[Analytical Perspectives]
[Federal Receipts and Collections]
[5. Tax Expenditures]
[From the U.S. Government Publishing Office, www.gpo.gov]


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                           5. TAX EXPENDITURES

  Tax expenditures are revenue losses due to preferential provisions of 
the Federal tax laws, such as special exclusions, exemptions, 
deductions, credits, deferrals, or tax rates. They are alternatives to 
other policy instruments, such as spending or regulatory programs, as 
means of achieving Federal policy goals. Tax expenditures are created 
for a variety of reasons: to encourage certain activities, to improve 
fairness, to ease compliance with and administration of the tax system, 
and to reduce certain tax-induced distortions. The Congressional Budget 
Act of 1974 (Public Law 93-344) requires that a list of tax expenditures 
be included in the budget.
  The largest tax expenditures tend to be associated with the individual 
income tax. For example, sizeable tax preferences are provided for 
pension contributions and earnings, employer contributions for medical 
insurance, mortgage interest payments on owner-occupied homes, capital 
gains, and payments of State and local individual income and property 
taxes. Tax expenditures under the corporate income tax tend to be 
related to the rate of cost recovery for various investments; as is 
discussed below, the extent to which these provisions are classified as 
tax expenditures varies according to the conceptual baseline used. 
Charitable contributions and credits for State taxes on bequests are the 
largest tax expenditures under the unified transfer (i.e., estate and 
gift) tax.
  Because of potential interactions among provisions, this chapter does 
not present a grand total for the revenue loss estimated from tax 
expenditures. Moreover, past tax changes entailing broad elimination of 
tax expenditures were generally accompanied by changes in tax rates or 
other basic provisions, so that the net effects on Federal revenues were 
considerably (if not totally) offset. Nevertheless, in aggregate, tax 
expenditures have revenue impacts of hundreds of billions of dollars, 
and are some of the most important ways in which the Federal Government 
affects economic decisions and social welfare.
  Tax expenditures relating to the individual and corporate income taxes 
are considered first in this chapter. They are estimated for fiscal 
years 1999-2005 using three methods of accounting: revenue loss, outlay 
equivalent, and present value. The present value approach provides 
estimates of the revenue losses for tax expenditures that involve 
deferrals of tax payments into the future or have similar long-term 
effects. Tax expenditures relating to the unified transfer tax are 
considered in a section at the end of the chapter.
  The section of the chapter on performance measures and economic 
effects presents information related to assessment of the effect of tax 
expenditures on the achievement of program performance goals. This 
section is a complement to the government-wide performance plan required 
by the Government Performance and Results Act of 1993. Tax expenditures 
are also discussed in Section V of the Budget, which considers the 
Federal Government's spending, regulatory, and tax policies across 
functional areas.

                   TAX EXPENDITURES IN THE INCOME TAX

                        Tax Expenditure Estimates

  The Treasury Department prepared all tax expenditure estimates 
presented here based upon tax law enacted as of December 31, 1999. 
Expired or repealed provisions are not listed if their revenue effects 
result only from taxpayer activity occurring before fiscal year 1999. 
Due to the time required to estimate the large number of tax 
expenditures, the estimates are based on mid-session economic 
assumptions; exceptions are the earned income tax credit and child 
credit provisions, which involve outlay components and hence are updated 
to reflect the economic assumptions used elsewhere in the budget.
  The total revenue loss estimates for tax expenditures for fiscal years 
1999-2005 are displayed according to the budget's functional categories 
in Table 5-1. Descriptions of the specific tax expenditure provisions 
follow the tables of estimates and discussion of general features of the 
tax expenditure concept.
  As in prior years, two baseline concepts--the normal tax baseline and 
the reference tax law baseline--are used to identify tax expenditures. 
For the most part, the two concepts coincide. However, items treated as 
tax expenditures under the normal tax baseline, but not the reference 
tax law baseline, are indicated by the designation ``normal tax method'' 
in the tables. The revenue losses for these items are zero using the 
reference tax rules. The alternative baseline concepts are discussed in 
detail following the tables.
  Table 5-2 reports the respective portions of the total revenue losses 
that arise under the individual and corporate income taxes. Listing 
revenue loss estimates under the individual and corporate headings does 
not imply that these categories of filers benefit from the special tax 
provisions in proportion to the respective tax expenditure amounts 
shown. Rather, these breakdowns show the specific tax accounts through 
which the various provisions are cleared. The ultimate beneficiaries of 
corporate tax expenditures could be stock

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holders, employees, customers, or others, depending on economic forces.
  Table 5-3 ranks the major tax expenditures by fiscal year 2001 revenue 
loss. This table merges several individual entries provided in Table 5-
1; for example, Table 5-3 contains one merged entry for charitable 
contributions instead of the three separate entries found in Table 5-1.

                 Interpreting Tax Expenditure Estimates

  The revenue loss estimates shown for individual tax expenditures in 
Tables 5-1, 5-2, and 5-3 do not necessarily equal the increase in 
Federal revenues (or the change in the budget balance) that would result 
from repealing these special provisions, for the following reasons:
  Eliminating a tax expenditure may have incentive effects that alter 
economic behavior. These incentives can affect the resulting magnitudes 
of the formerly subsidized activity or of other tax preferences or 
Government programs. For example, if deductibility of mortgage interest 
were limited, some taxpayers would hold smaller mortgages, with a 
concomitantly smaller effect on the budget than if no such limits were 
in force.
  Tax expenditures are interdependent even without incentive effects. 
Repeal of a tax expenditure provision can increase or decrease the 
revenue losses associated with other provisions. For example, even if 
behavior does not change, repeal of an itemized deduction could increase 
the revenue losses from other deductions because some taxpayers would be 
moved into higher tax brackets. Alternatively, repeal of an itemized 
deduction could lower the revenue loss from other deductions if 
taxpayers are led to claim the standard deduction instead of itemizing. 
Similarly, if two provisions were repealed simultaneously, the increase 
in tax liability could be greater or less than the sum of the two 
separate tax expenditures, because each is estimated assuming that the 
other remains in force. In addition, the estimates reported in Table 5-1 
are the totals of individual and corporate income tax revenue losses 
reported in Table 5-2 and do not reflect any possible interactions 
between the individual and corporate income tax receipts. For this 
reason, the estimates in Table 5-1 (as well as those in Table 5-5, which 
are also based on summing individual and corporate estimates) should be 
regarded as approximations.
  Revenues raised by changes to tax expenditures are sensitive to timing 
effects and effective dates. Changes in some provisions could yield 
their full potential revenue gains relatively quickly, whereas changes 
to other provisions would only gradually yield their full revenue 
potential, especially if certain deductions or exemptions were 
grandfathered.
  The annual value of tax expenditures for tax deferrals is reported on 
a cash basis in all tables except Table 5-4. Cash-based estimates 
reflect the difference between taxes deferred in the current year and 
incoming revenues that are received due to deferrals of taxes from prior 
years. Although such estimates are useful as a measure of cash flows 
into the Government, they do not accurately reflect the true economic 
cost of these provisions. For example, for a provision where activity 
levels have changed, so that incoming tax receipts from past deferrals 
are greater than deferred receipts from new activity, the cash-basis tax 
expenditure estimate can be negative, despite the fact that in present-
value terms current deferrals do have a real cost to the Government. 
Alternatively, in the case of a newly enacted deferral provision, a 
cash-based estimate can overstate the real cost to the Government 
because the newly deferred taxes will ultimately be received. Present-
value estimates, which are a useful supplement to the cash-basis 
estimates for provisions involving deferrals, are discussed below.
  Repeal on major tax provisions may have some impact on overall levels 
of income and rates of economic growth and, thus, on the budget economic 
assumptions. In practice, however, most changes in particular provisions 
are unlikely to have significant macroeconomic effects.

                         Present-Value Estimates

  Discounted present-value estimates of revenue losses are presented in 
Table 5-4 for provisions that involve tax deferrals or other long-term 
revenue effects. These estimates complement the cash-based tax 
expenditure estimates presented in the other tables.
  The present-value estimates represent the revenue losses, net of 
future tax payments, that follow from activities undertaken during 
calendar year 1999 which cause the deferrals or other long-term revenue 
effects. For instance, a pension contribution in 1999 would cause a 
deferral of tax payments on wages in 1999 and on pension earnings on 
this contribution (e.g., interest) in later years. In some future year, 
however, the 1999 pension contribution and accrued earnings would be 
paid out and taxes would be due; these receipts are included in the 
present-value estimate. In general, this conceptual approach is similar 
to the one used for reporting the budgetary effects of credit programs, 
where direct loans and guarantees in a given year affect future cash 
flows.

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                                     Table 5-1.  TOTAL REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX
                                                                (In millions of dollars)
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                  Total revenue loss from corporate and individual Income taxes
                                                                        --------------------------------------------------------------------------------
                                                                           1999      2000      2001      2002      2003      2004      2005    2001-2005
--------------------------------------------------------------------------------------------------------------------------------------------------------
              National Defense
       1       Exclusion of benefits and allowances to armed forces         2,120     2,140     2,160     2,180     2,200     2,220     2,240    11,000
                personnel..............................................

              International affairs:
       2       Exclusion of income earned abroad by U.S. citizens......     2,330     2,550     2,790     3,040     3,285     3,545     3,825    16,485
       3       Exclusion of certain allowances for Federal employees          635       665       695       725       760       795       830     3,805
                abroad.................................................
       4       Exclusion of income of foreign sales corporations.......     3,640     3,890     4,160     4,460     4,770     5,100     5,460    23,950
       5       Inventory property sales source rules exception.........     1,050     1,100     1,150     1,250     1,350     1,450     1,550     6,750
       6       Deferral of income from controlled foreign corporations      5,800     6,200     6,600     7,000     7,450     7,900     8,400    37,350
                (normal tax method)....................................
       7       Deferred taxes for financial firms on certain income           960     1,190     1,290       540         0         0         0     1,830
                earned overseas........................................

              General science, space, and technology:
       8       Expensing of research and experimentation expenditures       1,890     1,865     1,885     1,965     2,090     2,245     2,410    10,595
                (normal tax method)....................................
       9       Credit for increasing research activities...............     1,705     1,010     3,360     3,710     2,970     2,605     1,505    14,150

              Energy:
      10       Expensing of exploration and development costs, fuels...       -80       -15       -30       -10        15        15        15         5
      11       Excess of percentage over cost depletion, fuels.........       265       275       280       280       285       290       290     1,425
      12       Alternative fuel production credit......................     1,025       960       905       845       125       125       125     2,125
      13       Exception from passive loss limitation for working              30        25        25        25        25        25        25       125
                interests in oil and gas properties....................
      14       Capital gains treatment of royalties on coal............        65        65        70        70        75        80        85       380
      15       Exclusion of interest on energy facility bonds..........       115       115       115       120       120       120       120       595
      16       Enhanced oil recovery credit............................       225       260       295       340       390       450       515     1,990
      17       New technology credit...................................        50        60        80        90        90        90        85       435
      18       Alcohol fuel credits \1\................................        15        15        15        15        15        15        15        75
      19       Tax credit and deduction for clean-fuel burning vehicles        85        90       105       100        80        55        20       360
      20       Exclusion from income of conservation subsidies provided        85        80        80        80        85        85        85       415
                by public utilities....................................

              Natural resources and environment:
      21       Expensing of exploration and development costs, nonfuel         15        15        20        20        20        20        20       100
                minerals...............................................
      22       Excess of percentage over cost depletion, nonfuel              225       230       245       250       265       275       285     1,320
                minerals...............................................
      23       Exclusion of interest on bonds for water, sewage, and          460       460       470       475       480       480       490     2,395
                hazardous waste facilities.............................
      24       Capital gains treatment of certain timber income........        65        65        70        70        75        80        85       380
      25       Expensing of multiperiod timber growing costs...........       495       500       530       565       590       605       630     2,920
      26       Investment credit and seven-year amortization for               10        10        10        15        15        15        15        70
                reforestation expenditures.............................
      27       Tax incentives for preservation of historic structures..       210       220       240       250       265       280       295     1,330

              Agriculture:
      28       Expensing of certain capital outlays....................        70        70        75        75        80        85        90       405
      29       Expensing of certain multiperiod production costs.......        85        85        90        95       105       110       110       510
      30       Treatment of loans forgiven for solvent farmers.........        10        10        10        10        10        10        10        50
      31       Capital gains treatment of certain income...............       635       665       695       725       760       795       830     3,805
      32       Income averaging for farmers............................        75        75        80        80        80        85        85       410
      33       Deferral of gain on sale of farm refiners...............        10        10        10        10        15        15        15        65

              Commerce and housing:
               Financial institutions and insurance:
      34        Exemption of credit union income.......................     1,470     1,550     1,650     1,765     1,890     2,020     2,155     9,480
      35        Excess bad debt reserves of financial institutions.....        60        65        55        45        35        20         5       160
      36        Exclusion of interest on life insurance savings........    13,920    14,985    16,130    17,365    18,870    20,130    21,680    94,175
      37        Special alternative tax on small property and casualty          5         5         5         5         5         5         5        25
                 insurance companies...................................
      38        Tax exemption of certain insurance companies owned by         220       225       235       240       250       255       265     1,245
                 tax-exempt organizations..............................
      39        Small life insurance company deduction.................       100       100       100       100       100       105       105       510
               Housing:
      40        Exclusion of interest on owner-occupied mortgage              905       915       920       930       940       950       955     4,695
                 subsidy bonds.........................................
      41        Exclusion of interest on rental housing bonds..........       155       155       160       160       160       160       160       800
      42        Deductibility of mortgage interest on owner-occupied       56,920    58,815    60,925    63,240    65,955    68,965    72,160   331,245
                 homes.................................................
      43        Deductibility of State and local property tax on owner-    21,215    22,185    23,075    24,000    24,980    25,915    26,840   124,810
                 occupied homes........................................
      44        Deferral of income from post-1987 installment sales....       995     1,015     1,035     1,055     1,075     1,095     1,115     5,375
      45        Capital gains exclusion on home sales..................    18,000    18,540    19,095    19,670    20,260    20,870    21,495   101,390
      46        Exception from passive loss rules for $25,000 of rental     5,315     5,035     4,790     4,555     4,330     4,100     3,885    21,660
                 loss..................................................
      47        Credit for low-income housing investments..............     2,820     3,055     3,195     3,300     3,405     3,485     3,540    16,925
      48        Accelerated depreciation on rental housing (normal tax      3,710     3,985     4,225     4,500     4,765     4,975     5,145    23,610
                 method)...............................................
               Commerce:
      49        Cancellation of indebtedness...........................        40        25        15        15        20        20        25        95
      50        Exceptions from imputed interest rules.................       160       160       160       165       165       165       165       820
      51        Capital gains (except agriculture, timber, iron ore,       39,405    40,575    41,780    43,025    44,300    45,615    46,965   221,685
                 and coal) (normal tax method).........................
      52        Capital gains exclusion of small corporation stock.....         5         5         5         5         5         5         5        25
      53        Step-up basis of capital gains at death................    25,800    27,090    28,240    29,370    30,545    31,765    33,035   152,955
      54        Carryover basis of capital gains on gifts..............       175       185       195       205       210       220       230     1,060
      55        Ordinary income treatment of loss from small business          35        35        40        40        40        40        40       200
                 corporation stock sale................................

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      56        Accelerated depreciation of buildings other than rental     1,660       710      -435      -755    -1,115    -1,695    -2,145    -6,145
                 housing (normal tax method)...........................
      57        Accelerated depreciation of machinery and equipment        26,445    27,740    32,830    33,345    34,265    36,390    37,330   174,160
                 (normal tax method)...................................
      58        Expensing of certain small investments (normal tax          1,465     1,590     1,925     1,965     1,920     1,895     1,905     9,610
                 method)...............................................
      59        Amortization of start-up costs (normal tax method).....       200       205       205       215       215       220       225     1,080
      60        Graduated corporation income tax rate (normal tax           6,360     6,300     6,275     6,460     6,490     6,710     6,815    32,750
                 method)...............................................
      61        Exclusion of interest on small issue bonds.............       310       315       315       320       320       325       330     1,610

              Transportation:
      62       Deferral of tax on shipping companies...................        15        15        15        15        15        15        15        75
      63       Exclusion of reimbursed employee parking expenses.......     1,725     1,805     1,895     1,995     2,100     2,210     2,330    10,530
      64       Exclusion for employer-provided transit passes..........       130       150       170       190       215       235       260     1,070

              Community and regional development:
      65       Investment credit for rehabilitation of structures              25        25        30        30        30        30        30       150
                (other than historic)..................................
      66       Exclusion of interest for airport, dock, and similar           730       735       740       750       755       765       770     3,780
                bonds..................................................
      67       Exemption of certain mutuals' and cooperatives' income..        60        60        60        65        65        65        70       325
      68       Empowerment zones and enterprise communities............       330       445       500       465       330       300       260     1,855
      69       Expensing of environmental remediation costs............       115       150       175        60       -30       -35       -30       140

              Education, training, employment, and social services:
               Education:
      70        Exclusion of scholarship and fellowship income (normal      1,085     1,110     1,120     1,130     1,140     1,150     1,165     5,705
                 tax method)...........................................
      71        HOPE tax credit........................................     4,595     4,925     5,125     5,145     4,745     4,615     5,335    24,965
      72        Lifetime Learning tax credit...........................     2,170     2,375     2,420     2,465     4,405     4,430     4,630    18,350
      73        Education Individual Retirement Accounts...............         0        10        25        40        60        80       105       310
      74        Deductibility of student-loan interest.................       240       265       310       350       375       395       430     1,860
      75        Deferral for State prepaid tuition plans...............       120       175       225       275       320       350       385     1,555
      76        Exclusion of interest on student-loan bonds............       245       250       255       255       255       260       260     1,285
      77        Exclusion of interest on bonds for private nonprofit          590       595       600       600       610       615       620     3,045
                 educational facilities................................
      78        Credit for holders of zone academy bonds...............         5        10        20        35        50        65        70       240
      79        Exclusion of interest on savings bonds redeemed to             10        15        15        15        15        20        20        85
                 finance educational expenses..........................
      80        Parental personal exemption for students age 19 or over       915       965     1,015     1,055     1,105     1,155     1,185     5,515
      81        Child credit \2\.......................................    19,435    19,575    19,480    18,970    18,155    17,535    16,855    90,995
      82        Deductibility of charitable contributions (education)..     2,525     2,650     2,765     2,910     3,035     3,140     3,300    15,150
      83        Exclusion of employer-provided educational assistance..       220       235       250       175         0         0         0       425
               Training, employment, and social services:
      84        Work opportunity tax credit............................       270       455       465       350       215        95        35     1,160
      85        Welfare-to-work tax credit.............................        35        60        80        80        60        25        10       255
      86        Exclusion of employer-provided child care..............       645       670       700       725       765       805       850     3,845
      87        Adoption assistance....................................       125       140       140       125        40        15        10       330
      88        Exclusion of employee meals and lodging (other than           650       680       710       740       775       810       845     3,880
                 military).............................................
      89        Credit for child and dependent care expenses...........     2,420     2,390     2,360     2,330     2,305     2,275     2,250    11,520
      90        Credit for disabled access expenditures................        50        50        55        55        55        60        60       285
      91        Expensing of costs of removing certain architectural            0         0         5         5         5         5         5        25
                 barriers to the handicapped...........................
      92        Deductibility of charitable contributions, other than      19,220    20,015    20,860    21,780    22,750    23,765    24,895   114,050
                 education and health..................................
      93        Exclusion of certain foster care payments..............        35        40        40        45        45        50        50       230
      94        Exclusion of parsonage allowances......................       320       340       365       390       415       445       475     2,090

              Health:
      95       Exclusion of employer contributions for medical             69,610    75,095    80,570    86,175    90,655    95,960   102,725   456,085
                insurance premiums and medical care....................
      96       Self-employed medical insurance premiums................       935     1,250     1,380     1,545     2,070     2,905     3,210    11,110
      97       Workers' compensation insurance premiums................     4,420     4,585     4,555     4,935     5,120     5,315     5,515    25,440
      98       Medical Savings Accounts................................        20        30        30        30        30        30        25       145
      99       Deductibility of medical expenses.......................     3,695     3,910     4,160     4,440     4,720     5,005     5,305    23,630
     100       Exclusion of interest on hospital construction bonds....     1,210     1,225     1,235     1,250     1,265     1,275     1,290     6,315
     101        Deductibility of charitable contributions (health).....     2,675     2,800     2,930     3,080     3,210     3,315     3,490    16,025
     102        Tax credit for orphan drug research....................        70        80        90       100       115       130       140       575
     103        Special Blue Cross/Blue Shield deduction...............       245       315       200       135       180       245       315     1,075

