordi-
nary income or loss.
‘‘(B) 
EXCEPTION.—Subparagraph 
(A)
shall not apply to any gain or loss which is allo-
cable to a period during which—
‘‘(i) the security is described in sub-
section (b)(1)(C) (without regard to sub-
section (b)(2)),
‘‘(ii) the security is held by a person
other than in connection with its activities
as a dealer in securities, or
‘‘(iii) the security is improperly identi-
fied (within the meaning of subparagraph
(A) or (B) of paragraph (2)).
‘‘(e) REGULATORY AUTHORITY.—The Secretary shall
prescribe such regulations as may be necessary or appro-
priate to carry out the purposes of this section, including
rules—
‘‘(1) to prevent the use of year-end transfers,
related parties, or other arrangements to avoid the
provisions of this section, and