Jobs and Growth Tax Relief Reconciliation Act of 2003

Jobs and Growth Tax Act of 2003 - Amends the Internal Revenue Code to accelerate the following previously enacted tax reductions: (1) the 10-percent individual income tax rate bracket expansion: (2) the reduction in individual income tax rates; (3) the 15-percent individual income tax rate bracket expansion for married taxpayers filing joint returns; (4) the increase in the standard deduction for married taxpayers filing joint returns; and (5) the increase in the child tax credit.Triples the small business expensing limit.Excludes from gross income the excludable portion of dividends. Sets forth definitions and rules concerning such exclusion.

Jobs and Growth Reconciliation Tax Act of 2003 - Title I: Acceleration of Certain Previously Enacted Tax Reductions - (Sec. 101) Amends the Internal Revenue Code to increase the 2003, 2004, and 2005 child tax credit to $1,000. Provides for advance payment for 2003. Maintains the 2006, 2007, and 2008 credit at $700.(Sec. 102) Accelerates the increase in the 15 percent bracket for joint filers to twice that of single filers to make such increase applicable to 2003, 2004, and 2005.(Sec. 103) Accelerates the increase in the standard deduction for joint filers to twice that of single filers to make such increase applicable to 2003, 2004, and 2005.(Sec. 104) Revises the expansion of the 10 percent bracket for married taxpayers filing jointly scheduled to increase from $12,000 to $14,000 in 2008 as follows: (1) $14,000 through 2005; (2) $12,000 for 2006 and 2007; and (3) $14,000 for 2008 and beyond. Revises inflation adjustment provisions.(Sec. 105) Accelerates to 2003 individual income tax rate reductions scheduled to begin in 2006.(Sec. 106) Increases the $49,000 and $35,750 alternative minimum tax exemption amounts to $64,000 and $43,250, respectively.Title II: Growth Incentives for Business - (Sec. 201) Revises provisions concerning the special allowance for certain property acquired after September 10, 2001, and before September 11, 2004, with respect to certain property the original use of which commenced after May 5, 2003, to increase the 30 percent bonus to 50 percent and extend the placed in service date through January 1, 2006 (2007, in certain cases).(Sec. 202) Increases the expensing allowance to $100,000 and the phaseout limit to $400,000 for 2003 through 2007. Provides inflation adjustments.(Sec. 203) Increases the net operating loss carryback period from two to five years and extends it from 2002 through 2005.Title III: Reduction in Taxes on Dividends and Capital Gains - (Sec. 301) Reduces, for the regular and alternative minimum tax, the 10 and 20 percent adjusted net capital gain rates to 5 and 15 percent, respectively, with transition rules for years that include May 6, 2003.(Sec. 302) Provides, for the regular and alternative minimum tax, for the taxation of dividends received by an individual from domestic corporations at net capital gain rates.(Sec. 303) Makes the provisions of this title effective through 2012.Title IV: Corporate Estimated Tax Payments for 2003 - (Sec. 401) States that, notwithstanding Code provisions concerning failure to pay corporate estimated taxes, 52 percent of the amount of any required installment of corporate estimated tax which is otherwise due in September 2003 shall not be due until October 1, 2003.

(This measure has not been amended since it was reported to the House on May 8, 2003. The summary of that version is repeated here.)Jobs and Growth Reconciliation Tax Act of 2003 - Title I: Acceleration of Certain Previously Enacted Tax Reductions - (Sec. 101) Amends the Internal Revenue Code to increase the 2003, 2004, and 2005 child tax credit to $1,000. Provides for advance payment for 2003. Maintains the 2006, 2007, and 2008 credit at $700.(Sec. 102) Accelerates the increase in the 15 percent bracket for joint filers to twice that of single filers to make such increase applicable to 2003, 2004, and 2005.(Sec. 103) Accelerates the increase in the standard deduction for joint filers to twice that of single filers to make such increase applicable to 2003, 2004, and 2005.(Sec. 104) Revises the expansion of the 10 percent bracket for married taxpayers filing jointly scheduled to increase from $12,000 to $14,000 in 2008 as follows: (1) $14,000 through 2005; (2) $12,000 for 2006 and 2007; and (3) $14,000 for 2008 and beyond. Revises inflation adjustment provisions.(Sec. 105) Accelerates to 2003 individual income tax rate reductions scheduled to begin in 2006.(Sec. 106) Increases the $49,000 and $35,750 alternative minimum tax exemption amounts to $64,000 and $43,250, respectively.Title II: Growth Incentives for Business - (Sec. 201) Revises provisions concerning the special allowance for certain property acquired after September 10, 2001, and before September 11, 2004, with respect to certain property the original use of which commenced after May 5, 2003, to increase the 30 percent bonus to 50 percent and extend the placed in service date through January 1, 2006 (2007, in certain cases).(Sec. 202) Increases the expensing allowance to $100,000 and the phaseout limit to $400,000 for 2003 through 2007. Provides inflation adjustments.(Sec. 203) Increases the net operating loss carryback period from two to five years and extends it from 2002 through 2005.Title III: Reduction in Taxes on Dividends and Capital Gains - (Sec. 301) Reduces, for the regular and alternative minimum tax, the 10 and 20 percent adjusted net capital gain rates to 5 and 15 percent, respectively, with transition rules for years that include May 6, 2003.(Sec. 302) Provides, for the regular and alternative minimum tax, for the taxation of dividends received by an individual from domestic corporations at net capital gain rates.(Sec. 303) Makes the provisions of this title effective through 2012.Title IV: Corporate Estimated Tax Payments for 2003 - (Sec. 401) States that, notwithstanding Code provisions concerning failure to pay corporate estimated taxes, 52 percent of the amount of any required installment of corporate estimated tax which is otherwise due in September 2003 shall not be due until October 1, 2003.

