[House Report 106-90]
[From the U.S. Government Publishing Office]
106th Congress Report
1st Session HOUSE OF REPRESENTATIVES 106-90
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TAX RELIEF FOR PERSONNEL IN THE FEDERAL REPUBLIC OF YUGOSLAVIA (SERBIA/
MONTENEGRO) AND CERTAIN OTHER AREAS
_______
April 13, 1999.--Committed to the Committee of the Whole House on the
State of the Union and ordered to be printed
_______
Mr. Archer, from the Committee on Ways and Means, submitted the
following
R E P O R T
[To accompany H.R. 1376]
[Including cost estimate of the Congressional Budget Office]
The Committee on Ways and Means to whom was referred the
bill (H.R. 1376) to extend the tax benefits available with
respect to services performed in a combat zone to services
performed in the Federal Republic of Yugoslavia (Serbia/
Montenegro) and certain other areas, and for other purposes,
having considered the same, report favorably thereon with an
amendment and recommend that the bill as amended do pass.
CONTENTS
Page
I. Introduction................................................ 2
A. Purpose and Summary................................... 2
B. Background and Need for Legislation................... 2
C. Legislative History................................... 2
II. Explanation of the Bill...................................... 2
III.Vote of the Committee........................................ 8
IV. Budget Effects of the Bill................................... 8
A. Committee Estimates of Budgetary Effects.............. 8
B. Statement Regarding New Budget Authority and Tax
Expenditures......................................... 10
C. Cost Estimate Prepared by the Congressional Budget
Office............................................... 10
V. Other Matters To Be Discussed Under Rules of the House....... 11
A. Committee Oversight Findings and Recommendations...... 11
B. Summary of Findings and Recommendations of the
Committee on Government Reform....................... 11
C. Constitutional Authority Statement.................... 11
D. Information Relating to Unfunded Mandates............. 11
E. Applicability of House Rule XX15(c)................... 12
F. Tax Complexity Analysis............................... 12
The amendment if as follows:
In section 1(b) insert ``(above the 39th parallel)'' after
``the northern Ionian Sea''.
I. INTRODUCTION
A. Purpose and Summary
The bill (H.R. 1376): (1) provides that service in a
qualified hazardous duty area (Federal Republic of Yugoslavia
(Serbia/Montenegro), Albania, the Adriatic Sea, and the
Northern Ionian Sea) is to be treated as if it were a combat
zone; and (2) makes the suspension of time provisions of Code
section 7508 applicable to personnel serving as part of
``Operation Allied Force'' outside those areas.
B. Background and Need for Legislation
The bill is intended to treat service by United States
Armed Forces (and support) personnel in the Federal Republic of
Yugoslavia (Serbia/Montenegro), Albania, the Adriatic Sea, and
the Northern Ionian Sea as if it were combat zone service for
purposes of the Internal Revenue Code. The bill also makes the
suspension of time provisions of Code section 7508 applicable
to personnel serving as part of Operation Allied Force ourside
those areas.
C. Legislative History
H.R. 1376 was introduced by Mr. Archer and others on April
13, 1999, and was marked up by the Committee on April 13, 1999.
The bill was ordered favorably reported (by voice vote) with
amendment on April 13, 1999.
II. EXPLANATION OF THE BILL
Present Law
General time limits for filing tax returns
Present law provides that individuals generally must file
their Federal income tax returns by April 15 of the year
following the close of a taxable year (sec. 6072). Present law
also provides that the Secretary may grant reasonable
extensions of time for filing such returns (sec. 6081).
Treasury regulations provide an additional automatic two-month
extension (until June 15 for calendar-year individuals) for
United States citizens and residents in military or naval
service on duty on April 15 of the following year (the
otherwise applicable due date of the return) outside the United
States (Treas. Reg. sec. 1.6081-5(a)(6)). No action is
necessary to apply for this extension, but taxpayers must
indicate on their returns (when filed) that they are claiming
this extension. Unlike most extensions of time to file, this
extension applies to both filing returns and paying the tax
due.
Treasury regulations also provide, upon application on the
proper form, an automatic four-month extension (until August 15
for calendar-year individuals) for any individual timely filing
that form and paying the amount of tax estimated to be due
(Treas. Reg. sec. 1.6081-4).
