ESTIMATES OF FEDERAL TAX EXPENDITURES FOR FISCAL YEARS 2001-2005

[JPRT 107-1-01]
[From the U.S. Government Publishing Office]

JCS-1-01

[JOINT COMMITTEE PRINT]

ESTIMATES OF FEDERAL TAX
EXPENDITURES FOR
FISCAL YEARS 2001-2005

Prepared for the

COMMITTEE ON WAYS AND MEANS

and the

COMMITTEE ON FINANCE

__________

By the Staff of the

JOINT COMMITTEE ON TAXATION

[GRAPHIC] [TIFF OMITTED] TONGRESS.#13

APRIL 6, 2001
JOINT COMMITTEE ON TAXATION

107th Congress, 1st Session
------
HOUSE SENATE
WILLIAM M. THOMAS, California CHARLES E. GRASSLEY, Iowa
Chairman Vice Chairman
PHILIP M. CRANE, Illinois ORRIN G. HATCH, Utah
E. CLAY SHAW, Jr., Florida FRANK H. MURKOWSKI, Alaska
CHARLES B. RANGEL, New York MAX BAUCUS, Montana
FORTNEY PETE STARK, California JOHN D. ROCKEFELLER IV, West
Virginia
Lindy L. Paull, Chief of Staff
Bernard A. Schmitt, Deputy Chief of Staff
Mary M. Schmitt, Deputy Chief of Staff

C O N T E N T S

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Page
Introduction..................................................... 1

I. The Concept of Tax Expenditures...................................2

II. Measurement of Tax Expenditures..................................13

III.Tax Expenditure Estimates........................................15

Table 1. Tax Expenditure Estimates by Budget Function,
Fiscal Years 2001-2005............................... 16

Table 2. Distribution of All Returns, Taxable Returns,
Itemized Returns, and Tax Liability by Income Class.. 24

Table 3. Distribution of Selected Individual Tax
Expenditures by Income Class......................... 25

INTRODUCTION

This report \1\ on tax expenditures for fiscal years 2001-
2005 is prepared by the staff of the Joint Committee on
Taxation (``Joint Committee staff '') for the House Committee
on Ways and Means and the Senate Committee on Finance. The
report also is submitted to the House and Senate Committees on
the Budget.
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\1\ This report may be cited as follows: Joint Committee on
Taxation, Estimates of Federal Tax Expenditures for Fiscal Years 2001-
2005 (JCS-1-01), April 6, 2001.
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As in the case of earlier reports,\2\ the estimates of tax
expenditures in this report were prepared in consultation with
the staff of the Office of Tax Analysis in the Treasury
Department (``the Treasury''). The Treasury published its
estimates of tax expenditures for fiscal years 1999-2005 in the
Administration's budgetary statement of February 2000.\3\ The
lists of tax expenditures in this Joint Committee staff report
and the Administration's budgetary statement overlap
considerably; the differences are discussed in Part I of this
report under the heading ``Comparisons with Treasury.''
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\2\ Joint Committee on Taxation, Estimates of Federal Tax
Expenditures, October 4, 1972, June 1, 1973, July 8, 1975, March 15,
1976, March 16, 1977, March 14, 1978, March 15, 1979, March 6, 1980,
March 16, 1981, March 8, 1982, March 7, 1983, November 9, 1984, April
12, 1985, March 1, 1986, February 27, 1987, March 8, 1988, February 28,
1989, March 9, 1990, March 11, 1991, April 24, 1992, April 22, 1993,
November 9, 1994, September 1, 1995, November 26, 1996, December 15,
1997, December 14, 1998, and December 22, 1999.
\3\ Office of Management and Budget, ``Tax Expenditures,'' Budget
of the United States Government: Analytical Perspectives, Fiscal Year
2001, February 7, 2000, pp. 107-139.
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The Joint Committee staff has made its estimates (as shown
in Table 1) based on the provisions in tax law as enacted
through December 31, 2000. Expired or repealed provisions are
not listed unless they have continuing revenue effects that are
associated with ongoing taxpayer activity. Proposed extensions
or modifications of expiring provisions are not included until
they have been enacted into law.
Part I of this report contains a discussion of the concept
of tax expenditures. Part II is a discussion of the measurement
of tax expenditures. Estimates of tax expenditures for fiscal
years 2001-2005 are presented in Table 1 in Part III. Table 2
shows the distribution of tax returns by income class, and
Table 3 presents distributions of selected individual tax
expenditures by income class.