              Income security:
     104       Exclusion of railroad retirement system benefits........       395       405       410       415       420       430       430     2,105
     105        Exclusion of workers' compensation benefits............     5,185     5,330     5,785     6,040     6,310     6,575     6,865    31,575
     106        Exclusion of public assistance benefits (normal tax           345       360       375       390       405       420       435     2,025
                method)................................................
     107        Exclusion of special benefits for disabled coal miners.        75        75        70        70        65        60        55       320
     108        Exclusion of military disability pensions..............       130       130       135       140       140       145       150       710
               Net exclusion of pension contributions and earnings:
     109        Employer plans.........................................    83,780    88,830    92,390    97,085   102,575   108,020   113,705   513,775
     110        Individual Retirement Accounts.........................    13,350    15,050    15,975    17,030    17,630    18,250    18,750    87,635
     111        Keogh plans............................................     5,230     5,550     5,895     6,255     6,635     7,040     7,465    33,290
               Exclusion of other employee benefits:

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     112        Premiums on group term life insurance..................     1,700     1,740     1,780     1,820     1,860     1,915     1,970     9,345
      13        Premiums on accident and disability insurance..........       185       195       205       215       225       235       245     1,125
     114        Income of trusts to finance supplementary unemployment          0         0         0         5         5         5         5        20
                benefits...............................................
     115        Special ESOP rules.....................................     1,130     1,175     1,205     1,250     1,300     1,360     1,425     6,540
     116        Additional deduction for the blind.....................        30        30        30        30        35        35        35       165
     117        Additional deduction for the elderly...................     1,785     1,830     1,890     1,955     1,985     2,030     2,110     9,970
     118        Tax credit for the elderly and disabled................        35        35        35        35        35        35        35       175
     119        Deductibility of casualty losses.......................       255       265       275       285       295       310       325     1,490
     120        Earned income tax credit \3\...........................     4,825     4,700     4,790     4,985     5,205     5,440     5,740    26,160

              Social Security:
               Exclusion of social security benefits:
     121        Social Security benefits for retired workers...........    17,135    18,010    18,885    19,995    21,230    22,505    16,515    99,130
     122        Social Security benefits for disabled..................     2,390     2,595     2,830     3,090     3,375     3,700     3,150    16,145
     123        Social Security benefits for dependents and survivors..     3,775     3,900     4,050     4,210     4,385     4,555     3,625    20,825

              Veterans benefits and services:
     124       Exclusion of veterans death benefits and disability          2,940     3,070     3,200     3,335     3,490     3,655     3,830    17,510
                compensation...........................................
     125        Exclusion of veterans pensions.........................        65        70        75        80        85        85        90       415
     126        Exclusion of GI bill benefits..........................        75        85        90        90        95       100       105       480
     127        Exclusion of interest on veterans housing bonds........        40        40        40        40        40        40        40       200

              General purpose fiscal assistance:
     128       Exclusion of interest on public purpose bonds...........    22,750    22,975    23,205    23,440    23,670    23,905    24,145   118,365
     129       Deductibility of nonbusiness State and local taxes other    37,740    40,240    42,390    44,735    47,610    50,530    53,480   238,745
                than on owner-occupied homes...........................
     130       Tax credit for corporations receiving income from doing      2,515     2,590     2,670     2,600     2,550     2,600     2,650    13,070
                business in U.S. possessions...........................

              Interest:
     131       Deferral of interest on U.S. savings bonds..............     1,015     1,065     1,115     1,175     1,235     1,295     1,355     6,175

              Addendum: Aid to State and local governments:
               Deductibility of:
                Property taxes on owner-occupied homes.................    21,215    22,185    23,075    24,000    24,980    25,915    26,840   124,810
                Nonbusiness State and local taxes other than on owner-     37,740    40,240    42,390    44,735    47,610    50,530    53,480   238,745
                 occupied homes
               Exclusion of interest on State and local bonds for:
                Public purposes........................................    22,750    22,975    23,205    23,440    23,670    23,905    24,145   118,365
                Energy facilities......................................       115       115       115       120       120       120       120       595
                Water, sewage, and hazardous waste disposal facilities.       460       460       470       475       480       480       490     2,395
                Small-issues...........................................       310       315       315       320       320       325       330     1,610
                Owner-occupied mortgage subsidies......................       905       915       920       930       940       950       955     4,695
                Rental housing.........................................       155       155       160       160       160       160       160       800
                Airports, docks, and similar facilities................       730       735       740       750       755       765       770     3,780
                Student loans..........................................       245       250       255       255       255       260       260     1,285
                Private nonprofit educational facilities...............       590       595       600       600       610       615       620     3,045
                Hospital construction..................................     1,210     1,225     1,235     1,250     1,265     1,275     1,290     6,315
                Veterans' housing......................................        40        40        40        40        40        40        40       200
               Credit for holders of zone academy bonds................         5        10        20        35        50        65        70       240
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ In addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise tax receipts (in millions of dollars) as
  follows: 1999 $760; 2000 $800; 2001 $805; 2002 $810; 2003 $815; 2004 $825; and 2005 $830.

\2\ The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999
  $445; 2000 $550; 2001 $520; 2002 $505; 2003 $460; 2004 $450; and 2005 $420.

\3\ The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on outlays (in millions of dollars) is as
  follows: 1999 $25,632; 2000 $25,676; 2001 $25,799; 2002 $26,876; 2003 $27,638; 2004 $28,701; and 2005 $29,722.

Note: Provisions with estimates denoted normal tax method have no revenue loss under the reference tax law method. All estimates have been rounded to
  the nearest $5 million. Provisions with estimates that rounded to zero in each year are not included in the table.


[[Page 112]]


                                                                       Table 5-2.  CORPORATE AND INDIVIDUAL INCOME TAX REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES
                                                                                                        (In millions of dollars)
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                                                                                         Revenue Loss
                                                                                    ----------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                                                   Corporations                                                               Individuals
                                                                                    ----------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                                                                                      2001-                                                                       2001-
                                                                                       1999     2000     2001     2002     2003     2004     2005     2005      1999     2000     2001     2002     2003      2004      2005      2005
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
             National Defense
       1       Exclusion of benefits and allowances to armed forces personnel......  .......  .......  .......  .......  .......  .......  .......  ........    2,120    2,140    2,160    2,180     2,200     2,220     2,240    11,000

             International affairs:
       2       Exclusion of income earned abroad by U.S. citizens..................  .......  .......  .......  .......  .......  .......  .......  ........    2,330    2,550    2,790    3,040     3,285     3,545     3,825    16,485
       3       Exclusion of certain allowances for Federal employees abroad........  .......  .......  .......  .......  .......  .......  .......  ........      635      665      695      725       760       795       830     3,805
       4       Exclusion of income of foreign sales corporations...................    3,640    3,890    4,160    4,460    4,770    5,100    5,460    23,950  .......  .......  .......  .......  ........  ........  ........  ........
       5       Inventory property sales source rules exception.....................    1,050    1,100    1,150    1,250    1,350    1,450    1,550     6,750  .......  .......  .......  .......  ........  ........  ........  ........
       6       Deferral of income from controlled foreign corporations (normal tax     5,800    6,200    6,600    7,000    7,450    7,900    8,400    37,350  .......  .......  .......  .......  ........  ........  ........  ........
                method)............................................................
       7       Deferred taxes for financial firms on certain income earned overseas      960    1,190    1,290      540        0        0        0     1,830  .......  .......  .......  .......  ........  ........  ........  ........

             General science, space, and technology:
       8       Expensing of research and experimentation expenditures (normal tax      1,855    1,830    1,850    1,925    2,050    2,200    2,365    10,390       35       35       35       40        40        45        45       205
                method)............................................................
       9       Credit for increasing research activities...........................    1,675      995    3,300    3,650    2,925    2,565    1,490    13,930       30       15       60       60        45        40        15       220

             Energy:
      10       Expensing of exploration and development costs, fuels...............      -70      -15      -30      -10       15       15       15         5      -10        0        0        0         0         0         0         0
      11       Excess of percentage over cost depletion, fuels.....................      220      225      230      230      235      240      240     1,175       45       50       50       50        50        50        50       250
      12       Alternative fuel production credit..................................      975      915      860      805      125      125      125     2,040       50       45       45       40         0         0         0        85
      13       Exception from passive loss limitation for working interests in oil   .......  .......  .......  .......  .......  .......  .......  ........       30       25       25       25        25        25        25       125
                and gas properties.................................................
      14       Capital gains treatment of royalties on coal........................  .......  .......  .......  .......  .......  .......  .......  ........       65       65       70       70        75        80        85       380
      15       Exclusion of interest on energy facility bonds......................       30       30       30       30       30       30       30       150       85       85       85       90        90        90        90       445
      16       Enhanced oil recovery credit........................................      205      235      270      310      355      410      470     1,815       20       25       25       30        35        40        45       175
      17       New technology credit...............................................       45       50       60       70       70       70       65       335        5       10       20       20        20        20        20       100
      18       Alcohol fuel credits \1\............................................       10       10       10       10       10       10       10        50        5        5        5        5         5         5         5        25
      19       Tax credit and deduction for clean-fuel burning vehicles............       70       75       85       80       65       45       15       290       15       15       20       20        15        10         5        70
      20       Exclusion from income of conservation subsidies provided by public         -5       -5       -5       -5        0        0        0       -10       90       85       85       85        85        85        85       425
                utilities..........................................................

             Natural resources and environment:
      21       Expensing of exploration and development costs, nonfuel minerals....       10       10       15       15       15       15       15        75        5        5        5        5         5         5         5        25
      22       Excess of percentage over cost depletion, nonfuel minerals..........      180      185      195      200      210      220      230     1,055       45       45       50       50        55        55        55       265
      23       Exclusion of interest on bonds for water, sewage, and hazardous           115      115      120      120      120      120      125       605      345      345      350      355       360       360       365     1,790
                waste facilities...................................................
      24       Capital gains treatment of certain timber income....................  .......  .......  .......  .......  .......  .......  .......  ........       65       65       70       70        75        80        85       380
      25       Expensing of multiperiod timber growing costs.......................      305      310      330      350      365      375      390     1,810      190      190      200      215       225       230       240     1,110
      26       Investment credit and seven-year amortization for reforestation       .......  .......  .......  .......  .......  .......  .......  ........       10       10       10       15        15        15        15        70
                expenditures.......................................................
      27       Tax incentives for preservation of historic structures..............      170      180      195      205      215      230      240     1,085       40       40       45       45        50        50        55       245

             Agriculture:
      28       Expensing of certain capital outlays................................       10       10       10       10       10       10       10        50       60       60       65       65        70        75        80       355
      29       Expensing of certain multiperiod production costs...................       10       10       10       10       15       15       15        65       75       75       80       85        90        95        95       445
      30       Treatment of loans forgiven for solvent farmers.....................  .......  .......  .......  .......  .......  .......  .......  ........       10       10       10       10        10        10        10        50
      31       Capital gains treatment of certain income...........................  .......  .......  .......  .......  .......  .......  .......  ........      635      665      695      725       760       795       830     3,805
      32       Income averaging for farmers........................................  .......  .......  .......  .......  .......  .......  .......  ........       75       75       80       80        80        85        85       410
      33       Deferral of gain on sale of farm refiners...........................       10       10       10       10       15       15       15        65

             Commerce and housing:
               Financial institutions and insurance:
      34        Exemption of credit union income...................................    1,470    1,550    1,650    1,765    1,890    2,020    2,155     9,480  .......  .......  .......  .......  ........  ........  ........  ........
      35        Excess bad debt reserves of financial institutions.................       60       65       55       45       35       20        5       160  .......  .......  .......  .......  ........  ........  ........  ........

[[Page 113]]


      36        Exclusion of interest on life insurance savings....................      420      450      485      520      565      605      650     2,825   13,500   14,535   15,645   16,845    18,305    19,525    21,030    91,350
      37        Special alternative tax on small property and casualty insurance           5        5        5        5        5        5        5        25  .......  .......  .......  .......  ........  ........  ........  ........
                 companies.........................................................
      38        Tax exemption of certain insurance companies owned by tax-exempt         220      225      235      240      250      255      265     1,245  .......  .......  .......  .......  ........  ........  ........  ........
                 organizations.....................................................
      39        Small life insurance company deduction.............................      100      100      100      100      100      105      105       510  .......  .......  .......  .......  ........  ........  ........  ........
               Housing:
      40        Exclusion of interest on owner-occupied mortgage subsidy bonds.....      230      230      230      235      235      240      240     1,180      675      685      690      695       705       710       715     3,515
      41        Exclusion of interest on rental housing bonds......................       40       40       40       40       40       40       40       200      115      115      120      120       120       120       120       600
      42        Deductibility of mortgage interest on owner-occupied homes.........  .......  .......  .......  .......  .......  .......  .......  ........   56,920   58,815   60,925   63,240    65,955    68,965    72,160   331,245
      43        Deductibility of State and local property tax on owner-occupied      .......  .......  .......  .......  .......  .......  .......  ........   21,215   22,185   23,075   24,000    24,980    25,915    26,840   124,810
                 homes.............................................................
      44        Deferral of income from post-1987 installment sales................      260      265      270      275      280      285      290     1,400      735      750      765      780       795       810       825     3,975
      45        Capital gains exclusion on home sales..............................  .......  .......  .......  .......  .......  .......  .......  ........   18,000   18,540   19,095   19,670    20,260    20,870    21,495   101,390
      46        Exception from passive loss rules for $25,000 of rental loss.......  .......  .......  .......  .......  .......  .......  .......  ........    5,315    5,035    4,790    4,555     4,330     4,100     3,885    21,660
      47        Credit for low-income housing investments..........................    2,115    2,290    2,395    2,475    2,555    2,615    2,655    12,695      705      765      800      825       850       870       885     4,230
      48        Accelerated depreciation on rental housing (normal tax method).....      110      120      135      160      180      200      230       905    3,600    3,865    4,090    4,340     4,585     4,775     4,915    22,705
               Commerce:
      49        Cancellation of indebtedness.......................................  .......  .......  .......  .......  .......  .......  .......  ........       40       25       15       15        20        20        25        95
      50        Exceptions from imputed interest rules.............................  .......  .......  .......  .......  .......  .......  .......  ........      160      160      160      165       165       165       165       820
      51        Capital gains (except agriculture, timber, iron ore, and coal)       .......  .......  .......  .......  .......  .......  .......  ........   39,405   40,575   41,780   43,025    44,300    45,615    46,965   221,685
                 (normal tax method)...............................................
      52        Capital gains exclusion of small corporation stock.................  .......  .......  .......  .......  .......  .......  .......  ........        5        5        5        5         5         5         5        25
      53        Step-up basis of capital gains at death............................  .......  .......  .......  .......  .......  .......  .......  ........   25,800   27,090   28,240   29,370    30,545    31,765    33,035   152,955
      54        Carryover basis of capital gains on gifts..........................  .......  .......  .......  .......  .......  .......  .......  ........      175      185      195      205       210       220       230     1,060
      55        Ordinary income treatment of loss from small business corporation    .......  .......  .......  .......  .......  .......  .......  ........       35       35       40       40        40        40        40       200
                 stock sale........................................................
      56        Accelerated depreciation of buildings other than rental housing        1,195      655      230       15     -260     -625     -905    -1,545      465       55     -665     -770      -855    -1,070    -1,240    -4,600
                 (normal tax method)...............................................
      57        Accelerated depreciation of machinery and equipment (normal tax       21,100   22,085   26,970   27,265   27,965   29,825   30,465   142,490    5,345    5,655    5,860    6,080     6,300     6,565     6,865    31,670
                 method)...........................................................
      58        Expensing of certain small investments (normal tax method).........      395      490      630      665      630      625      645     3,195    1,070    1,100    1,295    1,300     1,290     1,270     1,260     6,415
      59        Amortization of start-up costs (normal tax method).................      120      125      125      130      130      135      135       655       80       80       80       85        85        85        90       425
      60        Graduated corporation income tax rate (normal tax method)..........    6,360    6,300    6,275    6,460    6,490    6,710    6,815    32,750  .......  .......  .......  .......  ........  ........  ........  ........
      61        Exclusion of interest on small issue bonds.........................       80       80       80       80       80       80       85       405      230      235      235      240       240       245       245     1,205

             Transportation:
      62       Deferral of tax on shipping companies...............................       15       15       15       15       15       15       15        75  .......  .......  .......  .......  ........  ........  ........  ........
      63       Exclusion of reimbursed employee parking expenses...................  .......  .......  .......  .......  .......  .......  .......  ........    1,725    1,805    1,895    1,995     2,100     2,210     2,330    10,530
      64       Exclusion for employer-provided transit passes......................  .......  .......  .......  .......  .......  .......  .......  ........      130      150      170      190       215       235       260     1,070

             Community and regional development:
      65       Investment credit for rehabilitation of structures (other than             15       15       15       15       15       15       15        75       10       10       15       15        15        15        15        75
                historic)..........................................................
      66       Exclusion of interest for airport, dock, and similar bonds..........      185      185      185      190      190      195      195       955      545      550      555      560       565       570       575     2,825
      67       Exemption of certain mutuals' and cooperatives' income..............       60       60       60       65       65       65       70       325  .......  .......  .......  .......  ........  ........  ........  ........
      68       Empowerment zones and enterprise communities........................      150      205      220      185      130      110       90       735      180      240      280      280       200       190       170     1,120
      69       Expensing of environmental remediation costs........................       95      125      145       50      -25      -30      -25       115       20       25       30       10        -5        -5        -5        25


[[Page 114]]


             Education, training, employment, and social services:
               Education:
      70        Exclusion of scholarship and fellowship income (normal tax method).  .......  .......  .......  .......  .......  .......  .......  ........    1,085    1,110    1,120    1,130     1,140     1,150     1,165     5,705
      71        HOPE tax credit....................................................  .......  .......  .......  .......  .......  .......  .......  ........    4,595    4,925    5,125    5,145     4,745     4,615     5,335    24,965
      72        Lifetime Learning tax credit.......................................  .......  .......  .......  .......  .......  .......  .......  ........    2,170    2,375    2,420    2,465     4,405     4,430     4,630    18,350
      73        Education Individual Retirement Accounts...........................  .......  .......  .......  .......  .......  .......  .......  ........        0       10       25       40        60        80       105       310
      74        Deductibility of student-loan interest.............................  .......  .......  .......  .......  .......  .......  .......  ........      240      265      310      350       375       395       430     1,860
      75        Deferral for State prepaid tuition plans...........................  .......  .......  .......  .......  .......  .......  .......  ........      120      175      225      275       320       350       385     1,555
      76        Exclusion of interest on student-loan bonds........................       60       65       65       65       65       65       65       325      185      185      190      190       190       195       195       960
      77        Exclusion of interest on bonds for private nonprofit educational         150      150      150      150      155      155      155       765      440      445      450      450       455       460       465     2,280
                 facilities........................................................
      78        Credit for holders of zone academy bonds...........................        5       10       20       35       50       65       70       240  .......  .......  .......  .......  ........  ........  ........  ........
      79        Exclusion of interest on savings bonds redeemed to finance           .......  .......  .......  .......  .......  .......  .......  ........       10       15       15       15        15        20        20        85
                 educational expenses..............................................
      80        Parental personal exemption for students age 19 or over............  .......  .......  .......  .......  .......  .......  .......  ........      915      965    1,015    1,055     1,105     1,155     1,185     5,515
      81        Child credit \2\...................................................  .......  .......  .......  .......  .......  .......  .......  ........   19,435   19,575   19,480   18,970    18,155    17,535    16,855    90,995
      82        Deductibility of charitable contributions (education)..............      485      515      545      595      615      610      650     3,015    2,040    2,135    2,220    2,315     2,420     2,530     2,650    12,135
      83        Exclusion of employer-provided educational assistance..............  .......  .......  .......  .......  .......  .......  .......  ........      220      235      250      175         0         0         0       425
               Training, employment, and social services:
      84        Work opportunity tax credit........................................      230      385      395      300      185       80       30       990       40       70       70       50        30        15         5       170
      85        Welfare-to-work tax credit.........................................       30       50       65       70       50       20       10       215        5       10       15       10        10         5         0        40
      86        Exclusion of employer-provided child care..........................  .......  .......  .......  .......  .......  .......  .......  ........      645      670      700      725       765       805       850     3,845
      87        Adoption assistance................................................  .......  .......  .......  .......  .......  .......  .......  ........      125      140      140      125        40        15        10       330
      88        Exclusion of employee meals and lodging (other than military)......  .......  .......  .......  .......  .......  .......  .......  ........      650      680      710      740       775       810       845     3,880
      89        Credit for child and dependent care expenses.......................  .......  .......  .......  .......  .......  .......  .......  ........    2,420    2,390    2,360    2,330     2,305     2,275     2,250    11,520
      90        Credit for disabled access expenditures............................       15       15       15       15       15       15       15        75       35       35       40       40        40        45        45       210
      91        Expensing of costs of removing certain architectural barriers to           0        0        5        5        5        5        5        25
                 the handicapped...................................................
      92        Deductibility of charitable contributions, other than education and      600      635      680      740      760      755      805     3,740   18,620   19,380   20,180   21,040    21,990    23,010    24,090   110,310
                 health............................................................
      93        Exclusion of certain foster care payments..........................  .......  .......  .......  .......  .......  .......  .......  ........       35       40       40       45        45        50        50       230
      94        Exclusion of parsonage allowances..................................  .......  .......  .......  .......  .......  .......  .......  ........      320      340      365      390       415       445       475     2,090

