To amend the Internal Revenue Code of 1986 to provide for the treatment of bad debt reserves of savings associations which are required to convert into banks, and for other purposes.
Thrift Charter Conversion Tax Act of 1995 - Amends the Internal Revenue Code to repeal the reserve method of accounting for determining deductions for bad debts by thrift institutions, effective for taxable years beginning after 1995. Repeals, with respect to thrift institutions to which such accounting method applied, provisions relating to: (1) the denial of a portion of certain tax credits to a thrift institution; (2) special rules regarding the foreclosure of property securing loans of a thrift institution; (3) the reduction in the dividends received reduction of a thrift institution; and (4) the ability of a thrift institution to use a net operating loss to offset its income from a residential interest in a real estate mortgage investment conduit. Provides rules to implement the change in the method of accounting required by the repeal.
Defines "applicable excess reserves." Sets forth provisions for thrifts which become small banks.
Provides for the suspension of recapture if the taxpayer meets the "residential loan requirement." Defines the term residential loan requirement. Allows in cases where the taxpayer is not a large bank, for the purposes of determining the net amounts of adjustments, that only the excess of the reserve for bad debts as of the close of the last taxable year before the disqualification year over the balance of reserves shall be taken into account. Provides for the treatment of reserves for bad debts under the elective cut-off method. Prohibits the inclusion of a portion of reserve in gross income under the elective cut-off method. Provides for continued application of provisions respecting distributions to stockholders, but the amount of the reserve accounted for by the taxpayer shall be only the balance of the amount of the applicable excess reserves. Provides for the treatment of the balance of the applicable excess reserves and the balance of reserves accounted for by a taxpayer as carryovers in certain corporate acquisitions.
Allows the amount allowed as a deduction under provisions of the Federal Deposit Insurance Act, to include the amount paid during 1996 as a special assessment to the Savings Association Insurance Fund (SAIF) under Federal law as amended by the Federal Thrift Charter Conversion Act of 1995 as contained in H.R. 2491 as passed by the House of Representatives.
On motion to refer the bill and the accompanying veto message to the Committee on The Budget. Agreed to without objection.
Introduced in House
Introduced in House
Sponsor introductory remarks on measure. (CR E1971-1972)
Referred to the House Committee on Ways and Means.
Committee Hearings Held.
Committee Consideration and Mark-up Session Held.
Ordered to be Reported (Amended) by Voice Vote.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 104-324.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 104-324.
Placed on the Union Calendar, Calendar No. 175.
For Further Action See H.R.2491.
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