Reconciliation bill

TABLE OF CONTENTS:

Title I: Broad Based Tax Relief

Title II: Family Tax Relief Provisions

Title III: Retirement Savings Tax Relief

Subtitle A: Individual Retirement Arrangements

Subtitle B: Expanding Coverage

Subtitle C: Enhancing Fairness for Women

Subtitle D: Increasing Portability for Participants

Subtitle E: Strengthening Pension Security and

Enforcement

Subtitle F: Encouraging Retirement Education

Subtitle G: Reducing Regulatory Burdens

Subtitle H: Plan Amendments

Title IV: Education Tax Relief Provisions

Title V: Health Care Tax Relief Provisions

Title VI: Small Business Tax Relief Provisions

Title VII: Estate and Gift Tax Relief Provisions

Subtitle A: Reductions of Estate, Gift, and

Generation-Skipping Transfer Taxes

Subtitle B: Conservation Easements

Subtitle C: Annual Gift Exchange

Subtitle D: Simplification of Generation-Shipping

Transfer Tax

Title VIII: Tax Exempt Organizations Provisions

Title IX: International Tax Relief

Title X: Housing and Real Estate Tax Relief Provisions

Subtitle A: Low-Income Housing Credit

Subtitle B: Historic Homes

Subtitle C: Provisions Relating to Real Estate

Investment Trusts

Subtitle D: Private Activity Bond Volume Cap

Subtitle E: Leasehold Improvements Depreciation

Title XI: Miscellaneous Provisions

Title XII: Extension of Expired and Expiring Provisions

Title XIII: Revenue Offsets

Subtitle A: General Provisions

Subtitle B: Loophole Closers

Title XIV: Technical Corrections

Title XV: Compliance with Congressional Budget Act

Taxpayer Refund Act of 1999 - Title I: Broad Based Tax Relief - Amends the Internal Revenue Code to reduce the lowest individual regular income tax rate from 15 percent to 14 percent.

(Sec. 102) Phases-in an increase in the size of the 14-percent rate bracket.

Title II: Family Tax Relief Provisions - Permits married taxpayers to calculate separate taxable income for each spouse and to be taxed as two single individuals on the same return. Calculates the tax due is calculated by applying the tax rates for single individuals to the separate taxable incomes. Requires both spouses to elect to either use a standard deduction or to itemize their deductions.

(Sec. 202) Increases the starting point of the phase-out of the earned income credit for married couples filing a joint return by $2,000.

(Sec. 203) Expands the list of persons eligible to: (1) make qualified foster care payments; and (2) place foster care individuals.

(Sec. 204) Increases the maximum dependent care credit percentage from 30 percent to 50 percent for taxpayers with an adjusted gross income (AGI) of $30,000 or less. Phases-down the 50 percent credit rate by one percentage point for each $1,000 of AGI, or fraction thereof, between $30,001 and $59,000.

(Sec. 205) Provides for an employer-provided child care credit (of up to $150,000) equal to the sum of: (1) 25 percent of the qualified child care expenditures; and (2) 10 percent of the qualified child care resource and referral expenditures.

(Sec. 206) Permits an individual to offset the entire regular tax liability (without regard to the minimum tax) by the personal nonrefundable credit. Repeals the provision reducing the refundable child credit by the alternative minimum tax (AMT). Permits the deduction for personal exemptions in computing AMT.

Title III: Retirement Savings Tax Relief - Subtitle A: Individual Retirement Arrangements - Increases the annual contribution limit for traditional IRAs and Roth IRAs in $1,000 annual increments, beginning in 2001, until the limit reaches $5,000 in 2003, and thereafter, the limit is indexed for inflation in $100 increments. Increases the AGI phase-out limits for active participants in an employer-sponsored plan.