I. THE CONCEPT OF TAX EXPENDITURES

Overview
``Tax expenditures'' are defined under the Congressional
Budget and Impoundment Control Act of 1974 (``the Budget Act'')
as ``revenue losses attributable to provisions of the Federal
tax laws which allow a special exclusion, exemption, or
deduction from gross income or which provide a special credit,
a preferential rate of tax, or a deferral of tax liability.''
\4\ Thus, tax expenditures include any reductions in income tax
liabilities that result from special tax provisions or
regulations that provide tax benefits to particular taxpayers.
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\4\ Congressional Budget and Impoundment Control Act of 1974 (P.L.
93-344), sec. 3(3).
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Special income tax provisions are referred to as tax
expenditures because they may be considered to be analogous to
direct outlay programs, and the two can be considered as
alternative means of accomplishing similar budget policy
objectives. Tax expenditures are most similar to those direct
spending programs that have no spending limits, and that are
available as entitlements to those who meet the statutory
criteria established for the programs.\5\
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\5\ There are a few tax expenditures that have statutorily imposed
limits. One example is the tax credit for low-income rental housing.
This credit is available only to those who have received credit
allocations from State housing authorities. There are statutory limits
on the total amounts of credit allocations that the States can make
each year.
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Estimates of tax expenditures are prepared for use in
budget analysis. They are a measure of the economic benefits
that are provided through the tax laws to various groups of
taxpayers and sectors of the economy. The estimates also may be
useful in determining the relative merits of achieving
specified public goals through tax benefits or direct outlays.
The legislative history of the Budget Act indicates that
tax expenditures are to be defined with reference to a normal
income tax structure (referred to here as ``normal income tax
law''). The determination of whether a provision is a tax
expenditure is made on the basis of a broad concept of income
that is larger in scope than ``income'' as defined under
general U.S. income tax principles.\6\ The Joint Committee
staff has used its judgment in distinguishing between those
income tax provisions (and regulations) that can be viewed as a
part of normal income tax law and those special provisions that
result in tax expenditures. A provision traditionally has been
listed as a tax expenditure by the Joint Committee staff if
there is a reasonable basis for such classification and the
provision results in more than a de minimis revenue loss, which
solely for this purpose means a total revenue loss of at least
$50 million over the five fiscal years 2001-2005. The Joint
Committee staff emphasizes, however, that in the process of
listing tax expenditures, no judgment is made, nor any
implication intended, about the desirability of any special tax
provision as a matter of public policy.
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\6\ For this reason, the tax expenditure list in Table 1 includes,
for example, estimates for the net exclusion of pension contributions
and earnings, the exclusion of extraterritorial income, as well as
other exclusions, notwithstanding that such exclusions define income
under the general rule of U.S. income taxation.
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If a tax expenditure provision were eliminated, Congress
might choose to continue financial assistance through other
means rather than terminate all Federal assistance for the
activity. If a replacement spending program were enacted, the
higher revenues received as a result of the elimination of a
tax expenditure might not represent a net budget gain. A
replacement program could involve direct expenditures, direct
loans or loan guarantees, regulatory activity, a different form
of tax expenditure, or a general reduction in tax rates. Joint
Committee staff estimates of tax expenditures do not anticipate
such policy responses.
The Budget Act uses the term tax expenditure to refer to
the special tax provisions that are contained in the Federal
income taxes on individuals and corporations.\7\ Other Federal
taxes such as excise taxes, employment taxes, and estate and
gift taxes may also have exceptions, exclusions, and credits,
but those special tax provisions are not included in this
report because they are not part of the income tax. Thus, for
example, the income tax exclusion for employer-paid health
insurance is included, but the Federal Insurance Contributions
Act (``FICA'') tax exclusion for employer-paid health insurance
is not treated as a tax expenditure.\8\
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\7\ The Federal income tax on individuals also applies to estates
and trusts, which are subject to a separate income tax rate schedule
(Internal Revenue Code section 1(e)). Estates and trusts may benefit
from some of the same tax expenditure provisions that apply to
individuals. In Table 1 of this report, the tax expenditures that apply
to estates and trusts have been included in the estimates of tax
expenditures for individual taxpayers.
\8\ In its budget statement, the Treasury Department identifies tax
expenditures in the unified transfer tax (the estate and gift tax and
the generation-skipping transfer tax). See, Office of Management and
Budget, ``Tax Expenditures,'' February 7, 2000, pp. 137-139. Other
analysts have explored applying the concept of tax expenditures to the
payroll and excise taxes. See, Jonathan Barry Forman, ``Would a Social
Security Tax Expenditure Budget Make Sense?'' Public Budgeting and
Financial Management, 5, 1993, pp. 311-335, and Bruce F. Davie, ``Tax
Expenditures in the Federal Excise Tax System,'' National Tax Journal,
XLVII, March 1994, pp. 39-62.
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Some provisions in the Internal Revenue Code provide for
special tax treatment that is less favorable than normal income
tax law. Examples of such provisions include (1) the denial of
deductions for certain lobbying expenses, (2) the denial of
deductions for certain executive compensation, and (3) the 2-
percent floor on itemized deductions for unreimbursed employee
expenses. Tax provisions that provide treatment less favorable
than normal income tax law are not shown in this report because
they are not included in the statutory definition of a tax
expenditure.
Individual Income Tax
Under the Joint Committee staff methodology, the normal
structure of the individual income tax includes the following
major components: one personal exemption for each taxpayer and
one for each dependent, the standard deduction, the existing
tax rate schedule, and deductions for investment and employee
business expenses. Most other tax benefits to individual
taxpayers can be classified as exceptions to normal income tax
law.
Personal exemptions and the standard deduction are treated
as part of normal income tax law because these amounts
approximate the level of income below which it would be
difficult for an individual or a family to obtain minimal
amounts of food, clothing, and shelter. Those itemized
deductions that are not necessary for the generation of income
are classified as tax expenditures, but only to the extent that
they exceed the standard deduction level.
Under present law, all employee compensation is subject to
tax unless the tax code contains a specific exclusion for the
income. There are specific exclusions for the following
employer-provided benefits: coverage under accident and health
plans,\9\ accident and disability insurance, group term life
insurance, educational assistance, transportation benefits
(parking, van pools, and transit passes), child care, meals and
lodging furnished for the convenience of the employer, employee
awards, and other miscellaneous fringe benefits (e.g., employee
discounts, services provided to employees at no additional cost
to employers, tuition reductions, and de minimis fringe
benefits). Each of these exclusions is classified as a tax
expenditure in this report.
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\9\ Present law contains an exclusion for employer-provided
coverage under accident and health plans (sec. 106 of the Internal
Revenue Code of 1986, the ``Code'') and an exclusion for benefits
received by employees under employer-provided accident and health plans
(Code sec. 105(b)). These two exclusions are viewed as a single tax
expenditure. Under normal income tax law, the value of employer-
provided accident and health coverage would be includable in the income
of employees, but employees would not be subject to tax on the accident
and health insurance benefits (reimbursements) that they might receive.
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Under normal income tax law, employer contributions to
pension plans and income earned on pension assets would be
taxable to employees as the contributions are made and as the
income is earned, and employees would not receive any deduction
or exclusion for their pension contributions. Under present
law, employer contributions to qualified pension plans and
employee contributions made at the election of the employee
through salary reduction are not taxed until distributed to the
employee, and income earned on pension assets is not taxed
until distributed. The tax expenditure for ``net exclusion of
pension contributions and earnings'' is computed as the income
taxes forgone on current tax-excluded pension contributions and
earnings less the income taxes paid on current pension
distributions (including the 10-percent additional tax paid on
early withdrawals from pension plans).
Under present law, social security retirement benefits are
fully or partially excluded from gross income.\10\ Under normal
income tax law, retirees would be entitled to an exclusion for
only the portion of social security retirement benefits that
represents a return of the social security taxes that they paid
during their working years. Thus, the exclusion of social
security retirement benefits in excess of social security tax
payments is classified as a tax expenditure.
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\10\ For taxpayers with modified adjusted gross incomes above
certain levels, up to 85 percent of social security retirement benefits
are includable in income.
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All Medicare benefits are excluded from taxation. The value
of Medicare Part A insurance generally is greater than the
Health Insurance (``HI'') tax contributions that enrollees made
during their working years, and the value of Medicare Part B
insurance generally is greater than the Part B premium that
enrollees must pay. The exclusion of the value of Medicare Part
A insurance in excess of HI tax contributions is classified as
a tax expenditure, and the exclusion of the value of Medicare
Part B insurance in excess of premiums paid also is classified
as a tax expenditure.
Public assistance benefits are excluded from gross income
by law or by Internal Revenue Service regulations. Table 1
contains tax expenditure estimates for workers' compensation
benefits, special benefits for disabled coal miners, and cash
public assistance benefits (which include Supplemental Security
Income benefits and Temporary Assistance for Needy Families
benefits).
The individual income tax does not include in gross income
the imputed income that individuals receive from the services
provided by owner-occupied homes and durable goods.\11\
However, the Joint Committee staff does not classify this
exclusion as a tax expenditure. The measurement of imputed
income for tax purposes presents administrative problems and
its exclusion from taxable income may be regarded as an
administrative necessity.\12\
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\11\ The National Income and Product Accounts include estimates of
this imputed income. The accounts appear in U.S. Department of
Commerce, Bureau of Economic Analysis, Survey of Current Business,
published monthly.
\12\ If the imputed income from owner-occupied homes were included
in adjusted gross income, it would be proper to include all mortgage
interest deductions and related property tax deductions as part of the
normal income tax structure, since interest and property tax deductions
would be allowable as a cost of producing imputed income. It also would
be appropriate to allow deductions for depreciation and maintenance
expenses for owner-occupied homes.
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Under normal income tax law, individuals would be allowed
to deduct only the interest on indebtedness incurred in
connection with a trade or business or an investment. Thus, the
deductions for mortgage interest and property taxes on a
principal or second residence are classified as tax
expenditures.
The Joint Committee staff assumes that, for administrative
feasibility, normal income tax law would tax capital gains in
full in the year the gains are realized through sale or
exchange. Thus, the deferral of tax until realization is not
classified as a tax expenditure, but reduced rates of tax,
further deferrals of tax (beyond the year of sale or exchange),
and exclusions of certain capital gains are classified as tax
expenditures.
It also is assumed that normal income tax law would not
provide for any indexing of the basis of capital assets for
changes in the general price level. Thus, under normal income
tax law (as under present law), the income tax would be levied
on nominal gains as opposed to real gains in asset values. If,
as an alternative, normal income tax law were defined to
include full indexing of the basis of capital assets, the
capital gains tax expenditure estimates in Table 1 generally
would be lower than those shown.
There are many types of State and local government bonds
and private purpose bonds that qualify for tax-exempt status
for Federal income tax purposes. Table 1 contains a separate
tax expenditure listing for each type of bond.
Business Income Taxation
Regardless of the legal form of organization (sole
proprietorship, partnership, or S or C corporation), the same
general principles are used in the computation of taxable
business income. Thus, most business tax expenditures apply
equally to unincorporated and incorporated businesses.
One of the most difficult issues in defining tax
expenditures for business income relates to the tax treatment
of capital costs. Under present law, capital costs may be
recovered under a variety of alternative methods, depending
upon the nature of the costs and the status of the taxpayer.
For example, investments in equipment and structures may
qualify for tax credits, expensing, accelerated depreciation,
or straight-line depreciation. The Joint Committee staff
generally classifies as tax expenditures cost recovery
allowances that are more favorable than those provided under
the alternative depreciation system (sec. 168(g)), which
provides for straight-line recovery over tax lives that are
longer than those permitted under the accelerated system.
As indicated above, the Joint Committee staff assumes that
