LEGISLATIVE HISTORY OF THE ACT The Tax Reform Act of 1976 was the result of over two years of legislative deliberations largely during the 94th Congress, although some of the provisions were originally considered by the House Ways and Means Committee during the 93rd Congress.1 Consideration of the Act in the 94th Congress proceeded on the following schedule: June 23 through June 25, 1975: Panel Discussions before the House Committee on Ways and Means. July 8 through July 31, 1975: Hearings before the House Committee on Ways and Means. November 12, 1975: Bill (H.R. 10612) reported by the House Committee on Ways and Means (House Report 94-658). December 3 and 4, 1975: Bill considered and passed by the House of Representatives. March 17 through April 13, 1976; July 20 through 22, 1976: Hearings before the Senate Committee on Finance. June 10, 1976: Bill reported by the Senate Committee on Finance (Senate Report 94-938): Supplemental report filed by Senate Committee on Finance on July 20, 1976 (Senate Report 94-938, Part 2). June 16-18, 21-25, 28-30, July 1-2, 20-23, 26-30, and August 3-6, 1976: Bill considered and passed by the Senate. September 13, 1976: Committee on Conference submitted Conference Report (House Report 94-1515; Senate Report 94-1236). September 16, 1976: Conference report (and House Concurrent Resolution 751) approved by the House and Senate. October 4, 1976: Tax Reform Act of 1976 (Public Law 94-455) signed by the President. 1 The Ways and Means Committee did not report a tax reform bill in the 93rd Congress but did hold extensive discussions (February 5-28, 1973) and hearings (March 5 through May 1, 1973) on the subject. The Ways and Means Committee also held legislative markup sessions on tax reform late in the 2nd session (1974), but had only made tentative decisions prior to the end of the 93rd Congress. In addition, H.R. 17488, The Energy Tax and Individual Relief Act of 1974, reported by that committee on November 26, 1974 (House Report 93-1502), included provisions relating to real estate investment trusts and the taxation of foreign income, much of which was later included in the Tax Reform Act of 1976. (V) i Capitalization and Amortization of Real Property Construction Period Interest and Taxes (Sec. 201). a. Farming Syndicates (Sec. 207). b. Limitation of Loss With Respect to Farms to the Limitation of Loss to Amount At Risk (Sec. 204) Retroactive Allocations of Partnership Income or d. Partnership Special Allocations (Sec. 213(d))_ 67 |