(Sec. 303) Provides for Individual Development Accounts (IDA). Permits, if an eligible individual establishes an IDA with a qualified financial institution, the qualified financial institution to deposit into a separate, parallel, individual or pooled matching account an eligible matching contribution for the taxable year. Provides a tax credit for certain matching contributions to an IDA. Prohibits matching contributions after December 31, 2005. Permits qualified distributions only if, among other things: (1) the holder of the IDA has completed an economic literacy course offered by a qualified financial institution, a nonprofit organization, or a government entity; and (2) the distribution is used for qualified expenses (qualified higher education expenses, qualified first-time homebuyer costs, qualified business capitalization costs, or qualified rollovers).

(Sec. 304) Permits IRAs to invest in any coin certified by a recognized grading service.

Subtitle B: Expanding Coverage - Provides for optional treatment of elective deferrals as plus contributions.

(Sec. 312) Increases elective deferral contribution limits.

(Sec. 313) Eliminates certain current rules concerning plan loans made to an owner-employee.

(Sec. 314) Provides that elective deferral contributions are not subject to deduction limits.

(Sec. 315) Amends the Employee Retirement Income Security Act (ERISA) of 1974 to provide that, during the first five years of a new single-employer plan of a small employer (100 or fewer employees), the flat rate Pension Benefit Guaranty Corporation (PGBC) premium will be five dollars per plan participant. Provides for a reduced additional PGBC variable premium for new employers.

(Sec. 317) Eliminates user fee requirements for requests to the IRS concerning the status of pension plans.

(Sec. 318) Amends the IRC to allow an eligible employer to establish and maintain a SAFE annuity (an individual retirement annuity) or a SAFE trust (a trust forming part of a defined benefit plan), both to be funded by the employer. Makes the employer contributions deductible without limitation and otherwise provides for the treatment of contributions and distributions. Mandates a penalty for early withdrawals. Requires simplified employer reports for SAFE annuities and simplified actuarial reports for SAFE trusts.

Amends ERISA to exempt SAFE trusts from coverage requirements and SAFE annuities from certain employer reporting requirements.

(Sec. 319) Modifies top-heavy rules.

Subtitle C: Enhancing Fairness for Women - Provides that individuals who have attained age 50 may make additional catch-up elective contributions to employer-sponsored retirement plans and additional catch-up IRA contributions.

(Sec. 322) Sets forth requirements relating to equitable treatment for contributions of employees to defined contribution plans. Requires that certain contributions by church plans are not to be treated as exceeding a specified limit.

(Sec. 323) Revises requirements relating to tax treatment of division of section 457 plan benefits upon divorce.

(Sec. 324) Directs the Secretary to revise regulations relating to safe harbor relief for hardship withdrawals from cash or deferred arrangements.

(Sec. 325) Provides for faster vesting of certain employer matching contributions.

Subtitle D: Increasing Portability for Participants - Permits rollovers from and to various types of plans.

(Sec. 332) Permits individual retirement plan (IRA) rollovers only if certain conditions are met.

(Sec. 333) Permits rollover of after-tax contributions in an exempt trust under specified conditions.

(Sec. 334) Sets forth a hardship exception to the 60-day rule.

(Sec. 335) Sets forth requirements for treatment of forms of distribution available under transferor and transferee plans.

(Sec. 336) Revises restrictions on distributions, including the same desk exception.

(Sec. 337) Authorizes trustee-to-trustee transfers to purchase permissive service credit with respect to governmental defined benefit plans.

(Sec. 338) Allows employers to disregard rollovers for purposes of cash-out amounts, under retirement plan provisions.

(Sec. 339) Revises year of inclusion in gross income requirements for section 457 plans.

Subtitle E: Strengthening Pension Security and Enforcement - Amends the IRC and ERISA to phase-in increases in the percentage of the current liability funding limit. Repeals such limit beginning January 1, 2004.

(Sec. 342) Amends ERISA to direct the PBGC to prescribe rules relating to missing participants for multiemployer plans covered by the PBGC that terminate.

(Sec. 343) Amends the IRC to allow an employer, in determining the amount of nondeductible contributions for any taxable year, to elect not to take into account any contributions to a defined benefit plan except to the extent that they exceed the full-funding limitation.