In general, individuals must make quarterly estimated tax
payments by April 15, June 15, September 15, and January 15 of
the following taxable year. Wage withholding is considered to
be a payment of estimated taxes.
Suspension of time periods
In general, present law suspends the period of time for
performing various acts under the Internal Revenue Code, such
as filing tax returns, paying taxes, or filing a claim for
credit or refund of tax, for any individual serving in the
Armed Forces of the United States in an area designated as a
``combat zone'' during the period of combatant activities (sec.
7508). An individual who becomes a prisoner of war is
considered to continue in active service and is therefore also
eligible for these suspension of time provisions. The
suspension of time also applies to an individual serving in
support of such Armed Forces in the combat zone, such as Red
Cross personnel, accredited correspondents, and civilian
personnel acting under the direction of the Armed Forces in
support of those Forces. The designation of a combat zone must
be made by the President in an Executive Order. The President
must also designate the period of combatant activities in the
combat zone (the starting date and the termination date of
combat).
The suspension of time encompasses the period of service in
the combat zone during the period of combatant activities in
the zone, as well as (1) any time of continuous qualified
hospitalization resulting from injury received in the combat
zone \1\ or (2) time in missing in action status, plus the next
180 days.
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\1\ Two special rules apply to continuous hospitalization inside
the United States. First, the suspension of time provisions based on
continuous hospitalization inside the United States are applicable only
to the hospitalized individual; they are not applicable to the spouse
of such individual. Second, in no event do the suspension of time
provisions based on continuous hospitalization inside the United States
extend beyond five years from the date the individual returns to the
United States. These two special rules do not apply to continuous
hospitalization outside the United States.
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The suspension of time applies to the following acts:
(1) Filing any return of income, estate, or gift tax
(except employment and withholding taxes);
(2) Payment of any income, estate, or gift tax
(except employment and withholding taxes);
(3) Filing a petition with the Tax Court for
redetermination of a deficiency, or for review of a
decision rendered by the Tax Court;
(4) Allowance of a credit or refund of any tax;
(5) Filing a claim for credit or refund of any tax;
(6) Bringing suit upon any such claim for credit or
refund;
(7) Assessment of any tax;
(8) Giving or making any notice or demand for the
payment of any tax, or with respect to any liability to
the United States in respect of any tax;
(9) Collection of the amount of any liability in
respect of any tax;
(10) Bringing suit by the United States in respect of
any liability in respect of any tax; and
(11) Any other act required or permitted under the
internal revenue laws specified in regulations
prescribed under section 7508 by the Secretary of the
Treasury.
Individuals may, if they choose, perform any of these acts
during the period of suspension.
Spouses of qualifying individuals are entitled to the same
suspension of time, except that the spouse is ineligible for
this suspension for any taxable year beginning more than two
years after the date of termination of combatant activities in
the combat zone.
Exclusion for combat zone compensation
Gross income does not include certain combat zone
compensation of members of the Armed Forces (sec. 112). If
enlisted personnel serve in a combat zone during any part of
any month, military pay for that month is excluded from gross
income. In addition, if enlisted personnel are hospitalized as
a result of injuries, wounds, or disease incurred in a combat
zone, military pay for that month is also excluded from gross
income; this exclusion is limited, however, to hospitalization
during any part of any month beginning not more than two years
after the end of combat in the zone. In the case of
commissioned officers, these exclusions from income are limited
to the maximum enlisted amount \2\ of military pay.
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\2\ This is defined as the highest rate of basic pay at the highest
pay grade applicable for that month to any enlisted member of the Armed
Forces of the United States, plus, in the case of an officer entitled
to combat pay, the amount of combat pay payable to that officer for
that month. (sec. 112(c)(5)).
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Income tax withholding does not apply to military pay to
the extent that an employee (whether enlisted personnel or
commissioned officer) is entitled to the exclusion from income
for combat pay (sec. 3401(a)(1)).