normal income tax law would not provide for any indexing of the
basis of capital assets. Thus, normal income tax law would not
take into account the effects of inflation on tax depreciation.
The expensing and depreciation tax expenditure estimates in
Table 1 are larger than would be the case if normal income tax
law provided for inflation adjustments in the basis of assets
for tax depreciation purposes.
The Joint Committee staff uses several accounting standards
in evaluating the provisions in the Code that govern the
recognition of business receipts and expenses. Under the Joint
Committee staff view, normal income tax law is assumed to
require the accrual method of accounting, the standard of
``economic performance'' (used in the Code to test whether
liabilities are deductible), and the general concept of
matching income and expenses. In general, tax provisions that
do not satisfy all three standards are viewed as tax
expenditures. For example, the deduction for contributions to
taxpayer-controlled mining reclamation reserve accounts is
viewed as a tax expenditure because the contributions do not
satisfy the economic performance standard. (Adherence to the
standard would require that the taxpayer make an irrevocable
contribution toward future reclamation, involving a trust fund
or similar mechanism, as occurs in a number of areas in the
Code.) The deduction for contributions to nuclear
decommissioning trust accounts is not viewed as a tax
expenditure because the contributions are irrevocable (i.e.,
they satisfy the economic performance standard). However,
present law provides for a reduced rate of tax on the income of
nuclear decommissioning trust accounts, and this reduced rate
of tax is viewed as a tax expenditure.
The alternative minimum tax (``AMT'') and the passive
activity loss rules are not viewed by the Joint Committee staff
as a part of normal income tax law. Instead, they are viewed as
provisions that reduce the magnitude of the tax expenditures to
which they apply. For example, the AMT reduces the value of
business tax credits (for those taxpayers subject to the AMT)
by not allowing the tax credits to be claimed in the
calculation of AMT liability. Similarly, the passive loss rules
defer otherwise allowable deductions and credits from passive
activities until a time when the taxpayer has passive income or
disposes of the assets associated with the passive activity.
Exceptions to the AMT and the passive loss rules are not
classified as tax expenditures by the Joint Committee staff
because the effects of the exceptions already are incorporated
in the estimates of related tax expenditures.
Corporate Income Tax
The income of corporations (other than S corporations)
generally is subject to the corporate income tax. The corporate
income tax includes a graduated tax rate schedule. The lower
tax rates in the schedule are classified by the Joint Committee
staff as a tax expenditure (as opposed to normal income tax
law) because they are intended to provide tax benefits to small
business and, unlike the graduated individual income tax rates,
are unrelated to concerns about ability of individuals to pay
taxes.
Certain income of pass-through entities is exempt from the
corporate income tax. The income of sole proprietorships, S
corporations, and most partnerships is taxed only at the
individual level. The special tax rules for these pass-through
entities are not classified as tax expenditures because the tax
benefits are available to any entity that chooses to organize
itself and operate in the required manner.
Nonprofit corporations that satisfy the requirements of
Code section 501 also generally are exempt from corporate
income tax. The tax exemption of certain nonprofit cooperative
business organizations, such as trade associations, is not
treated as a tax expenditure for the same reason applicable to
for-profit pass-through business entities. With respect to
other nonprofit organizations, such as charities, tax-exempt
status is not classified as a tax expenditure because the
nonbusiness activities of such organizations generally must
predominate and their unrelated business activities are subject
to tax. In general, the imputed income derived from nonbusiness
activities conducted by individuals or collectively by certain
nonprofit organizations is outside the normal income tax base.
However, the ability of donors to such nonprofit organizations
to claim a charitable contribution deduction is a tax
expenditure (because such contributions do not generate income
to the donor), as is the exclusion of income granted to holders
of tax-exempt financing issued by charities.
Recent Legislation
The FSC Repeal and Extraterritorial Income Exclusion Act of
2000 (H.R. 4986), enacted on November 15, 2000 (P.L. 106-519),
repealed the Foreign Sales Corporation (``FSC'') provisions and
enacted an extraterritorial income exclusion, effective for
transactions after September 30, 2000. The exclusion for
extraterritorial income is included in the tax expenditure list
in Table 1.
The Community Renewal Tax Relief Act of 2000 (the
``Community Renewal Tax Act''),\13\ extended and modified a
number of tax expenditures, as follows:
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\13\ The Community Renewal Tax Relief Act of 2000 (H.R. 5662) was
incorporated by reference in the Consolidated Appropriations Act, 2001,
which was enacted on December 2, 2000 (P.L. 106-554).
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--Numerous changes were made in the tax rules for
empowerment zones. The designation of empowerment zone status
for existing empowerment zones (other than the District of
Columbia enterprise zone) was extended through December 31,
2009. The 20-percent wage credit will be made available to all
existing empowerment zones beginning in 2002, and $35,000
(rather than $20,000) of additional section 179 expensing will
be available for qualified zone property placed in service by
qualified zone businesses in taxable years beginning after
December 31, 2001. Certain businesses in existing empowerment
zones (other than the District of Columbia enterprise zone)
will become eligible for more generous tax-exempt bond rules,
beginning in 2002. The Secretaries of Housing and Urban
Development (``HUD'') and Agriculture are authorized to
designate nine additional empowerment zones, which will be
eligible for the same tax incentives as existing zones, for the
period beginning January 1, 2002, and ending on December 31,
2009. In addition, taxpayers are now permitted to roll over the
gain from the sale or exchange of qualified empowerment zone
assets held for more than one year if the proceeds are used to
purchase other qualified assets in the same zone within 60
days, effective for sales or exchanges after the date of
enactment, for assets purchased after the date of enactment.
And the Act increases to 60 percent (from 50 percent) the
exclusion of gain from the sale of qualifying small business
stock held more than five years if the stock also satisfies the
requirements of a qualifying business under the empowerment
zone rules, effective for qualifying stock purchased after the
date of enactment. In Table 1, all of these changes are
reflected in the tax expenditure estimate for ``empowerment
zone tax incentives.''
--The per-capita allocation for the low-income housing
credit was increased from $1.25 per capita to $1.50 per capita
in calendar year 2001 and to $1.75 per capita in calendar year
2002. Beginning in calendar year 2003, the allocation will be
adjusted annually for inflation. For small States, a minimum
annual allocation of $2 million will be provided for calendar
years 2001 and 2002, and beginning in 2003, the small State
minimum will be adjusted for inflation. Other changes also were
made to the basic rules for the credit, effective for calendar
years after 2000.
--The State volume limits on tax-exempt private activity
bonds were increased beyond what would have occurred under
prior law. In calendar year 2001, the volume limit will be the
greater of $62.50 per resident or $187.5 million. Beginning in
calendar year 2002, the volume limit will be the greater of $75
per resident or $225 million, and thereafter the volume limit
will be adjusted annually for inflation.
--The expensing of environmental remediation costs, which
was scheduled to expire on December 31, 2001, was extended
through December 31, 2003, and the provision was expanded to
include costs incurred at any site that contains a hazardous
substance and is certified by the appropriate State agency,
effective for costs paid or incurred after the date of
enactment (December 2, 2000).
--The $5,000 tax credit for first-time homebuyers of a
principal residence in the District of Columbia, which was
scheduled to expire for residences purchased after December 31,
2001, was extended through December 31, 2003.
--The District of Columbia enterprise zone designation,
which was scheduled to expire on December 31, 2002, was
extended through December 31, 2003.
--The enhanced deduction for donations of computer
technology and equipment, which was scheduled to expire on
December 31, 2001, was extended through December 31, 2003. The
deduction also was expanded to include donations to public
libraries, donations of property reacquired by computer
manufacturers, and donations of property no later than three
years (instead of two years) after the date the taxpayer
acquired or substantially completed the construction of the
property, with all three changes effective for contributions
made after December 31, 2000.
--The deadline for the establishment of new medical savings
accounts (``MSAs'') was extended from December 31, 2000, to
December 31, 2002.
The Community Renewal Tax Act also created two additional
tax expenditures:
--The Act authorizes the Secretary of HUD to designate up
to 40 ``renewal communities'' from areas nominated by States
and local governments. The areas so designated will be eligible
for the following tax incentives: (1) a zero-percent rate for
capital gains from the sale of qualifying assets; (2) a 15-
percent wage credit to employers for the first $10,000 of
qualified wages; (3) a ``commercial revitalization deduction''
that will allow taxpayers to deduct either (a) 50 percent of
qualifying expenditures for the taxable year in which a
qualified building is placed in service, or (b) all qualifying
expenditures ratably over a 10-year period beginning in the
month in which a qualified building is placed in service; (4)
an additional $35,000 of section 179 expensing for qualified
property; and (5) an expansion of the work opportunity tax
credit with respect to individuals who live in a renewal
community. These tax benefits generally will be effective
beginning on January 1, 2002, and will terminate on December
31, 2009. These tax benefits have been combined into a single
tax expenditure that is listed in Table 1 as ``renewal
community tax incentives.''
--The Act creates a new tax credit for qualified equity
investments made after December 31, 2000, to acquire stock in a
community development entity (``CDE''). A CDE is any domestic
corporation or partnership that has a primary mission of
serving or providing investment capital to low-income
communities or low-income persons and satisfies certain other
requirements. The amount of the credit allowed to an investor
in a CDE is five percent of the investment for the year in
which the investment is made, an additional five percent in
each of the following two years, and six percent in each of the
following four years. This tax expenditure is listed in Table 1
as ``new markets tax credit.''
The Installment Tax Correction Act of 2000 (H.R. 3594),
enacted on December 28, 2000 (P.L. 106-573), restores the
option for accrual accounting taxpayers to use the installment
method of accounting, and thus negates a provision in H.R.
1180, enacted on December 17, 1999 (P.L. 106-170) that would
have disallowed the use of the installment method for such
taxpayers after that date. This increases the tax expenditure
for ``deferral of gain on non-dealer installment sales.''
Comparisons with Treasury Department
The Joint Committee staff and Treasury lists of tax
expenditures differ in two respects. First, the Treasury uses a
different classification of those provisions that can be
considered a part of normal income tax law under both the
individual and business income taxes. In general, the Joint
Committee staff methodology involves a narrower concept of
normal income tax law. Thus, the Joint Committee list of tax
expenditures includes some provisions that are not contained in
the Treasury list. The cash method of accounting provides an
example. The Treasury considers the cash accounting option for
certain businesses to be a part of normal income tax law, but
the Joint Committee staff methodology treats it as a departure
from normal income tax law that constitutes a tax expenditure.
Second, the Joint Committee staff list excludes those
provisions that are estimated to result in revenue losses below
the de minimis amount, i.e., less than $50 million over the
five fiscal years 2001-2005. The Treasury does not have a de
minimis exception. Thus, the Treasury list of tax expenditures
includes some provisions that are not contained in the Joint
Committee staff list.
The Joint Committee staff and Treasury estimates of tax
expenditures span slightly different sets of years. The
Treasury's estimates cover a seven-year period--the last fiscal
year, the current fiscal year when the President's budget is
submitted, and the next five fiscal years, i.e., fiscal years
1999-2005. The Joint Committee staff estimates cover the
current fiscal year and the succeeding four fiscal years, i.e.,
fiscal years 2001-2005.
For the past nine years, the President's budget has
contained a section that reviews and tabulates the estate and
gift tax provisions that the Treasury considers as tax
expenditures. The Joint Committee staff considers estate and
gift tax provisions as being outside of the normal income tax
structure and thus omits them from its list of tax
expenditures.
In some cases, two or more of the tax expenditure items in
the Treasury list have been combined into a single item in the
Joint Committee staff list, and vice versa. The Table 1
descriptions of some tax expenditures also may vary from the
descriptions used by the Treasury.
The following is a list of tax expenditure provisions in
the Joint Committee staff list that are not classified as tax
expenditures by the Treasury:\14\
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\14\ There are two additional tax expenditure provisions in the
Joint Committee staff list that are not classified as tax expenditures
by the Treasury: the expensing of tertiary injectants and the exclusion
of investment income from structured settlement amounts. These
provisions are not listed in Table 1 because the estimated revenue
losses are below the de minimis amount ($50 million over the five
fiscal years 2001-2005).
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Natural resources and environment
--Exclusion of contributions in aid of construction for water
and sewer utilities
--Special rules for mining reclamation reserves
--Special tax rate for nuclear decommissioning reserve funds
Agriculture
--Exclusion of cost-sharing payments
--Cash accounting for agriculture
--Five-year carryback period for net operating losses
attributable to farming

