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The effect of RRA '93 on individual taxpayers.

It appears at this point that the Revenue Reconciliation Act of 1993 (RRA), Title XIII of the Omnibus Budget Reconciliation Act of 1993, will require only a relatively small number of individuals to pay higher income taxes. It is important, however, that those affected begin planning now to minimize their liabilities and to be certain they have cash-on-hand April 15 to pay their tax bill.

Individuals will see numerous changes in the tax law, from higher regular and alternative minimum tax rates to changes in the way they pay their tax liability. Elderly taxpayers will confront higher taxation of social security benefits, while all taxpayers will face the tightening or elimination of several deductions. Individuals will also need to be aware of new capital gain rules, providing an increased differential between the tax rates for ordinary income and capital gains. Finally, a myriad of more focused provisions will affect individuals involved in certain types of activities.

Technical detail is provided below on the implementation of these new provisions and includes, where possible, planning insights for emerging strategies under the new law.

Individual Income Subject to Higher Taxes

Effective January 1, 1993, individuals at the upper end of the income spectrum are subject to higher income tax rates. RRA imposes a new 36% tax rate on individual taxpayers at the following taxable income levels:
Married Filing Separately: $70,000
Single: $115,000
Head of Household: $127,500
Married Filing Jointly and
Surviving Spouses: $140,000

In addition, all taxpayers will face an additional 10% surtax on taxable income that exceeds $250,000, regardless of filing status. This brings the marginal rate on income at or above this level to 39.6%.

Another important change to note affecting higher income taxpayers is the elimination of the hospital insurance wage base cap, which previously required that 1.45% of wages up to $135,000 (2.9% of self employment income) had to be contributed to Medicare hospital insurance. Effective after 1993, the percentage of wages to be paid remains the same; however, the $135,000 limit is repealed and all wages and self-employment income are subject to tax.

Expanded Inclusion of Social Security Benefits in Taxable Income

Finally, the package broadens individual income subject to taxation by including a higher percentage of social security income in the taxable income calculation for some taxpayers after 1993. The provisional income calculation remains the same, with taxpayers adding back to adjusted gross income any tax-exempt interest income to determine their "modified adjusted gross income (AGI)" under Internal Revenue Code (I.R.C.) 86(b) (2). Taxpayers then add one-half of their Social Security benefits received during the year to the modified AGI figure to determine their provisional income. The original threshold levels at which provisional income triggered inclusion of Social Security benefits also remain in place, with up to 50% of benefits being included for single individuals exceeding $25,000 in provisional income and for married couples filing jointly who exceed $32,000 in provisional income.

The new law will include in taxable income up to 85% of the social security benefits of single taxpayers with provisional income of $34,000 or more and married taxpayers filing jointly with provisional income of $44,000 or more. (For married couples filing separately, provisional income in excess of $0 will cause 85% inclusion of social security benefits.) Under new I.R.C. 86(a)(2), for those who exceed these thresholds, the amount included in gross income under this section shall be equal to the lesser of items A and B as outlined below.:

(A) The sum of:

(i) 85% of the amount the provisional income exceeds the threshold; plus

(ii) the lesser of:

a. the amount that would have been included under pre-'93 rules (50%); OR

b. $4,500 for individuals/$6,000 for married couples filing jointly.


(B) 85% of the social security benefits received during the year.

To use an example, assume a married couple with $45,000 in provisional income and $10,000 in social security benefits. These taxpayers would take the lesser of:

(A) The sum of:

(i) $1,000 x 85% = 850; PLUS

(ii) The lesser of:

a. $10,000 x 50% = $5,000 (pre-'93 rules),


b. $6,000 (married couple filing jointly required add-back).

The total for "A" is $5,850, to be compared to:

(B) $10,000 x 75% = $8,500.

Here, the lesser amount is shown in item A; therefore, the taxpayers would include $5,850 of their Social Security benefits in their adjusted gross income.

Some Provisions Designed to Ease Burden of Retroactivity

RRA '93 does include provisions to alleviate the strain the retroactive provisions will place on taxpayers. The first and more general of the two excuses underpayment penalties on any underpayment in 1993 related directly to the retroactive provisions of the act. For individuals, this means that any underpayment caused solely by the changes in the tax law effective in 1993 will not be subject to underpayment penalties.

