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Treas. HJ 10 .A13P4 v. 214 U. S. Dept. of|Treasury. Press releases../ LIBRARY MAR1319Pn TREASURY DEPAftiM epartmentoftheTREASURY tfHINGTON,D.C. 20220 TELEPHONE 566-2041 FOR RELEASE AT 4:00 P.M. May 22, 1978 TREASURY TO AUCTION $2,250 MILLION OF 4-YEAR 1-MONTH NOTES The Department of the Treasury will auction $2,250 million of 4-year 1-month notes to raise new cash. Additional amounts of the notes may be issued to Federal Reserve Banks as agents of foreign and international monetary authorities at the average price of accepted competitive tenders. Details about the new security are given in the attached highlights of the offering and in the official offering circular. oOo Attachment B-933 HIGHLIGHTS OF TREASURY OFFERING TO 'RHE PUBLIC OF 4-YEAR 1-MONTH NOTES TO BE ISSUED JUNE 7, 1978 May 22, 1978 Amount Offered: To the public Description of Security: Term and type of security Series and CUSIP designation $2,250 million 4-year 1-month notes Series H-1982 (CUSIP No. 912827 HU 9) Maturity date June 30, 1982 Call date No provision Interest coupon rate To be determined based on the average of accepted bids Investment yield To be determined at auction Premium or discount To be determined after auction Interest payment dates December 31 and June 30 (first payment on December 31, 1978) Minimum denomination available $1,000 Terms of Sale: Method of sale Yield Auction Accrued interest payable by investor None Preferred allotment Noncompetitive bid for $1,000,000 or less Deposit requirement 5% of face amount Deposit guarantee by designated institutions Acceptable Key Dates: Deadline for receipt of tenders Wednesday, May 31, 1978, by 1:30 p.m., EDST Settlement date (final payment due) a) cash or Federal funds Wednesday, June 7, 1978 b) check drawn on bank within FRB district where submitted Monday, June 5, 1978 c) check drawn on bank outside FRB district where Friday, June 1978 Delivery submitted date for coupon securities. Tuesday, June 2, 13, 1978 Department theTREASURY WASHINGTON, O.C. 20220 TELEPHONE 566-2041 May 22, 1978 FOR IMMEDIATE RELEASE RESULTS OF TREASURY'S WEEKLY BILL AUCTIONS Tenders for $2,200 million of 13-week Treasury bills and for $3,400 million of 26-week Treasury bills, both series to be issued on May 25, 1978, were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: 13-week bills maturing August 24, 1978 Price High Low Average Discount Rate 98.377 a/ 6.421% 98.357 6.500% 98.363 6.476% Investment Rate 1/ 6.62% 6.70% 6.68% 26-week bills maturing November 24, 1978 : Price Discount Rate : 96.395 : 96.365 : 96.370 Investment Rate 1/ 7.092% 7.151% 7.141% 7.46% 7.52% 7.51% a./ Excepting 1 tender of $600,000 Tenders at the low price for the 13-week bills were allotted 18% Tenders at the low price for the 26-week bills were allotted 41% TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTS AND TREASURY: Location Received Accepted Received Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco $ 23,275,000 3,585,530,000 23,690,000 45,680,000 31,140,000 26,410,000 314,880,000 40,705,000 20,450,000 23,045,000 18,745,000 214,790,000 $ 23,275,000 1,831,730,000 23,690,000 40,680,000 21,140,000 26,410,000 69,380,000 16,065,000 20,450,000 23,045,000 18,745,000 77,490,000 $ 44,265,000 4,766,790,000 10,670,000 87,710,000 54,515,000 19,790,000 460,670,000 41,070,000 19,385,000 21,005,000 6,620,000 359,325,000 $ 16,315,000 2,828,190,000 10,670,000 84,760,000 33,515,000 19,790,000 97,720,000 14,070,000 16,385,000 21,005,000 5,620,000 244,985,000 7,950,000 7,950,000 7,210,000 7,210,000 Treasury TOTALS $4,376,290,000 $2,200,050,000b/: $5,899,025,000 V Includes $339,965,000 noncompetitive tenders from the public. J Includes $196,965,000 noncompetitive tenders from the public. 1/Equivalent coupon-issue yield. B-934 Accepted $3,400,235,C-CC-c/ Department of theTREASURY WASHINGTON, D.C. 20220 TELEPHONE 566-2041 FOR RELEASE UPON DELIVERY Expected at 2:00 p.m. May 24, 1978 STATEMENT OF EMIL M. SUNLEY, DEPUTY ASSISTANT SECRETARY OF THE TREASURY FOR TAX POLICY BEFORE THE SUBCOMMITTEE ON OVERSIGHT OF THE HOUSE WAYS AND MEANS COMMITTEE ON EXTENSION OF THE HIGHWAY TRUST FUND Mr. Chairman and Members of this Distinguished Committee: When development of an interstate highway system was being considered in the mid-19501s, the Congress decided to establish a separate funding system for this and other Federal highway aid programs. A trust fund, the Highway Trust Fund, was established with financing from most of the taxes on motoring products — the rates being raised in some cases -- plus two new taxes, that on manufacturers1 sales of tread rubber and an annual use tax on heavy trucks and buses. In accordance with the determination that motorists should pay for Federal highway aid, the Fund contained, and continues to contain, a provision designed to prevent spending of more than the balance in the Fund. Under one clause in the law, the Fund may borrow from the general fund of the Treasury but must repay the advances (with interest). But the provision that actually prevents spending more in a fiscal year than is available during the year is one requiring a reduction in apportionments for the interstate system whenever the Secretary of the Treasury (after consultation with the Secretary of Transportation) decides that amounts that will be available in the Fund, after all other required highway aid expenditures have been made, will be insufficient to pay amounts expected to come due if the full amounts authorized to be appropriated for the interstate system for any fiscal year are apportioned. Under such circumstances, the Secretary of Transportation is then required to reduce the apportionments to the States with respect to the interstate system so as to forestall the estimated deficiency. The reduction in the apportionments is to be made among the States on a pro rata basis. Subsequently, B-935 whenever the Secretary of the Treasury estimates that - 2 Highway Trust Fund balances will become available to pay for apportionments for the interstate highway system which were previously withheld, the amounts previously withheld are to be apportioned by the Secretary of Transportation. The withholding of apportionments only from the interstate system served to protect the Federal aid programs for other roads, such programs having been in effect for many years before the interstate program was added. Federal aid for highways is one area where a user charge system definitely is a responsible method of financing, as the motoring public, including truckers, is the direct beneficiary of the highway aid. But if expenditures are to be met from user charges, a requirement has to be in force which will make certain that expenditures are kept in line with tax funds available for any given year. If expenditures during a year can anticipate future receipts, it is very likely that the practical result will be that the "deficit" will never be made up. The need for maintaining current levels of spending will be advanced as a reason for "delaying" repayment of the debt. H.R. 11733 as reported by the House Public Works Committee authorizes appropriations for Federal highway aid for the fiscal years 1979-1982 which would be considerably in excess of the revenues expected of the Trust Fund during that period. To pay for the 4-year level of authorization in the Public Works Committee bill would require extension of the user taxes and Trust Fund more than 4 years beyond the present September 30, 1979 expiration date. But extension of the taxes beyond the period of authorization of expenditures should not be considered as a way of paying for the authorizations now proposed by H.R. 11733. To do so would destroy the orderly sequence of highway financing. This is why we have strongly recommended that the highway spending program be limited to current receipts from the user taxes within the 4-year time frame recommended for extension of the Highway Trust Fund and highway user taxes. An alternative, of course, that would accommodate the Public Works Committee's level of authorizations within a 4-year time frame would be to increase the gasoline tax by 2 cents a gallon (over $2 billion a year) for 4 years. We do not recommend an increase as part of a highway program. - 3 The current law requirement for adjustments to apportionments when estimated future receipts of the Fund will be inadequate to pay for expenditures resulting from authorized apportionments now requires all reductions to be made in apportionments for the interstate system. An amendment to this provision as proposed by Congressmen Conable and Gibbons would make the required reductions the same percentage for all Federal-aid highway and highway safety construction programs. This amendment also would specify that the procedure for determination of the need for a reduction in apportionments be carried out under a more definite time table, and that any percentage cutback be published in the Federal Register a stated time before the beginning of the next fiscal year. Present law is rather vague as to when the Secretary of the Treasury has to notify the Secretary of Transportation of the need for reduction in interstate systems apportionments. A more structured procedure than currently exists for determini and announcing reductions in apportionments would be helpful in altering all concerned with highway aid programs as to changes in apportionments from the level of authorizations. Requiring all programs to be reduced proportionately whenever a cutback is required would prevent the whole of any cutback from falling on the interstate system and thus limit the effect of a cutback on the completion of the interstate system which already is greatly behind schedule. Under present law, an authorization program which is greatly in excess of anticipated revenues for the Trust Fund, as is the case with H.R. 11733, would require suspending a large proportion of interstate system apportionments during part of the 4-year period covered by the bill. For these reasons, we believe the Conable-Gibbons amendment would provide a better mechanism 0O0 for managing highway funding. FOR IMMEDIATE RELEASE May 23, 1978 RESULTS OF AUCTION OF 2-YEAR NOTES The Department of the Treasury has accepted $2,400 million of $5,764 million of tenders received from the public for the 2-year notes, Series P-1980, auctioned today. The range of accepted competitive bids was as follows: Lowest yield 8.00% 1/ Highest yield Average yield 8.10% 8.09% The interest rate on the notes will be 8%. At the 8% rate, the above yields result in the following prices: Low-yield price 100.000 High-yield price Average-yield price 99.819 99.837 The $2,400 million of accepted tenders includes $988 million of noncompetitive tenders and $1,352 million of competitive tenders from private investors, including 35% of the amount of notes bid for at the high yield. It also includes $ 60 million of tenders at the average price from Federal Reserve Banks as agents for foreign and international monetary authorities in exchange for maturing securities. In addition to the $2,400 million of tenders accepted in the auction process, $ 177 million of tenders were accepted at the average price from Government accounts and Federal Reserve Banks for their own account in exchange for securities maturing May 31, 1978, and $470 million of tenders were accepted at the average price from Federal Reserve Banks as agents for foreign and internationl monetary authorities for new cash. 1/ Excepting 8 tenders totaling $105,000 B-936 FOR RELEASE UPON DELIVERY Expected at 11:00 am, E.D.T. May 24, 1978 REMARKS OF THE HONORABLE W. MICHAEL BLUMENTHAL SECRETARY OF THE TREASURY BEFORE THE INTERNATIONAL MONETARY CONFERENCE MEXICO CITY, MEXICO MAY 24, 1978 This annual conference provides a unique forum for an exchange of views on key issues facing the world financial and banking community. It is of great value to me to participate, and a distinct privilege to address this assembly. We in government and you in the banking industry share a common interest in a smoothly working international monetary system, and a strong and active world economy. The actions of governments help shape the environment within which banks operate; your industry in turn helps determine the economic framework for public policy. A clear understanding of each others' views is not only beneficial but essential. Your conferences contribute greatly towards achieving that understanding. The New System This year's meeting comes at a time when we are entering a new phase of international monetary history. Just last month, with the ratification of the new IMF Articles, we inaugurated the new international monetary system vLich had been agreed at Jamaica. Our collective task in the coming year will be to implement that new system, to get it operating effectively. And, within the framework of the new system, to achieve a better balance in the pattern of international payments. For the United States, the aim of adjustment and a better payments pattern has special meaning. We know we have a resoonsibility to reduce our current account deficit, and to assure a strong and healthy dollar. We are determined to fulfill that responsibility, by improving the fundamental strength of our economy, and by following sound underlying economic and financial policies. There is now an increased awareness of our determination to take all necessary action needed for a sound dollar: to curb inflation, cut back our dependence on imported oil, and improve our export performance, along the lines announced by President Carter on April 11. With this increased worldwide awareness, the uncertainty and disorder that B-937 -2periodically characterized the exchange markets in the six months October throuqh March has qradually given way in recent weeks to an improved tone. We are working hard to maintain it that way. Our intention was never otherwise. I mention this by way of introduction to some thoughts I would like to share with you on the monetary system we live under and must work with. The efforts of the Carter Administration to set these fundamental economic variables in order are the m; P a: a move away ^t^m UL^XW^ UV xm^^^ -^«.^*.w...^~ .