[Analytical Perspectives]
[Federal Receipts and Collections]
[3. Federal Receipts]
[From the U.S. Government Printing Office, www.gpo.gov]


                                     

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                    FEDERAL RECEIPTS AND COLLECTIONS

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[[Page 35]]
 
                          3.  FEDERAL RECEIPTS

  Receipts (budget and off-budget) are taxes and other collections from 
the public that result from the exercise of the Government's sovereign 
or governmental powers. The difference between receipts and outlays 
determines the surplus or deficit.

  Growth in receipts.--Total receipts in 1997 are estimated to be 
$1,495.2 billion, an increase of $68.5 billion or 4.8 percent relative 
to 1996. This increase is largely due to assumed increases in incomes 
resulting from both real economic growth and inflation. Receipts are 
projected to grow at an average annual rate of 5.0 percent between 1997 
and 2002, rising to $1912.2 billion.
  As a share of GDP, receipts are projected to remain fairly constant, 
declining from 19.0 percent in 1996 to 18.9 percent in 2002.
                                     

                                                         Table 3-1.  RECEIPTS BY SOURCE--SUMMARY                                                        
                                                                (In billions of dollars)                                                                
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                                                                                                    Estimate                                            
                 Source                    1995 actual -------------------------------------------------------------------------------------------------
                                                            1996          1997          1998          1999          2000          2001          2002    
--------------------------------------------------------------------------------------------------------------------------------------------------------
Individual income taxes.................      590.2         630.9         645.1         683.4         714.2         748.7         790.0         834.5   
Corporation income taxes................      157.0         167.1         185.0         201.7         212.7         225.4         236.7         245.8   
Social insurance taxes and contributions      484.5         507.5         536.2         560.9         589.4         618.8         647.0         679.5   
  (On-budget)...........................     (133.4)       (140.1)       (148.2)       (154.6)       (161.6)       (168.8)       (175.8)       (184.8)  
  (Off-budget)..........................     (351.1)       (367.4)       (388.0)       (406.3)       (427.8)       (450.0)       (471.2)       (494.6)  
Excise taxes............................       57.5          53.9          59.6          60.4          61.7          62.8          64.2          65.6   
Estate and gift taxes...................       14.8          15.9          17.1          18.1          19.5          20.9          22.5          24.1   
Customs duties..........................       19.3          19.3          20.5          20.8          20.9          21.9          22.4          24.3   
Miscellaneous receipts..................       31.9          32.1          31.8          32.7          34.2          35.3          37.1          38.4   
                                         ---------------------------------------------------------------------------------------------------------------
  Total receipts........................    1,355.2       1,426.8       1,495.2       1,577.9       1,652.5       1,733.8       1,819.8       1,912.2   
    (On-budget).........................   (1,004.1)     (1,059.3)     (1,107.2)     (1,171.6)    ( 1,224.8)     (1,283.9)     (1,348.6)     (1,417.6)  
    (Off-budget)........................     (351.1)       (367.4)      ( 388.0)       (406.3)       (427.8)       (450.0)       (471.2)       (494.6)  
--------------------------------------------------------------------------------------------------------------------------------------------------------

                                     

                                         Table 3-2.  CHANGES IN RECEIPTS                                        
                                            (In billions of dollars)                                            
----------------------------------------------------------------------------------------------------------------
                                                                       Estimate                                 
                                    ----------------------------------------------------------------------------
                                        1996       1997       1998       1999       2000       2001       2002  
----------------------------------------------------------------------------------------------------------------
Receipts under tax rates and                                                                                    
 structure in effect January 1,                                                                                 
 1996\1\...........................    1,423.6    1,495.8    1,569.0    1,640.2    1,719.4    1,800.3    1,886.0
Telecommunications Act of 1996.....        4.3        4.7        5.5        6.3        7.0        7.7        7.9
Social security (OASDI) taxable                                                                                 
 earnings base increases:..........                                                                             
  $62,700 to $65,100 on Jan. 1,                                                                                 
   1997............................  .........        1.0        2.8        3.1        3.5        3.9        4.3
  $65,100 to $68,100 on Jan. 1,                                                                                 
   1998............................  .........  .........        1.3        3.5        3.9        4.3        4.9
  $68,100 to $71,100 on Jan. 1,                                                                                 
   1999............................  .........  .........  .........        1.3        3.5        3.9        4.3
  $71,100 to $74,100 on Jan. 1,                                                                                 
   2000............................  .........  .........  .........  .........        1.3        3.5        3.9
  $74,100 to $76,800 on Jan. 1,                                                                                 
   2001............................  .........  .........  .........  .........  .........        1.2        3.2
  $76,800 to $80,100 on Jan. 1,                                                                                 
   2002............................  .........  .........  .........  .........  .........  .........        1.4
Proposals\2\.......................       -1.6      -11.7       -6.3       -7.8      -11.0      -11.6      -10.7
Extension of expired trust fund                                                                                 
 excise taxes\2\...................        0.5        5.5        5.7        6.0        6.3        6.7        7.0
                                    ----------------------------------------------------------------------------
  Total, receipts under existing                                                                                
   and proposed legislation........    1,426.8    1,495.2    1,577.9    1,652.5    1,733.8    1,819.8   1,912.2 
----------------------------------------------------------------------------------------------------------------
\1\These estimates assume a social security taxable earnings base of $62,700 through 2002.                      
\2\Net of income offsets.                                                                                       
[[Page 36]]
                           ENACTED LEGISLATION

  Self-Employed Health Insurance Act.--This Act restored the 25 percent 
health insurance deduction for the self-employed for 1994 and increased 
it to 30 percent thereafter. The associated revenue losses were more 
than offset by other revenue and outlay provisions. The major provisions 
of the Act that affected receipts are described below.
  Restore and increase deduction for health insurance costs of self-
employed individuals.--The 25 percent health insurance deduction for 
self-employed individuals and their dependents, which had expired for 
taxable years beginning after December 31, 1993, was retroactively 
reinstated. In addition, the deduction was permanently increased to 30 
percent for taxable years beginning after December 31, 1994.
  Repeal special rules applicable to Federal Communications Commission 
(FCC) certified sales of broadcast property.--Under prior law, sellers 
of FCC-licensed broadcast facilities were allowed to defer taxes on 
gains realized in the sale or exchange of FCC-licensed broadcast 
properties to minority owners. Such deferrals were executed through FCC-
issued tax certificates. Under this Act, deferral was repealed effective 
for all sales and exchanges on or after January 17, 1995 and for all 
sales and exchanges occuring before that date for which the FCC tax 
certificate was issued on or after January 17, 1995. The repeal did not 
apply to binding written contracts for which the seller had applied to 
the FCC for a certificate of deferral before January 17, 1995.
  Modify earned income tax credit (EITC) eligibility.--Effective for 
taxable years beginning after December 31, 1995, taxpayers with annual 
aggregate interest, dividend, tax-exempt interest and net rental and 
royalty income exceeding $2,350 would no longer be eligible for the 
EITC.
  Prohibit nonrecognition of gain on involuntary conversions in certain 
related-party transactions.--Section 1033 of the Internal Revenue Code 
allows certain taxpayers to defer a gain realized from certain 
involuntary conversions of property if the taxpayer purchases similar or 
related property within a specified period. Under this Act, taxpayers 
would no longer be allowed to defer gain on involuntary conversions 
occurring on or after February 6, 1995 if the replacement property or 
stock were purchased from a related person.
  Extend New York State hospital surcharge provision.--Under the Omnibus 
Budget Reconciliation Act of 1993, certain employers were prohibited 
from receiving a Federal tax deduction for health insurance expenses if 
they failed to comply with New York State's hospital rate-setting/
surcharge laws. This provision, which expired on May 12, 1995, was 
extended through December 31, 1995.

  Telecommunications Act of 1996.--This Act, which provided for a major 
restructuring of the Nation's communications laws, fulfilled this 
Administration's promise to reform telecommunications laws in a manner 
that leads to competition and private investment, promotes universal 
service and open access to information networks, and provides for 
flexible government regulation. Under the Act, all interstate 
telecommunications carriers would be required to contribute funds, as 
prescribed by the FCC, to the preservation and advancement of universal 
service. The contributions would be used to provide and upgrade 
facilities and services, as prescribed by the FCC. Telecommunications 
carriers would receive credit toward their contribution by providing 
discount service to schools, libraries, and health care providers in 
rural areas. Because the amounts collected would be spent, the net 
budget effect would be zero.
                        ADMINISTRATION PROPOSALS
                           Provide Tax Relief
  The President's plan targets tax relief to middle-income Americans 
through his Middle Class Bill of Rights, which was originally proposed 
in last year's budget. His plan also includes estate tax relief for 
small businesses and family farms, expanded expensing for small 
businesses, pension simplification, and initiatives for economically 
distressed areas.

  Middle Class Bill of Rights.--The Administration is again proposing 
the three features of its Middle Class Bill of Rights designed to give 
middle-income families the tax relief they need to help them raise their 
children, save for the future and pay for postsecondary education. These 
provisions would be subject to trigger-off (that is, would cease to be 
effective) on January 1, 2001 in the event that the Federal budget 
deficit is not at least $20 billion below the Congressional Budget 
Office's (CBO's) estimate for the year 2000.
  Provide tax credit for dependent children.--A non-refundable credit 
would be allowed for each dependent child under the age of 13. The 
credit would equal $300 for 1996, 1997 and 1998, and would rise to $500 
for 1999 and subsequent years. The credit would be phased out for 
taxpayers with adjusted gross income (AGI) between $60,000 and $75,000. 
Both the credit amount and the phase-out range would be indexed for 
inflation beginning in 2000. The credit would be applied before the 
earned income tax credit but could not be used to offset alternative 
minimum tax liability.
  Expand Individual Retirement Accounts (IRAs).--Under present law, 
eligibility for deductible IRAs is phased out for single taxpayers with 
AGI between $25,000 and $35,000 and for couples filing a joint return 
with AGI between $40,000 and $50,000, if the 
[[Page 37]]
individual (or the 
individual's spouse) is an active participant in an employer-sponsored 
retirement plan. Under the Administration's proposal, the AGI thresholds 
and phase-out ranges would be doubled over time. For 1996 through 1998, 
eligibility would be phased out for single taxpayers with AGI between 
$45,000 and $65,000, and for couples filing a joint return with AGI 
between $70,000 and $90,000. For 1999 and later years, eligibility would 
be phased out for single taxpayers with AGI between $50,000 and $70,000 
and for couples filing a joint return with AGI between $80,000 and 
$100,000. These thresholds and the present law annual contribution limit 
of $2,000 would be indexed for inflation. Withdrawals from IRAs would 
not be subject to the 10 percent early withdrawal tax if the proceeds 
were used to pay post-secondary education costs, to buy or build a first 
home, to cover living expenses if unemployed for at least 12 consecutive 
weeks, or to pay catastrophic medical expenses (including nursing home 
or other costs associated with caring for an incapacitated parent or 
grandparent). In addition, each individual eligible for a deductible IRA 
would have the option of contributing an amount up to the contribution 
limit to a traditional deductible IRA or to a new back-loaded special 
IRA. Contributions to this special IRA would not be tax deductible, but 
distributions of the contributions would be tax-free. If the 
contributions remained in the account for at least five years, earnings 
on the contributions also would be tax-free when withdrawn. Withdrawals 
of account balances from special IRAs during the five-year period would 
be subject to ordinary income tax and a 10 percent early withdrawal tax. 
However, withdrawals during the five-year period for the purposes 
described above (or upon death or disability of the taxpayer) would not 
be subject to the early withdrawal tax. Individuals whose AGI for a year 
fell within the eligibility thresholds would be allowed to convert an 
existing IRA into a special IRA, and for conversions before 1998, income 
inclusion would be spread over four years.
  Provide tax incentive for education and training.--Effective January 
1, 1996, a deduction would be permitted for up to $5,000 in expenditures 
on post-secondary school education and training for the taxpayer, the 
taxpayer's spouse and dependents. The maximum allowable deduction would 
increase to $10,000 effective January 1, 1999. The maximum allowable 
deduction would be phased out for taxpayers filing a joint return with 
AGI (before the proposed deduction) between $100,000 and $120,000. For 
taxpayers filing a head-of-household or single return, the maximum 
allowable deduction would be phased out for those with AGI between 
$70,000 and $90,000. The phase-out ranges would be indexed for inflation 
beginning in 2000. Qualifying education expenses are those related to 
post-secondary education paid to institutions and programs eligible for 
Federal assistance. Deductible expenses would include tuition and fees, 
but would not include meals, lodging, books or transportation.