             Health:
      95       Exclusion of employer contributions for medical insurance premiums    .......  .......  .......  .......  .......  .......  .......  ........   69,610   75,095   80,570   86,175    90,655    95,960   102,725   456,085
                and medical care...................................................
      96       Self-employed medical insurance premiums............................  .......  .......  .......  .......  .......  .......  .......  ........      935    1,250    1,380    1,545     2,070     2,905     3,210    11,110
      97       Workers' compensation insurance premiums............................  .......  .......  .......  .......  .......  .......  .......  ........    4,420    4,585    4,555    4,935     5,120     5,315     5,515    25,440
      98        Medical Savings Accounts...........................................  .......  .......  .......  .......  .......  .......  .......  ........       20       30       30       30        30        30        25       145
      99       Deductibility of medical expenses...................................  .......  .......  .......  .......  .......  .......  .......  ........    3,695    3,910    4,160    4,440     4,720     5,005     5,305    23,630
      00       Exclusion of interest on hospital construction bonds................      305      310      310      315      320      320      325     1,590      905      915      925      935       945       955       965     4,725
     101       Deductibility of charitable contributions (health)..................      585      620      660      720      740      735      780     3,635    2,090    2,180    2,270    2,360     2,470     2,580     2,710    12,390
     102       Tax credit for orphan drug research.................................       70       80       90      100      115      130      140       575  .......  .......  .......  .......  ........  ........  ........  ........
     103       Special Blue Cross/Blue Shield deduction............................      245      315      200      135      180      245      315     1,075  .......  .......  .......  .......  ........  ........  ........  ........

             Income security:
     104       Exclusion of railroad retirement system benefits....................  .......  .......  .......  .......  .......  .......  .......  ........      395      405      410      415       420       430       430     2,105
     105       Exclusion of workers' compensation benefits.........................  .......  .......  .......  .......  .......  .......  .......  ........    5,185    5,330    5,785    6,040     6,310     6,575     6,865    31,575
     106       Exclusion of public assistance benefits (normal tax method).........  .......  .......  .......  .......  .......  .......  .......  ........      345      360      375      390       405       420       435     2,025

[[Page 115]]


     107       Exclusion of special benefits for disabled coal miners..............  .......  .......  .......  .......  .......  .......  .......  ........       75       75       70       70        65        60        55       320
     108       Exclusion of military disability pensions...........................  .......  .......  .......  .......  .......  .......  .......  ........      130      130      135      140       140       145       150       710
               Net exclusion of pension contributions and earnings:
     109        Employer plans.....................................................  .......  .......  .......  .......  .......  .......  .......  ........   83,780   88,830   92,390   97,085   102,575   108,020   113,705   513,775
     110        Individual Retirement Accounts.....................................  .......  .......  .......  .......  .......  .......  .......  ........   13,350   15,050   15,975   17,030    17,630    18,250    18,750    87,635
     111        Keogh plans........................................................  .......  .......  .......  .......  .......  .......  .......  ........    5,230    5,550    5,895    6,255     6,635     7,040     7,465    33,290
               Exclusion of other employee benefits:
     112        Premiums on group term life insurance..............................  .......  .......  .......  .......  .......  .......  .......  ........    1,700    1,740    1,780    1,820     1,860     1,915     1,970     9,345
     113        Premiums on accident and disability insurance......................  .......  .......  .......  .......  .......  .......  .......  ........      185      195      205      215       225       235       245     1,125
     114        Income of trusts to finance supplementary unemployment benefits....        0        0        0        5        5        5        5        20  .......  .......  .......  .......  ........  ........  ........  ........
     115        Special ESOP rules.................................................      860      890      915      950      990    1,040    1,090     4,985      270      285      290      300       310       320       335     1,555
     116        Additional deduction for the blind.................................  .......  .......  .......  .......  .......  .......  .......  ........       30       30       30       30        35        35        35       165
     117        Additional deduction for the elderly...............................  .......  .......  .......  .......  .......  .......  .......  ........    1,785    1,830    1,890    1,955     1,985     2,030     2,110     9,970
     118        Tax credit for the elderly and disabled............................  .......  .......  .......  .......  .......  .......  .......  ........       35       35       35       35        35        35        35       175
     119        Deductibility of casualty losses...................................  .......  .......  .......  .......  .......  .......  .......  ........      255      265      275      285       295       310       325     1,490
     120        Earned income tax credit \3\.......................................  .......  .......  .......  .......  .......  .......  .......  ........    4,825    4,700    4,790    4,985     5,205     5,440     5,740    26,160

             Social Security:
               Exclusion of social security benefits:
     121        Social Security benefits for retired workers.......................  .......  .......  .......  .......  .......  .......  .......  ........   17,135   18,010   18,885   19,995    21,230    22,505    16,515    99,130
     122        Social Security benefits for disabled..............................  .......  .......  .......  .......  .......  .......  .......  ........    2,390    2,595    2,830    3,090     3,375     3,700     3,150    16,145
     123        Social Security benefits for dependents and survivors..............  .......  .......  .......  .......  .......  .......  .......  ........    3,775    3,900    4,050    4,210     4,385     4,555     3,625    20,825

             Veterans benefits and services:
     124       Exclusion of veterans death benefits and disability compensation....  .......  .......  .......  .......  .......  .......  .......  ........    2,940    3,070    3,200    3,335     3,490     3,655     3,830    17,510
     125       Exclusion of veterans pensions......................................  .......  .......  .......  .......  .......  .......  .......  ........       65       70       75       80        85        85        90       415
     126       Exclusion of GI bill benefits.......................................  .......  .......  .......  .......  .......  .......  .......  ........       75       85       90       90        95       100       105       480
     127       Exclusion of interest on veterans housing bonds.....................       10       10       10       10       10       10       10        50       30       30       30       30        30        30        30       150

             General purpose fiscal assistance:
     128       Exclusion of interest on public purpose bonds.......................    5,735    5,790    5,850    5,910    5,965    6,025    6,085    29,835   17,015   17,185   17,355   17,530    17,705    17,880    18,060    88,530
     129       Deductibility of nonbusiness State and local taxes other than on      .......  .......  .......  .......  .......  .......  .......  ........   37,740   40,240   42,390   44,735    47,610    50,530    53,480   238,745
                owner-occupied homes...............................................
     130       Tax credit for corporations receiving income from doing business in     2,515    2,590    2,670    2,600    2,550    2,600    2,650    13,070  .......  .......  .......  .......  ........  ........  ........  ........
                U.S. possessions...................................................

             Interest:
     131       Deferral of interest on U.S. savings bonds..........................  .......  .......  .......  .......  .......  .......  .......  ........    1,015    1,065    1,115    1,175     1,235     1,295     1,355     6,175

             Addendum: Aid to State and local governments:
               Deductibility of:
                Property taxes on owner-occupied homes.............................  .......  .......  .......  .......  .......  .......  .......  ........   21,215   22,185   23,075   24,000    24,980    25,915    26,840   124,810
                Nonbusiness State and local taxes other than on owner-occupied       .......  .......  .......  .......  .......  .......  .......  ........   37,740   40,240   42,390   44,735    47,610    50,530    53,480   238,745
                 homes.............................................................
               Exclusion of interest on State and local bonds for:
                Public purposes....................................................    5,735    5,790    5,850    5,910    5,965    6,025    6,085    29,835   17,015   17,185   17,355   17,530    17,705    17,880    18,060    88,530
                Energy facilities..................................................       30       30       30       30       30       30       30       150       85       85       85       90        90        90        90       445
                Water, sewage, and hazardous waste disposal facilities.............      115      115      120      120      120      120      125       605      345      345      350      355       360       360       365     1,790
                Small-issues.......................................................       80       80       80       80       80       80       85       405      230      235      235      240       240       245       245     1,205
                Owner-occupied mortgage subsidies..................................      230      230      230      235      235      240      240     1,180      675      685      690      695       705       710       715     3,515
                Rental housing.....................................................       40       40       40       40       40       40       40       200      115      115      120      120       120       120       120       600
                Airports, docks, and similar facilities............................      185      185      185      190      190      195      195       955      545      550      555      560       565       570       575     2,825
                Student loans......................................................       60       65       65       65       65       65       65       325      185      185      190      190       190       195       195       960
                Private nonprofit educational facilities...........................      150      150      150      150      155      155      155       765      440      445      450      450       455       460       465     2,280
                Hospital construction..............................................      305      310      310      315      320      320      325     1,590      905      915      925      935       945       955       965     4,725
                Veterans' housing..................................................       10       10       10       10       10       10       10        50       30       30       30       30        30        30        30       150

[[Page 116]]


               Credit for holders of zone academy bonds............................        5       10       20       35       50       65       70       240  .......  .......  .......  .......  ........  ........  ........  ........
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ In addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise tax receipts (in millions of dollars) as follows: 1999 $760; 2000 $800; 2001 $805; 2002 $810; 2003 $815; 2004 $825; and
  2005 $830.

\2\ The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $445; 2000 $550; 2001 $520; 2002 $505; 2003 $460; 2004 $450; and 2005 $420.

\3\ The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999 $25,632; 2000 $25,676; 2001 $25,799; 2002 $26,876; 2003 $27,638; 2004
  $28,701; and 2005 $29,722.

Note: Provisions with estimates denoted normal tax method have no revenue loss under the reference tax law method. All estimates have been rounded to the nearest $5 million. Provisions with estimates that rounded to zero in each
  year are not included in the table.


[[Page 117]]


             Table 5-3.  MAJOR TAX EXPENDITURES IN THE INCOME TAX, RANKED BY TOTAL 2001 REVENUE LOSS
                                            (In millions of dollars)
----------------------------------------------------------------------------------------------------------------
                                    Provision                                         2001          2001-2005
----------------------------------------------------------------------------------------------------------------
Net exclusion of pension contributions and earnings: Employer plans...........      92,390          513,775
Exclusion of employer contributions for medical insurance premiums and medical      80,570          456,085
 care.........................................................................
Deductibility of mortgage interest on owner-occupied homes....................      60,925          331,245
Deductibility of nonbusiness State and local taxes other than on owner-             42,390          238,745
 occupied homes...............................................................
Capital gains (except agriculture, timber, iron ore, and coal) (normal tax          41,780          221,685
 method)......................................................................
Accelerated depreciation of machinery and equipment (normal tax method).......      32,830          174,160
Step-up basis of capital gains at death.......................................      28,240          152,955
Deductibility of charitable contributions, total..............................      26,555          145,225
Exclusion of interest on public purpose bonds.................................      23,205          118,365
Deductibility of State and local property tax on owner-occupied homes.........      23,075          124,810
Child credit \2\..............................................................      19,480           90,995
Capital gains exclusion on home sales.........................................      19,095          101,390
Exclusion of Social Security benefits for retired workers.....................      18,885           99,130
Exclusion of interest on life insurance savings...............................      16,130           94,175
Net exclusion of pension contributions and earnings: Individual Retirement          15,975           87,635
 Accounts.....................................................................
Deferral of income from controlled foreign corporations (normal tax method)...       6,600           37,350
Graduated corporation income tax rate (normal tax method).....................       6,275           32,750
Net exclusion of pension contributions and earnings: Keogh plans..............       5,895           33,290
Exclusion of workers' compensation benefits...................................       5,785           31,575
HOPE tax credit...............................................................       5,125           24,965
Exclusion of interest on non-public purpose State and local debt..............       4,850           24,720
Earned income tax credit \3\..................................................       4,790           26,160
Exception from passive loss rules for $25,000 of rental loss..................       4,790           21,660
Workers' compensation insurance premiums......................................       4,555           25,440
Accelerated depreciation on rental housing (normal tax method)................       4,225           23,610
Exclusion of income of foreign sales corporations.............................       4,160           23,950
Deductibility of medical expenses.............................................       4,160           23,630
Exclusion of Social Security benefits for dependents and survivors............       4,050           20,825
Credit for increasing research activities.....................................       3,360           14,150
Exclusion of veterans death benefits and disability compensation..............       3,200           17,510
Credit for low-income housing investments.....................................       3,195           16,925
Exclusion of Social Security benefits for disabled............................       2,830           16,145
Exclusion of income earned abroad by U.S. citizens............................       2,790           16,485
Tax credit for corporations receiving income from doing business in U.S.             2,670           13,070
 possessions..................................................................
Lifetime Learning tax credit..................................................       2,420           18,350
Credit for child and dependent care expenses..................................       2,360           11,520
Exclusion of benefits and allowances to armed forces personnel................       2,160           11,000
Expensing of certain small investments (normal tax method)....................       1,925            9,610
Exclusion of reimbursed employee parking expenses.............................       1,895           10,530
Additional deduction for the elderly..........................................       1,890            9,970
Expensing of research and experimentation expenditures (normal tax method)....       1,885           10,595
Exclusion of other employee benefits: Premiums on group term life insurance...       1,780            9,345
Exemption of credit union income..............................................       1,650            9,480
Self-employed medical insurance premiums......................................       1,380           11,110
Deferred taxes for financial firms on certain income earned overseas..........       1,290            1,830
Special ESOP rules............................................................       1,205            6,540
Inventory property sales source rules exception...............................       1,150            6,750
Exclusion of scholarship and fellowship income (normal tax method)............       1,120            5,705
Deferral of interest on U.S. savings bonds....................................       1,115            6,175
Deferral of income from post-1987 installment sales...........................       1,035            5,375
Parental personal exemption for students age 19 or over.......................       1,015            5,515
Alternative fuel production credit............................................         905            2,125
Exclusion of employee meals and lodging (other than military).................         710            3,880
Exclusion of employer-provided child care.....................................         700            3,845
Capital gains treatment of certain income from agriculture....................         695            3,805
Exclusion of certain allowances for Federal employees abroad..................         695            3,805
Expensing of multiperiod timber growing costs.................................         530            2,920
Excess of percentage over cost depletion, fuels and nonfuel minerals..........         525            2,745
Empowerment zones and enterprise communities..................................         500            1,855
Work opportunity tax credit...................................................         465            1,160
Exclusion of railroad retirement system benefits..............................         410            2,105
Exclusion of public assistance benefits (normal tax method)...................         375            2,025
Exclusion of parsonage allowances.............................................         365            2,090
Deductibility of student-loan interest........................................         310            1,860
Enhanced oil recovery credit..................................................         295            1,990
Deductibility of casualty losses..............................................         275            1,490
Exclusion of employer-provided educational assistance.........................         250              425
Tax incentives for preservation of historic structures........................         240            1,330
Tax exemption of certain insurance companies owned by tax-exempt organizations         235            1,245

[[Page 118]]


Deferral for State prepaid tuition plans......................................         225            1,555
Amortization of start-up costs (normal tax method)............................         205            1,080
Exclusion of other employee benefits: Premiums on accident and disability              205            1,125
 insurance....................................................................
Special Blue Cross/Blue Shield deduction......................................         200            1,075
Carryover basis of capital gains on gifts.....................................         195            1,060
Expensing of environmental remediation costs..................................         175              140
Exclusion for employer-provided transit passes................................         170            1,070
Exceptions from imputed interest rules........................................         160              820
Adoption assistance...........................................................         140              330
Exclusion of military disability pensions.....................................         135              710
Tax credit and deduction for clean-fuel burning vehicles......................         105              360
Small life insurance company deduction........................................         100              510
Expensing of certain multiperiod production costs.............................          90              510
Exclusion of GI bill benefits.................................................          90              480
Tax credit for orphan drug research...........................................          90              575
Welfare-to-work tax credit....................................................          80              255
Income averaging for farmers..................................................          80              410
New technology credit.........................................................          80              435
Exclusion from income of conservation subsidies provided by public utilities..          80              415
Exclusion of veterans pensions................................................          75              415
Expensing of certain capital outlays..........................................          75              405
Capital gains treatment of royalties on coal..................................          70              380
Exclusion of special benefits for disabled coal miners........................          70              320
Capital gains treatment of certain timber income..............................          70              380
Exemption of certain mutuals' and cooperatives' income........................          60              325
Credit for disabled access expenditures.......................................          55              285
Excess bad debt reserves of financial institutions............................          55              160
Ordinary income treatment of loss from small business corporation stock sale..          40              200
Exclusion of certain foster care payments.....................................          40              230
Tax credit for the elderly and disabled.......................................          35              175
Medical Savings Accounts......................................................          30              145
Additional deduction for the blind............................................          30              165
Investment credit for rehabilitation of structures (other than historic)......          30              150
Education Individual Retirement Accounts......................................          25              310
Exception from passive loss limitation for working interests in oil and gas             25              125
 properties...................................................................
Credit for holders of zone academy bonds......................................          20              240
Expensing of exploration and development costs, nonfuel minerals..............          20              100
Cancellation of indebtedness..................................................          15               95
Alcohol fuel credits \1\......................................................          15               75
Exclusion of interest on savings bonds redeemed to finance educational                  15               85
 expenses.....................................................................
Deferral of tax on shipping companies.........................................          15               75
Deferral of gain on sale of farm refiners.....................................          10               65
Investment credit and seven-year amortization for reforestation expenditures..          10               70
Treatment of loans forgiven for solvent farmers...............................          10               50
Capital gains exclusion of small corporation stock............................           5               25
Special alternative tax on small property and casualty insurance companies....           5               25
Expensing of costs of removing certain architectural barriers to the                     5               25
 handicapped..................................................................
Income of trusts to finance supplementary unemployment benefits...............           0               20
Expensing of exploration and development costs, fuels.........................         -30                5
Accelerated depreciation of buildings other than rental housing (normal tax           -435           -6,145
 method)......................................................................
----------------------------------------------------------------------------------------------------------------
\1\ In addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise
  tax receipts (in millions of dollars) as follows: 1999 $760; 2000 $800; 2001 $805; 2002 $810; 2003 $815; 2004
  $825; and 2005 $830.

\2\ The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in
  millions of dollars) is as follows: 1999 $445; 2000 $550; 2001 $520; 2002 $505; 2003 $460; 2004 $450; and 2005
  $420.

\3\ The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on
  outlays (in millions of dollars) is as follows: 1999 $25,630; 2000 $25,675; 2001 $25,800; 2002 $26,875; 2003
  $27,640; 2004 $28,700; and 2005 $29,720.

Note: Provisions with estimates denoted ``normal tax method'' have no revenue loss under the reference tax law
  method. All estimates have been rounded to the nearest $5 million. Provisions with estimates that rounded to
  zero in each year are not included in the table.

Note: Three categories in the table are aggregated: Deductibility of charitable contributions, exclusion of
  interest for non-public purpose State and local debt, and excess of percentage over cost depletion for fuels
  and nonfuel minerals.