* by some external means, and toward the concept of placing directly on nations the responsibility for developing exchang stability by following sound underlying economic and financial policies. It is a move in the right direction. It is an effort we must all support. Historical Precis Under the gold standard, with exchange rates rigidly tied to gold, domestic economic policies were clearly and sometimes brutally subordinated to international imperatives. Exchange stability was imposed on countries from the outside, and sometimes at great cost. While adjustment occurred, it was at times accomplished harshly and inflexibly, with the result that the system broke down, and led in the 1930's to a period of restrictions and predatory exchange rate policies. The Bretton Woods par value system was designed to correct, on the one hand, the excesses of the gold standard, and on the other, the aggressive exchange rate behavior of the interwar years: it retained the general framework of a gold standard, but provided for greater flexibility and greater freedom of national policy formulation by permitting par value changes in event of "fundamental disequilibrium." It was for a time a highly successful system. But fundamental changes in global patterns of economic growth, coupled with dramatic growth in the size and fluidity of the international capital markets, brought it under strain in the 1960's and early 1970's and led to the need for reform. The new system now embodied in the IMF Articles retains the basic Bretton Woods philosophy of cooperation and liberal trade and payments. But it moves away from trying to force stability on nations through an external mechanism — as the gold standard to an extreme degree and the Bretton Woods system to a lesser degree had tried to do but failed. Instead it aims at developing stability through the application of sound underlying economic and financial policies in individual countries. It is a more realistic, more pragmatic approach. It focuses attention less on -3the symptoms of instability in the world economy — conditions in the exchange markets — and more on the root causes: the pursuit of divergent and in some cases inappropriate national policies by individual countries. The main obligations placed on nations under the new IMF Articles are two fold. First, each nation must endeavor to direct its policies toward orderly growth with reasonable price stability. Second, each nation must avoid manipulating its exchange rate to avoid adjustment or gain unfair competitive advantage. t These are tough demands. The monetary system would function well if all nations followed sensible policies directed toward non-inflationary growth, and if they did not try to maintain exchange rates at artificial levels. But we must frankly acknowledge that neither our new monetary system, nor any likely alternative system, can force sovereign nations against their will to adopt particular domestic economic and financial policies. In the last analysis, German and Japanese growth policy is made by German and Japanese authorities. Swiss and British monetary policy is made by the Swiss and British authorities. And American economic and financial policy is made by American authorities — the President and the Congress. Despite these individual differences, all of the major countries have a responsibility to work toward the internal discipline that is essential to meaningful stability in the international monetary system. This is one reason why the heads of state have taken to periodic Summit meetings — to foster the kind of gap bridging of domestic macro-economic policies that is necessary for a smoothly functioning exchange market for goods and money. We must expect that solutions will not be quick or dramatic, and that they will yield only to patience and determination. Yet what we have in the new IMF Articles is a mechanism which can help us reconcile these differences, an improved framework for cooperation in adjustment and management of the monetary system, a foundation on which we can build if there is the international will to cooperate. It will take a lot of work, and we should not except too much too quickly. But it clearly is in the common interest of all nations to endeavor to ensure its success. Making the System Work Through Surveillance In order to give operational content to the new system, the IMF will have to develop and sharpen its processes of surveillance over nations' policies — both its broad examination of members' general economic and financial policies, and its more direct examination of their exchange rate policies. We look to -4surveillance by the Fund as the cornerstone of a smoothly working monetary system. Surveillance will give the system its backbone and structure, provide the means of assessing responsible international behavior, and permit the influence of the international community to be brought to bear on nations which fail to comply with their obligations. The United States is fully committed to making this process work. To this end, we have made specific proposals to meet three requirements: first, the IMF must have full information about policies and developments in member countries; second, the IMF as an institution must be so organized as to handle its surveillance duties effectively, and with the involvement of the senior political officials responsible in their own governments; third, the IMF must have the techniques by which it can bring to bear the full moral force of the world community's views on the compliance or non-compliance of individual countries with their international obligations. A system based on effective surveillance seems to me to have distinct advantages over previous systems. It relies in a real sense on analysis and judgment — rather than on mechanical rules and operating procedures. It is more flexible: it can be adapted to take account of the different circumstances of different countries, and also of changing conditions in the international economy over time. It permits more evenhanded treatment of nations, in that surveillance applies equally to those in surplus and those in deficit, and an imbalance in one direction is no less a matter of international concern than an imbalance in the other direction. The surveillance system thus broadens the authority and strengthens the hand of the IMF, whose ability to influence members' policies was in the past largely limited to the relatively few members borrowing in the Fund's credit tranches. Should We Stick To It? In anticipating the move to flexible exchange rates, some observers expected that greater flexibility would remove the discipline from the system — that nations could ignore developments in their exchange markets, and pursue internal monetary and fiscal policies without regard to their external effects. While it is widely recognized that flexible rates have helped the world economy to deal with some major shocks in recent years, one notes today increased ambivalence in some circles about the new system, perhaps because of growing realization that such expectations were not realistic. The exchange market implications of persistent large payments imbalances are often discomforting: export industries and workers are not happy about exchange rate appreciation; consumers do not like to see the prices of their imports rise because of depreciation; private and official entities holding large amounts of foreign currencies -5react strongly to exchange rate changes. These and other factors can and do bring powerful forces to bear on the process of national economic decision making, in a manner which is often discomforting to politicians. But the failure of the flexible exchange rate system to meet up to false expectations and the fact that in practice, the new regime does not obviate the need for national economic discipline, is scarcely cause for abandoning it as some have suggested. No system can provide freedom from discipline. Our present efforts must be aimed at trying to make the new system work rather than to replace it with something new. The United States government accepts the role of exchange rate movements as a barometer of whether a nation is following such policies on growth, inflation, and balance-of-payments adjustment. To be sure, we stand ready to intervene in the market to counter speculation and disorder in the market. But we do not believe efforts by countries to maintain exchange rates out of kilter with underlying economic and financial performance would be practical or desirable. Moreover, there is a need to avoid the uncertainties that would arise from expectations that further major changes in the international system are in prospect. The introduction of a new monetary system is a major event, an inherently disruptive change which is always difficult for the world to absorb. As the trustees of the world's monetary system, we can build confidence only by making such changes at infrequent intervals on an evolutionary basis. There are now, and there will continue to be, various proposals for major adaptations in the present system. As intellectually interesting as these may be, the United States feels strongly that we have no responsible choice but to get on with the more prosaic, nuts and bolts job of making the flexible exchange rate system work. The Future I am not suggesting that we should reject the possibility of future long-term evolution in the system or in the roles of different reserve assets. I can envision various possibilities which might in time develop. For example, I am confident that the future will bring an expansion in the role of the SDR. The SDR has important long-run potential for the system, and the United States, which worked in the 1960's to help establish that asset, favors the development of that potential. Consideration is now being given within the IMF to some moves to increase the financial attractiveness of the SDR, and to ways of expanding its usability in transactions. The -6possibility of a further allocation of SDRs is also under study. The United States has suggested a review of other possibilities — in particular, that an allocation of SDR might be considered' in connection with the payment of funds to the IMF as part of any increase in quotas that might be approved in the future. We have also suggested that possibilities be studied for increased use of SDR in regular IMF credit transactions as part of the longer-run development of the asset. We should be receptive to other ways of increasing the use, and usefulness, of the SDR. A second possible evolution which may occur in the future and is now receiving renewed attention is the development of a European currency. Monetary union has been a longstanding objective of the European Community, which has been frustrated in a sense by the same kinds of problems that confront the system generally — payments imbalances, difficulties of national policy coordination and harmonization, and wide differences in actual economic performance. Whether union is feasible and desirable is largely a question for the European nations themselves to decide. If the Community wishes to move toward currency unification and develop a single European currency with an international role, the United States would have no objection in principle provides that such a step would be fully compatible with the broader financial system. We would be prepared to examine any such proposals with an open mind and with understanding. But such changes in the monetary system should be seen as possibilities for the future. Now we must work to improve the operation of the adjustment process, and achieve a better balance in the pattern of world payments. That effort must be conducted within the monetary system as it presently exists. The Role of the Dollar I would like to conclude with a few comments on the role of the dollar in the system. In my opinion, the reserve currency role of the dollar is neither an "exorbitant privilege" for the United States, as some allege, nor an "exorbitant burden," as other contend. Under the par value system, it was argued that a privilege existed for reserve currency countries in that the U.S. was then permitted, by issuing its currency, to borrow too easily and finance deficits on too large a scale. But any such privilege is much reduced or eliminated under present arrangements: — First, because with flexible exchange rates dollar accumulations by other countries are less an automatic result of the operation of the system and more a matter of discretion; -7— Second, because with present large and open capital markets, onshore and off, many other deficit countries can at any time be borrowing dollar in large amounts and putting them on the market — with the result that borrowing to finance U.S. deficits is not the major source of the growth in supply of dollars. Also, the burden alleged to arise from our reserve currency role — that the U.S. does not have the same freedom as others to adjust its exchange rate — is, I suspect, more a function of the size of our market and competitive strength of our economy than our reserve currency role. I feel also that the decline in the dollar's exchange rate which occurred during the latter part of last year and early months of this year had little to do with the dollar's reserve currency role. During the last quarter of 1977 and the first quarter of this year, the dollar declined by an average 8 percent, trade weighted. But in that six-month period the United States was itself running a current account deficit at an annual rate of nearly $30 billion. The factors underlying the U.S. payments deficit were well known to the market — our failure to adjust to the high cost of energy; a rate of inflation that was rising while some other countries were holding inflation rates stable; growth in our economy while other economies were stagnating; and for a variety of reasons, a lack of sufficient growth in our exports. These problems did not arise from the dollar's role as a reserve currency. They would have caused balance-of-payments deficits and exchange rate pressures under any type of international monetary system, whether or not the dollar were widely held in reserves. In fact, there was not a lot of shifting of reserves out of dollars during those months. A change in the role of the dollar is not a cure for our problems. The solution to the U.S. balance-of-payments deficit lies in dealing with the factors which caused it — energy, inflation, weak export performance, inadequate growth abroad. As the largest economy and provider of the world's vehicle currency, we understand that the burden falls especially heavily on the United States to maintain economic discipline, to set these fundamentals right. But we do not look to a revision of the international monetary system, or to a change in the dollar's role in that system, or to other devices such as the introduction of a substitution account to replace dollars with SDRs, as a solution to the difficulties the dollar has faced. Conclusion In the end, the central issue of the internatioanl monetary system is — and will continue to be — the operation of the adjustment process, the questions of what forces are brought to -8bear on what countries to adopt internal or external policies to bring their respective external positions into sustainable harmony. Different mechanical arrangements, such as the gold standard and the Bretton Woods system of par values and gold convertibility, can have powerful implications for these questions. We have to recognize clearly that when we discuss "reform" of the system, we are discussing the means by which international rules or judgments are applied to the fundamental national economic policies of individual nations as they affect the adjustment process. The new monetary system recognizes the issue explicitly and squarely in its focus on underlying policy and economic stability in member nations. This approach provides the potential, if we are all genuinely willing to make it work, for a more satisfactory and balanced operation of the system as a whole than we have yet experienced in this century. O00O FOR IMMEDIATE RELEASE MAY 23, 1978 Contact: Robert E. Nipp 202/566-5328 TREASURY ANNOUNCES RESULTS OF GOLD AUCTION The Department of the Treasury announced that 300,000 ounces of fine gold were sold today to 12 successful bidders at prices from $180.01 to $182.35 per ounce, yielding an average price of $180.38 per ounce. Gross proceeds from this sale were $54.1 million. Of the proceeds, $12.7 million will be used to retire Gold Certificates held by Federal Reserve banks. The remaining $41.4 million will be deposited into the Treasury as a miscellaneous receipt. These sales were made as the first in a series of monthly auctions being conducted by the General Services Administration on behalf of the Department of the Treasury. The next auction, at which another 300,000 ounces will be offered, will be held on June 20. A total of 212 bids were submitted by 44 bidders for a total amount of 1,364,400 ounces at prices ranging from $12 to $182.35 per ounce. The list of the successful bidders and the amount of gold awarded to each is attached. The General Services Administration will release additional detail later. Attachment B-938 Ounces Swiss Bank Corporation Zurich, Switzerland Dresdner Bank 97,600 Frankfurt, Federal Republic of Germany Union Bank of Switzerland 50,000 Zurich, Switzerland Sharps Pixley 18,000 New York, New York NMR Metals Inc. 13,200 New York, New York Merrill-Montagu 4,800 New York, New York Swiss Credit Bank 2,000 Zurich, Switzerland J. Aron Inc. 10,000 New York, New York Monex International Ltd. 400 Newport Beach, California Samuel Montagu 3,600 London, U.K. Johnson Matthey Bankers, Ltd. 3,200 London, U.K. Morris Cannan 800 San Antonio, Texas 96,400 TMM^nTATTr iMMtuiAib Statement by W. Michael Blumenthal Secretary of the Treasury May I left New York yesterday with the feeling that resolution of city'r, fiscal crisis was near and Senator Proxmire agreed to defer postponement of the Senate Banking Committee hearing Wednesday until the last possible moment. The negotiating parties have worked diligently to find common ground. The state and city officials, the banking community and the union leaders are closer to agreement than ever before. But we are now right down to the wire and I am disappointed that the self-imposed deadline was not met. It is essential that the remaining issues be resolved quickly so that the hearing of the Senate Banking Committee can proceed. I think both sides understand the necessity of reaching a settlement that is, first and most important, fiscally responsible, that is fair to all parties and that permits the City to effect needed efficiencies through collaboration with its union leaders and employees. 