  Increase deduction for self-employed health insurance.--For a 
discussion of this proposal, see ``Other Provisions'' category below.
  Increase expensing for small business.--In lieu of depreciation, a 
taxpayer with a sufficiently small amount of annual investment may elect 
to deduct up to $17,500 of the cost of qualifying property placed in 
service during the taxable year. The amount of tangible depreciable 
property that small businesses can expense each year would be increased 
to $25,000 under the Administration's proposal. The increase would be 
effective for property placed in service in taxable years beginning 
after December 31, 1995 and would be phased in, starting at $19,000 in 
1996, and then increasing over a six-year period in annual increments of 
$1,000. This provision would be subject to trigger-off (that is, the 
amount of tangible depreciable property that small businesses can 
expense each year would revert to $17,500) on January 1, 2001 in the 
event that the Federal budget deficit is not at least $20 billion below 
CBO's estimate for the year 2000.
  Provide estate tax relief for small business.--Estate tax attributable 
to certain interests in closely held businesses may be paid in 
installments over a period of up to 14 years. A special four percent 
interest rate is provided for the tax deferred on the first $1 million 
of value. The $1 million cap has been in effect since 1976. To address 
the liquidity problems that may arise upon the death of a farmer or 
small business owner, and to adjust for inflation, the Administration 
proposes to increase the amount of property eligible for the special 
interest rate from $1 million to $2.5 million. The proposal also 
simplifies current law by eliminating distinctions based on the form of 
ownership, providing alternatives to the estate tax lien, and reducing 
the interest rate by 50 percent or more in exchange for making the 
interest payments nondeductible. The proposal would be effective for 
decedents who die after December 31, 1996.
  Simplify pension plan rules.--The Administration proposes to simplify 
the design and administration of retirement plans sponsored by 
businesses of all sizes, nonprofit organizations, and State and local 
governments, as well as for multiemployer plans. These measures not only 
would simplify the rules governing these plans, but also would 
potentially expand pension coverage and stimulate private savings, 
particularly for employees of small firms. These measures include, a 
new, simple retirement savings plan (the National Employee Savings Trust 
or the NEST) for small businesses. It combines the most attractive 
features of the IRA and the 401(k) plan, minimizes administrative and 
compliance costs, and eliminates the need for employer involvement with 
the Government. The NEST is designed to encourage retirement savings by 
middle- and low-income workers, not only the highly paid, without 
complicated forms or calculations.
[[Page 38]]
  Provide tax incentives for distressed areas.--The Administration is 
proposing tax incentives for the cleanup of polluted urban and rural 
areas and is proposing an expansion of the empowerment zone and 
enterprise community program, as described below. The proposal would be 
subject to trigger-off for qualified expenses incurred after December 
31, 2000 in the event that the Federal budget deficit is not at least 
$20 billion below CBO's estimate for the year 2000.
  Provide tax incentives to clean up environmentally contaminated areas 
known as brownfields in distressed communities.--To encourage the 
cleanup of polluted urban and rural areas known as brownfields, the 
Administration proposes to allow certain nondeductible costs incurred by 
businesses to remediate environmentally contaminated land in certain 
areas to be capitalized and amortized over a 60-month period. Qualified 
sites generally would be limited to those properties located in high-
poverty areas, Federal empowerment zones and enterprise communities, and 
areas subject to current Environmental Protection Agency (EPA) 
Brownfields Pilots. To claim this incentive, taxpayers would be required 
to obtain from the appropriate State or local agency, or the EPA in 
certain circumstances, verification that the site satisfies the 
geographic requirement. The proposal would be effective for qualified 
expenses incurred after the date of enactment.
  Expand Empowerment Zone and Enterprise Community program.--Under the 
Omnibus Budget Reconciliation Act of 1993, certain tax incentives were 
provided for nine empowerment zones and 95 enterprise communities. The 
tax incentives were a 20-percent employer wage credit, increased Section 
179 expensing, and a new category of tax-exempt financing. Qualifying 
businesses in empowerment zones were eligible for all three incentives, 
while businesses in enterprise communities were eligible for the tax-
exempt financing. Over 500 communities submitted applications for these 
104 designations that were announced in December 1994. The 
Administration proposes a three-part expansion of this program. First, 
the designation of two additional urban empowerment zones would be 
authorized, to be made within 180 days of enactment. Second, the 
restrictions on the tax-exempt financing would be loosened to make this 
incentive more accessible. Third, the designation of 40 additional 
empowerment zones and 65 additional enterprise communities would be 
authorized. Businesses in the new enterprise communities would be 
eligible for the current-law tax-exempt financing, as revised, as well 
as the brownfields tax incentive described above on an additional 500 
acres. Businesses in the new empowerment zones would be eligible for the 
current-law section 179 expensing, the brownfields tax incentive on an 
additional 1,000 acres, and tax-exempt financing that would not be 
subject to the current-law State volume caps, but rather would only be 
subject to zone-by-zone volume caps. The current-law wage credit would 
not be applicable in any of the new zones and communities. The 
designations of these new zones and communities would be required to 
occur before 1998, and the designations would generally be effective for 
10 years.

  Provide tax relief for troops involved in the Bosnian peacekeeping 
operations.--For a discussion of this proposal, see ``Other Provisions'' 
category below.
     Eliminate Unwarranted Benefits and Adopt Other Revenue Measures
  The President's plan cuts unwarranted corporate tax subsidies, closes 
tax loopholes, improves tax compliance and adopts other revenue 
measures. These reforms, which are estimated to save $43.6 billion 
during the 7-year period, 1996-2002, are described below.