(Sec. 344) Imposes an excise tax on a plan failing to provide required notice of a significant reduction in the rate of future benefit accrual.

(Sec. 345) Amends the Taxpayer Relief Act of 1997 to protect investment of employee contributions to 401(k) plans by providing that specified requirements apply to elective deferrals for plan years beginning after December 31, 1998.

(Sec. 346) Makes certain compensation limitations for defined benefit plans inapplicable to governmental and multiemployer plans. Prohibits combining or aggregating a multiemployer plan with any other plan maintained by the employer for the purpose of applying such limitations.

Subtitle F: Encouraging Retirement Education - Requires that pension benefit statements be furnished annually (once every three years for defined benefit plans) or on request. Allows written or electronic statements. Requires multiemployer plans to furnish a statement (written or electronic) on request.

(Sec. 352) Excludes qualified retirement planning services from gross income (as a fringe benefit).

Subtitle G: Reducing Regulatory Burdens - Directs the Secretary, by regulation, to provide that plan satisfies the nondiscrimination requirements concerning highly employees if it meets pre-1994 requirements and certain other conditions are met.

(Sec. 362) Amends the IRC and ERISA to revise requirements relating to timing of plan valuations.

(Sec. 363) Amends ERISA rules for substantial owners relating to plan terminations to revise: (1) the phase-in of the guarantee; and (2) the allocation of assets.

(Sec. 364) Amends IRC requirements for applicable dividends to allow dividends of employee stock ownership plans to be reinvested without loss of dividend deduction.

(Sec. 365) Revises the notice and consent period regarding distributions. Directs the Secretary tomodify certain regulations to provide that the description of a participant's right, if any, to defer receipt of a distribution shall also describe the consequences of failing to defer such receipt.

(Sec. 367) Repeals a transition rule relating to certain highly compensated employees under the Tax Reform Act of 1986.

(Sec. 368) Directs the Secretary to modify certain regulations with respect to certain plan participation by employees of tax-exempt entities under the IRC.

(Sec. 369) Revises ERISA requirements for annual report dissemination.

(Sec. 370) Revises rules concerning the exclusion for employer provided transit passes.

Subtitle H: Plan Amendments - Prescribes requirements for plan amendments or annuity contract amendments under the IRC.

Title IV: Education Tax Relief Amendments - Eliminates the 60-month limit on student loan interest deductions and increases the income limitation on student loan deductions.

(Sec. 402) Permits private educational institutions to maintain qualified tuition programs which are comparable to qualified State tuition programs. Excludes qualified distributions from such accounts from gross income.

(Sec. 403) Excludes from gross income certain amounts received under the National Health Corps Scholarship Program or the Armed Forces Health Professions Scholarship and Financial Assistance Program.

(Sec. 404) Permanently extends the exclusion from gross income of employer-provided educational assistance and restores the exclusion for such assistance on the graduate level.

(Sec. 405) Increases the amount by which certain governmental bonds used to finance public school capital expenditures may be exempted from specified arbitrage bond provisions.

(Sec. 406) Provides for the treatment of qualified public educational facility bonds as exempt facility bonds. Defines a "qualified public educational facility" as any school facility which is: (1) part of a public elementary school or a public secondary school; and (2) owned by a private, for-profit corporation pursuant to a public-private partnership agreement with a State or local educational agency. Provides for an exception from the State volume cap.

(Sec. 407) Permits aggregate Federal guarantees of up to $500 million in school construction bonds by the Federal Housing Finance Board.

Title V: Health Care Tax Relief Provisions - Phases-in a 100 percent deduction (for both itemizers and nonitemizers) for the health and long-term care insurance costs of individuals not participating in employer-subsidized health plans.

(Sec. 502) Permits offering long-term care insurance under cafeteria plans and flexible spending arrangements.

(Sec. 503) Permits a taxpayer an additional exemption for certain elderly family members who need long-term care and who reside with the taxpayer.

