Middle-Class Alternative Minimum Tax Relief Act of 2004-Part II
(b) EFFECTIVE DATE.-The amendment made by this section shall apply to communications made on or after the date of the enactment of this Act.
SEC. 207. DISCLOSURE OF REPORTABLE TRANSACTIONS.
(a) IN GENERAL.-Section 6111 (relating to registration of tax shelters) is amended to read as follows:
"SEC. 6111. DISCLOSURE OF REPORTABLE TRANSACTIONS.
"(a) IN GENERAL.-Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth-
"(1) information identifying and describing the transaction,
"(2) information describing any potential tax benefits expected to result from the transaction, and
"(3) such other information as the Secretary may prescribe.
Such return shall be filed not later than the date specified by the Secretary.
"(b) DEFINITIONS.-For purposes of this section-
"(1) MATERIAL ADVISOR.-
"(A) IN GENERAL.-The term 'material advisor' means any person-
"(i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, or carrying out any reportable transaction, and
"(ii) who directly or indirectly derives gross income in excess of the threshold amount for such aid, assistance, or advice.
"(B) THRESHOLD AMOUNT.-For purposes of subparagraph (A), the threshold amount is-
"(i) $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and
"(ii) $250,000 in any other case.
"(2) REPORTABLE TRANSACTION.-The term 'reportable transaction' has the meaning given to such term by section 6707A(c).
"(c) REGULATIONS.-The Secretary may prescribe regulations which provide-
"(1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements,
"(2) exemptions from the requirements of this section, and
"(3) such rules as may be necessary or appropriate to carry out the purposes of this section.".
(b) CONFORMING AMENDMENTS.-
(1) The item relating to section 6111 in the table of sections for subchapter B of chapter 61 is amended to read as follows:
"Sec. 6111. Disclosure of reportable transactions.".
(2)(A) So much of section 6112 as precedes subsection (c) thereof is amended to read as follows:
"SEC. 6112. MATERIAL ADVISORS OF REPORTABLE TRANSACTIONS MUST KEEP LISTS OF ADVISEES.
"(a) IN GENERAL.-Each material advisor (as defined in section 6111) with respect to any reportable transaction (as defined in section 6707A(c)) shall maintain, in such manner as the Secretary may by regulations prescribe, a list-
"(1) identifying each person with respect to whom such advisor acted as such a material advisor with respect to such transaction, and
"(2) containing such other information as the Secretary may by regulations require.
This section shall apply without regard to whether a material advisor is required to file a return under section 6111 with respect to such transaction.".
(B) Section 6112 is amended by redesignating subsection (c) as subsection (b).
(C) Section 6112(b), as redesignated by subparagraph (B), is amended-
(i) by inserting "written" before "request" in paragraph (1)(A), and
(ii) by striking "shall prescribe" in paragraph (2) and inserting "may prescribe".
(D) The item relating to section 6112 in the table of sections for subchapter B of chapter 61 is amended to read as follows:
"Sec. 6112. Material advisors of reportable transactions must keep lists of advisees.".
(3)(A) The heading for section 6708 is amended to read as follows:
"SEC. 6708. FAILURE TO MAINTAIN LISTS OF ADVISEES WITH RESPECT TO REPORTABLE
TRANSACTIONS.".
(B) The item relating to section 6708 in the table of sections for part I of subchapter B of chapter 68 is amended to read as follows:
"Sec. 6708. Failure to maintain lists of advisees with respect to reportable transactions.".
(C) REQUIRED DISCLOSURE NOT SUBJECT TO CLAIM OF CONFIDENTIALITY.-Subparagraph (A) of section 6112(b)(1), as redesignated by subsection (b)(2)(B), is amended by adding at the end the following new flush sentence:
"For purposes of this section, the identity of any person on such list shall not be privileged.".
