[Congressional Record Volume 141, Number 40 (Friday, March 3, 1995)]
[House]
[Page H2641]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
SPECIAL ORDERS
The SPEAKER pro tempore. Under the Speaker's announced policy of
January 4, 1995, and under a previous order of the House, the following
Members are recognized for 5 minutes each.
The SPEAKER pro tempore. Under a previous order of the House, the
gentleman from Texas [Mr. Archer] is recognized for 5 minutes.
Mr. ARCHER. Mr. Speaker, today I am introducing the Tax Technical
Corrections Act of 1995. I am joined on this legislation by Sam
Gibbons, the distinguished ranking minority member of the Ways and
Means Committee.
This legislation makes necessary technical corrections to implement
the intent of prior tax legislation. Virtually all of the items in this
bill were included in H.R. 3419, which passed in the House during the
103d Congress. However, the bill does include some new technical
corrections.
I am introducing this legislation in order to give the public an
opportunity to comment on it. Because I intend to mark up the technical
corrections legislation during the Ways and Means Committee's
consideration of the Contract With America tax provisions within the
next 2 weeks, I would ask that any comments be submitted to the Ways
and Means Committee as soon as possible.
The following are the new technical corrections which were not
included in the prior legislation:
First, the bill clarifies that a U.S. shareholder's inclusion of a
controlled foreign corporation's earnings invested in excess passive
assets is treated like a dividend for purposes of the foreign tax
credit limitation. Thus, like other amounts included in income with
respect to a controlled foreign corporation, the inclusion would be
characterized by reference to the underlying nature of the earnings and
profits of the foreign corporation.
Second, the bill provides an inflation adjustment of the dollar
amounts where a parent elects to include child's unearned income on the
parent's return.
Third, the bill provides that the exclusion from income for a
taxpayer's investment in an annuity contract applies to his entire
investment in the contract, in the case of an annuity contract with a
refund feature.
The bill also includes a number of new clerical changes, deletions of
obsolete provisions, and date changes necessitated by the passage of
time.
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