IB 
Union Calendar No. 463 
110TH CONGRESS 
2D SESSION 
H. R. 6275 
[Report No. 110–728] 
To amend the Internal Revenue Code of 1986 to provide individuals 
temporary relief from the alternative minimum tax, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
JUNE 17, 2008 
Mr. RANGEL (for himself, Mr. MCDERMOTT, Mr. LEWIS of Georgia, Mr. 
NEAL of Massachusetts, Mr. POMEROY, Mrs. JONES of Ohio, Mr. 
BLUMENAUER, Ms. BERKLEY, Mr. CROWLEY, Mr. VAN HOLLEN, Mr. 
MEEK of Florida, Mr. LEVIN, and Mr. LARSON of Connecticut) intro-
duced the following bill; which was referred to the Committee on Ways 
and Means 
JUNE 20, 2008 
Reported with an amendment, committed to the Committee of the Whole 
House on the State of the Union, and ordered to be printed 
[Strike out all after the enacting clause and insert the part printed in italic] 
[For text of introduced bill, see copy of bill as introduced on June 17, 2008] 
A BILL 
To amend the Internal Revenue Code of 1986 to provide 
individuals temporary relief from the alternative min-
imum tax, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00001
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
SECTION 1. SHORT TITLE, ETC. 
(a) SHORT TITLE.—This Act may be cited as the ‘‘Al-
ternative Minimum Tax Relief Act of 2008’’. 
(b) REFERENCE.—Except as otherwise expressly pro-
vided, whenever in this Act an amendment or repeal is ex-
pressed in terms of an amendment to, or repeal of, a section 
or other provision, the reference shall be considered to be 
made to a section or other provision of the Internal Revenue 
Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents for 
this Act is as follows: 
Sec. 1. Short title, etc. 
TITLE I—INDIVIDUAL TAX RELIEF 
Sec. 101. Extension of increased alternative minimum tax exemption amount. 
Sec. 102. Extension of alternative minimum tax relief for nonrefundable personal 
credits. 
TITLE II—REVENUE PROVISIONS 
Sec. 201. Income of partners for performing investment management services 
treated as ordinary income received for performance of services. 
Sec. 202. Limitation of deduction for income attributable to domestic production 
of oil, gas, or primary products thereof. 
Sec. 203. Limitation on treaty benefits for certain deductible payments. 
Sec. 204. Returns relating to payments made in settlement of payment card and 
third party network transactions. 
Sec. 205. Application of continuous levy to property sold or leased to the Federal 
Government. 
Sec. 206. Time for payment of corporate estimated taxes. 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00002
Fmt 6652
Sfmt 6213
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
TITLE I—INDIVIDUAL TAX 
RELIEF 
SEC. 101. EXTENSION OF INCREASED ALTERNATIVE MIN-
IMUM TAX EXEMPTION AMOUNT. 
(a) IN GENERAL.—Paragraph (1) of section 55(d) is 
amended— 
(1) by striking ‘‘($66,250 in the case of taxable 
years beginning in 2007)’’ in subparagraph (A) and 
inserting ‘‘($69,950 in the case of taxable years begin-
ning in 2008)’’, and 
(2) by striking ‘‘($44,350 in the case of taxable 
years beginning in 2007)’’ in subparagraph (B) and 
inserting ‘‘($46,200 in the case of taxable years begin-
ning in 2008)’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2007. 
SEC. 102. EXTENSION OF ALTERNATIVE MINIMUM TAX RE-
LIEF 
FOR 
NONREFUNDABLE 
PERSONAL 
CREDITS. 
(a) IN GENERAL.—Paragraph (2) of section 26(a) is 
amended— 
(1) by striking ‘‘or 2007’’ and inserting ‘‘2007, 
or 2008’’, and 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00003
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
(2) by striking ‘‘2007’’ in the heading thereof and 
inserting ‘‘2008’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to taxable years beginning after Decem-
ber 31, 2007. 
TITLE II—REVENUE PROVISIONS 
SEC. 201. INCOME OF PARTNERS FOR PERFORMING INVEST-
MENT MANAGEMENT SERVICES TREATED AS 
ORDINARY INCOME RECEIVED FOR PERFORM-
ANCE OF SERVICES. 
(a) IN GENERAL.—Part I of subchapter K of chapter 
1 is amended by adding at the end the following new sec-
tion: 
‘‘SEC. 710. SPECIAL RULES FOR PARTNERS PROVIDING IN-
VESTMENT 
MANAGEMENT 
SERVICES 
TO 
PARTNERSHIP. 
‘‘(a) TREATMENT OF DISTRIBUTIVE SHARE OF PART-
NERSHIP ITEMS.—For purposes of this title, in the case of 
an investment services partnership interest— 
‘‘(1) IN
GENERAL.—Notwithstanding section 
702(b)— 
‘‘(A) any net income with respect to such 
interest for any partnership taxable year shall be 
treated as ordinary income for the performance 
of services, and 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00004
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
shall be taken into account as an increase in 
such partner’s distributive share of the taxable 
income of the partnership (except to the extent 
such excess is otherwise taken into account in de-
termining the taxable income of the partnership), 
‘‘(B) such property shall be treated for pur-
poses of subpart B of part II as money distrib-
uted to such partner in an amount equal to such 
fair market value, and 
‘‘(C) the basis of such property in the hands 
of such partner shall be such fair market value. 
Subsection (b) of section 734 shall be applied without 
regard to the preceding sentence. 
‘‘(5) APPLICATION OF SECTION 751.—In applying 
section 751(a), an investment services partnership in-
terest shall be treated as an inventory item. 