(d) EFFECTIVE DATE.-The amendments made by this section shall apply to transactions with respect to which material aid, assistance, or advice referred to in section 6111(b)(1)(A)(i) of the Internal Revenue Code of 1986 (as added by this section) is provided after the date of the enactment of this Act.
SEC. 208. MODIFICATIONS TO PENALTY FOR FAILURE TO REGISTER TAX SHELTERS.
(a) IN GENERAL.-Section 6707 (relating to failure to furnish information regarding tax shelters) is amended to read as follows:
"SEC. 6707. FAILURE TO FURNISH INFORMATION REGARDING REPORTABLE TRANSACTIONS.
"(a) IN GENERAL.-If a person who is required to file a return under section 6111(a) with respect to any reportable transaction-
"(1) fails to file such return on or before the date prescribed therefor, or
"(2) files false or incomplete information with the Secretary with respect to such transaction, such person shall pay a penalty with respect to such return in the amount determined under subsection (b).
"(b) AMOUNT OF PENALTY.-
"(1) IN GENERAL.-Except as provided in paragraph (2), the penalty imposed under subsection (a) with respect to any failure shall be $50,000.
"(2) LISTED TRANSACTIONS.-The penalty imposed under subsection (a) with respect to any listed transaction shall be an amount equal to the greater of-
"(A) $200,000, or
"(B) 50 percent of the gross income derived by such person with respect to aid, assistance, or advice which is provided with respect to the listed transaction before the date the return including the transaction is filed under section 6111.
Subparagraph (B) shall be applied by substituting '75 percent' for '50 percent' in the case of an intentional failure or act described in subsection (a).
"(c) CERTAIN RULES TO APPLY.-The provisions of section 6707A(d) shall apply to any penalty imposed under this section.
"(d) REPORTABLE AND LISTED TRANSACTIONS.-The terms 'reportable transaction' and 'listed transaction' have the respective meanings given to such terms by section 6707A©.".
(b) CLERICAL AMENDMENT.-The item relating to section 6707 in the table of sections for part I of subchapter B of chapter 68 is amended by striking "tax shelters" and inserting "reportable transactions".
(c) EFFECTIVE DATE.-The amendments made by this section shall apply to returns the due date for which is after the date of the enactment of this Act.
SEC. 209. MODIFICATION OF PENALTY FOR FAILURE TO MAINTAIN LISTS OF INVESTORS.
(a) IN GENERAL.-Subsection (a) of section 6708 is amended to read as follows:
"(a) IMPOSITION OF PENALTY.-
"(1) IN GENERAL.-If any person who is required to maintain a list under section 6112(a) fails to make such list available upon written request to the Secretary in accordance with section 6112(b)(1)(A) within 20 business days after the date of the Secretary's request, such person shall pay a penalty of $10,000 for each day of such failure after such 20th day.
"(2) REASONABLE CAUSE EXCEPTION.-No penalty shall be imposed by paragraph (1) with respect to the failure on any day if such failure is due to reasonable cause.".
(b) EFFECTIVE DATE.-The amendment made by this section shall apply to requests made after the date of the enactment of this Act.
SEC. 210. PENALTY ON PROMOTERS OF TAX SHELTERS.
(a) PENALTY ON PROMOTING ABUSIVE TAX SHELTERS.-Section 6700(a) is amended by adding at the end the following new sentence: "Notwithstanding the first sentence, if an activity with respect to which a penalty imposed under this subsection involves a statement described in paragraph (2)(A), the amount of the penalty shall be equal to 50 percent of the gross income derived (or to be derived) from such activity by the person on which the penalty is imposed.".
(b) EFFECTIVE DATE.-The amendment made by this section shall apply to activities after the date of the enactment of this Act.
SEC. 211. INCREASES IN PENALTIES FOR AIDING AND ABETTING UNDERSTATEMENTS.
