[Congressional Record Volume 149, Number 73 (Thursday, May 15, 2003)]
[Senate]
[Pages S6421-S6428]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]




    JOBS AND GROWTH TAX RELIEF RECONCILIATION ACT OF 2003--Continued

  Mr. BAUCUS. Mr. President, what is the regular order?
  The PRESIDING OFFICER. The reconciliation act, and it is necessary to 
set aside the pending Burns amendment.
  Mr. BAUCUS. I ask unanimous consent that the Burns amendment be set 
aside.
  The PRESIDING OFFICER. Without objection, it is so ordered.


                           Amendment No. 614

  The PRESIDING OFFICER. The business now is the amendment of the 
Senator from Michigan.
  Who yields time?
  Ms. STABENOW. Mr. President, I ask unanimous consent that Senator 
Mikulski be added as a cosponsor of the amendment.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  Ms. STABENOW. Mr. President, I urge my colleagues to support this 
very important amendment for the seniors of this country. This does 
that. First and foremost, before we pass the dividend tax cut and the 
top rate tax cut, we will proceed to develop and pass a comprehensive 
prescription drug benefit that is equivalent to what we receive in the 
Senate. I have heard many colleagues express the concern I share, which 
is that the seniors and the disabled of this country ought to have the 
same ability to have the prescription drug coverage we as Federal 
employees do.
  This amendment simply sets our priorities straight. It says before we 
proceed with these two tax cuts, we will pass a comprehensive 
prescription drug benefit based on FEHBP, the most common portion of 
which is used by Senate and House Members. I urge my colleagues to 
support this amendment.
  The PRESIDING OFFICER. Who yields time? The Senator from Iowa.
  Mr. GRASSLEY. Mr. President, I oppose this amendment. I feel exactly 
about Medicare and prescription drug issues as the Senator from 
Michigan, but this is not the way to do it. This amendment reduces our 
jobs and growth package even before the Finance Committee takes up a 
comprehensive prescription drug benefit and Medicare improvement bill.
  I hope everybody knows that I am very committed to reporting a $400 
billion bill out of the Finance Committee, and doing it this summer, 
hopefully within the month. This will add a comprehensive prescription 
drug benefit for seniors.
  The amendment before us jumps the gun. I am working in a bipartisan 
way on a prescription drug policy that fits within that $400 billion 
framework in our budget resolution. In fact, I have a 4 o'clock meeting 
today with Senators on that issue that, obviously, I am not going to be 
able to keep because of these rollcall votes. We need to keep the jobs 
and growth package complete.
  The PRESIDING OFFICER. The Senator's time has expired.
  Mr. GRASSLEY. Mr. President, I want to raise a point of order. This 
upsets the balance of our bill. This language is not germane to the 
measure before the Senate. Therefore, I raise a point of order under 
section 305(b)(2) of the Congressional Budget Act.
  The PRESIDING OFFICER. The Senator from Michigan.
  Ms. STABENOW. Due to the fact the budget resolution does not contain 
enough revenue to do what our distinguished chairman has just 
indicated, this amendment is necessary to make that happen. Pursuant to 
section 904 of the Congressional Budget Act of 1974, I move to waive 
the applicable sections of that act and the budget resolution for the 
consideration of the pending amendment. I ask for the yeas and nays.
  The PRESIDING OFFICER. Is there a sufficient second?
  There appears to be a sufficient second.
  The question is on agreeing to the motion. The clerk will call the 
roll.
  The assistant legislative clerk called the roll.
  The yeas and nays resulted--yeas 44, nays 56, as follows:

                      [Rollcall Vote No. 159 Leg.]

                                YEAS--44

     Akaka
     Bayh
     Biden
     Bingaman
     Boxer
     Byrd
     Cantwell
     Chafee
     Clinton
     Conrad
     Corzine
     Daschle
     Dayton
     Dodd
     Dorgan
     Durbin
     Edwards
     Feingold
     Feinstein
     Graham (FL)
     Harkin
     Hollings
     Inouye
     Johnson
     Kennedy
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Murray
     Nelson (FL)
     Pryor
     Reed
     Reid
     Rockefeller
     Sarbanes
     Schumer
     Stabenow
     Wyden

                                NAYS--56

     Alexander
     Allard
     Allen
     Baucus
     Bennett
     Bond
     Breaux
     Brownback
     Bunning
     Burns
     Campbell
     Carper
     Chambliss
     Cochran
     Coleman
     Collins
     Cornyn
     Craig
     Crapo
     DeWine
     Dole
     Domenici
     Ensign
     Enzi
     Fitzgerald
     Frist
     Graham (SC)
     Grassley
     Gregg
     Hagel
     Hatch
     Hutchison
     Inhofe
     Jeffords
     Kyl
     Lott
     Lugar
     McCain
     McConnell
     Miller
     Murkowski
     Nelson (NE)
     Nickles
     Roberts
     Santorum
     Sessions
     Shelby
     Smith
     Snowe
     Specter
     Stevens
     Sununu
     Talent
     Thomas
     Voinovich
     Warner
  The PRESIDING OFFICER. On this vote, the yeas are 44, the nays are 
56. Three-fifths of the Senators duly chosen and sworn not having voted 
in the affirmative, the motion is rejected. The point of order is 
sustained, and the amendment falls.
  Mr. GRASSLEY. Mr. President, I move to reconsider the vote.
  Mr. BAUCUS. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.
  The next amendment is the Warner amendment. The Senator from Iowa.
  Mr. GRASSLEY. I ask unanimous consent that the Warner amendment be 
set aside to take up another amendment, and then we will take up the 
Warner amendment next.
  The PRESIDING OFFICER. Is there objection? Without objection, it is 
so ordered.

[[Page S6422]]

                     Amendment No. 592, As Modified

  The PRESIDING OFFICER. The next amendment is the Voinovich amendment. 
Who yields time?
  The Senator from Montana.
  Mr. BAUCUS. I understand the regular order is the Voinovich 
amendment. The Senator from Ohio has the right to speak.
  The PRESIDING OFFICER. The Senator is correct.
  The Senator from Ohio.
  Mr. VOINOVICH. I have an amendment that has been modified. The 
modification has been agreed to. I send my amendment, with the 
modification, to the desk.
  The PRESIDING OFFICER. Without objection, the amendment is so 
modified.
  The amendment, as modified, is as follows:

 (Purpose: To establish a blue ribbon commission on comprehensive tax 
                                reform)

       At the appropriate place insert the following:

     SECTION 1. SHORT TITLE.

       This Act may be cited as the ``Fundamental Tax Reform 
     Commission Act of 2003''.

     SEC. 2. ESTABLISHMENT OF COMMISSION.

       (a) Establishment.--There is established the ``Blue Ribbon 
     Commission on Comprehensive Tax Reform'' (in this Act 
     referred to as the ``Commission'').
       (b) Membership.--
       (1) Composition.--The Commission shall be composed of 12 
     members of whom--
       (A) 1 shall be the Chairman of the Board of Governors of 
     the Federal Reserve System;
       (D) 2 shall be appointed by the majority leader of the 
     Senate;
       (E) 2 shall be appointed by the minority leader of the 
     Senate;
       (F) 2 shall be appointed by the Speaker of the House of 
     Representatives;
       (G) 2 shall be appointed by the minority leader of the 
     House of Representatives; and
       (H) 3 shall be appointed by the President, of which--
       (i) no more than 2 shall be of the same party as the 
     President; and
       (2) Federal employees.--The members of the Commission may 
     be employees or former employees of the Federal Government.
       (3) Date.--The appointments of the members of the 
     Commission shall be made not later than July 30, 2003.
       (c) Period of Appointment; Vacancies.--Members shall be 
     appointed for the life of the Commission. Any vacancy in the 
     Commission shall not affect its powers, but shall be filled 
     in the same manner as the original appointment.
       (d) Initial Meeting.--Not later than 30 days after the date 
     on which all members of the Commission have been appointed, 
     the Commission shall hold its first meeting.
       (e) Meetings.--The Commission shall meet at the call of the 
     Chairman.
       (f) Quorum.--A majority of the members of the Commission 
     shall constitute a quorum, but a lesser number of members may 
     hold hearings.
       (g) Chairman and Vice Chairman.--The President shall select 
     a Chairman and Vice Chairman from among its members.