23, RESULTS OF TREASURY'S 52-WEEK BILL AUCTION Tenders for $2,456 million of 52-week Treasury bills to be dated May 30, 1978, and to mature May 29, 1979 were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: (Excepting 1 tender of.$165,000) Investment Rate Price Discount Rate High - 92.508 7.410% ' 7.96% _ 92.499 Low Average92.501 (Equivalent Coupon-Issue Yield) 7.419% 7.417% 7.97% 7.97% Tenders at the low price were allotted 71%. TOTAL TENDERS RECEIVED AND ACCEPTED • BY FEDERAL RESERVE DISTRICTS AND TREASURY: Location Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco Received $ 37,625,000 4,296,645,000 32,905,000 69,040,000 90,555,000 11,965,000 807,450,000 39,025,000 28,920,000 17,480,000 5,720,000 305,005,000 Accepted $ 7,625,000 2,084,195,000 2,905,000 8,360,000 66,555,000 8,265,000 226,200,000 11,155,000 5,050,000 6,480,000 3,720,000 22,420,000 Treasury 2,605,000 2,605,000 TOTAL $5,744,940,000 $2,455,535,000 The $2,456 million of accepted tenders includes $105 million of noncompetitive tenders from the public and $1,142 million of tenders from Federal Reserve Banks for themselves and as agents of foreign and international monetary authorities accepted at the average price. An additional $ 21 million of the bills will be issued to Federal Reserve Banks as agents of foreign and international monetary authorities for new cash. B-939 partmentoftheTREASURY SHINGTON.D.C. 20220 TELEPHONE 506-2041 FOR RELEASE ON DELIVERY May 25, "1978"— 9:00 a.m. EDST STATEMENT OF THE HONORABLE RICHARD J. DAVIS ASSISTANT SECRETARY OF THE TREASURY FOR ENFORCEMENT AND OPERATIONS BEFORE THE SUBCOMMITTEE ON CRIMINAL LAWS AND PROCEDURES OF THE SENATE COMMITTEE ON THE JUDICIARY Mr. Chairman and Members of the Subcommittee: I very much appreciate the opportunity to appear before this Subcommittee today in order to discuss legislation which would require the tagging of explosive materials. The proposed tagging would serve two purposes, identification and detection. Identification taggants would remain intact after a bomb explodes and enable the type of explosive used to be identified and traced. Detection taggants would enable the presence of a bomb to be established before it exploded. The Treasury Department strongly supports the adoption of such legislation. It would provide us with critical tools in the battle against terrorists and others who use explosives illegally: it would help us apprehend the bomber, and it would help save lives and preserve property by preventing explosions from taking place. Bombing is a particu lary vicious and indiscriminate crime, and it is a c learly deliberate act of violence. One does not, in a moment of intense anger, grab his "home protection bomb" from a closet and blowThe bomber actively has to up his spouse or neighbor acquire the knowledge of how to make a bomb; he has to fabricate the explosive d evice; and he has to plant it. This is a calculated, pla nned and indisputably intentional process. At the s ame time the consequences of B-940 - 2 the bomber's action are severe: death, injury and the destruction of property. For these reasons we believe that we should do all that we legitimately can to meet this problem. The tagging of all commercial explosives of the types used in bombings is one such action about which you have already heard much testimony. Representatives of ATF and the Aerospace Corporation have testified concerning the value of identification tagging, and a detailed report prepared by Management Science Associates has been submitted for your consideration. I will not repeat what these others have already said. What is clear is that the addition of identification taggants to commercial explosive materials or their boosters will better enable law enforcement authorities to trace the explosive material from a bomb scene to its last recorded owner and, hopefully, to its ultimate user. The chances of solving more bombing crimes will be improved when identification tagging is introduced. From Treasury's perspective, the vital issue as to identification tagging is whether the crimes solved and the deterrence established will be worth the effort and costs of requiring the identification taggants. We believe that the answer is clearly affirmative. The American people can only profit from this program. Bombers can only lose. And, the costs for the manufacturers, dealers and users of explosive materials will not be excessive. If identification tagging is desirable, a successful detection tagging program is critical. Bombing is a crime that is carried out secretly and without warning. A bomb is small and lightweight. It can be hidden easily. Through a time delay mechanism or a motion-activated detonator, it can be concealed (or mailed) and then abandoned by its creator. The bomber can choose his explosive device, select his target, and plant his bomb. But once he has left it, every passerby becomes a random target as it explodes without warning. - 3 The need, therefore, is to develop the ability to detect the presence of a bomb before it explodes. As the Subcommittee has learned from the previous detailed testimony of Mr. Atley Peterson of the Bureau of Alcohol, Tobacco and Firearms and Dr. Robert Moler of Aerospace Corporation, substantial progress in developing a working capability to tag explosives so that they may be detected before exploding has recently been made. And it is this part of the tagging program from which the greatest direct benefits to the public safety can be expected. With detection taggants added to explosive materials and with detection devices placed at high target value locations, we can go beyond solving bombing crimes only after the destruction has happened and begin, through pre-detonation discovery, to prevent bombings from occurring. While the costbenefit of this form of tagging is less certain than that for identification tagging, this life saving potential is of primary importance. I would now like to discuss some of the points that have been raised during these hearings. Initially, it has been suggested to the Subcommittee by some industry representatives that the Federal government should buy the tagging materials and distribute them to the explosives manufacturers. There has also been a suggestion that the Government should bear the liability for any adverse results of explosives tagging. It is the Treasury Department's belief that the Federal government should not interpose itself in the commercial chain and create an artificial and unnecessary "middleman" between the producers of taggants and their customers, the manufacturers of explosive materials. The function of Treasury's Bureau of Alcohol, Tobacco and Firearms with respect to the explosives industry should be to develop the requirements and to monitor the execution of the tagging programs. The BATF function clearly should not be that of an - 4 unnecessary, bureaucratic intruder in the marketplace. We believe either role — that of distributor of taggants or insurer of manufacturers — should be reserved for private enterprise where it will be accomplished as guided by normal market forces and business management interests. Any involvement of the Federal government in this "middleman" role is unnecessary and would create an unfortunate precedent. We sincerely hope the Subcommittee will not add any requirements of this sort to S. 2013. Some have suggested that taggants would be required before it becomes safe or feasible to do so. That is not our desire. Taggants for each class of explosives should not be required until the all around safety, performance quality and environmental impact of the tagged explosive are established through rigorous research and testing. In addition, a tagging requirement should only be imposed if the taggant itself has the requisite longevity, survivability, and uniqueness to accomplish its task. It is because tagging technology and the readiness and adequacy for implementation varies according to the type of explosive, that we have recommended in all Treasury testimony that S. 2013 should include greater discretionary authority and flexibility for the Secretary in determining what explosive materials should be tagged and when. Specific language to provide this flexibility while setting forth the requirements discussed above has been developed by Treasury and adopted for the explosives tagging provisions of S. 2236, the antiterrorism bill introduced by the Senate Governmental Affairs Committee. A copy of this language is attached to my testimony. It is our view that this legislation should require the insertion of taggants in all types of commercially available explosive materials which are used in crimes. The Secretary would then have the authority, applying the standards in our proposed language, to impose the specific requirement for each class of - 5 explosives within a reasonable time after the taggant for that class has been successfully tested and is available. The Secretary would exempt those classes of explosives not yet ready for tagging. Mr. Chairman, the benefits of tagging are clear. It will not, however, provide a panacea, instantly solving the problem of explosives crime. Identification tagging will help solve some bombings, not all. Detection tagging does not mean that all bombs will immediately be detected. Together, however, they will meaningfully advance our ability to deal with the bombing problem, and may deter some from using this deadly instrument. These would be major advances. One thing is clear, however: the extent to which tagging will help counter bombing crimes will be largely influenced by how quickly and how many forms of explosives are tagged. It is critical, therefore, that as soon as technology allows, the requirement that a particular class of explosives be tagged should go into effect. One class of explosives is ready to be tagged now; others will be shortly. We, therefore, urge that this legislation be passed during this session. We can then minimize the delay in getting tagged explosives into the marketplace and maximize our ability to apprehend those who use bombs and to save the lives of their intended victims at the earliest possible time. The Treasury Department deeply appreciates the detailed attention which the Subcommittee and you, Mr. Chairman, have given to the problem of bombings and the tagging of explosives to help fight this severe crime problem. We believe that nearly all American citizens share in the desire so often expressed before and by the Members of this Subcommittee that all explosive materials commonly used in the various forms of criminal and terrorist bombings should, when operationally feasible, be required to contain both identification and detection taggants. - 6 We will gladly continue to work with the Subcommittee's staff to achieve a final version of S. 2013 which will accomplish our mutual goal of a workable scheme for requiring the tagging of explosive materials for identification and for detection. That concludes my statement, Mr. Chairman, I will bo happy to answer any questions the Subcommittee may have. 0O0 FOR IMMEDIATE RELEASE May 24, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY ANNOUNCES COUNTERVAILING DUTY INVESTIGATION OF IMPORTS OF AMPICILLIN TRIHYDRATE FROM SPAIN The Treasury Department today announced an investigation to determine whether the Government of Spain is subsidizing exports of ampicillin trihydrate. The investigation results from a petition filed on behalf of domestic interests. Ampicillin trihydrate is a semi-synthetic form of penicillin used in the treatment of disease. The Countervailing Duty Law requires that the Secretary of the Treasury collect an additional duty that equals the size of the "bounty or grant" (subsidy) paid on the exportation or manufacture of merchandise imported into the United States. A preliminary determination in this case must be made not later than September 23, 1978, and a final determination no later than March 23, 1979. Notice of this action will appear in the Federal Register on May 25, 1978. Imports of ampicillin trihydrate from Spain amounted to approximately $13,000 during calendar year 1977. o B-941 0 o FOR IMMEDIATE RELEASE May 25, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY ANNOUNCES FINDING OF DUMPING IN GILMORE CASE The Treasury Department announced today that it is issuing a "Finding of Dumping" with respect to imports of carbon steel plate from Japan. This action follows the Treasury's January 13, 1978, Determination of Sales at Less Than Fair Value and the U. S. International Trade Commission's April 24, 1978, Determination of Injury in the case. A Finding of Dumping means that all entries of the merchandise from the date of withholding of appraisement, in this case October 5, 1977, will be assessed for antidumping duties if they have been sold at below fair value. Imports of this merchandise during calendar year 1976 were valued at roughly $174 million. Notice of this action will be published in the Federal Register of May 30, 1978. o B-942 0 o ipartmentoftheTREASURY SHINGTON,D.C. 20220 TELEPHONE 566-2041 Press w«uuv;t: FOR IMMEDIATE RELEASE May 25, 1978 Non-Press Contact AUJJCi u E • m 202/566-5328 202/566-8235 566-8651 566-5286 TRIGGER PRICES ADJUSTED: HEARING SET ON GREAT LAKES DIVERSION CLAIMS The Department of the Treasury announced today that the handling charges used to calculate trigger prices of steel mill products entering through West Coast ports will be increased from the present rate of $3 to $7 per metric ton, effective for shipments exported to the United States on or after May 31, 1978. This adjustment is being made to more accurately reflect actual Japanese handling costs. The Department also announced that it will review the effect of the trigger price mechanism on the Great Lakes region. Specifically, the Department will consider allegations that a secondary effect of the trigger price mechanism has been or will be to divert steel imports from Great Lakes to East, West and Gulf coast ports. As a result of a preliminary review of these claims, the Department is considering adjustments in the Great Lakes freight rates used to calculate trigger prices for steel plate and cold and hot rolled sheets to reflect more closely actual Japanese freight costs. A hearing will consider these proposed adjustments, together with other proposals to correct this claimed diversionary effect. Written comment on the issues is invited through Thursday, June 12, 1978, while written requests to testify will be considered through Thursday, June 8, 1978. If sufficient interest is expressed, a hearing will be held on Monday, June 12, 1978, according to Robert H. Mundheim, Treasury General Counsel. B-943 -2The Treasury notice, which will be published in the next several days in the Federal Register, states that the Treasury Department, in cooperation with officials of the Saint Lawrence Seaway Development Corporation, has reviewed the trigger price freight rates in light of Bureau of the Census data concerning actual shipments to the Great Lakes in 1977. From this review, it appears that adjustment in some of the freight rates may be appropriate as follows: Great Lakes Adjusted Great Lakes Trigger Price Trigger Price Freight Rate Freight Rate (per metric ton) (per metric ton) Steel Plates $40 $30 - $32 Hot Rolled Sheets $35 $31 - $33 Cold Rolled Sheets $35 $29 - $31 Subject to comments received from the public, it is the intention of the Treasury Department to adjust the Great Lakes freight rates within the ranges indicated above and to apply the adjusted rates to trigger prices for all shipments to the Great Lakes exported on or after July 1, 1978. The notice also identifies a number of other proposals which have been made to correct the alleged diversionary effect. Specific factual information has been requested to enable the Department to determine whether any of these proposed adjustments in the trigger price mechanism are warranted. Written comment is being requested and a hearing may be held to air these issues and to secure comment from those supporting or contesting the basis for adjustments in the trigger price mechanism. A copy of the Treasury notice is attached. # Department of the Treasury NOTICE Adjustment of Handlina Charges and Hearing on Great Lakes "trigger prices" for imported steel mill products. Notice is hereby given that the handling charges used to calculate trigger prices of steel mill products entering through Wfest Coast ports will be increased to $7 per metric ton, effective for shipments exported on or after Mav 31, 1978. It has been determined that this adjustment is necessary to reflect more accurately actual Japanese handlina costs. The Treasury Department is also hereby inviting public content on its program for monitoring imports of steel mill products as it affects the Great Lakes region. A hearing will be held to consider allegations that a secondary effect of the trigger price mechanism has been or will be to divert steel imports from Great Lakes to East, West, and Gulf coast ports. As a result of its preliminary review of these claims, the Treasury Department is considering an adjustment in the Great Lakes freight rates used to calculate triqger prices for steel plate and cold airi hot rolled sheets to reflect more closely actual Japanese freiaht costs. The hearina will consider these proposed adjustments, together with other proposals to correct this claimed diversionary effect. BACKGROUND; Under the trigaer Drioe mechanism, import specialists at every port of entry monitor the prices of all imported steel mill products to gather information on possible sales at "less than fair value" within the meaning of the Antidumping Act. As guidelines for the aathering of such information, triager prices have been calculated frcm data on the costs of production of the Japanese basic steel industry. Information on sales below trigaer prices is forwarded to Customs headquarters in Washington where it is tabulated and compared to other available data to determine whether an antidumping proceeding should be initiated. If, as a result of such an investiaation. sales at less than fair value are found by the Treasury Department and injury is found by the International Trade Commission, a dumping finding will be made. Trigger prices reflect the Japanese cost of producing steel mill products plus the cost of transporting such products to each of the four maior importing regions: The Wpst Coast, Gulf Coast* East Coast, and Great Lakes. As freight costs increase, triqger prices increase. For example, the current trigger prices for cold - 2 rolled sheeti/ far each of the four regions axe: Base Charges to CUF Price Freight Handling Interest Itotal West Coast $297 $23 $3?