[Congressional Bills 107th Congress]
[From the U.S. Government Publishing Office]
[H.R. 3402 Introduced in House (IH)]







107th CONGRESS
  1st Session
                                H. R. 3402

To provide tax incentives for the recovery of businesses in the City of 
   New York which were impacted by the September 11, 2001, terrorist 
                                attacks.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                            December 4, 2001

  Mr. Rangel (for himself, Mr. Nadler, Mrs. Maloney of New York, Mr. 
  Serrano, Mr. Towns, Mr. Hinchey, Mrs. McCarthy of New York, and Mr. 
   McNulty) introduced the following bill; which was referred to the 
                      Committee on Ways and Means

_______________________________________________________________________

                                 A BILL


 
To provide tax incentives for the recovery of businesses in the City of 
   New York which were impacted by the September 11, 2001, terrorist 
                                attacks.

    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 ``New York Recovery From Terrorism Act 
of 2001''.

SEC. 2. EXPANSION OF WORK OPPORTUNITY TAX CREDIT TARGETED CATEGORIES TO 
              INCLUDE CERTAIN EMPLOYEES IN NEW YORK CITY.

    (a) In General.--For purposes of section 51 of the Internal Revenue 
Code of 1986 (relating to work opportunity credit), a New York Recovery 
Zone business employee shall be treated as a member of a targeted 
group.
    (b) New York Recovery Zone Business Employee.--For purposes of this 
section--
            (1) In general.--The term ``New York Recovery Zone business 
        employee'' means, with respect to the period beginning after 
        September 10, 2001, and ending before January 1, 2005, any 
        employee of a New York Recovery Zone business if--
                    (A) substantially all the services performed during 
                such period by such employee for such business are 
                performed in a trade or business of such business 
                located in an area described in paragraph (2), and
                    (B) with respect to any employee of such business 
                described in paragraph (2)(B), such employee is 
                certified by the New York State Department of Labor as 
                not exceeding, when added to all other employees 
                previously certified with respect to such period as New 
                York Recovery Zone business employees with respect to 
                such business, the number of employees of such business 
                on September 11, 2001, in the New York Recovery Zone.
            (2) New york recovery zone business.--The term ``New York 
        Recovery Zone business'' means any business establishment which 
        is--
                    (A) located in the New York Recovery Zone, or
                    (B) located in the City of New York, New York, 
                outside the New York Recovery Zone, as the result of 
                the destruction or damage of such establishment by the 
                September 11, 2001, terrorist attack.
            (3) New york recovery zone.--The term ``New York Recovery 
        Zone'' means the area located on or south of Canal Street, East 
        Broadway (east of its intersection with Canal Street), or Grand 
        Street (east of its intersection with East Broadway) in the 
        Borough of Manhattan in the City of New York, New York.
            (4) Special rules for determining amount of credit.--For 
        purposes of applying subpart E of part IV of subchapter B of 
        chapter 1 of the Internal Revenue Code of 1986 to wages paid or 
        incurred to any New York Recovery Zone business employee--
                    (A) section 51(a) of such Code shall be applied by 
                substituting ``qualified wages'' for ``qualified first-
                year wages'',
                    (B) section 51(d)(12)(A)(i) of such Code shall be 
                applied to the certification of individuals employed by 
                a New York Recovery Zone business before April 1, 2002, 
                by substituting ``on or before May 1, 2002'' for ``on 
                or before the day on which such individual begins work 
                for the employer'',
                    (C) subsections (c)(4) and (i)(2) of section 51 of 
                such Code shall not apply, and
                    (D) in determining qualified wages, the following 
                shall apply in lieu of section 51(b) of such Code:
                            (i) Qualified wages.--The term ``qualified 
                        wages'' means the wages paid or incurred by the 
                        employer for work performed during the period 
                        beginning on September 11, 2001, and ending on 
                        December 31, 2004, to individuals who are New 
                        York Recovery Zone business employees of such 
                        employer.
                            (ii) Only first $6,000 of wages per taxable 
                        year taken into account.--The amount of the 
                        qualified wages which may be taken into account 
                        with respect to any individual shall not exceed 
                        $6,000 per taxable year of the employer.
    (c) Credit Allowed Against Regular and Minimum Tax.--
            (1) In general.--Subsection (c) of section 38 of the 
        Internal Revenue Code of 1986 (relating to limitation based on 
        amount of tax) is amended by redesignating paragraph (3) as 
        paragraph (4) and by inserting after paragraph (2) the 
        following new paragraph:
            ``(3) Special rules for new york recovery zone business 
        employee credit.--
                    ``(A) In general.--In the case of the New York 
                Recovery Zone business employee credit--
                            ``(i) this section and section 39 shall be 
                        applied separately with respect to such credit, 
                        and
                            ``(ii) in applying paragraph (1) to such 
                        credit--
                                    ``(I) the tentative minimum tax 
                                shall be treated as being zero, and
                                    ``(II) the limitation under 
                                paragraph (1) (as modified by subclause 
                                (I)) shall be reduced by the credit 
                                allowed under subsection (a) for the 
                                taxable year (other than the New York 
                                Recovery Zone business employee 
                                credit).
                    ``(B) New york recovery zone business employee 
                credit.--For purposes of this subsection, the term `New 
                York Recovery Zone business employee credit' means the 
                portion of work opportunity credit under section 51 
                determined under section 2 of the New York Recovery 
                From Terrorism Act of 2001.''.
            (2) Conforming amendment.--Subclause (II) of section 
        38(c)(2)(A)(ii) of such Code is amended by inserting ``or the 
        New York Recovery Zone business employee credit'' after 
        ``employment credit''.
            (3) Effective date.--The amendments made by this subsection 
        shall apply to taxable years ending after September 11, 2001.

