(1) Section 401(k)(2)(B)(i) of such Code is
amended by striking ‘‘or’’ at the end of subclause
(III), by striking ‘‘and’’ at the end of subclause (IV)
and inserting ‘‘or’’, and by inserting after subclause
(IV) the following new subclause:
‘‘(V) the date on which distribu-
tions for qualified higher education
expenses 
(as 
defined 
in 
section
72(t)(6)) or start-up expenses (as de-
fined in section 195(c)) or qualified
first-time homebuyer distributions (as
defined in section 72(t)(7)(A)) are
made, and’’.
(2) Section 403(b)(11) of such Code is amend-
ed 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 sub-
paragraph (B) the following new subparagraph:
‘‘(C) for the payment of qualified higher
education expenses (as defined in section
72(t)(6)), start-up expenses (as defined in sec-
tion 195(c)), or qualified acquisition costs (as
defined in section 72(t)(7)) with respect to a
principal residence (as so defined) of a first-
time homebuyer (as so defined).’’
(f) EFFECTIVE DATE.—The amendments made by
this section shall apply to payments and distributions after
the date of the enactment of this Act.
SEC. 5. MINIMUM TAX ON FOREIGN AND FOREIGN-OWNED
CORPORATIONS.
(a) IN GENERAL.—Subchapter A of chapter 1 of the
Internal Revenue Code of 1986 (relating to determination
of tax liability) is amended by adding at the end thereof
the following new part:
‘‘PART VIII—MINIMUM TAX ON CERTAIN FOREIGN
AND FOREIGN-OWNED CORPORATIONS
‘‘Sec. 59B. Minimum tax on certain foreign and foreign-owned
corporations.
‘‘SEC. 59B. MINIMUM TAX ON CERTAIN FOREIGN AND FOR-
EIGN-OWNED CORPORATIONS.
‘‘(a) IMPOSITION OF TAX.—In the case of a corpora-
tion to which this section applies, there is hereby imposed
(in addition to any other tax imposed by this subtitle) a
tax equal to the excess (if any) of—
‘‘(1) 35 percent of the product of—
‘‘(A) 9 percent, and
‘‘(B) an amount equal to 75 percent of the
gross receipts of the taxpayer from the sale or
leasing of property manufactured by the tax-
payer or by any foreign person that is a related
party of the taxpayer, over
‘‘(2) the aggregate tax imposed under sections
11, 55, and 1201 for such year.
‘‘(b) TAXPAYERS TO WHICH SECTION APPLIES.—
This section shall apply to a corporation for the taxable
year if—
‘‘(1) such corporation is—
‘‘(A) a domestic corporation which is 25-
percent foreign-owned, or
‘‘(B) a foreign corporation engaged in a
trade or business within the United States, and
‘‘(2) the gross receipts from the sale or leasing
of property manufactured by such corporation or by
any foreign person that is a related party of such
corporation are greater than the lesser of—
‘‘(A) $2,000,000, or
‘‘(B) an amount equal to 10 percent of the
total gross receipts of such corporation.
‘‘(c) DEFINITIONS.—For purposes of this section, the
term ‘25-percent foreign-owned’, ‘foreign person’, and ‘re-
lated party’ have the respective meanings given such terms
by section 6038A(c).’’
(b) CLERICAL AMENDMENT.—The table of parts for
such subchapter A is amended by adding at the end there-
of the following new item:
‘‘Part VIII. Minimum tax on certain foreign and foreign-owned
corporations.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
December 31, 1994.
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HR 1389 IH——2