(Sec. 504) Adds to the list of taxable vaccines any conjugate vaccine of streptococcus pneumoniae. Reduces the per dose vaccine tax rate. Requires a report on the adequacy of the Vaccine Injury Compensation Trust Fund to meet claims.

Title VI: Small Business Tax Relief Provisions - Provides for the deduction of 100 percent of the health insurance costs of self-employed individuals.

(Sec. 602) Increases to $30,000 the amount which may be expensed as section 179 property.

(Sec. 603) Makes the 6.2 percent Federal Unemployment Tax Act rate effective through calendar year 2004 (currently, 2007) and the 6.0 percent rate effective through calendar year 2005 (currently, 2008).

(Sec. 604) Coordinates, for farmers, income averaging with the alternative minimum tax.

(Sec. 605) Permits an individual engaged in an eligible farming business a limited deduction for amounts paid into a Farm and Risk Management Account. Defines such an account.

Title VII: Estate and Gift Tax Relief Tax Provisions - Subtitle A: Reductions of Estate, Gift, and Generation-Skipping Transfer Taxes - Reduces the maximum estate tax rate from 55 to 50 percent. Repeals the phaseout of graduated rates.

(Sec. 702) Replaces the unified credit with a unified exemption amount.

Subtitle B: Conservation Easements - Doubles the distance within which qualified conservation easements must be located from a metropolitan area, national park, or wilderness area.

Subtitle C: Annual Gift Exclusion - Phases-in a doubling of the annual gift exclusion.

Subtitle D: Simplification of Generation-Skipping Transfer Tax - Permits the retroactive allocation of the generation-skipping transfer tax (GST) in certain cases.

(Sec. 732) Permits the severance of a trust if there is a "qualified severance."

(Sec. 733) Modifies certain valuation rules.

(Sec. 734) Requires regulations prescribing the circumstances and procedures under which extensions of time will be granted in the case of a GST exemption or exception.

Title VIII: Tax Exempt Organizations Provisions - Exempts an organization from income tax if it is created by a State to provide property and casualty insurance coverage for property for which such coverage is otherwise unavailable.

(Sec. 802) Modifies rules relating to unrelated business taxable income for amounts received from controlled entities.

(Sec. 803) Repeals the separate grass roots lobbying expenditure limit.

(Sec. 804) Exempts from inclusion as income individual retirement account (IRA) distributions used for qualified charitable purposes. Sets forth related rules for charitable remainder trusts, pooled income funds, and charitable gift annuities.

(Sec. 805) Excludes from an individual's gross income amounts received as reimbursement regarding the use of a passenger automobile for the benefit of a charitable organization. Relieves the organization of certain reporting requirements regarding the reimbursements.

(Sec. 806) Treats certain expenses incurred by whaling captains while carrying out sanctioned activities for Native Alaskan subsistence whaling as a charitable contribution deduction.

(Sec. 807) Permits charitable contributions to be made to qualified low-income schools after the end of a tax year, if such contributions are made before the required filing time.

(Sec. 808) Permits non-itemizers to deduct a portion of their charitable contributions.

(Sec. 809) Phases-in increases in the percentage limitations applicable to charitable contributions.

(Sec. 810) Sets forth a limited exception to the excess business holdings rule.

Title IX: International Tax Relief - Permits treating each electing worldwide affiliated group as an affiliated group for purposes allocating and apportioning interest expense for each domestic corporation which is a member of the group.

(Sec. 902) Revises provisions concerning the of application of look-thru rules to dividends from noncontrolled section 902 corporations to provide, in general, that any dividend from a noncontrolled section 902 corporation with respect to the taxpayer shall be treated as income in a separate category in proportion to the ratio of: (1) the portion of earnings and profits attributable to income in such category; to (2) the total amount of earnings and profits.

(Sec. 903) Excludes from the definition of "foreign base company oil related income" the pipeline transportation of oil or gas within such foreign country.