SEC. 3. TAX-EXEMPT PRIVATE ACTIVITY BONDS FOR REBUILDING PORTION OF NEW 
              YORK CITY DAMAGED IN THE SEPTEMBER 11, 2001, TERRORIST 
              ATTACK.

    (a) Treatment as Qualified Bonds.--For purposes of the Internal 
Revenue Code of 1986, any qualified NYC recovery bond shall be treated 
as an exempt facility bond under section 141(e) of such Code.
    (b) Qualified NYC Recovery Bond.--For purposes of this section, the 
term ``qualified NYC recovery bond'' means any bond which--
            (1) is issued by the State of New York or any political 
        subdivision thereof (or any agency, instrumentality or 
        constituted authority on behalf thereof), and
            (2) meets the requirements of subsections (c) through (f).
    (c) Designation Requirements.--A bond meets the requirements of 
this subsection if it is issued as part of an issue designated as a 
qualified NYC recovery bond by the Mayor of the City of New York, New 
York, or an individual specifically appointed to make such designation.
    (d) Issuance and Volume Requirements.--
            (1) In general.--Except as provided in paragraph (3), a 
        bond issued as part of an issue meets the requirements of this 
        subsection if such bond is issued during 2002 (or during the 
        period elected under paragraph (2)) and the aggregate face 
        amount of the bonds issued pursuant to such issue, when added 
        to the aggregate face amount of qualified NYC recovery bonds 
        previously issued, does not exceed $12,500,000,000.
            (2) Elective carryforward of unused limitation.--If the 
        volume cap under paragraph (1) exceeds the aggregate amount of 
        qualified NYC recovery bonds issued during 2002, the issuing 
        authority under subsection (b) may elect to carry forward such 
        excess volume cap for an additional 3-year period under rules 
        similar to the rules of section 146(f) of the Internal Revenue 
        Code of 1986 (other than paragraph (2) thereof).
            (3) Certain current refundings not counted.--For purposes 
        of paragraph (1), there shall not be taken into account any 
        current refunding bond the proceeds of which are used to refund 
        any bond described in paragraph (1) to the extent the face 
        amount of such current refunding bond does not exceed the 
        outstanding face amount of the refunded bond.
    (e) Qualified Project Requirements.--
            (1) In general.--A bond meets the requirements of this 
        subsection if it is issued as part of an issue at least 95 
        percent of the net proceeds of which are to be used for 
        qualified project costs.
            (2) Qualified project costs.--For purposes of this 
        subsection--
                    (A) In general.--The term ``qualified project 
                costs'' means--
                            (i) with respect to a qualified project 
                        described in paragraph (3)(A)(i), the costs of 
                        acquisition, construction, reconstruction, and 
                        renovation of commercial real property and 
                        residential rental real property, including--
                                    (I) buildings and their structural 
                                components,
                                    (II) fixed tenant improvements, and
                                    (III) public utility property, and
                            (ii) with respect to a qualified project 
                        described in paragraph (3)(A)(ii), the costs of 
                        acquisition, construction, reconstruction, and 
                        renovation of commercial real property, 
                        including--
                                    (I) buildings and their structural 
                                components, and
                                    (II) fixed tenant improvements.
                    (B) Limitations.--
                            (i) Residential rental real property.--Such 
                        term shall not include costs with respect to 
                        residential rental real property to the extent 
                        such costs for all such property exceed 20 
                        percent of the aggregate face amount of the 
                        bonds issued under this section.
                            (ii) Retail sales property.--Such term 
                        shall not include costs with respect to 
                        property used for retail sales of tangible 
                        property and functionally related and 
                        subordinate property to the extent such costs 
                        for all such property exceeds 10 percent of the 
                        aggregate face amount of the bonds issued under 
                        this section.
                            (iii) Movable fixtures and equipment.--Such 
                        term shall not include costs with respect to 
                        movable fixtures and equipment.
            (3) Qualified projects.--For purposes of this subsection--