(a) IN GENERAL.-Section 6701(b) is amended to read as follows:
"(b) AMOUNT OF PENALTY.-
"(1) IN GENERAL.-The amount of the penalty imposed by subsection (a) shall be the greater of-
"(A) $2,000, or
"(B) 50 percent of the gross income derived (or to be derived) from the activity giving rise to the penalty.
"(2) CORPORATIONS.-If the return, affidavit, claim, or other document relates to the tax liability of a corporation, paragraph (1)(A) shall be applied by substituting '$20,000' for '$2,000'."
(b) EFFECTIVE DATE.-The amendment made by this section shall apply to activities after the date of the enactment of this Act.
Subtitle B-Enron-Related Tax Shelter Provisions
SEC. 221. LIMITATION ON TRANSFER OR IMPORTATION OF BUILT-IN LOSSES.
(a) IN GENERAL.-Section 362 (relating to basis to corporations) is amended by adding at the end the following new subsection:
"(e) LIMITATIONS ON BUILT-IN LOSSES.-
"(1) LIMITATION ON IMPORTATION OF BUILT-IN LOSSES.-
"(A) IN GENERAL.-If in any transaction described in subsection (a) or (b) there would (but for this subsection) be an importation of a net built-in loss, the basis of each property described in subparagraph (B) which is acquired in such transaction shall (notwithstanding subsections (a) and (b)) be its fair market value immediately after such transaction.
"(B) PROPERTY DESCRIBED.-For purposes of subparagraph (A), property is described in this subparagraph if-
"(i) gain or loss with respect to such property is not subject to tax under this subtitle in the hands of the transferor immediately before the transfer, and
"(ii) gain or loss with respect to such property is subject to such tax in the hands of the transferee immediately after such transfer. In any case in which the transferor is a partnership, the preceding sentence shall be applied by treating each partner in such partnership as holding such partner's proportionate share of the property of such partnership.
"(C) IMPORTATION OF NET BUILT-IN LOSS.-For purposes of subparagraph (A), there is an importation of a net built-in loss in a transaction if the transferee's aggregate adjusted bases of property described in subparagraph (B) which is transferred in such transaction would (but for this paragraph) exceed the fair market value of such property immediately after such transaction.
"(2) LIMITATION ON TRANSFER OF BUILT-IN LOSSES IN SECTION 351 TRANSACTIONS.-
"(A) IN GENERAL.-If-
"(i) property is transferred by a transferor in any transaction which is described in subsection (a) and which is not described in paragraph (1) of this subsection, and
"(ii) the transferee's aggregate adjusted bases of such property so transferred would (but for this paragraph) exceed the fair market value of such property immediately after such transaction, then, notwithstanding subsection (a), the transferee's aggregate adjusted bases of the property so transferred shall not exceed the fair market value of such property immediately after such transaction.
"(B) ALLOCATION OF BASIS REDUCTION.-The aggregate reduction in basis by reason of subparagraph (A) shall be allocated among the property so transferred in proportion to their respective built-in losses immediately before the transaction.
"(C) EXCEPTION FOR TRANSFERS WITHIN AFFILIATED GROUP.-Subparagraph (A) shall not apply to any transaction if the transferor owns stock in the transferee meeting the requirements of section 1504(a)(2). In the case of property to which subparagraph (A) does not apply by reason of the preceding sentence, the transferor's basis in the stock received for such property shall not exceed its fair market value immediately after the transfer.".
(b) COMPARABLE TREATMENT WHERE LIQUIDATION.-Paragraph (1) of section 334(b) (relating to liquidation of subsidiary) is amended to read as follows:
"(1) IN GENERAL.-If property is received by a corporate distributee in a distribution in a complete liquidation to which section 332 applies (or in a transfer described in section 337(b)(1)), the basis of such property in the hands of such distributee shall be the same as it would be in the hands of the transferor; except that the basis of such property in the hands of such distributee shall be the fair market value of the property at the time of the distribution-
"(A) in any case in which gain or loss is recognized by the liquidating corporation with respect to such property, or
"(B) in any case in which the liquidating corporation is a foreign corporation, the corporate distributee is a domestic corporation, and the corporate distributee's aggregate adjusted bases of property described in section 362(e)(1)(B) which is distributed in such liquidation would (but for this subparagraph) exceed the fair market value of such property immediately after such liquidation.".