Insurance companies

--Special treatment of life insurance company reserves
--Deduction of unpaid property loss reserves of property and
casualty companies

Business and commerce

--Expensing of magazine circulation expenditures
--Special rules for magazine, paperback book, and record
returns
--Completed contract rules
--Cash accounting, other than agriculture
--Deferral of gain on like-kind exchanges
--Exception from net operating loss limitations for
corporations in bankruptcy
--Tax credit for employer-paid FICA taxes on tips
--Deferral of gain on involuntary conversions resulting from
Presidentially-declared disasters

Employment

--Exclusion of miscellaneous fringe benefits
--Exclusion of employee awards
--Exclusion of income earned by voluntary employee beneficiary
associations

Medicare

--Exclusion of untaxed Medicare benefits for Hospital Insurance
--Exclusion of untaxed Medicare benefits for Supplementary
Medical Insurance

The following is a list of the tax expenditure provisions
that are included in the Treasury list but are excluded from
the Joint Committee staff list because the estimated revenue
losses are below the de minimis amount (less than $50 million
over the five fiscal years 2001-2005):

Energy

--Tax credit for electric vehicles
--Deductions for clean-fuel vehicles and refueling property

Natural resources and environment

--Tax credit and seven-year amortization for reforestation
expenditures

Agriculture

--Deferral of tax on gains from the sale of stock in a
qualified refiner or processor to an eligible
farmer's cooperative

Financial institutions

--Bad debt reserves of financial institutions

Insurance companies

--Special alternative tax on small property and casualty
insurance companies
--Tax exemption for insurance companies owned by tax-exempt
organizations

Business and commerce

--Ordinary income treatment of losses from sales of small
business corporation stock
--Exclusion of income from discharge of indebtedness incurred
in connection with qualified real property

Social services

--Expensing of costs for removing architectural barriers

There are three additional tax expenditure provisions in
the Treasury list that are not included in the Joint Committee
staff list. Two of the provisions involve exceptions to the
passive loss rules: the exception for working interests in oil
and gas properties, and the exception for up to $25,000 of
rental losses. The Joint Committee staff does not classify
these two provisions as tax expenditures; the effects of the
passive loss rules (and exceptions to the rules) are included
in the estimates of the tax expenditure provisions that are
affected by the rules.\15\ The third tax expenditure in the
Treasury list that is not included in the Joint Committee staff
list is the exemption of certain income of telephone and
electric cooperatives. The Joint Committee staff does not
classify this provision as a tax expenditure because the
special tax rules for pass-through entities are assumed to be a
part of normal tax law.\16\
---------------------------------------------------------------------------
\15\ See discussion of the alternative minimum tax and passive loss
rules, above on page 6.
\16\ See discussion on page 7, above.

