ELIMINATION OF INTEREST RATE DIFFERENTIAL ON OVERLAPPING PERIODS OF INTEREST ON TAX OVERPAYMENTS AND UNDERPAYMENTS.

SEC. 3301. ELIMINATION OF INTEREST RATE DIFFERENTIAL ON OVERLAPPING PERIODS OF INTEREST ON TAX OVERPAYMENTS AND UNDERPAYMENTS. (a) In General.— Section 6621 (relating to determination of rate of interest) is amended by adding at the end the following new subsection: “(d) Elimination of Interest on Overlapping Periods of Tax Overpayments and Underpayments.— To the extent that, for any period, interest is payable under subchapter A and allowable under subchapter B on equivalent underpayments and overpayments by the same taxpayer of tax imposed by this title, the net rate of interest under this section on such amounts shall be zero for such period.”. (b) Conforming Amendment.— Subsection (f) of section 6601 (relating to satisfaction by credits) is amended by adding at the end the following new sentence: “The preceding sentence shall not apply to the extent that section 6621(d) applies.”. (c) Effective Dates.— (1) In general.— Except as provided under paragraph (2), the amendments made by this section shall apply to interest for periods beginning after the date of the enactment of this Act. (2) Special rule.— The amendments made by this section shall apply to interest for periods beginning before the date of the enactment of this Act if the taxpayer— (A) reasonably identifies and establishes periods of such tax overpayments and underpayments for which the zero rate applies; and (B) not later than December 31, 1999, requests the Secretary of the Treasury to apply section 6621(d) of the Internal Revenue Code of 1986, as added by subsection (a), to such periods.