     SEC. 3. DUTIES OF THE COMMISSION.

       (a) Study.--The Commission shall conduct a thorough study 
     of all matters relating to a comprehensive reform of the 
     Federal tax system, including the reform of the Internal 
     Revenue Code of 1986 and the implementation (if appropriate) 
     of other types of tax systems.
       (b) Recommendations.--The Commission shall develop 
     recommendations on how to comprehensively reform the Federal 
     tax system in a manner that generates appropriate revenue for 
     the Federal Government.
       (c) Report.--Not later than 18 months after the date on 
     which all intitial members of the commission have been 
     appointed pursuant to section 2(b), the Commission shall 
     submit a report to the President and Congress which shall 
     contain a detailed statement of the findings and conclusions 
     of the Commission, together with its recommendations for such 
     legislation and administrative actions as it considers 
     appropriate.

     SEC. 4. POWERS OF THE COMMISSION.

       (a) Hearings.--The Commission may hold such hearings, sit 
     and act at such times and places, take such testimony, and 
     receive such evidence as the Commission considers advisable 
     to carry out this Act.
       (b) Information From Federal Agencies.--The Commission may 
     secure directly from any Federal department or agency such 
     information as the Commission considers necessary to carry 
     out this Act. Upon request of the Chairman of the Commission, 
     the head of such department or agency shall furnish such 
     information to the Commission.
       (c) Postal Services.--The Commission may use the United 
     States mails in the same manner and under the same conditions 
     as other departments and agencies of the Federal Government.
       (d) Gifts.--The Commission may accept, use, and dispose of 
     gifts or donations of services or property.

     SEC. 5. COMMISSION PERSONNEL MATTERS.

       (a) Compensation of Members.--Each member of the Commission 
     who is not an officer or employee of the Federal Government 
     shall be compensated at a rate equal to the daily equivalent 
     of the annual rate of basic pay prescribed for level IV of 
     the Executive Schedule under section 5315 of title 5, United 
     States Code, for each day (including travel time) during 
     which such member is engaged in the performance of the duties 
     of the Commission. All members of the Commission who are 
     officers or employees of the United States shall serve 
     without compensation in addition to that received for their 
     services as officers or employees of the United States.
       (b) Travel Expenses.--The members of the Commission shall 
     be allowed travel expenses, including per diem in lieu of 
     subsistence, at rates authorized for employees of agencies 
     under subchapter I of chapter 57 of title 5, United States 
     Code, while away from their homes or regular places of 
     business in the performance of services for the Commission.
       (c) Staff.--
       (1) In general.--The Chairman of the Commission may, 
     without regard to the civil service laws and regulations, 
     appoint and terminate an executive director and such other 
     additional personnel as may be necessary to enable the 
     Commission to perform its duties. The employment of an 
     executive director shall be subject to confirmation by the 
     Commission.
       (2) Compensation.--The Chairman of the Commission may fix 
     the compensation of the executive director and other 
     personnel without regard to chapter 51 and subchapter III of 
     chapter 53 of title 5, United States Code, relating to 
     classification of positions and General Schedule pay rates, 
     except that the rate of pay for the executive director and 
     other personnel may not exceed the rate payable for level V 
     of the Executive Schedule under section 5316 of such title.
       (d) Detail of Government Employees.--Any Federal Government 
     employee may be detailed to the Commission without 
     reimbursement, and such detail shall be without interruption 
     or loss of civil service status or privilege.
       (e) Procurement of Temporary and Intermittent Services.--
     The Chairman of the Commission may procure temporary and 
     intermittent services under section 3109(b) of title 5, 
     United States Code, at rates for individuals which do not 
     exceed the daily equivalent of the annual rate of basic pay 
     prescribed for level V of the Executive Schedule under 
     section 5316 of such title.

     SEC. 6. TERMINATION OF THE COMMISSION.

       The Commission shall terminate 90 days after the date on 
     which the Commission submits its report under section 3.

     SEC. 7. AUTHORIZATION OF APPROPRIATIONS.

       There are authorized to be appropriated such sums as are 
     necessary to the Commission to carry out this Act.

  Mr. VOINOVICH. Mr. President, I ask that the amendment, as modified, 
be accepted by voice vote.
  The PRESIDING OFFICER. Is there objection to vitiating the yeas and 
nays?
  The Senator from Montana.
  Mr. BAUCUS. Mr. President, might I ask the Senator from Ohio if the 
modification is the one that changes the ratio of the membership?
  Mr. VOINOVICH. It changes the ratio of the membership and increases 
more representation by minority. It takes off the head of the IRS, and 
it is more evenly balanced and meets the problems that we talked about 
last night.
  Mr. BAUCUS. I have no objection.
  The PRESIDING OFFICER. Without objection, it is so ordered. The yeas 
and nays are vitiated.
  The question is on agreeing to the amendment, as modified.
  The amendment (No. 592), as modified, was agreed to.
  Mr. BAUCUS. Mr. President, I move to reconsider the vote.
  Mr. REID. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.
  The PRESIDING OFFICER. The Senator from Montana.
  Mr. BAUCUS. I understand the next amendment is the Graham of Florida 
amendment.
  The PRESIDING OFFICER. If the Warner amendment is once again set 
aside.
  Mr. BAUCUS. I ask unanimous consent that the Warner amendment and all 
relevant amendments be temporarily set aside so we can next proceed to 
the Graham of Florida amendment.
  The PRESIDING OFFICER. Without objection, it is so ordered.


                           Amendment No. 617

  The PRESIDING OFFICER. Who yields time on the Graham amendment?
  Mr. GRAHAM of Florida. I ask unanimous consent that Senators 
Rockefeller and Kerry be added as cosponsors to my amendment.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  Mr. GRAHAM of Florida. Mr. President, we have more dismal news on the 
state of the economy in today's press; that the April sales in the 
United

[[Page S6423]]

States declined .9 percent below those in March. This is what the chief 
economist of Wells Fargo had to say about this development: Consumers 
are tapped out. They have done a marvelous job of supporting the 
economy, but they are basically done. We need something else to pull up 
the slack.
  I suggest that what we need is this amendment which will place money 
in the hands of those Americans and institutions most likely to spend 
and therefore create demand. Those include payroll, small business. It 
includes those who have already lost their jobs and their unemployment 
benefits and State governments. This proposal would focus on the next 2 
years----
  The PRESIDING OFFICER. The Senator's time has expired.
  Mr. GRAHAM of Florida. The period of time in which we need to have a 
stimulus. Most importantly, this would not add to the national debt 
because it would be fully offset, therefore avoiding the potential that 
by adding to the deficit we will add to the economic problems that we 
will have in the future.
  Mr. President, I ask unanimous consent that an article from today's 
Washington Post on consumer spending be printed in the Record.
  There being no objection, the material was ordered to be printed in 
the Record, as follows:

                [From the Washington Post, May 15, 2003]