(Sec. 904) Excludes from the definition of "foreign base company services income" income derived in connection with the performance of services which are related to the transmission of high voltage electricity.

(Sec. 905) Provides for the treatment of advance pricing agreements as confidential taxpayer information.

(Sec. 906) Exempts certain air transportation rights sold to foreign individuals from the 7.5 percent excise tax.

(Sec. 907) Repeals the 90 percent limitation on the utilization of the alternative minimum tax foreign tax credit.

(Sec. 908) Repeals the special foreign corporation sales rule for military property.

Title X: Housing and Real Estate Tax Relief Provisions - Subtitle A: Low-Income Housing Credit - Modifies the low-income housing credit.

Subtitle B: Historic Homes - Establishes a credit equal to 20 percent of the qualified rehabilitation expenditures made by a taxpayer with respect to a qualified historic home.

Subtitle C: Provisions Relating to Real Estate Investment Trusts - Part I: Treatment of Income and Services Provided By Taxable REIT Subsidiaries - Excludes taxable REIT subsidiaries (TRSs) from the five and ten percent asset tests.

(Sec. 1022) Allows TRSs to provide non-customary tenant services.

(Sec. 1023) Allows a REIT to establish a TRS (as defined).

(Sec. 1024) Includes in the definition of "disqualified interest" (Sec. 163 of the IRC) any interest paid or accrued by a TRS to the REIT.

(Sec. 1025) Imposes a 100 percent tax on any interest payments by a TRS to the REIT in excess of the commercially reasonable interest rate.

Part II: Health Care REITs - Includes within the definition of the term "foreclosure property" any qualified health care property acquired by a REIT as the result of the termination of a lease of such property.

Part III: Conformity With Regulated Investment Company Rules - Changes the distribution requirement from 95 percent to 90 percent.

Part IV: Clarification of Exception From Impermissible Tenant Service Income - Provides, with respect to the definition of an independent contractor, that in the event that any class of stock of is regularly traded on an established securities market, only owners who own, directly or indirectly, more than five percent of such class of stock shall be taken into account as owning any of the stock of such class for purposes of applying the 35 percent limitation.

Part V: Modification of Earnings and Profits Rules - Provides rules for determining whether a Regulated Investment Company (RIC) has earnings and profits form a non-RIC year.

Part VI: Study Relating to Taxable REIT Subsidiaries - Directs the: (1) Commissioner of the Internal Revenue shall conduct a study to determine how many taxable REIT subsidiaries are in existence and the aggregate amount of taxes paid by such subsidiaries; and (2) the Secretary of the Treasury to submit a report to the Congress describing the results of such study.

Subtitle D: Private Activity Bond Volume Cap - Accelerates the increase in the volume cap on State private activity bonds.

Subtitle E: Leasehold Improvements Depreciation - Includes qualified leasehold improvement property as 15 year property for purposes of the accelerated cost recovery depreciation rules. Defines "qualified leasehold improvement property" as certain improvements to an interior portion of a building which is nonresidential property.

Title XI: Miscellaneous Provisions - Repeals the: (1) LUST taxes on fuel used in trains; and (2) 4.3-cents-per-gallon General Fund excise tax on diesel fuel used by railroads and on fuels used by barges operating on designated inland waterways.

(Sec. 1102) Amends the Internal Revenue Code with respect to the tax treatment of Settlement Trusts established under the Alaska Native Claims Settlement Act.

Exempts from income taxation any such Settlement Trust electing coverage by this Act. Declares that for an electing trust: (1) no amount shall be includible in the gross income of a Settlement Trust beneficiary by reason of a contribution to the Settlement Trust during such taxable year; and (2) the ordinary requirements for taxation of trusts and beneficiaries shall not apply.

Requires an electing trust to distribute at least 55 percent of its adjusted taxable income each taxable year. Imposes a tax on a trust, in the amount of the failure, if the distribution is insufficient.