[[Page 119]]


            Table 5-4.  PRESENT VALUE OF SELECTED TAX EXPENDITURES FOR ACTIVITY IN CALENDAR YEAR 1999
                                            (In millions of dollars)
----------------------------------------------------------------------------------------------------------------
                                                                                                       Present
                                                   Provision                                          Value of
                                                                                                    Revenue Loss
----------------------------------------------------------------------------------------------------------------
       1     Deferral of income from controlled foreign corporations (normal tax method)..........     5,960
       2     Deferred taxes for financial firms on income earned overseas.........................       965
       3     Expensing of research and experimentation expenditures (normal tax method)...........     2,570
       4     Expensing of exploration and development costs--fuels................................       110
       5     Expensing of exploration and development costs--nonfuels.............................        10
       6     Expensing of multiperiod timber growing costs........................................       240
       7     Expensing of certain multiperiod production costs--agriculture.......................        90
       8     Expensing of certain capital outlays--agriculture....................................        75
       9     Deferral of income on life insurance and annuity contracts...........................    22,100
      10     Accelerated depreciation of rental housing (normal tax method).......................     2,845
      11     Accelerated depreciation of buildings other than rental housing (normal tax method)..       335
      12     Accelerated depreciation of machinery and equipment (normal tax method)..............    32,780
      13     Expensing of certain small investments (normal tax method)...........................     1,030
      14     Amortization of start-up costs (normal tax method)...................................       170
      15     Deferral of tax on shipping companies................................................        15
      16     Deferral for state prepaid tuition plans.............................................       170
      17     Credit for holders of zone academy bonds.............................................       220
      18     Credit for low-income housing investments............................................     2,730
      19     Exclusion of pension contributions--employer plans...................................    95,620
      20     Exclusion of IRA contributions and earnings..........................................     6,005
      21     Exclusion of contributions and earnings for Keogh plans..............................     3,510
      22     Exclusion of interest on public-purpose bonds........................................    26,995
      23     Exclusion of interest on non-public purpose bonds....................................     3,950
      24     Deferral of interest on U.S. savings bonds...........................................       405
----------------------------------------------------------------------------------------------------------------

                           Outlay Equivalents

  The concept of ``outlay equivalents'' complements ``revenue losses'' 
as a measure of the budget effect of tax expenditures. It is the amount 
of outlay that would be required to provide the taxpayer the same after-
tax income as would be received through the tax preference. The outlay-
equivalent measure allows a comparison of the cost of the tax 
expenditure with that of a direct Federal outlay. Outlay equivalents are 
reported in Table 5-5.
  The outlay-equivalent measure is larger than the revenue-loss estimate 
when the tax expenditure is judged to function as a Government payment 
for service. This occurs because an outlay program would increase the 
taxpayer's pre-tax income. For some tax expenditures, however, the 
revenue loss equals the outlay equivalent measure. This occurs when the 
tax expenditure is judged to function like a price reduction or tax 
deferral that does not directly enter the taxpayer's pre-tax income.\1\
---------------------------------------------------------------------------
  \1\ Budget outlay figures generally reflect the pre-tax price of the 
resources. In some instances, however, Government purchases or subsidies 
are exempted from tax by a special tax provision. When this occurs, the 
outlay figure understates the resource cost of the program and is, 
therefore, not comparable with other outlay amounts. For example, the 
outlays for certain military personnel allowances are not taxed. If this 
form of compensation were treated as part of the employee's taxable 
income, the Defense Department would have to make larger cash payments 
to its military personnel to leave them as well off after tax as they 
are now. The tax subsidy must be added to the tax-exempt budget outlay 
to make this element of national defense expenditures comparable with 
other outlays.

[[Page 120]]



                                     Table 5-5.  OUTLAY EQUIVALENT ESTIMATES FOR TAX EXPENDITURES IN THE INCOME TAX
                                                                (In millions of dollars)
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                                        Outlay Equivalents
                                                                        --------------------------------------------------------------------------------
                                                                           1999      2000      2001      2002      2003      2004      2005    2001-2005
--------------------------------------------------------------------------------------------------------------------------------------------------------
             National Defense
       1       Exclusion of benefits and allowances to armed forces         2,470     2,495     2,520     2,545     2,570     2,600     2,630    12,865
                personnel..............................................

             International affairs:
       2       Exclusion of income earned abroad by U.S. citizens......     3,940     4,270     4,625     5,000     5,370     5,760     6,185    26,940
       3       Exclusion of income of foreign sales corporations.......     5,600     5,980     6,400     6,860     7,340     7,850     8,400    36,850
       4       Inventory property sales source rules exception.........     1,620     1,690     1,770     1,920     2,080     2,230     2,380    10,380
       5       Deferral of income from controlled foreign corporations      5,800     6,200     6,600     7,000     7,450     7,900     8,400    37,350
                (normal tax method)....................................
       6       Deferred taxes for financial firms on income earned            960     1,190     1,290       540         0         0         0     1,830
                overseas...............................................

             General science, space, and technology:
       7       Expensing of research and experimentation expenditures       1,890     1,865     1,875     1,960     2,090     2,245     2,415    10,585
                (normal tax method)....................................
       8       Credit for increasing research activities...............     2,625     1,550     5,175     5,710     4,570     4,010     2,320    21,785

             Energy:
       9       Expensing of exploration and development costs, fuels...       -80       -20       -30       -10        15        15        15         5
      10       Excess of percentage over cost depletion, fuels.........       325       330       335       340       345       350       355     1,725
      11       Alternative fuel production credit......................     1,495     1,400     1,315     1,235       775       180       180     3,685
      12       Exception from passive loss limitation for working              30        25        25        25        25        25        25       125
                interests in oil and gas properties....................
      13       Capital gains treatment of royalties on coal............        85        85        95        95       100       105       115       510
      14       Exclusion of interest on energy facility bonds..........       165       165       165       170       170       170       170       845
      15       Enhanced oil recovery credit............................       315       360       415       480       550       635       730     2,810
      16       New technology credit...................................        70        85       120       130       125       125       125       625
      17       Alcohol fuel credits \1\................................        15        15        15        15        15        15        15        75
      18       Tax credit and deduction for clean-fuel burning vehicles       110       125       135       125       105        70        25       460
      19       Exclusion from income of conservation subsidies provided       115       110       105       110       115       115       115       560
                by public utilities....................................

             Natural resources and environment:
      20       Expensing of exploration and development costs, nonfuel         15        15        15        15        15        20        20        85
                minerals...............................................
      21       Excess of percentage over cost depletion, nonfuel              275       285       295       310       320       335       350     1,610
                minerals...............................................
      22       Exclusion of interest on bonds for water, sewage, and          660       660       670       680       685       685       705     3,425
                hazardous waste facilities.............................
      23       Capital gains treatment of certain timber income........        85        85        95        95       100       105       115       510
      24       Expensing of multiperiod timber growing costs...........       495       500       530       565       585       610       630     2,920
      25       Investment credit and seven-year amortization for               15        15        15        15        15        15        15        75
                reforestation expenditures.............................
      26       Tax incentives for preservation of historic structures..       205       225       240       255       265       280       295     1,335

             Agriculture:
      27       Expensing of certain capital outlays....................        65        70        75        75        80        85        85       400
      28       Expensing of certain multiperiod production costs.......        85        85        90        95       100       105       110       500
      29       Treatment of loans forgiven for solvent farmers.........        10        10        10        10        10        10        10        50
      30       Capital gains treatment of certain income...............       845       885       925       965     1,015     1,060     1,105     5,070
      31       Income averaging for farmers............................        75        75        80        80        80        85        85       410
      32       Deferral of gain on sale of farm refiners...............        10        10        10        10        15        15        15        65

             Commerce and housing:
               Financial institutions and insurance:
      33        Exemption of credit union income.......................     1,910     2,015     2,160     2,320     2,490     2,675     2,865    12,510
      34        Excess bad debt reserves of financial institutions.....        75        85        70        55        40        25         5       195
      35        Exclusion of interest on life insurance savings........    13,920    14,985    16,130    17,365    18,870    20,130    21,680    94,175
      36        Special alternative tax on small property and casualty          5         5         5         5         5         5         5        25
                 insurance companies...................................
      37        Tax exemption of certain insurance companies owned by         295       300       315       320       335       340       355     1,665
                 tax-exempt organizations..............................
      38        Small life insurance company deduction.................       135       135       135       135       135       140       140       685
               Housing:
      39        Exclusion of interest on owner-occupied mortgage            1,300     1,310     1,320     1,330     1,345     1,365     1,370     6,730
                 subsidy bonds.........................................
      40        Exclusion of interest on rental housing bonds..........       220       220       230       230       230       230       230     1,150
      41        Deductibility of mortgage interest on owner-occupied       56,920    58,815    60,925    63,240    65,955    68,965    72,160   331,245
                 homes.................................................
      42        Deductibility of State and local property tax on owner-    21,215    22,185    23,075    24,000    24,980    25,915    26,840   124,810
                 occupied homes........................................
      43        Deferral of income from post-1987 installment sales....       995     1,015     1,035     1,055     1,075     1,095     1,115     5,375
      44        Capital gains exclusion on home sales..................    22,500    23,175    23,870    24,590    25,325    26,090    26,870   126,745
      45        Exception from passive loss rules for $25,000 of rental     5,315     5,035     4,790     4,555     4,330     4,100     3,885    21,660
                 loss..................................................
      46        Credit for low-income housing investments..............         0         0         0         5         5         5         5        20
      47        Accelerated depreciation on rental housing (normal tax      3,710     3,985     4,225     4,495     4,760     4,975     5,145    23,600
                 method)...............................................
               Commerce:
      48        Cancellation of indebtedness...........................        40        25        15        15        20        20        25        95
      49        Exceptions from imputed interest rules.................       160       160       160       165       165       165       165       820
      50        Capital gains (except agriculture, timber, iron ore,       52,540    54,100    55,705    57,365    59,065    60,820    62,620   295,575
                 and coal) (normal tax method).........................
      51        Capital gains exclusion of small corporation stock.....         5         5         5         5         5         5         5        25
      52        Step-up basis of capital gains at death................    34,400    36,120    37,655    39,160    40,725    42,355    44,045   203,940
      53        Carryover basis of capital gains on gifts..............       175       185       195       205       210       220       230     1,060
      54        Ordinary income treatment of loss from small business          45        45        55        55        55        55        55       275
                 corporation stock sale................................
      55        Accelerated depreciation of buildings other than rental     1,655       705      -435      -755    -1,110    -1,695    -2,140    -6,135
                 housing (normal tax method)...........................

[[Page 121]]


      56        Accelerated depreciation of machinery and equipment        26,440    27,735    32,825    33,340    34,260    36,380    37,325   174,130
                 (normal tax method)...................................
      57        Expensing of certain small investments (normal tax          1,465     1,590     1,920     1,965     1,915     1,890     1,900     9,590
                 method)...............................................
      58        Amortization of start-up costs (normal tax method).....       200       205       205       215       215       220       225     1,080
      59        Graduated corporation income tax rate (normal tax           9,790     9,690     9,655     9,940     9,985    10,325    10,485    50,390
                 method)...............................................
      60        Exclusion of interest on small issue bonds.............       445       450       450       460       460       465       475     2,310

             Transportation:
      61       Deferral of tax on shipping companies...................        20        20        20        20        20        20        20       100
      62       Exclusion of reimbursed employee parking expenses.......     2,225     2,330     2,450     2,575     2,710     2,855     3,005    13,595
      63       Exclusion for employer-provided transit passes..........       180       205       235       265       295       330       360     1,485

             Community and regional development:
      64       Investment credit for rehabilitation of structures              25        25        25        25        25        25        30       130
                (other than historic)..................................
      65       Exclusion of interest for airport, dock, and similar         1,045     1,050     1,060     1,075     1,085     1,095     1,105     5,420
                bonds..................................................
      66       Exemption of certain mutuals' and cooperatives' income..        60        60        60        65        65        65        70       325
      67       Empowerment zones and enterprise communities............       325       445       500       470       325       300       265     1,860
      68       Expensing of environmental remediation costs............       150       200       235        80       -40       -50       -40       185

             Education, training, employment, and social services:
               Education:
      69        Exclusion of scholarship and fellowship income (normal      1,190     1,220     1,235     1,240     1,255     1,265     1,280     6,275
                 tax method)...........................................
      70        HOPE tax credit........................................     5,890     6,310     6,570     6,595     6,080     5,915     6,845    32,005
      71        Lifetime Learning tax credit...........................     2,780     3,045     3,100     3,160     5,645     5,675     5,935    23,515
      72        Education Individual Retirement Accounts...............         0        10        25        40        60        80       105       310
      73        Deductibility of student-loan interest.................       300       335       390       440       470       495       535     2,330
      74        Deferral for State prepaid tuition plans...............       120       175       225       275       320       355       385     1,560
      75        Exclusion of interest on student-loan bonds............       355       360       365       365       365       370       370     1,835
      76        Exclusion of interest on bonds for private nonprofit          845       855       860       860       875       880       890     4,365
                 educational facilities................................
      77        Credit for holders of zone academy bonds...............         5        15        30        50        75        90       100       345
      78        Exclusion of interest on savings bonds redeemed to             15        20        20        20        20        30        30       120
                 finance educational expenses..........................
      79        Parental personal exemption for students age 19 or over     1,010     1,070     1,125     1,165     1,225     1,280     1,310     6,105
      80        Child credit \2\.......................................    25,915    26,100    25,975    25,290    24,205    23,385    22,475   121,330
      81        Deductibility of charitable contributions (education)..     3,435     3,685     3,850     4,040     4,250     4,395     4,610    21,145
      82        Exclusion of employer-provided educational assistance..       275       290       310       215         0         0         0       525
               Training, employment, and social services:
      83        Work opportunity tax credit............................       270       455       465       350       215        95        35     1,160
      84        Welfare-to-work tax credit.............................        35        60        80        80        60        25        10       255
      85        Exclusion of employer provided child care..............       860       890       930       970     1,020     1,075     1,135     5,130
      86        Adoption assistance....................................       160       175       180       160        55        20        10       425
      87        Exclusion of employee meals and lodging (other than           795       830       865       905       945       990     1,030     4,735
                 military).............................................
      88        Credit for child and dependent care expenses...........     3,225     3,185     3,145     3,110     3,075     3,035     3,000    15,365
      89        Credit for disabled access expenditures................        65        65        75        75        75        80        80       385
      90        Expensing of costs of removing certain architectural            0         0         5         5         5         5         5        25
                 barriers to the handicapped...........................
      91        Deductibility of charitable contributions, other than      25,750    26,955    28,115    29,380    30,790    32,200    33,755   154,240
                 education and health..................................
      92        Exclusion of certain foster care payments..............        45        50        50        55        55        60        60       280
      93        Exclusion of parsonage allowances......................       395       420       450       480       515       550       585     2,580

             Health:
      94       Exclusion of employer contributions for medical             88,730    95,950   103,085   110,390   115,840   122,545   131,495   583,355
                insurance premiums and medical care....................
      95       Self-employed medical insurance premiums................     1,145     1,535     1,700     1,900     2,550     3,580     3,955    13,685
      96       Workers' compensation insurance premiums................     5,520     5,730     5,945     6,170     6,400     6,645     3,895    29,055
      97       Medical Savings Accounts................................        30        40        45        45        45        40        35       210
      98       Deductibility of medical expenses.......................     3,695     3,910     4,160     4,440     4,720     5,005     5,305    23,630
      99       Exclusion of interest on hospital construction bonds....     1,735     1,755     1,770     1,790     1,815     1,830     1,850     9,055
     100       Deductibility of charitable contributions (health)......     3,640     3,910     4,095     4,300     4,525     4,665     4,900    22,485
     101       Tax credit for orphan drug research.....................        70        80        90       100       115       130       140       575
     102       Special Blue Cross/Blue Shield deduction................       325       420       270       180       240       325       420     1,435

             Income security:
     103       Exclusion of railroad retirement system benefits........       395       405       410       415       420       430       430     2,105
     104       Exclusion of workers' compensation benefits.............     5,185     5,330     5,785     6,040     6,310     6,575     6,865    31,575
     105       Exclusion of public assistance benefits (normal tax            345       360       375       390       405       420       435     2,025
                method)................................................
     106       Exclusion of special benefits for disabled coal miners..        75        75        70        70        65        60        55       320
     107       Exclusion of military disability pensions...............       130       130       135       140       140       145       150       710
               Net exclusion of pension contributions and earnings:
     108        Employer plans.........................................    97,960   104,060   108,190   113,770   120,275   126,700   133,400   602,335
     109        Individual Retirement Accounts.........................    18,290    20,025    21,360    22,770    23,695    24,645    25,445   117,915
     110        Keogh plans............................................     6,630     7,040     7,475     7,930     8,415     8,925     9,465    42,210
               Exclusion of other employee benefits:
     111        Premiums on group term life insurance..................     2,240     2,290     2,340     2,395     2,445     2,520     2,590    12,290

[[Page 122]]


     112        Premiums on accident and disability insurance..........       235       250       260       275       290       305       315     1,445
     113       Income of trusts to finance supplementary unemployment           0         0         0         5         5         5         5        20
                benefits...............................................
     114       Special ESOP rules......................................     1,565     1,630     1,670     1,730     1,800     1,885     1,975     9,060
     115       Additional deduction for the blind......................        35        35        40        40        40        45        45       210
     116       Additional deduction for the elderly....................     2,155     2,215     2,285     2,360     2,400     2,455     2,555    12,055
     117       Tax credit for the elderly and disabled.................        45        45        45        45        45        45        45       225
     118       Deductibility of casualty losses........................       280       290       300       315       325       340       355     1,635
     119       Earned income tax credit \3\............................     5,360     5,220     5,320     5,540     5,785     6,045     6,380    29,070

             Social Security:
               Exclusion of social security benefits:
     120        Social Security benefits for retired workers...........    17,135    18,010    18,885    19,995    21,230    22,505    16,515    99,130
     121        Social Security benefits for disabled..................     2,390     2,595     2,830     3,090     3,375     3,700     3,150    16,145
     122        Social Security benefits for dependents and survivors..     3,775     3,900     4,050     4,210     4,385     4,555     3,625    20,825

             Veterans benefits and services:
     123       Exclusion of veterans death benefits and disability          2,940     3,070     3,200     3,335     3,490     3,655     3,830    17,510
                compensation...........................................
     124       Exclusion of veterans pensions..........................        65        70        75        80        85        85        90       415
     125       Exclusion of GI bill benefits...........................        75        85        90        90        95       100       105       480
     126       Exclusion of interest on veterans housing bonds.........        60        60        60        60        60        60        60       300

             General purpose fiscal assistance:
     127       Exclusion of interest on public purpose bonds...........    32,600    32,925    33,250    33,590    33,920    34,255    34,600   169,615
     128       Deductibility of nonbusiness State and local taxes other    37,740    40,240    42,390    44,735    47,610    50,530    53,480   238,745
                than on owner-occupied homes...........................
     129       Tax credit for corporations receiving income from doing      3,590     3,700     3,815     3,715     3,640     3,715     3,785    18,670
                business in U.S. possessions...........................

             Interest:
     130       Deferral of interest on U.S. savings bonds..............     1,015     1,065     1,115     1,175     1,235     1,295     1,355     6,175

             Addendum: Aid to State and local governments:
               Deductibility of:
                Property taxes on owner-occupied homes.................    21,215    22,185    23,075    24,000    24,980    25,915    26,840   124,810
                Nonbusiness State and local taxes other than on owner-     37,740    40,240    42,390    44,735    47,610    50,530    53,480   238,745
                 occupied homes........................................
               Exclusion of interest on State and local bonds for:
                Public purposes........................................    32,600    32,925    33,250    33,590    33,920    34,255    34,600   169,615
                Energy facilities......................................       165       165       165       170       170       170       170       845
                Water, sewage, and hazardous waste disposal facilities.       660       660       670       680       685       685       705     3,425
                Small-issues...........................................       445       450       450       460       460       465       475     2,310
                Owner-occupied mortgage subsidies......................     1,300     1,310     1,320     1,330     1,345     1,365     1,370     6,730
                Rental housing.........................................       220       220       230       230       230       230       230     1,150
                Airports, docks, and similar facilities................     1,045     1,050     1,060     1,075     1,085     1,095     1,105     5,420
                Student loans..........................................       355       360       365       365       365       370       370     1,835
                Private nonprofit educational facilities...............       845       855       860       860       875       880       890     4,365
                Hospital construction..................................     1,735     1,755     1,770     1,790     1,815     1,830     1,850     9,055
                Veterans' housing......................................        60        60        60        60        60        60        60       300
               Credit for holders of zone academy bonds................         5        15        30        50        75        90       100       345
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ In addition, the partial exemption from the excise tax for alcohol fuels results in a reduction in excise tax receipts (in millions of dollars) as
  follows: 1999 $760; 2000 $800; 2001 $805; 2002 $810; 2003 $815; 2004 $825; and 2005 $830.