/ $7 $330 Gulf Coast $297 $23 $5 $8 $333 East Coast $297 $27 $4 $9 $337 Great Lakes $297 $35 $4 $11 $347 It is asserted that both the absolute and relative level of the trigger prices far the Great lakes region will lead to the diversion of steel from the Great lakes to West, Gulf, and fest Coast ports. Serious economic dislocations far the Great lakes region would allegedly follow frcm such a diversion, particularly for those longshoremen, stevedores, varehousemen, and terminal operators whose work depends en inported steel. Moreover, backhaul cargo, such as grain, would allegedly be diverted to other coasts. Finally, it is claimed that the Saint Iawrence Seaway Development Corporation, whose annual revenues are dependent en steel imports, will suffer substantial losses. A nutiber of proposals have been offered to correct this alleged anomaly: 1. Equalize the Great lakes importation charges with those of the Ekst Coast. 2. Adjust the trigger price importation charges to reflect more closely actual freight differentials for Japanese steel iirports as recorded in official U.S. Census tabulations. 3. Adjust the Great lakes inportaticn charges to reflect the least cost route far the Japanese, even where that involves an inland route such as the Mississippi River. Those who contest the need for any change in the current Great lakes trigger prices point out that the trigger prices wei.e based upon both the production costs and the transportation costs for the Japanese. As such, they provide appropriate guidelines for the Treasury Department to gather information on sales vrtiich warrant further scrutiny in light of the fair value standard in the Antidumping Act. The Antidurtping Act does not permit equalizing the •'•For the third quarter, trigger prices on this product will be increased by 5.5 percent. (43 FR 20070) 2 Subject to the increase announced in this notice. - 3 different freight costs associated with shipping merchandise frcm the country of export to various parts of the United States. Jtar example, if the West Coast trigaer prices were applied across the board, the trigaer prices would provide a standard for identifying sales at potentially less than fair value only at West Coast ports. Cn the other hand, if the Great Lakes trigger prices were applied to nation-wide entries, the trigger prices would identify far too many sales as potentially at less than fair value. Under the Antidumpina Act Japanese sales to the West Coast can properlv be made at a lower price than sales to the Great Lakes. It has also been pointed out that the actual evidence of diversion may be difficult to document. However, if the diversion has occurred, or will occur, it should be evident from a variety of sources. For example, Great lakes grain trade offsets freiaht costs for imported steel into the Great Lakes by providing shippers with a backhaul cargo. Has this trade been affected? Have seaway tolls declined? Since the St. Lawrence Seaway opened in mid-April, clear evidence of a significant diversionary effect has not been presented to the Treasury Department. The Treasury Department, in cooperation with officials of the Saint Lawrence Seaway Development Corporation, has reviewed the trigger price freight rates in light of Bureau of the Census data concerning actual shipments to the Great lakes in 1977. From this review, it appears that adjustments in same of the freight rates may *be appropriate as follows: Great Lakes Trigger Price Freight Rate (per metric tan) Adjusted Great Lakes Trigger Price Freight Rate (per metric ton) Steel Plates $40 $30 - $32 Hot Rolled Sheets $35 $31 - $33 Cold Rolled Sheets $35 $29 - $31 Subject to comments received from the public, it is the intention of the Treasury Department to adiust the Great Lakes freight rates within the ranges indicated above and to apply the adjusted rates to trigaer prices for all shipments to the Great Lakes exported on or after July 1, 1978. PUBLIC COMMENT: The public is invited to Garment on the issues outlined above. In particular, the Department is interested in any factual data which would affirm or disaffirm any of the contentions - 4 made. In considering the possible diversion of steel shipments from Great Lakes ports of entry* the Department will be interested in receiving factual evidence concerning steel and related shipments, such as: 1. The experience of out nun and charter carriers since the TPM became effective with respect to (a) orders for shipping space to Great Lakes ports as compared to East or Gulf Coast ports for the balance of the current year, (b) number of cancellations of prior orders to Great Lakes ports, (c) number of diversions from the Great lakes to East or Gulf Coast ports requested, and (d) volume of traffic now on order compared to prior years. 2. The extent of the infrastructure at Great Lakes ports for handling return or onward cargo by vessels delivering steel and the effect, if any, of the availability of such cargo on inward freight rates and on outbound shipping space at Great Lakes ports. 3. The experience of infrastructure facilities (e.g. grain elevators, marine terminals) since the TPM beoamp ef^ecrive with respect to (a) cancellations of soaoe or services: (b) level of orders or volume of transactions: and (c) coninunications to customers concerning Possible shipning space rhar wi^l be available at Great lakes ports for the balance of the year. PROCEDURES: 1. Written submissions* Written submissions which are received before the close of business on Thursday. June 12, 1978. will be considered. Tb b^ included in the record, wirrten submissions must be submitted in five copies. Each submission should designate clearly the name and address of the party makina the submission. 2. Requests to present oral testimony: All requests to present oral testimony, an* an outline of the oronosed testimony, must be received in writing not later than the close of business, Thursday, June 8# 1978. Requests to present oral testimony should include the followina information: (a) The name, (if the (if address, telephone number, and official position applicable) of the partv submitting the request, and person or persons vdio will present the oral testimony different frcm the partv submitting the request); - 5 (b) The position to be taken by the party; and (c) The amount of time requested for the presentation of oral testimony, and, if more than 10 minutes is requested, the reasons therefore. Treasury might find it useful to organize oral testimony into panels of witnesses so that specific issues can be explored in depth among persons who bring to the discussion varying experience and points of view. 3. Oral Testimony: If sufficient interest is expressed, oral testimony will be heard on Monday, June 12, 1978. Each person scheduled to testify will be notified of the date and the amount of time allotted for his presentation. 4. Comnunications: All carmunications with regard to written submissions or oral testimony should be addressed to: Peter D. Ehrenhaft. Deputy Assistant Secretary for Tariff Affairs, Room 3424, Department of the Treasury, Washington, D.C. 20220. Telephone: 202-566-2806. . MAY 2 5 1978 Dated: partmentoftheTREASURY TELEPHONE 566-2041 ;HINGT0N,D.C. 20220 May 26, 1978 FOR IMMEDIATE RELEASE RESULTS OF TREASURY'S WEEKLY BILL AUCTIONS Tenders for $2,201 million of 13-week Treasury bills and for $3,401 million of 26-week Treasury bills, both series to be issued on June 1, 1978, were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: 13-week bills maturing August 31, 1978 Price High Low Average Discount Rate 98.326a/ 6.622% 98.314 6.670% 98.317 6.658% 26-week bills maturing November 30, 1978 Investment Rate 1/ Discount Investment Price Rate Rate 1/ 6.83% 6.88% 6.87% 96.389b/ 7.143% 7.51% 96.375 7.170% 7.54% 96.380 7.160% 7.53% a./ Excepting 4 tenders totaling $3,230,000 b/ Excepting 1 tender of $200,000 Tenders at the low price for the 13-week bills were allotted 75%. Tenders at the low price for the 26-week bills were allotted 96%. TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTS AND TREASURY: Location Received Accepted Received Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco $ 15,995,000 3,468,615,000 16,785,000 39,940,000 26,560,000 25,530,000 504,510,000 43,200,000 3,710,000 22,390,000 10,200,000 298,695,000 $ 15,995,000 1,856,490,000 16,785,000 29,940,000 15,560,000 24,030,000 102,260,000 15,200,000 3,710,000 22,390,000 10,200,000 78,695,000 $ 68,980,000 4,533,530,000 63,430,000 113,010,000 46,560,000 17,960,000 427,975,000 40,960,000 14,500,000 15,950,000 5,780,000 209,845,000 $ 48,780,000 2,815,930,000 63,430,000 97,610,000 29,200,000 17,960,000 158,875,000 13,920,000 4,500,000 15,950,000 5,780,0 123,845,0 5,105,000 5,105.,000 $2,200,540,000c/ $5,563,585,000 $3,400,885.00C Treasury 9,285,000 TOTALS $4,485,415,000 9,285,000 c/lncludes $ 320,465,000 noncompetitive tenders from the public. d/lncludes $ 174,735,000 noncompetitive tenders from the public. ^./Equivalent coupon-issue yield. B-944 — Accepted FOR RELEASE AT 12:15 P.M. May 26, 1978 TREASURY OFFERS $6,000 MILLION OF 20-DAY TREASURY BILLS The Department of the Treasury, by this public notice, invites tenders for approximately $6,000 million of 20-day Treasury bills to be issued June 2, 1978, representing an additional amount of bills dated December 22, 1977, maturing June 22, 1978 (CUSIP No. 912793 Q9 0 ) . Competitive tenders will be received at all Federal Reserve Banks and Branches up to 12:30 p.m., Eastern Daylight Saving time, Thursday, June 1, 1978. Noncompetitive tenders will not be accepted. Tenders will not be received at the Department of the Treasury, Washington. Wire and telephone tenders may be received at the discretion of each Federal Reserve Bank or Branch. Each tender for the issue must be for a minimum amount of $1,000,000. Tenders over $1,000,000 must be in multiples of $1,000,000. The price on tenders offered must be expressed on the basis of 100, with not more than three decimals, e.g., 99.925. Fractions may not be used. The bills will be issued on a discount basis under competitive bidding, and at maturity their par amount will be payable without interest. Except for definitive bills in the $100,000 denomination, which will be available only to investors who are able to show that they are required by law or regulation to hold securities in physical form, this series of bills will be issued entirely in book-entry form in a minimum denomination of $10,000 and in any higher $5,000 multiple, on the records of the Federal Reserve Banks and Branches Banking institutions and dealers who make primary markets in Government securities and report daily to the Federal Reserve Bank of New Yor*k their positions in and borrowings on such securities may submit tenders for account of customers, if the names of the customers and the amount for each customer are furnished. Others are only permitted to submit tenders for their own account. B-945 -2No deposit need accompany tenders from incorporated banks and trust companies and from responsible and recognized dealers in investment securities for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, or for bills issued in bearer form, where authorized. A deposit of 2 percent of the par amount of the bills applied for must accompany tenders for such bills from others, unless an express guaranty of payment by an incorporated bank or trust company accompanies the tenders. Public announcement will be made by the Department of the Treasury of the amount and price range of accepted bids. Those submitting tenders will be advised of the acceptance or rejection of their tenders. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and the Secretary's action shall be final. Settlement for accepted tenders in accordance with the bids must be made or completed at the Federal Reserve Bank or Branch in cash or other immediately available funds on Friday, June 2, 1978. Under Sections 454(b) and 1221(5) of the Internal Revenue Code of 1954 the amount of discount at which these bills are sold is considered to accrue when the bills are sold, redeemed or otherwise disposed of, and the bills are excluded from consideration as capital assets. Accordingly, the owner of these bills (other than life insurance companies) must include in his or her Federal income tax return, as ordinary gain or loss, the difference between the price paid for the bills on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made. Department of the Treasury Circulars, No. 418 (current revision), Public Debt Series - Nos. 26-76 and 27-76, and this notice, prescribe the terms of these Treasury bills and govern the conditions of their issue. Copies of the circulars may be obtained from any Federal Reserve Bank or Branch. # # # FOR IMMEDIATE RELEASE May 26, 1978 Contact: George G. Ross 202/566-2356 TREASURY RELEASES TAX INITIATIVES OF THE PRESIDENT'S URBAN PROGRAM The Treasury Department today made available the three tax proposals which make up the tax initiatives of the President's Urban Program, announced on March 27, 1978. The three proposals are the Targeted Employment Tax Credit, the Small Issue Industrial Development Bond, and the Differential Investment Tax Credit. The proposals are in . the form of draft legislation, explanations, and letters of transmittal. The legislation was prepared in the form of amendments to H.R. 12078, the President's Tax Program. Attached are Fact Sheets, explanations, draft legislation, and a copy of the letter of transmittal to Al Ullman, Chairman of the House Ways and Means Committee. A similar letter wa3 sent to Russell B. Long, Chairman of the Senate Finance Committee, as well as to the President of the Senate and the Speaker of the House. Also attached is a list of the areas of the country which satisfy the distress test for eligibility under the ..Industrial Development Bond and Differential Investment Tax "Credit provisions of the Administration's Urban Program. o 3-946 0 o DEPARTMENT OF THE TREASURY WASHINGTON. D.C. 20220 ASSISTANT SECRETARY MAY 2 5 1978 Dear Mr. Chairman: For your information, I am enclosing copies of the letters and enclosures which I have sent today to the Speaker of the House of Representatives and the President of the Senate with respect to the Small Issue Industrial Development Bond and Differential Investment Tax Credit initiatives of the President's urban program. These proposals, together with the Targeted Employment Tax Credit proposal sent to you on May 22, 1978, comprise the tax initiatives of the President's urban program, announced on March 27, 1978. Sincer Donald C. Lubick Acting Assistant Secretary (Tax Policy) The Honorable Al Ullman Chairman, Committee on Ways and Means House of Representatives Washington, D.C. 20515 Enclosures FACT SHEET Small Issue Industrial Development Bonds The President's Proposal; . The size of projects which may be financed with tax exempt "small issues" of industrial development bonds will be increased from a maximum of $5 million to $20 million, but .the tax exemption will be allowed only for acquisition*or construction of land or depreciable property in "distressed" areas. The test for -economic distress will be applied to areas defined by either: 1) the boundaries of any city, town or other unit of general purpose government or 2) the area within a county's boundaries outside of all general purpose units of local government. Local area eligibility will be defined separately for two groups: local areas with boundaries in whole or in part within an SMSA and local areas wholly outside of SMSAs. An area will be eligible if it meets at least three of four criteria relative to all local areas within its group: i) its local unemployment rate is above the average, ii) its five-year growth rate of employment is below the average, iii) its five-year growth rate of population is below the average, and iv) its five-year absolute change in per-capita income is below the average. Present Law: Industrial development bonds are securities issued by State and local governments for the benefit of private borrowers. One of the cases for which interest on such bonds is tax-exempt is for small issues, where the amount of the bonds sold does not exceed $1 million or the total capital expenses on the facility being financed do not exceed $5 million. 