  Disallow interest deduction for corporate-owned life insurance (COLI) 
policy loans.--Under existing law, a company that sets up a COLI program 
may borrow against the cash value of the life insurance contracts on the 
lives of its employees. The interest paid on such loans generally is 
deductible by the company, subject to certain limitations. However, the 
earnings credited to the COLI policies are not subject to current tax. 
In addition, benefits that the company receives upon the deaths of 
insured employees are not taxed, ensuring that the income credited under 
the contracts is never subject to tax. To restrict further this tax-
arbitrage opportunity, the Administration proposes to phase out the 
deduction of interest on COLI contracts. The proposal generally would be 
effective with respect to interest paid or accrued after December 31, 
1995.
  Deny interest deduction on certain debt instruments.--If an instrument 
qualifies as equity, the issuer generally does not receive a deduction 
for dividends paid. If an instrument qualifies as debt, the issuer may 
receive a deduction for accrued interest and the holder generally 
includes interest in income, subject to certain limitations. The line 
between debt and equity is uncertain and it has proven difficult to 
formulate general rules of classification. Taxpayers have exploited this 
lack of guidance by issuing instruments that have substantial equity 
features, but for which they claim interest deductions. Generally 
effective for instruments issued on or after December 7, 1995, subject 
to certain transition rules, the Administration proposes that no 
deduction be allowed for interest or original issue discount (OID) on an 
instrument issued by a corporation that has a maximum term of more than 
40 years, or is payable in stock of the issuer or a related party. The 
proposal also modifies the rules for indebtedness that is reflected as 
equity on the issuer's financial statements.
  Defer original issue discount deduction on convertible debt.--If a 
debt instrument is convertible into stock and provides no payment of, or 
adjustment for, accrued interest on conversion, no deduction is allowed 
for accrued but unpaid stated interest. In contrast, the accrued but 
unpaid discount on a convertible debt instrument with OID generally is 
deductible, even if the 
[[Page 39]]
instrument is converted before the issuer pays 
any OID. The Administration proposal would defer the deduction for OID 
on convertible debt until payment and would be effective for convertible 
debt issued on or after December 7, 1995, subject to certain transition 
rules.
  Reduce dividends-received deduction to 50 percent.--A corporate holder 
of stock generally is entitled to a deduction for dividends received on 
stock in the following amounts: 70 percent if the recipient owns less 
than 20 percent of the stock of the payor, 80 percent if the recipient 
owns 20 percent or more of the stock, and 100 percent if the recipient 
owns 80 percent or more of the stock. The Administration proposes to 
reduce the deduction to 50 percent for corporations owning less than 20 
percent of the stock of a U.S. corporation because the existing 70-
percent deduction is too generous for corporations that do not have a 
sufficient ownership interest in the issuing corporation. The proposal 
would be effective for dividends paid or accrued more than 30 days after 
the date of enactment.
  Modify holding period for dividends-received deduction.--The 
dividends-received deduction is allowed to a corporate shareholder only 
if the shareholder satisfies a 46-day holding period for the dividend-
paying stock or a 91-day period for certain dividends on preferred 
stock. The 46- or 91-day holding period generally does not include any 
time in which the shareholder is protected from the risk of loss 
otherwise inherent in the ownership of an equity interest. However, the 
holding period requirement does not have to be proximate to the time the 
dividend distribution is made. Effective for dividends paid or accrued 
more than 30 days after the date of enactment, the Administration 
proposes that in order for a dividend to be eligible for the dividends-
received deduction, the holding period requirement must be satisfied 
with respect to that dividend over a period immediately before or 
immediately after the taxpayer becomes entitled to receive the dividend.
  Extend pro rata disallowance of tax-exempt interest expense to all 
corporations.--No income tax deduction is allowed for interest on debt 
used directly or indirectly to acquire or hold investments the income on 
which is tax-exempt. The determination of whether debt is used to 
acquire or hold tax-exempt investments depends on the holder of the 
instrument. For financial institutions and dealers in tax-exempt 
investments, debt generally is treated as financing all of the 
taxpayer's assets proportionately. For corporations, other than 
financial institutions and dealers, and for individuals, deductions are 
disallowed only when indebtedness is incurred or continued for the 
purpose of purchasing or carrying tax-exempt investments. These 
corporations are therefore able to reduce their tax liabilities 
inappropriately through the double Federal tax benefits of interest 
expense deductions and tax-exempt interest income. Effective for taxable 
years beginning after the date of enactment, with respect to obligations 
acquired after December 7, 1995, the Administration proposes that all 
corporations other than insurance companies be treated the same as 
financial institutions are treated under current law with regard to 
deductions for interest on debt used directly or indirectly to acquire 
or hold tax-exempt obligations. The proposal also would expressly apply 
these rules to related parties, by treating all members of a 
consolidated group (other than members that are insurance companies) as 
a single entity and by tracing debt and tax-exempt holdings among other 
related parties.
  Require average-cost basis for stocks, securities, etc.--A taxpayer 
who sells stock or other securities is allowed to account for the 
transaction by specifically identifying the stock or securities or by 
using an accounting system such as first-in, first-out or last-in, 
first-out. The Administration proposes to require taxpayers to determine 
their basis in substantially identical securities using the average of 
all their holdings in the securities. Holding period would be determined 
on a first-in, first-out basis. The method of determining basis and 
holding period would apply to all securities, including stocks, notes, 
bonds, and derivative financial instruments. A special rule would allow 
the Treasury to treat securities that are substantially identical as not 
subject to the average-cost rule if they have a special status under a 
provision of the Code (such as built-in gain with respect to a 
partnership). Securities not subject to average cost under this rule 
would be treated as sold on a first-in, first-out basis. The proposal 
would be effective 30 days after the date of enactment.
  Require recognition of gain on certain stocks, indebtedness and 
partnership interests.--Gain and loss are generally taken into account 
for tax purposes when realized. Gain or loss is usually realized with 
respect to a capital asset at the time the asset is sold. Many 
transactions designed to reduce or eliminate risk of loss and 
opportunity for gain on financial assets generally do not cause 
realization. For example, taxpayers may lock in gain on securities by 
entering into a ``short against the box,'' that is, the taxpayer owns 
securities that are the same as or substantially identical to the 
securities borrowed and sold short. It is inappropriate for taxpayers to 
be able to dispose of the economic risks and rewards of owning 
appreciated property without realizing income for tax purposes. 
Therefore, the Administration proposes to require a taxpayer to 
recognize gain (but not loss) upon entering into a constructive sale of 
any appreciated position in stock, a debt instrument, or a partnership 
interest. A taxpayer would be treated as making a constructive sale of 
an appreciated position when the taxpayer (or in certain limited 
circumstances, a person related to the taxpayer) substantially 
eliminates risk of loss and opportunity for gain by entering into one or 
more positions with respect to the same or substantially identical 
property. The proposal would generally be effective for constructive 
sales entered into after the date of enactment.
[[Page 40]]
  Change the treatment of gains and losses on extinguishment.--The tax 
law distinguishes between the sale of a right or obligation to a third 
party and the extinguishment or retirement of the right or obligation. A 
sale to a third party can give rise to capital treatment while an 
extinguishment is ordinary. Extinguishment treatment has been eliminated 
for all debt instruments except those issued by natural persons and for 
most options and other positions in actively traded property. The 
application of the extinguishment doctrine in other contexts is unclear. 
The extinguishment doctrine allows taxpayers to control whether gain or 
loss is capital or ordinary by deciding whether to sell or extinguish a 
contract. The Administration proposes to eliminate the remaining 
portions of the extinguishment doctrine so that gain or loss 
attributable to the cancellation, lapse, expiration, or other 
termination of any right or obligation with respect to property that is 
or would be a capital asset in the hands of the taxpayer would be 
treated as gain or loss from the sale or exchange of a capital asset. In 
addition, the proposal would repeal the natural person exception for 
debt instruments. The proposal would be effective 30 days after the date 
of enactment.
  Require reasonable payment assumptions for interest accruals on 
certain debt instruments.--The original issue discount (OID) rules do 
not measure income appropriately for certain debt instruments that are 
prepayable. If the instruments are held in large pools, it can be 
statistically predicted that a certain portion will prepay. Prepayment 
assumptions are used to account for certain debt instruments with 
payments based on mortgages, but the OID rules otherwise ignore these 
probabilities. The proposal would require taxpayers that hold prepayable 
debt instruments in large pools to use prepayment assumptions similar to 
the rules that apply for debt instruments with payments based on 
mortgages. The proposal would be effective for taxable years beginning 
after the date of enactment.
  Require gain recognition for certain extraordinary dividends.--A 
corporate shareholder is generally allowed to deduct a percentage of 
dividends received from another domestic corporation. Certain dividends 
and dividend equivalent transactions are treated as ``extraordinary'' 
dividends. If a corporate shareholder receives an extraordinary 
dividend, the corporate shareholder must reduce the basis of the stock 
to which the distribution relates by the amount of the nontaxed portion 
of the dividend (generally the amount of the dividend that was 
deducted). If the nontaxed portion of the dividend exceeds the basis of 
the stock, the excess is deferred and recognized on a later disposition 
of the stock. If a shareholder's stock is redeemed, the redemption may 
be treated as a dividend if the shareholder's interest in the 
corporation has not been meaningfully reduced. In determining if a 
shareholder's interest has been meaningfully reduced, the ownership of 
options to purchase stock may be treated as actual stock ownership. The 
exclusion of a substantial portion of the amount received by a corporate 
shareholder on the redemption of its stock is inappropriate in certain 
cases when options are used to create stock ownership. Also, it is 
inappropriate to defer gain recognition when the portion of the 
distribution that is excluded due to the dividends received deduction 
exceeds the basis of the stock with respect to which the extraordinary 
dividend is received. The Administration proposes that corporate 
shareholders will recognize gain on redemptions of stock that are 
treated as dividends because of options when the nontaxed portion of the 
dividend exceeds the basis of the shares surrendered. In addition, 
immediate gain recognition would be required whenever the basis of stock 
with respect to which any extraordinary dividend was received was 
reduced below zero. The proposed change generally would be effective for 
distributions after May 3, 1995.
  Repeal percentage depletion for non-fuel minerals mined on Federal and 
formerly Federal lands.--Taxpayers are allowed to deduct a reasonable 
allowance for depletion relating to certain mineral deposits. The 
depletion deduction for any taxable year is calculated under either the 
cost depletion method or the percentage depletion method, whichever 
results in the greater allowance for depletion for the year. The 
percentage depletion method is viewed as an incentive for mineral 
production rather than as a normative rule for recovering the taxpayer's 
investment in the property. This incentive is excessive with respect to 
minerals mined on Federal and formerly Federal lands under the 1872 
mining act, in light of the minimal costs of acquiring the mining rights 
($5.00 or less per acre). Effective for taxable years beginning after 
the date of enactment, the Administration proposes to repeal percentage 
depletion for non-fuel minerals mined on lands where the mining rights 
were originally acquired under the 1872 law.
  Modify loss carryback and carryforward rules.--Net operating losses 
(NOLs) generally can be used to offset taxable income from the prior 
three taxable years (carrybacks) and the succeeding 15 taxable years 
(carryforwards). Because of the increased complexity and administrative 
burden associated with carrybacks, the carryback period should be 
shortened. The carryforward period could be lengthened, however, to 
allow taxpayers more time to utilize their NOLs without increasing 
either complexity or administrative burdens. The Administration proposes 
to limit carrybacks of NOLs to one year and to extend carryforwards to 
20 years, effective for NOLs arising in taxable years beginning after 
the date of enactment.
  Treat certain preferred stock as ``boot.''--In reorganization 
transactions, no gain or loss is recognized except to the extent ``other 
property'' (boot) is received; that is, property other than certain 
stock, including preferred stock. Upon the receipt of ``other 
property,'' gain but not loss can be recognized. Because preferred stock 
has an enhanced likelihood of recovery of principal 
[[Page 41]]
or of maintaining a 
dividend or both, such tax-free treatment is inappropriate. The 
Administration therefore proposes to treat certain preferred stock as 
``other property,'' subject to certain exceptions. The proposal 
generally would be effective for transactions after December 7, 1995.
  Repeal tax-free conversions of large C corporations to S 
corporations.--A corporation can avoid the existing two-tier tax by 
electing to be treated as an S corporation or by converting to a 
partnership. Converting to a partnership is a taxable event that 
generally requires the corporation to recognize any built-in gain on its 
assets and requires the shareholders to recognize any built-in gain on 
their stock. By contrast, the conversion to an S corporation is 
generally tax-free, except that the S corporation generally must 
recognize the built-in gain on assets held at the time of conversion if 
the assets are sold within 10 years. Under the Administration's 
proposal, the conversion of a C corporation with a value of more than $5 
million into an S corporation would be treated as a liquidation of the C 
corporation followed by a contribution of the assets to an S corporation 
by the recipient shareholders. Thus, the proposal would require 
immediate gain recognition by both the corporation (with respect to its 
appreciated assets) and its shareholders (with respect to their stock). 
This proposal makes the tax treatment of conversions to an S corporation 
generally consistent with conversions to a partnership. The proposal 
would apply to elections that are first effective for a taxable year 
beginning after January 1, 1997 and to acquisitions of a C corporation 
by an S corporation made after December 31, 1996.
  Require gain recognition on certain distributions of controlled 
corporation stock.--A corporation is generally required to recognize 
gain on a distribution of property (including stock of a controlled 
corporation) unless the distribution meets certain requirements. If 
various requirements are met, including restrictions relating to 
acquisitions and dispositions of stock of the distributing corporation 
or the controlled corporation, a distribution of the stock of a 
controlled corporation will be tax-free to the distributing corporation. 
Certain distributions may effectively be dispositions of a business, in 
which case tax-free treatment for the distributing corporation is 
inappropriate. Accordingly, the Administration proposes to adopt 
additional restrictions on acquisitions and dispositions of the stock of 
a distributing corporation or controlled corporation that are related to 
the distribution. Under this proposal, the distributing corporation 
would recognize gain on the distribution of the stock of the controlled 
corporation if the shareholders of the distributing corporation do not 
retain a sufficient stock interest (generally 50 percent) in the 
distributing and controlled corporations during the four-year period 
commencing two years prior to the distribution. For this purpose, 
unrelated transactions (such as public trading on the stock market) 
would be disregarded. This proposal would be effective generally for 
distributions occurring after the date of announcement.
  Reform the treatment of certain stock transfers.--Certain sales of 
stock to a related corporation are treated as the payment of a dividend 
by the purchaser. In cases where the seller is a corporation that does 
not actually own stock in the purchaser, taxpayers may take the position 
that the transaction produces tax benefits that would be unavailable if 
the purchaser distributed a dividend to its actual shareholders. For 
example, if a foreign-controlled domestic corporation sells the stock of 
a subsidiary to a foreign sister corporation, the domestic corporation 
may take the position that it is entitled to credit foreign taxes that 
were paid by the foreign sister corporation. In such cases, the 
Administration proposes to limit the amount treated as a dividend (and 
the associated foreign tax credits) from the purchaser to the amount of 
the purchaser's earnings and profits attributable to stock owned by U.S. 
persons related to the seller. If the purchaser is a domestic 
corporation, taxpayers may take the position that stock basis need not 
be reduced by the nontaxed portion of the dividend. The proposal would 
also clarify that a deemed dividend from a purchaser that is a domestic 
corporation should generally be treated as an extraordinary dividend 
requiring a basis reduction. The proposal would further require gain 
recognition to the extent that the nontaxed portion exceeds the basis of 
the shares transferred. The proposal generally would be effective for 
transactions after the date of announcement.
  Reformulate Puerto Rico and possessions tax credit.--Domestic 
corporations with business operations in U.S. possessions may elect the 
Section 936 credit, which generally eliminates the U.S. tax on certain 
income that is related to their possession-based operations. Income 
exempt from U.S. tax under this provision falls into two broad 
categories: (1) possession business income derived from the active 
conduct of a trade or business within a possession or from the sale or 
exchange of substantially all of the assets used in such a trade or 
business; and (2) possession source investment income (QPSII), which is 
attributable to investment in the possession or in certain Caribbean 
Basin countries. The amount of the credit attributable to possession 
business income is subject to limitations enacted under the Omnibus 
Budget Reconciliation Act of 1993; Section 936 companies may elect 
either a reduced percentage of the profits-based credit as allowed under 
prior law (60 percent in 1994, phasing down to 40 percent beginning in 
1998), or a limitation based on the company's economic activity in the 
possessions (measured by wages and other compensation, depreciation, and 
certain taxes paid). To provide a more efficient tax incentive for the 
economic development of Puerto Rico and other U.S. possessions, and to 
continue the effort toward this goal that was begun in the 1993 Act, the 
Administration proposes to (1) phase out the profits-based branch of the 
active-business portion of 
[[Page 42]]
the credit over five years, beginning in 
1997, and (2) allow excess amounts of economic-activity limitation to be 
carried foward for up to five years. The proposal would retain the 
economic-activity limitation on the active-business portion of the 
credit, as well as the passive-income portion of the credit for taxes 
otherwise payable on QPSII, as under present law. Revenues raised would 
be made available to Puerto Rico for programs under the Social Security 
Act and to promote job creation.
  Expand Subpart F provisions regarding income from notional principal 
contracts and stock lending transactions.--Subpart F income includes 
income from notional principal contracts referenced to foreign currency, 
commodities, or interest rates, or to indices based thereon. It also 
includes income with respect to the lending of debt securities. Subpart 
F income does not include income from equity swaps or other types of 
notional principal contracts or income from transfers of equities. 
Subpart F income should include income from all types of notional 
principal contracts and from stock-lending transactions, because such 
income is indistinguishable on policy grounds from other types of highly 
mobile income already targeted by Subpart F. The Administration is 
proposing to include in Subpart F income the net income from equity 
swaps and certain categories of notional principal contracts that are 
not reached by current law, as well as income from stock lending 
transactions. An ordinary-course-of-business exception would be provided 
for regular dealers in property, forwards, options, notional principal 
contracts, and similar financial instruments. The proposal would be 
effective for taxable years beginning after the date of enactment.
  Modify taxation of captive ``insurance'' companies.--For tax purposes, 
``insurance'' has been defined by the courts to require ``risk 
shifting'' or ``risk distribution.'' In the case of a ``captive'' 
insurance company, one court has held that risk-shifting and risk-
distribution requirements are satisfied even if the captive's ``related 
person insurance income'' accounts for nearly 70 percent of its total 
business. The Administration proposes that an insurance arrangement 
between a captive insurer and a large shareholder of the captive 
generally would not be respected as a valid insurance arrangement if 
more than 50 percent of the captive's net written premiums were 
attributable to the insurance or reinsurance of large-shareholder risks. 
In addition, such a captive would not be considered an insurance company 
for tax purposes. The proposal would be effective generally for the 
first taxable year beginning after the date of enactment.
  Reform foreign tax credit.--The Administration proposes the following 
foreign tax credit reforms.
  Eliminate interest allocation exception for certain non-financial 
corporation.--For foreign tax credit purposes, taxpayers generally are 
required to allocate and apportion interest expense between U.S. and 
foreign source income based on the proportion of the taxpayer's total 
assets in each location. Such allocation and apportionment is required 
to be made for affiliated groups as a whole rather than on a subsidiary-
by-subsidiary basis. However, certain types of financial institutions 
that are members of an affiliated group are treated as members of a 
separate affiliated group for purposes of the allocation and 
apportionment of interest expense. The Tax Reform Act of 1986 included a 
targeted rule that treats a certain corporation as a financial 
institution for this purpose. The Administration believes that this 
relief should not be provided. The proposal would repeal the targeted 
exception provided by the Tax Reform Act of 1986, effective for taxable 
years beginning after the date of enactment.
  Modify foreign tax credit carryback and carryforward rules.--The 
United States permits taxpayers to credit income taxes paid to a foreign 
government against U.S. tax on foreign source income. Through the 
foreign tax credit limitations, the Code prevents the use of foreign tax 
credits to reduce U.S. tax on U.S. source income. Under the foreign tax 
credit mechanism, current foreign income taxes in excess of the relevant 
current-year foreign tax credit limitation are not creditable against 
current U.S. tax liabilities. However, such excess foreign tax credits 
generally may be carried back for two years and carried forward for five 
years, and used as a credit to the extent there is excess foreign tax 
credit limitation (that is, an excess of the foreign tax credit 
limitation over creditable foreign taxes) in any of those years. 
Experience over the years has shown, however, that carrybacks are 
associated with increased complexity and administrative burdens as 
compared to carryforwards. Therefore, to reduce such complexity and 
burdens, the proposal would limit foreign tax credit carrybacks to one 
year and extend foreign tax credit carryforwards to seven years. The 
proposal would be effective for foreign taxes paid or accrued or deemed 
paid or accrued in taxable years beginning after December 31, 1996.