A second provision of the new law will allow individuals to pay that portion of their 1993 tax liability solely attributable to the individual rate increases effective this year in three equal installments on April 15 of 1994, 1995 and 1996 without incurring interest or penalty. Four important restrictions apply. First, only the difference between tax calculated based on the new rate structure and tax calculated under the previous rate structure qualifies for installment payment. Second, the election is only available for taxable years beginning in the calendar year 1993 and must be made on the 1993 return. Third, the due date for each of the installment payments is the due date of the individual taxpayer's return without extension, meaning April 15 for the vast majority of individuals.

Finally, the installment agreement will be immediately terminated and the unpaid tax bill in its entirety will be due if the taxpayer does not meet an installment payment on or before the required date or if the Service believes the collection of any amount under the installment agreement is in jeopardy. This provision is not included in the Internal Revenue Code but is found at 13201 of the RRA itself.

Clearly, the installment payment option is one that eligible taxpayers should take advantage of, as it amounts to an interest-free loan over two years. If the taxpayer normally files an extension, as high-income individuals are prone to do, care must be taken that the individual's liability is not understated on April 15, 1994, 1995 or 1996. Failure to properly calculate the liability at this point will invalidate the entire arrangement. As the Research Institute of America reports, acceleration of income into 1993 solely to take advantage of this provision is not valuable, as taxpayers would still be better off paying the tax later than sooner (RIA Complete Analysis of RRA 93, 103). However, this provision combined with the increase in earned income subject to Medicare taxes that will be effective after January 1, 1994, could provide some incentive for the acceleration of earned income into 1993, if possible.

Estimated Tax Relief for Higher Income Individuals

I.R.C. 6654 has been amended under the new law to provide an estimated tax safe harbor for all individuals, eliminating the previous requirement that individuals meeting certain conditions had to file estimates based on 90% of their current year's projected liability. Under the provisions in the RRA, individuals with adjusted gross incomes exceeding $150,000 in the immediately preceding tax year will not be subject to interest and underpayment penalties if they pay 110% of their last year's liability in four installments over the course of the year. The Act makes this new estimated tax safe harbor effective for tax years beginning after December 31, 1993 (RRA 13214).

Alternative Minimum Tax Changes for Non-Corporate Taxpayers

Changes to the alternative minimum tax include higher rates and a two-tiered AMT structure for noncorporate filers subject to the AMT; however, they also have the benefit of higher exemption amounts.

The Revenue Reconciliation Act of 1993 raised the lowest alternative minimum tax rate from the existing 24% level to 26% on AMT income exceeding the exemption threshold by up to $175,000. AMT income exceeding the threshold by more than $175,000 will now be taxed at a second higher AMT rate of 28%. Married taxpayers filing separately incur the higher AMT rate at AMT income in excess of $87,500. Congress reports that this will contribute to the progressivity of the tax system, requiring those at higher incomes to pay higher taxes (Ways & Means Committee Report, p. 197).

It is important to note, however, that RRA '93 does increase the amount of AMT income taxpayers can exempt from the calculation of the tax. The exemption for married taxpayers filing joint returns will increase from $40,000 to $45,000; the amount for singles and heads of household will increase from $30,000 to $33,75O; and married couples filing separately will see their exemption increase from $20,000 to $22,500.

Married taxpayers filing separately must still include an additional amount in AMT income. Previously, these taxpayers had to add back the lesser of 25% of AMT income in excess of $155,000 or $20,000. Under the new law, this will become the lesser of 25% of AMT income in excess of $165,000 or $22,500.

RRA '93 holds good news for those subject to the AMT who make charitable gifts of appreciated property. In order to encourage taxpayers to make these types of gifts, Congress has retroactively extended and made permanent the previously temporary rule that eliminated the provision in the AMT limiting the deductibility of these gifts at their adjusted basis to the taxpayer. Contributions of appreciated property will now be deducted from AMT income at fair market value.

One final important provision regarding the alternative minimum tax involves the capital gains incentive for investment in small businesses. RRA '93 reduces the benefit of this provision to those subject to the AMT by creating a preference equal to 50% of the deduction for ordinary income tax purposes.