2Reasons for the Recommendation: . Many areas of the nation have been suffering from high unemployment and a declining economic base. More investment is needed in these distressed areas to provide jobs and to promote economic development. The exception under present law that allows tax exemption for small issue IDBs enables States and localities to promote economic development by attracting new plants* Because their use is universally available, however, the competitive advantage to any one locality.in attracting investment is largely cancelled by the use of the IDBs by other localities. Raising the dollar amount of the small issue exemption and limiting its application to economically distressed areas will serve the purpose of encouraging investment where it is most needed. Effects on Revenue: The revenue effect of this proposal is negligible through calendar year 1983. FACT SHEET Differential Investment Tax Credit The President's Proposal: . An additional investment credit of five percent, beyond the 10 percent credit of current law, will be provided for certain investments in distressed areas. This additional credit will be allowed only for those investments or portions of an investment for which the Department of Commerce has issued a "certificate of necessity." Certificates for up to $400 million of additional credits may be issued during 1979 and 1980 for eligible investments. Only investment in distressed areas will be eligible to be certified. In selecting investments, the Department of Commerce will be required to consider the extent to which the investment will provide job opportunities in and contribute to the tax and economic bases of the distressed area. In addition, the Department of Commerce will have authority to certify investments in distressed enclaves located in jurisdictions that do not themselves qualify as distressed areas. However, only 5 percent of the investments certified for the differential credit may be in such distressed enclaves. The definition of distressed areas is the same as for Small Issue Industrial Development Bonds. (See Fact Sheet for Small Issue Industrial Development Bonds.) Present Law: Taxpayers are currently entitled to a credit against their Federal income tax liabilities equal to 10 percent of their investments in certain qualified assets. There is no provision in current law for variations in the investment credit according to the geographic location of particular investments. -2- Reasons for the Recommendation: . By augmenting the existing 10 percent credit, the differential investment credit will encourage companies to undertake specific projects that will create additional employment opportunities and help to relieve the fiscal pressure on local governments in communities that have been encountering relatively slow economic growth and high unemployment. The requirement for certification of individual projects will assure that the additional stimulus of this credit will be limited to projects that are likely to contribute to economic development and to provide jobs in distressed communities. The certification mechanism provides a method for limiting the total cost of the program by preventing an open-ended subsidy to all investments in distressed areas. Effect on Revenue: This proposal will reduce tax liabilities by $41 million in calendar year 1979, $132 million in calendar 1980, and $114 million in calendar 1981. FACT SHEET Targeted Employment Tax Credit The President's Proposal: • k Targeted Employment Tax Credit will replace the New Jobs Tax Credit, which expires after this year. The proposed tax credit will be available to employers * of young persons aged 18-24 who are from low-income households (less than 70% of regional lower living standard) and handicapped individuals who are referred from vocational rehabilitation programs. • The amount of the credit will be one-third of the employee's FUTA wages up to. a maximum credit of $2,000 for the first year of employment and one-fourth of those wages up to $1,500 for the second year. • Eligible individuals will be certified by local agencies that are designated by the Department of Labor. Neither the employer nor the IRS will be responsible for determining eligibility of employees. • Restrictions and conditions: —The employee must be employed full-time and for at least 75 days. —The credit may not offset more than 90 percent of tax liability in any year. —The eiEployer's deduction for wages paid must be reduced by the amount of the credit. —No more than 20 percent of an employer's wage base for Federal unemployment insurance taxes may be counted in the base for the credit. --Employers may not simultaneously earn employment credits and on-the-job training payments or WIN credits for the same employees. Present Law: • The New Jobs Tax Credit allows a credit of up to $2,100 for increased employment in 1977 and 1978. • Total amount of the credit is one-half of amount by which current FUTA wages exceeds 102% of prior year's FUTA wages. • An additional credit of 10% of FUTA wages is allowed for certain handicapped individuals. . Restrictions: —Credit is limited to $100,000, 25% of present year FUTA wages, 50% of the excess of total wages over 105% last year's total wages, or income tax liability, whichever is less. --The employer's deduction for wages paid must be reduced by the amount of the credit allowable. Reasons for the Recommendation: . The proposed credit focuses the incentive on disadvantaged young people, who are experiencing the highest rates of unemployment. . The new credit is hot Restricted to companies that have employment growth. Thus, there will be greater certainty" that hiring eligibles will result in credits for the employer. Also, the incentives will be spread more evenly by industry and region. . Under the Jobs Credit no incentive is provided for hiring more than 47 new employees, while under the proposed credit all taxpaying employers will be given an incentive to employ additional disadvantaged and handicapped individuals, up to 20% of their FUTA payroll. • Young persons in poor households will be aided in finding full-time, private sector jobs and they will be assisted in keeping these jobs while they learn skills and gain regular work experience. • Credits will be earned for employment of about 1.9 million disadvantaged and handicapped persons when the proposed program is fully in effect. Effect on Revenue: This proposal will reduce tax liabilities by $0.6 billion in calendar year 19 79 and by $1.5 billion when fully effective. SMALL ISSUE INDUSTRIAL DEVELOPMENT BONDS Present Law and Related Provisions of the Administration's Tax Program Industrial development bonds (IDBs) are obligations which raise capital for private business enterprise but are nominally issued by State or local governments. Most frequently, the proceeds of an issue of IDBs are used to acquire or to construct a facility; the facility is then "leased" to a private user for a rental exactly sufficient to pay debt service on the bonds. The lease generally provides that the private user may purchase the facility for a nominal amount at the end of the lease term. Payment of debt service on the bonds is secured by the rental payments and the facility itself. Generally the nominal issuer is not liable for payment of debt service on the bonds and the holders must look solely to the credit of the private user. In issuing tax-exempt IDBs a State or local government essentially lends its tax exemption to a private business to enable it to finance facilities at the lower interest rates prevailing in the tax-exempt market. In addition, the -2- "lease" agreement between the issuer and the private user is generally treated as a conditional sale contract for Federal income tax purposes; the user is, therefore, able to obtain the tax benefits associated with ownership of the property, including investment tax credits and accelerated depreciation or amortization. State and local governments use IDB financing to assist local industrial development. Since these governments incur no liability on the bonds, which are universally recognized as a debt of the private user, the issuance of IDBs has no direct consequence to the nominal issuer. Interest on State and local government obligations is generally exempt from tax under the Internal Revenue Code. However, the Revenue and Expenditure Control Act of 1968 denied tax exemption to IDBs, with certain exceptions. In general, a bond is an IDB under the Code if (1) the proceeds of the issue are to be used in any trade or business not carried on by a government or tax-exempt organization and if (2) repayment of principal or interest is secured by an interest in, or derived from payments with respect to, property used in a trade or business. Obligations issued by a State or local government to raise funds for use by a nonprofit, charitable organization in its trade or business are not generally treated as IDBs and are thus tax exempt. -3- One of the exceptions to the general rule allows taxexemption for "small issues" of IDBs in amounts of $1 million or less if the proceeds are used for the acquisition or* construction of land or depreciable property. The $1 million limitation applies to all bonds issued to provide facilities in one municipality or county for the same person or group of related persons. At the election of the issuer, the $1 million limitation m^y *>e increased to $5 million. However, the $5 million limitation applies to the sum of all small issues plus the total capital expenditures over a six-year period (other than those financed by small issue IDBs), of that person or group of related persons in the municipality or county. Under the President's 1978 Tax Program, the maximum small issue exemption would be doubled from $5 million to $10 million. The small issue exemption would also be limited to IDBs issued to finance the acquisition or construction of land or depreciable property in economically distressed areas. The President's 1978 Tax Program also includes a Taxable Bond Option (TBO) for State and local governments. Under TBO, State and local governments will have the right to elect to issue taxable bonds and other debt obligations with the -4- Federal Government paying a fixed percentage of the issuer's interest cost. For obligations issued during 1979 and .1980, the Federal Government will pay 35 percent of the interest cost. For obligations issued thereafter, the Federal Government will pay 40 percent. In general, all otherwise tax-exempt State and local obligations will be eligible for TBO. In particular, this means that TBO will be available for IDBs qualifying for tax exemption under the small issue exception for distressed areas. Explanation of Proposal Increase in Small Issue Exemption The maximum small issue exemption for IDBs will be raised from $5 million to $20 million. Tax exemption for small issue IDBs will be limited to IDBs issued to finance the acquisition or construction of land or depreciable property in economically distressed areas. Alternative Subsidy from National Development Bank In addition to increasing the limitation for tax-exempt (or optional TBO) small issue IDBs, the President's urban proposals will authorize the National Development Bank under -5- an alternative program to subsidize the interest costs on loans for private facilities to be located in distressed areas. issues. This subsidy will be available only for taxable The subsidy will equal 35 percent of the interest costs of bonds issued in 1979 and 1980 and 40 percent of the interest costs of bonds issued after 1980, the same subsidy rate available under TBO. Geographic Definition of an Area for Eligibility An area will be defined as economically distressed according to the criteria described in the next section. The boundaries of an area to which the test for economic distress will be applied are either: (1) the boundaries of any city, town or other unit of general-purpose local government, or (2) the area within a county's boundaries outside of all general-purpose units of local government. In the case of Alaska, the portion of a Census Division not lying within the boundaries of a local government will be subject to the test for economic distress. Any State or local government may issue a tax-exempt IDB that meets the definition of a small issue for the acquisition or construction of land or depreciable property in any economically distressed area within its boundary. -6- Eligibility Conditions Two geographical categories will be used for purposes of determining local area eligibility: (a) all local areas with boundaries in whole or in part within a Standard Metropolitan Statistical Area (SMSA) as defined by the Department of Commerce and reported to the Secretary of the Treasury, and (b) all local areas wholly outside of SMSAs. An eligible local area is an area that meets at least three of the following four criteria relative to all local areas in its category: i. its local unemployment rate (defined over a suitable period of time) is above the average, ii. its five-year growth rate of employment is less than the average, iii. its five-year growth rate of population is less than the average, and iv. its five-year absolute changes in per capita income is less than the average. This definition of distress measures both the level of economic activity (in the unemployment variable) and the rate of change of economic activity (in the employment growth rate, population growth rate, and per capita income change variables). An area which has below average unemployment may -7- still qualify as distressed if it has a low rate of economic growth according to each of the three measures of change. This means that poor areas with slow growth can qualify for assistance even if their unemployment rate is slightly below the national average. On the other hand, the use of an absolute change in per capita income will tend to eliminate wealthy areas with low percentage, but high absolute, changes in income since such areas will generally have below average unemployment. Thus aid will be channeled to those areas which are not