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Section 2. Reports and Studies

MANDATED REPORTS AND STUDIES

Listed below (by subject, citation of request, and due date) are mandated studies either outstanding or received in the 102d Congress for which the Department of the Treasury, Office of Tax Policy, has primary responsibility.

1. Americans Working Abroad (Section 912). Section 208-Foreign Earned Income Act of 1978 (P.L. 95-615) as amended by Section 114. The Economic Recovery Tax Act of 1981 (P.L. 97-34). Due end of 1993 (every 5 years).

2. Source Rule on Sales of Personal Property. Section 1211(d), Title XII, the Tax Reform Act of 1986 (P.L. 99-514).

Due January 1, 1992.

3. Reform of Subchapter C. Section 634, Title VI, the Tax Reform Act of 1986 (P.L. 99–514).

Due January 1, 1992.

4. Study of Certain Fraternal Beneficiary Societies. Section 1012(c)(2), Title X, the Tax Reform Act of 1986 (P.L. 99-514). Due July 1, 1992.

5. Worthlessness of Bad Debts. The Tax Reform Act of 1986 (P.L. 99-514), Conference Report (99-841), p. II-316.

Due January 1, 1988.

6. Pension Plans Full-Funding Limitation. Section 9301(c)(3), Title IX, the Omnibus Budget Reconciliation Act of 1987 (P.L. 100– 203).

Due April 15, 1991.

7. Limiting Policyholder Dividend Deduction for Mutual Companies. Section 1025, Title X, the Tax Reform Act of 1986 (P.L. 99-514).

Due January 1, 1992.

8. Publicly Traded Limited Partnerships (final report). Section 10215, the Omnibus Budget Reconciliation Act of 1987 (P.L. 100-203).

Due January 1, 1989-Final Report. Partial report received March 30, 1990.

9. Definition of United States Resident. Section 6138, the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647). Due May 1, 1989.

10. Minimum Participation Rules. Section 6056, the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647).

Due February 15, 1991. Received March 15, 1991.

11. Treatment of Certain Technical Personnel. Section 6072, the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100647).

Due February 15, 1991. Received March 15, 1991.

12. Taxation of Social Security Benefits (1987). Section 121, the Social Security Amendments of 1983 (P.L. 98-21), p. 97, Stat. 84.

Due Annually. Received March 1, 1991.

13. International Boycott Provision. Section 1067, the Tax Reform Act of 1976 (P.L. 94-455), as amended by Section 411, the Deficit Reduction Act of 1984 (P.L. 98-369).

Due 1993-4-year cycle.

14. Treatment of Certain Family Service Providers. Section 6305(e), the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647).

Due January 1, 1992.

15. Deferred Compensation under Section 457. Section 6064(d)(4), the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100647).

Due January 1, 1992.

16. Private Foundation Grant-Making Expenses. The Deficit Reduction Act of 1984 (P.L. 98-369), Conference Report (98-861), p. 1087.

Due January 1, 1990-Extended from January 1, 1988 by letter from Chairman Rostenkowski, September 10, 1985. Received January 1990.

17. Spin-off of Defined Benefit Plan Assets to Bridge Banks. Section 6067(b), the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647).

Due January 1, 1992.

18. DISC/FSC/FSC Services. Section 506, Revenue Act of 1971 (P.L. 92-178), as amended by Section 804, the Deficit Reduction Act of 1984 (P.L. 98-369), as amended by Section 6252(b)(2), the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100647), Also Conference Report (98-861), p. 976.

Due Final DISC: April 4, 1987, First FSC: December 31, 1990. Quadrennial. FSC Services: January 18, 1985.

19. Possessions Corporation (Seventh Report). Section 441, the Deficit Reduction Act of 1984 (P.L. 98-369) as it amends Ways and Means and Senate Finance Reports on the Tax Reform Act of 1976 (P.L. 94-455), as amended by Section 6252(b)(1) of the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100647).

Next report Due December 31, 1992. Quadrennial.

