Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 7

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               The GATT amendment also included a corollary 2-percentage              
          point interest rate differential applicable for periods after               
          December 31, 1994, in the interest rate applicable to large                 
          corporate tax underpayments in excess of $100,000.  Sec. 6621(c).           
               The above changes in the interest rates applicable to large            
          corporate over- and underpayments were added by Congress as                 
          “outlay reduction[s] * * * to assist in offsetting the projected            
          cost of the implementing legislation” relating to the GATT                  
          treaty.  S. Rept. 103-412, at 11 (1994); H. Rept. 103-826 (I),              
          at 9 (1994), U.S.C.C.A.N. 1994, pp. 3773, 3781.  The Senate                 
          report explained as follows:                                                

               As set forth below in the * * * [Congressional Budget                  
               Office] cost estimate, the Uruguay Round agreement                     
               includes a commitment by the United States to reduce                   
               U.S. tariffs which would cause a loss of receipts to                   
               the U.S. Treasury.  As explained above, the Budget                     
               Enforcement Act and Senate Rules require that these                    
               costs be offset.  Due to this pay-as-you go                            
               requirement, it is both “necessary” and “appropriate”                  
               that provisions designed to offset the costs of the                    
               Uruguay Round agreement be included in this                            
               implementing legislation.  [S. Rept. 103-412, at 135.]                 

               Petitioners acknowledge that respondent, with respect to               
          each of the years in issue, has refunded to petitioners all                 
          overpaid taxes and overpaid interest that petitioners paid to               
          respondent, plus compound interest thereon through December 31,             

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