                  Consumers Trimmed Spending In April


              drop in gasoline sales was factor in decline

                 (By Dina ElBoghdady and Anitha Reddy)

       Consumer spending dipped in April as shoppers were more 
     concerned about their jobs than the easing of tensions with 
     Iraq, increasing prospects that economic growth will be tepid 
     at best in the second half of the year.
       The Commerce Department reported yesterday that April 
     retail sales fell 0.1 percent from March, when pent-up demand 
     created by February's snow storms helped boost sales 2.3 
     percent.
       Excluding auto purchases, April sales declined 0.9 percent, 
     the report showed.
       ``Consumers are tapped out,'' said Sung Won Sohn, chief 
     economic officer at Wells Fargo & Co. ``They've done a 
     marvelous job of supporting the economy, but they are 
     basically done . . . We need something else to pull up the 
     slack.''
       A large portion of the overall sales decline came from 
     consumers spending less on gasoline. Gas purchases fell 5.9 
     percent from late March to late April as gas prices slid by 
     about a dime on average.
       But shoppers also held back on their purchases of clothing, 
     furniture and garden supplies because of uncertainty about 
     holding on to their jobs, or finding new ones, if necessary. 
     The jobless rate is 6 percent today, compared with slightly 
     over 4 percent a year ago. Consumers' hesitancy was a big 
     factor preventing the postwar bounce that economists had 
     expected.
       ``It's not just that the unemployment rate is a problem, 
     it's that the people who are unemployed are unemployed for a 
     longer period of time,'' said John E. Silvia, chief 
     economicst at Wachovia. ``The job pool is stagnant.''
       A tax cut might prompt shoppers to increase spending and 
     help fuel a more robust recovery, said David A. Wyss, chief 
     economist at Standard & Poor's Corp.
       Wyss said the savings patterns of the average American 
     indicate that any extra money in after-tax pay would be spent 
     rather than saved.
       ``The saving rate is pretty much flat, which certainly 
     suggests that consumers are spending as much money as they 
     have,'' Wyss said. ``You can't expect them to do much more 
     than that.''
       Sales fell 3.2 percent at clothing and accessory stores, 
     1.4 percent at department stores and 0.5 percent at 
     restaurants and bars.
       ``I've just been going out a lot less,'' said Tonya Sawyer, 
     a claims adjustor shopping at the Fashion Centre at Pentagon 
     City. ``So I don't have the need for clothes or make-up.''
       Instead, the 30 years old said she relies on new books and 
     CDs, rental videos and her dog Bella to entertain herself in 
     her Arlington apartment. Sales at stores that sell sporting 
     goods, books, music and hobby materials increased 1.2 
     percent.
       Even the one demographic group that stores hoped might show 
     steadfast devotion to shopping--teenage girls during prom 
     season--was being wary.
       ``It's finding what you want at the right price'' that's so 
     hard, said Breona Cain, a high school senior from Largo who 
     was at Pentagon City with two friends yesterday, searching 
     for the perfect accessories for her dress.
       Auto sales rose 2.5 percent in April, thanks to widespread 
     no-interest financing offers.
       ``Consumers have shown they're opportunistic,'' said Frank 
     Badillo, senior economist at Retail Forward Inc., a market 
     research firm. ``So certain sectors are benefiting in what is 
     otherwise a weak environment.''
       Some economists say that in such an uncertain climate it's 
     too early to guage the outlook for the rest of the year.
       ``The April results should most properly be viewed as 
     transition from a war footing to a normal peacetime 
     footing,'' Ken Mayland, president of Clear View Economics, 
     said in a report. ``Consumers are betwixt and between a 
     `recession' mindset and a `recovery mindset. They have not 
     bought in to either.''
  The PRESIDING OFFICER. The Senator's time has expired.
  Who yields time?
  Mr. KYL. Mr. President, speaking on behalf of Senator Grassley, this 
is a complete substitute and therefore, obviously, will have to be 
opposed. It strikes all of the good work from the committee bill 
regarding the child credit, marriage penalty, AMT, reduction of rates 
for individuals and small businesses, as well as the dividend relief.
  We certainly appreciate the Senator's concerns about unemployment 
insurance and relief for the States. Obviously, we are committed to 
addressing the unemployment insurance issue. As everyone now knows, we 
have $20 billion for State aid in the bill, and therefore we will have 
to make a point of order. The matter is not germane to the measure now 
before the Senate. Therefore, I make a point of order that the pending 
amendment violates section 305(b)(2) of the Congressional Budget Act of 
1974.
  Mr. GRAHAM of Florida. Pursuant to section 904 of the Budget Act I 
ask that the point of order against my amendment be waived.
  I ask for the yeas and nays.
  The PRESIDING OFFICER. Is there a sufficient second?
  There appears to be a sufficient second.
  The question is on agreeing to the motion.
  The clerk will call the roll.
  The senior assistant bill clerk called the roll.
  The result was announced--yeas 35, nays 65, as follows:

                      [Rollcall Vote No. 160 Leg.]

                                YEAS--35

     Akaka
     Biden
     Bingaman
     Boxer
     Breaux
     Byrd
     Cantwell
     Clinton
     Corzine
     Daschle
     Dayton
     Dodd
     Dorgan
     Durbin
     Feingold
     Feinstein
     Graham (FL)
     Harkin
     Hollings
     Inouye
     Jeffords
     Kennedy
     Kerry
     Landrieu
     Lautenberg
     Leahy
     Levin
     Mikulski
     Murray
     Nelson (FL)
     Reid
     Rockefeller
     Sarbanes
     Stabenow
     Wyden

                                NAYS--65

     Alexander
     Allard
     Allen
     Baucus
     Bayh
     Bennett
     Bond
     Brownback
     Bunning
     Burns
     Campbell
     Carper
     Chafee
     Chambliss
     Cochran
     Coleman
     Collins
     Conrad
     Cornyn
     Craig
     Crapo
     DeWine
     Dole
     Domenici
     Edwards
     Ensign
     Enzi
     Fitzgerald
     Frist
     Graham (SC)
     Grassley
     Gregg
     Hagel
     Hatch
     Hutchison
     Inhofe
     Johnson
     Kohl
     Kyl
     Lieberman
     Lincoln
     Lott
     Lugar
     McCain
     McConnell
     Miller
     Murkowski
     Nelson (NE)
     Nickles
     Pryor
     Reed
     Roberts
     Santorum
     Schumer
     Sessions
     Shelby
     Smith
     Snowe
     Specter
     Stevens
     Sununu
     Talent
     Thomas
     Voinovich
     Warner
  The PRESIDING OFFICER. On this question, the yeas are 35, the nays 
are 65. Three-fifths of the Senators duly chosen and sworn not having 
voted in the affirmative, the motion is rejected. The point of order is 
sustained, and the amendment falls.
  Mr. GRASSLEY. I move to reconsider the vote.
  Mr. BAUCUS. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.