providing adequate employment opportunities or are lagging behind the economic expansion of the rest of the nation. SMSAs encompass all the major urban areas of the country. Dividing local jurisdictions into two groups allows urban and non-urban areas to be compared to the average within their own group. Because some of the evaluation criteria used may have different meanings in urban and rural areas, this division is necessary to assure that each area is evaluated according to reasonably comparable criteria. In addition, the division provides that areas of economic distress in all sections of the country, including both distressed urban and distressed rural areas, are eligible for assistance. -8- In determining eligibility, data comparisons will be made for approximately 40,000 local government jurisdictions. It is important, however, that those areas in the country not within the boundaries of an incorporated local government also be eligible for assistance if they meet the test of economic distress. To assure this result, these unincorporated areas will be treated as a separate jurisdiction for which "balance of county" indicators will be calculated. A list of eligible local areas will be published every year reflecting the most recent available data. For predictability in investment planning, loss of eligibility for a previously eligible local area will be delayed for one year after failure of the formal eligibility test. Reasons for Change and Analysis of Effects The basic purpose of the urban tax proposals is to encourage private sector investment that will revitalize geographic areas suffering from long-term economic distress. Distressed areas include many of the major central cities in the nation, which have for years suffered the effects of a declining economic base, high unemployment and the loss of jobs and population to surrounding suburbs and to high-growth -9- regions. However, the proposal has been designed to take into account problems of economic distress outside as well a within major urban areas. The exception under present law that allows tax exemption for small issue IDBs enables States and localities to promote economic development by attracting new plants. Because their use is universally available, however, the competitive benefit to any one locality in attracting investment is largely cancelled by the use of IDBs by other localities. This proposal is designed to correct that defec of present law, by restructuring the incentive to target investment more sharply to areas of economic distress. Under the proposed eligibility test, St?te and local governments will be able to utilize the expanded small issue IDB provision on behalf of private investments in areas encompassing about one-third of the nation's population. Eligible areas will include almost all of the nation's largest cities, many smaller cities with high unemployment and slow growth, and stagnating rural areas throughout the country. Because the right to issue tax-exempt small issue IDBs will be limited to investments in eligible areas, the dollar cost to the Treasury will be negligible. The increased volume of IDBs issued in distressed areas will be -10- matched by a reduction in IDBs in areas not meeting the eligibility test. Thus, the incentives provided in this program will encourage State and local governments to issue IDBs to attract additional investment to distressed areas, while not increasing generally the use of tax-exempt borrowing or the amount of Federal subsidy under the proposed TBO. Revenue Estimate The revenue effect of this proposal is negligible (less than $1 million annually) . SMALL ISSUE INDUSTRIAL DEVELOPMENT BONDS H.£. 12078 (the Revenue -Act of 197S) is amended as follows: (1) Amend section 312 (Federal interest subsidyvfor State and local governments) by adding at the end thereof the following: (j) Industrial Development Bond Issues in Economically Distressed Areas.—See the National Development Bank Act of 1978 for alternative subsidy for issues in economically distressed areas the face amount of which is $20,000,000 or less (including issues which fail to satisfy the requirements of subparagraph (D) of section 103(b)(6) (exemption for certain small issues of industrial development bonds) by reason of clause (ii) thereof). (2) Amend section 321(b) (a) By striking out "the National Development Bank Act of 1978", and inserting in lieu thereof "section 322 of the Revenue Act of 1978"; and (b) By inserting the following paragraph after paragraph (2): (3) by striking out "$5,000,000" in the heading and text of subparagraph (D) and inserting in lieu thereof "$20,000,000". (3) Definition of Economically Distressed Areas.— Add the following new section to the bill. -2SEC. 322 ECONOMICALLY DISTRESSED AREAS. (a)' An area shall be treated as an economically distressed area to the extent such area is located with or within the qualifying areas shown on a list published by the Secretary of the Treasury in accordance with subsection (f). Notwithstanding the previous sentence, this treatment shall apply for the annual or interim period specified in subsection (f) and for the next following annual period. (b) Economically Distressed Areas Defined.—An "economically distressed area" is the area of a local government if for such area of local government at least three of the following conditions are satisfied: (1) The unemployment rate is above the average unemployment rate for the statistical grouping to which such local government belongs; (2) The rate of growth in employment is less than the rate of growth for the statistical grouping to which such local government belongs; (3) The absolute change in per capita income is less than the absolute change for the statistical grouping to which such local government belongs; and (4) The rate of growth in population is less than the rate of growth for the statistical grouping to which such local government belongs. The rates referred to in this subsection shall be determined as specified in subsection (d). -3(c) Definitions. (1) The term "local government" means (A) a municipality, township, or other political subdivision of a State (other than a county) which is a unit of general government (determined on the same principles as are used by the Bureau of the Census for general statistical purposes), including the District of Columbia, and (B) so much of a county (or, in the case of Alaska, a census division) as is not specified in subparagraph (A)• (2) The term "statistical grouping" shall mean either all Standard Metropolitan Statistical Areas ("SMSA's") (as determined by the Secretary of Commerce) considered as a group, or all areas outside of SMSA's ("non-SMSA's") considered as a group. A local government belongs to the statistical grouping comprised of all SMSA's if any part of the area of such local government is within the area of an SMSA; otherwise, such local government belongs to the statistical grouping comprised of non-SMSA's. (d) Determination of Rates. (1) Unemployment Rate.—For the purposes of this section the unemployment rate for a local government shall be determined by computing the average rate of -4unemployment in the area contained within the local government during the roost recent 20 calendar quarters for which data are available. The dates that define the period of time shall be the same for all local governments. (2) Rate of Growth in Employment.—For the purposes of this section, the rate of growth in employment for a local government shall be determined by subtracting from the employment in the area contained within the local government for the most recent 4 calendar quarters for which data are available, the employment within such area for a 4-calendar quarter period which preceded such recent 4 calendar quarters by either 5 or 6 years, as determined by the Bureau of Labor Statistics for the Secretary of Labor, and dividing this difference by the employment within such area for the earlier 4-calendar quarter period. For the interim period described in subsection (f)(2), the previous sentence shall be applied by substituting "at least 5 or 6 years" for "either 5 or 6 years". The dates that define the periods of time shall be the same for all local governments. (3) Absolute Change in Per Capita Income.—For the purposes of this section, the absolute change in per capita -5income for a local government shall be determined"by subtracting from the per capita income in the area contained within the local government for the most recent year for which data are available, the per capita income within such area for a year which preceded such recent year by either 5 or 6 years, as determined by the Bureau of the Census for the Secretary of Commerce for general statistical purposes. The dates that define the periods of time shall be the same for all local governments. (4) Rate of Growth in Population.—For purposes of this section, the rate of growth in population for a local government shall be determined by subtracting from the population in the area contained within the local government for the most recent year for which population data are available, the population in such area as of a date which preceded the date of the most recently available population data by either 5 or 6 years, as determined by the Bureau of the Census for the Secretary of Commerce for general statistical purposes, and dividing this difference by the population within such area for the earlier year. The dates that define the periods of time shall be the same for all local governments. -6(5) Nonavailability of Data for Specified TjLme Period.—If data are not available for the specified period of time for eligibility under paragraph (1) or for the earlier periods of time referred to in paragraphs (2), (3), and (4), the Secretary of Labor or the Secretary of Commerce, as the case may be, shall determine the local rate in question on the basis of data for the most appropriate period of time of less than 2 0 calendar quarters (in the case of paragraph (1)) or of less than 5 years (in the case of paragraphs (2), (3), and (4)). (6) Assignment of Rates.—Where an unemployment rate or rate of growth in employment cannot be determined for a local government, the unemployment rate or rate of growth in employment for the smallest unit of local government or appropriate geographic area for for which a local rate has been determined within the jurisdiction or area in which such local government is located shall be assigned to such local government. However, if the Governor of the State in which such local government is located has provided the Secretary of Labor with an unemployment rate or rate of growth in employment for such local government and the Secretary of Labor determines that such rate has been developed in a manner consistent with the procedures used by the Secretary of Labor then such rate shall be assigned to the local government. -7(7) For local governments described in subsection (c)(1) (B), the data required for paragraphs (1) through (4) shall be determined by subtracting from the data for the county so much of such data as are applicable to local governments described in subsection (c) (1)(A). (e) Responsibility for Determining Rates. (1) The Secretary of Labor shall determine or assign unemployment rates and rates of growth in employment for each local government and for each statistical grouping annually and shall report such rates annually to the Secretary of the Treasury. (2) The Secretary of Commerce shall determine the absolute change in per capita income and the rate of growth in population for each unit of local government and for each statistical grouping annually and shall report such rates annually to the Secretary of the Treasury. (f) Based upon the data supplied in accordance with subsection (e), the Secretary of the Treasury (or his delegate) (1) Shall annually compile and publish a list of all local governments which meet the requirements set forth in subsection (b), and (2) Is authorized to publish prior to the first annual publication described in paragraph (1) an interim list of all local governments which meet the requirements set forth in subsection (b). -8Each such publication shall state the period of time for which the list is applicable. DIFFERENTIAL INVESTMENT TAX CREDIT Present Law and Related Provisions of the Administration's Tax Program Taxpayers are entitled to a credit against their Federal income tax liabilities equal to 10 percent of their investments in certain qualified assets. The rate of this investment credit was temporarily increased to 10 percent from 7 percent as of January 25, 1975, and is scheduled to revert to 7 percent on January 1, 1981. Property eligible for the investment credit consists of depreciable property having an estimated useful life of 3 or more years which is either tangible personal property or other tangible property (such as fixtures and heavy machinery) used as an integral part of the productive process. The amount of investment credit for any year may be used, dollar for dollar, to offset tax liability of up to $25,000. Credits in excess of $25,000 may, in general, be used to offset up to 50 percent of tax liability in excess of $25,000. In any year in which the amount of the taxpayer's investment credit exceeds the applicable limits, the excess may be carried back to the three taxable years before and -2- forward to the seven taxable years after the year in which the asset was placed in service. In the case of pollution control equipment that is amortized over five years, the amount of the credit is reduced to 5 percent. Other exceptions apply to public utilities, railroads, and airlines. There is, however, no provision for variations in the investment credit according to the geographic location of particular investments. The President's 1978 Tax Program includes several significant changes in the investment credit. The current 10 percent investment credit would be made permanent. Industrial structures (including investments made to rehabilitate existing industrial structures) placed in service after December 31, 1977 would be included among the assets that will qualify for the credit. The investment credit (and investment credit carryovers) would be available to offset up to 90 percent of a taxpayer's liability for tax, including the first $25,000 of tax liability. Special limits for public utilities, railroads, and airlines would be phased out. Certified pollution control facilities eligible for the special 5 year amortization period would be made eligible for the full 10 percent investment credit. -3- Explanation of the Proposal The Administration proposes enactment of an additional investment credit for certain investments in distressed areas. The amount of this differential credit will be 5 percent, in addition to the existing 10 percent credit, for those investments or portions of an investment for which the Department of Commerce has issued a "certificate of necessity." Certificates for up to $400 million of additional credits may be issued during 1979 and 1980 for eligible investments. Only investments in distressed areas, as defined for purposes of the industrial development bond proposal, will be eligible to be certified. DEVELOPMENT BONDS." See "SMALL ISSUE INDUSTRIAL In selecting investments, the Department of Commerce will be required to consider the extent to which the investment will provide job opportunities in and contribute to the tax and economic bases of the distressed area. In addition, the Department of Commerce will have authority to certify investments in distressed enclaves located in jurisdictions that do not themselves qualify as distressed areas. However, only 5 percent of the investments certified for the differential credit may be in such distressed enclaves. -4- Applications for certificates allowing the additional credit will be made to the Department of Commerce, which will select those qualifying for the additional credit. After the issuance of a provisional certificate, the investor will be required, at a time when the investment is nearly complete, to obtain from the Department.of Commerce a further certification that the project has been carried out substantially as described in the provisional certificate. The final certificate issued by the Department of Commerce, when filed with the investor's tax return for the year the project is placed in service, will entitle the investor to the additional 5 percent credit. The additional investment credit otherwise will be subject to current rules governing qualification, limitations, and carryovers. Reasons for Change By augmenting the existing 10 percent credit, the differential investment credit will encourage companies to undertake specific projects that will create additional employment opportunities and help to relieve the fiscal pressure on local governments in communities that have been encountering relatively slow economic growth and high unemployment. The requirement for certification of individual projects will assure that the additional stimulus 5- cf this predit will be concentrated on those projects that are likely to contribute most to local economic development. This procedure is similar to the use of certificates of necessity during World War II and the Korean conflict to target incentives so as to induce production of goods necessary to the war effort. The certifying agency will be in a position to encourage the infusion of private capital into those localities- that need it the most and to select those projects that will have the most beneficial economic effects. The commitment of $400 million of tax revenues during a two-year period will encourage a private commitment of $8 billion of investment in economically distressed areas over a period of several years, as the projects are actually placed in service. Revenue Estimate Change in Tax Liability ($ millions) : Calendar Year :1979 -41 -132 -114 -30 -12 1980 1981 1982 1983 DIFFERENTIAL INVESTMENT TAX CREDIT R.R. 12078" (ihe Revenue Act of 1978) is amended by adding the following new sections to the bill: Sec. 422 , Additional Investment Credit for Certain Distressed . Area Property. (a) Allowance.