  Modify rules relating to foreign oil and gas extraction income.--To be 
eligible for the U.S. foreign tax credit, a foreign levy must be the 
substantial equivalent of an income tax in the U.S. sense, regardless of 
the label the foreign government attaches to it. Under regulations, a 
foreign levy is a tax if it is a compulsory payment under the authority 
of a foreign government to levy taxes and is not compensation for a 
specific economic benefit provided by the foreign country. Taxpayers 
that are subject to a foreign levy and that also receive (directly or 
indirectly) a specific economic benefit from the levying country are 
referred to as ``dual capacity'' taxpayers and may not claim a credit 
for that portion of the foreign levy paid as compensation for the 
specific economic benefit received. The proposal would treat as taxes 
payments by a dual-capacity taxpayer to a foreign country that would 
otherwise qualify as income taxes or ``in lieu of'' taxes, only if there 
is a ``generally applicable income tax'' in that country. For this 
purpose, a generally applicable income tax is 
[[Page 43]]
an income tax (or a series 
of income taxes) that applies to trade or business income from sources 
in that country, so long as the levy has substantial application both to 
non-dual-capacity taxpayers and to persons who are citizens or residents 
of that country. Where the foreign country does generally impose an 
income tax, as under present law, credits would be allowed up to the 
level of taxation that would be imposed under that general tax, so long 
as the tax satisfies the new statutory definition of a ``generally 
applicable income tax.'' The proposal would treat foreign oil and gas 
income as Subpart F income. It also would create a new foreign tax 
credit basket within Section 904 for foreign oil and gas income. The 
proposal would be effective for taxable years beginning after the date 
of enactment. The proposal would yield to U.S. treaty obligations that 
allow a credit for taxes paid or accrued on certain oil or gas income.
  Require thrifts to account for bad debts in the same manner as 
banks.--A thrift institution that holds at least 60 percent of its 
portfolio in home mortgages, cash, and government obligations is 
permitted to maintain a reserve for bad debts. Annual additions to its 
bad debt reserve may be calculated under either the ``percentage of 
taxable income'' method or the ``experience'' method. These methods can 
be more generous than the rules applicable to commercial banks. As a 
result of the increasing convergence of the banking and thrift 
industries, the special rules applicable to thrifts are no longer 
warranted. The Administration proposes that effective for taxable years 
beginning after the date of enactment, thrifts must account for bad 
debts in the same manner as banks. Specifically, the percentage-of-
taxable-income method of computing bad debt reserves would no longer be 
available; thrifts with $500 million or less of adjusted bases in their 
assets would be permitted to use the experience method and thrifts with 
greater than $500 million in adjusted bases in their assets would be 
required to use the specific charge-off method. Post-1987 reserves would 
be recaptured over six years, unless the former thrift meets mortgage 
loan requirements, in which case recapture would be delayed up to two 
years.
  Reform depreciation under the income forecast method.--All estimated 
income from the use of property or the sale of merchandise would be 
taken into account in determining depreciation under the income forecast 
method. This change, which would generally be effective for property 
placed in service after September 13, 1995, would eliminate the 
inappropriate acceleration of depreciation of the cost of motion picture 
films, video tapes, sound recordings, and other similar property that 
occurs under current law. Interest would be charged or credited to 
compensate for errors in estimates.
  Phase out preferential tax deferral for certain large farm 
corporations required to use accrual accounting.--Under the Revenue Act 
of 1987, family farm corporations were required to change to the accrual 
method of accounting if their gross receipts exceeded $25 million in any 
taxable year beginning after 1985. However, in lieu of including in 
gross income the entire amount of the adjustment attributable to the 
change in accounting method, a family farm corporation could establish a 
suspense account. The amount of the suspense account was to be included 
in gross income if the corporation ceased to be a family corporation or 
to the extent the gross receipts of the corporation from farming 
declined. To eliminate the potential indefinite deferral of the 
adjustment, the Administration proposes to repeal the ability of family 
farm corporations to establish such suspense accounts. Any taxpayer 
subsequently required to change to the accrual method of accounting 
would be required to take the adjustment into account generally over a 
ten-year period. Any existing suspense accounts would be restored to 
income ratably over a ten-year period, or sooner to the extent provided 
under existing law. This provision would be effective for taxable years 
beginning after September 13, 1995.
  Repeal lower of cost or market inventory accounting method.--Taxpayers 
required to maintain inventories are permitted to use a variety of 
methods to determine the cost of their ending inventories, including the 
last-in, first-out (LIFO) method, the first-in, first-out (FIFO) method, 
and the retail method. Taxpayers not using a LIFO method may determine 
the carrying values of their inventories by applying the lower of cost 
or market (LCM) method and by writing down the cost of goods that are 
unsalable at normal prices or unusable in the normal way because of 
damage, imperfection or other causes (subnormal goods method). The 
allowance of write-downs under the LCM and subnormal goods methods is 
essentially a one-way mark-to-market method that understates taxable 
income. The Administration proposes to repeal the LCM and subnormal 
goods methods, effective for taxable years beginning after the date of 
enactment.
  Repeal components of cost inventory accounting method.--Taxpayers that 
use the LIFO method to determine the cost of their ending inventories 
may use a variety of dollar-value methods, including double extension, 
link-chain and other index methods, in order to determine whether an 
increment has occurred and the cost of that increment. Certain taxpayers 
are permitted to use simplified LIFO methods based on externally 
developed price indexes. Some taxpayers that use a dollar-value, double-
extension method make their computations with respect to the three 
components of cost (materials, labor and overhead) of their finished 
goods and work-in-process inventories (the COC method), rather than the 
aggregate cost of these goods (the total product cost method). The COC 
method, in many cases, does not adequately account for technological 
efficiencies in which skilled labor is substituted for less-skilled 
labor or where overhead costs replace direct labor costs. The 
Administration is proposing to repeal 
[[Page 44]]
the COC method effective for 
taxable years beginning after the date of enactment.
  Modify basis adjustment rules under Section 1033.--The Administration 
proposes that when a taxpayer acquires a controlling interest in the 
stock of a corporation as replacement property after an involuntary 
conversion, the corporation must be required to reduce its adjusted 
bases in its assets by the same amount as the taxpayer is required to 
reduce its basis in the acquired stock. The corporation's adjusted bases 
in its assets would not be reduced, in the aggregate, below the 
taxpayer's basis in its stock. In addition, the basis of any individual 
asset would not be reduced below zero. This proposal, which would allow 
deferral of gain recognition, but not the avoidance of that gain, would 
generally be effective for involuntary conversions occurring after 
September 13, 1995.
  Expand requirement that involuntarily converted property be replaced 
with property acquired from an unrelated party.--Gain realized by 
taxpayers from certain involuntary conversions is deferred to the extent 
the taxpayer purchases property similar or related in service or use to 
the converted property within a specified period of time. C corporations 
(and partnerships with one or more corporate partners that own more than 
50 percent of the capital or profits interest in the partnership) 
generally are not entitled to defer gain if the replacement property is 
purchased from a related person. The Administration proposes to extend 
this rule to any other taxpayer, including an individual, that acquires 
replacement property from a related person, unless the taxpayer has an 
aggregate realized gain of $100,000 or less during the year as a result 
of involuntary conversions. In the case of a partnership or S 
corporation, the $100,000 annual limitation would apply to the entity 
and each partner or shareholder. The proposal would generally be 
effective for involuntary conversions occurring after September 13, 
1995.
  Place further restrictions on like-kind exchanges involving personal 
property.--An exchange of property, like a sale, is generally a taxable 
transaction. However, no gain or loss is recognized if property held for 
productive use in a trade or business or for investment is exchanged for 
property of a like kind that is to be held for productive use in a trade 
or business or for investment. In general, any kind of real estate is 
treated as of a like kind with other real property; however real 
property located in the United States and real property located outside 
the United State are not of a like kind. For personal property, property 
of a ``like class'' is treated as being of a like kind; no restrictions 
apply with regard to location in or outside the United States. To 
conform the limitations on exchanges of personal property to the 
limitations on exchanges of real property, the Administration proposes 
that effective generally for exchanges after December 6, 1995, personal 
property located in the United States and personal property located 
outside the United States would not be treated as like kind.
  Disallow rollover and one-time exclusion on sale of residence to the 
extent of previously claimed depreciation.--Generally, under Section 
1034, no gain is recognized on the sale or exchange of a principal 
residence to the extent that the amount of the sales price is reinvested 
in a new residence within a specified period. In addition, Section 121 
generally provides a taxpayer with a one-time election to exclude from 
gross income up to $125,000 of gain from the sale of a principal 
residence if the taxpayer has attained the age of 55 before the sale and 
has used the residence as a principal residence for three or more of the 
five years preceding the sale. Because depreciation is allowed with 
respect to a portion of a residence when that portion is used for 
business purposes and those deductions reduce the owner's basis in the 
residence, the Administration is proposing to require gain recognition 
on the sale of a principal residence to the extent of any depreciation 
allowable after December 31, 1995. Similarly, the amount of otherwise 
allowable one-time exclusion would be reduced to the extent of 
depreciation allowable after December 31, 1995.
  Require registration of certain confidential corporate tax shelters.--
Many corporate tax shelters are not registered with the Internal Revenue 
Service (IRS). Requiring registration of corporate tax shelters would 
allow the IRS to make better informed judgments regarding the audit of 
corporate tax returns and to monitor whether legislation or 
administrative action is necessary regarding the type of transactions 
being registered. The Administration is therefore proposing the 
registration of any investment, plan, arrangement or transaction: (1) a 
significant purpose of the structure of which is tax avoidance or 
evasion by a corporate participant, (2) that is offered to any potential 
participant under conditions of confidentiality, and (3) for which the 
tax shelter promoter may receive total fees in excess of $100,000. The 
proposal would be effective for any tax shelter offered to potential 
participants after the date the Secretary of the Treasury prescribes 
guidance regarding the filing requirements.
  Require reporting of payments to corporations rendering services to 
Federal agencies.--All persons engaged in a trade or business and making 
payments of $600 or more to another person in remuneration for services 
generally must report those payments to the IRS and to the recipient. No 
reporting is required if the recipient is a corporation, permitting 
significant amounts of income to escape the tax system. To ensure that 
corporations that do business with the Federal Government appropriately 
report as income their payments from the Federal Government, the 
Administration proposes to require executive agencies to report payments 
of $600 or more made to corporations for services rendered. The proposal 
would be effective for 
[[Page 45]]
returns the due date of which is more than 90 
days after the date of enactment.
  Increase penalties for failure to file correct information returns.--
All persons engaged in a trade or business and making payments of $600 
or more to another person in remuneration for services generally must 
report those payments to the IRS. Any person who fails to report such 
payments in a timely manner or incorrectly reports such payments is 
subject to penalties. For taxpayers filing large volumes of information 
returns or reporting significant payments, existing penalties ($15 per 
return, not to exceed $75,000 if corrected within 30 days; $30 per 
return not to exceed $150,000 if corrected by August 1; and $50 per 
return if not corrected at all) may not be sufficient to encourage 
timely and accurate reporting. The Administration proposes to increase 
the general penalty amount to the greater of $50 per return or five 
percent of the total amount required to be reported. The increased 
penalty would not apply if the aggregate amount actually reported by the 
taxpayer on all returns filed for that calendar year was at least 97 
percent of the amount required to be reported. The increased penalty 
would be effective for returns the due date for which is more than 90 
days after the date of enactment.
  Extend Internal Revenue Service (IRS) user fees.--The IRS provides 
written responses to questions of individuals, corporations, and 
organizations relating to their tax status or the effects of particular 
transactions for tax purposes. The IRS responds to these inquiries 
through the issuance of letter rulings, determination letters, and 
opinion letters. The authority to charge fees for these requests, which 
is scheduled to expire effective with requests made after September 30, 
2000, is proposed to be extended for two years through September 30, 
2002.
  Apply failure-to-pay penalty to substitute returns.--The failure-to-
pay penalty, which is a percentage of the tax due, generally runs from 
the due date of a return until the tax is paid. If, however, a taxpayer 
fails to file a return, and the Commissioner prepares a substitute 
return for the taxpayer, then the tax on which the penalty is measured 
is considered a deficiency and the penalty begins to run only ten days 
after the IRS sends the taxpayer notice and demand for payment of the 
tax. There is no reason to treat a taxpayer for whom the Commissioner 
prepares a substitute return more favorably than taxpayers who pay late 
but nevertheless file their own returns. Therefore, the proposal would 
require that the failure-to-pay penalty apply to taxpayers for whom the 
Commissioner prepares substitute returns, in the same manner as it 
applies to delinquent taxpayers (that is, that the penalty commences 
running from the due date of the return). The proposal would be 
effective for returns due after the date of enactment.
  Repeal exemption for withholding on gambling winnings from bingo and 
keno in excess of $5,000.--Proceeds of most wagers with odds of less 
than 300 to 1 are exempt from withholding, as are all bingo and keno 
winnings. The proposal would impose withholding on proceeds of bingo or 
keno in excess of $5,000 at a rate of 28 percent, regardless of the odds 
of the wager, effective for payments made after the date of enactment.
  Require tax reporting for payments to attorneys.--Tax information 
reporting is required for persons engaged in a trade or business making 
payments in the course of the trade or business of rent, salaries, 
wages, or other fixed or determinable income. Treasury regulations 
require a payor to report payments of attorney's fees if the payments 
are made in the course of a trade or business, although generally a 
payor is not required to report payments made to corporations. If a 
payment to an attorney is a gross amount, and it cannot be determined 
what portion is the attorney's fee (as in the case of lump-sum judgments 
or settlements made jointly payable to a lawyer and a plaintiff), then 
no reporting is required. The Administration proposes requiring that any 
person making a payment in the course of a trade or business to a lawyer 
or a law firm, whether as sole or joint payee, report the payment to the 
IRS. When the portion that constitutes fees cannot be determined, the 
amount paid would be reported as gross proceeds. A lawyer receiving a 
payment would be required to provide his or her taxpayer identification 
number to the payor or be subject to applicable penalties and backup 
withholding. The exception for payments to corporations would not apply 
to payments of attorney's fees. The proposal would be effective for 
payments made after December 31, 1996.
  Repeal advance refunds of diesel fuel tax for diesel cars and light 
trucks.--The first purchaser of a diesel-powered automobile or light 
truck is entitled to a payment in the nature of an advance refund of the 
difference between the diesel fuel excise tax and the gasoline excise 
tax. The amount of the refund typically is small, not warranting the 
resources required to effectively administer the procedure. Accordingly, 
the Administration proposes to repeal the provision allowing these 
payments, effective for vehicles purchased after the date of enactment.
  Extend oil spill excise tax.--Before January 1, 1995, a five-cents-
per-barrel excise tax was imposed on domestic crude oil and imported 
petroleum products. The tax was dedicated to the Oil Spill Liability 
Trust Fund to finance the cleanup of oil spills and was not imposed for 
a calendar quarter if the unobligated balance in the Trust Fund exceeded 
$1 billion at the close of the preceding quarter. The Administration 
proposes to reinstate this tax for the period after the date of 
enactment and before October 1, 2006. The tax would be suspended for a 
given calendar quarter if the unobligated 
[[Page 46]]
Trust Fund balances at the end 
of the preceding quarter exceeded $2.5 billion.
  Impose excise taxes on kerosene as diesel fuel.--A 24.3-cents-per-
gallon excise tax is imposed on diesel fuel upon removal from a 
registered terminal facility unless the fuel is indelibly dyed and is 
destined for a nontaxable use. Treasury regulations provide that 
kerosene is not treated as a diesel fuel for this purpose; thus, undyed 
kerosene is not subject to the diesel fuel excise tax when it is removed 
from a terminal. Undyed kerosene is subject to tax, however, when it is 
blended with diesel fuel. Distributors of this blended fuel frequently 
do not pay the tax, thereby placing complying taxpayers at a competitive 
disadvantage and resulting in revenue losses to the Federal government. 
Effective July 1, 1997, the Administration proposes to tax kerosene as 
diesel fuel when it is removed from a terminal, unless the kerosene 
qualifies as aviation fuel. Exceptions would be provided for aviation 
fuel and, to the extent provided in regulations, for feedstock uses. In 
addition, special refund rules would apply in certain cases of kerosene 
used for heating purposes.
  Permanently extend luxury excise tax on passenger vehicles.--A 10 
percent luxury excise tax is levied on the retail price of passenger 
vehicles in excess of an inflation-adjusted threshold ($34,000 in 1996). 
The Administration proposes to permanently extend this tax, which is 
scheduled to expire after December 31, 1999.
  Extend and modify Federal Unemployment Act (FUTA) provisions.--The 
temporary unemployment surtax of 0.2 percent imposed on employers, which 
is scheduled to expire with respect to wages paid after December 31, 
1998, is proposed to be extended through December 31, 2006. Beginning in 
2002, the Administration proposes to require an employer to pay Federal 
and State unemployment taxes monthly (instead of quarterly) in a given 
year, if the employer's FUTA tax liability in the immediately prior year 
was $1,100 or more.
                  Other Provisions That Affect Receipts