Jobs and Growth Tax Relief Reconciliation Act of 2003 - Title I: Acceleration of Certain Previously Enacted Tax Reductions - (Sec. 101) Amends the Internal Revenue Code to accelerate the increase to the $1,000 child tax credit to include 2003 and 2004. Maintains the levels and the sunset established under the Economic Growth and Tax Reconciliation Act of 2001 (EGTRRA) for years following.Provides for advance payment for 2003.(Sec. 102) Accelerates the increase in the 15 percent bracket for joint filers to twice that of single filers to make such increase applicable to 2003 and 2004. Maintains the levels and the sunset established under EGTRRA for years following.(Sec. 103) Accelerates the increase in the standard deduction for joint filers to twice that of single filers to make such increase applicable to 2003 and 2004. Maintains the levels and the sunset established under EGTRRA for years following.(Sec. 104) Revises the expansion of the 10 percent bracket for married taxpayers filing jointly scheduled to increase from $12,000 to $14,000 in 2008 as follows: (1) $14,000 through 2004; and (2) $12,000 for 2005 through 2007. Maintains the levels and the sunset established under EGTRRA for years following. Revises inflation adjustment provisions.(Sec. 105) Accelerates to 2003 individual income tax rate reductions scheduled to begin in 2006. Maintains that level and the sunset established under EGTRRA for years following.(Sec. 106) Increases the $49,000 (for 2001 through 2004) and $35,750 (for 2001 through 2004) alternative minimum tax exemption amounts to $58,000 (for 2003 and 2004) and $40,250 (for 2003 and 2004), respectively.(Sec. 107) Establishes that the sunset provisions of EGTRRA apply to this title.Title II: Growth Incentives for Business - (Sec. 201) Revises provisions concerning the special allowance for certain property acquired after September 10, 2001, and before September 11, 2004, with respect to certain property the original use of which commenced after May 5, 2003, to increase the 30 percent bonus to 50 percent and extend the placed in service date through January 1, 2005 (2006, in certain cases).(Sec. 202) Increases the $25,000 expensing allowance to $100,000 for 2003 through 2005, the $200,000 phaseout limit to $400,000 for 2003 through 2005, and includes off-the-shelf computer software placed in service in 2003 through 2005 as qualifying property. Provides for inflation adjustments.Title III: Reduction in Taxes on Dividends and Capital Gains - (Sec. 301) Reduces, for the regular and alternative minimum tax, the 10 and 20 percent adjusted net capital gain rates to 5 (zero percent in 2008) and 15 percent, respectively, for taxable years beginning on or after May 6, 2003, with transition rules for years that include May 6, 2003.(Sec. 302) Provides, for the regular and alternative minimum tax, for the taxation of dividends received by an individual from domestic corporations at net capital gain rates. Includes as qualified dividend income dividends from qualified foreign corporations (foreign corporations incorporated in the United States or certain corporations eligible for benefits of a comprehensive tax treaty with the United States).(Sec. 303) Sunsets provisions of this title December 31, 2008. Title IV: Temporary State Fiscal Relief - (Sec. 401) Provides $10 billion for State and local government assistance and $10 billion for Medicaid assistance through September 30, 2004. Amends the Social Security Act to add a new title, Temporary State Fiscal Relief. Title V: Corporate Estimated Tax Payments for 2003 - (Sec. 501) Requires payment of 25 percent of September 2003 corporate estimated taxes by October 1, 2003.