20. Study of Depreciation Treatment of Certain Vehicles. Section 7612(f), the Omnibus Budget Reconciliation Act of 1989 (P.L. 101-239).

Due April 15, 1991.

21. Study of Return Requirement Where Cash Received in Trade or Business. Section 11318(d), Omnibus Budget Reconciliation Act of 1990 (P.L. 101-508).

Due March 31, 1991.

22. Study of Section 482. Section 11316, Omnibus Budget Reconciliation Act of 1990 (P.L. 101-508).

Due March 1, 1991.

23. Study of Special Valuation Rules with Respect to Estate Tax Freezes. Section 11602(d), Omnibus Budget Reconciliation Bill of 1990 (P.L. 101-508).

Due December 31, 1992.

MAJOR TREASURY STUDIES

The following major Treasury studies provide useful information about the tax system and ways in which it might be reformed:

Tax Reform for Fairness, Simplicity, and Economic Growth-The Treasury Department Report to the President, Office of the Secretary, Department of the Treasury, 3 volumes (November 1984). Volume 1 of the study discusses the need for tax reform in 1984, surveys various options, and proposes a modified flat tax. It discusses comprehensively, in the context of needed reforms, the taxation of individuals and families, the taxation of capital and business income, and various industry-specific subsidies. It also discusses the relative advantages and disadvantages of a consumption tax and a value-added tax. Volume 2 of the study provides additional information concerning the scope and operative effect of its proposals. It describes then-current law for numerous specific issues, gives reasons for change, details its proposals, and analyzes the probable effect of each proposal. Volume 3 is devoted to the valueadded tax. It describes and evaluates the value-added tax from an economic and administrative perspective.

The President's 1978 Tax Program-Detailed Descriptions and Supporting Analyses of the Proposals, Department of the Treasury (January 30, 1978). The study presents a set of proposals to stimulate the economy through reduced rates and to make the tax system more equitable and simple. Because many of the proposals in this study have already been adopted or overtaken by subsequent developments in the law, they may be largely of historical interest, although the more general policy goals discussed are still current.

Blueprints for Basic Tax Reform, Department of the Treasury (January 17, 1977) (in 1982 there was published commercially a revision of this study by Mr. David H. Bradford, who as Deputy Assistant Secretary for Tax Policy (Tax Analysis) directed the work on the original 1977 study). This study presents two specific model tax systems: (1) a reformed comprehensive income tax that would, among other things, eliminate the separate corporate income tax; and (2) a cash-flow tax based on consumption. The study analyzes the relative merits of the two models and contains quantitative analyses.

RECENT JOINT COMMITTEE ON TAXATION PAMPHLETS ON TAX ISSUES

Following is a selective list of some recent pamphlets prepared by the staff of the Joint Committee on Taxation. These pamphlets provide useful background information on various issues that have come before the Committee on Ways and Means for hearings, as well as descriptions and analyses of particular proposals that may have been under consideration. If the pamphlets remain in print, copies may be obtained by calling (202)-225-2647. Certain additional 1991 pamphlets are reprinted as part of this document (e.g., JCS-2-91: Description of Tax Provisions Expiring in 1991 and 1992 is reprinted as Part VIII; JCS-3-91: Schedule of Present Excise Taxes (as of January 1, 1991) is reprinted in section 5 of Part III).

JCS-1-90

JCS-90 DOCUMENTS

(GPO-PRINTED PAMPHLETS)

Background and Issues Relating to the Taxation of Foreign Investment in the United States Scheduled for Hearings Before the House Committee on Ways and Means on January 24-25 and 30-31, 1990 (January 23, 1990).

JCS-4-90

Explanation of Miscellaneous Tax Proposals Scheduled for Hearings Before the Subcommittee on Select Revenue Measures of the House Committee on Ways and Means on February 21-22, 1990 (February 14, 1990).

JCS-6-90 Present Law and Background Relating to Federal Environmental Tax Policy Schedule for Hearings by the Committee on Ways and Means on March 6-7 and 14, 1990 (March 1, 1990).

