- 72 -
significant business presence tests for other appropriate
cases (including a value added test for services), which are
consistent with the statutory tests.
Id. at 507, supra, 1982-2 C.B. 618-619.
We are at a loss to understand how the foregoing advances
the thesis of that part of respondent’s brief, that “Attribution
is contrary to the legislative history and the purpose behind the
enactment of section 936.”
Respondent’s focus on “cost to the Treasury” led us to
examine the revenue estimates for the “Limit on possession
credit” provisions, as they appeared in the Senate Finance
Committee report (S. Rept. 97-494 Vol. 1, 102-103 (1982)), and
the conference committee report (H. Conf. Rept. 97-760, 692-693
(1982)), which are set forth in table 4.15
Table 4
Estimated increase in revenue
(millions of dollars) from:
Fiscal Senate Finance Conference
Year Committee amendment agreement
1983 412 201
1984 1,027 428
1985 1,251 473
1986 1,356 516
1987 1,470 559
The conference committee added paragraph (5), the election-
out provision we deal with in the instant cases, to the Senate
15For a recent example of the use of congressional numerical
estimates as an aid in interpreting legislation, see Toyota Motor
Mfg., Kentucky, Inc. v. Williams, 534 U.S. 184, ___ (2002) (slip
op. at 9).
Page: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 NextLast modified: May 25, 2011