Jobs and Growth Tax Relief Reconciliation Act of 2003 - Title I: Acceleration of Certain Previously Enacted Tax Reductions - (Sec. 101) Amends the Internal Revenue Code to accelerate the increase to the $1,000 child tax credit to include 2003 and 2004. Maintains the levels and the sunset established under the Economic Growth and Tax Reconciliation Act of 2001 (EGTRRA) for years following.Provides for advance payment for 2003.(Sec. 102) Accelerates the increase in the 15 percent bracket for joint filers to twice that of single filers to make such increase applicable to 2003 and 2004. Maintains the levels and the sunset established under EGTRRA for years following.(Sec. 103) Accelerates the increase in the standard deduction for joint filers to twice that of single filers to make such increase applicable to 2003 and 2004. Maintains the levels and the sunset established under EGTRRA for years following.(Sec. 104) Revises the expansion of the 10 percent bracket for married taxpayers filing jointly scheduled to increase from $12,000 to $14,000 in 2008 as follows: (1) $14,000 through 2004; and (2) $12,000 for 2005 through 2007. Maintains the levels and the sunset established under EGTRRA for years following. Revises inflation adjustment provisions.(Sec. 105) Accelerates to 2003 individual income tax rate reductions scheduled to begin in 2006. Maintains that level and the sunset established under EGTRRA for years following.(Sec. 106) Increases the $49,000 (for 2001 through 2004) and $35,750 (for 2001 through 2004) alternative minimum tax exemption amounts to $58,000 (for 2003 and 2004) and $40,250 (for 2003 and 2004), respectively.(Sec. 107) Establishes that the sunset provisions of EGTRRA apply to this title.Title II: Growth Incentives for Business - (Sec. 201) Revises provisions concerning the special allowance for certain property acquired after September 10, 2001, and before September 11, 2004, with respect to certain property the original use of which commenced after May 5, 2003, to increase the 30 percent bonus to 50 percent and extend the placed in service date through January 1, 2005 (2006, in certain cases).(Sec. 202) Increases the $25,000 expensing allowance to $100,000 for 2003 through 2005, the $200,000 phaseout limit to $400,000 for 2003 through 2005, and includes off-the-shelf computer software placed in service in 2003 through 2005 as qualifying property. Provides for inflation adjustments.Title III: Reduction in Taxes on Dividends and Capital Gains - (Sec. 301) Reduces, for the regular and alternative minimum tax, the 10 and 20 percent adjusted net capital gain rates to 5 (zero percent in 2008) and 15 percent, respectively, for taxable years beginning on or after May 6, 2003, with transition rules for years that include May 6, 2003.(Sec. 302) Provides, for the regular and alternative minimum tax, for the taxation of dividends received by an individual from domestic corporations at net capital gain rates. Includes as qualified dividend income dividends from qualified foreign corporations (foreign corporations incorporated in the United States or certain corporations eligible for benefits of a comprehensive tax treaty with the United States).(Sec. 303) Sunsets provisions of this title December 31, 2008. Title IV: Temporary State Fiscal Relief - (Sec. 401) Provides $10 billion for State and local government assistance and $10 billion for Medicaid assistance through September 30, 2004. Amends the Social Security Act to add a new title, Temporary State Fiscal Relief. Title V: Corporate Estimated Tax Payments for 2003 - (Sec. 501) Requires payment of 25 percent of September 2003 corporate estimated taxes by October 1, 2003.

Jobs and Growth Tax Relief Reconciliation Tax Act of 2003 - Title I: Acceleration of Certain Previously Enacted Tax Reductions; Increased Expensing for Small Businesses - (Sec. 101) Amends the Internal Revenue Code to accelerate, from 2008 to 2003, the expansion, from $12,000 to $14,000, of the 10 percent bracket for married taxpayers filing jointly.Revises inflation adjustment provisions and makes them effective in 2004.(Sec. 102) Accelerates, to 2003, individual income tax rate reductions scheduled to begin in 2006.(Sec. 103) Increases, for individuals, the alternative minimum tax exemption amounts for 2003, 2004, and 2005.(Sec. 104) Accelerates, to 2003, the increase in the standard deduction for joint filers to twice that of single filers.(Sec. 105) Accelerates, to 2003, the increase in the 15 percent bracket for joint filers to twice that of single filers.(Sec. 106) Accelerates, to 2003, the increase to the $1,000 child tax credit.(Sec. 107) Increases the expensing allowance to $75,000, the phaseout limit to $325,000, and provides for inflation adjustments. Permits the expensing of off-the-shelf computer software.(Sec. 108) States the each amendment made by this title (other than section 107) shall be subject to title IX (Compliance with the Congressional Budget Act) of the Economic Growth and Tax Relief Reconciliation Act of 2001 to the same extent and in the same manner as the provision of such Act to which such amendment relates.Title II: Partial Exclusion of Dividends - (Sec 201) Excludes up to $500 of qualified dividend income on a joint return ($250 on an individual return), plus 10 percent (20 percent after 2007) of such income in excess of such amount from gross income.Title III: Revenue Provisions - Subtitle A: Provisions Designed to Curtail Tax Shelters - (Sec. 301) Sets forth rules for use in applying the economic substance doctrine, including defining economic substance.(Sec. 302) Imposes penalties on individuals who fail to include on any return or statement required information regarding reportable transactions (transactions needing a return or statement because the Secretary determines they have a potential for tax avoidance or evasion). Authorizes the Commissioner of Internal Revenue to rescind all or any portion of such penalties under certain specified conditions.(Sec. 303) Prescribes an accuracy related civil penalty of 20 percent (or higher in certain specified cases) of the amount of any reportable transaction understatement for such understatement (with exceptions). Specifies a formula for determining such figure. Provides for coordination with penalties on other understatements, including prohibiting penalties under this section from applying to the penalty for fraud.(Sec. 304) Imposes a penalty of 40 percent (20 percent, if there has been adequate disclosure) of the understatement for a noneconomic substance transaction understatement.