Capital Gains Provisions Under RRA '93

While the Revenue Reconciliation Act of 1993 increased the marginal individual income tax rates considerably for high income taxpayers, the maximum capital gains rate remains 28%.

Practitioners should be aware of two provisions that expand the definition of ordinary income under the new law. The act provides that holders of stripped preferred stock must recognize income in the same way as a holder of a bond with an original issue discount (OID). Therefore, the difference between the taxpayer's basis and the redemption value of the stock rights must be included ratably over a period of time. Unfortunately, the new code sections do not provide guidance on what date should be used as an equivalent to the redemption date under the OID rules.

Also, RRA '93 provides that original issue discount on certain types of bonds not previously subject to the OID rules must be included in ordinary income. Previously, gain on the disposition of tax exempt bonds and bonds issued before 7-19-84 that contained an original issue discount were treated as capital gains. The new rules apply to any obligations purchased after April 30, 1993.

With the increased differential between capital gains and ordinary income taxes, many individuals will seek transactions that create the favored type of income. RRA '93 takes steps to prevent capital gains treatment for some common transactions used to convert ordinary income into capital gain, but the act also provides additional capital gains incentives that favor certain specific investments.

Capital Gain Treatment Disallowed for Some Transactions

Under RRA '93, three types of transactions that previously would have resulted in capital gains will now result in ordinary income. The rules focus on eliminating capital gain treatment in transactions where the gain is based primarily on the time value of the money involved |I.R.C. 1258(c)(1)~. Under the new I.R.C. 1258, which was effective as of April 30, 1993, the following "conversion transactions" will result in ordinary income:

* Transactions in which property is acquired and an agreement is made at or near the time of the acquisition to resell the property for a definite price.

* "Applicable straddles" as defined in I.R.C. 1092, which are offsetting positions held in personal property so as to minimize the taxpayer's risk of loss.

* Transactions marketed or sold to the taxpayer on the premise that the investment will produce an interest-like regular return that will be taxed as capital gain (Senate Finance Committee Report, p. 234).

1258 also reserves for Treasury the right to subject other transactions to this treatment by regulation.

Gain resulting from one of these conversion transactions shall be treated by the taxpayer as ordinary income (but not as interest) for all purposes of the Internal Revenue Code (Senate Report, p. 234). However, Congress provided for the possibility that one of these transactions could provide a rate of return in excess of the time value of the money involved. A conversion transaction that provides a return in excess of 120% of the applicable Federal rate, as defined in I.R.C. 1274(d), will result in capital gain treatment for the amount of the excess. The Senate Finance Committee provided the following example of how this provision works:

Assume that X purchases stock for $100 on January 1, 1994, and on that same day agrees to sell it to Y on January 1, 1996, for $115. Assume that the applicable rate is 5% (compounded annually for the sake of this example). On January 1, 1996, X delivers the stock to Y in exchange for $115 in satisfaction of their agreement. Under pre-RRA '93 law, X would have a capital gain of $15. Under new I.R.C. 1258, $12.36 will be recharacterized as ordinary income (120% of 5% compounded annually for two years on an investment of $100). The remaining $2.64 will be taxed as capital gain (Senate Finance Report, p. 235).

The Committee report indicates that the key factor in determining whether a transaction may be characterized as a conversion transaction is the amount of risk borne by the taxpayer. To avoid conversion transaction treatment, a taxpayer must take on "a risk not typical of a lender" (Senate Finance Report, p. 236). In the example above, if X had granted only a call option to Y, the fact that X bore the risk of Y not purchasing the stock would make the gain resulting from this transaction a capital gain.

Finally, there are four more items to note regarding conversion transactions. First, the taxpayer's net investment for purposes of determining gain is adjusted by the fair market value of any position that becomes a part of the transaction and by any interest on borrowed funds that must be capitalized under I.R.C. 263(g). Second, for items held by the taxpayer prior to commitment to a conversion transaction, any built-in loss at the time the asset is committed to the transaction is not subject to the new rules. Under these rules, the asset will be valued for net investment purposes at its fair market value at the time of commitment to the transaction, with any built-in loss being recognized separately upon disposition. Third, commitments to provide investments in the future will not qualify as commitments to a conversion transaction until the funds become unavailable for use elsewhere. Finally, exceptions apply for options dealers and commodities dealers who take part in conversion transactions in their normal course of business.

