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2. Property held for use in a trade or business or held for investment
in a like-kind exchange.

303

B. Low-Income Housing Tax Credit......

306

C. Rehabilitation Tax Credit......

307

D. Orphan Drug Tax Credit...........

E. Work Opportunity Tax Credit and Welfare-to-Work Tax Credit
F. Indian Employment Tax Credit...............

G. Electric Vehicle Credit and Clean Fuel Vehicle Deduction
VII. ACCOUNTING AND COST RECOVERY PROVISIONS

A. Structural Issues Relating to Accounting for Capital Expenditures.
B. Cash Method of Accounting for Small Businesses.
C. Amortization of Organization Expenditures
D. Depreciation--Mid-Quarter Convention...

310

311

317

320

322

322

328

332

334

VIII. FINANCIAL PRODUCTS AND INSTITUTIONS ...........

336

A. Structural Issues Relating to Financial Products and Institutions
B. Modification of the Straddle Rules ......

336

339

C. Provide More Uniform Treatment of Interest Charges
D. Redraft Rules for Taxation of Annuities.....

344

356

E. Special Rules for Mortgage Guaranty Insurance, Lease Guaranty
Insurance, and Insurance of State and Local Obligations.....

377

F. Special Deduction and Exception to Reduction in Unearned
Premium Reserves for Blue Cross and Blue Shield Organizations..
G. Treatment of Life Insurance Companies.

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B. Anti-Deferral Regimes Applicable to Income Earned Through

Foreign Corporations.............

398

C. Expand Subpart F De Minimis Rule.......

419

D. Look-Through Rules for Dividends from Noncontrolled Section 902
Corporations

421

E. Foreign Tax Credits Claimed Indirectly Through Partnerships

424

F. Conform Sections 30A and 936 .............

428

G. Application of Uniform Capitalization Rules for Foreign Persons.

432

H. Secondary Withholding Tax on Dividends From Foreign Corporations ....
I. Capital Gains of Certain Nonresident Individuals..

436

440

J. U.S. Model Tax Treaties.....

445

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A. Percentage Limits on Grass-Roots Lobbying Expenditures of

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C. Capital Gains Treatment to Apply to Outright Sales of Timber by
Landowners

465

D. Qualifications for the Zero-Percent Capital Gain Rate in the D.C.
Enterprise Zone

466

XII.

E. Uniform Rules and Incentives for Economically Distressed Areas ....
F. Permit Expensing of Certain Geological and Geophysical Costs
EXCISE TAXES

A. Highway Trust Fund Excise Taxes.......

468

475

478

478

B. Airport and Airway Trust Fund Excise Taxes...............

490

C. Harbor Maintenance Trust Fund Excise Tax and Tax on Passenger
Transportation by Water......

497

D. Aquatic Resources Trust Fund Excise Taxes........

F. Black Lung Trust Fund Excise Tax..........

G. Communications Excise Tax......

H. Ozone-Depleting Chemicals Excise Tax..........

I. Alcohol Excise Taxes.........

J. Tobacco Excise Taxes......

XIII. TAX-EXEMPT BONDS......

499

E. Federal Aid to Wildlife Fund and Non-Regular Firearms Excise Tax..

501

503

504

507

508

513

516

A. Eliminate Five-Percent Disproportionate Use Limit.

B. Consolidate Prohibited/Restricted Use Facilities Rules.

516

517

.......

C. Provisions Rendered or Being Rendered Obsolete by the Passage of Time ..

1. Deadwood provisions....

520

a. Mortgage revenue bonds--Federal disaster area modifications..........
b. Interim authority for governors regarding allocation of private
activity bond volume limits.........

520 520

521

2. Other provisions.

522

.....

a. Consolidate qualified mortgage bonds and qualified veterans'
mortgage bonds .......

522

b. Eliminate $150 million limit for qualified 501(c)(3) bonds...