(Sec. 305) Modifies the substantial understatement penalty for nonreportable transactions in the cases of corporations other than an S corporation or a personal holding company.(Sec. 306) Expands the scope of provisions that do not give the confidentiality privilege to communications between a corporation and its tax practitioner concerning tax shelters to make such provisions applicable to communications (with respect to tax shelters) between any taxpayer and the taxpayer's tax practitioner.(Sec. 307) Directs a material advisor, with respect to any reportable transaction, to make a return (in such form as the Secretary may prescribe) describing the transaction, its potential tax benefits, and other information prescribed by the Secretary. Defines material advisor as any person who provides material aid, assistance or advice regarding a reportable transaction and who derives gross income in excess of a specified threshold amount. Authorizes the Secretary to prescribe exemptions from such requirements.(Sec. 308) Modifies the monetary penalty and revises provisions for failing to register a tax shelter with the Secretary. Allows the Commissioner to rescind such penalties.(Sec. 309) Modifies the penalty levied on material advisors for failure to furnish required information regarding reportable transactions to the Secretary.(Sec. 310) Revises provisions authorizing a civil action in the name of the United States to enjoin promoters of abusive tax shelters.(Sec. 311) Amends provision dealing with understatement of a taxpayer's liability by an income tax preparer, including to raise the amount of the penalty for such an offense.(Sec. 312) Amends provisions of Federal law pertaining to a civil penalty for violations concerning records and reports on foreign financial agency transactions to authorize the Secretary to impose a penalty of up to $5,000 in cases not involving willful violations (presently the maximum is $100,000 and applies to willful violations). Sets forth an exemption under specified circumstances. Permits a penalty of between $25,000-$100,000 in instances of willful violation, with no exemption. Specifies criteria for calculating the amount of such penalties.(Sec. 313) Modifies prohibition of filing a frivolous tax return, and increases the amount of the civil penalty for committing such an offense. Imposes a civil penalty for a specified frivolous submissions (to be waived if such submission is withdrawn within 30 days). Allows the Secretary to reduce penalties for frivolous submissions.(Sec. 314) Penalizes an individual for making a statement with respect to certain tax statements (deductions, credits, and etc.) that an individual knows is false or fraudulent as to any material matter at the rate of 50 percent of the gross income derived from such activity.(Sec. 315) Permits, with respect to the failure to include any information with respect to a listed (tax avoidance) transaction, tax assessment at any time within six years after the filing of the related return.(Sec. 316) Prohibits the deduction for interest paid on any underpayment of tax attributable to nondisclosed reportable transaction and noneconomic substance transaction understatements.Subtitle B: Enron-Related Tax Shelter Provisions - (Sec. 321) Limits the basis of certain corporate property acquired by the issuance of stock or as paid-in surplus and for which there is the importation of net built-in loss to the property's fair market value immediately after the transfer of such property.(Sec. 322) Prohibits an allocation of any decrease in the adjusted basis of partnership property to stock in a corporation which is a partner in the partnership.(Sec. 323) Repeals part V (Financial Asset Securitization Investment Trusts) of subchapter M (Regulated Investment Companies and Real Estate Investment Trusts).(Sec. 324) Expands the definition of a disqualified debt instrument with respect to deduction disallowance on certain debt instruments of corporations.(Sec. 325) Expands the authority to disallow deductions, credits, or other allowances under provisions disallowing such benefits due to acquisitions made to evade or avoid income tax.(Sec. 326) Amends provisions affecting passive foreign investment companies to state that the term "qualified portion" (of a shareholder's holding period) does not include any period if there is only a remote likelihood of an inclusion in gross income under subpart F (Controlled Foreign Income).(Sec. 327) Adds to the definition of the term "real estate investment trust" by stating that such term includes a corporation, trust, or association which is not a controlled entity.Subtitle C: Other Corporate Governance Provisions - Part I: General Provisions - (Sec. 331) Permits the Secretary of the Treasury, in prescribing regulations governing the tax liability of an affiliated group of corporations making a consolidated return, to prescribe rules applicable to corporations filing consolidated returns that are different from other provisions concerning consolidated returns that would apply if such corporations filed separate returns.(Sec. 332) Requires the signing of corporate tax returns by the chief executive officer.(Sec. 333) Permits an exception to the denial of the deduction for fines paid to allow a deduction for amounts constituting restitution.(Sec. 334) Prohibits a deduction for amounts paid as punitive damages, with exceptions for a wrongful death action and certain other cases.Includes in gross income amounts paid by insurance as punitive damages.(Sec. 335) Increases penalties for fraudulent underpayments or overpayments, attempting to evade or defeat taxes, and fraudulent or false statements.Part II: Executive Compensation Reform - (Sec. 336) Provides for the treatment of creditors claims on nonqualified deferred compensation funded with assets located outside of the United States.(Sec. 337) Includes funded deferred compensation of disqualified (corporate insider) individuals in gross income.(Sec. 338) Prohibits the deferral of gain from the exercise of stock options and restricted stock gains through deferred compensation arrangements.