  Assess fees for examination of FDIC-insured banks and bank holding 
companies (receipt effect).--The Administration proposes to require the 
Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve to 
assess fees for examination of FDIC-insured banks and bank holding 
companies. The Federal Reserve currently funds the costs of such 
examinations from earnings; therefore, deposits of earnings by the 
Federal Reserve, which are classified as governmental receipts, will 
increase by the amount of the fees.
  Expand fees collected under the securities laws.--The Administration 
proposes to expand certain fees collected under the securities laws as 
part of a legislative package to provide the Securities and Exchange 
Commission with a sound and stable long term funding structure. The 
Administration intends to work with Congress to secure early enactment 
of such a legislative proposal.
  Establish IRS continuous levy.--The Administration seeks to strengthen 
the enforcement tools available to the IRS to recover delinquent tax 
debt. New authority is proposed for the IRS to effect a continuous levy 
on non-means tested Federal payments, such as Federal salaries and 
pensions, received by individuals who owe delinquent tax debt.
  Extend the Generalized System of Preferences (GSP) and modify other 
trade provisions.--Under GSP duty-free access is provided to over 4,000 
items from about 142 eligible developing countries that meet certain 
worker rights and other criteria. This program is proposed to apply 
retroactively to July 31, 1995, when it expired, and to be extended 
through September 30, 2000. The Administration also proposes to provide 
expanded trade benefits mainly on textiles and apparel to Caribbean 
Basin countries who meet new eligibility criteria needed to prepare for 
a future free trade agreement with the U.S. The program is proposed to 
expire on September 30, 2001.
  Increase deduction for self-employed health insurance.--The 
Administration proposes to increase the 30 percent deduction for health 
insurance expenses of self-employed individuals and their dependents to 
35 percent for 1996 and 1997, 40 percent for 1998, 45 percent for 1999, 
and 50 percent for 2000 and subsequent years. The increased deduction 
would be subject to trigger-off (that is, the deductible percentage 
would revert to 30 percent) on January 1, 2001 in the event that the 
Federal budget deficit is not at least $20 billion below CBO's estimate 
for the year 2000.
  Increase employee contributions to the Civil Service Retirement System 
(CSRS) and the Federal Employees Retirement System (FERS).--The 
Administration proposes to increase employee contributions to CSRS and 
FERS by 0.5 percent of base pay in three steps. Contributions would 
increase by 0.25 percent of base pay on April 1, 1996, another 0.15 
percent on January 1, 1997 and a final 0.10 percent on January 1, 1998. 
These higher contribution rates would be effective through 2002; on 
January 1, 2003, contribution rates would return to the levels in effect 
on March 31, 1996.
  Deter expatriation tax avoidance.--The United States requires U.S. 
citizens and residents to pay tax on their worldwide income. However, 
some U.S. taxpayers relinquish their U.S. citizenship or residence and 
thereby avoid future U.S. tax on unrealized gains. To ensure that these 
individuals pay their fair share of U.S. tax, when a U.S. citizen 
renounces U.S. citizenship or when a noncitizen who has been a lawful 
permanent resident of the United States for at least 10 
[[Page 47]]
years becomes a 
nonresident of the United States, the Administration is proposing that 
such individual's assets be deemed to be disposed of and reacquired at 
their fair market value in a transaction in which gain or loss is 
recognized. There would be an exemption for up to $600,000 of gain and 
for U.S. real property interests. The provision would apply to any 
expatriation after February 6, 1995.
  Tighten rules for taxing foreign trusts.--Some U.S. taxpayers avoid 
paying applicable U.S. tax on their share of income earned by foreign 
trusts. To ensure that U.S. tax is collected on this income, the 
Administration is proposing enhanced information reporting requirements 
for assets transferred to foreign trusts, effective generally for 
taxable years beginning after the date of enactment. In addition, under 
current law, distributions received by U.S. taxpayers from certain 
foreign trusts may be treated as nontaxable gifts. The Administration is 
proposing that, effective generally on the date of enactment, U.S. 
taxpayers who receive such distributions pay U.S. tax on the 
distributions that represent trust income, unless U.S. law treats a U.S 
taxpayer as owning the trust assets.
  Extend environmental tax on corporate taxable income deposited in the 
Hazardous Substance Superfund Trust Fund.--A tax equal to 0.12 percent 
of alternative minimum taxable income in excess of $2 million is levied 
on all corporations and deposited in the Hazardous Substance Superfund 
Trust Fund. The Administration proposes to reinstate this tax, which 
expired on December 31, 1995, for taxable years beginning after December 
31, 1995 and before January 1, 2007.
  Improve compliance by tax-exempt entities through intermediate 
sanctions and other measures.--The Administration proposes to add new 
excise taxes on parties that use their control over charitable and 
nonprofit organizations to extract benefits without providing property 
or services of at least equal value in return (effective generally for 
transactions occurring on or after September 14, 1995). In addition, the 
Administration is proposing to expand the reporting and disclosure 
requirements that relate to information returns filed by tax-exempt 
organizations and to increase the penalties for failure to comply with 
these requirements, generally effective 90 days after the date of 
enactment.
  Modify Federal pay raise (receipt effect).--The Administration is 
proposing a pay raise of 3 percent for 1997, less than the raise that 
would take effect under normal operation of the law. This 3 percent 
raise would cover both the national schedule and the locality pay 
adjustments. The lower proposed pay raise affects Federal employees' 
contributions to CSRS and FERS.
  Provide tax relief for troops involved in the Bosnia peacekeeping 
operations.--The Administration is proposing tax relief for troops 
involved in the Bosnia peacekeeping operations. All of the military pay 
of enlisted personnel and part of the pay of officers would be exempt 
from income tax, and filing deadlines would be extended, similar to the 
relief afforded personnel in the Persian Gulf. The Bosnia peacekeeping 
operation involves the dangers of combat situations; this benefit is 
proposed in recognition of our troops' sacrifice. The Administration 
will work with Congress to ensure early enactment of tax relief for 
these troops.
                     Modify Earned Income Tax Credit