                      Amendment No. 550 Withdrawn

  The PRESIDING OFFICER. Without objection, the pending Warner 
amendment is set aside.
  The Senator from Virginia.
  Mr. WARNER. Mr. President, I ask to have the amendment set aside.
  The PRESIDING OFFICER (Mr. Crapo). Without objection, it is so 
ordered.
  Mr. WARNER. My request is on behalf of Senator Collins, Senator 
Craig, Senator Allen, and Senator Murkowski. I do so because we have 
made a conscientious effort, together with the cooperation of the 
managers of this bill, to find the offset and we simply could not find 
the offset.
  The thrust of our amendment is for the teachers in America. The 
amendment is very simple. It compensates them through a tax deduction 
for each time they reach into their own pocketbooks or pockets to buy 
school supplies for their students. We need to increase

[[Page S6424]]

that amount from $250 which is current law. We need to broaden it so 
they can use some of the deduction for purposes of continuing 
education. This is an amendment not for the rich; it is simply for 
those who serve America and ask very little by way of salary.
  We cannot move it at this time, but the managers very generously have 
acceded to this colloquy. The managers have agreed to look at this in 
future tax legislation and for the time being will agree to extend it 
so this current law of the $250 deduction will not expire at the end of 
this calendar year.
  I ask the question of my colleague.
  Mr. GRASSLEY. The Senator accurately stated what my intentions are, 
but let me say it for myself so the Senator knows I have said it.
  First of all, I need to thank the Senator for his cooperation in 
working with us on this amendment so we can expedite the bill. Also, I 
make clear I am a strong supporter of the Senator's legislation and the 
expansion of it and would agree to make sure we get this done before 
the end of the calendar year, so that would involve extending it and 
expanding these teacher provisions.
  This all deals--so everyone knows what we are talking about--with the 
extension of legislation passed within the last 2 years. It sunsets. We 
make these permanent, and there would be a significant increase in the 
above-the-line deduction for teachers.
  Mr. WARNER. Mr. President, I thank my distinguished colleague. 
Perhaps the ranking member may wish to address this issue. If the 
ranking member would care to make a comment about the withdrawal of the 
amendment of the Senator from Virginia?
  Mr. BAUCUS. Mr. President, I thank the Senator from Virginia for 
asking the question. All I can say at this point is we will do the very 
best we can.
  Mr. WARNER. I thank my colleague. I move to withdraw the amendment.
  The PRESIDING OFFICER. Without objection, the amendment is withdrawn.


                           Amendment No. 575

  The PRESIDING OFFICER. The business before the Senate is the Kyl 
amendment.
  The Senator from Arizona.
  Mr. KYL. Mr. President, is there an order for me to speak to the Kyl 
amendment at this point?
  The PRESIDING OFFICER. The Senator has the floor for 1 minute.
  Mr. KYL. Mr. President, this is the amendment that would return money 
to the States from the tobacco company payments to trial lawyers, money 
that exceeded reasonable fees as determined by a common standard in the 
courts and an IRS Code provision.
  What we have done in this amendment is to apply it only 
prospectively, not retroactively. The fee is a reasonable fee plus 500 
percent, and in any event the lawyers are guaranteed--and, colleagues, 
please note this--$20,000 per hour. That is what the lawyers are 
guaranteed in those cases, those 10 to 15 cases per year to which this 
would apply.
  Those fees were not set by contract. They were not set by courts. The 
money is going to be paid by the tobacco companies. The only question 
is, are these excess fees going to be paid to the tobacco lawyers or 
are they going to be paid to the States?
  I will have at both desks a chart which shows how much money each of 
the States would receive. It is between $6 billion and $9 billion in 
total. You can see the amount listed on this sheet. I ask you to 
consult that because that is money your States would receive if this 
amendment is adopted.
  The PRESIDING OFFICER. Who speaks in opposition? The Senator from 
Montana.
  Mr. BAUCUS. Mr. President, I yield to the Senator from Louisiana.
  The PRESIDING OFFICER. The Senator from Louisiana.
  Mr. BREAUX. Mr. President, this amendment was already offered in the 
Senate Finance Committee. It was defeated by a bipartisan vote of 
Republicans and Democrats in the Finance Committee.
  IRS should not be involved in setting the fees for CEOs in this 
country. They should not be involved in setting the fees for plumbers 
or electricians. And they should not be involved in setting the fees 
for attorneys who have had voluntary agreements between defendants and 
the plaintiffs about what they should be paid, which have been approved 
by the courts. All of these fees have been approved by the courts or by 
the arbitrator. They were voluntarily agreed to.
  Lawyers don't get paid by the hour in these cases; they get paid by 
the job. IRS should not determine what are correct payments for 
services.
  Mr. BIDEN. Will the Senator yield me 10 seconds?
  Mr. BREAUX. I yield it if I have any time remaining.
  Mr. BIDEN. I want to point out company lawyers were paid $700 million 
per year, per year, for 5 years. Plaintiffs' lawyers had to risk $100 
million of their own money.
  The PRESIDING OFFICER. All time has expired.
  Mr. BREAUX. Mr. President, the pending amendment is not germane. 
Therefore, I make a point of order the amendment violates section 
305(b)(2) of the Congressional Budget Act of 1974.
  Mr. KYL. Mr. President, I move to waive the provision. I ask for the 
yeas and nays.
  The PRESIDING OFFICER. Is there a sufficient second? There is a 
sufficient second.
  The question is on agreeing to the motion. The clerk will call the 
roll.
  The assistant legislative clerk called the roll.
  Mr. LOTT (when his name was called). Present.
  Mr. REID. I announce that the Senator from Hawaii (Mr. Inouye) is 
necessarily absent.
  The PRESIDING OFFICER. Are there any other Senators in the Chamber 
desiring to vote?
  The yeas and nays resulted--yeas 37, nays 61, as follows:

                      [Rollcall Vote No. 161 Leg.]

                                YEAS--37

     Alexander
     Allard
     Bennett
     Bond
     Brownback
     Bunning
     Burns
     Campbell
     Collins
     Cornyn
     Craig
     Dole
     Domenici
     Ensign
     Enzi
     Fitzgerald
     Frist
     Grassley
     Gregg
     Hagel
     Hutchison
     Inhofe
     Kyl
     Lugar
     McCain
     McConnell
     Murkowski
     Nickles
     Roberts
     Santorum
     Sessions
     Snowe
     Stevens
     Sununu
     Talent
     Thomas
     Warner

                                NAYS--61

     Akaka
     Allen
     Baucus
     Bayh
     Biden
     Bingaman
     Boxer
     Breaux
     Byrd
     Cantwell
     Carper
     Chafee
     Chambliss
     Clinton
     Cochran
     Coleman
     Conrad
     Corzine
     Crapo
     Daschle
     Dayton
     DeWine
     Dodd
     Dorgan
     Durbin
     Edwards
     Feingold
     Feinstein
     Graham (FL)
     Graham (SC)
     Harkin
     Hatch
     Hollings
     Jeffords
     Johnson
     Kennedy
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Miller
     Murray
     Nelson (FL)
     Nelson (NE)
     Pryor
     Reed
     Reid
     Rockefeller
     Sarbanes
     Schumer
     Shelby
     Smith
     Specter
     Stabenow
     Voinovich
     Wyden

                        ANSWERED ``PRESENT''--1

       
       Lott
       

                             NOT VOTING--1

       
       Inouye
       
  The PRESIDING OFFICER. On this vote, the yeas are 37, the nays are 
61, and one Senator responded ``present.'' Three-fifths of the Senators 
duly chosen and sworn not having voted in the affirmative, the motion 
is rejected. The point of order is sustained, and the amendment falls.
  Mr. GRASSLEY. Mr. President, I move to reconsider the vote.
  Mr. BAUCUS. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.


                           Amendment No. 619

  The PRESIDING OFFICER. The next amendment is the Landrieu amendment. 
Each side has 1 minute.
  Who yields time?
  Mr. BAUCUS. Mr. President, I ask unanimous consent that relevant 
pending amendments be temporarily laid aside so that Senator Landrieu's 
amendment can be voted on.
  The PRESIDING OFFICER. The Landrieu amendment is now before the body.
  Mr. GRASSLEY. Mr. President, the Senate is not in order.
  The PRESIDING OFFICER. The Senator is correct. Senators will please 
take their conversations off the floor.
  The Senator from Louisiana.
  Ms. LANDRIEU. Thank you, Mr. President.
  Mr. President, this afternoon we are being asked to buy a pig in a 
poke.