Capital Gain Investment Incentives Under RRA '93

While RRA '93 does limit capital gain treatment for some transactions, it also provides incentives for capital investment in two specific types of businesses. Gains from investments in certain qualifying small businesses and from investments in specialized small business investment companies (SSBIC's) qualify for especially favorable treatment under the new tax law.

One of the most attractive provisions in the Revenue Reconciliation Act of 1993 is its capital gain incentive for investment in Qualifying Small Business Stock (QSBS). One-half of the eligible gain on the sale of QSBS will be excluded when calculating income from capital gains. Unfortunately, this provision also happens to be one of the most complicated in the entire package. Much is sure to be written on this entity in the months and years ahead as regulations and case law clarify the rules involved. This discussion, based largely on The RIA Complete Analysis of the Revenue Reconciliation Act of 1993, 702.5-704, attempts to provide an overview of the items to be considered when planning a qualified small business.

"Eligible gain" is gain on the sale or exchange of qualifying small business stock held for more than five years. Before we can determine what type of stock will qualify, we must first examine the criteria describing a qualifying business under the new rules. A qualifying small business must be a domestic C corporation at the date of issuance of the stock, for "substantially all of the holding period," and at the date of the sale or exchange for which this treatment is sought. 1202(c)&(d).

Remember, S corporations will not qualify for this treatment. Second, what will constitute "substantially all of the holding period" has not been defined by the act, so guidance must come from the regulations.

Stock becomes qualifying small business stock when the following conditions are met:

* The stock must be acquired at its original issue, whether directly or through an underwriter |1202(c)(1)(B)~. (Some exceptions exist for gifts and bequests of QSBS and for acquisition of QSBS by options.)

* The stock must be acquired in exchange for money or other non-stock property, or as compensation for services provided to the corporation (not including services performed as an underwriter for the stock). 1202(c)(1)(B).

* Stock cannot qualify under this provision if the corporation has repurchased shares of its own stock under certain conditions described in 1202(c)(3). This provision is designed to assure that QSBS is original issue stock.

* During substantially all of the holding period, the corporation must either meet certain "active business requirements" or qualify as a specialized small business investment company (SSBIC) |1202(c)(2)~. First, let's examine the active business requirements.

A corporation meets the active business requirements when at least 80% (by value) of the corporate assets are used in the active conduct of at least one qualified trade or business and the corporation qualifies as an eligible corporation |1202(e)(1)~. At this point, you are probably asking, "What is a qualified trade or business and what is an eligible corporation?" The new sections of the Code do not say what qualifies under these provisions--they only say what does not qualify.

A qualified trade or business is not:

* a business involving the performance of services in the fields of health, law, engineering, architecture, accounting, actuarial science, performing arts, consulting, athletics, financial services, brokerage services or any trade or business where the principal asset of such trade or business is the reputation or skill of one or more of its employees;

* a banking, insurance, financing, leasing, investing or similar business;

* an extraction or mining business;

* a hotel, motel, restaurant or similar business. |I.R.C. 1202(e)(3)~

An eligible corporation is not:

* a DISC or former DISC;

* a corporation with a 936 election in effect;


* a cooperative. |I.R.C. 1202(e)(4)~

In addition, the new section sets forth two instances where a corporation will automatically fail the active business requirements. First, for any period in which more than 10% of assets exceeding liabilities consist of stock in a non-subsidiary corporation, the corporation fails to meet the active business requirement |1202(e)(5)(B)~. Second, for any period in which 10% of the total value of assets consists of real estate not used in the active conduct of a trade or business, the corporation will fail to meet the active business requirement |1202(e)(7)~. For purposes of this test, owning, dealing in or renting real property will not be considered the active conduct of a trade or business.

Note here that each of these provisions disqualifies the QSBS only for the duration of the infraction. This will become important when regulations are propounded to clarify the "substantially all of the holding period" requirement.

