TABLE 2.-REVENUE EFFECT OF TAX REFORM, ESTATE AND GIFT TAX, AND TAX CUT PROVISIONS OF THE ACT BY TITLE AND SECTION Continued

Sec. 1014-Interest charge on accumulation distributions from foreign trusts.......

-1

12

(1)

Sec. 1015-Excise tax on transfers of property to foreign persons to avoid Federal income tax..

Part 1-Amendments affecting tax treatment of controlled foreign corporations and their shareholders:

Sec. 1021-Amendment of provision relating to investment
in U.S. property by controlled foreign corporations....
Sec. 1022-Repeal of exclusion for earnings of less devel-
oped country corporations for purposes of section 1248..
Sec. 1023-Exclusion from subpart F of certain earnings of
insurance companies....

Sec. 1024-Shipping profits of foreign corporations...
Limitation on definition of foreign base company sales
income in the case of certain agricultural products...
See footnotes at end of table.

(2)

-5

<-5

-5

TABLE 2.-REVENUE EFFECT OF TAX REFORM, ESTATE AND GIFT TAX, AND TAX CUT PROVISIONS 1 OF THE ACT BY TITLE AND SECTION 1-Continued

[In millions of dollars; fiscal years]

TITLE X-Continued

Changes in the Treatment of Foreign Income-Continued

Part III-Amendments affecting treatment of foreign taxes:
Sec. 1031-Requirement that foreign tax credit be deter-
mined on overall basis.

Sec. 1032 Recapture of foreign losses.
Sec. 1033-Dividends from less developed country corpora-
tions to be grosses up for purposes of determining United
States income and foreign tax credit against that income..
Sec. 1034-Treatment of capital gains for purposes of
foreign tax credit.....

Sec. 1035-Foreign oil and gas extraction income.
Sec. 1036-Underwriting income..

Sec. 1037-Third-tier foreign tax credit when section 951
applies...

Part IV-Money or other property moving out of or into the
United States:

Sec. 1041-Portfolio debt investments in United States of
nonresident aliens and foreign corporations..
Sec. 1042-Changes in ruling requirements under section
367; certain changes in section 1248.

Sec. 1043-Continguous country branches of domestic life insurance companies..

Sec. 1301-Disposition of private foundation property under transition rules of Tax Reform Act of 1969.

Sec. 1302-New private foundations set-asides.

Sec. 1303-Minimum distribution amount for private foundations.
Sec. 1304 Extension of time to amend charitable remainder
trust governing instrument..

Sec. 1305-Unrelated trade or business income of trade shows,
State fairs, etc.:

Charitable organizations not subject to an unrelated busi-
ness income tax on rental income from trade shows..
County fairs not subject to an unrelated business income

tax.

Sec. 1306-Declaratory judgments with respect to section 501(c)(3) status and classification..

Sec. 1307-Lobbying by public charities.

Sec. 1308-Tax liens, etc., not to constitute acquisition indebted

ness..

See footnotes at end of table.

TABLE 2.-REVENUE EFFECT OF TAX REFORM, ESTATE AND GIFT TAX, AND TAX CUT PROVISIONS OF THE ACT BY TITLE AND SECTION Continued

ABLE 2.-REVENUE EFFECT OF TAX REFORM, ESTATE AND GIFT TAX, AND TAX CUT FROVISIONS 1 OF THE ACT BY TITLE AND SECTION 1-Continued

[In millions of dollars; fiscal years]

TITLE XXI

Miscellaneous Provisions

Sec. 2101-Tax treatment of certain housing associations....

Sec. 2102-Treatment of certain disaster Payments..

Sec. 2103-Tax treatment of certain 1972 disaster losses.

Sec. 2104-Tax treatment of certain debts owned by political parties, etc., to accrual basis taxpayers

Sec. 2105-Tax-exempt bonds for student loans.

Sec. 2106-Personal holding company income amendments.

Sec. 2107-Work incentive program expenses.

Sec. 2108-Repeal of excise tax on light-duty truck parts.

Sec. 2109-Exclusion from excise tax on certain articles resold after modification...

Sec. 2110-Franchise transfers.

Sec. 2111-Employers' duties in connection with the recording and reporting of tips..

Sec. 2112-Treatment of certain pollution control facilities..

Sec. 2113-Clarification of status of certain fishermen's organi-
zations..

Sec. 2114-Application of section 6013(e) of the Internal
Revenue Code of 1954.

Transfers of oil and gas property within the same controlled group or family.

<-10

Sec. 2116-Implementation of Federal-State Tax Collection Act of 1972.

TABLE 2.-REVENUE EFFECT OF TAX REFORM, ESTATE AND GIFT TAX, AND TAX CUT PROVISIONS OF ACT

1 This table has omitted Title I-Short Title and Title XIX-Repeal and Revision of Obsolete, Rarely Used, Etc., Provisions. 2 Less than $5,000,000.

The revenue impact of this provision will not be very great; its magnitude, however, is not determinable because of lack of information regarding the practices of the State legislators during the period covered by the provision. Reflects liability of prior years.

It is estimated that this provision will decrease budget receipts by $65,000,000 in the aggregate over the next 5 fiscal years.

There is also an estimated $2,000,000 decrease in budget receipts for fiscal year 1976 under this provision.

7 The long-run estimates are as follows: unified rates and credit, -$1.23 billion; marital deduction, -$153 million; valuation, -$14 million; extension of time, less than $500,000; unification, $300 million; generation skipping, $280 million; carryover of basis, $1.08 billion; and total, $263 million.

79-667 O-77-3