(Sec. 339) Increases the withholding from supplemental wage payments in excess of $1 million.Subtitle D: International Provisions - Part I: Provisions to Discourage Expatriation - (Sec. 340) Revises IRC expatriation tax provisions.States that all property of a "covered expatriate" (a U.S. citizen who relinquishes citizenship, or a long-term U.S. resident who ceases to be a lawful permanent resident or who commences foreign residency under the provisions of a tax treaty) shall be treated as sold on the day before the "expatriation date" for its fair market value, and that gain (in excess of $600,000) and loss shall be taken into account for the taxable year of the sale (with subsequent adjustment). Permits an individual to defer payments of the additional tax imposed by such deemed sale (but not beyond such person's death). Sets forth interest provisions. Requires provision of tax payment security.Exempts certain U.S. citizens from being treated as a covered expatriate who: (1) became a citizen of the United States and another country at birth; or (2) relinquished U.S. citizenship before reaching 18 and 1/2 years old.Permits an individual to make an irrevocable decision to be taxed as a U.S. citizen with respect to all property otherwise covered by the expatriation provisions. Requires an individual to: (1) furnish tax payment security; and (2) waive any rights under U.S. treaties that would preclude assessment or collection of relevant tax.Excludes certain U.S. real property interests from the provisions of this Act. Subjects the following retirement plans to the provisions of this Act: (1) qualified retirement plans, including specified annuity plans and individual retirement accounts; (2) specified deferred compensation plans; and (3) foreign retirement or pension plans.Establishes special rules for covered expatriates' interests in trusts and qualified trusts.Includes in a recipient's gross income the value of property received by gift or bequest from a covered expatriate, with exceptions for transfers otherwise subject to estate or gift tax. Makes such provisions applicable to gifts and bequests received on or after February 5, 2003, from an individual whose expatriation date occurs after such date.Makes such expatriate tax provisions, unless otherwise provided for by this Act, effective on or after February 5, 2003.Amends the Immigration and Nationality Act to deny a former citizen reentry into the United States for noncompliance with the provisions of this title. (Current law denies reentry based upon tax-motivated expatriation.) Permits IRS-Immigration and Naturalization Service information sharing for such purpose. Makes such provisions effective upon enactment of this Act.(Sec. 341) Treats a foreign incorporated entity treated as an inverted domestic corporation as a domestic corporation.(Sec. 342) Imposes on an individual who is a disqualified individual with respect to any inverted corporation a tax equal to 20 percent of the value of the specified stock compensation held (directly or indirectly) by or for the benefit of such individual or a member of such individual's family at any time during the 12-month period beginning on the date which is 6 months before the inversion date.(Sec. 343) Revises provisions relating to allocation in the case of a reinsurance agreement involving tax avoidance or evasion.Part II: Other Provisions - (Sec. 344) Provides, as a general rule, that if: (1) a taxpayer eligible to participate in the Department of the Treasury's Offshore Voluntary Compliance Initiative did not participate in such initiative; and (2) any interest or applicable penalty is imposed with respect to any arrangement to which such initiative applied or to any underpayment of Federal income tax attributable to items arising in connection with such arrangement, then, notwithstanding any other provision of law, the amount of such interest or penalty shall be equal to twice that determined without regard to this section.(Sec. 345) Includes certain foreign source income as effectively connected income.(Sec. 346) Sets forth a rule for determining the basis of amounts paid from foreign pension plans.(Sec. 347) Sets forth a rule concerning the recapture of overall foreign losses on the sale of controlled foreign corporations.(Sec. 348) Establishes a special rule to prevent the mismatching of interest and original issue discount deductions and income inclusion transactions with related foreign persons.(Sec. 349) Amends the Tariff Act of 1930 concerning the sale of gasoline and diesel fuel at duty-free sales enterprises.(Sec. 350) Repeals the earned income exclusion of citizens or residents living abroad.Subtitle E: Other Revenue Provisions - (Sec. 351) Directs the Secretary to establish a program requiring the payment of user fees, until September 30, 2013, for: (1) requests to the Internal Revenue Service for ruling letters, opinion letters, and determination letters; and (2) other similar requests.(Sec. 352) Includes any vaccine against hepatitis A under the 75-cents-per-dose manufacturer's excise tax.(Sec. 353) Provides for the treatment of property contributed to a partnership with a built-in loss. Permits the adjustment to the basis of undistributed partnership property if there is a substantial basis reduction.(Sec. 354) Permits the application of stripped preferred stock rules and stripped bond rules in the case of an account or entity substantially all of the assets of which consist of bonds, preferred stock, or combination thereof.(Sec. 355) Requires a corporation making a taxable acquisition to report specified information.(Sec. 356) Establishes a minimum holding period for withholding tax on gain and income other than dividends in order to claim the foreign tax credit.(Sec. 357) Permits the IRS to enter into qualified tax collection contracts.(Sec. 358) Extends the authority for customs user fees through December 31, 2013.(Sec. 359) Increases from $350,000 to $600,000 the maximum amount of premiums that may be written annually by a tax-exempt insurance company (other than a life insurance company) in order to remain tax-exempt.(Sec. 360) Authorizes the IRS to enter into partial payment installment agreements with taxpayers. Requires review of such agreements at least every two years.(Sec. 361) Permits (currently, prohibits) the amortization of intangibles by sports franchises.(Sec. 362) Permits making a cash deposit to suspend the running of interest on potential underpayments.(Sec. 363) Revises provisions concerning the treatment of certain stock purchases as asset acquisitions and the tax on a deemed sale not being taken into account for estimated tax purposes.(Sec. 364) Limits a charitable deduction with respect to any patent, copyright, trademark, trade name, trade secret, know-how, software, or similar property, or applications or registrations of such property.(Sec. 365) Extends provisions (including ERISA provisions) permitting the transfers of excess pension assets to retiree health accounts for eight additional years.(Sec. 366) Revises rules concerning the taxable income insurance companies.