  Modify earned income tax credit (EITC).--The Administration is 
proposing the following modifications designed to target the EITC to 
intended recipients: (1) Individuals who are living in the U.S. 
illegally or who do not have proper documentation for employment 
purposes would not be eligible to claim the EITC. (2) The IRS would be 
allowed to use mathematical error procedures to deny claims for the EITC 
and the dependency exemption. (3) The definition of adjusted gross 
income used for phasing out the credit would be modified to disregard 
net capital losses, net losses from nonbusiness rents and royalties, net 
losses from trusts and estates, and 50 percent of net losses from sole 
proprietorships, partnerships and S corporations. (4) The definition of 
disqualified income for purposes of determining eligibility for the EITC 
would be expanded to include net passive income that is not included in 
self-employment income and net capital gain; in addition, the 
disqualified income threshold would be lowered to $2,200 in 1996 and 
indexed for inflation in subsequent years. (5) Demonstration projects in 
up to four states would be authorized to test the provision of advance 
payment of the EITC through State agencies, generally effective 90 days 
after the date of enactment.
                 Extend Expired Trust Fund Excise Taxes
  The President's plan includes extension of the following excise taxes 
that have been previously reflected in the baseline.

  Extend excise taxes deposited in the Hazardous Substance Superfund 
Trust Fund.--The excise taxes that are levied on petroleum, chemicals, 
and imported substances and deposited in the Hazardous Substance 
Superfund Trust Fund, are proposed to be reinstated for the period after 
the date of enactment and before October 1, 2006. These taxes expired on 
December 31, 1995.
  Extend excise taxes deposited in the Airport and Airway Trust Fund.--
The excise taxes that are levied on domestic air passenger tickets, 
international departures, domestic air cargo and non-commercial aviation 
fuels and deposited in the Airport and Airway Trust Fund, are proposed 
to be reinstated for the period after the date of enactment and before 
October 1, 2006. These taxes (except for 14 cents per gallon of the tax 
[[Page 48]]
on gasoline used in non-commercial aviation, which is being deposited in 
the Highway Trust Fund absent authority to transfer the tax to the 
Airport and Airway Trust Fund) expired on December 31, 1995.
  Extend excise taxes deposited in the Leaking Underground Storage Tank 
(LUST) Trust Fund.--The excise taxes that are levied on gasoline, other 
motor fuels, methanol and ethanol fuels, and on fuels used in inland 
waterways and deposited in the LUST Trust Fund, expired on December 31, 
1995. The Administration proposes to reinstate these taxes for the 
period after the date of enactment and before October 1, 2006.
                        Other Expired Provisions
  A number of tax provisions have expired. The Administration supports 
the revenue-neutral extension of these provisions as discussed below and 
looks forward to working with the Congress to achieve that goal. These 
provisions include the following:
  Exclusion for employer-provided educational assistance.--Certain 
amounts paid by an employer for educational assistance provided to an 
employee are excluded from the employee's gross income for income and 
payroll tax purposes. This exclusion expired with respect to amounts 
paid after December 31, 1994. The Administration has previously proposed 
permanent extension of this provision.
  Targeted jobs tax credit.--A tax credit, generally equal to 40 percent 
of up to $6,000 of qualified first year wages, is provided to employers 
who hire individuals from several targeted groups. The credit expired 
with respect to individuals hired after December 31, 1994. The 
Administration strongly supports the goals of this program but has 
serious concerns over the cost-effectiveness of its current design. The 
Administration would support extension if the problems undermining the 
credit's effectiveness are addressed.
  Research and experimentation (R&E) tax credit.--The 20 percent tax 
credit provided for certain research and experimentation expenditures 
expired with respect to expenditures made after June 30, 1995. The 
Administration has previously proposed permanent extension of this 
provision.
  Tax credit for orphan drug clinical testing expenses.--A 50 percent 
non-refundable tax credit is allowed for a taxpayer's qualified clinical 
testing expenses paid or incurred in the testing of certain drugs, 
generally referred to as orphan drugs, for rare diseases or conditions. 
This credit expired with respect to expenses incurred after December 31, 
1994.
  Tax deduction for contributions to private foundations.--The deduction 
for a contribution to a private foundation is generally limited to the 
adjusted basis of the contributed property. However, a taxpayer who 
contributed qualified appreciated stock to a private foundation before 
January 1, 1995 was allowed to deduct the full fair market value of the 
stock, rather than the adjusted basis of the contributed stock.
                Tax Simplification and Taxpayers' Rights
  The Administration continues to support revenue-neutral initiatives 
designed to promote sensible and equitable administration of the tax 
laws. These include simplification, technical corrections, and taxpayer 
compliance measures. In addition to legislative initiatives, such as the 
pension simplification proposals described above, the Administration is 
committed to taking appropriate administrative action to simplify tax 
laws and enhance procedural safeguards for taxpayers. For instance, the 
Administration recently has announced its intent to simplify the current 
complex rules for classifying business organizations as either 
corporations or partnerships for Federal income tax purposes. In 
addition, the Administration recently has adopted administratively a 
number of measures included in pending Taxpayer Bill of Rights 
legislation.
                                     