Exemption from tax upon death in a combat zone
An individual in active service as a member of the Armed
Forces who dies while serving in a combat zone (or as a result
of wounds, disease, or injury received while serving in a
combat zone) is not subject to income tax for the year of death
(as well as for any prior taxable year ending on or after the
first day the individual served in the combat zone) (sec. 692).
Special computational rules apply in the case of joint returns.
A reduction in estate taxes is also provided with respect to
individuals dying under these circumstances (sec. 2201).
Special rules permit the filing of a joint return where a
spouse is in missing status as a result of service in a combat
zone (sec. 6013(f)(1)). Special rules for determining surviving
spouse status apply where the deceased spouse was in missing
status as a result of service in a combat zone (sec. 2(a)(3)).
Exemption from telephone excise tax
The telephone excise tax is not imposed on ``any toll
telephone service'' that originates in a combat zone (sec.
4253(d)).
Operation Desert Storm: Executive Order designating Persian Gulf Area
as a combat zone
On January 21, 1991, President Bush signed Executive Order
12744, designating the Persian Gulf Area as a combat zone. This
designation was retroactive to January 17, 1991, the date
combat commenced in that area, and continues in effect until
terminated by another Executive Order. An Executive Order
terminating this combat zone designation has not been issued.
Thus, individuals serving in the Persian Gulf Area are eligible
for the suspension of time provisions and military pay
exclusions (among other provisions) described above, beginning
on January 17, 1991.
The Executive Order specifies that the Persian Gulf Area is
the Persian Gulf, the Red Sea, the Gulf of Oman, part of the
Arabian Sea, the Gulf of Aden, and the entire land areas of
Iraq, Kuwait, Saudi Arabia, Oman, Bahrain, Qatar, and the
United Arab Emirates.
Operation Desert Shield: Legislative extension of time
On January 30, 1991, President Bush signed Public Law 102-
2. This Act amended section 7508 by providing that any
individual who performs Desert Shield services (and the spouse
of such an individual) is entitled to the benefits of the
suspension of time provisions of section 7508. Desert Shield
services are defined as services in the Armed Forces of the
United States (or in support of those Armed Forces) if such
services are performed in the area designated by the President
as the ``Persian Gulf Desert Shield area'' and such services
are performed during the period beginning August 2, 1990, and
ending on the date on which any portion of the area was
designated by the President as a combat zone pursuant to
section 112 (which was January 17, 1991).
Operation Joint Endeavor: Administrative extension of time
On December 12, 1995, the Internal Revenue Service
announced \3\ that it was administratively extending the time
to file tax returns until December 15, 1996, for members of the
Armed Forces ``departing `Operation Joint Endeavor' '' on or
after March 1, 1996. In addition, the IRS stated that the
penalties for failure to file tax returns and failure to pay
taxes would not be assessed with respect to these individuals.
Also, the IRS stated that it would administratively place any
balance due accounts into suspense status and suspend
examinations while the member is serving in ``Operation Joint
Endeavor.''
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\3\ Letter dated December 12, 1995, from John T. Lyons, Assistant
Commissioner (International), Internal Revenue Service, to Lt. Col.
David M. Pronchick, Armed Forces Tax Counsel, Department of Defense.
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Operation Joint Endeavor and Operation Able Sentry: Legislative
treatment as if a combat zone
Pursuant to Public Law 104-117,\4\ a qualified hazardous
duty area is treated in the same manner as if it were a combat
zone for purposes of the following provisions of the Code:
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\4\ 110 Stat. 827 (March 20, 1996).
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(1) the special rule for determining surviving spouse
status where the deceased spouse was in missing status
as a result of service in a combat zone (sec. 2(a)(3));
(2) the exclusions from income for combat pay (sec.
112);
(3) forgiveness of income taxes of members of the
Armed Forces dying in the combat zone or by reason of
combat-zone incurred wounds (sec. 692);
(4) the reduction in estate taxes for members of the
Armed Forces dying in the combat zone or by reason of
combat-zone incurred wounds (sec. 2201);
(5) the exemption from income tax withholding for
military pay for any month in which an employee is
entitled to the exclusion from income (sec.