(Sec. 367) Modifies rules concerning the treatment of transfers to creditors in divisive reorganizations.(Sec. 368) Increases from under 14 to under 18 the age of minor children whose unearned income is taxed at the parent's taxation rate.(Sec. 369) Modifies provisions concerning start-up and organizational expenditures.(Sec. 370) Modifies the definition of nonqualified preferred stock.(Sec. 371) Assigns, for depreciation purposes, a class life for electric utility (20 years) and gas utility (15 years) clearing and grading costs (Sec. 372) Treats as dividend distributions earnings by certain U.S. holding companies to a completely liquidated foreign corporation.(Sec. 373) Sets forth, with respect to depreciation, a special rule concerning certain service contract lease terms.(Sec. 374) Makes the exclusion for gain on the sale of a principal residence inapplicable if the principal residence was acquired in a like-kind exchange in which the gain was not recognized within the required five year period.Subtitle F: Other Provisions - (Sec. 381) Authorizes appropriations, through December 31, 2004, to States for: (1) improving education or job training; (2) improving health care services; (3) improving transportation or other infrastructure; (4) improving law enforcement or public safety; and (5) maintaining essential government services.Provides for increased Medicaid payments to States through December 31, 2004.(Sec. 382) Amends title XVI (Supplemental Security Income of the Social Security Act to require the Commissioner of Social Security to review State agency blindness and disability determinations.(Sec. 383) Amends title XXI (State Children's Health Insurance Program) (SCHIP) of the Social Security Act to prohibit the use of SCHIP funds to provide coverage to childless adults, except for pregnant women.(Sec. 384) Increases, temporarily, the cap on Medicaid payments to extremely low DSH (Disproportionate Share Hospitals) States.Title IV: Small Business and Agricultural Provisions - Subtitle A: Small Business Provisions - (Sec. 401) Modifies the debt-financed property provisions by excluding from the definition of acquisition indebtedness any indebtedness incurred by a small business investment company licensed under the Small Business Investment Act of 1958 that is evidenced by a debenture: (1) issued by such company under such Act, or (2) held or guaranteed by the Small Business Administration.(Sec. 402) Repeals the special occupational taxes on producers and marketers of alcoholic beverages.(Sec. 403) Exempts a person who manufactures, produces, and imports fewer than 50 firearms per year from the firearms excise tax.(Sec. 404) Revises the excise tax provisions on bows, arrows, and other archery equipment, including to increase the minimum draw weight for a taxable bow from 10 to 30 pounds.Subtitle B: Agricultural Provisions - (Sec. 411) Provides for the application of capital gain treatment to outright sales of timber whether or not the owner retains economic interest.(Sec. 412) Extends, with respect to involuntary conversion rules, the replacement period, from two to four years, for livestock sold on account of weather related conditions.(Sec. 413) Excludes from gross income amounts received as loan repayments under the Nation Health Service Corps Loan Repayment Program established under the Public Health Service Act.(Sec. 414) Provides that the patronage dividends of cooperatives shall not be reduced by stock dividends to the extent the stock dividends are in addition to amounts otherwise payable.Title V: Simplification and Other Provisions - Subtitle A: Uniform Definition of Child - (Sec. 501) Rewrites the provision defining the term "dependent" in the Code and modifies head of household, dependent care credit, child tax credit, earned income credit, personal exemption, and other provisions to be consistent with such definition.Subtitle B: Simplification - (Sec. 511) Repeals: (1) the provision that a life insurance corporation is not an includible corporation unless the common parent makes an election to treat life insurance companies as includible corporations; and (2) the five-year limitation providing that a life insurance company may not be treated as an includible corporation until it has been a member of the group for the five taxable years immediately preceding the taxable year for which the consolidated return is filed.(Sec. 512) Provides that, for a mutual life insurance company's taxable years beginning after December 31, 2003, and before January 1, 2009, the differential earnings rate is treated as zero for purposes of computing both the differential earnings amount and the recomputed differential earnings amount, under the rules requiring reduction in certain deductions of mutual life insurance companies.(Sec. 513) Modifies the active business definition by determining the active business test by reference to the relevant affiliated group.Subtitle C: Other Provisions - (Sec. 521) Allows a deduction for attorneys' fees and costs paid in connection with a claim of unlawful discrimination or certain claims against the Federal Government.(Sec. 522) Doubles, for 2004 and 2005, the amount of the section 382 limitation (the limitation on net operating loss carry forwards and certain built-in losses following ownership change) applicable to corporations that experience an ownership change emerging from a bankruptcy or a similar case.(Sec. 523) Increases the historic rehabilitation credit from 20 to 25 percent for certain low-income housing for the elderly.(Sec. 524) Modifies rules concerning the application of the income forecast method of depreciation.(Sec. 525) Permits a second or third advance refunding of bonds if the original bond was issued to finance governmental facilities used for a public elementary or secondary school in any State in which the Sate's highest court ruled by opinion issued on November 21, 2002, that the Sate school funding system violated the State constitution and was constitutionally inadequate.(Sec. 526) Excludes from "gross income" income derived by a nonresident alien individual from a legal wagering transaction initiated outside the United States in a parimutuel pool with respect to a live horse race in the United States.(Sec. 527) Appropriates $48,000,000 for FY 2004 for allotments to States for reimbursement of emergency health services furnished to undocumented aliens.(Sec. 528) Allows the deduction of premiums for mortgage insurance. Provides for the phaseout of such deduction based on income.