Includes in the beneficiary's gross income, as ordinary income, any distribution from an electing trust (only when the actual distribution is received). Provides that distributions from the trust will be taxable as ordinary income even if the distribution represents a return of capital. Requires tax withholding on trust distributions over a certain amount.

(Sec. 1103) Permits businesses to recover, as specified, long-term unused credits against the alternative minimum tax.

(Sec. 1104) Permits a five-year net operating loss carryback for losses attributable to operating mineral interests of independent oil and gas producers.

(Secs. 1105 and 1106) Allows both geological and geophysical expenditures on domestic oil and gas exploration and development and delay rental payments, at the taxpayer's election, to be deducted from gross income at the time incurred.

(Sec. 1107) Provides that, for specified purposes of the active business definition, all members of a corporation's separate affiliated group shall be treated as one corporation.

(Sec. 1108) Increases the maximum dollar limitation on reforestation expenses eligible for amortization and suspends such dollar limitation through calendar year 2003.

(Sec. 1109) Revises the excise tax on arrow components.

(Sec. 1110) Doubles the Joint Committee on Taxation reporting threshold for refunds and credits.

(Sec. 1111) Modifies the definition of a rural airport for purposes of the air passenger tax.

(Sec. 1112) Provides that the patronage dividends of cooperatives shall not be reduced by stock dividends to the extent the stock dividends are in addition to amounts otherwise payable.

(Sec. 1113) Repeals certain provisions concerning the filing of consolidated returns by insurance companies.

(Sec. 1114) Modifies, for lending or finance companies, the exemption from the personal holding company tax.

(Sec. 1115) Expands the credit for modifications to inter-city buses to meet Americans with Disabilities Act requirements.

(Sec. 1116) Accelerates the 80 percent deduction for business meal expenses for individuals subject to Federal hours of service limitations.

(Sec. 1117) Provides for the treatment of a qualified highway infrastructure project bond as an exempt private activity bond.

(Sec. 1118) Extends the District of Columbia (DC) homebuyer credit by one year and increases the phase-out range.

(Sec. 1119) Eliminates the ten percent poverty rate limitation for purposes of the zero-percent capital gains rate for DC zone assets.

(Sec. 1120) Classifies any natural gas gathering line as seven-year property for purposes of depreciation. Defines natural gas gathering line.

(Sec. 1121) Exempts small seaplanes from the air passenger excise taxes.

Title XII: Extension of Expired and Expiring Provisions - Extends the: (1) research credit (permanently); (2) subpart F (Controlled Foreign Corporations) exemption for active income financing (for five years); (3) taxable income limit on percentage depletion for marginal oil and gas wells (for five years); (4) work opportunity credit and the welfare-to-work credit (for five years); (5) credit for electricity produced by wind and closed-loop biomass (for five years) and extends a credit to facilities using poultry waste; and (6) expiration date for the expensing of certain environmental remediation costs until June 30, 2004.

Maintains the exemption of Alaska from dyeing requirements for diesel fuel and kerosene exempt from the gasoline tax.

Repeals the exemption from such dyeing requirements for other States exempted by the Administrator of the Environmental Protection Agency from such requirements under the Clean Air Act.

Title XIII: Revenue Offsets - Subtitle A: General Provisions - Modifies the foreign tax credit carryback and carryover periods.

(Sec. 1302) Amends provisions involving returns relating to the cancellation of indebtedness by certain entities to include within the definition of "applicable financial entity" any organization a significant trade or business of which is the lending of money.

(Sec. 1303) Increases the withholding rate for nonperiodic distributions from 10 to 15 percent.

(Sec. 1304) Directs the Secretary to establish a program requiring the payment of user fees for requests to the IRS for ruling letters, opinion letters, determination letters, and other similar requests. Terminates fees October 1, 2009.

(Sec. 1305) Prohibits transfers of excess pension assets to retiree health account made after September 30, 2009, (currently, after December 31, 2000) from being treated as qualified transfers.