                    (A) In general.--The term ``qualified project'' 
                means any project--
                            (i) located within the New York Recovery 
                        Zone, or
                            (ii) located within the City of New York, 
                        New York, but outside of the New York Recovery 
                        Zone, but only if--
                                    (I) such project consists of at 
                                least 100,000 square feet of usable 
                                office or other commercial space 
                                located in a single building or 
                                multiple adjacent buildings, and
                                    (II) the aggregate face amount of 
                                the bonds issued to finance such 
                                project, when added to the aggregate 
                                face amount of all bonds issued to 
                                finance all other projects described in 
                                this clause, does not exceed 
                                $7,000,000,000.
                    (B) New york recovery zone.--The term ``New York 
                Recovery Zone'' means the area located on or south of 
                Canal Street, East Broadway (east of its intersection 
                with Canal Street), or Grand Street (east of its 
                intersection with East Broadway) in the Borough of 
                Manhattan in the City of New York, New York.
    (f) General Requirements.--A bond meets the requirements of this 
subsection if it is issued as part of an issue which meets the 
requirements of part IV of subchapter B of chapter 1 of the Internal 
Revenue Code of 1986 applicable to an exempt facility bond, except as 
follows:
            (1) Sections 142(d) and 150(b)(2) (relating to qualified 
        residential rental project), and section 146 (relating to 
        volume cap) of such Code shall not apply to bonds issued under 
        this section.
            (2) The application of section 147(c) of such Code 
        (relating to limitation on use for land acquisition) shall be 
        determined by reference to the aggregate authorized face amount 
        of all bonds issued under this section rather than the net 
        proceeds of each issue.
            (3) Section 147(d) of such Code (relating to acquisition of 
        existing property not permitted) shall be applied by 
        substituting ``50 percent'' for ``15 percent'' each place it 
        appears.
            (4) Section 148(f)(4)(C) of such Code (relating to 
        exception from rebate for certain proceeds to be used to 
        finance construction expenditures) shall apply to construction 
        proceeds of bonds issued under this section.
            (5) Rules similar to the rules of section 143(a)(2)(A)(iv) 
        of such Code (relating to use of loan repayments) shall apply 
        to bonds issued under this section.
    (g) Bond Interest not an AMT Preference Item.--For purposes of 
section 57(a)(5) of the Internal Revenue Code of 1986, a qualified NYC 
recovery bond shall not be treated as a specified private activity 
bond.
    (h) Separate Issue Treatment of Portions of an Issue.--This section 
shall not apply to the portion of the proceeds of an issue which (if 
issued as a separate issue) would be treated as a qualified bond or as 
a bond that is not a private activity bond (determined without regard 
to subsection (a)), if the issuer elects to so treat such portion.
    (i) Net Proceeds.--For purposes of this section, the term ``net 
proceeds'' has the meaning given such term by section 150(a)(3) of the 
Internal Revenue Code of 1986.
    (j) Interest on Debt Used To Purchase or Carry Qualified NYC 
Recovery Bonds.--
            (1) In general.--Clause (i) of section 265(b)(3)(A) of such 
        Act (relating to exception for certain tax-exempt obligations) 
        of such Code is amended by adding at the end the following new 
        flush sentence:
                        ``Such term includes a tax-exempt obligation 
                        issued pursuant to section 3 of the New York 
                        Recovery From Terrorism Act of 2001.''
            (2) Refundings.--Subparagraph (D) of section 265(b)(3) of 
        such Code is by adding at the end the following new clause:
                            ``(iv) Refundings of certain obligations.--
                        In the case of a refunding (or a series of 
                        refundings) of a qualified tax-exempt 
                        obligation that is an obligation issued 
                        pursuant to section 3 of the New York Recovery 
                        From Terrorism Act of 2001, the refunding 
                        obligation shall be treated as a qualified tax-
                        exempt obligation if the refunding obligation 
                        meets the requirements of such section.''.
            (2) Effective date.--The amendments made by this subsection 
        shall apply to taxable years ending on or after the date of the 
        enactment of this Act.

