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Abstract: 

The Tax Increase Prevention and Reconciliation Act of 2005 initially looked as if it would be a major overhaul of some parts of the tax system. It even looked for a time as if there might be a legislative definition of “economic substance.” A number of provisions that expired in 2005 were expected to be extended, but were not. Perhaps a technical corrections bill will follow, or perhaps some provisions near and dear to certain Congressional hearts will be added to a pension reform bill that is, as of this writing, under consideration. A complete list of the Code’s provisions, the Internal Revenue Code sections they modify, and their general effect, is provided. A comparison with the committee reports shows that many ideas were dropped towards the end of the legislative process, some of which will undoubtedly surface in 2007, if not before.

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