—Section 46(a) (2) (as amended by section 421 of this Act) is amended by adding after subparagraph (B) the following new subparagraph: "(C) Distressed Area Property.—The amount of credit determined under this paragraph for the taxable.year is the amount determined without regard to this subparagraph plus five percent of that part of the qualified investment (as determined under subsections (c) and (d)) which is attributable to distressed area property (as • defined in subsection (h))." (b) Distressed Area Property.—Section 46 is amended by adding at the end thereof the following: "(h) Distressed Area Property.—For purposes of this section, a qualified investment is attributable to distressed area property to the extent of the basis of new section 38 property (as defined in section 48(c)), and so much of the qualified progress expenditures for the taxable year with respect to progress expenditure property (as defined in subsection (d)(2)(A)), as are specified in a final certificate issued pursuant to section 423 of the Revenue Act of 1978. - 2 Sec. 423/ Certification of Investments in Distressed Areas as Eligible for Additional Investment Credit _ (a) Availability.—The additional investment credit provided for in section 48(a)(2)(C) of the Code, as amended by sections 421 and 422 of this Act, shall be available in the amount finally certified by the Secretary of Commerce (or his delegate) pursuant to subsection (c). (b) Provisional. Certification.— (1) On the request of any person, at such time and in such manner as the Secretary of Commerce may prescribe by regulations, the Secretary of Commerce may issue a provisional certificate stating that a proposed investment made (A) in a jurisdiction that qualifies as an economically distressed area (as defined in section 322 of this Act), or (B) in any other locale that substantially meets the criteria used to define a distressed area, will be eligible for the additional credit for "distressed area property" provided in section 48(a)(2)(C). For purposes of this subsection, the determination of whether an area qualifies under subparagraph (A) or (B) shall be made as of the date of issuance of the provisional certificate. (2) In issuing the provisional certificate provided for in paragraph (1), the Secretary of Commerce shall 3describe the project for which the certificate is issued, the period of time (which for good cause shown ther Secretary of Commerce may extend) within which the project must be substantially completed, the maximum amount of investment for which the certificate is issued, and such other terms and conditions as the Secretary of Commerce may prescribe by regulations.. (3) In selecting investments for which certificates may be issued pursuant to paragraph (1), the Secretary of Commerce shall take into consideration, among other things, (A) for purposes of paragraph (1)(A), the extent to which any proposed investment will contribute to the - economic and tax bases of the jurisdiction in which it is proposed to be made, the extent to which it will, when placed in service, result in an increase in job opportunities,particularly for the chronically unemployed and low income and minority residents, available in such jurisdiction, and such other factors as the Secretary of Commerce by regulations may prescribe, and (B) for purposes of paragraph (1)(B), the pop- ulation density of the locale, the extent to which residents of the locale will benefit frcm the investment, and such other factors as the Secretary of Commerce by regulations may prescribe. - 4 (c) Final certification.— (1) When the Secretary of Commerce finds that any • investment for which a provisional certificate was issued pursuant to subsection (b) has been substantially completed within the time, in the manner and in compliance with such other terms and conditions as were set forth in such provisional certificate, the Secretary of Commerce shall issue a final certificate which shall specify, among other things, the identity of the project, and the amount of investment finally certified as being in distressed area property. Such final certificate shall also contain such additional information as the Secretary of Commerce (in consultation with the Secretary of the Treasury) may require by regulations. (2) No final certificates may be issued after December 31, 1982.—No final certificate issued after December 31, 1982 shall be valid for purposes of subsection (a) . (d) The amount of distressed area investment for which the Secretary of Commerce may issue provisional certificates may not exceed, in the aggregate, $4 billion during calendar year 1979 and $8 billion during calendar years 1979 and 1980; provided, that of such amount, no more than $200 million during calendar year 1979 and $400 million during calendar years 1979 and 1980 may be for investments described in subsection (b)(1)(B). DEPARTMENT OF THE TREASURY WASHINGTON. D.C. 20220 ASSISTANT SECRETARY MAY 2 2 1978 Dear Mr. Chairman: For your information, I am enclosing copies of the letters and enclosures which I have sent today to the Speaker of the House of Representatives and the President of the Senate with respect to the Targeted Employment Tax Credit initiative of the President's urban program. Sincerely, Donald C. Lubick Acting Assistant Secretary (Tax Policy) The Honorable Al Ullman Chairman, Committee on Ways and Means House of Representatives Washington, D.C. 20515 Enclosures TARGETED EMPLOYMENT TAX CREDIT Present Law Under present law, a New Jobs Tax Credit is allowed to employers for additions to employment in a trade or business over a base level that is determined by employment in the previous calendar year Qualified increases in employment are measured by the amount of an employer's aggregate unemployment insurance wages under the Federal Unemployment Tax Act (FUTA) . Generally, the credit is 50 percent of the amount by which FUTA wages paid during the current calendar year exceeds 102 percent of FUTA wages paid during the preceding year. calendar An additional credit equal to 10 percent of FUTA wages paid to certain handicapped individuals is also allowed. The credit applies only to FUTA wages paid for calendar years 1977 and 1978. The amount of the New Jobs Tax Credit is limited to the lesser of: (1) 50 percent of the amount by which total wages paid during the current year exceeds 105 percent of total wages paid during the previous year; (2) 25 percent of FUTA wages paid during the current year; -2(3) $100,000 for any given year (except for the additional 10 percent credit for handicapped individuals); or (4) The employers' income tax liability for the year, reduced by certain other credits. The employer's deduction for wages must be reduced by the amount of the credit allowable. Unused credits may be carried back three years and forward seven years. Special rules apply to controlled groups of corporations and other entities under common control, self-employed individuals who become employees, and situations where ownership of a major portion of a business changes hands. Explanation of the Proposal The Administration proposes that the present New Jobs Tax Credit be allowed to expire, as scheduled, and that a Targeted Employment Tax Credit be enacted in its place to be effective January 1, 1979. This credit would be available to employers of certain low-income young persons and certain handicapped individuals. These persons would be certified as eligible by local agencies designated as "prime sponsors" under the Comprehensive Employment and Training Act (CETA). To be certified as eligible, an individual must be either (1) at least 18 years of age and no more than 24 years of age and a member of a household that has an income of less than 70 percent of the regional lower living standard, or - 3 (2) a handicapped individual referred to the employer under. a vocational rehabilitation referral plan. An individual may not be certified as eligible while employed under a contract for on-the-job training that is financed from any Federally funded source. Generally, an employer would be entitled to a credit against income tax equal to one-third of the FUTA wages paid to eligible employees during their first year of employment plus one-fourth of the FUTA wages paid to eligible employees during their second year of employment. The credit is available only for full-time employment (at least 30 hours per week) in a trade or business within the United States; and no credit will be allowed unless the employee has been kept in continuous full-time employment for at least 75 calendar days. The amount of base wages eligible for the credit in any year is limited to 20 percent of the employer's total FUTA payroll. The amount of the credit that may be claimed in any year is also limited by the same rule that the Administration has prcposed for the investment credit and for the welfare credits; that is, the total amount of all of these tax credits may not exceed 90 percent of tax liability in any 1 year. Credits in excess of the 90 percent limit may be carried back 3 years or forward 7 years, as under current law. The requirement of present jobs credit that the - 4 employer's deduction for wages be reduced by the amount of the credit allowed would also be continued under this proposal. An employer would not be allowed to claim a WIN or welfare credit and a targeted employment credit for wages paid to the same employee. Reasons for Change The Targeted Employment Tax Credit would replace the present, unfocused Jobs Credit that may reward employees for any increase in employment. Thus, the tax incentive for hiring additional employees would be focused on disadvantaged young people, who are experiencing as a group the highest rates of unemployment, and on handicapped individuals. In recent years, the average unemployment rate among disadvantaged 18 to 24 year olds has been several tiroes the average rate for the labor force as a whole. In addition, there is evidence that employment of minorities within this group has not responded to the overall decline in unemployment in the current recovery as rapidly as would be forecast from previous recoveries. The Targeted Employment Tax Credit attacks a serious problem of structural unemployment and is, therefore, an important complement to a program of overall fiscal stimulus. - 5 The proposed employment credit also avoids the tendency of the present incremental credit to reward industries and regions that experience rapid or sporadic employment growth relative to those that have gradual or no growth. This feature of the present jobs credit is not only unfair, but it also may contribute to cyclical instability in the economy. The existing credit provides no additional hiring incentive for employers that are subject to the $100,000 ceiling nor has it succeeded in stimulating many new employment opportunities among employers that are not limited by this ceiling. Recent preliminary evidence from a survey of taxpayers indicates that a very large percentage of the existing credit goes to employers who report no conscious effort to increase employment in response to the credit. The proposed credit will provide assistance for disadvantaged young persons to find jobs or to obtain better jobs in the private labor market. It will also provide private employers an incentive to retain eligible workers during the critical first 2 years of employment in which work habits and skills are developed. The eligible individual will be able to offer an employer the prospect of a tax credit of as much as $2,000 for the first year of employment and up to $1,500 for the second year of employment. - 6 So long as the employee is retained for at least 75 calendar days, and eligible employees account for no more than 20 percent of FUTA payroll, the employer will be entitled to the tax credit. The amount of credit will not depend upon the size of the employer's business or how rapidly it is growing. There are no "recapture" rules for employees that leave, whatever the cause. Thus, there is a high degree of certainty associated with this proposal. Such certainty is important to the success of any economic incentive program. An employee who meets the eligibility criteria need not change jobs or experience a period of unemployment in order to qualify an employer for credits. However, an employee who leaves a job after 75 calendar days, must be recertified as still within the age and income limits in order to remain eligible. These rules are intended to provide flexibility for employers and employees in their employment decisions and also to minimize compliance and administrative burdens. The employer would only need to keep track of the first day of employment for each eligible employee and maintain separate accounts for FUTA wages paid to those in the first year and those in the second year of employment. The employee who loses a job or wishes to seek a better one may have the advantage of eligibility at any time that the age and household income tests are met. Neither the certification agency, nor the IRS would be required to follow individual workers from job to job. - 7 tinder this proposal an employer whose work force con- * sists primarily of semiskilled or inexperienced workers could not undertake wholesale replacement of non-eligible employees with eligible employees. The share of FUTA payroll that qualifies for the credit is limited to 20 percent. This is approximately the average rate of labor turnover in a year, so that employers could reach the maximum credit in a year by filling job vacancies as they normally occur. When the proposed program is fully in effect, credits will be allowed on behalf of approximately 1.9 million disadvantaged and handicapped workers. Many of these would otherwise have been unemployed and many will have found better jobs (including full-time in place of part-time jobs) as a result of their eligibility. Revenue Estimate Change in Tax Liability ($ millions) Calendar Years ~~ 19 79 19 80 19 81 19 82 19 83 -562 -1,069 -1,231 -1,306 -1,381 -1,498 Full effect TARGETED EMPLOYMENT TAX CREDIT H.R. 12078 (the Revenue Act of 1978) is amended by adding the following new section to the bill. SECTION 215. TARGETED EMPLOYMENT TAX CREDIT. (a) Amount of Credit.—Section 51 of the Internal Revenue Code of 1954 is amended to read as follows: "SEC. 51. AMOUNT OF CREDIT. "(a) First-In-First-Out Rule.—The amount of the credit allowed by section 44B for the taxable year shall be an amount equal to the sum o f — "(1) the section 44B credit carry- overs carried to such taxable year, "(2) the amount of the credit determined under subsection (b) for such taxable year, plus "(3) the section 44B credit carry- backs carried to such taxable year. "(b) Determination of Amount of Credit for Current Taxable Year.