SEC. 4. ADDITIONAL ADVANCE REFUNDING PERMITTED OF CERTAIN BONDS.

    Paragraph (3) of section 149(d) of the Internal Revenue Code of 
1986 shall not apply to the first advance refunding after the date of 
the enactment of this Act of any issue if--
            (1) the original bond was issued by--
                    (A) the City of New York,
                    (B) the Port Authority of New York and New Jersey,
                    (C) the Metropolitan Transit Authority of the City 
                of New York,
                    (D) the New York City Municipal Water Authority, or
                    (E) any hospital which is located in the City of 
                New York, described in section 501(c)(3) of such Code, 
                and exempt from tax under section 501(a) of such Code,
            (2) no bond (issued as part of the refunding issue) is 
        issued to advance refund a private activity bond (other than a 
        qualified hospital bond which is a qualified 501(c)(3) bond, as 
        such terms are defined in section 145 of such Code), and
            (3) other than the bonds being refunded by such refunding 
        issue, the original bonds and all prior refundings of such 
bonds have been redeemed as of the date of the enactment of this Act.
The preceding sentence shall apply only if the refunding bonds meet the 
requirements of clauses (iii), (iv), and (v) of section 149(d)(3)(A) of 
such Code.

SEC. 5. GAIN OR LOSS FROM PROPERTY DAMAGED OR DESTROYED IN NEW YORK 
              RECOVERY ZONE.