(C) EFFECTIVE DATES.-
(1) IN GENERAL.-The amendment made by subsection (a) shall apply to transactions after the date of the enactment of this Act.
(2) LIQUIDATIONS.-The amendment made by subsection (b) shall apply to liquidations after the date of the enactment of this Act.
SEC. 222. NO REDUCTION OF BASIS UNDER SECTION 734 IN STOCK HELD BY PARTNERSHIP IN CORPORATE PARTNER.
(a) IN GENERAL.-Section 755 is amended by adding at the end the following new subsection:
"(C) NO ALLOCATION OF BASIS DECREASE TO STOCK OF CORPORATE PARTNER.-In making an allocation under subsection (a) of any decrease in the adjusted basis of partnership property under section 734(b)--
"(1) no allocation may be made to stock in a corporation (or any person which is related (within the meaning of section 267(b) or 707(b)(1)) to such corporation) which is a partner in the partnership, and
"(2) any amount not allocable to stock by reason of paragraph (1) shall be allocated under subsection (a) to other partnership property in such manner as the Secretary may prescribe.
Gain shall be recognized to the partnership to the extent that the amount required to be allocated under paragraph (2) to other partnership property exceeds the aggregate adjusted basis of such other property immediately before the allocation required by paragraph (2).".
(b) EFFECTIVE DATE.-The amendment made by this section shall apply to distributions after the date of the enactment of this Act.
SEC. 223. EXPANDED DISALLOWANCE OF DEDUCTION FOR INTEREST ON CONVERTIBLE DEBT.
(a) IN GENERAL.-Paragraph (2) of section 163(l) is amended by inserting "or equity held by the issuer (or any related party) in any other person" after "or a related party".
(b) CAPITALIZATION ALLOWED WITH RESPECT TO EQUITY OF PERSONS OTHER THAN ISSUER AND RELATED PARTIES.-Section 163(l) is amended by redesignating paragraphs (4) and (5) as paragraphs (5) and (6) and by inserting after paragraph (3) the following new paragraph:
"(4) CAPITALIZATION ALLOWED WITH RESPECT TO EQUITY OF PERSONS OTHER THAN ISSUER AND RELATED PARTIES.-If the disqualified debt instrument of a corporation is payable in equity held by the issuer (or any related party) in any other person (other than a related party), the basis of such equity shall be increased by the amount not allowed as a deduction by reason of paragraph (1) with respect to the instrument.".
(c) EXCEPTION FOR CERTAIN INSTRUMENTS ISSUED BY DEALERS IN SECURITIES.-Section 163(l), as amended by subsection (b), is amended by redesignating paragraphs (5) and (6) as paragraphs (6) and (7) and by inserting after paragraph (4) the following new paragraph:
"(5) EXCEPTION FOR CERTAIN INSTRUMENTS ISSUED BY DEALERS IN SECURITIES.-For purposes of this subsection, the term 'disqualified debt instrument' does not include indebtedness issued by a dealer in securities (or a related party) which is payable in, or by reference to, equity (other than equity of the issuer or a related party) held by such dealer in its capacity as a dealer in securities. For purposes of this paragraph, the term 'dealer in securities' has the meaning given such term by section 475.".
(C) CONFORMING AMENDMENTS.-Paragraph (3) of section 163(l) is amended-
(1) by striking "or a related party" in the material preceding subparagraph (A) and inserting "or any other person", and
(2) by striking "or interest" each place it appears.
(d) EFFECTIVE DATE.-The amendments made by this section shall apply to debt instruments issued after the date of the enactment of this Act.
