[Congressional Bills 105th Congress]
[From the U.S. Government Publishing Office]
[S. 2535 Introduced in Senate (IS)]







105th CONGRESS
  2d Session
                                S. 2535

  To prohibit the Secretary of the Treasury from issuing regulations 
                   dealing with hybrid transactions.


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                   IN THE SENATE OF THE UNITED STATES

            October 1 (legislative day, September 29), 1998

 Mr. Breaux (for himself and Mr. Mack) introduced the following bill; 
     which was read twice and referred to the Committee on Finance

_______________________________________________________________________

                                 A BILL


 
  To prohibit the Secretary of the Treasury from issuing regulations 
                   dealing with hybrid transactions.

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

SECTION 1. HYBRID TRANSACTIONS UNDER SUBPART F.

    (a) Prohibition on Regulations.--The Secretary of the Treasury (or 
his delegate)--
            (1) shall not issue temporary or final regulations relating 
        to the treatment of hybrid transactions under subpart F of part 
        III of subchapter N of chapter 1 of the Internal Revenue Code 
        of 1986 pursuant to Internal Revenue Service Notice 98-35 or 
        any other regulations reaching the same or similar result as 
        such notice,
            (2) shall retroactively withdraw any regulations described 
        in paragraph (1) which were issued after the date of such 
        notice and before the date of the enactment of this Act, and
            (3) shall not modify or withdraw sections 301.7701-1 
        through 301.7701-3 of the Treasury Regulations (relating to the 
        classification of certain business entities) in a manner which 
        alters the treatment of hybrid transactions under such subpart 
        F.
    (b) Study and Report.--The Secretary of the Treasury (or his 
delegate) shall study the tax treatment of hybrid transactions under 
such subpart F and submit a report to the Committee on Ways and Means 
of the House of Representatives and the Committee on Finance of the 
Senate. The Secretary shall hold at least one public hearing to receive 
comments from any interested party prior to submitting such report.
                                 <all>