- 21 -
Rept. 99-841, supra at 261, 1986-3 C.B. (Vol. 4) at
261.9]
9 But for these citations, respondent’s argument on brief
includes no citation to the legislative history underlying the
Tax Reform Act of 1986 (1986 Act), Pub. L. 99-514, 100 Stat.
2085, enactment of the current AMT regime. Our research has
revealed two other times in which the term “separate from but
parallel to” appears in that legislative history. The conferees
stated that the House bill provided the following rules on the
application of the AMT FTCs and the AMT NOLs to corporate
taxpayers:
Under the House bill, foreign tax credits are
allowed against the minimum tax, under limits similar
to those applying under the regular tax. Credits that
cannot be used in the current taxable year because of
these limits are carried over under a system separate
from but parallel to that applying for regular tax
purposes.
* * * * * * *
Under the House bill, the net operating loss
deduction is allowed against alternative minimum
taxable income. For any taxable year beginning after
1985, the minimum tax is reduced by the items of tax
preference arising in that year. Minimum tax NOLs are
carried over under a system separate from but parallel
to that applying for regular tax purposes. [H. Conf.
Rept. 99-841 (Vol. II), supra at II-281, II-282 (1986),
1986-3 C.B. (Vol. 4) at 281, 282.]
In addition to these two uses of the word “parallel” and the
other two uses referenced by the parties, our research has
uncovered only one other time that the word “parallel” appears in
the legislative history underlying the 1986 Act’s enactment of
the current AMT regime. The conferees stated in its discussion
of corporate AMT NOLs:
It is clarified that, in light of the parallel
nature of the regular tax and minimum tax systems, any
limitations applying for regular tax purposes to the
use by a consolidated group of NOLs or current year
losses (e.g., section 1503) apply for minimum tax
purposes as well. [H. Conf. Rept. 99-841, supra at II-
(continued...)
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