There is still one more test the small business must meet in order to be a qualifying small business: the infamous gross assets test. From the effective date of the Revenue Reconciliation Act of 1993 (August 10, 1993) to a point in time immediately after the issuance of the stock that would otherwise be qualified, the aggregate gross assets of the corporation cannot exceed 50 million dollars. Amounts received in the sale of the stock must be included in this calculation. Also, for purposes of this calculation, a parent-subsidiary controlled group is treated as one corporation. The calculation to derive the proper figure for aggregate gross assets is cash on hand plus the adjusted basis of all property held, as explained in I.R.C. 1202(d).

Once a small business has actually qualified under these provisions, 50% of any gain from the sale or exchange of the business' stock held by an individual for more than five years will be excluded from tax. The exclusion is limited, however, to $10 million or 10 times the taxpayer's adjusted basis in the stock, whichever is greater. It is also important to remember that one-half of the excluded amount is treated as a preference item when calculating alternative minimum taxable income.

Finally, a few last items about qualified small businesses:

* If the stock is held by a pass-through entity, the benefits will pass through to the partners or shareholders as long as the stock qualifies and has been held by the entity for at least five years and the individual held his or her interest in the pass-through continuously from the date the entity acquired the qualified stock. I.R.C. 1202(g).

* If the stock is acquired for property, the basis in the stock is no less than the fair market value of the property at the date of exchange. This treatment prevents individuals from sheltering gain by exchanging appreciated property. I.R.C. 1202(i).

* Special rules apply for gifts and bequests of QSBS and for distributions of QSBS from partnerships to partners. With some exceptions, the donee, legatee or partner receiving the distribution will qualify as holding the stock from the date of its original issue. I.R.C. 1202(h).

* The provision is effective August 10, 1993.

* This discussion on qualified small business stock, perhaps more than any other provision in the new law, will require further study on the part of any practitioner who plans to use this potentially valuable but highly complex tax planning tool.

Specialized Small Business Investment Companies

The Revenue Reconciliation Act of 1993 encourages investments in Specialized Small Business Investment Companies (SSBIC's). SSBIC's are partnerships and corporations licensed by the Small Business Administration to invest in minority-owned small business operations.

The principal benefit of investment in an SSBIC is the sheltering of capital gains on common stock. Individual and corporate taxpayers can shelter capital gain on the sale of publicly-traded common stock to the extent that the proceeds from the sale of the common stock are invested in a SSBIC within 60 days of the sale of the publicly-traded common stock. This exclusion is not available to estates, trusts, partnerships or S corporations. New I.R.C. 1044 limits the exclusion available in any year to taxpayers as follows:

* All individuals, except those married filing separate returns, may exclude the lesser of $50,000 of qualifying gain in the current year or $500,000 less the total of all gains excluded in prior years.

* Married individuals filing separate returns may exclude the lesser of $25,000 of qualifying gain in the current year or $250,000 less the total of all gains excluded in prior years.

* Corporations may exclude the lesser of $250,000 of qualifying gain in the current year or $1 million less the total of all gains excluded in prior years.

Another benefit to holders of corporate SSBIC stock is the fact that, under I.R.C. 1044 (c)(3), such stock automatically meets the active business requirement, which at least removes one of the hurdles discussed above in becoming qualifying small business stock. Therefore, if the SSBIC and the shareholder meet all of the other requirements, a shareholder may shelter capital gain by purchasing the stock and exclude it when the stock is sold. Normally, under 1044(d), unrecognized gain would reduce the basis for determining gain or loss of an investment in an SSBIC. However, for SSBICs that meet the requirements for QSBS, basis is not reduced for the purpose of determining gain.

Earned Income Credit Changes Under RRA '93

The Revenue Reconciliation Act of 1993 takes several steps designed to simplify and expand the coverage of the earned income credit. As it existed prior to the new law, the credit consisted of three components. The basic credit was designed to assist individuals working at lower wages who had children. The supplemental health insurance credit was designed to reimburse low-income individuals who provided health insurance to their dependents, either through work or independently. Finally, the supplemental young child credit was enacted to provide additional relief for low-income taxpayers with infants born during the taxable year.

The last two pieces of the credit further complicated tax calculations by reducing some itemized deductions. The health insurance credit reduced any itemized medical deductions that may have been taken on Schedule A. Similarly, any health insurance deduction that may have been allowed to a self-employed individual would also have to be reduced by the amount of this credit. Those taxpayers who qualified for the young child credit were precluded from counting that child or children for whom they took the credit in the calculation for the dependent care credit under I.R.C. 21.