\2\ The figures in the table indicate the effect of the child tax credit on receipts. The effect on outlays (in millions of dollars) is as follows: 1999
  $445; 2000 $550; 2001 $520; 2002 $505; 2003 $460; 2004 $450; and 2005 $420.

\3\ The figures in the table indicate the effect of the earned income tax credit on receipts. The effect on outlays (in millions of dollars) is as
  follows: 1999 $25,632; 2000 $25,676; 2001 $25,799; 2002 $26,876; 2003 $27,638; 2004 $28,701; and 2005 $29,722.

Note: Provisions with estimates denoted normal tax method have no revenue loss under the reference tax law method. All estimates have been rounded to
  the nearest $5 million. Provisions with estimates that rounded to zero in each year are not included in the table.


[[Page 123]]

                        Tax Expenditure Baselines

  A tax expenditure is a preferential exception to the baseline 
provisions of the tax structure. The 1974 Congressional Budget Act did 
not, however, specify the baseline provisions of the tax law. Deciding 
whether provisions are preferential exceptions, therefore, is a matter 
of judgment. As in prior years, this year's tax expenditure estimates 
are presented using two baselines: the normal tax baseline, which is 
used by the Joint Committee on Taxation, and the reference tax law 
baseline, which has been reported by the Administration since 1983.
  The normal tax baseline is patterned on a comprehensive income tax, 
which defines income as the sum of consumption and the change in net 
wealth in a given period of time. The normal tax baseline allows 
personal exemptions, a standard deduction, and deductions of the 
expenses incurred in earning income. It is not limited to a particular 
structure of tax rates, or by a specific definition of the taxpaying 
unit.
  The reference tax law baseline is also patterned on a comprehensive 
income tax, but is closer to existing law. Reference law tax 
expenditures are limited to special exceptions in the tax code that 
serve programmatic functions. These functions correspond to specific 
budget categories such as national defense, agriculture, or health care. 
Tax expenditures under the reference law baseline are generally tax 
expenditures under the normal tax baseline, but the reverse is not 
always true.
  Both the normal and reference tax baselines allow several major 
departures from a pure comprehensive income tax. For example:
     Income is taxable only when it is realized in exchange. 
          Thus, neither the deferral of tax on unrealized capital gains 
          nor the tax exclusion of imputed income (such as the rental 
          value of owner-occupied housing or farmers' consumption of 
          their own produce) is regarded as a tax expenditure. Both 
          accrued and imputed income would be taxed under a 
          comprehensive income tax.
     There is a separate corporation income tax. Under a 
          comprehensive income tax, corporate income would be taxed only 
          once--at the shareholder level, whether or not distributed in 
          the form of dividends.
     Values of assets and debt are not adjusted for inflation. A 
          comprehensive income tax would adjust the cost basis of 
          capital assets and debt for changes in the price level during 
          the time the assets or debt are held. Thus, under a 
          comprehensive income tax baseline, the failure to take account 
          of inflation in measuring depreciation, capital gains, and 
          interest income would be regarded as a negative tax 
          expenditure (i.e., a tax penalty), and failure to take account 
          of inflation in measuring interest costs would be regarded as 
          a positive tax expenditure (i.e., a tax subsidy).
  Although the reference law and normal tax baselines are generally 
similar, areas of difference include:
    Tax rates. The separate schedules applying to the various 
          taxpaying units are included in the reference law baseline. 
          Thus, corporate tax rates below the maximum statutory rate do 
          not give rise to a tax expenditure. The normal tax baseline is 
          similar, except that it specifies the current maximum rate as 
          the baseline for the corporate income tax. The lower tax rates 
          applied to the first $10 million of corporate income are thus 
          regarded as a tax expenditure. Similarly, under the reference 
          law baseline, preferential tax rates for capital gains 
          generally do not yield a tax expenditure; only capital gains 
          treatment of otherwise ``ordinary income,'' such as that from 
          coal and iron ore royalties and the sale of timber and certain 
          agricultural products, is considered a tax expenditure. The 
          alternative minimum tax is treated as part of the baseline 
          rate structure under both the reference and normal tax 
          methods.
     Income subject to the tax. Income subject to tax is defined 
          as gross income less the costs of earning that income. The 
          Federal income tax defines gross income to include: (1) 
          consideration received in the exchange of goods and services, 
          including labor services or property; and (2) the taxpayer's 
          share of gross or net income earned and/or reported by another 
          entity (such as a partnership). Under the reference tax rules, 
          therefore, gross income does not include gifts--defined as 
          receipts of money or property that are not consideration in an 
          exchange--or most transfer payments, which can be thought of 
          as gifts from the Government.\2\ The normal tax baseline also 
          excludes gifts between individuals from gross income. Under 
          the normal tax baseline, however, all cash transfer payments 
          from the Government to private individuals are counted in 
          gross income, and exemptions of such transfers from tax are 
          identified as tax expenditures. The costs of earning income 
          are generally deductible in determining taxable income under 
          both the reference and normal tax baselines.\3\
---------------------------------------------------------------------------
  \2\ Gross income does, however, include transfer payments associated 
with past employment, such as social security benefits.
  \3\ In the case of individuals who hold ``passive'' equity interests 
in businesses, however, the pro-rata shares of sales and expense 
deductions reportable in a year are limited. A passive business activity 
is defined to be one in which the holder of the interest, usually a 
partnership interest, does not actively perform managerial or other 
participatory functions. The taxpayer may generally report no larger 
deductions for a year than will reduce taxable income from such 
activities to zero. Deductions in excess of the limitation may be taken 
in subsequent years, or when the interest is liquidated.
---------------------------------------------------------------------------
     Capital recovery. Under the reference tax law baseline no 
          tax expenditures arise from accelerated depreciation. Under 
          the normal tax baseline, the depreciation allowance for 
          machinery and equipment is determined using straight-line 
          depreciation over tax lives equal to mid-values of the asset 
          depreciation range (a depreciation system in effect from 1971 
          through 1980). The normal tax baseline for real property is 
          computed using 40-year straight-line depreciation.
     Treatment of foreign income. Both the normal and reference 
          tax baselines allow a tax credit for foreign income taxes paid 
          (up to the amount of U.S.

[[Page 124]]

          income taxes that would otherwise be due), which prevents 
          double taxation of income earned abroad. Under the normal tax 
          method, however, controlled foreign corporations (CFCs) are 
          not regarded as entities separate from their controlling U.S. 
          shareholders. Thus, the deferral of tax on income received by 
          CFCs is regarded as a tax expenditure under this method. In 
          contrast, except for tax haven activities, the reference law 
          baseline follows current law in treating CFCs as separate 
          taxable entities whose income is not subject to U.S. tax until 
          distributed to U.S. taxpayers. Under this baseline, deferral 
          of tax on CFC income is not a tax expenditure because U.S. 
          taxpayers generally are not taxed on accrued, but unrealized, 
          income.
  Beyond these examples, there are still more areas of difference where 
the Joint Committee on Taxation considers a somewhat broader set of tax 
expenditures under its normal tax baseline than under the reference 
baseline considered here.

    Performance Measures and the Economic Effects of Tax Expenditures

  The Government Performance and Results Act of 1993 (GPRA) directs 
Federal agencies to develop annual and strategic plans for their 
programs and activities. These plans set out performance objectives to 
be achieved over a specific time period. Most of these objectives will 
be achieved through direct expenditure programs. However, tax 
expenditures may also contribute to achieving these goals. The report of 
the Senate Governmental Affairs Committee on GPRA \4\ calls on the 
Executive branch to undertake a series of analyses to assess the effect 
of specific tax expenditures on the achievement of agencies' performance 
objectives.
---------------------------------------------------------------------------
  \4\ Committee on Government Affairs, United States Senate, 
``Government Performance and Results Act of 1993'' (Report 103-58, 
1993).
---------------------------------------------------------------------------
  One finding of pilot studies on selected tax expenditures undertaken 
by Treasury's Office of Tax Analysis is that much of the data needed for 
thorough analysis are not currently available. Hence, assessment of data 
needs and availability from Federal statistical agencies, program-agency 
studies, or private-sector sources, should prove valuable to broader 
efforts to assess the effects of tax expenditures and to compare their 
effectiveness with other policy means of achieving important public 
objectives. This effort will complement information published by the 
Joint Committee on Taxation and the Senate Budget Committee on tax 
expenditures.\5\
---------------------------------------------------------------------------
  \5\ Joint Committee on Taxation, ``Estimates of Federal Tax 
Expenditures for Fiscal Years 1999-1993,'' JCS-7-98, December 14, 1998; 
and Committee on the Budget, United States Senate, ``Tax Expenditures: 
Compendium of Background Material on Individual Provisions,'' prepared 
by the Congressional Research Service (S. Prt. 104-69, December 1996).
---------------------------------------------------------------------------
  Over the next few years, the Executive Branch's focus will be on the 
availability of the data needed to assess the effects of the tax 
expenditures designed to increase savings. As one part of this effort, 
Treasury's Office of Tax Analysis and its Statistics of Income Division 
(IRS) are developing the specifications for a new data sample which will 
follow the same individual income tax filers over an extended period of 
time. Such a sample is called a ``panel'' sample. Current economic 
analyses of the effect of Federal tax laws are generally based on data 
from ``cross-section'' samples, which capture the demographic and 
economic circumstances of individuals and the provisions of Federal tax 
law only at a single point in time. However, over time, the demographic 
and economic status of individuals changes in ways that can 
significantly change how they are affected by current (or proposed) 
Federal tax laws. In addition, some provisions of the tax law have 
effects over multiple years, and the effects of some tax provisions 
change over time due to phase-ins, phase-outs, and other factors. The 
new panel sample will capture the changing demographic and economic 
circumstances of individuals and the effects of changes in tax law over 
an extended period of time. Data from the panel sample will therefore 
permit more extensive, and better, analyses of many tax provisions than 
can be performed using only cross-section data. In particular, data from 
the panel sample will enhance our ability to analyze the effect of tax 
expenditures designed to increase savings. Other efforts to improve data 
available for the analysis of savings tax expenditures will be 
undertaken over the next several years by OMB, Treasury and other 
agencies.

  Comparison of tax expenditure, spending, and regulatory policies. Tax 
expenditures by definition work through the tax system and, 
particularly, the income tax. Thus, they may be relatively advantageous 
policy approaches when the benefit or incentive is related to income and 
is intended to be widely available.\6\ Because there is an existing 
public administrative and private compliance structure for the tax 
system, the incremental administrative and compliance costs for a tax 
expenditure may be low in some cases. In addition, some tax expenditures 
actually simplify the tax system (for example, the exclusion for up to 
$500,000 of capital gains on home sales). Tax expenditures also 
implicitly subsidize certain activities. Spending, regulatory or tax-
disincentive policies, can also modify behavior, but may have different 
economic effects. Finally, a variety of tax expenditure tools can be 
used--e.g., deductions, credits, exemptions and deferrals; floors and 
ceilings; and phase-ins and phase-outs, dependent on income, expenses, 
or demographic characteristics (age, number of family members, etc.). 
This wide range means that tax expenditures can be flexible and can have 
very different economic effects.
---------------------------------------------------------------------------
  \6\ Although this section focuses upon tax expenditures under the 
income tax, tax preferences also arise under the unified transfer, 
payroll, and excise tax systems. Such preferences can be useful when 
they relate to the bases of those taxes, such as an excise tax exemption 
for certain types of consumption that are deemed meritorious.
---------------------------------------------------------------------------
  Tax expenditures also have limitations. In many cases they add to the 
complexity of the tax system, which raises both administrative and 
compliance costs. For example, various holding periods and tax rates for 
capital gains can complicate filing and decisionmaking. The income tax 
system may have little or no contact with persons who have no or very 
low incomes, and does not inquire into certain characteristics of 
individ

[[Page 125]]

uals used in some spending programs, such as wealth. These features may 
reduce the effectiveness of tax expenditures for addressing certain 
income-transfer objectives. Tax expenditures also generally do not 
enable the same degree of agency discretion as outlay programs. For 
example, grant or direct Federal service delivery programs can 
prioritize which activities are addressed with what amount of resources 
in a way that is difficult to emulate with tax expenditures. Finally, 
tax expenditures may not receive the same frequency or level of scrutiny 
afforded to other programs.
  Outlay programs, in contrast, have advantages where direct government 
service provision is particularly warranted--such as equipping and 
providing the armed forces or administering the system of justice. 
Outlay programs may also be specifically designed to meet the needs of 
low-income families who would not otherwise be subject to income taxes 
or need to file a return. Outlay programs may also receive more year-to-
year oversight and fine tuning through the legislative and executive 
budget process. In addition, the availability of many different types of 
spending programs--including direct government provision; credit 
programs; and payments to State and local governments, the private 
sector, or individuals in the form of grants or contracts--provides 
flexibility for policy design. On the other hand, certain outlay 
programs--such as direct government service provision--may rely less 
directly on economic incentives and private-market provision than tax 
incentives, which may reduce the relative efficiency of spending 
programs for some goals. Spending programs also require resources to be 
raised via taxes, user charges, or government borrowing. Finally, 
spending programs, particularly on the discretionary side, may respond 
less readily to changing activity levels and economic conditions than 
tax expenditures.
  Regulations have more direct and immediate effects than outlay and 
tax-expenditure programs because regulations apply directly and 
immediately to the regulated party (i.e., the intended actor)--generally 
in the private sector. Regulations can also be fine-tuned more quickly 
than tax expenditures, because they can generally be changed by the 
executive branch without legislation. Like tax expenditures, regulations 
often rely largely upon voluntary compliance, rather than detailed 
inspections and policing. As such, the public administrative costs tend 
to be modest, relative to the private resource costs associated with 
modifying activities. Historically, regulations have tended to rely on 
proscriptive measures, as opposed to economic incentives. This reliance 
can diminish their economic efficiency, although this feature can also 
promote full compliance where (as in certain safety-related cases) 
policymakers believe that trade-offs with economic considerations are 
not of paramount importance. Also, regulations generally do not directly 
affect Federal outlays or receipts. Thus, like tax expenditures, they 
may escape the type of scrutiny that outlay programs receive. However, 
most regulations are subjected to a formal type of benefit-cost analysis 
that goes well beyond the analysis required for outlays and tax-
expenditures. To some extent, the GPRA requirement for performance 
evaluation will address this lack of formal analysis.
  Some policy objectives are achieved using multiple approaches. For 
example, minimum wage legislation, the earned income tax credit, and the 
food stamp program are regulatory, tax expenditure, and direct outlay 
programs, respectively, all having the objective of improving the 
economic welfare of low-wage workers.
  Tax expenditures, like spending and regulatory programs, have a 
variety of objectives and effects. These include: encouraging certain 
types of activities (e.g., saving for retirement or investing in certain 
sectors); increasing certain types of after-tax income (e.g., favorable 
tax treatment of social security income); reducing private compliance 
costs and government administrative costs (e.g., the exclusion for up to 
$500,000 of capital gains on home sales); and promoting tax neutrality 
(e.g., accelerated depreciation in the presence of inflation). Some of 
these objectives are well suited to quantitative measurement, while 
others are less well suited. Also, many tax expenditures, including 
those cited above, may have more than one objective. For example, 
accelerated depreciation may encourage investment. In addition, the 
economic effects of particular provisions can extend beyond their 
intended objectives (e.g., a provision intended to promote an activity 
or raise certain incomes may have positive or negative effects on tax 
neutrality).
  Performance measurement is generally concerned with inputs, outputs, 
and outcomes. In the case of tax expenditures, the principal input is 
usually the tax revenue loss. Outputs are quantitative or qualitative 
measures of goods and services, or changes in income and investment, 
directly produced by these inputs. Outcomes, in turn, represent the 
changes in the economy, society, or environment that are the ultimate 
goals of programs.
  Thus, for a provision that reduces taxes on certain investment 
activity, an increase in the amount of investment would likely be a key 
output. The resulting production from that investment, and, in turn, the 
associated improvements in national income, welfare, or security, could 
be the outcomes of interest. For other provisions, such as those 
designed to address a potential inequity or unintended consequence in 
the tax code, an important performance measure might be how they change 
effective tax rates (the discounted present value of taxes owed on new 
investments or incremental earnings) or excess burden (an economic 
measure of the distortions caused by taxes). Effects on the incomes of 
members of particular groups may be an important measure for certain 
provisions.

  An overview of evaluation issues by budget function. The discussion 
below considers the types of measures that might be useful for some 
major programmatic groups of tax expenditures. The discussion is 
intended to be illustrative and not all encompassing. However, it is 
premised on the assumption that the data needed to perform the analysis 
are available or can be devel

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oped. In practice, data availability is likely to be a major challenge, 
and data constraints may limit the assessment of the effectiveness of 
many provisions. In addition, such assessments can raise significant 
challenges in economic modeling.
  National defense.--Some tax expenditures are intended to assist 
governmental activities. For example, tax preferences for military 
benefits reflect, among other things, the view that benefits such as 
housing, subsistence, and moving expenses are intrinsic aspects of 
military service, and are provided, in part, for the benefit of the 
employer, the U.S. Government. Tax benefits for combat service are 
intended to reduce tax burdens on military personnel undertaking 
hazardous service for the Nation. A portion of the tax expenditure 
associated with foreign earnings is targeted to benefit U.S. Government 
civilian personnel working abroad by offsetting the living costs that 
can be higher than those in the United States. These tax expenditures 
should be considered together with direct agency budget costs in making 
programmatic decisions.
  International affairs.--Tax expenditures are also aimed at promoting 
U.S. exports. These include the exclusion for income earned abroad by 
nongovernmental employees and preferences for income from exports and 
U.S.-controlled foreign corporations. Measuring the effectiveness of 
these provisions raises challenging issues. In addition to determining 
their effectiveness in markets of the benefitting firms, analysis should 
consider the extent to which macroeconomic factors lead to offsetting 
effects, such as increased imports, which could moderate any net effects 
on employment, national output, and trade deficits. Similar issues arise 
in the case of export promotion programs supported by outlays.
  General science, space and technology; energy; natural resources and 
the environment; agriculture; and commerce and housing.--A series of tax 
expenditures reduces the cost of investment, both in specific 
activities--such as research and experimentation, extractive industries, 
and certain financial activities--and more generally, through 
accelerated depreciation for plant and equipment. These provisions can 
be evaluated along a number of dimensions. For example, it could be 
useful to consider the strength of the incentives by measuring their 
effects on the cost of capital (the interest rate which investments must 
yield to cover their costs) and effective tax rates. The impact of these 
provisions on the amounts of corresponding forms of investment--such as 
research spending, exploration activity, or equipment--might also be 
estimated. In some cases, such as research, there is evidence that the 
investment can provide significant positive externalities--that is, 
economic benefits that are not reflected in the market transactions 
between private parties. It could be useful to quantify these 
externalities and compare them with the degree of tax subsidy provided. 
Measures could also indicate the provisions' effects on production from 
these investments--such as numbers or values of patents, energy 
production and reserves, and industrial production. Issues to be 
considered include the extent to which the preferences increase 
production (as opposed to benefitting existing producers) and their 
cost-effectiveness relative to other policies. Analysis could also 
consider objectives that are more difficult to measure but still are 
ultimate goals, such as promoting the Nation's technological base, 
energy security, environmental quality, or economic growth. Such an 
assessment is likely to involve tax analysis as well as consideration of 
non-tax matters such as market structure, scientific, and other 
information (such as the effects of increased domestic fuel production 
on imports from various regions, or the effects of various energy 
sources on the environment).
  Housing investment also benefits from tax expenditures, including the 
mortgage interest deduction and preferential treatment of capital gains 
on homes. Measures of the effectiveness of these provisions could 
include their effects on increasing the extent of home ownership and the 
quality of housing. In addition, the mortgage interest deduction offsets 
the taxable nature of investment income received by homeowners, so the 
relationship between the deduction and such earnings is also relevant to 
evaluation of this provision. Similarly, analysis of the extent of 
accumulated inflationary gains is likely to be relevant to evaluation of 
the capital gains preference for home sales. Deductibility of State and 
local property taxes assists with making housing more affordable as well 
as easing the cost of providing community services through these taxes. 
Provisions intended to promote investment in rental housing could be 
evaluated for their effects on making such housing more available and 
affordable. These provisions should then be compared with alternative 
programs that address housing supply and demand.

