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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,
1994.
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