RRA '93 simplifies the calculation of the earned income credit by eliminating the separate calculation of the supplemental health insurance and young child credits in favor of a larger basic credit. This also eliminates the adjustments that were necessary to the deductions listed above under previous law. This relief, however, will not go into effect until tax years beginning after December 31, 1993.

The Revenue Reconciliation Act of 1993 expanded the amount of the basic earned income credit available and the number of individuals eligible for the credit. In 1994, the credit for taxpayers with one qualifying child will be 26.3% of the first $7,750 of earned income, reduced by 15.98% of any earned income exceeding $11,000. Taxpayers with two qualifying children will receive a credit of 30% of their first $8,426 of earned income, reduced by 17.68% of any earned income over $11,000 (I.R.C. 32). These percentages will increase by statute in 1995 and 1996, then level off. The threshold amounts will see some adjustment by statute in 1995, after which they will be indexed to inflation (I.R.C. 32).

The new law also expands the number of individuals eligible for the credit by extending the credit to low-income workers who do not have children. The definition of "eligible individual" under I.R.C. 32(c) now includes childless individuals if they:

* Make their principal place of abode in the United States for more than half of the taxable year;

* Fall between the ages of 25 and 65 at the end of the tax year; and

* Cannot be claimed as a dependent on another individual's tax return.

Those individuals qualifying under this section will be eligible for a credit of 7.65% of their first $4,000 in earned income, reduced by 7.65% of any earned income in excess of $5,000.

In an effort to make more taxpayers aware of the advanced payment option for earned income credit recipients, Congress has mandated notification of some EIC recipients. Employers should be aware that the IRS will be required to notify individuals who receive the earned income credit as a refund at the end of the year that the advance payment option is available |I.R.C. 3507(f)~. Also, in order to reduce the possibility of balances due at the end of the tax year, Congress has limited the amount of the EIC available in advance to 60% of the projected year-end EIC.

Other RRA '93 Provisions

Moving Expenses

New rules limit the deductibility of job-related moving expenses to taxpayers. Previously, to qualify for deductibility, a move had to be at least 35 miles. Under RRA '93, that threshold is expanded to 50 miles.

Once that threshold is met, the items that are considered deductible have been severely limited under the new law. Only expenses directly attributable to moving yourself, your family and your personal belongings to the new home may be deducted. After December 31, 1993, indirect amounts, such as pre-move house hunting trips, meals while in a temporary abode and costs associated with selling your old house and buying your new house will no longer be deductible under the new law.

The good news on moving expenses is that they will now be allowed above the line as a deduction to reach adjusted gross income.

Relief for Disaster Victims

RRA '93 provides some relief for individuals facing gain on involuntary conversions of property as a result of presidentially-declared disasters. The following new rules will apply:

* Gain on unscheduled personal property that was contained within the residence will no longer be recognized |I.R.C. 1033(h)(1)(a)(i)~.

* Proceeds received for the residence and its contents will be treated as a common pool of funds, allowing individuals to replace their residences and personal property in a lump sum without having to recognize gains on some pieces and losses on others. As long as you spend all of the proceeds to replace your home and its contents, you will qualify for nonrecognition of gain |I.R.C. 1033(h)(1)(A)(ii)~.

* The replacement period for property converted involuntarily has been extended from the current two years to four years under the new law |I.R.C. 1033(h)(1)(B)~.

RRA '93 will provide both obstacles and opportunities to practitioners and clients in the years ahead. The keys to successful planning under the new law will be an awareness of the provisions which increase the burden of some taxpayers and an understanding of the provisions that provide favorable tax treatment for targeted types of investments.

Jeffrey Lear is director of Federal Affairs & Tax Counsel for the National Society of Public Accountants.
COPYRIGHT 1993 National Society of Public Accountants
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Title Annotation:Back to School: The Revenue Reconciliation Act of 1993
Author:Lear, Jeffrey A.
Publication:The National Public Accountant
Date:Nov 1, 1993
Previous Article:Summarizing the changes of RRA '93.
Next Article:Business taxation under RRA '93.

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