[Congressional Bills 105th Congress]
[From the U.S. Government Publishing Office]
[S. 724 Introduced in Senate (IS)]







105th CONGRESS
  1st Session
                                 S. 724

    To amend the Internal Revenue Code of 1986 to provide corporate 
                    alternative minimum tax reform.


_______________________________________________________________________


                   IN THE SENATE OF THE UNITED STATES

                              May 8, 1997

 Mr. Nickles (for himself, Mr. Rockefeller, Mr. Lott, Mr. Breaux, Mr. 
 Hatch, Ms. Moseley-Braun, Mr. Murkowski, Mr. D'Amato, Mr. Gramm, Mr. 
  Mack, Mr. Lieberman, Mr. Cochran, Mr. Brownback, Mr. Enzi, and Mr. 
  Hutchinson) 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 to provide corporate 
                    alternative minimum tax reform.

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

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Alternative Minimum Tax Reform Act 
of 1997''.

SEC. 2. MODIFICATION OF DEPRECIATION RULES UNDER MINIMUM TAX.

    (a) In General.--Clause (i) of section 56(a)(1)(A) of the Internal 
Revenue Code of 1986 is amended by inserting ``and before January 1, 
1997,'' after ``December 31, 1986,''.
    (b) Conforming Amendment.--Clause (ii) of section 56(a)(1)(A) of 
such Code is amended by striking ``The method'' and inserting ``In the 
case of property placed in service before January 1, 1997, the 
method''.
    (c) Effective Date.--The amendments made by this section shall 
apply to taxable years ending after December 31, 1996.

SEC. 3. LONG-TERM UNUSED CREDITS ALLOWED AGAINST MINIMUM TAX.

    (a) In General.--Section 53(c) of the Internal Revenue Code of 1986 
(relating to limitation) is amended by adding at the end the following 
new paragraph:
            ``(2) Special rule for taxpayers with long-term unused 
        credits.--
                    ``(A) In general.--If--
                            ``(i) a corporation to which section 56(g) 
                        applies has a long-term unused minimum tax 
                        credit for a taxable year, and
                            ``(ii) no credit would be allowable under 
                        this section for the taxable year by reason of 
                        paragraph (1),
                then there shall be allowed a credit under subsection 
                (a) for the taxable year in the amount determined under 
                subparagraph (B).
                    ``(B) Amount of credit.--For purposes of 
                subparagraph (A), the amount of the credit shall be 
                equal to the least of the following for the taxable 
                year:
                            ``(i) The long-term unused minimum tax 
                        credit.
                            ``(ii) 50 percent of the taxpayer's 
                        tentative minimum tax.
                            ``(iii) The excess (if any) of the amount 
                        under paragraph (1)(B) over the amount under 
                        paragraph (1)(A).
                    ``(C) Long-term unused minimum tax credit.--For 
                purposes of this paragraph--
                            ``(i) In general.--The long-term unused 
                        minimum tax credit for any taxable year is the 
                        portion of the minimum tax credit determined 
                        under subsection (b) attributable to the 
                        adjusted net minimum tax for taxable years 
                        beginning after 1986 and ending before the 5th 
                        taxable year immediately preceding the taxable 
                        year for which the determination is being made.
                            ``(ii) First-in, first-out ordering rule.--
                        For purposes of clause (i), credits shall be 
                        treated as allowed under subsection (a) on a 
                        first-in, first-out basis.''
    (b) Conforming Amendments.--(1) Section 53(c) of such Code (as in 
effect before the amendment made by subsection (a)) is amended--
            (A) by striking ``The'' and inserting:
                    ``(1) In general.--The'', and
            (B) by redesignating paragraphs (1) and (2) as 
        subparagraphs (A) and (B), respectively.
    (2) Subparagraph (C) of section 108(b)(4) of such Code is amended 
by striking ``and (G)'' in the text and heading and inserting ``, (C), 
and (G)''.
    (c) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after December 31, 1996.
                                 <all>