To amend the Internal Revenue Code of 1986 to provide for the treatment of not-for-profit residual market insurance companies under the alternative minimum tax and to repeal the taxable income limitation on the recognition of built-in gain of S corporations.

Amends the Internal Revenue Code to allow an insurance company to use its alternative tax net operating loss deduction to offset 100 percent (currently, 90 percent) of alternative minimum taxable income, if such insurance company is created by a State or instrumentality thereof and is operated on a not-for-profit basis exclusively to provide coverage to individuals or businesses for high-risk needs where coverage is not otherwise available or affordable.

Repeals the limitation that prevents an S corporation (small business corporation) from being taxed on built-in gains resulting from conversion from a C corporation to the extent such gains exceed the taxable income of the S corporation.