[Congressional Bills 106th Congress]
[From the U.S. Government Publishing Office]
[S. 1299 Introduced in Senate (IS)]







106th CONGRESS
  1st Session
                                S. 1299

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


_______________________________________________________________________


                   IN THE SENATE OF THE UNITED STATES

                             June 29, 1999

Mr. Rockefeller (for himself, Mr. Nickles, Mr. Robb, Mr. Hatch, and Mr. 
Mack) 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 1999''.

SEC. 2. LONG-TERM UNUSED CREDITS ALLOWED AGAINST MINIMUM TAX.

    (a) In General.--Subsection (c) of section 53 of the Internal 
Revenue Code of 1986 (relating to limitation) is amended by adding at 
the end the following:
            ``(2) Special rule for corporations with long-term unused 
        credits.--
                    ``(A) In general.--If a corporation to which 
                section 56(g) applies has a long-term unused minimum 
                tax credit for a taxable year, the credit allowable 
                under subsection (a) for the taxable year shall not 
                exceed the greater of--
                            ``(i) the limitation determined under 
                        paragraph (1) for the taxable year, or
                            ``(ii) the least of the following for the 
                        taxable year:
                                    ``(I) The sum of the tax imposed by 
                                section 55 and the regular tax reduced 
                                by the sum of the credits allowed under 
                                subparts A, B, D, E, and F of this 
                                part.
                                    ``(II) The long-term unused minimum 
                                tax credit.
                                    ``(III) The sum of--
                                            ``(aa) the excess (if any) 
                                        of the amount under paragraph 
                                        (1)(A) over the amount under 
                                        paragraph (1)(B), plus
                                            ``(bb) 50 percent of the 
                                        tentative minimum tax 
                                        (determined under section 
                                        55(b)(1)(B)).
                    ``(B) 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 3rd 
                        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.--Section 53(c) of such Code is amended--
            (1) by striking ``The'' and inserting the following:
            ``(1) In general.--The''; and
            (2) by redesignating paragraphs (1) and (2) as 
        subparagraphs (A) and (B), respectively.

SEC. 3. 10-YEAR CARRYBACK OF CERTAIN NET OPERATING LOSSES.

    Section 56(d) of the Internal Revenue Code of 1986 (relating to 
definition of alternative tax net operating loss deduction) is amended 
by adding at the end the following:
            ``(3) Special rule.--In the case of a corporation to which 
        section 56(g) applies which has a net operating loss under this 
        part for 3 or more consecutive taxable years which includes a 
        taxable year beginning after the date of enactment of this 
        paragraph, the loss for each such year shall be a net operating 
        loss carryback for purposes of this part to each of the 10 
        years preceding the taxable year of such loss.''.

SEC. 4. EFFECTIVE DATE.

    The amendments made by this Act shall apply to taxable years 
beginning after December 31, 1998.
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