3401(a)(1));
(6) the exemption from the telephone excise tax for
toll telephone service that originates in a combat zone
(sec. 4253(d));
(7) the special rule permitting filing of a joint
return where a spouse is in missing status as a result
of service in a combat zone (sec. 6013(f)(1)); and
(8) the suspension of time provisions (sec. 7508).
A qualified hazardous duty area means Bosnia and
Herzegovina, Croatia, or Macedonia, if, as of the date of
enactment, any member of the Armed Forces is entitled to
hostile fire/imminent danger pay for services performed in such
country. Members of the Armed Forces are in Bosnia and
Herzegovina and Croatia as part of ``Operation Joint Endeavor''
(the NATO operation).\5\ Members of the Armed Forces are in
Macedonia as part of ``Operation Able Sentry'' (the United
Nations operation). In addition, persons other than Members of
the Armed Forces who are serving in support of these operations
of the Armed Forces are eligible for the suspension of time
provisions in section 7508 of the Code.\6\ This provision was
effective on November 21, 1995 (the date the Dayton Accord was
initialed).
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\5\ Operation Joint Endeavor has been replaced by Operation Joint
Forge. The IRS has stated that personnel serving under Operation Joint
Forge will be treated the same as personnel under Operation Joint
Endeavor because Joint Forge is ``the substantive continuation'' of
Joint Endeavor. Letter dated July 17, 1998, from Tommy G. DeWeese,
District Director for the International District, Internal Revenue
Service, to LTC Thomas K. Emswiler, Armed Forces Tax Council,
Department of Defense.
\6\ In addition, persons other than Members of the Armed Forces are
eligible for some of the other seven provisions listed above, under
specified circumstances. For example, civilian employees of the United
States are eligible for the forgiveness of income tax provisions of
section 692 if they die as a result of injuries sustained overseas in
specified terroristic or military actions.
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Suspension of time provisions for other Operation Joint Endeavor
personnel
An individual who is performing services as part of
Operation Joint Endeavor outside the United States while
deployed away from the individual's permanent duty station will
qualify for the suspension of time provisions in section 7508
of the Code during the period that hostile fire/imminent danger
pay is paid in Bosnia and Herzegovina, Croatia, or Macedonia.
Announcement of Intention to Issue Executive Order Designating Kosovo
Area of Operations as a Combat Zone
On April 12, 1999, President Clinton announced his
intention to issue an Executive Order designating the Federal
Republic of Yugoslavia (Serbia/Montenegro), Albania, the
Adriatic Sea, and the northern Ionian Sea (including all of
their air spaces) as a combat zone for purposes of the Internal
Revenue Code.
Reasons for Change
The Committee believes that it is appropriate to apply the
special tax rules applicable to combat zones to service in the
Federal Republic of Yugoslavia (Serbia/Montenegro), Albania,
the Adriatic Sea, and the Northern Ionian Sea in the same
manner as if those areas were a combat zone. In addition, the
Committee believes that it is appropriate to provide that
military personnel performing services outside of those areas
but still a part of Operation Allied Force qualify for the
suspension of time provisions in section 7508 of the Code
during the period that hostile fire/imminent danger pay is paid
with respect to those areas, provided that those services are
performed both outside the United States and while deployed
away from that individual's duty station.
Explanation of Provision
The bill contains two elements. First, the bill treats the
Federal Republic of Yugoslavia (Serbia/Montenegro), Albania,
the Adriatic Sea, and the northern Ionian Sea above the 39th
parallel (including all of their air spaces) as a qualified
hazardous duty area. Consequently, military personnel serving
in those areas are entitled to relief under all eight of the
hazardous duty area provisions listed above. Several special
rules apply to civilian personnel. Civilian personnel serving
in those areas in support of the Armed Forces are entitled to
the suspension of time provisions in section 7508 of the Code.
In addition, civilian employees of the United States serving in
those areas are entitled to (a) the special rule for
determining surviving spouse status where the deceased spouse
was in missing status as a result of service in a combat zone
(sec. 2(a)(3)); (b) forgiveness of income taxes of employees
dying in the combat zone or by reason of combat-zone incurred
wounds (sec. 692); and (c) the special rule permitting filing
of a joint return where a spouse is in missing status as a
result of service in a combat zone (sec. 6013(f)(1)).