    (a) General Rule.--For purposes of the Internal Revenue Code of 
1986, if a taxpayer elects the application of this section with respect 
to any eligible property, then any gain or loss on the disposition of 
the property shall be determined without regard to any compensation (by 
insurance or otherwise) received by the taxpayer for damages sustained 
to the property as a result of the terrorist attacks occurring on 
September 11, 2001. Such election shall be made at such time and in 
such manner as the Secretary of the Treasury may prescribe, and, once 
made, is irrevocable.
    (b) Limitation Based on Purchase of Replacement Property.--
            (1) In general.--Subsection (a) shall apply to compensation 
        received with respect to eligible property only to the extent 
        of the cost of any qualified replacement property purchased by 
        the taxpayer.
            (2) Allocation.--If the aggregate compensation received by 
        a taxpayer with respect to all eligible property exceeds the 
        aggregate cost of all qualified replacement property purchased 
        by the taxpayer, such cost shall be allocated to such eligible 
        property in accordance with rules prescribed by the Secretary.
            (3) Special rule for consolidated groups.--For purposes of 
        paragraph (1), an affiliated group filing a consolidated return 
        may elect to treat any qualified replacement property purchased 
        by a member of the group as purchased by another member of the 
        group.
    (c) Eligible Property.--For purposes of this section, the term 
``eligible property'' means any tangible property--
            (1) which is section 1245 property (as defined in section 
        1245(a)(3) of the Internal Revenue Code of 1986) or qualified 
        leasehold improvement property (as defined in section 168(k)(3) 
        of such Code),
            (2) substantially all of the use of which as of September 
        11, 2001, was in a business establishment of the taxpayer 
        located in the New York Recovery Zone, and
            (3) which was damaged or destroyed in the terrorist attacks 
        of September 11, 2001.
    (d) Qualified Replacement Property.--For purposes of this section--
            (1) In general.--The term ``qualified replacement 
        property'' means tangible property--
                    (A) which is described in subsection (c)(1),
                    (B) which is purchased by the taxpayer on or after 
                September 11, 2001, and placed in service in the City 
                of New York, New York, before January 1, 2007,
                    (C) the original use of which in such city begins 
                with the taxpayer, and
                    (D) substantially all of the use of which is 
                reasonably expected to be in connection with a business 
                establishment of the taxpayer located in such city.
            (2) Recapture.--The Secretary shall, by regulations, 
        provide for the recapture of any Federal tax benefit provided 
        by this section in cases where a taxpayer ceases to use 
        property as qualified replacement property and such recapture 
        is necessary to prevent the avoidance of the purposes of this 
        section.
    (e) Coordination With Other Provisions of Code.--For purposes of 
the Internal Revenue Code of 1986--
            (1) Special rule for treatment of unrecognized gain in 
        eligible property.--Sections 1245 and 1250 of such Code shall 
        not apply to any gain on the disposition of eligible property 
        not recognized by reason of this section.
            (2) Loss election not to apply to eligible property.--If a 
        taxpayer elects the application of this section with respect to 
        any eligible property, the taxpayer may not make an election 
        under section 165(i) of such Code with respect to any loss 
        attributable to the property.
            (3) Basis adjustments of qualified replacement property.--
                    (A) In general.--The basis of any qualified 
                replacement property shall be reduced by the amount of 
                any compensation disregarded by reason of subsection 
                (a).
                    (B) Special rules for recapture.--For purposes of 
                sections 1245 and 1250 of such Code, any reduction 
                under subparagraph (A) shall be treated as a deduction 
                allowed for depreciation, except that for purposes of 
                section 1250(b) of such Code, the determination of what 
                would have been the depreciation adjustments under the 
                straight line method shall be made as if there had been 
                no reduction under subparagraph (A).
            (4) Special rules for applying section 1033.--For purposes 
        of applying section 1033 of such Code to converted property 
        which is eligible property with respect to which an election 
        under subsection (a) has been made--
                    (A) the amount realized from the eligible property 
                shall not include any compensation received by the 
                taxpayer which is disregarded by reason of subsection 
                (a), and
                    (B) any qualified replacement property shall be 
                disregarded in determining whether property was 
                acquired for the purposes of replacing the converted 
                property.
    (f) Other Definitions and Rules.--For purposes of this section--
            (1) New york recovery zone.--The term ``New York Recovery 
        Zone'' means the area located on or south of Canal Street, East 
        Broadway (east of its intersection with Canal Street), or Grand 
        Street (east of its intersection with East Broadway) in 
the Borough of Manhattan in the City of New York, New York.
            (2) Time for assessment.--Rules similar to the rules of 
        subparagraphs (C) and (D) of section 1033(a)(2) of such Code 
        shall apply for purposes of this section.
            (3) Related party limitation.--Section 1033(i) of such Code 
        shall apply for purposes of this section.

SEC. 6. CREDIT FOR INDIVIDUALS RESIDING IN LOWER MANHATTAN.

    (a) In General.--Subpart A of part IV of subchapter A of chapter 1 
of the Internal Revenue Code of 1986 (relating to nonrefundable 
personal credits) is amended by inserting after section 25B the 
following:

``SEC. 25C. CREDIT FOR RESIDENTS OF LOWER MANHATTAN.

