IRS reform bill proposes revenue offsets.

• Author: Olson, Mitchel L.
• Position: Brief Article

On May 5, 1998, Senator Roth proposed additional revenue offsets to finance the IRS reform legislation. They included a provision to tighten the definition of operating losses eligible for a special 10-year carryback, a provision to modify the rollover rules for Roth individual retirement accounts (IRAs), and a four-year extension of the current user fees the Service charges for letter rulings.

The first proposal would define and limit the "specified liability loss" that may be carried back 10 years. Under this proposal, these losses would include only amounts attributable to a liability that arises under a Federal or state law for reclamation of land, decommissioning of a nuclear power plant, dismantlement of an off-shore oil-drilling platform, remediation of environment contamination or payments arising under a workers' compensation statute, if such liability occurs at least three years before the beginning of the tax year.

The second proposal would modify the minimum distribution requirements to determine adjusted gross income (AGI) for Roth IRA conversions. Under present law, taxpayers with AGI of $100,000 or less may convert amounts held in existing IRAs into Roth IRAs. Married taxpayers filing separate returns are not eligible to make the conversion.

Currently, uniform minimum distribution rules generally apply to all types of tax-favored retirement plans, including...