II. MEASUREMENT OF TAX EXPENDITURES

Tax Expenditure Estimates Generally
A tax expenditure is measured by the difference between tax
liability under present law and the tax liability that would
result from a recomputation of tax without benefit of the tax
expenditure provision. Taxpayer behavior is assumed to remain
unchanged for tax expenditure estimating purposes.\17\
---------------------------------------------------------------------------
\17\ An alternative way to measure tax expenditures is to express
their values in terms of ``outlay equivalents.'' An outlay equivalent
is the dollar size of a direct spending program that would provide
taxpayers with net benefits that would equal what they now receive from
a tax expenditure. The Treasury Department presents estimates of outlay
equivalents in the President's budget in addition to presenting
estimates in the same manner as the Joint Committee staff.
---------------------------------------------------------------------------
The tax expenditure estimates in this report are based on
Congressional Budget Office and Joint Committee staff
projections of the gross income, deductions, and expenditures
of individuals and corporations for calendar years 2000-2005.
These projections are used to compute tax liabilities for the
present-law revenue baseline and tax liabilities for the
alternative baseline that assumes that the tax expenditure
provision does not exist.
Internal Revenue Service (``IRS'') statistics from recent
tax returns are used to develop projections of the tax credits,
deductions, and exclusions that will be claimed under the
present-law baseline. These IRS statistics show the actual
usage of the various tax expenditure provisions. In the case of
some tax expenditures, such as the earned income tax credit,
there is evidence that some taxpayers are not claiming all of
the benefits to which they are entitled, while others are
filing claims that exceed their entitlements. The tax
expenditure estimates in this report are based on projections
of actual claims under the various tax provisions, not the tax
benefits to which taxpayers are entitled.
Some tax expenditure estimates are based partly on
statistics for income, deductions, and expenses for prior
years. Accelerated depreciation is an example. Estimates for
this tax expenditure are based on the difference between tax
depreciation deductions under present law and the deductions
that would have been claimed in the current year if investments
in the current year and all prior years had been depreciated
using the alternative (normal income tax law) depreciation
system.
Each tax expenditure is estimated separately, under the
assumption that all other tax expenditures remain in the tax
code. If two or more tax expenditures were estimated
simultaneously, the total change in tax liability could be
smaller or larger than the sum of the amounts shown for each
item separately, as a result of interactions among the tax
expenditure provisions.
Year-to-year differences in the estimates for each tax
expenditure reflect changes in tax law, including phaseouts of
tax expenditure provisions and changes that alter the
definition of the normal income tax structure, such as the tax
rate schedule, the personal exemption amount, and the standard
deduction. Some of the estimates for this tax expenditure
report may differ from estimates made in previous years because
of changes in law and economic conditions, the availability of
better data, and improved estimating techniques.
Tax Expenditures versus Revenue Estimates
A tax expenditure estimate is not the same as a revenue
estimate for the repeal of the tax expenditure provision for
two reasons. First, tax expenditure estimates do not
incorporate any changes in taxpayer behavior, whereas revenue
estimates incorporate the effects of the behavioral changes
that are anticipated to occur in response to the repeal of a
tax provision. Second, tax expenditure estimates are concerned
with changes in the tax liabilities of taxpayers. Because the
tax expenditure focus is on tax liabilities as opposed to
Federal government tax receipts, there is no concern for the
timing of tax payments. Revenue estimates are concerned with
changes in Federal tax receipts, which are affected by the
timing of tax payments.
If a tax expenditure provision were repealed, it is likely
that the repeal would be made effective at the beginning of a
calendar year. In this case, the revenue estimate for repeal
would show a smaller revenue gain in the first fiscal year than
in subsequent years, because the repeal would be occurring
after the start of the government's fiscal year. The revenue
estimate might also reflect some delay in the timing of the
revenue gains as a result of the taxpayer tendency to postpone
or forgo changes in tax withholding and estimated tax payments.

III. TAX EXPENDITURE ESTIMATES

Tax expenditures are grouped in Table 1 in the same
functional categories as outlays in the Federal budget.
Estimates are shown separately for individuals and
corporations. Those tax expenditures that do not fit clearly
into any single budget category have been placed in the most
appropriate category.
Several of the tax expenditure items involve small amounts
of revenue, and those estimates are indicated in Table 1 by
footnote 1. For each of these items, the footnote means that
the tax expenditure is less than $50 million in the fiscal
year.
Table 2 presents tax return information for each of nine
income classes on the number of all returns (including filing
and nonfiling units), the number of taxable returns, the number
of returns with itemized deductions, and the amount of tax
liability.
Table 3 provides distributional estimates by income class
for some of the tax expenditures that affect individual
taxpayers. Not all tax expenditures that affect individuals are
shown in this table because of the difficulty in making
reliable estimates of the income distribution of items that do
not appear on tax returns under present law.