[[Page S6425]]

That is what we would say in Louisiana--a pig in a poke. Please 
colleagues, do not vote for the underlying bill. Senator Corzine and 
Senator Schumer and I offer an amendment which is a $350 billion 
alternative that is truly stimulative. It tries to work with the 
administration but takes out the nonstimulative portion and puts in a 
rebate on wages. If we want to create jobs, then let us stop taxing 
them.
  Our amendment also treats States as respected partners and not as 
charitable aid organizations, which they are not.
  It also says that tax cuts aren't the only way to stimulate the 
economy; that you can make strategic investments. As politicians, live 
up to your promises to children by funding education and health care.
  Don't buy a pig in a poke, and don't turn your back on the 2 million 
companies, 2 million farms, and 2 million partnerships that do not get 
a penny from the dividend tax cut.
  Mr. GRASSLEY. Mr. President, the way to make sure the American people 
are not buying a pig in a poke is to get more money in the pockets of 
the taxpayers so that there is less money around here for 535 Members 
of Congress to play with.
  I want to speak in regard to this amendment; that the complete 
substitute will cut back our efforts to reduce marginal rates for 
families and small businesses.
  In addition, the bill will make millions of taxpayers subject to the 
alternative minimum tax.
  I appreciate the Senator's efforts on the child tax, and we already 
have a $95 billion child tax credit.
  We also have significant State aid in the bill.
  We have a point of order, as we have had before on an amendment like 
this.
  I raise that point of order--that the language is not germane to the 
measure now before the Senate. The point of order is under section 
305(b)(2) of the Congressional Budget Act.
  Ms. LANDRIEU. Mr. President, pursuant to section 904 of the 
Congressional Budget Act, I move to waive the applicable sections of 
that act for the consideration of this amendment, and I ask for the 
yeas and nays.
  The PRESIDING OFFICER. Is there a sufficient second?
  There is a sufficient second.
  The question is on agreeing to the motion. The clerk will call the 
roll.
  The legislative clerk called the roll.
  The yeas and nays resulted--yeas 47, nays 53, as follows:

                      [Rollcall Vote No. 162 Leg.]

                                YEAS--47

     Akaka
     Baucus
     Bayh
     Biden
     Bingaman
     Boxer
     Breaux
     Byrd
     Cantwell
     Carper
     Clinton
     Conrad
     Corzine
     Daschle
     Dayton
     Dodd
     Dorgan
     Durbin
     Edwards
     Feingold
     Feinstein
     Graham (FL)
     Harkin
     Hollings
     Inouye
     Jeffords
     Johnson
     Kennedy
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Murray
     Nelson (FL)
     Pryor
     Reed
     Reid
     Rockefeller
     Sarbanes
     Schumer
     Stabenow
     Wyden

                                NAYS--53

     Alexander
     Allard
     Allen
     Bennett
     Bond
     Brownback
     Bunning
     Burns
     Campbell
     Chafee
     Chambliss
     Cochran
     Coleman
     Collins
     Cornyn
     Craig
     Crapo
     DeWine
     Dole
     Domenici
     Ensign
     Enzi
     Fitzgerald
     Frist
     Graham (SC)
     Grassley
     Gregg
     Hagel
     Hatch
     Hutchison
     Inhofe
     Kyl
     Lott
     Lugar
     McCain
     McConnell
     Miller
     Murkowski
     Nelson (NE)
     Nickles
     Roberts
     Santorum
     Sessions
     Shelby
     Smith
     Snowe
     Specter
     Stevens
     Sununu
     Talent
     Thomas
     Voinovich
     Warner
  The PRESIDING OFFICER. On this vote, the yeas are 47, the nays are 
53. Three-fifths of the Senators duly chosen and sworn not having voted 
in the affirmative, the motion is rejected. The point of order is 
sustained, and the amendment falls.
  Mr. GRASSLEY. Mr. President, I move to reconsider the vote.
  Mr. BAUCUS. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.
  Mr. BAUCUS. Mr. President, my understanding is there are pending 
votes that require unanimous consent to be set aside. I make that 
request so that the next Landrieu amendment can be in order.
  The PRESIDING OFFICER. Without objection, it is so ordered.


                           Amendment No. 620

  The PRESIDING OFFICER. The Landrieu amendment No. 620 is before the 
Senate.
  There are 2 minutes equally divided.
  Who yields time?
  The Senator from Louisiana.
  Ms. LANDRIEU. Mr. President, this amendment would go a long way to 
send the right message to our guardsmen and reservists. Over 370,000 
have been activated since September 11 and the attack on this city and 
our Nation.
  As we know, it has been made painfully aware to us that many of these 
guardsmen and reservists who serve take a cut in pay because they leave 
their jobs, they close their businesses to temporarily serve us.
  This amendment will give their employers, and themselves if they are 
an employer, the opportunity to write off 50 percent of the cost of 
their salaries so those salaries can be maintained while they are 
protecting and serving us. It is the least we can do.
  The other side is going to say they will get to it later. Let's get 
to it today. Let's not let this tax bill pass without honoring the 
Guard and Reserves and giving them a chance to keep their businesses 
open while they keep us safe.
  The PRESIDING OFFICER. The Senator from Iowa.
  Mr. GRASSLEY. Mr. President, this amendment proposes to offer a 50-
percent tax credit for employers of reservists to encourage 
differential pay.
  This amendment does not benefit those who are self-employed and 
provides little benefit to small businesses with little equity.
  In addition, nearly 80 percent of the cost of the military tax bill, 
which we have already passed in the Senate, is dedicated to reservists 
with the above-the-line deduction that was included because Senator 
DeWine pushed very hard for it.
  The amendment is paid for by reducing the dividend exclusion which is 
essential to our growth package; in other words, to keep a well 
balanced growth package.
  So the amendment I see as an attack on the jobs and growth bill, and 
I ask that it not be adopted.
  Mr. President, I raise a point of order on germaneness, that the 
amendment is not germane. The point of order comes under section 
305(b)(2) of the Congressional Budget Act.
  Ms. LANDRIEU. Mr. President, I ask unanimous consent that Senator 
Feingold, Senator Stabenow, and Senator Mikulski be added as cosponsors 
of the amendment.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  Ms. LANDRIEU. Mr. President, pursuant to section 904 of the 
Congressional Budget Act, I move to waive the applicable sections of 
that act for the consideration of the pending amendment, and I ask for 
the yeas and nays.
  The PRESIDING OFFICER. Is there a sufficient second?
  There appears to be a sufficient second.
  The question is on agreeing to the motion.
  The clerk will call the roll.
  The bill clerk called the roll.
  The yeas and nays resulted--yeas 46, nays 54, as follows:

                      [Rollcall Vote No. 163 Leg.]