  Transportation.--Employer-provided parking is a fringe benefit that, 
for the most part, is excluded from taxation. The tax expenditure 
revenue loss estimates reflect the cost of parking that is leased by 
employers for employees; an estimate is not currently available for the 
value of parking owned by employers and provided to their employees. The 
exclusion for employer-provided transit passes is intended to promote 
use of this mode of transportation, which has environmental and 
congestion benefits. The tax treatments of these different benefits 
could be compared with alternative transportation policies.
  Community and regional development.--A series of tax expenditures is 
intended to promote community and regional development by reducing the 
costs of financing specialized infrastructure, such as airports, docks, 
and stadiums. Empowerment zone and enterprise community provisions are 
designed to promote activity in disadvantaged areas. These provisions 
can be compared with grants and other policies designed to spur economic 
development.

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  Education, training, employment, and social services.--Major 
provisions in this function are intended to promote post-secondary 
education, to offset costs of raising children, and to promote a variety 
of charitable activities. The education incentives can be compared with 
loans, grants, and other programs designed to promote higher education 
and training. The child credits are intended to adjust the tax system 
for the costs of raising children; as such, they could be compared to 
other Federal tax and spending policies, including related features of 
the tax system, such as personal exemptions (which are not defined as a 
tax expenditure). Evaluation of charitable activities requires 
consideration of the beneficiaries of these activities, who are 
generally not the parties receiving the tax reduction.
  Health.--Individuals also benefit from favorable treatment of 
employer-provided health insurance. Measures of these benefits could 
include increased coverage and pooling of risks. The effects of 
insurance coverage on final outcome measures of actual health (e.g., 
infant mortality, days of work lost due to illness, or life expectancy) 
or intermediate outcomes (e.g., use of preventive health care or health 
care costs) could also be investigated.
  Income security, social security, and veterans benefits and 
services.--Major tax expenditures in the income security function 
benefit retirement savings, through employer-provided pensions, 
individual retirement accounts, and Keogh plans. These provisions might 
be evaluated in terms of their effects on boosting retirement incomes, 
private savings, and national savings (which would include the effect on 
private savings as well as public savings or deficits). Interactions 
with other programs, including social security, also may merit analysis. 
As in the case of employer-provided health insurance, analysis of 
employer-provided pension programs requires imputing the benefits 
provided at the firm level to individuals.
  Other provisions principally affect the incomes of members of certain 
groups, rather than affecting incentives. For example, tax-favored 
treatment of social security benefits, certain veterans benefits, and 
deductions for the blind and elderly provide increased incomes to 
eligible parties. The earned-income tax credit, in contrast, should be 
evaluated for its effects on labor force participation as well as the 
income it provides lower-income workers.

  General purpose fiscal assistance and interest.--The tax-exemption for 
public purpose State and local bonds reduces the costs of borrowing for 
a variety of purposes (borrowing for non-public purposes is reflected 
under other budget functions). The deductibility of certain State and 
local taxes reflected under this function primarily relates to personal 
income taxes (property tax deductibility is reflected under the commerce 
and housing function). Tax preferences for Puerto Rico and other U.S. 
possessions are also included here. These provisions can be compared 
with other tax and spending policies as means of benefitting fiscal and 
economic conditions in the States, localities, and possessions. Finally, 
the tax deferral for interest on U.S. savings bonds benefits savers who 
invest in these instruments. The extent of these benefits and any 
effects on Federal borrowing costs could be evaluated.
  The above illustrative discussion, although broad, is nevertheless 
incomplete, both for the provisions mentioned and the many that are not 
explicitly cited. Developing a framework that is sufficiently 
comprehensive, accurate, and flexible to reflect the objectives and 
effects of the wide range of tax expenditures will be a significant 
challenge. OMB, Treasury, and other agencies will work together, as 
appropriate, to address this challenge. As indicated above, over the 
next few years the Executive Branch's focus will be on the availability 
of the data needed to assess the effects of the tax expenditures 
designed to increase savings.

                  Descriptions of Income Tax Provisions

  Descriptions of the individual and corporate income tax expenditures 
reported upon in this chapter follow.

                            National Defense

  1. Benefits and allowances to armed forces personnel.--The housing and 
meals provided military personnel, either in cash or in kind, as well as 
certain amounts of pay related to combat service, are excluded from 
income subject to tax.

                          International Affairs

  2. Income earned abroad.--U.S. citizens who lived abroad, worked in 
the private sector, and satisfyied a foreign residency requirement in 
1999 may exclude up to $74,000 in foreign earned income from U.S. taxes. 
The exclusion increases in 2000, 2001, and 2002 to $76,000, $78,000, and 
$80,000, respectively. In addition, if these taxpayers receive a 
specific allowance for foreign housing from their employers, they may 
also exclude the value of that allowance. If they do not receive a 
specific allowance for housing expenses, they may deduct against their 
U.S. taxes that portion of such expenses that exceeds one-sixth the 
salary of a civil servant at grade GS-14, step 1 ($63,567 in 1999). 
Beginning this year, the value of U.S. tax benefits provided to 
employees of the U.S. government who live and work overseas is not 
included under this heading. Those tax benefits now are included under 
their own heading, Exclusion of Certain Allowances for Federal Employees 
Abroad (#3).
  3. Exclusion of Certain Allowances for Federal Employees Abroad.--U.S. 
Federal civilian employees and Peace Corps members who work outside the 
continental United States are allowed to exclude from U.S. taxable 
income certain special allowances they receive to compensate them for 
the relatively high costs associated with living overseas. The 
allowances supplement wage income and cover expenses like rent, 
education, and the cost of travel to and from the United States.

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  4. Income of Foreign Sales Corporations.--The Foreign Sales 
Corporation (FSC) provisions exempt from tax a portion of U.S. 
exporters' foreign trading income to reflect the FSC's sales functions 
as foreign corporations. These provisions conform to the General 
Agreement on Tariffs and Trade.
  5. Sales source rule exceptions.--The worldwide income of U.S. persons 
is taxable by the United States and a credit for foreign taxes paid is 
allowed. The amount of foreign taxes that can be credited is limited to 
the pre-credit U.S. tax on the foreign source income. The sales source 
rules for inventory property allow U.S. exporters to use more foreign 
tax credits by allowing the exporters to attribute a larger portion of 
their earnings abroad than would be the case if the allocation of 
earnings was based on actual economic activity.
  6. Income of U.S.-controlled foreign corporations.--The income of 
foreign corporations controlled by U.S. shareholders is not subject to 
U.S. taxation. The income becomes taxable only when the controlling U.S. 
shareholders receive dividends or other distributions from their foreign 
stockholding. Under the normal tax method, the currently attributable 
foreign source pre-tax income from such a controlling interest is 
considered to be subject to U.S. taxation, whether or not distributed. 
Thus, the normal tax method considers the amount of controlled foreign 
corporation income not distributed to a U.S. shareholder as tax-deferred 
income.
  7. Exceptions under subpart F for active financing income.--Financial 
firms can defer taxes on income earned overseas in an active business. 
Taxes on income earned through December 31, 2001 can be deferred. The 
Tax Relief Extension Act of 1999 extended the expiration date from 
December 31, 1999 to December 31, 2001.

                 General Science, Space, and Technology

  8. Expensing R&E expenditures.--Research and experimentation (R&E) 
projects can be viewed as investments because, if successful, their 
benefits accrue for several years. It is often difficult, however, to 
identify whether a specific R&E project is successful and, if 
successful, what its expected life will be. Under the normal tax method, 
the expensing of R&E expenditures is viewed as a tax expenditure. The 
baseline assumed for the normal tax method is that all R&E expenditures 
are successful and have an expected life of five years.
  9. R&E credit.--The research and experimentation (R&E) credit, which 
expired on June 30, 1999, was reinstated (retroactively) in the Tax 
Relief Extension Act of 1999 for five years (through June 30, 2004). The 
Act also increased the credit rates for the alternative credit by one 
percentage point and extended the research credit to include research 
conducted in Puerto Rico and the U.S. possessions. The tax credit is 20 
percent of qualified research expenditures in excess of a base amount. 
The base amount is generally determined by multiplying a ``fixed-base 
percentage'' by the average amount of the company's gross receipts for 
the prior four years. The taxpayer's fixed base percentage generally is 
the ratio of its research expenses to gross receipts for 1984 through 
1988. Taxpayers may also elect an alternative credit regime. Under the 
alternative credit regime the taxpayer is assigned a three-tiered fixed-
base percentage that is lower than the fixed-base percentage that would 
otherwise apply, and the credit rate is reduced (the rates range from 
2.65 percent to 3.75 percent). A 20-percent credit with a separate 
threshold is provided for a taxpayer's payments to universities for 
basic research.

                                 Energy

  10. Exploration and development costs.--For successful investments in 
domestic oil and gas wells, intangible drilling costs (e.g., wages, the 
costs of using machinery for grading and drilling, the cost of 
unsalvageable materials used in constructing wells) may be expensed 
rather than amortized over the productive life of the property. 
Integrated oil companies may deduct only 70 percent of such costs and 
must amortize the remaining 30 percent over five years. The same rule 
applies to the exploration and development costs of surface stripping 
and the construction of shafts and tunnels for other fuel minerals.
  11. Percentage depletion.--Independent fuel mineral producers and 
royalty owners are generally allowed to take percentage depletion 
deductions rather than cost depletion on limited quantities of output. 
Under cost depletion, outlays are deducted over the productive life of 
the property based on the fraction of the resource extracted. Under 
percentage depletion, taxpayers deduct a percentage of gross income from 
mineral production at rates of 22 percent for uranium; 15 percent for 
oil, gas and oil shale; and 10 percent for coal. The deduction is 
limited to 50 percent of net income from the property, except for oil 
and gas where the deduction can be 100 percent of net property income. 
Production from geothermal deposits is eligible for percentage depletion 
at 65 percent of net income, but with no limit on output and no 
limitation with respect to qualified producers. Unlike depreciation or 
cost depletion, percentage depletion deductions can exceed the cost of 
the investment.
  12. Alternative fuel production credit.--A nontaxable credit of $3 per 
barrel (in 1979 dollars) of oil-equivalent production is provided for 
several forms of alternative fuels. The credit is generally available if 
the price of oil stays below $29.50 (in 1979 dollars). The credit 
generally expires on December 31, 2002.
  13. Oil and gas exception to passive loss limitation.--Owners of 
working interests in oil and gas properties are exempt from the 
``passive income'' limitations. As a result, the working interest-
holder, who manages on behalf of himself and all other owners the 
development of wells and incurs all the costs of their operation, may 
aggregate negative taxable income from such interests with his income 
from all other sources.
  14. Capital gains treatment of royalties on coal.--Sales of certain 
coal under royalty contracts can be treated as capital gains rather than 
ordinary income.

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  15. Energy facility bonds.--Interest earned on State and local bonds 
used to finance construction of certain energy facilities is tax-exempt. 
These bonds are generally subject to the State private-activity bond 
annual volume cap.
  16. Enhanced oil recovery credit.--A credit is provided equal to 15 
percent of the taxpayer's costs for tertiary oil recovery on U.S. 
projects. Qualifying costs include tertiary injectant expenses, 
intangible drilling and development costs on a qualified enhanced oil 
recovery project, and amounts incurred for tangible depreciable 
property.
  17. New technology credits.--A credit of 10 percent is available for 
investment in solar and geothermal energy facilities. In addition, a 
credit of 1.5 cents is provided per kilowatt hour of electricity 
produced from renewable resources such as wind and biomass. The 
renewable resources credit applies only to electricity produced by a 
facility placed in service on or before December 31, 2001. The Tax 
Relief Extension Act of 1999 extended the expiration date from June 30, 
1999 to December 31, 2001 and expanded the credit to apply to 
electricity produced from poultry waste facilities (placed in service 
after December 31, 1999).
  18. Alcohol fuel credits.--An income tax credit is provided for 
ethanol that is derived from renewable sources and used as fuel. The 
credit equals 54 cents per gallon in 1998, 1999, and 2000; 53 cents per 
gallon in 2001 and 2002; 52 cents per gallon in 2003 and 2004; and 51 
cents per gallon in 2005, 2006, and 2007. To the extent that ethanol is 
mixed with taxable motor fuel to create gasohol, taxpayers may claim an 
exemption of the Federal excise tax rather than the income tax credit. 
In addition, small ethanol producers are eligible for a separate 10 
cents per gallon credit.
  19. Credit and deduction for clean-fuel vehicles and property.--A tax 
credit of 10 percent (not to exceed $4,000) is provided for purchasers 
of electric vehicles. Purchasers of other clean-fuel burning vehicles 
and owners of clean-fuel refueling property may deduct part of their 
expenditures. The credit and deduction are phased out from 2002 through 
2005.
  20. Exclusion of utility conservation subsidies.--Subsidies by public 
utilities for non-business customer expenditures on energy conservation 
measures are excluded from the gross income of the customer.

                    Natural Resources and Environment

  21. Exploration and development costs.--Certain capital outlays 
associated with exploration and development of nonfuel minerals may be 
expensed rather than depreciated over the life of the asset.
  22. Percentage depletion.--Most nonfuel mineral extractors may use 
percentage depletion rather than cost depletion, with percentage 
depletion rates ranging from 22 percent for sulfur to 5 percent for sand 
and gravel.
  23. Sewage, water, and hazardous waste bonds.--Interest earned on 
State and local bonds used to finance the construction of sewage, water, 
or hazardous waste facilities is tax-exempt. These bonds are generally 
subject to the State private-activity bond annual volume cap.
  24. Capital gains treatment of certain timber.--Certain timber sold 
under a royalty contract can be treated as a capital gain rather than 
ordinary income.
  25. Expensing multiperiod timber growing costs.--Most of the 
production costs of growing timber may be expensed rather than 
capitalized and deducted when the timber is sold. In most other 
industries, these costs are capitalized under the uniform capitalization 
rules.
  26. Credit and seven-year amortization for reforestation.--A 10-
percent investment tax credit is allowed for up to $10,000 invested 
annually to clear land and plant trees for the production of timber. Up 
to $10,000 in forestation investment may also be amortized over a seven-
year period rather than capitalized and deducted when the trees are sold 
or harvested. The amount of forestation investment that may be amortized 
is not reduced by any of the allowable investment credit.
  27. Historic preservation.--Expenditures to preserve and restore 
historic structures qualify for a 20-percent investment credit, but the 
depreciable basis must be reduced by the full amount of the credit 
taken.

                               Agriculture

  28. Expensing certain capital outlays.--Farmers, except for certain 
agricultural corporations and partnerships, are allowed to expense 
certain expenditures for feed and fertilizer, as well as for soil and 
water conservation measures. Expensing is allowed, even though these 
expenditures are for inventories held beyond the end of the year, or for 
capital improvements that would otherwise be capitalized.
  29. Expensing multiperiod livestock and crop production costs.--The 
production of livestock and crops with a production period of less than 
two years is exempt from the uniform cost capitalization rules. Farmers 
establishing orchards, constructing farm facilities for their own use, 
or producing any goods for sale with a production period of two years or 
more may elect not to capitalize costs. If they do, they must apply 
straight-line depreciation to all depreciable property they use in 
farming.
  30. Loans forgiven solvent farmers.--Farmers are forgiven the tax 
liability on certain forgiven debt. Normally, a debtor must include the 
amount of loan forgiveness as income or reduce his recoverable basis in 
the property to which the loan relates. If the debtor elects to reduce 
basis and the amount of forgiveness exceeds his basis in the property, 
the excess forgiveness is taxable. For insolvent (bankrupt) debtors, 
however, the amount of loan forgiveness reduces carryover losses, then 
unused credits, and then basis; any remainder of the forgiven debt is 
excluded from tax. Farmers with forgiven debt are considered insolvent 
for tax purposes, and thus qualify for income tax forgiveness.

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  31. Capital gains treatment of certain income.--Certain agricultural 
income, such as unharvested crops, can be treated as capital gains 
rather than ordinary income.
  32. Income averaging for farmers.--Taxpayers can lower their tax 
liability by averaging, over the prior three-year period, their taxable 
income from farming.
  33. Deferral of gain on sales of farm refiners.--A taxpayer who sells 
stock in a farm refiner to a farmers' cooperative can defer recognition 
of gain if the taxpayer reinvests the proceeds in qualified replacement 
property.

                          Commerce and Housing

  This category includes a number of tax expenditure provisions that 
also affect economic activity in other functional categories. For 
example, provisions related to investment, such as accelerated 
depreciation, could be classified under the energy, natural resources 
and environment, agriculture, or transportation categories.
  34. Credit union income.--The earnings of credit unions not 
distributed to members as interest or dividends are exempt from income 
tax.
  35. Bad debt reserves.--Small (less than $500 million in assets) 
commercial banks, mutual savings banks, and savings and loan 
associations may deduct additions to bad debt reserves in excess of 
actually experienced losses.
  36. Deferral of income on life insurance and annuity contracts.--
Favorable tax treatment is provided for investment income within 
qualified life insurance and annuity contracts. Investment income earned 
on qualified life insurance contracts held until death is permanently 
exempt from income tax. Investment income distributed prior to the death 
of the insured is tax-deferred, if not tax-exempt. Investment income 
earned on annuities is treated less favorably than income earned on life 
insurance contracts, but it benefits from tax deferral without annual 
contribution or income limits generally applicable to other tax-favored 
retirement income plans.
  37. Small property and casualty insurance companies.--Insurance 
companies that have annual net premium incomes of less than $350,000 are 
exempt from tax; those with $350,000 to $2.1 million of net premium 
incomes may elect to pay tax only on the income earned by their 
investment portfolio.
  38. Insurance companies owned by exempt organizations.--Generally, the 
income generated by life and property and casualty insurance companies 
is subject to tax, albeit by special rules. Insurance operations 
conducted by such exempt organizations as fraternal societies and 
voluntary employee benefit associations, however, are exempt from tax.
  39. Small life insurance company deduction.--Small life insurance 
companies (gross assets of less than $500 million) can deduct 60 percent 
of the first $3 million of otherwise taxable income. The deduction 
phases out for otherwise taxable income between $3 million and $15 
million.
  40. Mortgage housing bonds.--Interest earned on State and local bonds 
used to finance homes purchased by first-time, low-to-moderate-income 
buyers is tax-exempt. The amount of State and local tax-exempt bonds 
that can be issued to finance such private activity is limited. The 
combined volume cap for mortgage housing bonds, rental housing bonds, 
student loan bonds, and industrial development bonds is $50 per capita 
($150 million minimum) per State. The volume cap increases to $55 per 
capita ($165 million minimum) in 2003 and ratably annually thereafter 
until the cap reaches $75 per capita ($225 million minimum) in 2007. 
States may issue mortgage credit certificates (MCCs) in lieu of mortgage 
revenue bonds. MCCs entitle home buyers to income tax credits for a 
specified percentage of interest on qualified mortgages. The total 
amount of MCCs issued by a State cannot exceed 25 percent of its annual 
ceiling for mortgage-revenue bonds.
  41. Rental housing bonds.--Interest earned on State and local 
government bonds used to finance multifamily rental housing projects is 
tax-exempt. At least 20 percent (15 percent in targeted areas) of the 
units must be reserved for families whose income does not exceed 50 
percent of the area's median income; or 40 percent for families with 
incomes of no more than 60 percent of the area median income. Other tax-
exempt bonds for multifamily rental projects are generally issued with 
the requirement that all tenants must be low or moderate income 
families. Rental housing bonds are subject to the volume cap discussed 
in the mortgage housing bond section above.
  42. Interest on owner-occupied homes.--Owner-occupants of homes may 
deduct mortgage interest on their primary and secondary residences as 
itemized nonbusiness deductions. The mortgage interest deduction is 
limited to interest on debt no greater than the owner's basis in the 
residence and, for debt incurred after October 13, 1987, it is limited 
to no more than $1 million. Interest on up to $100,000 of other debt 
secured by a lien on a principal or second residence is also deductible, 
irrespective of the purpose of borrowing, provided the debt does not 
exceed the fair market value of the residence. Mortgage interest 
deductions on personal residences are tax expenditures because the 
taxpayers are not required to report the value of owner-occupied housing 
services as gross income.
  43. Taxes on owner-occupied homes.--Owner-occupants of homes may 
deduct property taxes on their primary and secondary residences even 
though they are not required to report the value of owner-occupied 
housing services as gross income.
  44. Installment sales.--Dealers in real and personal property (i.e., 
sellers who regularly hold property for sale or resale) cannot defer 
taxable income from installment sales until the receipt of the loan 
repayment. Nondealers (i.e., sellers of real property used in their 
business) are required to pay interest on deferred taxes attributable to 
their total installment obligations in excess of $5 million. Only 
properties with sales prices exceeding $150,000 are includable in the 
total. The pay