524

c. Eliminate qualified small-issuer exception for certain bank-qualified
bonds

525

d. Modify public notice requirements

526

D. Arbitrage Rebate Provisions.......

528

XIV. ESTATE AND GIFT TAX PROVISION--Conform Certain

XV.

XVI.

Family-Owned and Small Business Provisions
EMPLOYMENT TAX PROVISIONS...............................

A. Structural Issues Relating to Worker Classification..............

B. Structural Issues Relating to Determination of Individuals Subject to
Self-Employment Tax

COMPLIANCE AND ADMINISTRATION PROVISIONS..........
A. Structural Issues Relating to Alternate Return Filing Systems ...............
B. Structural Issues Relating to Judicial Proceedings in Federal Tax Cases
C. Penalties and Interest........

D. Disclosure of Returns and Return Information ...

XVII. DEADWOOD PROVISIONS ..........

Page

531

539

539

551

555

555

560

568

572

579

VOLUME III

I.

II.

SUMMARIES OF ACADEMIC PAPERS SUBMITTED TO THE JOINT
COMMITTEE STAFF..

A. Jonathan Barry Forman, Simplification for Low-Income Taxpayers: 2001....
B. Deborah A. Geier, Simplifying and Rationalizing the Federal Income Tax
Law Applicable to Transfers in Divorce ....

C. Frances R. Hill, Private Benefit, Public Benefit and Exemption

D. Frances R. Hill, Exemption and Commercial Activities: Approaches to
Rationalizing Unrelated Business Income Tax

E. Annette Nellen, Simplification of the EITC Through Structural Changes....
F. George K. Yin and David J. Shakow, Reforming and Simplifying the
Income Taxation of Private Business Enterprises

ACADEMIC PAPERS SUBMITTED TO THE JOINT COMMITTEE
STAFF

......

A. Jonathan Barry Forman, Simplification for Low-Income Taxpayers: 2001....
B. Deborah A. Geier, Simplifying and Rationalizing the Federal Income Tax
Law Applicable to Transfers in Divorce .....

C. Frances R. Hill, Private Benefit, Public Benefit and Exemption.
D. Frances R. Hill, Exemption and Commercial Activities: Approaches to
Rationalizing Unrelated Business Income Tax

E. Annette Nellen, Simplification of the EITC Through Structural Changes.....
F. George K. Yin and David J. Shakow, Reforming and Simplifying the
Income Taxation of Private Business Enterprises..

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22

34

19

9

10

10

19

143

175

205

220

INTRODUCTION

This document,' is a report of the staff of the Joint Committee on Taxation (“Joint Committee staff") in connection with a study of the overall state of the Federal tax system. This report is being transmitted, as required under section 8022(3)(B) of the Internal Revenue Code of 1986, to the House Committee on Ways and Means and the Senate Committee on Finance. Under section 8022(3)(B), the Joint Committee staff is required to report at least once each Congress on the overall state of the Federal tax system and to make recommendations with respect to possible simplification proposals and other matters relating to the administration of the Federal tax system.

The Joint Committee staff is publishing this study in three volumes. Volume I of this study contains Part One (Executive Summary and Joint Committee on Taxation Staff Study Mandate and Methodology), Part Two (Overall State of the Federal Tax System), and four Appendices (Academic Advisors to the Joint Committee on Taxation, Tax Policy Advisors to the Joint Committee on Taxation, General Accounting Office Materials, and Congressional Research Service Materials). Volume II of this study contains Part Three (Recommendations of the Joint Committee on Taxation Staff to Simplify the Federal Tax System). Volume III of this study contains papers relating to simplification submitted to the Joint Committee on Taxation by tax scholars in connection with the study.

1 This document may be cited as follows: Joint Committee on Taxation, Study of the Overall State of the Federal Tax System and Recommendations for Simplification, Pursuant to Section 8022(3)(B) of the Internal Revenue Code of 1986 (JCS-3-01), April 2001.

2

Section 8022(3)(B) was added by section 4002(a) of the Internal Revenue Service Restructuring and Reform Act of 1998.

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