                                YEAS--46

     Akaka
     Baucus
     Bayh
     Biden
     Bingaman
     Boxer
     Breaux
     Byrd
     Cantwell
     Carper
     Clinton
     Conrad
     Corzine
     Daschle
     Dayton
     Dodd
     Dorgan
     Durbin
     Edwards
     Feingold
     Graham (FL)
     Harkin
     Hollings
     Inouye
     Jeffords
     Johnson
     Kennedy
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Murray
     Nelson (FL)
     Pryor
     Reed
     Reid
     Rockefeller
     Sarbanes
     Schumer
     Stabenow
     Wyden

                                NAYS--54

     Alexander
     Allard
     Allen
     Bennett
     Bond
     Brownback
     Bunning
     Burns
     Campbell
     Chafee
     Chambliss
     Cochran
     Coleman
     Collins
     Cornyn
     Craig
     Crapo
     DeWine
     Dole
     Domenici
     Ensign
     Enzi
     Feinstein
     Fitzgerald
     Frist
     Graham (SC)
     Grassley
     Gregg
     Hagel
     Hatch
     Hutchison
     Inhofe
     Kyl
     Lott
     Lugar
     McCain
     McConnell
     Miller
     Murkowski
     Nelson (NE)
     Nickles
     Roberts
     Santorum
     Sessions
     Shelby

[[Page S6426]]


     Smith
     Snowe
     Specter
     Stevens
     Sununu
     Talent
     Thomas
     Voinovich
     Warner
  The PRESIDING OFFICER (Mr. Smith). On this vote, the yeas are 46, the 
nays are 54. Three-fifths of the Senate duly chosen and sworn not 
having voted in the affirmative, the motion is rejected.
  The point of order is sustained and the amendment falls.
  Mr. KYL. Mr. President, I move to reconsider the vote.
  Mr. BAUCUS. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.


                      Amendment No. 621 Withdrawn

  Mr. BAUCUS. Mr. President, I ask unanimous consent that the votes on 
the various amendments next up be temporarily laid aside so we can 
proceed to the Landrieu amendment No. 621.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  The Senator from Louisiana.
  Ms. LANDRIEU. Mr. President, I thank my colleagues for their 
patience. Senator Sessions and I offered this amendment. We are not 
going to ask for a vote, but I would like to explain it in 1 minute. We 
offered this amendment to try to technically correct a glitch in the 
renewal community law. It only affects districts in Louisiana and 
Alabama now, but it could affect, in the near term, districts in 40 
other States.
  I am going to ask the chairman of the Finance Committee to consider 
this fix. It only costs $14 million a year and it will help create jobs 
in some of the poorest areas in our country. So if I could ask for 
their consideration, I will at this time withdraw the amendment.
  Mr. KYL. Mr. President, I have spoken to the Senator from Louisiana. 
I know the chairman is appreciative of her efforts along with the 
Senator from Alabama. He is anxious to continue to work with her on 
this matter. He appreciates their very strong interest in trying to 
rectify this situation. On behalf of the chairman, I can say he will be 
willing to work with her.
  Mr. BAUCUS. Mr. President, I, too, have spoken with the Senator and 
understand her concerns and will do my utmost to help resolve the 
issue.
  The PRESIDING OFFICER. Without objection, the amendment is withdrawn.
  Mr. BAUCUS. Mr. President, I suggest the absence of a quorum.
  The PRESIDING OFFICER. The clerk will call the roll.
  The bill clerk proceeded to call the roll.
  Mr. BAUCUS. Mr. President, I ask unanimous consent that the order for 
the quorum call be rescinded.
  The PRESIDING OFFICER. Without objection, it is so ordered.


                           Amendment No. 557

  Mr. BAUCUS. Mr. President, I ask unanimous consent that the votes on 
the earlier amendments be temporarily laid aside so we can now proceed 
to amendment No. 557 by the Senator from New York.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  The Senator from New York is recognized.
  Mr. SCHUMER. Mr. President, this is a simple amendment. Two years 
ago, on the last tax bill, we took a historic step in this body. We 
said part of college tuition should be tax deductible. We required that 
the first $3,000 be deductible for a family making up to $160,000 a 
year. This will raise that. It goes up to $4,000 in the next fiscal 
year under the previous law, and then it expires in 2006. This law 
would make it permanent and raise the amount to $8,000 initially, next 
year, and then $12,000 in future years.
  It is very simple. It pays for itself, by the way, by reducing the 
top rate not by three points but by one point. The choice is simple. 
Middle-class people have an awfully difficult time paying for college. 
If you are rich, you can afford it. If you are poor, we help you, and 
we should. But the middle class gets stuck. Families are up late at 
night worrying about how they are going to pay the tuition bill.
  I ask my colleagues, which do they choose? Bring the top rate down 
but not as quickly and help middle-class families with the second 
greatest expense they face other than their home, or bring the rate 
down quickly? It is a simple choice. I hope the body will vote for the 
middle-class parents who are stuck with these huge tuition bills.
  Mr. KYL. Mr. President, we added the tuition provision in the bill 2 
years ago, and it is obviously supported by a broad number of people in 
the body. The problem is that this addition is way too expensive and 
comes out of the top rate reduction from the bill that is on the floor, 
the acceleration of the marginal income tax rate provision of the bill.
  Obviously, we have to oppose this particular amendment. This is a 
matter that could be dealt with in a different way but not by paying 
for it in the manner it is paid for. It is not germane. Therefore, I 
raise a point of order under 305(b)(2) of the Congressional Budget Act 
of 1974.
  Mr. SCHUMER. Mr. President, I ask that the point of order be waived, 
and I ask for the yeas and nays.
  The PRESIDING OFFICER. Is there a sufficient second?
  There is a sufficient second.
  The question is on agreeing to the motion.
  The clerk will call the roll.
  The legislative clerk called the roll.
  The PRESIDING OFFICER. Are there any other Senators in the Chamber 
desiring to vote?
  The yeas and nays resulted--yeas 49, nays 51, as follows:

                      [Rollcall Vote No. 164 Leg.]

                                YEAS--49

     Akaka
     Baucus
     Bayh
     Biden
     Bingaman
     Boxer
     Breaux
     Byrd
     Cantwell
     Carper
     Clinton
     Collins
     Conrad
     Corzine
     Daschle
     Dayton
     Dodd
     Dorgan
     Durbin
     Edwards
     Feingold
     Feinstein
     Graham (FL)
     Harkin
     Hollings
     Inouye
     Jeffords
     Johnson
     Kennedy
     Kerry
     Kohl
     Landrieu
     Lautenberg
     Leahy
     Levin
     Lieberman
     Lincoln
     Mikulski
     Murray
     Nelson (FL)
     Nelson (NE)
     Pryor
     Reed
     Reid
     Rockefeller
     Sarbanes
     Schumer
     Stabenow
     Wyden

                                NAYS--51

     Alexander
     Allard
     Allen
     Bennett
     Bond
     Brownback
     Bunning
     Burns
     Campbell
     Chafee
     Chambliss
     Cochran
     Coleman
     Cornyn
     Craig
     Crapo
     DeWine
     Dole
     Domenici
     Ensign
     Enzi
     Fitzgerald
     Frist
     Graham (SC)
     Grassley
     Gregg
     Hagel
     Hatch
     Hutchison
     Inhofe
     Kyl
     Lott
     Lugar
     McCain
     McConnell
     Miller
     Murkowski
     Nickles
     Roberts
     Santorum
     Sessions
     Shelby
     Smith
     Snowe
     Specter
     Stevens
     Sununu
     Talent
     Thomas
     Voinovich
     Warner
  The PRESIDING OFFICER. On this vote, the yeas are 49, the yeas are 
51. Three-fifths of the Senators duly chosen and sworn not having voted 
in the affirmative, the motion is rejected. The point of order is 
sustained, and the amendment falls.
  Mr. BAUCUS. I move to reconsider the vote.
  Mr. REID. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.


