[Congressional Bills 103th Congress]
[From the U.S. Government Publishing Office]
[S. 2415 Introduced in Senate (IS)]

103d CONGRESS
  2d Session
                                S. 2415

To amend the Internal Revenue Code of 1986 relating to the treatment of 
   partnership investment expenses under the alternative minimum tax.


_______________________________________________________________________


                   IN THE SENATE OF THE UNITED STATES

              August 23 (legislative day, August 18), 1994

  Mr. Dodd (for himself, Mr. Hatch, Mr. Bumpers, Mr. Boren, and Mrs. 
Boxer) introduced the following bill; which was read twice and referred 
                      to the Committee on Finance

_______________________________________________________________________

                                 A BILL


 
To amend the Internal Revenue Code of 1986 relating to the treatment of 
   partnership investment expenses under the alternative minimum tax.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. TREATMENT OF PARTNERSHIP INVESTMENT EXPENSES UNDER MINIMUM 
              TAX.

    (a) General Rule.--Subparagraph (A) of section 56(b)(1) of the 
Internal Revenue Code of 1986 (relating to limitation on deductions) is 
amended to read as follows:
                    ``(A) Disallowance of certain deductions.--
                            ``(i) In general.--No deduction shall be 
                        allowed--
                                    ``(I) for any miscellaneous 
                                itemized deduction (as defined in 
                                section 67(b)), or
                                    ``(II) for any taxes described in 
                                paragraph (1), (2), or (3) of section 
                                164(a).
                            ``(ii) Treatment of partnership investment 
                        expenses.--Subclause (I) of clause (i) shall 
                        not apply to the taxpayer's distributive share 
                        of the expenses described in section 212 of any 
                        partnership; except that the aggregate amount 
                        allowed as a deduction by reason of this 
                        sentence shall not exceed the lesser of (I) the 
                        aggregate adjusted investment income of the 
                        taxpayer from partnerships, or (II) the excess 
                        of the aggregate of the taxpayer's distributive 
                        shares of such expenses over 2 percent of 
                        adjusted gross income. For purposes of the 
                        preceding sentence, the term `adjusted 
                        investment income' means investment income (as 
                        defined in section 163(d)(4)(B) without regard 
                        to subclause (II) of clause (ii) or clause 
                        (iii)) reduced by investment interest (as 
                        defined in section 163(d)(3)).
                            ``(iii) Treatment of certain taxes.--
                        Subclause (II) of clause (i) shall not apply to 
                        any amount allowable in computing adjusted 
                        gross income.''
    (b) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 1993.
                                 <all>