SEC. 224. EXPANDED AUTHORITY TO DISALLOW TAX BENEFITS UNDER SECTION 269.
(a) IN GENERAL.-Subsection (a) of section 269 (relating to acquisitions made to evade or avoid income tax) is amended to read as follows:
"(a) IN GENERAL.-If-
"(1)(A) any person or persons acquire, directly or indirectly, control of a corporation, or
"(B) any corporation acquires, directly or indirectly, property of another corporation and the basis of such property, in the hands of the acquiring corporation, is determined by reference to the basis in the hands of the transferor corporation, and
"(2) the principal purpose for which such acquisition was made is evasion or avoidance of Federal income tax,
then the Secretary may disallow such deduction, credit, or other allowance. For purposes of paragraph (1)(A), control means the ownership of stock possessing at least 50 percent of the total combined voting power of all classes of stock entitled to vote or at least 50 percent of the total value of all shares of all classes of stock of the corporation.".
(b) EFFECTIVE DATE.-The amendment made by this section shall apply to stock and property acquired after the date of the enactment of this Act.
SEC. 225. MODIFICATION OF INTERACTION BETWEEN SUBPART F AND PASSIVE FOREIGN INVESTMENT COMPANY RULES.
(a) LIMITATION ON EXCEPTION FROM PFIC RULES FOR UNITED STATES SHAREHOLDERS OF CONTROLLED FOREIGN CORPORATIONS.-Paragraph (2) of section 1297(e) (relating to passive foreign investment company) is amended by adding at the end the following flush sentence:
"Such term shall not include any period if the earning of subpart F income by such corporation during such period would result in only a remote likelihood of an inclusion in gross income under section 951(a)(1)(A)(i).".
(b) EFFECTIVE DATE.-The amendment made by this section shall apply to taxable years of controlled foreign corporations beginning after the date of the enactment of this Act, and to taxable years of United States shareholders with or within which such taxable years of controlled foreign corporations end.
Amend the title so as to read: "A bill to provide for significant temporary relief from the alternative minimum tax and for a framework for a total reform of the alternative minimum tax.".
The SPEAKER pro tempore. Pursuant to House Resolution 619, the gentleman from Massachusetts (Mr. Neal) and a
Member opposed each will control 30 minutes.
The Chair recognizes the gentleman from Massachusetts (Mr. Neal).
Mr. NEAL of Massachusetts. Mr. Speaker, I yield myself such time as I may consume.
Mr. Speaker, the gentleman from Pennsylvania (Mr. English) is a good friend of mine. He is a member of the Committee on Ways and Means, and he really is a very decent guy, but he is really wrong in what he said earlier. To suggest that these tax cuts and this mania that we have witnessed now for tax cuts for the last 3 years has not had a substantial impact on the size of Federal deficit is to really put our heads in the sand. Let me remind Members of this House we are now fighting two wars with three tax cuts, and the mathematics are there for everybody to see.
An announcement this morning by Secretary Rumsfeld that 135,000 troops now are going to stay in Iraq for an extended tour of duty, well into the year 2005, and let us be honest with the American people, they are there for 2006 and 2007 and maybe through 2010. That is the reality that we confront. We are going to a $500 billion deficit this year after coming out of the Clinton years when we not only balanced the budget but projected surpluses for years to come.
I want to remind "all is well" that this proposal from the gentleman from Connecticut today has never even been vetted in the Committee on Ways and Means. Maybe I am mistaken, but I believe after having served in that committee for 12 years that the Committee on Ways and Means has a responsibility for tax revenue issues. So this is being brought to us by an individual who is not on the committee and indeed it has not been aired in the committee. There has been no public hearing on the proposal that we are going to vote on in an hour. So we find ourselves having this debate about alternative minimum tax.
