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GENERAL EXPLANATION

OF THE

TAX REFORM ACT OF 1976

(H.R. 10612, 94TH CONGRESS, PUBLIC LAW 94455)

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CONGRESS OF THE UNITED STATES

(94th Cong., 2d sess.)

JOINT COMMITTEE ON TAXATION
SENATE

HOUSE
RUSSELL B. LONG, Louisiana, Chairman AL ULLMAN, Oregon, Vice Chairman
HERMAN E. TALMADGE, Georgia

JAMES A. BURKE, Massachusetts
VANCE HARTKE, Indiana

DAN ROSTENKOWSKI, Illinois CARL T. CURTIS, Nebraska

HERMAN T. SCHNEEBELI, Pennsylvania PAUL J. FANNIN, Arizona

BARBER B. CONABLE, JR., New York
LAURENCE N. WOODWORTH, Chief of Staff
HERBERT L. CHABOT, A 88istant Chief of Staff
BERNARD M. SHAPIRO, A 88istant Chief of Staff

(II)

LETTER OF TRANSMITTAL

CONGRESS OF THE UNITED STATES,

JOINT COMMITTEE ON TAXATION,

Washington, D.C., December 29, 1976. Hon. RUSSELL B. LONG, Chairman, Hon. AL ULLMAN, Vice Chairman, Joint Committee on Taxation,

U.S. Congress, Washington, D.C. DEAR MESSRS. CHAIRMEN : While committee reports explain the position of the House Committee on Ways and Means, or the position of the Senate Committee on Finance, they do not in all cases explain the tax legislation as finally passed by the Congress. This becames particularly important in the case of major legislation where there are many changes between the bill as passed by the House, or as passed by the Senate, and the bill which finally becomes public law. The Tax Reform Act of 1976, because of its comprehensive scope and because of the many changes which were made in this legislation, both by the Senate and subsequently by the conferees, is an illustration of where the differences were especially significant.

This document represents the effort of the staff of the Joint Committee on Taxation to provide an explanation of the Tax Reform Act of 1976 as finally enacted and is comparable to a number of similar documents prepared by the staff on other revenue acts in recent years. For the most part, where provisions which were unchanged in conference were described in either the House or Senate report, that explanation is carried over in this document. No attempt is made here to carry the explanation further than is customary in the case of committtee reports and therefore it does not deal with issues which are customarily explained in regulations or rulings.

The first major part of the document contains a summary of and the reasons previously given for the various provisions. The second part contains the revenue estimates on the legislation as finally enacted and the third part is a general explanation of the provisions appearing in the order in which they appear in the public law.

This material has been prepared by the staff of the Joint Committee on Taxation after the Tax Reform Act of 1976 was passed. It has not been reviewed by the tax committees and therefore only reflects the staff's view as to the intent of Congress. It is hoped that this document ::will be useful in gaining a better understanding of the Tax Reform Act of 1976. Sincerely yours,

LAURENCE N. WOODWORTH,

Chief of Staff.

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