JCS-7-90 Estimates of Federal Tax Expenditures for Fiscal
Years 1991-1995 Prepared for the Committee on Ways and
Means and the Committee on Finance (March 9, 1990).
JCS-8-90 Tax Treatment of Short-Term Trading Scheduled for
a Hearing Before the Senate Committee on Finance on
March 21, 1990 (March 19, 1990).

JCS-9-90

Present-Law Rules Relating to Qualified Pension Plans Scheduled for a Hearing Before the Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service of the Senate Committee on Finance on March 23, 1990 (March 22, 1990).

JCS-10-90 Proposals and Issues Relating to Taxation of Capital Gains and Losses Scheduled for a Hearing Before the Senate Committee on Finance on March 28, 1990 (March 23, 1990). JCS-11-90 Present Law, Proposals, and Issues Relating to Individual Retirement Arrangements and Other Savings Incentives Scheduled for a Hearing Before the Senate Committee on Finance on March 27, 1990 (March 26, 1990).

JCS-12-90 Explanation of Methodology Used to Estimate Proposals Affecting the Taxation of Income from Capital Gains (March 27, 1990).

JCS-13-90 Federal Transfer Tax Consequences of Estate Freezes Scheduled for a Hearing Before the Committee on Ways and Means on April 24, 1990 (April 20, 1990).

JCS-22-90 Present Law and Certain Issues Relating to Transfer Pricing (Code Section 482) Scheduled for Hearings Before the Subcommittee on Oversight of the House Committee on Ways and Means on July 10 and 12, 1990 (June 28, 1990). JCS-23-90 Present Law and Proposals Relating to Increasing Domestic Energy Production and Reserves Scheduled for a Hearing Before the Subcommittee on Energy and Agricultural Taxation of the Committee on Finance on July 27, 1990 (July 26, 1990). JCS-24-90 Simplification of Present-Law Tax Rules Relating to Qualified Pension Plans (S. 2901, The Employee Benefits Simplification Act) Scheduled for a Hearing Before the Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service of the Senate Committee on Finance on August 3, 1990 (August 3, 1990).

JCX-90 DOCUMENTS

(JOINT COMMITTEE PHOTOCOPY DOCUMENTS)

JCX-1-90 Background and Issues on Certain Tax and Trade Alcohol Fuel Initiatives Scheduled for a Hearing Before the House Committee on Ways and Means on February 1, 1990 (January 30, 1990).

JCX-8-90 Present Law and Issues Relating to Social Security Tax Treatment of Nonqualified Compensation Scheduled for a Hearing Before the Subcommittee on Social Security of the House Committee on Ways and Means on April 5, 1990 (April 2, 1990).

JCX-16-90

Overview of the Enforcement and Administration of the Employee Retirement Income Security Act of 1974 Scheduled for a Hearing Before the Subcommittee on Oversight of the House Committee on Ways and Means on June 12-14, 1990 (June 6, 1990).

JCX-22-90 Present-Law Tax Rules and Proposed Committee Amendment Under S. 712, Puerto Rico Status Referendum Act-Markup Consideration by Senate Committee on Finance on August 1, 1990 (August 1, 1990).

JCX-23-90 Revenue Estimates of Proposed Committee Amendment Under S.712 Puerto Rico Status Referendum ActMarkup Consideration by Senate Committee on Finance on August 1, 1990 (August 1, 1990).

JCX-24-90 Simplification of Tax Rules Relating to Employee Benefit Programs Maintained by Churches (S. 2902, The Church Retirement Benefits Simplification Act) Scheduled for a Hearing Before the Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service of the Senate Committee on Finance on August 3, 1990 (August 3, 1990).

JCX-25-90 Description of H.R. 5454 (The Technical Corrections Act of 1990) (August 3, 1990).

JCX-40-90 Description of H.R. 5826 (Small Business Tax Incentive Act of 1990) Scheduled for Markup Consideration by the

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