    ``(a) Allowance of Credit.--In the case of an individual who is a 
qualified resident with respect to the taxable year, there shall be 
allowed as a credit against the tax imposed by this chapter for the 
taxable year an amount equal to $5,000.
    ``(b) Limitations.--
            ``(1) Limitation based on adjusted gross income.--
                    ``(A) In general.--The amount of the credit allowed 
                under subsection (a) shall be reduced (but not below 
                zero) by $50 for each $1,000 (or fraction thereof) by 
                which the taxpayer's modified adjusted gross income 
                exceeds $150,000.
                    ``(B) Modified adjusted gross income.--For purposes 
                of subparagraph (A), the term `modified adjusted gross 
                income' means adjusted gross income determined without 
                regard to sections 911, 931, or 933.
            ``(2) Maximum credit per residence and per qualified 
        resident.--
                    ``(A) Per residence.--As provided by the Secretary, 
                the credit under subsection (a) shall not be allowed 
                with respect to more than 1 individual with respect to 
                a principal residence for the taxable year.
                    ``(B) Per qualified resident.--The aggregate credit 
                allowed under subsection (a) with respect to any 
                individual for all taxable years shall not exceed 
                $5,000 and no such credit shall be allowed for a 
                taxable year if the credit was so allowed for a 
                preceding taxable year.
    ``(c) Qualified Resident.--For purposes of this section--
            ``(1) In general.--The term `qualified resident' means an 
        individual who--
                    ``(A) maintains a principal residence--
                            ``(i) which is located on or south of Canal 
                        Street, East Broadway (east of its intersection 
                        with Canal Street), or Grand Street (east of 
                        its intersection with East Broadway) in the 
                        Borough of Manhattan in the City of New York, 
                        New York, and
                            ``(ii) for at least 6 consecutive months 
                        during calendar year 2002 or 2003,
                    ``(B) makes more than half of the aggregate rental, 
                mortgage, or any similar payment with respect to the 
                residence during the period described in subparagraph 
                (A)(ii), and
                    ``(C) is certified under paragraph (5).
            ``(2) Multiple residents agreement.--For purposes of 
        paragraph (1)(B), an individual shall be treated as making more 
        than half of the aggregate rental, mortgage, or similar 
        payments for the period with respect to the residence if--
                    ``(A) no one person with respect to the period 
                makes over half of such payments,
                    ``(B) over half of such aggregate payments are made 
                by persons each of whom, but for the fact that such 
                person did not make over half of such payments, would 
                have been a qualified resident with respect to the 
                residence,
                    ``(C) the taxpayer contributed over 10 percent of 
                such payments, and
                    ``(D) each person described in subparagraph (B) 
                (other than the taxpayer) who contributed over 10 
                percent of such payments files a written declaration 
                (in such manner and form as the Secretary may 
                prescribe) that such person will not claim a credit 
                with respect to such residence.
            ``(3) Principal residence.--The term `principal residence' 
        has the same meaning as when used in section 121, except that 
        no ownership requirement shall be imposed.
            ``(4) Year credit allowed.--The credit allowed under 
        subsection (a) shall be allowed for the taxable year in which 
        the period described in paragraph (1)(A)(ii) ends.
            ``(5) Certification.--For purposes of paragraph (1)(C), the 
        appropriate State or local authority shall--
                    ``(A) certify whether an individual, requesting 
                such certification, meets the requirements of 
                subparagraphs (A) and (B) of paragraph (1),
                    ``(B) issue a certification to such individual 
                meeting such requirements which--
                            ``(i) contains a written statement showing 
                        the name and address of the person making such 
                        certification and the phone number of the 
                        information contact for such person, and
                            ``(ii) is furnished on or before March 1 of 
                        the year following the calendar year in which 
                        the credit under subsection (a) is allowed, and
                            ``(C) not certify more than 32,000 
                        individuals in any calendar year as being 
                        qualified residents for purposes of this 
                        section.
    ``(d) Verification.--No credit shall be allowed under subsection 
(a) to a taxpayer unless the taxpayer includes, on the return of tax 
for the taxable year--
            ``(1) proof of the certification received under subsection 
        (c)(5), and
            ``(2) such other information as the Secretary determines 
        necessary.
    ``(e) Information Reporting.--
            ``(1) In general.--Any State or local authority which 
        issues the certification required under subsection (c)(5) shall 
        make the return described in paragraph (2) (at such time as the 
        Secretary may prescribe) with respect to each individual to 
        whom such certification is provided.
            ``(2) Form and manner of returns.--A return is described in 
        this subsection if such return--
                    ``(A) is in such form as the Secretary may 
                prescribe, and
                    ``(B) contains--
                            ``(i) the name, address, and TIN of the 
                        individual to whom such certification is 
                        provided, and
                            ``(ii) such other information as the 
                        Secretary may reasonably prescribe.''.
    (b) Conforming Amendment.--The table of sections for subpart A of 
part IV of subchapter A of chapter 1 of such Code is amended by 
inserting after the item relating to section 25B the following:

                              ``Sec. 25C. Credit for residents of lower 
                                        Manhattan.''.
    (c) Effective Date.--The amendments made by this section shall 
apply to taxable years beginning after the date of the enactment of 
this Act.
                                 <all>