Table 1.--Tax Expenditure Estimates By Budget Function, Fiscal Years 2001-2005
[Billions of dollars]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Corporations Individuals
Function ------------------------------------------------------------------------------------------ Total
2001 2002 2003 2004 2005 2001 2002 2003 2004 2005 2001-05
--------------------------------------------------------------------------------------------------------------------------------------------------------
National Defense
Exclusion of benefits and allowances to Armed ....... ....... ....... ....... ....... 1.9 2.0 2.0 2.0 2.0 9.9
Forces personnel.................................
Exclusion of military disability benefits......... ....... ....... ....... ....... ....... 0.1 0.1 0.1 0.1 0.1 0.5
International Affairs
Exclusion of income earned abroad by U.S. citizens ....... ....... ....... ....... ....... 2.4 2.5 2.7 2.9 3.0 13.5
Exclusion of certain allowances for Federal ....... ....... ....... ....... ....... 0.2 0.2 0.3 0.3 0.3 1.3
employees abroad.................................
Exclusion of extraterritorial income.............. 4.4 4.7 5.1 5.5 5.9 ....... ....... ....... ....... ....... 25.6
Deferral of active income of controlled foreign 3.7 4.0 4.2 4.5 4.8 ....... ....... ....... ....... ....... 21.2
corporations.....................................
Inventory property sales source rule exception.... 4.5 4.8 5.2 5.6 6.0 ....... ....... ....... ....... ....... 26.1
Deferral of certain financing income.............. 0.9 0.5 0.1 ....... ....... ....... ....... ....... ....... ....... 1.5
General Science, Space, and Technology
Tax credit for qualified research expenditures.... 3.3 3.4 3.6 3.0 1.8 ....... ....... ....... ....... ....... 15.0
Expensing of research and experimental 2.9 2.6 2.5 2.5 2.5 ....... ....... ....... ....... ....... 13.0
expenditures.....................................
Energy
Expensing of exploration and development costs:
Oil and gas..................................... 0.6 0.6 0.6 0.4 0.3 (\1\) (\1\) (\1\) (\1\) (\1\) 3.1
Other fuels..................................... (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
Excess of percentage over cost depletion:
Oil and gas..................................... 0.3 0.3 0.3 0.3 0.4 (\1\) (\1\) (\1\) (\1\) (\1\) 1.7
Other fuels..................................... (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
Tax credit for enhanced oil recovery costs........ 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 1.0
Tax credit for production of non-conventional 1.2 1.3 0.8 0.5 0.5 0.3 0.3 0.2 0.1 0.1 5.3
fuels............................................
Tax credits for alcohol fuels \2\................. (\1\) (\1\) (\1\) (\1\) (\1\) ....... ....... ....... ....... ....... (\1\)
Exclusion of interest on State and local (\1\) (\1\) (\1\) (\1\) (\1\) 0.1 0.1 0.1 0.1 0.1 0.7
government industrial development bonds for
energy production facilities.....................
Exclusion of energy conservation subsidies ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
provided by public utilities.....................
Tax credit for investments in solar and geothermal (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
energy facilities................................
Tax credit for electricity production from wind, (\1\) (\1\) (\1\) (\1\) (\1\) 0.1 0.1 0.1 0.1 0.1 0.4
biomass, and poultry waste.......................
Natural Resources and Environment
Expensing of exploration and development costs, (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
nonfuel minerals.................................
Excess of percentage over cost depletion, nonfuel 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.7
minerals.........................................
Expensing of multiperiod timber-growing costs..... 0.2 0.2 0.2 0.2 0.2 (\1\) (\1\) (\1\) (\1\) (\1\) 1.0
Exclusion of interest on State and local 0.2 0.2 0.2 0.2 0.2 0.4 0.4 0.4 0.4 0.4 2.9
government sewage, water, and hazardous waste
facilities bonds.................................
Special rules for mining reclamation reserves..... (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
Special tax rate for nuclear decommissioning 0.1 0.2 0.2 0.2 0.2 ....... ....... ....... ....... ....... 0.9
reserve fund.....................................
Exclusion of contributions in aid of construction (\1\) (\1\) (\1\) (\1\) (\1\) ....... ....... ....... ....... ....... 0.1
for water and sewer utilities....................
Agriculture
Expensing of soil and water conservation (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
expenditures.....................................
Expensing of fertilizer and soil conditioner costs (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.3
Expensing of the costs of raising dairy and (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
breeding cattle..................................
Exclusion of cost-sharing payments................ (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
Exclusion of cancellation of indebtedness income ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
of farmers.......................................
Cash accounting for agriculture................... (\1\) (\1\) (\1\) (\1\) (\1\) 0.3 0.4 0.4 0.4 0.5 2.2
Income averaging for farmers...................... ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
Five-year carryback period for net operating (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
losses attributable to farming...................
Commerce and Housing
Financial institutions:
Exemption of credit union income................ 0.7 0.7 0.8 0.8 0.8 ....... ....... ....... ....... ....... 3.9
Insurance companies:
Exclusion of investment income on life insurance 1.3 1.3 1.4 1.4 1.5 23.0 23.6 24.2 24.9 25.5 128.2
and annuity contracts..........................
Small life insurance company taxable income 0.1 0.1 0.1 0.1 0.1 ....... ....... ....... ....... ....... 0.7
adjustment.....................................
Special treatment of life insurance company 1.2 1.2 1.3 1.3 1.4 ....... ....... ....... ....... ....... 6.4
reserves.......................................
Deduction of unpaid property loss reserves for 2.9 2.9 3.0 3.0 3.1 ....... ....... ....... ....... ....... 14.9
property and casualty insurance companies......
Special deduction for Blue Cross and Blue Shield 0.1 0.1 0.1 0.1 0.1 ....... ....... ....... ....... ....... 0.5
companies......................................
Housing:
Deduction for mortgage interest on owner- ....... ....... ....... ....... ....... 62.7 66.0 69.1 72.4 76.1 346.3
occupied residences............................
Deduction for property taxes on owner-occupied ....... ....... ....... ....... ....... 21.0 21.6 22.3 23.0 23.6 111.6
residences.....................................
Exclusion of capital gains on sales of principal ....... ....... ....... ....... ....... 13.3 13.4 13.5 13.6 13.8 67.6
residences.....................................
Exclusion of interest on State and local 0.3 0.3 0.3 0.3 0.3 0.8 0.8 0.8 0.7 0.7 5.4
government bonds for owner-occupied housing....
Exclusion of interest on State and local 0.1 0.1 0.1 0.1 0.1 0.2 0.2 0.2 0.1 0.1 1.1
government bonds for rental housing............
Depreciation of rental housing in excess of 0.3 0.3 0.3 0.3 0.3 2.5 2.6 2.8 3.0 3.3 15.9
alternative depreciation system................
Tax credit for low-income housing............... 2.7 2.7 2.9 3.0 3.2 1.1 1.2 1.2 1.3 1.4 20.8
Tax credit for first-time homebuyers in the ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) ....... ....... 0.1
District of Columbia...........................
Tax credit for rehabilitation of historic 0.3 0.4 0.4 0.4 0.4 0.1 0.1 0.1 0.1 0.1 2.3
structures.....................................
Other business and commerce:
Reduced rates of tax on long-term capital gains. ....... ....... ....... ....... ....... 38.7 40.6 41.8 43.1 44.9 209.1
Exclusion of capital gains at death............. ....... ....... ....... ....... ....... 26.0 27.6 29.5 30.9 35.1 149.1
Carryover basis of capital gains on gifts....... ....... ....... ....... ....... ....... 2.6 2.8 3.1 3.4 3.6 15.5
Deferral of gain on non-dealer installment sales 0.6 0.6 0.6 0.6 0.7 0.4 0.4 0.4 0.4 0.4 5.2
Deferral of gain on like-kind exchanges......... 1.2 1.3 1.4 1.4 1.5 0.4 0.4 0.4 0.5 0.5 9.0
Deferral of gain on involuntary conversions ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
resulting from Presidentially-declared
disasters......................................
Depreciation of buildings other than rental 1.2 1.2 1.1 0.9 0.8 0.5 0.5 0.4 0.4 0.3 7.4
housing in excess of alternative depreciation
system.........................................
Depreciation of equipment in excess of 27.7 30.3 31.1 30.5 29.8 7.5 8.2 8.4 8.1 7.7 189.2
alternative depreciation system................
Expensing of depreciable business property...... 0.3 0.3 0.2 0.1 (\1\) 1.2 1.2 0.7 0.4 0.2 4.7
Amortization of business startup costs.......... (\1\) (\1\) (\1\) (\1\) (\1\) 0.4 0.4 0.4 0.4 0.4 2.0
Reduced rates on first $10,000,000 of corporate 4.3 4.4 4.5 4.6 4.7 ....... ....... ....... ....... ....... 22.4
taxable income.................................
Permanent exemption from imputed interest rules. (\1\) (\1\) (\1\) (\1\) (\1\) 0.2 0.2 0.3 0.3 0.3 1.3
Expensing of magazine circulation expenditures.. (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
Special rules for magazine, paperback book, and (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
record returns.................................
Completed contract rules........................ 0.2 0.2 0.2 0.2 0.2 (\1\) (\1\) (\1\) (\1\) (\1\) 1.1
Cash accounting, other than agriculture......... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1 0.1 0.1 0.1 0.1 0.5
Exclusion of interest on State and local 0.1 0.1 0.1 0.1 0.1 0.3 0.3 0.3 0.3 0.3 1.9
government small-issue industrial development
bonds..........................................
Exception from net operating loss limitations 0.5 0.5 0.5 0.5 0.5 ....... ....... ....... ....... ....... 2.5
for corporations in bankruptcy proceedings.....
Tax credit for employer-paid FICA taxes on tips. 0.1 0.1 0.1 0.1 0.1 0.2 0.2 0.2 0.2 0.2 1.6
Transportation
Deferral of tax on capital construction funds of 0.1 0.1 0.1 0.1 0.1 ....... ....... ....... ....... ....... 0.5
shipping companies...............................
Exclusion of employer-paid transportation benefits ....... ....... ....... ....... ....... 3.6 3.7 3.7 3.8 3.8 18.6
Exclusion of interest on State and local (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.5
government bonds for high-speed rail.............
Community and Regional Development
Empowerment zone tax incentives................... 0.1 0.2 0.3 0.3 0.3 0.1 0.3 0.4 0.4 0.4 2.8