Second, the bill also provides that military personnel
performing services outside of those areas but still a part of
Operation Allied Force qualify for the suspension of time
provisions in section 7508 of the Code during the period that
hostile fire/imminent danger pay is paid with respect to those
areas, provided that those services are performed both outside
the United States and while deployed away from that
individual's duty station.
Accordingly, the bill provides the same treatment for those
serving in (or in support of) Operation Allied Force as is
provided under present law to those serving in (or in support
of) Operation Joint Endeavor.
Effective Date
The provision is effective on March 24, 1999 (the date on
which Operation Allied Force commenced).
III. VOTE OF THE COMMITTEE
In compliance with clause 3(b) of rule XIII of the Rules of
the House of Representatives, the following statement is made
concerning the vote of the Committee in its consideration of
the bill, H.R. 1376.
The bill, H.R. 1376, was ordered favorably reported by
voice vote on April 13, 1999, with a quorum present.
IV. BUDGET EFFECTS OF THE BILL
A. Committee Estimate of Budgetary Effects
In compliance with clause 3(d)(2) of rule XIII of the Rules
of the House of Representatives, the following statement is
made concerning the effects on the budget of the bill, H.R.
1376, as reported.
The bill is estimated to have the following effects on
budget receipts for fiscal years 1999-2003:
ESTIMATED BUDGET EFFECTS OF H.R. 1376, RELATING TO TAX RELIEF FOR PERSONNEL IN YUGOSLAVIA, ALBANIA, THE ADRIATIC SEA, AND THE NORTHERN IONIAN SEA, AS
APPROVED BY THE COMMITTEE ON WAYS AND MEANS ON APRIL 13, 1999
[Fiscal years 1999-2009, in millions of dollars]
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Provision Effective 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 1999-2004 1999-2009
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1. Designate ``qualified 3/24/99 -22 -47 -23 -16 -10 -5 -1 (\1\) (\1\) (\1\) (\1\) -123 -125
hazardous duty area'' to
include Yugoslavia, Albania,
the Adriatic Sea, and the
Northern Ionian Sea.
2. Provide section 7508 3/24/99 Negligible Revenue Effect
suspensions to certain
military personnel outside
of hazardous duty area.
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Net total.............. ........... -22 -47 -23 -16 -10 -5 -1 (\1\) (\1\) (\1\) (\1\) -123 -125
....
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\1\ Loss of less than $500,000.
Note.--Details may not add to totals due to rounding.
Source: Joint Committee on Taxation.
B. Statement Regarding New Budget Authority and Tax Expenditures
In compliance with clause 3(c)(2) of rule XIII of the Rules
of the House of Representatives, the Committee states that the
bill involves no new or increased budget authority. The bill
involves increased tax expenditures for the income tax benefit
provisions related to combat pay (for amounts, see Part IV.A.,
above).
C. Cost Estimate Prepared by the Congressional Budget Office
In compliance with clause 3(c)(3) of rule XIII of the Rules
of the House of Representatives, requiring a cost estimate
prepared by the Congressional Budget Office (CBO), the
following statement by CBO is provided.
U.S. Congress,
Congressional Budget Office,
Washington, DC, April 13, 1999.
Hon. Bill Archer,
Chairman, Committee on Ways and Means,
House of Representatives, Washington, DC.
Dear Mr. Chairman: The Congressional Budget Office has
prepared the enclosed cost estimate for a bill to extend the
tax benefits available to services performed in a combat zone
to services performed in the Federal Republic of Yugoslavia
(Serbia/Montenegro) and certain other areas, and for other
purposes.
If you wish further details on this estimate, we will be
pleased to provide them. The CBO staff contact is Hester
Grippando.
Sincerely,
Barry B. Anderson
(For Dan L. Crippen, Director).
Enclosure.