(Sec. 1306) Excludes from the definition of "capital asset" (under rules for determining capital gains and losses) any commodities derivative financial instrument held by a commodities dealer, if such instrument clearly has no connection to the activities of the dealer as a dealer.

Subtitle B: Loophole Closers - Limits the use of the non-accrual experience method of accounting under provisions relating to special rules for services.

(Sec. 1312) Modifies rules relating to the exemption of certain ten or more employer plans from welfare benefit fund provisions.

(Sec. 1313) Prohibits, in general, the use of the installment method of accounting for accrual method dispositions.

(Sec. 1314) Treats a gain as an ordinary gain to the extent such gain exceeds the net underlying long-term capital gain where the taxpayer has gain from a constructive ownership transaction with respect to any financial position and such gain otherwise would be treated as a long-term capital gain. Provides that, to the extent such gain is treated as a long-term capital gain after the application of the previous sentence, the determination of the applicable capital gain rate (or rates) shall be determined on the basis of the respective rate (or rates) that would have been applicable to the net underlying long-term capital gain. Sets forth definitions and exceptions.

(Sec. 1315) Amends the IRC to disallow a deduction for the transfer of a charitable contribution to or for the use of a State or charitable tax-exempt organization or trust if in connection with such transfer: (1) the organization directly or indirectly pays, or has previously paid, any premium on any personal benefit contract (life insurance, annuity, or endowment contract, also known as charitable split-dollar life insurance) with respect to the transferor; or (2) there is an understanding (side agreement) that any person will directly or indirectly pay any premium on such contract with respect to such transferor. Imposes on such organization an excise tax equal to the premiums paid by it on the personal benefit contract.

Provides that certain persons shall not be treated as indirect beneficiaries: (1) in certain cases in which a charitable organization purchases an annuity contract to fund an obligation to pay a charitable gift annuity; or (2) solely by reason of being a noncharitable recipient of an annuity or unitrust amount paid by a charitable remainder trust that holds a life insurance, annuity or endowment contract.

(Sec. 1316) Prohibits from taking into account any dividend received from a closely held real estate investment trust by any person owning 10 percent or more of the stock or beneficial interests in the trust in computing annualized income installments in a manner similar to the manner under which partnership income inclusions are taken into account.

(Sec. 1317) Requires any employee stock ownership plan holding employer securities consisting of stock in an S corporation to provide that no portion of the assets of the plan attributable to (or allocable in lieu of) such employer securities may, during a nonallocation year, accrue (or be allocated directly or indirectly under any qualified plan of the employer) for the benefit of any disqualified individual.

(Sec. 1318) Revises the anti-abuse rules related to assumption of liability.

(Sec. 1319) Provides that, as a general rule, a transfer of an interest in intangible property shall be treated (under provisions concerning the transfer of property to a corporation controlled by the transferor) as a transfer of property even if the transfer is of less than all of the substantial rights of the transferor in the property.

(Sec. 1320) Makes a controlled entity ineligible to be a REIT (Real Estate Investment Trust). Defines "controlled entity."

(Sec. 1321) Sets forth rules concerning distributions to a corporate partner of stock in another corporation.

Title XIV: Technical Corrections - Sets forth amendments concerning, among other things: (1) the Tax and Trade Relief Extension Act of 1998; (2) the Internal Revenue Service Restructuring and Reform Act of 1998; (3) the Taxpayer Relief Act of 1997; (4) the treatment of worthless securities of affiliated corporations; (5) the IRA contribution amount of the lesser earning spouse; (6) modified endowment contracts; (7) lump-sum distributions; and (8) tentative carryback adjustments of losses from section 1256 contracts.

Title XV: Compliance With Congressional Budget Act - States that: (1) all provisions of, and amendments made by, this Act which are in effect on September 30, 2009, shall cease to apply as of the close of September 30, 2009; (2) all provisions of, and amendments made by, this Act which were terminated under clause (1) shall begin to apply again as of October 1, 2009, as provided in each such provision or amendment.