‘‘(c) INVESTMENT SERVICES PARTNERSHIP INTER-
EST.—For purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘investment serv-
ices partnership interest’ means any interest in a 
partnership which is held by any person if such per-
son provides (directly or indirectly) a substantial 
quantity of any of the following services with respect 
to the assets of the partnership in the conduct of the 
trade or business of providing such services: 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00009
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
‘‘(A) Advising as to the advisability of in-
vesting in, purchasing, or selling any specified 
asset. 
‘‘(B) Managing, acquiring, or disposing of 
any specified asset. 
‘‘(C) Arranging financing with respect to 
acquiring specified assets. 
‘‘(D) Any activity in support of any service 
described in subparagraphs (A) through (C). 
For purposes of this paragraph, the term ‘specified 
asset’ means securities (as defined in section 475(c)(2) 
without regard to the last sentence thereof), real es-
tate, commodities (as defined in section 475(e)(2))), 
or options or derivative contracts with respect to secu-
rities (as so defined), real estate, or commodities (as 
so defined). 
‘‘(2) EXCEPTION FOR CERTAIN CAPITAL INTER-
ESTS.— 
‘‘(A) IN GENERAL.—If— 
‘‘(i) a portion of an investment services 
partnership interest is acquired on account 
of a contribution of invested capital, and 
‘‘(ii) the partnership makes a reason-
able allocation of partnership items between 
the portion of the distributive share that is 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00010
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
with respect to invested capital and the por-
tion of such distributive share that is not 
with respect to invested capital, 
then subsection (a) shall not apply to the portion 
of the distributive share that is with respect to 
invested capital. An allocation will not be treat-
ed as reasonable for purposes of this subpara-
graph if such allocation would result in the part-
nership allocating a greater portion of income to 
invested capital than any other partner not pro-
viding services would have been allocated with 
respect to the same amount of invested capital. 
‘‘(B) SPECIAL RULE FOR DISPOSITIONS.— 
In any case to which subparagraph (A) applies, 
subsection (b) shall not apply to any gain or loss 
allocable to invested capital. The portion of any 
gain or loss attributable to invested capital is the 
proportion of such gain or loss which is based on 
the distributive share of gain or loss that would 
have been allocable to invested capital under sub-
paragraph (A) if the partnership sold all of its 
assets immediately before the disposition. 
‘‘(C) INVESTED CAPITAL.—For purposes of 
this paragraph, the term ‘invested capital’ 
means, the fair market value at the time of con-
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00011
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
tribution of any money or other property con-
tributed to the partnership. 
‘‘(D) TREATMENT OF CERTAIN LOANS.— 
‘‘(i) 
PROCEEDS
OF
PARTNERSHIP 
LOANS NOT TREATED AS INVESTED CAPITAL 
OF
SERVICE
PROVIDING
PARTNERS.—For 
purposes of this paragraph, an investment 
services partnership interest shall not be 
treated as acquired on account of a con-
tribution of invested capital to the extent 
that such capital is attributable to the pro-
ceeds of any loan or other advance made or 
guaranteed, directly or indirectly, by any 
partner or the partnership. 
‘‘(ii) LOANS FROM NONSERVICE PRO-
VIDING
PARTNERS
TO
THE
PARTNERSHIP 
TREATED AS INVESTED CAPITAL.—For pur-
poses of this paragraph, any loan or other 
advance to the partnership made or guaran-
teed, directly or indirectly, by a partner not 
providing services to the partnership shall 
be treated as invested capital of such part-
ner and amounts of income and loss treated 
as allocable to invested capital shall be ad-
justed accordingly. 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00012
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
‘‘(d) OTHER INCOME AND GAIN IN CONNECTION WITH 
INVESTMENT MANAGEMENT SERVICES.— 
‘‘(1) IN GENERAL.—If— 
‘‘(A) a person performs (directly or indi-
rectly) investment management services for any 
entity, 
‘‘(B) such person holds a disqualified inter-
est with respect to such entity, and 
‘‘(C) the value of such interest (or payments 
thereunder) is substantially related to the 
amount of income or gain (whether or not real-
ized) from the assets with respect to which the 
investment management services are performed, 
any income or gain with respect to such interest shall 
be treated as ordinary income for the performance of 
services. Rules similar to the rules of subsection (c)(2) 
shall apply where such interest was acquired on ac-
count of invested capital in such entity. 
‘‘(2) DEFINITIONS.—For purposes of this sub-
section— 
‘‘(A) DISQUALIFIED INTEREST.—The term 
‘disqualified interest’ means, with respect to any 
entity— 
‘‘(i) any interest in such entity other 
than indebtedness, 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00013
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS
‘‘(ii) convertible or contingent debt of 
such entity, 
‘‘(iii) any option or other right to ac-
quire property described in clause (i) or 
(ii), and 
‘‘(iv) any derivative instrument en-
tered into (directly or indirectly) with such 
entity or any investor in such entity. 
Such term shall not include a partnership inter-
est and shall not include stock in a taxable cor-
poration. 
‘‘(B) TAXABLE
CORPORATION.—The term 
‘taxable corporation’ means— 
‘‘(i) a domestic C corporation, or 
‘‘(ii) a foreign corporation subject to a 
comprehensive foreign income tax. 
‘‘(C) 
INVESTMENT
MANAGEMENT
SERV-
ICES.—The term ‘investment management serv-
ices’ means a substantial quantity of any of the 
services described in subsection (c)(1) which are 
provided in the conduct of the trade or business 
of providing such services. 
‘‘(D) COMPREHENSIVE
FOREIGN
INCOME 
TAX.—The term ‘comprehensive foreign income 
VerDate Aug 31 2005 
23:07 Jun 20, 2008
Jkt 069200
PO 00000
Frm 00014
Fmt 6652
Sfmt 6203
E:\BILLS\H6275.RH
H6275
pwalker on PROD1PC71 with BILLS