(Sec. 529) Expresses the sense of the Senate that the Senate Finance Committee should report out the Social Security Benefits Tax Relief Act of 2003, S. 514, to repeal the tax on seniors not later than July 31, 2003, and the Senate shall consider such bill not later than September 30, 2003, in a manner consistent with the preservation of the Medicare Trust Fund.(Sec. 530) Expresses the sense of the Senate that the Senate Finance Committee and the Joint Economic Committee should undertake a comprehensive analysis of simplification including flat tax proposals, including appropriate hearings and consider legislation providing for a flat tax.(Sec. 531) Permits certain distributions received by a U.S. corporation from a controlled foreign corporation to be taxed at 5.25 percent.Repeals the 10 percent rehabilitation tax credit for buildings placed in service before 1936.(Sec. 532) Includes unpaid child support in the gross income of the delinquent debtor.(Sec. 533) Expresses the sense of the senate that any reduction or elimination of the taxation on dividends should include provisions to preserve the success of the low-income housing tax credit.(Sec. 534) Permits a taxpayer to elect to treat any qualified broadband expenditure which is paid or incurred by the taxpayer as an expense which is not chargeable to capital account and any expenditure which is so treated shall be allowed as a deduction.(Sec. 535) Establishes a credit for wholesale distributors, distillers, and importers of distilled spirits for the financing costs of the federal excise tax on such spirits.(Sec. 536) Defines the term "contribution in aid of construction" for water and sewage disposal utilities.(Sec. 537) Repeals the provision prohibiting the deduction of travel expenses for spouses and dependents accompanying a taxpayer.(Sec. 538) Exempts small sightseeing aircraft from the air travel transportation tax.(Sec. 539) Requires a group health plan providing medical and surgical benefits with respect to a mastectomy to provide coverage for reconstructive surgery following a mastectomy.(Sec. 540) Permits the expansion of a designated renewal community area.(Sec. 541) Permits renewal community employers to qualify for the credit by employing certain residents of another renewal community if the other community is within the five miles and within the same State.(Sec. 542) Treats direct transit to a combat zone as service in a combat zone for purposes of the combat zone tax exclusion.(Sec. 543) Treats service at Guantanamo at Guantanamo Bay Naval Station, Cuba, and service performed on the Island of Diego Garcia as part of Operation Iraqi Freedom, and treats such service in the same manner as if such services were in a combat zone.(Sec. 544) Allows taxpayers to take citrus canker tree replacement payments into account as income or gain ratably over the ten-year period beginning with the taxable year in which the taxpayer receives or accrues the payment.(Sec. 545) Excludes from gross income punitive damages paid to a State under a split-award statute.(Sec. 546) Amends the Small Business Job Protection Act of 1986 to provide for the tax treatment of certain imported recycled halons.(Sec. 547) Modifies the involuntary conversion rules for businesses affected by the September 11th terrorist attacks to permit replacement property to be purchased by a member of an affiliated group.Subtitle D: Medicare Provisions - (Sec. 561) Amends title XVIII (Medicare) of the Social Security Act to raise the inpatient base rate for hospitals in rural areas to equal the rate in urban areas.(Sec. 562) Equalizes the Medicare DSH rates for rural and urban hospitals.(Sec. 563) Increases payments to low-volume hospitals.(Sec. 564) Adjusts the Medicare inpatient hospital prospective payment system (PPS) wage index to reduce the labor-related share of the index to 62 percent.(Sec. 565) Extends, for an additional year, the hold harmless provisions affecting rural hospitals from a decline in payment under the OPD (outpatient department services) PPS.(Sec. 566) Permits hospitals to allocate swing beds and acute care inpatient beds subject to a total limit of 25 beds.Eliminates the isolation test for cost-based Medical critical access hospital (CAH) facility ambulance services.(Sec. 567) Extends, temporarily, the 10 percent increase for rural home health services.(Sec. 568) Extends, temporarily, the five percent increase in PPS payments for certain rural hospital outpatient services.(Sec. 569) Extends, temporarily, the five percent increase in rural ground ambulance trips.(Sec. 570) Exempts rural health clinic practitioners providing skilled nursing facility services from certain bill filing requirements.(Sec. 571) Makes revisions to the Medicare Incentive Payment program.(Sec. 572) Extends, temporarily, payment at reasonable for laboratory tests performed in sole community hospitals.(Sec. 573) Establishes physician practice expense and malpractice geographic indices at 1.0.(Sec. 574) Freezes, temporarily, consumer price index updates in payments for durable medical equipment, orthotics, and prosthetics.(Sec. 575) Extends to clinical diagnostic laboratory tests the same coinsurance and deductible rules that apply to other part B (Supplementary Medical Insurance) services.(Sec. 576) Lowers the amount paid for covered outpatient drugs.(Sec. 577) Makes the sunset provisions of title X of this Act inapplicable to the provisions of this subtitle.Subtitle E: Provisions Relating to S Corporation Reform and Simplification - Part I: Maximum Number of Shareholders of an S Corporation - (Sec. 581) Treats a husband and wife as one shareholder. Permits, and sets forth criteria for, an election to treat all members of a family as one shareholder.(Sec. 582) Increases to 100 the maximum number of shareholders a small business organization may have to be eligible to elect S corporation treatment.(Sec. 583) Allows nonresident aliens as beneficiaries of an electing small business trust.Part II: Termination of Election and Additions to Tax Due to Passive Investment Income - (Sec. 584) Increases, to 60 percent, the 25 percent passive income threshold for S corporations.Excludes capital gain as a category of passive income.Part III: Treatment of S Corporation Shareholders - (sec. 585) Provides for the treatment of suspended losses incident to a divorce.(Sec. 586) Allows the beneficiary of a qualified S trust suspended losses under the at-risk and passive loss rules upon disposition of the stock.(Sec. 587) Disregards the unexercised powers of appointment in determining the beneficiaries of an electing small business trust.(Sec. 588) Revises electing small business trust distribution rules.Part IV: Provisions Relating to Banks - (Sec. 589) Exempts from prohibited transaction rules the sale of IRA stock held in trust.