                     Amendment No. 622, As Modified

  The PRESIDING OFFICER. The next amendment is the Ensign amendment No. 
622.
  The Senator from Nevada.
  Mr. ENSIGN. Mr. President, I have a technical modification to my 
amendment at the desk, and I ask unanimous consent that my amendment be 
so modified.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  The amendment, as modified, is as follows:
       On page 281, between lines 2 and 3, insert the following:

     SEC. ____. TOLL TAX ON EXCESS QUALIFIED FOREIGN DISTRIBUTION 
                   AMOUNT.

       (a) In General.--Subpart F of part III of subchapter N of 
     chapter 1 is amended by adding at the end the following new 
     section:

     ``SEC. 965. TOLL TAX IMPOSED ON EXCESS QUALIFIED FOREIGN 
                   DISTRIBUTION AMOUNT.

       ``(a) Toll Tax Imposed on Excess Qualified Foreign 
     Distribution Amount.--If a corporation elects the application 
     of this section, a tax shall be imposed on the taxpayer in an 
     amount equal to 5.25 percent of--
       ``(1) the taxpayer's excess qualified foreign distribution 
     amount, and
       ``(2) the amount determined under section 78 which is 
     attributable to such excess qualified foreign distribution 
     amount.

     Such tax shall be imposed in lieu of the tax imposed under 
     section 11 or 55 on the

[[Page S6427]]

     amounts described in paragraphs (1) and (2) for such taxable 
     year.
       ``(b) Excess Qualified Foreign Distribution Amount.--For 
     purposes of this section--
       ``(1) In general.--The term `excess qualified foreign 
     distribution amount' means the excess (if any) of--
       ``(A) dividends received by the taxpayer during the taxable 
     year which are--
       ``(i) from 1 or more corporations which are controlled 
     foreign corporations in which the taxpayer is a United States 
     shareholder on the date such dividends are paid, and
       ``(ii) described in a domestic reinvestment plan approved 
     by the taxpayer's president, chief executive officer, or 
     comparable official before the payment of such dividends and 
     subsequently approved by the taxpayer's board of directors, 
     management committee, executive committee, or similar body, 
     which plan shall provide for the reinvestment of such 
     dividends in the United States, including as a source for the 
     funding of worker hiring and training; infrastructure; 
     research and development; capital investments; or the 
     financial stabilization of the corporation for the purposes 
     of job retention or creation, over
       ``(B) the base dividend amount.
       ``(2) Base dividend amount.--The term `base dividend 
     amount' means an amount designated under subsection (c)(7), 
     but not less than the average amount of dividends received 
     during the fixed base period from 1 or more corporations 
     which are controlled foreign corporations in which the 
     taxpayer is a United States shareholder on the date such 
     dividends are paid.
       ``(3) Fixed base period.--
       ``(A) In general.--The term `fixed base period' means each 
     of 3 taxable years which are among the 5 most recent taxable 
     years of the taxpayer ending on or before December 31, 2002, 
     determined by disregarding--
       ``(i) the 1 taxable year for which the taxpayer had the 
     highest amount of dividends from 1 or more corporations which 
     are controlled foreign corporations relative to the other 4 
     taxable years, and
       ``(ii) the 1 taxable year for which the taxpayer had the 
     lowest amount of dividends from such corporations relative to 
     the other 4 taxable years.
       ``(B) Shorter period.--If the taxpayer has fewer than 5 
     taxable years ending on or before December 31, 2002, then in 
     lieu of applying subparagraph (A), the fixed base period 
     shall mean such shorter period representing all of the 
     taxable years of the taxpayer ending on or before December 
     31, 2002.
       ``(c) Definitions and Special Rules.--For purposes of this 
     section--
       ``(1) Dividends.--The term `dividend' means a dividend as 
     defined in section 316, except that the term shall also 
     include amounts described in section 951(a)(1)(B), and shall 
     exclude amounts described in sections 78 and 959.
       ``(2) Controlled foreign corporations and united states 
     shareholders.--The term `controlled foreign corporation' 
     shall have the same meaning as under section 957(a) and the 
     term `United States shareholder' shall have the same meaning 
     as under section 951(b).
       ``(3) Foreign tax credits.--The amount of any income, war, 
     profits, or excess profit taxes paid (or deemed paid under 
     sections 902 and 960) or accrued by the taxpayer with respect 
     to the excess qualified foreign distribution amount for which 
     a credit would be allowable under section 901 in the absence 
     of this section, shall be reduced by 85 percent.
       ``(4) Foreign tax credit limitation.--For all purposes of 
     section 904, there shall be disregarded 85 percent of--
       ``(A) the excess qualified foreign distribution amount,
       ``(B) the amount determined under section 78 which is 
     attributable to such excess qualified foreign distribution 
     amount, and
       ``(C) the amounts (including assets, gross income, and 
     other relevant bases of apportionment) which are attributable 
     to the excess qualified foreign distribution amount which 
     would, determined without regard to this section, be used to 
     apportion the expenses, losses, and deductions of the 
     taxpayer under section 861 and 864 in determining its taxable 
     income from sources without the United States.

     For purposes of applying subparagraph (C), the principles of 
     section 864(e)(3)(A) shall apply.
       ``(5) Treatment of acquisitions and dispositions.--Rules 
     similar to the rules of section 41(f)(3) shall apply in the 
     case of acquisitions or dispositions of controlled foreign 
     corporations occurring on or after the first day of the 
     earliest taxable year taken into account in determining the 
     fixed base period.
       ``(6) Treatment of consolidated groups.--Members of an 
     affiliated group of corporations filing a consolidated return 
     under section 1501 shall be treated as a single taxpayer in 
     applying the rules of this section.
       ``(7) Designation of dividends.--Subject to subsection 
     (b)(2), the taxpayer shall designate the particular dividends 
     received during the taxable year from 1 or more corporations 
     which are controlled foreign corporations in which it is a 
     United States shareholder which are dividends excluded from 
     the excess qualified foreign distribution amount. The total 
     amount of such designated dividends shall equal the base 
     dividend amount.
       ``(8) Treatment of expenses, losses, and deductions.--Any 
     expenses, losses, or deductions of the taxpayer allowable 
     under subchapter B--
       ``(A) shall not be applied to reduce the amounts described 
     in subsection (a)(1), and
       ``(B) shall be applied to reduce other income of the 
     taxpayer (determined without regard to the amounts described 
     in subsection (a)(1)).
       ``(d) Election.--
       ``(1) In general.--An election under this section shall be 
     made on the taxpayer's timely filed income tax return for the 
     taxable year (determined by taking extensions into account) 
     ending 120 days or more after the date of the enactment of 
     this section, and, once made, may be revoked only with the 
     consent of the Secretary.
       ``(2) All controlled foreign corporations.--The election 
     shall apply to all corporations which are controlled foreign 
     corporations in which the taxpayer is a United States 
     shareholder during the taxable year.
       ``(3) Consolidated groups.--If a taxpayer is a member of an 
     affiliated group of corporations filing a consolidated return 
     under section 1501 for the taxable year, an election under 
     this section shall be made by the common parent of the 
     affiliated group which includes the taxpayer, and shall apply 
     to all members of the affiliated group.
       ``(e) Regulations.--The Secretary shall prescribe such 
     regulations as may be necessary and appropriate to carry out 
     the purposes of this section, including regulations under 
     section 55 and regulations addressing corporations which, 
     during the fixed base period or thereafter, join or leave an 
     affiliated group of corporations filing a consolidated 
     return.''.
       (b) Conforming Amendment.--The table of sections for 
     subpart F of part III of subchapter N of chapter 1 is amended 
     by adding at the end the following new item:

``Sec. 965. Toll tax imposed on excess qualified foreign distribution 
              amount.''.

