S.410 - Wall Street Trading and Speculators Tax Act
A bill to amend the Internal Revenue Code of 1986 to impose a tax on certain trading transactions.
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SECTION 1. SHORT TITLE.
SEC. 2. TRANSACTION TAX.
‘Subchapter C--Tax on Trading Transactions
‘SEC. 4475. TAX ON TRADING TRANSACTIONS.
‘(b) Rate of Tax- The tax imposed under subsection (a) with respect to any covered transaction shall be 0.03 percent of the specified base amount with respect to such covered transaction.CommentsClose CommentsPermalink
‘(2) DERIVATIVE FINANCIAL INSTRUMENT- The term ‘derivative financial instrument’ includes any option, forward contract, futures contract, or any similar financial instrument.CommentsClose CommentsPermalink
‘(3) NOTIONAL PRINCIPAL CONTRACT- Except as otherwise provided by the Secretary, the term ‘notional principal contract’ means any financial instrument which requires two or more payments at specified intervals calculated by reference to a specified index upon one or more notional principal amounts. An amount shall not fail to be treated as a payment described in the preceding sentence merely because such amount is fixed on one date and paid or otherwise taken into account on a different date.CommentsClose CommentsPermalink
‘(C) any index based on any objectively determinable information (including the occurrence or nonoccurrence of any event) which is not within the control of any of the parties to the instrument and is not unique to any of the parties’ circumstances, andCommentsClose CommentsPermalink
‘(B) CERTAIN DEEMED EXCHANGES- In the case of a distribution treated as an exchange for stock under section 302 or 331, the corporation making such distribution shall be treated as having purchased such stock for purposes of this section.CommentsClose CommentsPermalink
‘(1) EXCEPTION FOR INITIAL ISSUES- No tax shall be imposed under subsection (a) on any covered transaction with respect to the initial issuance of any security described in subparagraph (A), (B), or (C) of subsection (e)(1).CommentsClose CommentsPermalink
‘(3) EXCEPTION FOR SECURITIES LENDING ARRANGEMENTS- No tax shall be imposed under subsection (a) on any covered transaction with respect to which gain or loss is not recognized by reason of section 1058.CommentsClose CommentsPermalink
‘(B) in the case of a purchase not described in subparagraph (A) which is executed by a broker (as defined in section 6045(c)(1)) which is a United States person, such broker.CommentsClose CommentsPermalink
‘(2) SPECIAL RULES FOR DIRECT, ETC., TRANSACTIONS- In the case of any transaction to which paragraph (1) does not apply, the tax imposed by this section shall be paid by--CommentsClose CommentsPermalink
‘(h) Certain Payments Treated as Separate Transactions- Except as otherwise provided by the Secretary, any payment with respect to a security described in subparagraph (D), (E), or (F) of subsection (e)(1) shall be treated as a separate transaction for purposes of this section, including--CommentsClose CommentsPermalink
‘(1) any net initial payment, net final or terminating payment, or net periodical payment with respect to a notional principal contract (or similar financial instrument),CommentsClose CommentsPermalink
‘(2) SPECIAL RULES FOR PAYMENT OF TAX ON DIRECT, ETC., TRANSACTIONS- In the case of any transaction which is a covered transaction solely by reason of paragraph (1) and which is not described in subsection (g)(1)--CommentsClose CommentsPermalink
‘(A) PAYMENT BY UNITED STATES SHAREHOLDERS- Any tax which would (but for this paragraph) be payable under subsection (g)(2) by the controlled foreign corporation shall, in lieu thereof, be paid by the United States shareholders of such controlled foreign corporation as provided in subparagraph (B).CommentsClose CommentsPermalink
‘(C) DEFINITIONS- For purposes of this subsection, the terms ‘United States shareholder’ and ‘controlled foreign corporation’ have the meanings given such terms in sections 951(b) and 957(a), respectively.CommentsClose CommentsPermalink
‘(j) Administration- The Secretary shall carry out this section in consultation with the Securities and Exchange Commission and the Commodity Futures Trading Commission.CommentsClose CommentsPermalink
‘(2) prescribe such regulations as are necessary or appropriate to prevent avoidance of the purposes of this section, including the use of non-United States persons in such transactions.’.CommentsClose CommentsPermalink
‘SEC. 36C. OFFSET FOR TRANSACTION TAX WITH RESPECT TO CERTAIN TAX-FAVORED ACCOUNTS.
‘(a) In General- There shall be allowed as a credit against the tax imposed by this subtitle for the taxable year an amount equal to 0.03 percent of the qualified tax-favored account contributions of the taxpayer for the taxable year.CommentsClose CommentsPermalink
‘(b) Qualified Tax-Favored Account Contributions- For purposes of this section, the term ‘qualified tax-favored account contributions’ means, with respect to any taxable year, the sum of--CommentsClose CommentsPermalink
‘(1) with respect to qualified retirement plans (as defined in section 4974(c)) of the taxpayer, the amount contributed to such plans for such taxable year to the extent that such contributions are allowable as a deduction or are excludable from gross income (or, in the case of a Roth IRA (as defined in section 408A(b)), the amount contributed),CommentsClose CommentsPermalink
‘(4) with respect to qualified tuition programs (as defined in section 529) and Coverdell education savings accounts (as defined in section 530) with respect to which the taxpayer is the designated beneficiary (or, in the case of a designated beneficiary with respect to whom another taxpayer is allowed a deduction under section 151, such other taxpayer in lieu of such designated beneficiary), the amount contributed for such taxable year.’.CommentsClose CommentsPermalink
(B) The table of sections for subpart C of part IV of subchapter A of chapter 1 of the Internal Revenue Code of 1986 is amended by inserting before the item relating to section 37 the following new item:CommentsClose CommentsPermalink
(c) Information Reporting With Respect to Controlled Foreign Corporations- Subparagraph (B) of section 6038(a)(1) is amended by inserting ‘and transactions which are covered transactions for purposes of section 4475 by reason of the application of section 4475(i)(1) to such corporation’ before the semicolon at the end.CommentsClose CommentsPermalink
(d) Clerical Amendment- The table of subchapters for chapter 36 of the Internal Revenue Code of 1986 is amended by inserting after the item relating to subchapter B the following new item:CommentsClose CommentsPermalink