H.R. --To extend the tax benefits available to services performed in
a combat zone to services performed in the Federal Republic of
Yugoslavia (Serbia/Montenegro) and certain other areas, and for
other purposes
This bill would provide tax benefits to the members of the
Armed Forces who are receiving special pay while subject to
hostile fire or imminent danger while serving in the Federal
Republic of Yugoslavia, Albania, the Adriatic Sea, or the
northern Ionic Sea. They would receive the same tax benefits
available to services performed in a combat zone. The bill
would also allow those service members outside the United
States who are deployed away from their permanent duty station
as part of Operation Allied Force to delay filing income tax
returns without penalty. The Joint Committee on Taxation (JCT)
has estimated that this bill would reduce governmental receipts
by $22 million in fiscal year 1999, and by $123 million over
the 1999-2009 period. The President currently has the authority
to declare the area designated by this bill a combat zone. If
the President does so before this bill is enacted, the revenue
loss of the bill would be negligible.
JCT has determined that this bill contains no private-
sector or intergovernmental mandates as defined in the Unfunded
Mandates Reform Act (UMRA) and would not affect the budgets of
state, local, or tribal governments.
The Balanced Budget and Emergency Deficit Control Act sets
up pay-as-you-go procedures for legislation affecting direct
spending or receipts. The net changes in governmental receipts
that are subject to pay-as-you-go procedures are shown in the
following table. For the purposes of enforcing pay-as-you-go
procedures, only the effects in the current year, the budget
year, and the succeeding four years are counted.
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By fiscal years, in millions of dollars--
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1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009
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Changes in receipts............................................. -22 -47 -23 -16 -10 -5 -1 0 0 0 0
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This estimate was prepared by Hester Grippando and approved
by G. Thomas Woodward, Assistant Director for Tax Analysis.
V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE
A. Committee Oversight Findings and Recommendations
With respect to clause 3(c)(1) of rule XIII of the Rules of
the House of Representatives (relating to oversight findings),
the Committee advises that it was a result of the Committee's
oversight activities concerning the tax treatment of military
(and support) personnel serving in ``Operation Allied Force''
that the Committee concluded that it is appropriate to enact
the provisions contained in the bill as reported.
B. Summary of Findings and Recommendations of the Committee on
Government Reform
With respect to clause 3(c)(4) of rule XIII of the Rules of
the House of Representatives, the Committee advises that no
oversight findings or recommendations have been submitted to
this Committee by the Committee on Government Reform with
respect to the provisions contained in the bill.
C. Constitutional Authority Statement
With respect to clause 3(d)(1) of rule XIII of the Rules of
the House of Representatives (relating to Constitutional
Authority), the Committee states that the Committee's action in
reporting this bill is derived from Article I of the
Constitution, Section 8 (``The Congress shall have Power To lay
and collect Taxes, Duties, Imposts and Excises * * * ''), and
from the 16th Amendment to the Constitution.
D. Information Relating to Unfunded Mandates
This information is provided in accordance with section 423
of the Unfunded Mandates Act of 1995 (P.L. 104-4).
The Committee has determined that the bill does not involve
any Federal mandate on the private sector nor does it involve
any Federal intergovernmental mandate on State, local, or
tribal governments.
E. Applicability of House Rule XXI5(b)
Rule XXI5(b) of the Rules of the House of Representatives
provides, in part, that ``No bill or joint resolution,
amendment, or conference report carrying a Federal income tax
rate increase shall be considered as passed or agreed to unless
determined by a vote of not less than three-fifths of the
Members.'' The Committee has carefully reviewed the provisions
of the bill, and states that the provisions of the bill do not
involve any Federal income tax rate increase within the meaning
of the rule.
F. Tax Complexity Analysis
Section 4022(b) of the Internal Revenue Service Reform and
Restructuring Act of 1998 (the ``IRS Reform Act'') requires the
Joint Committee on Taxation (in consultation with the Internal
Revenue Service and the Department of the Treasury) to provide
a tax complexity analysis. The complexity analysis is required
for all legislation reported by the Senate Committee on
Finance, the House Committee on Ways and Means, or any
committee of conference if the legislation includes a provision
that directly or indirectly amends the Internal Revenue Code
(the ``Code'') and has widespread applicability to individuals
or small businesses.
The staff of the Joint Committee on Taxation has determined
that a complexity analysis is not required under section
4022(b) of the IRS Reform Act because the bill contains no
provisions that amend the Internal Revenue Code and that have
widespread applicability to individuals or small businesses.