And I want to say something. I think my hands are clean on this issue. I have heard them say that the Democrats put this in place in the reform of the Tax Act of 1986. That may well be the case, but let me tell the Members something. I am in favor of repealing it. I think there ought to be some intellectual honesty as it relates to AMT. It has outlived its usefulness. It has outlived its purpose, and now middle-income taxpayers are now being asked to carry its burden.
We have a game of kind of hocus-pocus here. The Republicans stand up and say, well, we are going to give AMT relief. They are not giving AMT to the number of people they could and should be giving AMT relief to, largely because it does not square with the tax cuts that the administration has proposed, and once again Republicans in this House go along with very few questions asked about any issue. The administration says it is so, they just go along with it, no questions asked, even if the evidence a few weeks, months, years later turns a contrary conclusion.
Let me speak specifically, if I can, to this issue as it relates to this debate today. The alternative minimum tax was originally designed to make sure that everyone paid their fair share. Who among us can argue with that? The second notion of the proposal that we have offered today is that we want to grant some relief to the burden that the Republican Party has put on middle-income tax earners. If they, in fact, take advantage of certain credits in the Tax Code and they have a lot of children, they are penalized by their proposal. Do the Members know why? It is very simple, because the philosophy of the majority in of this body is that the only people in America that ought to have tax relief are the wealthy.
And to the credit of the wealthy 3 years ago, they were not even asking for tax relief. They wanted to pay down the debt, and public opinion polling concludes, once again, they still think that paying down the deficits are a far better use of taxpayer money than giving tax relief to even those who might benefit most from it.
They promised that they were going to do something about tax reform as it relates to AMT. But what they did not tell them was that they are going to give them tax relief on one hand and then if they sit down to do their tax forms, they are going to take it away from them if they have four or five children. If people desire to use the HOPE credit, they are going to take it away from them. If they try to take advantage of the child credit, they are going to take it away from them. So they give it to them on one hand and they take it back on the other. So in the end, there really is no tax relief as it relates to alternative minimum tax.
I want the Members to listen to this. Half, half of the promised benefits that we voted on last week under the marriage penalty bill, we were told we were going to provide relief to those folks as well, they are taken back to the Treasury by alternative minimum tax.
I have offered time and again, Mr. Speaker, a couple of very easy proposals in this body. Let us get rid of AMT. Let us scale back the size of the tax cuts the administration offered. Let us pay down the deficit. Let us pay for these two wars. Let us fix Social Security. Let us fix Medicare, as American people clearly desire. And let us give tax relief to middle-income Americans, particularly from alternative minimum tax.
I hope in the next few minutes as we engage this debate, we will have a chance to put the magnifying glass on the proposal that is before us today. And I have got to tell the Members, as a member of the oldest committee in this House, a committee that I believe is so desirable to sit on, a committee whose history is so profound as it relates to this Republic, they did not even have enough regard for the Committee on Ways and Means to hold a hearing on this proposal in the committee. This is the introduction to their proposal today on the House floor. Nobody has seen it until about an hour and a half ago.
So let us engage this debate. Let us have an opportunity to draw some attention to what it is that they are saying but, most importantly, to what it is that they are doing.
Mr. Speaker, I reserve the balance of my time.
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Mr. NEAL of Massachusetts. Mr. Speaker, I yield myself such time as I may consume.
Mr. Speaker, anytime that we can ask those companies that have moved to Bermuda to avoid paying American taxes with 134,000 troops in Iraq to pay their share, I am happy to have my fingerprints on that issue.
Mr. Speaker, I yield 4 minutes to the distinguished gentleman from Maryland (Mr. Hoyer), the Democratic whip.
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Mr. NEAL of Massachusetts. Mr. Speaker, I yield myself such time as I may consume.
Mr. Speaker, I remind the Republican Members a year ago in the Committee on Ways and Means they had a chance to vote for my AMT bill, which would have done exactly some of the things we are proposing to do today.
Mr. Speaker, I yield 3 minutes to the gentleman from Oregon (Mr. Blumenauer).