(Sec. 590) Excludes interest and dividends from the passive income test for bank S corporations.(Sec. 591) Provides for the treatment of qualifying director shares.Part V: Qualified Subchapter S Subsidiaries - (Sec. 592) Allows inadvertent qualified subchapter S subsidiary elections and terminations to be waived by the IRS.(Sec. 593) Provides authority with respect to information returns of wholly owned subsidiaries.Part VI: Additional Provisions - (Sec. 594) Eliminates all accumulated earnings and profits of a corporation accumulated in a taxable year beginning before 1983 for which the corporation was an electing small business corporation under subchapter S.Title VI: Blue Ribbon Commission on Comprehensive Tax Reform - (Sec. 601) Fundamental Tax Reform Commission Act of 2003 - Establishes the Blue Ribbon Commission on Comprehensive Tax Reform to: (1) conduct a thorough study of all matters relating to a comprehensive reform of the Federal tax system, including the reform of the Internal Revenue Code and the implementation (if appropriate) of other types of tax systems; (2) develop recommendations on how to comprehensively reform the Federal tax system in a manner that generates appropriate revenue for the Federal Government; and (3) issue a report. Terminates the Commission after issuance of the report. Authorizes appropriations.Title VII: Real Estate Investment Trusts - Subtitle A: REIT Corrections - (Sec. 701) Modifies REIT rules concerning: (1) straight debt; (2) the limited rental exception; (3) the customary services exception relating to redetermined rents; (4) the treatment of certain hedging instruments; (5) the 90 percent gross income test; and (6) prohibited transactions relating to timberland sales. Subtitle B: REIT Savings Provisions - (sec. 711) Revises REIT rules concerning income and asset requirements and permits exceptions to such requirements if there is reasonable cause, specified corrective actions are taken, and a specified tax is paid. Title VIII: Extensions of Certain Expiring Provisions - Subtitle A: Extensions of Expiring Provisions - (Sec. 801) Extends, for one year, provisions concerning: (1) parity in the application of certain limits to mental health benefits; (2) the allowance of nonrefundable personal credits against regular and minimum tax liability; (3) the credit for electricity produced from certain nonrenewable sources; (3) the work opportunity credit; (5) the welfare-to-work credit; (6) the income limit on percentage depletion for oil and gas produced from marginal wells; (7) qualified zone academy bonds; (8) the cover over of the tax on distilled spirits; (9) the deduction for corporate donations of computer technology; (10) the credit for qualified electric vehicles; (11) the deduction for clean-fuel vehicles and certain refueling property; (12) the deduction of school teacher's expenses; (13) medical savings accounts; and (14) the expensing of environmental remediation costs. Title IX: Improving Tax Equity for Military Personnel - Armed Forces Tax Fairness Act of 2003 - (Sec. 901) Authorizes a member of the uniformed services or the Foreign Service serving on "qualified official extended duty" (any duty in excess of 90 days while serving at a duty station which is at least 50 miles from the principal residence or while residing under Government orders in Government quarters), to extend for ten years the five-year period utilized in determining full exclusion of gain from the sale of a principal residence.Includes among the uniformed services: (1) the armed forces; (2) the commissioned corps of the National Oceanic and Atmospheric Administration; and (3) the commissioned corps of the Public Health Service.Makes such provisions effective as if included in section 312 of the Taxpayer Relief Act of 1997.States that if a refund or credit resulting from this section is prevented before the close of the one-year period beginning on the date of the enactment of this Act by the operation of any law or rule of law (including res judicata), such refund or credit may be allowed if claimed before the close of such period.(Sec. 902) Excludes from gross income as a qualified military benefit the amount of the death gratuity payable under chapter 75 of title 10 of the United States Code, effective with respect to deaths occurring after September 10, 2001.(Sec. 903) Exempts amounts received under the Homeowners Assistance Program from inclusion as gross income.(Sec. 904) Extends combat zone filing rules to contingency operations.(Sec. 905) Includes ancestors or lineal descendants of past or present members of the armed forces or of cadets as qualifying members of veterans' organizations for purposes of such organizations' tax-exempt status determination.(Sec. 906) Includes dependent care assistance provided under a dependent care assistance program for a member of the uniformed services by reason of such member's status or service as an income-excludable qualified military benefit.(Sec. 907) Exempts distributions from an education individual retirement account from the ten percent additional tax for non-educational use: (1) if made for an account holder at the United States Military Academy, the United States Naval Academy, the United States Air Force Academy, the United States Coast Guard Academy, or the United States Merchant Marine Academy; and (2) to the extent that the distribution does not exceed the costs of advanced education.(Sec. 908) Suspends the tax-exempt status of a designated terrorist organization (as defined by this Act). Denies: (1) deductions for contributions made to such an organization; and (2) administrative or judicial challenge to such suspension or denial. Provides for refund or credit in a case of erroneous designation.(Sec. 909) Provides a deduction for itemizers and non-itemizers for unreimbursed overnight travel, meals, and lodging expenses of National Guard and Reserve members who must travel more than 100 miles away from home and stay overnight as part of their official duties.(Sec. 910) Provides tax relief for families of the Columbia Space Shuttle by making the tax relief provisions applicable to terrorist attack victims applicable to the Columbia Space Shuttle.Title X: Sunset - (Sec. 1001) Provides that, except for title I (other than section 107) and title III (other than section 362), the provisions of, and amendments made, by this Act shall not apply to taxable years beginning after December 31, 2012, and the Internal Revenue Code shall be applied and administered to such years as if such amendments had never been enacted.