Page:United States Statutes at Large Volume 109 Part 1.djvu/112

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109 STAT. 96 PUBLIC LAW 104-7 —APR. 11, 1995 26 USC 32 note. (b) EFFECTIVE DATE. —The amendments made by this section shall apply to taxable years beginning after December 31, 1995. SEC. 5. EXTENSION OF SPECIAL RULE FOR CERTAIN GROUP HEALTH PLANS. Section 13442(b) of the Omnibus Budget Reconciliation Act 26 USC 162 note, of 1993 (Public Law 103-66) is amended by striking "May 12, 1995" and inserting "December 31, 1995". SEC. 6. STUDY OF EXPATRIATION TAX. (a) IN GENERAL.—The staff of the Joint Committee on Taxation shall conduct a study of the issues presented by any proposals to affect the taxation of expatriation, including an evaluation of— (1) the effectiveness and enforceability of current law with respect to the tax treatment of expatriation, (2) the current level of expatriation for tax avoidance purposes, (3) any restrictions imposed by any constitutional requirement that the Federal income tax apply only to realized gains, (4) the application of international human rights principles to taxation of expatriation, (5) the possible effects of any such proposals on the free flow of capital into the United States, (6) the impact of any such proposals on existing tax treaties and future treaty negotiations, (7) the operation of any such proposals in the case of interests in trusts, (8) the problems of potential double taxation in any such proposals, (9) the impact of any such proposals on the trade policy objectives of the United States, (10) the administrability of such proposals, and (11) possible problems associated with existing law, including estate and gift tax provisions. (b) REPORT.— The Chief of Staff of the Joint Committee on Taxation shall, not later than June 1, 1995, report the results of the study conducted under subsection (a) to the Chairmen of the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate. Approved April 11, 1995. LEGISLATIVE HISTORY—H.R. 831: HOUSE REPORTS: Nos. 104-32 (Comm. on Ways and Means) and 104-92 (Comm. of Conference). SENATE REPORTS: No. 104-16 (Comm. on Finance). CONGRESSIONAL RECORD, Vol. 141 (1995): Feb. 21, considered and passed House. Mar. 24, considered and passed Senate, amended. Mar. 30, House agreed to conference report. Mar. 31, Apr. 3, Senate considered and agreed to conference report. WEEKLY COMPILATION OF PRESIDENTIAL DOCUMENTS, Vol. 31 (1995): Apr. 6, Presidential statement.