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Mr. NEAL of Massachusetts. Mr. Speaker, I am just curious, and I would ask the gentleman from Pennsylvania (Mr. English) or perhaps the gentleman from Florida (Mr. Foley), since this was never aired in the committee, this proposal has not been brought up in front of the committee, will the author of this proposal, will he be taking his picture with the Committee on Ways and Means later on at 2 o'clock? Will we have him there for the photograph for history and posterity? I was just wondering, since we now have nonmembers of the committee bringing these proposals forward.
Mr. Speaker, I yield 3 minutes to the distinguished gentleman from Michigan (Mr. Levin).
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Mr. NEAL of Massachusetts. Mr. Speaker, I yield for the purpose of making a unanimous consent request to the gentlewoman from Texas (Ms. Jackson-Lee).
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Mr. NEAL of Massachusetts. Mr. Speaker, a quick reminder to the previous speaker. More than half of the promised benefits last week of the marriage tax penalty are taken back under alternative minimum tax.
Mr. Speaker, I yield 3 minutes to the gentleman from New York (Mr. Hinchey).
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Mr. NEAL of Massachusetts. Mr. Speaker, I yield 3 minutes to the gentleman from New York (Mr. Israel).
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Mr. NEAL of Massachusetts. Mr. Speaker, I yield myself such time as I may consume.
Mr. Speaker, I remind the gentleman you cannot fix this on a long-term basis without doing something about the tax cuts that the gentleman was heralding a couple of minutes ago.
Mr. Speaker, I yield 3 minutes to the gentleman from North Dakota (Mr. Pomeroy).
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Mr. NEAL of Massachusetts. Mr. Speaker, I yield 2 ½ minutes to the gentleman from New York (Mr. Bishop).
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Mr. NEAL of Massachusetts. Mr. Speaker, might I inquire as to how much time is left.
The SPEAKER pro tempore (Mr. Bass). The gentleman from Massachusetts (Mr. Neal) has 1 ½ minutes remaining, and the gentleman from Pennsylvania (Mr. English) has 4 ¼ minutes remaining.
Mr. NEAL of Massachusetts. Is the gentleman prepared to close?
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Mr. NEAL of Massachusetts. Mr. Speaker, I yield myself the time that is left.
Mr. Speaker, we have had this debate now in this House for a long period of time. For Members on the majority side to say, well, this was a Democratic proposal in 1986 and then to conveniently forget or suggest that during their 10 years that they have not had sufficient opportunity, working, by the way, with a willing minority to fix the issue, really does not make a great deal of sense. This issue is hanging out there. It is waiting for a solution. There ought to be an opportunity in a bipartisan manner to fix it.
I have said flatly I am in favor of repealing the alternative minimum tax. Let us get rid of it. There is a revenue gap to make up, $600 billion, that has to be found somewhere; but when we offer the suggestion, it goes nowhere, because it does not square, Mr. Speaker, with the tax cuts that the administration has offered and that the compliant Members of the majority have gone along with without ever, ever, ever asking a question.
Forbes magazine has suggested that the tax cuts that the Republican majority and the administration have offered only make the alternative minimum tax issue worse for middle-income Americans. We have heard today a suggestion that issues of war in the Middle East and in Afghanistan are irrelevant to these discussions. How are we going to pay for the troops, 134,000 that are in Iraq and 12,000 that are in Afghanistan, and support this war effort? How are we going to pay for, first, the Defense budget that goes to $421 billion at the conclusion of this session, $41 billion for homeland security? They are off by $140 billion in their prescription drug bill proposal; and the answer is, to all of this, tax cuts.
Mr. Speaker, we can fix the alternative minimum tax issue in a bipartisan manner. I am more than happy to offer my support to try to get that under way. Support the Democratic alternative today. It, in the end, is responsible tax policy, and show those people at Enron and show those people in Bermuda that they ought to pay like the rest of the American people.
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