Renewal community tax incentives.................. ....... 0.1 0.1 0.1 0.2 ....... 0.3 0.4 0.4 0.4 2.0
New markets tax credit............................ (\1\) (\1\) 0.1 0.1 0.2 (\1\) (\1\) 0.1 0.1 0.2 0.8
District of Columbia tax incentives............... (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.1 0.1 0.5
Indian reservation tax incentives................. 0.2 0.2 0.2 0.1 (\1\) 0.1 0.1 0.1 0.1 (\1\) 1.1
Expensing of environmental remediation costs...... (\1\) (\1\) 0.1 0.1 (\1\) (\1\) 0.1 0.1 0.1 (\1\) 0.7
Tax credit for rehabilitation of structures, other (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
than historic structures.........................
Exclusion of interest on State and local 0.2 0.2 0.2 0.2 0.2 0.5 0.5 0.5 0.5 0.5 3.6
government bonds for private airports, docks, and
mass-commuting facilities........................
Education, Training, Employment, and Social Services
Education and training:
Tax credits for tuition for post-secondary ....... ....... ....... ....... ....... 4.2 4.3 4.3 4.3 4.3 21.4
education......................................
Deduction for interest on student loans......... ....... ....... ....... ....... ....... 0.4 0.4 0.4 0.5 0.5 2.2
Exclusion of earnings of trust accounts for ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
higher education (``education IRAs'')..........
Exclusion of interest on educational savings ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
bonds..........................................
Deferral of tax on earnings of qualified State ....... ....... ....... ....... ....... 0.1 0.1 0.1 0.1 0.2 0.6
tuition programs...............................
Exclusion of scholarship and fellowship income.. ....... ....... ....... ....... ....... 1.2 1.3 1.4 1.5 1.5 6.9
Exclusion of employer-provided education ....... ....... ....... ....... ....... 0.4 0.1 ....... ....... ....... 0.5
assistance benefits............................
Parental personal exemption for students age 19 ....... ....... ....... ....... ....... 0.8 0.8 0.8 0.8 0.8 4.0
to 23..........................................
Exclusion of interest on State and local 0.1 0.1 0.1 0.1 0.1 0.3 0.3 0.2 0.2 0.2 1.7
government student loan bonds..................
Exclusion of interest on State and local 0.3 0.3 0.2 0.2 0.2 0.7 0.7 0.6 0.6 0.6 4.5
government bonds for private nonprofit
educational facilities.........................
Tax credit for holders of qualified zone academy (\1\) (\1\) 0.1 0.1 0.1 ....... ....... ....... ....... ....... 0.3
bonds..........................................
Deduction for charitable contributions to 0.9 1.0 1.1 1.2 1.3 4.2 4.4 4.6 4.8 5.1 28.6
educational institutions.......................
Employment:
Exclusion of employee meals and lodging (other ....... ....... ....... ....... ....... 0.8 0.8 0.9 0.9 0.9 4.3
than military).................................
Exclusion of benefits provided under cafeteria ....... ....... ....... ....... ....... 9.0 9.6 10.2 10.8 11.5 51.2
plans \3\......................................
Exclusion of housing allowances for ministers... ....... ....... ....... ....... ....... 0.4 0.4 0.4 0.4 0.5 2.1
Exclusion of miscellaneous fringe benefits...... ....... ....... ....... ....... ....... 7.3 7.9 8.4 9.0 9.7 42.3
Exclusion of employee awards.................... ....... ....... ....... ....... ....... 0.1 0.1 0.1 0.1 0.1 0.7
Exclusion of income earned by voluntary ....... ....... ....... ....... ....... 1.5 1.6 1.7 1.7 1.8 8.3
employees' beneficiary associations............
Special tax provisions for employee stock 0.8 0.9 0.9 0.9 0.9 0.2 0.2 0.2 0.3 0.3 5.7
ownership plans (ESOPs)........................
Work opportunity tax credit..................... 0.4 0.3 0.1 0.1 (\1\) 0.1 0.1 (\1\) (\1\) ....... 1.0
Welfare-to-work tax credit...................... 0.1 0.1 (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) ....... 0.3
Social services:
Tax credit for children under age 17 \4\........ ....... ....... ....... ....... ....... 19.1 18.7 18.3 17.9 17.4 91.4
Tax credit for child and dependent care expenses ....... ....... ....... ....... ....... 2.4 2.4 2.3 2.2 2.2 11.6
Exclusion of employer-provided child care \5\... ....... ....... ....... ....... ....... 0.5 0.6 0.6 0.6 0.7 3.0
Exclusion of certain foster care payments....... ....... ....... ....... ....... ....... 0.5 0.5 0.5 0.6 0.6 2.6
Adoption credit and employee adoption benefits ....... ....... ....... ....... ....... 0.2 0.1 (\1\) (\1\) (\1\) 0.4
exclusion......................................
Deduction for charitable contributions, other 1.6 1.7 1.9 2.1 2.2 22.6 23.8 25.0 26.3 27.5 134.7
than for education and health..................
Tax credit for disabled access expenditures..... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1 0.1 0.1 0.1 0.1 0.4
Health
Exclusion of employer contributions for health ....... ....... ....... ....... ....... 66.2 71.9 78.2 84.7 91.4 392.4
care, health insurance premiums, and long-term
care insurance premiums \6\......................
Exclusion of medical care and CHAMPUS/TRICARE ....... ....... ....... ....... ....... 1.6 1.6 1.6 1.6 1.7 8.1
medical insurance for military dependents,
retirees, and retiree dependents.................
Deduction for health insurance premiums and long- ....... ....... ....... ....... ....... 1.4 1.6 2.5 2.9 3.0 11.4
term care insurance premiums by the self-employed
Deduction for medical expenses and long-term care ....... ....... ....... ....... ....... 5.1 5.4 5.6 6.0 6.3 28.3
expenses.........................................
Exclusion of workers' compensation benefits ....... ....... ....... ....... ....... 4.7 4.9 5.1 5.4 5.6 25.7
(medical benefits)...............................
Medical savings accounts.......................... ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
Exclusion of interest on State and local 0.4 0.4 0.4 0.4 0.4 1.1 1.1 1.0 1.0 1.0 7.3
government bonds for private nonprofit hospital
facilities.......................................
Deduction for charitable contributions to health 0.9 1.0 1.0 1.1 1.2 2.9 3.1 3.2 3.4 3.5 21.3
organizations....................................
Tax credit for orphan drug research............... 0.1 0.1 0.1 0.1 0.1 ....... ....... ....... ....... ....... 0.5
Medicare
Exclusion of untaxed Medicare benefits:
Hospital insurance.............................. ....... ....... ....... ....... ....... 16.1 17.1 18.3 19.7 21.5 92.7
Supplementary medical insurance................. ....... ....... ....... ....... ....... 9.1 10.0 11.0 12.1 13.2 55.4
Income Security
Exclusion of workers' compensation benefits ....... ....... ....... ....... ....... 5.2 5.5 5.7 5.9 6.1 28.4
(disability and survivors payments)..............
Exclusion of special benefits for disabled coal ....... ....... ....... ....... ....... 0.1 0.1 0.1 0.1 0.1 0.4
miners...........................................
Exclusion of cash public assistance benefits...... ....... ....... ....... ....... ....... 0.7 0.7 0.8 0.8 0.8 3.7
Net exclusion of pension contributions and
earnings:
Employer plans.................................. ....... ....... ....... ....... ....... 85.0 84.1 82.4 83.9 87.4 422.8
Individual retirement plans..................... ....... ....... ....... ....... ....... 13.3 13.7 13.8 14.4 15.6 70.8
Keogh plans..................................... ....... ....... ....... ....... ....... 5.5 5.5 5.3 5.2 5.4 27.0
Exclusion of other employee benefits:
Premiums on group term life insurance........... ....... ....... ....... ....... ....... 2.1 2.2 2.3 2.4 2.5 11.5
Premiums on accident and disability insurance... ....... ....... ....... ....... ....... 2.2 2.3 2.4 2.6 2.7 12.3
Additional standard deduction for the blind and ....... ....... ....... ....... ....... 2.1 2.2 2.3 2.4 2.5 11.7
the elderly......................................
Tax credit for the elderly and disabled........... ....... ....... ....... ....... ....... (\1\) (\1\) (\1\) (\1\) (\1\) 0.1
Deduction for casualty and theft losses........... ....... ....... ....... ....... ....... 0.2 0.2 0.2 0.2 0.2 1.1
Earned income credit (EIC) \7\.................... ....... ....... ....... ....... ....... 4.2 4.3 4.3 4.4 4.5 21.6
Social Security and Railroad Retirement
Exclusion of untaxed social security and railroad ....... ....... ....... ....... ....... 24.9 25.6 26.6 27.6 28.4 133.1
retirement benefits..............................
Veterans' Benefits and Services
Exclusion of veterans' disability compensation.... ....... ....... ....... ....... ....... 2.2 2.3 2.4 2.4 2.5 11.8
Exclusion of veterans' pensions................... ....... ....... ....... ....... ....... 0.1 0.1 0.1 0.1 0.1 0.6
Exclusion and veterans' readjustment benefits..... ....... ....... ....... ....... ....... 0.1 0.1 0.1 0.1 0.1 0.7
Exclusion of interest on State and local (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) (\1\) 0.2
government bonds for veterans' housing...........
General Purpose Fiscal Assistance
Exclusion of interest on public purpose State and 6.6 6.6 6.2 6.0 6.1 17.1 17.1 16.0 15.5 15.7 113.0
local government debt............................
Deduction of nonbusiness State and local ....... ....... ....... ....... ....... 40.0 41.4 43.0 44.4 46.1 214.9
government income and personal property taxes....
Tax credit for Puerto Rico and possession income, 4.0 3.6 3.2 3.0 2.8 ....... ....... ....... ....... ....... 16.6
and Puerto Rico economic activity................
Interest
Deferral of interest on savings bonds............. ....... ....... ....... ....... ....... 1.6 1.6 1.6 1.6 1.6 8.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
\1\ Positive tax expenditure of less than $50 million.
\2\ In addition, the exemption from excise tax for alcohol fuels results in a reduction in excise tax receipts, net of income tax effect, of $0.6
billion per year in fiscal years 2001 through 2005.
\3\ Estimate includes amounts of employer-provided health insurance purchased through cafeteria plans and employee-provided child care purchased through
dependent care flexible spending accounts. These amounts are also included in other line items in this table.
\4\ The figures in the table show the effect of the child credit on receipts. The increase in outlays is: $0.8 billion in 2001, $0.8 billion in 2002,
$0.8 billion in 2003, $0.8 billion in 2004, and $0.8 billion in 2005.
\5\ Estimate includes employer-provided child care purchased through dependent care flexible spending accounts.
\6\ Estimate includes employer-provided health insurance purchased through cafeteria plans.
\7\ The figures in the table show the effect of the earned income credit on receipts. The increase in outlays is: $25.8 billion in 2001, $26.4 billion
in 2002, $26.7 billion in 2003, $27.2 billion in 2004, and $27.8 billion in 2005.