                                   Table 3-3.  EFFECT OF PROPOSALS ON RECEIPTS                                  
                                            (In billions of dollars)                                            
----------------------------------------------------------------------------------------------------------------
                                                                     Estimate                                   
                                --------------------------------------------------------------------------------
                                   1996      1997      1998      1999      2000      2001      2002    1996-2002
----------------------------------------------------------------------------------------------------------------
Provide tax relief:                                                                                             
  Middle Class Bill of Rights:                                                                                  
    Provide tax credit for                                                                                      
     dependent children........     -1.1      -9.7      -7.0      -8.9     -10.7     -10.7     -10.6      -58.6 
    Expand Individual                                                                                           
     Retirement Accounts (IRAs)  ........     -1.4      -0.4      -0.7      -1.1      -1.6      -2.5       -7.7 
    Provide tax incentive for                                                                                   
     education and training....     -0.2      -5.8      -5.6      -6.2      -7.5      -7.8      -8.0      -41.2 
                                --------------------------------------------------------------------------------
      Subtotal, Middle Class                                                                                    
       Bill of Rights..........     -1.3     -17.0     -13.0     -15.8     -19.3     -20.0     -21.1     -107.5 
                                                                                                                
  Increase expensing for small                                                                                  
   business....................  ........     -0.6      -0.5      -0.6      -0.7      -0.9      -0.8       -4.1 
  Provide estate tax relief for                                                                                 
   small business..............  ........  ........     -0.2      -0.2      -0.2      -0.2      -0.2       -1.0 
  Simplify pension plan                                                                                         
   rules\1\....................        *        -*      -0.1      -0.3      -0.3      -0.3      -0.3       -1.4 
  Provide tax incentives for                                                                                    
   distressed areas............       -*        -*      -0.3      -0.6      -0.8      -0.9      -0.8       -3.4 
                                --------------------------------------------------------------------------------
    Subtotal, Provide tax                                                                                       
     relief....................     -1.3     -17.6     -14.1     -17.5     -21.4     -22.4     -23.2     -117.4 
                                                                                                                
Eliminate unwarranted benefits                                                                                  
 and adopt other revenue                                                                                        
 measures:                                                                                                      
  Disallow interest deduction                                                                                   
   for corporate-owned life                                                                                     
   insurance policy loans......  ........      0.6       0.5       0.6       0.7       0.7       0.8        3.9 
[[Page 49]]
  Deny interest deduction on                                                                                    
   certain debt instruments....  ........      0.1       0.1       0.2       0.2       0.3       0.4        1.3 
  Defer original issue discount                                                                                 
   deduction on convertible                                                                                     
   debt........................  ........        *         *         *         *         *       0.1        0.2 
  Limit dividends-received                                                                                      
   deduction (DRD):                                                                                             
    Reduce DRD to 50 percent...  ........      0.2       0.4       0.4       0.4       0.4       0.4        2.0 
    Modify holding period for                                                                                   
     DRD.......................  ........        *         *         *         *         *         *        0.2 
    Interaction................  ........       -*        -*        -*        -*        -*        -*         -* 
  Extend pro rata disallowance                                                                                  
   of tax-exempt interest                                                                                       
   expense to all corporations.  ........        *       0.1       0.1       0.1       0.1       0.1        0.5 
  Require average-cost basis                                                                                    
   for stocks, securities, etc.  ........      0.6       0.7       0.6       0.7       0.7       0.7        4.1 
  Require recognition of gain                                                                                   
   on certain stocks,                                                                                           
   indebtedness and partnership                                                                                 
   interests...................  ........      0.2        -*       0.1       0.1       0.1       0.1        0.4 
  Change the treatment of gains                                                                                 
   and losses on extinguishment  ........        *         *         *         *         *         *          * 
  Require reasonable payment                                                                                    
   assumptions for interest                                                                                     
   accruals on certain debt                                                                                     
   instruments.................  ........      0.1       0.2       0.3       0.3       0.2       0.1        1.1 
  Require gain recognition for                                                                                  
   certain extraordinary                                                                                        
   dividends...................  ........     -0.1       0.1       0.1       0.1       0.1       0.1        0.3 
  Repeal percentage depletion                                                                                   
   for non-fuel minerals mined                                                                                  
   on Federal and formerly                                                                                      
   Federal lands...............  ........      0.1       0.1       0.1       0.1       0.1       0.1        0.5 
  Modify loss carryback and                                                                                     
   carryforward rules..........       -*         *       0.7       0.8       0.7       0.6       0.6        3.4 
  Treat certain preferred stock                                                                                 
   as ``boot''.................  ........      0.2       0.2       0.2       0.2       0.1         *        0.9 
  Repeal tax-free conversions                                                                                   
   of large C corporations to S                                                                                 
   corporations................  ........        *         *         *         *         *       0.1        0.2 
  Require gain recognition in                                                                                   
   certain distributions of                                                                                     
   controlled corporation stock  ........      0.1       0.1       0.1       0.1       0.1       0.1        0.5 
  Reform treatment of certain                                                                                   
   stock transfers.............  ........      0.1       0.1       0.1       0.1       0.1       0.2        0.8 
  Reformulate Puerto Rico and                                                                                   
   possessions tax credit......  ........      0.1       0.2       0.5       0.8       1.0       1.1        3.7 
  Expand Subpart F provisions                                                                                   
   regarding certain income....  ........        *         *         *         *         *         *        0.2 
  Modify taxation of captive                                                                                    
   ``insurance'' companies.....  ........        *         *         *         *         *         *        0.1 
  Reform foreign tax credit....  ........      0.2       0.9       1.1       1.0       0.9       0.9        4.9 
  Modify rules relating to                                                                                      
   foreign oil and gas                                                                                          
   extraction income...........  ........        *         *       0.1       0.1       0.1       0.1        0.4 
  Require thrifts to account                                                                                    
   for bad debts in same manner                                                                                 
   as banks....................  ........      0.2       0.2       0.3       0.3       0.3       0.3        1.6 
  Reform depreciation under the                                                                                 
   income forecast method......  ........      0.1       0.1       0.1         *         *         *        0.3 
  Phase out preferential tax                                                                                    
   deferral for certain large                                                                                   
   farm corporations required                                                                                   
   to use accrual accounting...      0.1       0.1       0.1       0.1       0.1       0.1       0.1        0.8 
  Initiate inventory reform:                                                                                    
    Repeal lower of cost or                                                                                     
     market method.............  ........      0.2       0.3       0.3       0.3       0.1         *        1.2 
    Repeal components of cost                                                                                   
     method....................  ........      0.2       0.2       0.2       0.2       0.2       0.2        1.1 
  Modify basis adjustment rules                                                                                 
   under Section 1033..........        *         *         *         *         *         *         *        0.1 
  Expand requirement that                                                                                       
   involuntarily converted                                                                                      
   property be replaced with                                                                                    
   property acquired from an                                                                                    
   unrelated party.............  ........        *         *         *         *         *         *          * 
  Place further restrictions on                                                                                 
   like-kind exchanges                                                                                          
   involving personal property.  ........        *         *         *         *         *         *        0.1 
  Disallow rollover and one-                                                                                    
   time exclusion on sale of                                                                                    
   residence to the extent of                                                                                   
   previously claimed                                                                                           
   depreciation................  ........        *         *         *         *         *         *          * 
  Require registration of                                                                                       
   certain corporate tax                                                                                        
   shelters....................  ........  ........        *         *         *         *         *          * 
  Require reporting of payments                                                                                 
   to corporations rendering                                                                                    
   services to Federal agencies  ........        *         *         *         *       0.1       0.1        0.3 
  Increase penalties for                                                                                        
   failure to file correct                                                                                      
   information returns.........  ........        *         *         *         *         *         *        0.1 
  Extend IRS user fees.........  ........  ........  ........  ........  ........        *         *        0.1 
  Apply failure-to-pay penalty                                                                                  
   to substitute returns.......        *         *         *         *         *         *         *        0.1 
  Repeal exemption for                                                                                          
   withholding on gambling                                                                                      
   winnings from bingo and keno                                                                                 
   in excess of $5,000.........        *         *         *         *         *         *         *          * 
  Require tax reporting for                                                                                     
   payments to attorneys.......  ........  ........        *         *         *         *         *          * 
  Repeal advance refunds of                                                                                     
   diesel fuel tax for diesel                                                                                   
   cars and light trucks\1\....        *         *         *         *         *         *         *        0.1 
  Extend oil spill excise                                                                                       
   tax\1\......................        *       0.2       0.2       0.2       0.2       0.2       0.2        1.4 
  Impose excise taxes on                                                                                        
   kerosene as diesel fuel\1\..  ........        *         *         *         *         *         *        0.2 
  Permanently extend luxury                                                                                     
   excise tax on passenger                                                                                      
   vehicles\1\.................  ........  ........  ........  ........      0.2       0.3       0.3        0.7 
  Extend and modify FUTA                                                                                        
   provisions:                                                                                                  
    Extend FUTA surtax\1\......  ........  ........  ........      0.8       1.2       1.2       1.2        4.4 
    Accelerate deposit of                                                                                       
     unemployment insurance                                                                                     
     taxes.....................  ........  ........  ........  ........  ........  ........      1.3        1.3 
                                --------------------------------------------------------------------------------
      Subtotal, Eliminate                                                                                       
       unwarranted benefits....      0.1       3.8       5.6       7.5       8.3       8.5       9.9       43.6 
                                                                                                                