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ment of a market rate of interest eliminates the benefit of the tax 
deferral. The tax exemption for nondealers with total installment 
obligations of less than $5 million is, therefore, a tax expenditure.
  45. Capital gains exclusion on home sales.--A homeowner can exclude 
from tax up to $500,000 ($250,000 for singles) of the capital gains from 
the sale of a principal residence. The exclusion may not be used more 
than once every two years.
  46. Passive loss real estate exemption.--In general, passive losses 
may not offset income from other sources. Losses up to $25,000 
attributable to certain rental real estate activity, however, are exempt 
from this rule.
  47. Low-income housing credit.--Taxpayers who invest in certain low-
income housing are eligible for a tax credit. The credit rate is set so 
that the present value of the credit is equal to 70 percent for new 
construction and 30 percent for (1) housing receiving other Federal 
benefits (such as tax-exempt bond financing), or (2) substantially 
rehabilitated existing housing. The credit is allowed in equal amounts 
over 10 years. State agencies determine who receives the credit; States 
are limited in the amount of credit they may authorize annually to $1.25 
per resident.
  48. Accelerated depreciation of rental property.--The tax depreciation 
allowance provisions are part of the reference law rules, and thus do 
not give rise to tax expenditures under the reference method. Under the 
normal tax method, however, a 40-year tax life for depreciable real 
property is the norm. Thus, a statutory depreciation period for rental 
property of 27.5 years is a tax expenditure. In addition, tax 
expenditures arise from pre-1987 tax allowances for rental property.
  49. Cancellation of indebtedness.--Individuals are not required to 
report the cancellation of certain indebtedness as current income. If 
the canceled debt is not reported as current income, however, the basis 
of the underlying property must be reduced by the amount canceled.
  50. Imputed interest rules.--Holders (issuers) of debt instruments are 
generally required to report interest earned (paid) in the period it 
accrues, not when paid. In addition, the amount of interest accrued is 
determined by the actual price paid, not by the stated principal and 
interest stipulated in the instrument. In general, any debt associated 
with the sale of property worth less than $250,000 is excepted from the 
general interest accounting rules. This general $250,000 exception is 
not a tax expenditure under reference law but is under normal law. 
Exceptions above $250,000 are a tax expenditure under reference law; 
these exceptions include the following: (1) sales of personal residences 
worth more than $250,000, and (2) sales of farms and small businesses 
worth between $250,000 and $1 million.
  51. Capital gains (other than agriculture, timber, iron ore, and 
coal).--Capital gains on assets held for more than 1 year are taxed at a 
lower rate than ordinary income. The lower rate on capital gains is 
considered a tax expenditure under the normal tax method but not under 
the reference law method.
  For assets held for more than 1 year, the top tax rate is 20 percent 
(10 percent for taxpayers who would otherwise pay capital gains tax at 
the 15-percent rate).
  In addition, for assets acquired after December 31, 2000, the maximum 
capital gains tax rates for assets held more than 5 years are 8 percent 
and 18 percent (rather than 10 percent and 20 percent). On January 1, 
2001, taxpayers may mark-to-market existing assets to start the 5-year 
holding period.
  52. Capital gains exclusion for small business stock.--An exclusion of 
50 percent is provided for capital gains from qualified small business 
stock held by individuals for more than 5 years. A qualified small 
business is a corporation whose gross assets do not exceed $50 million 
as of the date of issuance of the stock.
  53. Step-up in basis of capital gains at death.--Capital gains on 
assets held at the owner's death are not subject to capital gains taxes. 
The cost basis of the appreciated assets is adjusted upward to the 
market value at the owner's date of death. The step-up in the heir's 
cost basis means that, in effect, the tax on the capital gain is 
forgiven.
  54. Carryover basis of capital gains on gifts.--When a gift is made, 
the donor's basis in the transferred property (the cost that was 
incurred when the transferred property was first acquired) carries-over 
to the donee. The carryover of the donor's basis allows a continued 
deferral of unrealized capital gains.
  55. Ordinary income treatment of losses from sale of small business 
corporate stock shares.--Up to $100,000 in losses from the sale of small 
business corporate stock (capitalization less than $1 million) may be 
treated as ordinary losses. Such losses would, thus, not be subject to 
the $3,000 annual capital loss write-off limit.
  56. Accelerated depreciation of non-rental-housing buildings.--The tax 
depreciation allowance provisions are part of the reference law rules, 
and thus do not give rise to tax expenditures under reference law. Under 
normal law, however, a 40-year life for non-rental-housing buildings is 
the norm. Thus, the 39-year depreciation period for property placed in 
service after February 25, 1993, the 31.5-year depreciation period for 
property placed in service from 1987 to February 25, 1993, and the pre-
1987 depreciation periods create a tax expenditure.
  57. Accelerated depreciation of machinery and equipment.--The tax 
depreciation allowance provisions are part of the reference law rules, 
and thus do not give rise to tax expenditures under reference law. 
Statutory depreciation of machinery and equipment, however, is 
accelerated somewhat relative to the normal tax baseline, creating a tax 
expenditure.
  58. Expensing of certain small investments.--In 1999, qualifying 
investments in tangible property up to $19,000 can be expensed rather 
than depreciated

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over time. (The expensing limit increases annually until 2003, when it 
reaches $25,000). To the extent that qualifying investment during the 
year exceeds $200,000, the amount eligible for expensing is decreased. 
In 1999, the amount expensed is completely phased out when qualifying 
investments exceed $219,000.
  59. Business start-up costs.--When taxpayers enter into a new 
business, certain start-up expenses, such as the cost of legal services, 
are normally incurred. Taxpayers may elect to amortize these outlays 
over 60 months even though they are similar to other payments made for 
nondepreciable intangible assets that are not recoverable until the 
business is sold. The normal tax method treats this amortization as a 
tax expenditure; the reference tax method does not.
  60. Graduated corporation income tax rate schedule.--The corporate 
income tax schedule is graduated, with rates of 15 percent on the first 
$50,000 of taxable income, 25 percent on the next $25,000, and 34 
percent on the next $9.925 million. Compared with a flat 34-percent 
rate, the lower rates provide an $11,750 reduction in tax liability for 
corporations with taxable income of $10 million. This benefit is 
recaptured for corporations with taxable incomes exceeding $100,000 by a 
5-percent additional tax on corporate incomes in excess of $100,000, but 
less than $335,000.
  The corporate tax rate is 35 percent on income over $10 million. 
Compared with a flat 35-percent tax rate, the 34-percent rate provides a 
$100,000 reduction in tax liability for corporations with taxable 
incomes of $10 million. This benefit is recaptured for corporations with 
taxable incomes exceeding $15 million by a 3-percent additional tax on 
income over $15 million but less than $18.33 million. Because the 
corporate rate schedule is part of reference tax law, it is not 
considered a tax expenditure under the reference method. A flat 
corporation income tax rate is taken as the baseline under the normal 
tax method; therefore the lower rates is considered a tax expenditure 
under this concept.
  61. Small issue industrial development bonds.--Interest earned on 
small issue industrial development bonds (IDBs) issued by State and 
local governments to finance manufacturing facilities is tax-exempt. 
Depreciable property financed with small issue IDBs must be depreciated, 
however, using the straight-line method. The annual volume of small 
issue IDBs is subject to the unified volume cap discussed in the 
mortgage housing bond section above.

                             Transportation

  62. Deferral of tax on U.S. shipping companies.--Certain companies 
that operate U.S. flag vessels can defer income taxes on that portion of 
their income used for shipping purposes, primarily construction, 
modernization and major repairs to ships, and repayment of loans to 
finance these investments. Once indefinite, the deferral has been 
limited to 25 years since January 1, 1987.
  63. Exclusion of employee parking expenses.--Employee parking expenses 
that are paid for by the employer or that are received in lieu of wages 
are excludable from the income of the employee. In 1999, the maximum 
amount of the parking exclusion was $175 (indexed, except in 1999) per 
month. The tax expenditure estimate does not include parking at 
facilities owned by the employer.
  64. Exclusion of employee transit pass expenses.--Transit passes, 
tokens, fare cards, and vanpool expenses paid for by an employer or 
provided in lieu of wages to defray an employee's commuting costs are 
excludable from the employee's income. In 1999, the maximum amount of 
the exclusion wasis $65 (indexed, except in 1999) per month.

                   Community and Regional Development

  65. Rehabilitation of structures.--A 10-percent investment tax credit 
is available for the rehabilitation of buildings that are used for 
business or productive activities and that were erected before 1936 for 
other than residential purposes. The taxpayer's recoverable basis must 
be reduced by the amount of the credit.
  66. Airport, dock, and similar facility bonds.--Interest earned on 
State and local bonds issued to finance high-speed rail facilities and 
government-owned airports, docks, wharves, and sport and convention 
facilities is tax-exempt. These bonds are not subject to a volume cap.
  67. Exemption of income of mutuals and cooperatives.--The incomes of 
mutual and cooperative telephone and electric companies are exempt from 
tax if at least 85 percent of their revenues are derived from patron 
service charges.
  68. Empowerment zones and enterprise communities.--Qualifying 
businesses in designated economically depressed areas can receive tax 
benefits such as an employer wage credit, increased expensing of 
investment in equipment, special tax-exempt financing, and accelerated 
depreciation. A tax credit for contributions to certain community 
development corporations can also be available. In addition, certain 
first-time buyers of a principal residence in the District of Columbia 
can receive a tax credit on homes purchased on or before December 31, 
2001, and investors in certain D.C. property can receive a capital gains 
break.
  69. Expensing of environmental remediation costs.--Taxpayers who clean 
up hazardous substances at a qualified site may expense the clean-up 
costs, rather than capitalize the costs, even though the expenses will 
generally increase the value of the property significantly or 
appreciably prolong the life of the property. The expensing only applies 
to clean-up costs incurred on or before December 31, 2001. Tax Relief 
Extension Act of 1999 extended the expiration date from December 31, 
2000 to December 31, 2001.

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          Education, Training, Employment, and Social Services

  70. Scholarship and fellowship income.--Scholarships and fellowships 
are excluded from taxable income to the extent they pay for tuition and 
course-related expenses of the grantee. Similarly, tuition reductions 
for employees of educational institutions and their families are not 
included in taxable income. From an economic point of view, scholarships 
and fellowships are either gifts not conditioned on the performance of 
services, or they are rebates of educational costs. Thus, under the 
reference law method, this exclusion is not a tax expenditure because 
this method does not include either gifts or price reductions in a 
taxpayer's gross income. The exclusion, however, is considered a tax 
expenditure under the normal tax method, which includes gift-like 
transfers of government funds in gross income (many scholarships are 
derived directly or indirectly from government funding).
  71. HOPE tax credit.--The non-refundable HOPE tax credit allows a 
credit for 100 percent of an eligible student's first $1,000 of tuition 
and fees and 50 percent of the next $1,000 of tuition and fees. The 
credit only covers tuition and fees paid during the first two years of a 
student's post-secondary education. The credit is phased out ratably for 
taxpayers with modified AGI between $80,000 and $100,000 ($40,000 and 
$50,000 for singles).
  72. Lifetime Learning tax credit.--The non-refundable Lifetime 
Learning tax credit allows a credit for 20 percent of an eligible 
student's tuition and fees. For tuition and fees paid before January 1, 
2003, the maximum credit per return is $1,000. For tuition and fees paid 
after December 31, 2002, the maximum credit per return is $2,000. The 
credit is phased out ratably for taxpayers with modified AGI between 
$80,000 and $100,000 ($40,000 and $50,000 for singles). The credit 
applies to both undergraduate and graduate students.
  73. Education Individual Retirement Accounts.--Contributions to an 
education IRA are not tax-deductible. Investment income earned by 
education IRAs is not taxed when earned, and investment income from an 
education IRA is tax-exempt when withdrawn to pay for a student's 
tuition and fees. The maximum contribution to an education IRA is $500 
per year per beneficiary. The maximum contribution is phased down 
ratably for taxpayers with modified AGI between $150,000 and $160,000 
($95,000 and $110,000 for singles). Contributions may not be made to an 
education IRA in any year in which a contribution has been made to a 
State tuition plan for the same beneficiary.
  74. Student-loan interest.--Taxpayers may claim an above-the-line 
deduction of up to $2,500 ($1,000 in 1998, $1,500 in 1999, and $2,000 in 
2000) on interest paid on an education loan. Interest may only be 
deducted for the first five years in which interest payments are 
required. The maximum deduction is phased down ratably for taxpayers 
with modified AGI between $60,000 and $75,000 ($40,000 and $55,000 for 
singles).
  75. State prepaid tuition plans.--Some States have adopted prepaid 
tuition plans and prepaid room and board plans, which allow persons to 
pay in advance for college expenses for designated beneficiaries. Taxes 
on the earnings from these plans are paid by the beneficiaries and are 
deferred until the tuition is actually paid.
  76. Student-loan bonds.--Interest earned on State and local bonds 
issued to finance student loans is tax-exempt. The volume of all such 
private activity bonds that each State may issue annually is limited.
  77. Bonds for private nonprofit educational institutions.--Interest 
earned on State and local government bonds issued to finance the 
construction of facilities used by private nonprofit educational 
institutions is not taxed. The aggregate volume of all such private 
activity bonds that each State may issue during any calendar year is 
limited.
  78. Credit for holders of zone academy bonds.--Financial institutions 
that own zone academy bonds receive a non-refundable tax credit (set by 
the Treasury Department) rather than interest. The credit is included in 
gross income. Proceeds from zone academy bonds may only be used to 
improve impoverished schools. The total amount of zone academy bonds 
that may be issued is limited to $1.6 billion--$400 million in each year 
between 1998 and 2001. The Tax Relief Extension Act of 1999 allowed 
bonds to be issued in 2000 and 2001.
  79. U.S. savings bonds for education.--Interest earned on U.S. savings 
bonds issued after December 31, 1989 is tax-exempt if the bonds are 
transferred to an educational institution to pay for educational 
expenses. The tax exemption is phased out for taxpayers with AGI between 
$79,650 and $109,650 ($53,100 and $68,100 for singles) in 1999.
  80. Dependent students age 19 or older.--Taxpayers may claim personal 
exemptions for dependent children age 19 or over who (1) receive 
parental support payments of $1,000 or more per year, (2) are full-time 
students, and (3) do not claim a personal exemption on their own tax 
returns.
  81. Child credit.--Taxpayers with children under age 17 can qualify 
for a $500 child credit. The credit is phased out for taxpayers at the 
rate of $50 per $1,000 of modified AGI above $110,000 ($75,000 for 
singles). The child credit is refundable for taxpayers with three or 
more children.
  82. Charitable contributions to educational institutions.--Taxpayers 
may deduct contributions to nonprofit educational institutions. 
Taxpayers who donate capital assets to educational institutions can 
deduct the assets' current value without being taxed on any appreciation 
in value. An individual's total charitable contribution generally may 
not exceed 50 percent of adjusted gross income; a corporation's total 
charitable contributions generally may not exceed 10 percent of pre-tax 
income.
  83. Employer-provided educational assistance.--Employer-provided 
educational assistance is excluded

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from an employee's gross income even though the employer's costs for 
this assistance are a deductible business expense. This exclusion 
applies only to non-graduate courses beginning on or before December 31, 
2001. The Tax Relief Extension Act of 1999 extended the expiration date 
from May 31, 2000 to December 31, 2001.
  84. Work opportunity tax credit.--Employers can claim a tax credit for 
qualified wages paid to individuals who begin work on or before December 
31, 2000 and who are certified as members of various targeted groups. 
The Tax Relief Extension Act of 1999 extended the expiration date from 
June 30, 1999 to December 31, 2000. The amount of the credit that can be 
claimed is 25 percent for employment of less than 400 hours and 40 
percent for employment of 400 hours or more. The maximum credit per 
employee is $2,400 and can only be claimed on the first year of wages an 
individual earns from an employer. Employers must reduce their deduction 
for wages paid by the amount of the credit claimed.
  85. Welfare-to-work tax credit.--An employer is eligible for a tax 
credit on the first $20,000 of eligible wages paid to qualified long-
term family assistance recipients during the first two years of 
employment. The credit is 35 percent of the first $10,000 of wages in 
the first year of employment and 50 percent of the first $10,000 of 
wages in the second year of employment. The maximum credit is $8,500 per 
employee. The credit applies to wages paid to employees who are hired on 
or before December 31, 2001. The Tax Relief Extension Act of 1999 
extended the expiration date from June 30, 1999 to December 31, 2001.
  86. Employer-provided child care.--Employer-provided child care is 
excluded from an employee's gross income even though the employer's 
costs for the child care are a deductible business expense.
  87. Adoption credit and exclusion.--Taxpayers can receive a 
nonrefundable tax credit for qualified adoption expenses. The maximum 
credit is $5,000 per child ($6,000 for special needs adoptions, except 
foreign adoptions). The credit is phased-out ratably for taxpayers with 
modified AGI between $75,000 and $115,000. Unused credits may be carried 
forward. In lieu of the tax credit, taxpayers may exclude qualified 
adoption expenses from income, subject to the same maximum amounts and 
phase-out as the credit. The non-special needs adoption assistance and 
foreign special needs assistance expire on December 31, 2001.
  88. Employer-provided meals and lodging.--Employer-provided meals and 
lodging are excluded from an employee's gross income even though the 
employer's costs for these items are a deductible business expense.
  89. Child and dependent care expenses.--Married couples with child and 
dependent care expenses may claim a tax credit when one spouse works 
full time and the other works at least part time or goes to school. The 
credit may also be claimed by divorced or separated parents who have 
custody of children, and by single parents. Expenditures up to a maximum 
$2,400 for one dependent and $4,800 for two or more dependents are 
eligible for the credit. The credit is equal to 30 percent of qualified 
expenditures for taxpayers with incomes of $10,000 or less. The credit 
is reduced to a minimum of 20 percent by one percentage point for each 
$2,000 of income between $10,000 and $28,000.
  90. Disabled access expenditure credit.--Small businesses (less than 
$1 million in gross receipts or fewer than 31 full-time employees) can 
claim a 50-percent credit for expenditures in excess of $250 to remove 
access barriers for disabled persons. The credit is limited to $5,000.
  91. Expensing costs of removing architectural barriers.--Taxpayers can 
expense (up to $15,000 annually) the cost of removing architectural 
barriers to the handicapped rather than depreciate the cost over the 
useful life of the asset.
  92. Charitable contributions, other than education and health.--
Taxpayers may deduct contributions to charitable, religious, and certain 
other nonprofit organizations. Taxpayers who donate capital assets to 
charitable organizations can deduct the assets' current value without 
being taxed on any appreciation in value. An individual's total 
charitable contribution generally may not exceed 50 percent of adjusted 
gross income; a corporation's total charitable contributions generally 
may not exceed 10 percent of pre-tax income.
  93. Foster care payments.--Foster parents provide a home and care for 
children who are wards of the State, under contract with the State. 
Compensation received for this service is excluded from the gross 
incomes of foster parents; the expenses they incur are nondeductible.
  94. Parsonage allowances.--The value of a minister's housing allowance 
and the rental value of parsonages are not included in a minister's 
taxable income.