       (c) Effective Date.--Except as otherwise provided, the 
     amendments made by this section, other than the amendment 
     made by subsection (d), shall apply only to the first taxable 
     year of the electing taxpayer ending 120 days or more after 
     the date of the enactment of this Act.
       (d) Termination of Rehabilitation Credit for Buildings 
     Other Than Certified Historic Structures.--Section 47 
     (relating to rehabilitation credit) is amended by adding at 
     the end the following new subsection:
       ``(e) Termination of Credit for Buildings Other Than 
     Certified Historic Structures.--No credit shall be allowed 
     under subsection (a)(1) with respect to expenditures incurred 
     after December 31, 2003.''.

  Mr. ENSIGN. Mr. President, the modification says the offset included 
in the amendment repeals the tax credit for refurbishing of nonhistoric 
structures only, not historic structures, with which people had 
concerns.
  If you believe the American economy needs a shot in the arm right 
now, then you should vote for this amendment. Our amendment allows 
companies that have made money overseas to bring it back right now. 
They are taxed at 35 percent. When faced with a choice of whether they 
keep it overseas or bring it back, they keep it overseas. We are going 
to allow a 1-year exemption. The tax will be lowered from 35 percent to 
5.25 percent. They have 1 year to invest the money to create jobs in 
this country. As with Senator Boxer's very fine amendment in our bill, 
it cannot go for executive pay. The money has to be invested in America 
to create jobs.
  I believe this will be a tremendous stimulus to our economy, and I 
urge its adoption.
  I yield 10 seconds to my friend from California.
  The PRESIDING OFFICER. The Senator's time has expired.
  Mrs. BOXER. I ask for 10 seconds.
  The PRESIDING OFFICER. Without objection, it is so ordered.
  Mrs. BOXER. Mr. President, I hope my colleagues will vote for this 
one-time infusion of private sector dollars to create jobs and 
encourage business investment in plants and equipment. This infusion 
will happen immediately. I think it is what we need to fight for 
because our people are hurting out there.
  I thank the Chair.
  The PRESIDING OFFICER. The Senator's time has expired.


                        USE OF FUNDS REPATRIATED

  Mrs. BOXER. Mr. President, I rise to thank Senator Ensign for his 
leadership on the Invest in the USA Act. As we said earlier, this 
infusion of cash will provide an immediate and much needed boost to the 
economy. Over the next year, it is estimated that this legislation, 
which is included in this bill as an amendment, will bring $140 billion 
in foreign earnings back into the United States.
  As my friend is aware, under our amendment, which is the Invest in 
the USA Act of 2003, these funds are to be used as a source for worker 
hiring and training; infrastructure; research, and

[[Page S6428]]

development; capital investments; or the financial stabilization of the 
corporation for the purposes of job retention or creation. Any attempt 
to use these funds to increase executive pay would be a violation of 
the intent of this legislation.
  Mr. ENSIGN. Mr. President, the Senator from California is absolutely 
correct. These funds are meant to stimulate the economy. I pledge to 
work with Senator Boxer and our colleagues in conference to ensure that 
these funds may not be used for executive pay.
  The Senator from Louisiana.
  Mr. BREAUX. Mr. President, I rise in opposition to the Senator's 
amendment. This amendment was offered in the Senate Finance Committee. 
Republicans and Democrats joined to defeat this amendment.
  There is no question that the international tax laws need to be 
assessed. We have agreed to do that in the Finance Committee. The 
Republican leadership said they would look at all international tax 
laws and consequences.
  This is a retroactive tax break. This bill is supposed to be 
stimulative in the future, not in the past. This amendment will reward 
companies for what they did a long time ago when we ought to be looking 
at the bill in a prospective nature.
  A retroactive tax cut is not what we need. We ought to examine 
international tax laws. We have an agreement to do it in a bipartisan 
fashion. This does not belong in the bill at this time.
  I make a point of order that the amendment is nongermane under 
section 305(b)(2) of the Congressional Budget Act of 1974.
  Mr. ENSIGN. Mr. President, I move to waive that section of the 
Congressional Budget Act. Also, I note that many of the people who 
voted against this amendment in the Finance Committee will be voting 
for it today.
  Pursuant to section 904 of the Congressional Budget Act of 1974, I 
move to waive the applicable sections of that act for the consideration 
of this amendment, and I ask for the yeas and nays.
  The PRESIDING OFFICER. Is there a sufficient second?
  There appears to be a sufficient second.
  The question is on agreeing to the motion. The clerk will call the 
roll.
  The bill clerk called the roll.
  The yeas and nays resulted--yeas 75, nays 25, as follows:

                      [Rollcall Vote No. 165 Leg.]

                                YEAS--75

     Akaka
     Alexander
     Allard
     Allen
     Baucus
     Bayh
     Bennett
     Bond
     Boxer
     Brownback
     Bunning
     Burns
     Campbell
     Cantwell
     Carper
     Chafee
     Chambliss
     Cochran
     Coleman
     Collins
     Cornyn
     Corzine
     Craig
     Crapo
     DeWine
     Dodd
     Dole
     Domenici
     Ensign
     Enzi
     Feinstein
     Fitzgerald
     Frist
     Graham (SC)
     Grassley
     Gregg
     Hagel
     Hatch
     Hollings
     Hutchison
     Inhofe
     Jeffords
     Kyl
     Landrieu
     Lautenberg
     Leahy
     Lieberman
     Lincoln
     Lott
     Lugar
     McCain
     McConnell
     Miller
     Murkowski
     Murray
     Nelson (NE)
     Nickles
     Pryor
     Reid
     Roberts
     Santorum
     Schumer
     Sessions
     Shelby
     Smith
     Snowe
     Specter
     Stabenow
     Stevens
     Sununu
     Talent
     Thomas
     Voinovich
     Warner
     Wyden

                                NAYS--25

     Biden
     Bingaman
     Breaux
     Byrd
     Clinton
     Conrad
     Daschle
     Dayton
     Dorgan
     Durbin
     Edwards
     Feingold
     Graham (FL)
     Harkin
     Inouye
     Johnson
     Kennedy
     Kerry
     Kohl
     Levin
     Mikulski
     Nelson (FL)
     Reed
     Rockefeller
     Sarbanes
  The PRESIDING OFFICER. On this question, the yeas are 75, the nays 
are 25. Three-fifths of the Senators duly chosen and sworn having voted 
in the affirmative, the motion is agreed to.
  The question now is on the amendment.
  Mr. GRASSLEY. I urge we now adopt the amendment by voice vote.
  The PRESIDING OFFICER. The question is on agreeing to the amendment.
  The amendment (No. 622), as modified, was agreed to.
  Mr. GRASSLEY. I move to reconsider the vote.
  Mr. BAUCUS. I move to lay that motion on the table.
  The motion to lay on the table was agreed to.


                           Amendment No. 611

  Mr. BAUCUS. Mr. President, my understanding is the next amendment is 
the amendment offered by the Senator from North Dakota, Mr. Conrad.
  The PRESIDING OFFICER. The Senator is correct.
  The Senator from North Dakota.
  Mr. CONRAD. Mr. President, this bill increases the child tax credit 
from $600 to $1,000 effective back at the beginning of this year.
  My amendment simply takes it back another year to the beginning of 
2002. This is an efficient way of targeting money to those who are most 
likely to use it to give stimulus to the economy.
  I offset the additional cost by delaying part of the final reduction 
in the top marginal rate for a year and a half. This asks the top 1 
percent, actually less than 1 percent of the taxpayers, to take part of 
their reduction somewhat later. It gives a benefit to 27 million 
American families by asking less than a million American families to 
wait for the final part of their additional tax reduction for a year 
and a half.