Other provisions that affect                                                                                    
 receipts:                                                                                                      
  Assess fees for examination                                                                                   
   of FDIC-insured banks and                                                                                    
   bank holding companies                                                                                       
   (receipt effect)\1\.........  ........      0.1       0.1       0.1       0.1       0.1       0.1        0.5 
  Expand fees collected under                                                                                   
   the securities laws.........  ........      0.3       0.3       0.3       0.3       0.4       0.4        2.0 
  Establish IRS continuous levy  ........      0.4       0.4       0.4       0.3       0.2       0.1        1.8 
  Extend GSP and modify other                                                                                   
   trade provisions\1\.........     -0.6      -0.6      -0.5      -0.6      -0.6      -0.3   ........      -3.2 
  Increase deduction for self-                                                                                  
   employed health insurance...       -*      -0.1      -0.1      -0.2      -0.4      -0.5      -0.5       -1.9 
  Increase employee                                                                                             
   contributions to CSRS and                                                                                    
   FERS........................      0.1       0.4       0.5       0.6       0.6       0.6       0.6        3.4 
  Deter expatriation tax                                                                                        
   avoidance...................        *       0.2       0.2       0.4       0.4       0.5       0.5        2.3 
  Tighten rules for taxing                                                                                      
   foreign trusts..............      0.1       0.3       0.3       0.3       0.3       0.3       0.3        2.1 
  Extend corporate                                                                                              
   environmental tax\2\........  ........      1.0       0.6       0.7       0.7       0.7       0.8        4.5 
  Improve compliance by tax-                                                                                    
   exempt entities through                                                                                      
   intermediate sanctions and                                                                                   
   other measures..............        *         *         *         *         *         *         *          * 
[[Page 50]]
  Modify Federal pay raise                                                                                      
   (receipt effect)............  ........     -0.1      -0.1      -0.1      -0.1      -0.1      -0.1       -0.8 
  Provide tax relief to troops                                                                                  
   in Bosnia...................       -*        -*   ........  ........  ........  ........  ........        -* 
                                --------------------------------------------------------------------------------
      Subtotal, Other..........     -0.4       1.8       1.8       1.8       1.7       1.9       2.2       10.7 
                                --------------------------------------------------------------------------------
        Subtotal, Eliminate                                                                                     
         unwarranted benefits                                                                                   
         and other provisions                                                                                   
         that affect receipts..     -0.3       5.6       7.3       9.3      10.0      10.3      12.1       54.3 
                                --------------------------------------------------------------------------------
Modify earned income tax credit                                                                                 
 (EITC)........................        *       0.3       0.4       0.4       0.4       0.4       0.4        2.3 
                                ================================================================================
Total effect of proposals\1\...     -1.6     -11.7      -6.3      -7.8     -11.0     -11.6     -10.7      -60.8 
                                                                                                                
Extend expired trust fund                                                                                       
 excise taxes:                                                                                                  
  Extend superfund trust fund                                                                                   
   excise taxes\1\.............      0.1       0.7       0.7       0.7       0.7       0.7       0.7        4.2 
  Extend airport and airway                                                                                     
   trust fund taxes\1\.........      0.4       4.7       4.9       5.2       5.5       5.9       6.2       32.8 
  Extend LUST trust fund                                                                                        
   taxes\1\....................        *       0.1       0.1       0.1       0.1       0.1       0.1        0.8 
                                --------------------------------------------------------------------------------
    Total effect of extending                                                                                   
     expired trust fund excise                                                                                  
     taxes\1\..................      0.5       5.5       5.7       6.0       6.3       6.7       7.0       37.7 
----------------------------------------------------------------------------------------------------------------
*$50 million or less.                                                                                           
\1\Net of income offsets.                                                                                       
\2\Net of deductibility for income tax purposes.                                                                


[[Page 51]]
 
3.  FEDERAL RECEIPTS
---------------------------------------------------------------------------
Table 3-4.  RECEIPTS BY SOURCE------------------------------------------

(In millions of dollars)

------------------------------------------------------------------------
                                         1995        1996        1997   
               Source                   actual     estimate    estimate 
------------------------------------------------------------------------
Individual income taxes (federal                                        
 funds):                                                                
  Withheld..........................     499,927     535,566     567,153
  Proposed Legislation (PAYGO)......  ..........      -1,285     -17,201
  Other.............................     175,855     186,071     187,818
  Refunds...........................     -85,538     -89,479     -92,668
                                     -----------------------------------
Total net individual income taxes...     590,244     630,873     645,102
                                     ===================================
Corporation income taxes:                                               
  Federal funds:                                                        
    Gross Collections...............     173,810     184,632     200,143
    Proposed Legislation (PAYGO)....  ..........         136       2,113
    Refunds.........................     -17,418     -18,019     -18,510
                                     -----------------------------------
  Total Federal funds net                                               
   corporation income taxes.........     156,392     166,749     183,746
                                     -----------------------------------
  Trust funds:                                                          
    Gross Collections (Hazardous                                        
     substance superfund)...........         612         359          10
    Proposed Legislation (PAYGO)....  ..........  ..........       1,222
                                     -----------------------------------
Total net corporation income taxes..     157,004     167,108     184,978
                                     ===================================
Social insurance taxes and                                              
 contributions (trust funds):                                           
  Employment taxes and                                                  
   contributions:                                                       
    Old-age and survivors insurance                                     
     (Off-budget)...................     284,091     311,713     333,335
    Disability insurance (Off-                                          
     budget)........................      66,988      55,728      54,680
    Hospital insurance..............      96,024     101,848     108,770
    Railroad retirement:                                                
      Social Security equivalent                                        
       account......................       1,518       1,498       1,508
      Rail pension and supplemental                                     
       annuity......................       2,424       2,399       2,451
                                     -----------------------------------
  Total employment taxes and                                            
   contributions....................     451,045     473,186     500,744
                                     -----------------------------------
    On-budget.......................      99,966     105,745     112,729
    Off-budget......................     351,079     367,441     388,015
                                     -----------------------------------
  Unemployment insurance:                                               
    State taxes deposited in                                            
     Treasury\1\....................      23,158      24,047      25,006
    Federal unemployment tax                                            
     receipts\1\....................       5,696       5,739       5,806
    Railroad unemployment tax                                           
     receipts\1\....................          24          24          29
                                     -----------------------------------
  Total unemployment insurance......      28,878      29,810      30,841
                                     -----------------------------------
  Other retirement contributions:                                       
    Federal employees' retirement--                                     
     employee contributions.........       4,461       4,359       4,144
      Proposed Legislation (PAYGO)..  ..........          90         356
    Contributions for non-Federal                                       
     employees\2\...................          89          89          88
      Proposed Legislation (PAYGO)..  ..........           1           2
                                     -----------------------------------
  Total other retirement                                                
   contributions....................       4,550       4,539       4,590
                                     -----------------------------------
Total social insurance taxes and                                        
 contributions......................     484,473     507,535     536,175
                                     ===================================
  On-budget.........................     133,394     140,094     148,160
  Off-budget........................     351,079     367,441     388,015
                                     ===================================
Excise taxes:                                                           
  Federal funds:                                                        
    Alcohol taxes...................       7,216       7,189       7,173
    Tobacco taxes...................       5,878       5,872       5,796
    Transportation fuels tax........       8,491       6,920       7,162
    Telephone and teletype services.       3,794       4,010       4,241
    Ozone depleting chemicals and                                       
     products.......................         616         205          13
    Other Federal fund excise taxes.         946       1,598       1,520
      Proposed Legislation (PAYGO)..  ..........        -382           5
                                     -----------------------------------
  Total Federal fund excise taxes...      26,941      25,412      25,910
                                     -----------------------------------
  Trust funds:                                                          
    Highway.........................      22,611      24,564      24,900
      Proposed Legislation (PAYGO)..  ..........         -10           4
    Airport and airway..............       5,534       1,383  ..........
      Proposed Legislation (PAYGO)..  ..........         898       6,251
    Aquatic resources...............         306         320         325
    Black lung disability insurance.         608         620         633
    Inland waterway.................         103         125         131
    Hazardous substance superfund...         867         261  ..........
      Proposed Legislation (PAYGO)..  ..........         102         883
    Oil spill liability.............         211  ..........  ..........
      Proposed Legislation (PAYGO)..  ..........          34         294
    Vaccine injury compensation.....         138         123         123
    Leaking underground storage tank         165          41  ..........
      Proposed Legislation (PAYGO)..  ..........          13         174
                                     -----------------------------------
  Total trust funds excise taxes....      30,543      28,474      33,718
                                     -----------------------------------
Total excise taxes..................      57,484      53,886      59,628
                                     ===================================
Estate and gift taxes...............      14,763      15,924      17,067
  Proposed Legislation (PAYGO)......  ..........  ..........          10
                                     -----------------------------------
Total estate and gift taxes.........      14,763      15,924      17,077
                                     ===================================
Customs duties:                                                         
  Federal funds.....................      18,573      19,231      20,253
    Proposed Legislation (PAYGO)....  ..........        -706        -675
  Trust funds.......................         728         788         876
                                     -----------------------------------
Total customs duties................      19,301      19,313      20,454
                                     ===================================
MISCELLANEOUS RECEIPTS:\3\                                              
  Miscellaneous taxes...............         138         149         153
  United Mine Workers of America                                        
   combined benefit fund............         336         281         251
  Deposit of earnings, Federal                                          
   Reserve System...................      23,378      23,752      22,580
    Proposed Legislation (PAYGO)....  ..........  ..........          92
  Fees for permits and regulatory                                       
   and judicial services............       6,180       6,233       6,690
    Proposed Legislation (PAYGO)....  ..........  ..........         307
  Fines, penalties, and forfeitures.       1,781       1,580       1,598
  Restitutions, reparations, and                                        
   recoveries under military                                            
   occupation.......................  ..........           7           7
  Gifts and contributions...........         131         139         151
  Refunds and recoveries............  ..........          -5          -5
                                     -----------------------------------
Total miscellaneous receipts........      31,944      32,136      31,824
                                     ===================================
Total budget receipts...............   1,355,213   1,426,775   1,495,238
  On-budget.........................   1,004,134   1,059,334   1,107,223
  Off-budget........................     351,079     367,441     388,015
                                     -----------------------------------
             MEMORANDUM                                                 
  Federal funds.....................     842,214     893,132     926,831
  Trust funds.......................     326,739     355,579     377,918
  Interfund transactions............    -164,819    -189,377    -197,526
                                     -----------------------------------
Total on-budget.....................   1,004,134   1,059,334   1,107,223
                                     -----------------------------------
Off-budget (trust funds)............     351,079     367,441     388,015
[[Page 52]]
                                     ===================================
Total...............................   1,355,213   1,426,775   1,495,238
------------------------------------------------------------------------
\1\Deposits by States are State payroll taxes that cover the benefit    
  part of the program. Federal unemployment tax receipts cover          
  administrative costs at both the Federal and State level. Railroad    
  unemployment tax receipts cover both the benefits and adminstrative   
  costs of the program for the railroads.                               
\2\Represents employer and employee contributions to the civil service  
  retirement and disability fund for covered employees of Government-   
  sponsored, privately owned enterprises and the District of Columbia   
  municipal government.                                                 
\3\Includes both Federal and trust funds. Trust fund amounts in         
  miscellaneous receipts are 1995: $619 million; 1996: $575 million; and
  1997: $571 million.