                                 Health

  95. Employer-paid medical insurance and expenses.--Employer-paid 
health insurance premiums and other medical expenses (including long-
term care) are deducted as a business expense by employers, but they are 
not included in employee gross income. The self-employed also may deduct 
part of their family health insurance premiums.
  96. Self-employed medical insurance premiums.--Self-employed taxpayers 
may deduct a percentage of their family health insurance premiums. 
Taxpayers without self-employment income are not eligible for the 
special percentage deduction. The deductible percentage is 60 percent in 
1999 through 2001, 70 percent in 2002, and 100 percent in 2003 and 
thereafter.
  97. Workers compensation insurance premiums.--Workers compensation 
insurance premiums are paid by employers and deducted as a business 
expense, but the premiums are not included in employee gross income.
  98. Medical savings accounts.--Some employees may deduct annual 
contributions to a medical savings

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account (MSA); employer contributions to MSAs (except those made through 
cafeteria plans) for qualified employees are also excluded from income. 
An employee may contribute to an MSA in a given year only if the 
employer does not contribute to the MSA in that year. MSAs are only 
available to self-employed individuals or employees covered under an 
employer-sponsored high deductible health plan of a small employer. The 
maximum annual MSA contribution is 75 percent of the deductible under 
the high deductible plan for family coverage (65 percent for individual 
coverage). Earnings from MSAs are excluded from taxable income. 
Distributions from an MSA for medical expenses are not taxable. The 
number of taxpayers who may benefit annually from MSAs is generally 
limited to 750,000. No new MSAs may be established after December 31, 
2000.
  99. Medical care expenses.--Personal expenditures for medical care 
(including the costs of prescription drugs) exceeding 7.5 percent of the 
taxpayer's adjusted gross income are deductible.
  100. Hospital construction bonds.--Interest earned on State and local 
government debt issued to finance hospital construction is excluded from 
income subject to tax.
  101. Charitable contributions to health institutions.--Individuals and 
corporations may deduct contributions to nonprofit health institutions. 
Tax expenditures resulting from the deductibility of contributions to 
other charitable institutions are listed under the education, training, 
employment, and social services function.
  102. Orphan drugs.--Drug firms can claim a tax credit of 50 percent of 
the costs for clinical testing required by the Food and Drug 
Administration for drugs that treat rare physical conditions or rare 
diseases.
  103. Blue Cross and Blue Shield.--Blue Cross and Blue Shield health 
insurance providers in existence on August 16, 1986 and certain other 
nonprofit health insurers are provided exceptions from otherwise 
applicable insurance company income tax accounting rules that 
substantially reduce (or even eliminate) their tax liabilities.

                             Income Security

  104. Railroad retirement benefits.--Railroad retirement benefits are 
not generally subject to the income tax unless the recipient's gross 
income reaches a certain threshold. The threshold is discussed more 
fully under the social security function.
  105. Workers' compensation benefits.--Workers compensation provides 
payments to disabled workers. These benefits, although income to the 
recipients, are not subject to the income tax.
  106. Public assistance benefits.--Public assistance benefits are 
excluded from tax. The normal tax method considers cash transfers from 
the government as taxable and, thus, treats the exclusion for public 
assistance benefits as a tax expenditure.
  107. Special benefits for disabled coal miners.--Disability payments 
to former coal miners out of the Black Lung Trust Fund, although income 
to the recipient, are not subject to the income tax.
  108. Military disability pensions.--Most of the military pension 
income received by current disabled retired veterans is excluded from 
their income subject to tax.
  109. Employer-provided pension contributions and earnings.--Certain 
employer contributions to pension plans are excluded from an employee's 
gross income even though the employer can deduct the contributions. In 
addition, the tax on the investment income earned by the pension plans 
is deferred until the money is withdrawn.
  110. 401(k) plans and Individual Retirement Accounts.--Individual 
taxpayers can take advantage of several different tax-preferenced 
retirement plans: deductible IRAs, non-deductible IRAs, Roth IRAs, and 
401(k) plans (and 401(k)-type plans like 403(b) plans and the 
government's Thrift Savings Plan).
  In 1999, an employee could exclude up to $10,000 (indexed) of wages 
from AGI under a qualified arrangement with an employer's 401(k). 
Employees can annually contribute to a deductible IRA up to $2,000 (or 
100 percent of compensation, if less) or $4,000 on a joint return with 
only one working spouse if: (a) neither the individual nor spouse is an 
active participant in an employer-provided retirement plan, or (b) their 
AGI is below $40,000 ($25,000 for singles). The IRA deduction is phased 
out for taxpayers with AGI between $50,000 and $60,000 ($30,000 and 
$40,000 for singles). The phase-out range increases annually until it 
reaches $80,000 to $100,000 in 2007 ($50,000 to $60,000 for singles). 
Taxpayers whose AGI is above the start of the IRA phase-out range or who 
are active participants in an employer-provided retirement plan can 
contribute to a non-deductible IRA. The tax on the investment income 
earned by 401(k) plans, non-deductible IRAs, and deductible IRAs is 
deferred until the money is withdrawn.
  An employed taxpayer can make a non-deductible contribution of up to 
$2,000 (a non-employed spouse can also contribute up to $2,000 if a 
joint return is filed) to a Roth IRA. Investment income of a Roth IRA is 
not taxed when earned. Withdrawals from a Roth IRA are tax free if (1) 
the Roth IRA was opened at least 5 years before the withdrawal, and (2) 
the taxpayer either (a) is at least 59-1/2, (b) dies, (c) is disabled, 
or (d) purchases a first-time house. The maximum contribution to a Roth 
IRA is phased out for taxpayers with AGI between $150,000 and $160,000 
($95,000 and $110,000 for singles). Total annual contributions to a 
taxpayer's deductible, non-deductible, and Roth IRAs cannot exceed 
$2,000 ($4,000 for joints).
  111. Keogh plans.--Self-employed individuals can make deductible 
contributions to their own retirement (Keogh) plans equal to 25 percent 
of their income, up to a maximum of $30,000 per year. In addition, the 
tax on the investment income earned by Keogh plans is deferred until the 
money is withdrawn.

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  112. Employer-provided life insurance benefits.--Employer-provided 
life insurance benefits are excluded from an employee's gross income 
even though the employer's costs for the insurance are a deductible 
business expense.
  113. Employer-provided accident and disability benefits.--Employer-
provided accident and disability benefits are excluded from an 
employee's gross income even though the employer's costs for the 
benefits are a deductible business expense.
  114. Employer-provided supplementary unemployment benefits.--Employer-
provided supplementary unemployment benefits are excluded from an 
employee's gross income even though the employer's costs for the 
benefits are a deductible business expense.
  115. Employer Stock Ownership Plan (ESOP) provisions.--ESOPs are a 
special type of tax-exempt employee benefit plan. Employer-paid 
contributions (the value of stock issued to the ESOP) are deductible by 
the employer as part of employee compensation costs. They are not 
included in the employees' gross income for tax purposes, however, until 
they are paid out as benefits. The following special income tax 
provisions for ESOPs are intended to increase ownership of corporations 
by their employees: (1) annual employer contributions are subject to 
less restrictive limitations; (2) ESOPs may borrow to purchase employer 
stock, guaranteed by their agreement with the employer that the debt 
will be serviced by his payment (deductible by him) of a portion of 
wages (excludable by the employees) to service the loan; (3) employees 
who sell appreciated company stock to the ESOP may defer any taxes due 
until they withdraw benefits; and (4) dividends paid to ESOP-held stock 
are deductible by the employer.
  116. Additional deduction for the blind.--Taxpayers who are blind may 
take an additional $1,000 standard deduction if single, or $800 if 
married.
  117. Additional deduction for the elderly.--Taxpayers who are 65 years 
or older may take an additional $1,000 standard deduction if single, or 
$800 if married.
  118. Tax credit for the elderly and disabled.--Individuals who are 65 
years of age or older, or who are permanently disabled, can take a tax 
credit equal to 15 percent of the sum of their earned and retirement 
income. Income is limited to no more than $5,000 for single individuals 
or married couples filing a joint return where only one spouse is 65 
years of age or older, and up to $7,500 for joint returns where both 
spouses are 65 years of age or older. These limits are reduced by one-
half of the taxpayer's adjusted gross income over $7,500 for single 
individuals and $10,000 for married couples filing a joint return.
  119. Casualty losses.--Neither the purchase of property nor insurance 
premiums to protect its value are deductible as costs of earning income; 
therefore, reimbursement for insured loss of such property is not 
reportable as a part of gross income. Taxpayers, however, may deduct 
uninsured casualty and theft losses of more than $100 each, but only to 
the extent that total losses during the year exceed 10 percent of AGI.
  120. Earned income tax credit (EITC).--The EITC may be claimed by low 
income workers. For a family with one qualifying child, the credit is 34 
percent of the first $6,800 of earned income in 1999. The credit is 40 
percent of the first $9,540 of income for a family with two or more 
qualifying children. When the taxpayer's income exceeds $12,460, the 
credit is phased out at the rate of 15.98 percent (21.06 percent if two 
or more qualifying children are present). It is completely phased out at 
$26,928 of modified adjusted gross income ($30,580 if two or more 
qualifying children are present).
  The credit may also be claimed by workers who do not have children 
living with them. Qualifying workers must be at least age 25 and may not 
be claimed as a dependent on another taxpayer's return. The credit is 
not available to workers age 65 or older. In 1999, the credit is 7.65 
percent of the first $4,530 of earned income. When the taxpayer's income 
exceeds $5,670, the credit is phased out at the rate of 7.65 percent. It 
is completely phased out at $10,200 of modified adjusted gross income.
  For workers with or without children, the income level at which the 
credit's phase-outs begin and the maximum amounts of income on which the 
credit can be taken are adjusted for inflation. Earned income tax 
credits in excess of tax liabilities owed through the individual income 
tax system are refundable to individuals. This portion of the credit is 
shown as an outlay, while the amount that offsets tax liabilities is 
shown as a tax expenditure.

                             Social Security

  121. Social Security benefits for retired workers.--Social security 
benefits that exceed the beneficiary's contributions out of taxed income 
are deferred employee compensation and the deferral of tax on that 
compensation is a tax expenditure. These additional retirement benefits 
are paid for partly by employers' contributions that were not included 
in employees' taxable compensation. Portions (reaching as much as 85 
percent) of recipients' social security and tier 1 railroad retirement 
benefits are included in the income tax base, however, if the 
recipient's provisional income exceeds certain base amounts. Provisional 
income is equal to adjusted gross income plus foreign or U.S. possession 
income and tax-exempt interest, and one half of social security and tier 
1 railroad retirement benefits. The tax expenditure is limited to the 
portion of the benefits received by taxpayers who are below the base 
amounts at which 85 percent of the benefits are taxable.
  122. Social Security benefits for the disabled.--Benefit payments from 
the Social Security Trust Fund, for disability and for dependents and 
survivors, are excluded from the beneficiaries' gross incomes.
  123. Social Security benefits for dependents and survivors.--Benefit 
payments from the Social Security

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Trust Fund for dependents and survivors are excluded from the 
beneficiaries' gross income.

                     Veterans Benefits and Services

  124. Veterans death benefits and disability compensation.--All 
compensation due to death or disability paid by the Veterans 
Administration is excluded from taxable income.
  125. Veterans pension payments.--Pension payments made by the Veterans 
Administration are excluded from gross income.
  126. G.I. Bill benefits.--G.I. Bill benefits paid by the Veterans 
Administration are excluded from gross income.
  127. Tax-exempt mortgage bonds for veterans.--Interest earned on 
general obligation bonds issued by State and local governments to 
finance housing for veterans is excluded from taxable income. The 
issuance of such bonds is limited, however, to five pre-existing State 
programs and to amounts based upon previous volume levels for the period 
January 1, 1979 to June 22, 1984. Furthermore, future issues are limited 
to veterans who served on active duty before 1977.

                           General Government

  128. Public purpose State and local bonds.--Interest earned on State 
and local government bonds issued to finance public purpose construction 
(e.g., schools, roads, sewers) is tax-exempt.
  129. Deductibility of certain nonbusiness State and local taxes.--
Taxpayers may deduct State and local income taxes and property taxes 
even though these taxes primarily pay for services that, if purchased 
directly by taxpayers, would not be deductible.
  130. Business income earned in U.S. possessions.--U.S. corporations 
receiving income from investments or businesses located in a U.S. 
possession (e.g., Puerto Rico) can claim a credit against U.S. tax, 
which effectively excludes some of this income from tax. The credit 
expires December 31, 2005.

                                Interest

  131. U.S. savings bonds.--Taxpayers may defer paying tax on interest 
earned on U.S. savings bonds until the bonds are redeemed.

              TAX EXPENDITURES IN THE UNIFIED TRANSFER TAX

  Exceptions to the general terms of the Federal unified transfer tax 
favor particular transferees or dispositions of transferors, similar to 
Federal direct expenditure or loan programs. The transfer tax provisions 
identified as tax expenditures satisfy the reference law criteria for 
inclusion in the tax expenditure budget that were described above. There 
is no generally accepted normal tax baseline for transfer taxes.

                  Unified Transfer Tax Reference Rules

  The reference tax rules for the unified transfer tax from which 
departures represent tax expenditures include:
    Definition of the taxpaying unit. The payment of the tax is 
          the liability of the transferor whether the transfer of cash 
          or property was made by gift or bequest.
     Definition of the tax base. The base for the tax is the 
          transferor's cumulative, taxable lifetime gifts made plus the 
          net estate at death. Gifts in the tax base are all annual 
          transfers in excess of $10,000 (indexed) to any donee except 
          the donor's spouse. Excluded are, however, payments on behalf 
          of family members' educational and medical expenses, as well 
          as the cost of ceremonial gatherings and celebrations that are 
          not in honor of the donor.
     Property valuation. In general, property is valued at its 
          fair market value at the time it is transferred. This is not 
          necessarily the case in the valuation of property for transfer 
          tax purposes. Executors of estates are provided the option to 
          value assets at the time of the testator's death or up to six 
          months later.
     Tax rate schedule. A single graduated tax rate schedule 
          applies to all taxable transfers. This is reflected in the 
          name of the ``unified transfer tax'' that has replaced the 
          former separate gift and estate taxes. The tax rates vary from 
          18 percent on the first $10,000 of aggregate taxable 
          transfers, to 55 percent on amounts exceeding $3 million. A 
          lifetime credit is provided against the tax in determining the 
          final amount of transfer taxes that are due and payable. For 
          decedents dying in 1999, this credit allows each taxpayer to 
          make a $650,000 tax-free transfer of assets that otherwise 
          would be liable to the unified transfer tax. This figure is 
          scheduled to increase in steps to $1 million in 2005.\7\
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  \7\ An additional tax, at a flat rate of 55 percent, is imposed on 
lifetime, generation-skipping transfers in excess of $1 million. It is 
considered a generation-skipping transfer whenever the transferee is at 
lease two generations younger than the transferor, as it would be in the 
case of transfers to grandchildren or great-grandchildren. The liability 
of this tax is on the recipients of the transfer.
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     Time when tax is due and payable. Donors are required to 
          pay the tax annually as gifts are made. The generation-
          skipping transfer tax is payable by the donees whenever they 
          accede to the gift. The net estate tax liability is due and 
          payable within nine months after the decedent's death. The 
          Internal Revenue Service may grant an extension of up to 10 
          years for a reasonable cause. Interest is charged on the 
          unpaid tax liability at a rate equal to the cost of Federal 
          short-term borrowing, plus three percentage points.

                      Tax Expenditures by Function

  The estimates of tax expenditures in the Federal unified transfer tax 
for fiscal years 1999-2005 are dis

[[Page 138]]

played by functional category in Table 5-6. Outlay equivalent estimates 
are similar to revenue loss estimates for transfer tax expenditures and, 
therefore, are not shown separately. A description of the provisions 
follows.

                    Natural Resources and Environment

  1. Donations of conservation easements.--Bequests of property and 
easements (in perpetuity) for conservation purposes can be excluded from 
taxable estates. Use of the property and easements must be restricted to 
at least one of the following purposes: outdoor recreation or scenic 
enjoyment for the general public; protection of the natural habitats of 
fish, wildlife, plants, etc.; and preservation of historic land areas 
and structures. Conservation gifts are similarly excluded from the gift 
tax. Up to 40 percent of the value of land subject to certain 
conservation easements may be excluded from taxable estates; the maximum 
amount of the exclusion is $200,000 in 1999 and increases by $100,000 in 
each year through 2002.

                               Agriculture

  2. Special-use valuation of farms.--Up to $750,000 (indexed) in 
farmland owned and operated by a decedent and/or a member of the family 
may be valued for estate tax purposes on the basis of its ``continued 
use'' as farmland if: (1) the value of the farmland is at least 25 
percent of the gross estate; (2) the entire value of all farm property 
is at least 50 percent of the gross estate; and (3) family heirs to the 
farm agree to continue to operate the property as a farm for at least 10 
years.
  3. Tax deferral of closely held farms.--The tax on a decedent's farm 
can be deferred for up to 14 years if the value of the farm is at least 
35 percent of the net estate. For the first 4 years of deferral, no tax 
need be paid. During the last 10 years of deferral, the tax liability 
must be paid in equal annual installments. Throughout the 14 year 
period, interest is charged at a special, favorable rate.

                          Commerce and Housing

  4. Special-use valuation of closely-held businesses.--The special-use 
valuation rule available for family farms is also available for nonfarm 
family businesses. To be eligible for the special-use valuation, the 
same three conditions previously described must be met.
  5. Tax deferral of closely-held businesses.--The tax-deferral rule 
available for family farms is also available for nonfarm family 
businesses. To be eligible for the tax deferral, the value of stock in 
closely-held corporations must exceed 35 percent of the decedent's gross 
estate, less debt and funeral expenses.
  6. Exclusion for family-owned businesses.--Certain family-owned 
businesses that are bequeathed to qualified heirs can be excluded from 
taxable estates. The exclusion generally cannot exceed $1.3 million less 
the exemption value of the unified credit. The exclusion is recaptured 
if certain conditions are not maintained for 10 years.

          Education, Training, Employment, and Social Services

  7. Charitable contributions to educational institutions.--Bequests to 
educational institutions can be deducted from taxable estates.
  8. Charitable contributions, other than education and health.--
Bequests to charitable, religious, and certain other nonprofit 
organizations can be deducted from taxable estates.

                                 Health

  9. Charitable contributions to health institutions.--Bequests to 
health institutions can be deducted from taxable estates.

                           General Government

  10. State and local death taxes.--A credit against the Federal estate 
tax is allowed for State taxes on bequests. The amount of this credit is 
determined by a rate schedule that reaches a maximum of 16 percent of 
the taxable estate in excess of $60,000.

[[Page 139]]

                                     

                               Table 5-6.  REVENUE LOSS ESTIMATES FOR TAX EXPENDITURES IN THE FEDERAL UNIFIED TRANSFER TAX
                                                                (In millions of dollars)
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                                     Description                           1999      2000      2001      2002      2003      2004      2005    2001-2005
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             Natural Resources and Environment:
       1       Donations of conservation easements.....................        10        25        40        55        75        95       105        370

             Agriculture:
       2       Special use valuation of farm real property.............        95       100       105       110       115       125       120        575
       3       Tax deferral of closely held farms......................         5        15        20        20        20        25        30        115

             Commerce:
       4       Special use valuation of real property used in closely          10        10        10        10        15        15        15         65
                held businesses........................................
       5       Tax deferral of closely held business...................        35       100       110       110       120       130       180        650
       6       Exclusion for family owned businesses...................       505       520       535       550       495       440       395      2,415

             Education, training, employment, and social services:
       7       Deduction for charitable contributions (education)......       682       760       830       855       910       930     1,020      4,545
       8       Deduction for charitable contributions (other than           2,015     2,240     2,450     2,525     2,680     2,750     3,015     13,420
                education and health)..................................

             Health:
       9       Deduction for charitable contributions (health).........       615       685       750       775       820       840       925      4,110

             General government:
      10       Credit for State death taxes............................     5,825     6,070     6,345     6,640     6,945     7,265     7,595     34,790
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