Note.--Details may not add to totals due to rounding.
Source: Joint Committee on Taxation.

Table 2.--Distribution by Income Class of All Returns, Taxable Returns, Itemized Returns, and Tax Liability at
2000 Rates and 2000 Law and 2000 Income Levels \1\
[Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
All returns \3\ Taxable Itemized
Income class [thousands] \2\ returns returns Tax Liability
----------------------------------------------------------------------------------------------------------------
Below $10................................... 19,818 1,084 319 -$5,363
$10 to $20.................................. 23,803 7,532 846 -6,738
$20 to $30.................................. 19,493 11,062 1,749 9,601
$30 to $40.................................. 16,210 12,937 3,035 29,695
$40 to $50.................................. 13,054 11,797 3,874 38,578
$50 to $75.................................. 21,557 20,997 9,593 114,182
$75 to $100................................. 11,924 11,838 8,157 113,000
$100 to $200................................ 11,253 11,211 9,415 213,550
$200 and over............................... 3,101 3,096 2,817 377,329
-------------------------------------------------------------------
Total................................. 140,213 91,553 38,805 $883,834
----------------------------------------------------------------------------------------------------------------
\1\ Tax law as in effect on January 1, 2000, is applied to the 2000 level and sources of income and their
distribution among taxpayers.
\2\ The income concept used to place tax returns into classes is adjusted gross income (AGI) plus: (a) tax-
exempt interest, (b) employer contributions for health plans and life insurance, (c) employer share of FICA
tax, (d) workers' compensation, (e) nontaxable Social Security benefits, (f) insurance value of Medicare
benefits, (g) alternative minimum tax preference items, and (h) excluded income of U.S. citizens living
abroad.
\3\ Includes filing and nonfiling units. Filing units include all taxable and nontaxable returns. Nonfiling
units include individuals with income that is exempt from Federal income taxation (e.g., transfer payments,
interest from tax-exempt bonds, etc.). Excludes individuals who are dependents of other taxpayers and
taxpayers with negative income.

Note.--Details may not add to totals due to rounding.

Source: Joint Committee on Taxation.

Table 3.--Distribution by Income Class of Selected Individual Tax Expenditure Items, at 2000 Rates and 2000
Income Levels \1\
[Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
Medical deduction \3\ Real estate tax deduction
Income class [thousands] \2\ -------------------------------------------------------------------
Returns Amount Returns Amount
----------------------------------------------------------------------------------------------------------------
Below $10................................... 10 $2 21 $1
$10 to $20.................................. 155 52 298 40
$20 to $30.................................. 412 138 930 152
$30 to $40.................................. 767 372 2,109 426
$40 to $50.................................. 860 429 3,107 819
$50 to $75.................................. 1,546 1,219 8,229 2,683
$75 to $100................................. 696 856 7,332 3,833
$100 to $200................................ 423 1,243 8,522 6,980
$200 and over............................... 47 515 2,396 5,303
-------------------------------------------------------------------
Total................................. 4,916 $4,825 32,946 $20,237
----------------------------------------------------------------------------------------------------------------
Footnotes at end of table.

Table 3.--Distribution by Income Class of Selected Individual Tax Expenditure Items, at 2000 Rates and 2000
Income Levels \1\--Continued
[Money amounts in millions of dollars, returns in thousands]
----------------------------------------------------------------------------------------------------------------
Mortgage interest deduction
Income class [thousands] \2\ ---------------------------------
Returns Amount
----------------------------------------------------------------------------------------------------------------
Below $10..................................................................... 12 $1
$10 to $20.................................................................... 272 105
$20 to $30.................................................................... 906 386
$30 to $40.................................................................... 2,141 1,194
$40 to $50.................................................................... 3,016 2,591
$50 to $75.................................................................... 8,071 8,165
$75 to $100................................................................... 7,130 12,423
$100 to $200.................................................................. 8,097 22,131
$200 and over................................................................. 2,164 13,619
---------------------------------
Total................................................................... 31,809 $60,615
----------------------------------------------------------------------------------------------------------------
Footnotes for Table 3:
\1\ Excludes individuals who are dependents of other taxpayers and taxpayers with negative income.
\2\ The income concept used to place tax returns into classes is adjusted gross income (AGI) plus: (a) tax-
exempt interest, (b) employer contributions for health plans and life insurance, (c) employer share of FICA
tax, (d) workers' compensation, (e) nontaxable Social Security benefits, (f) insurance value of Medicare
benefits, (g) alternative minimum tax preference items, and (h) excluded income of U.S. citizens living
abroad.
\3\ Tax expenditure estimate does not include revenue losses attributable to deductions for long-term care and
long-term care insurance premiums.
\4\ Includes the refundable portion.
\5\ Less than 500 returns.
\6\ Less than $500,000.
Note.--Details may not add to totals due to rounding.
Source: Joint Committee on Taxation.