—The amount of the credit determined under this subsection for the taxable year shall be an amount equal to the sum o f — "(1) the amount that is equal to 1/3 of the wages paid to full-time eligible employees during their first year of employment, and "(2) the amount that is equal to 1/4 of the wages paid to full-time eligible employees during their second year of employment. - 2 For purposes of this subpart, an eligible employee's first year of employment begins on the first day of employment after certification or referral as described in section 51(d)(2), or, in the case of an individual who is employed at the time of certification or referral, on the first day of employment in the calendar year in which certification or referral occurs. "(c) Limitations and Conditions for Allowance.— "(1) Seventy-five day rule.—No credit shall be allowed with respect to an eligible employee unless that employee is employed for at least seventy-five consecutive calendar days. "(2) Remuneration must be for trade or business employment within the United States.—Remuneration paid to an eligible employee shall be taken into account only if more than one-haj.f of the remuneration so paid is for services performed in the United States in a trade or business of the employer. "(3) WIN credit may not be claimed.—An employer allowed a credit for the taxable year under section 40 with respect to the employment of an employee who is an eligible employee within the meaning of subsection (d)(2) shall not be allowed a credit under section 44B for wages paid to that employee during that taxable year -3"(4) Maximum amount of credit attributable to an employee's first year of employment.—The amount of the credit allowed attributable to wages paid to any one full-time eligible employee during the first year of employment shall not exceed $2,000. "(5) Limitation based on total wages.—The aggregate amount of wages used in computing the credit under subsection (b) shall not exceed 20 percent of the total amount of wages paid to all employees during the calendar year ending with or within the employer's taxable year. "(d) Definitions.—For purposes of this subpart.— "(1) Wages.—The tern 'wages' has the meaning given the term 'wages' by section 3306(b), except that for purposes of applying section 3306(b) services performed by an eligible employee— "(A) during more than one-half of any pay period (within the meaning of section 3306(d)) within the taxable year that constitute agricultural labor (within the meaning of section 3306 (k)), or "(B) for which more than one-half of the remuneration for the taxable year is attributable to services described in section 3306(c)(9), shall be considered to be employment. - 4 "(2) Eligible employee.—The term 'eligible employee' means an individual w h o — "(A) has been certified by the Secretary of Labor or such entity that he may choose, including a prime sponsor (as designated by the Secretary of Labor under chapter 17 of title 29, United States Code) or the state employment security agency, to be at the time of certification— "(i) at least eighteen years of age but not yet twenty-five years of age, "(ii) a member of a household that has an annualized income for the 6 month period prior to certification (exclusive of unemployment compensation and welfare payments) which, in relation to family size, is less than seventy percent of the lower living standard income level, and "(iii) not participating in an on- the-job training position in which funds provided, directly or indirectly, by the Federal Government are being paid to the employer as part of that individual's participation; or - 5 "(B) has a physical or mental disability which constitutes or results in a substantial handicap to employment and has been referred to the employer upon completion of (or while receiving) rehabilitative services pursuant t o — "(i) an individualized written rehabilita- tion plan under a State plan for vocational rehabilitation services approved under the Rehabilitation Act of 1973, or "(ii) a program of vocational rehabilita- tion carried out under chapter 31 of title 38, United States Code. "(3) Lower living standard income level.—The term 'lower living standard income level' means that income level (adjusted for regional and metropolitan and urban and rural differences and family size) determined annually by the Secretary of Labor based upon the most recent 'lower living family budget' issued by the Secretary of Labor." (b) Special Rules.— (1) Trades or businesses under common control.— Subsections (a) and (b) of section 52 of the Internal Revenue Code of 1954 are amended to read as follows: "(a) Controlled Group of Corporations.—For purposes of this subpart, an eligible employee who works for more than one corporation that is a member - 6 of the same controlled group of corporations shall be treated as employed by a single employer. In such a case, the credit (if any) allowed by section 44B to any such member shall be determined by the amount of wages it has paid the employee during the taxable year, after first taking into account any wages previously paid during the taxable year by other members of the controlled group. For purposes of this subsection, the term •controlled group of corporations' has the meaning given to such term by section 1563 (a) , except that— "(1) 'more than 50 percent' shall be substituted for 'at least 80 percent' each place it appears in section 1563 (a) (1) , and "(2) the determination shall be made without regard to subsections (a) (4) and (e) (3) (C) of section 1563. ("b) Employees of Partnerships, Proprietorships, Etc., Which Are Under Common Control.—For purposes of this subpart, under regulations prescribed by the Secretary, an eligible employee who works for more than one trade or business (whether or not incorporated) in a group of trades or businesses that are under common control shall be treated as employed by a single employer* - 7 and the credit (if any) allowed by section 44B to any such trade or business shall be determined by the amount of wages it has paid the employee during the taxable year, after first taking into account any wages previously paid during the taxable year by other trades or businesses in the same group under common control. The regulations prescribed under this subsection shall be based on principles similar to the principles which apply in the case of subsection (a).". (2) Conforming amendments.— (A) Subsections (c) and (e) of section 52 are deleted, subsection (d) is relettered as subsection (c), and subsection (f) is relettered as subsection (d). (B) Subsection (g) of section 52 is relettered as subsection (e) and is amended by inserting "and" at the end of paragraph (1), by striking out ", and" at the end of paragraph (2) and inserting in lieu thereof a period, and by striking out paragraph (3). (C) Subsection (h) of section 52 is relettered as subsection (f), and subsections (i) and (j) are deleted. - 8 (c) Limitation Based on Amount of Tax.— (1) Subsection (a) of section 53 of the Internal Revenue Code of 1954 is amended to read as follows: "(a) General Rule.—The credit allowed by section 44B for the taxable year shall not exceed ninety percent of its adjusted tax base provided in section 54 for the taxable year.". (2) Subsection (b) of section 53 is deleted. (3) Subsection (c) of section 53 is relettered as subsection (b) and amended to read as follows: "(b) Carryback and Carryover of Unused Credit.— "(1) In general.—If the sum of the amount of the section 44B credit carryovers to the taxable year under section 51 (a) (1) plus the amount determined under section 51 (a) (2) for the taxable year exceeds the amount of the limitation provided by subsection (a) for such taxable year (hereinafter in this subsection referred to as the "unused credit year"), such excess attributable to the amount determined under section 51 (a) (2) shall b e — " (A) a section 44B credit carryback to each of the 3 taxable years preceding the unused credit year, and - 9 "(B) a section 44B credit carryover to each of the 7 taxable years following the unused credit year, and, subject to the limitations imposed by section 51(b) and subsection (a) of this section, shall be taken into account under the provisions of section 51(a) in the manner provided therein. If any portion of such excess is a carryback to a taxable year beginning before January 1, 1977, section 44B shall be deemed to have been in effect for such taxable year for purposes of allowing such carryback as a credit under such section. The entire amount of the unused credit for an unused credit year shall be carried to the earliest of the 10 taxable years to which (by reason of subparagraphs (A) and (B)) such credit may be carried, and then to each of the other 9 taxable years to the extent that, because of the limitation contained in paragraph (2), such unused credit may not be added for a prior taxable year to which such unused credit may be carried. - 10 "(2) Limitation on carrybacks.--The amount of the unused credit that may be taken into account under section 51 (a) for any preceding taxable year shall not exceed the amount by which the limitation provided by subsection (a) of this section for such taxable year exceeds the sum of— " (A) the amounts determined under paragraphs (1) and (2) of section 51 (a) for such taxable year, plus "(B) the amounts which, by reason of this subsection, are carried back to such taxable year and are attributable to taxable years preceding the unused credit year. "(3) Limitation on carryovers.— The amount of the unused credit that may be taken into account under section 51 (a) (1) for any succeeding taxable year shall not exceed the amount by which the limitation provided by subsection (a) of this section for such taxable year exceeds the sum of the amounts which, by reason of this subsection, are carried to such taxable year and are attributable to taxable years preceding the unused credit year n - 11 (d) Technical and Conforming Amendments.~ (1) Clerical amendments.— (A) The table of sections for subpart A of part IV of subchapter A of chapter 1 is amended by striking "Sec. 44B. Credit for employment of certain new employees.", and inserting in lieu thereof, nSec. 44B. Targeted employment tax credit." (B) The table of subparts for part IV of subpart IV of subchapter A of chapter 1 is amended by striking "Subpart D. Rules for computing credit for employment of certain new employees.", and inserting in lieu thereof, "Subpart D. Rules for computing targeted employment tax credit." (2) Minimum tax.—Clause (iv) of section 56 (e) (1) (A) is amended by striking out "credit for employment of certain new employees", and inserting in lieu thereof "credit for employment of certain employees". (3) Corporate reorganizations.— (A) Paragraph (26)of section 381 (c) (relating to items of the distributor or transferor corporation) is amended by striking the word "NEW" from the heading. - 12 (B) Section 383 (relating to special limita- . tions on unused investment credits, work incentive program credits, new employee credits, foreign taxes, and capital losses) , as in effect for taxable years beginning after June 30, 1978, is amended— (i) by striking out "to any unused new employee credit of the corporation under section 53 (c)," and inserting in lieu thereof "to any unused new employee or targeted employment tax credit of the corporation under section 53 (b),"; and (ii) by inserting immediately after "New Employee Credits," in the heading the phrase "Targeted Employment Tax Credits," (C) Section 383 (as in effect on the day before the date of the enactment of the Tax Reform Act of 1976) is amended— (i) by striking out "to any unused new employee credit of the corporation under section 53(c)," and inserting in lieu thereof "to any unused new employee or targeted employment tax credit of the corporation under section 53 (b),"; and - 13 (ii) by inserting immediately after "New" Employee Credits ," in the heading the phrase "Targeted Employment Tax Credits,". (D) The table of sections for part V of sub- chapter C of chapter 1 is amended by inserting after "new employee credits," the phrase "targed employment tax credits,". (4) Statutes of limitation and interest relating to targeted employment tax credit carryback.— (A) Assessment and collection.—Subsection (p) of section 6501 (relating to limitations on assessment and collection) is amended b y — (i) revising the heading to read "Carry- backs of Credits under Section 44B"; and (ii) striking out "new employee" each place it appears and inserting in lieu thereof "section 44B". (B) Credit or refund.—Paragraph (9) of sec- tion 6511 (d) (relating to limitations on credit or refund) is amended b y — (i) revising the heading to read "Special period of limitation with respect to carrybacks of credits under section 44B"; and (ii) striking out "new employee" each place it appears and inserting in lieu thereof "section 44B". - 14 (C) Interest on underpayments and overpayments.Paragraph (5) of section 6601 (d) (relating to income tax reduced by carryback or adjustment for certain unused deductions) and section 6611 (f) (relating to refund of income tax caused by carryback or adjustment for certain unused deductions) are amended b y — (i) revising the headings to read "carryback of credits under section 4 4B."; and (ii) striking out "new employee" each place it appears and inserting in lieu thereof "section 44B". (5) Tentative carryback adjustments.— (A) Application for adjustment.—Section 6411 (relating to quick refunds in respect of tentative carryback adjustments) is amended— (i) by striking out "or unused new employee credit" each place it appears in such section and inserting in lieu thereof "unused new employee or targeted employment tax credit", (ii) by striking out "new employee credit" each place it appears in the first two sentences of subsection (a) and inserting in lieu thereof "new employee or targeted employment tax credit", and - 15 (iii) by striking out "section 53 (c)," • in the first sentence of subsection (a) and inserting in lieu thereof "section 53(b),". (B) Tentative carryback adjustment assessment period.—Section 6501 (m) (relating to tentative carryback adjustment assessment period) is amended by striking out "or a new employee credit carryback" and inserting in lieu thereof "a new employee credit carryback, or a targeted employment tax credit carryback". (6) Self-employment tax.—Subsection (a) of seeon 1402 (relating to net earnings from self-employment) amended by— (A) striking out "and" at the end of paragraph (11) ; (B) striking out the period at the end of paragraph (12) and inserting in lieu thereof "; and "; and (C) adding a new paragraph (13) to read as follows; "(13) the deduction for wages and salaries shall be determined without regard to section 280C". List of Eligible Jurisdictions for the Industrial Development Bond and Differential Investment Tax Credit Provisions of the Administration's Urban Program The accompanying list indicates the areas of the country which satisfy the distress test for eligibility under the Industrial Development Bond and Differential Investment Tax Credit provisions of the Administration's Urban Program. For towns, cities, and townships shown in the list, the eligible area is defined by the boundaries of the local jurisdiction. In the case of counties, the eligible area refers to that portion of the county outside of incorporated or organized jurisdictions. The key to the state codes in the list of eligible areas is as follows: 01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17 Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware District of Columbia Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Kentucky Louisiana Maine Maryland Massachusetts Michigan Minnesota Mississippi Missouri Montana Nebraska Nevada New Hampshire New Jersey New Mexico New York North Carolina 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 North Dakota Ohio Oklahoma Oregon Pennsylvania Rhode Island South Carolina South Dakota Tennessee Texas Utah Vermont Virginia Washington West Virginia Wisconsin Wyoming 0 5 / 2 3 / 7 8 AT 0 l : ? 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 1 BARBOUR COUNTY 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 i 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 i 1 1 1 1 I 1 1 1 1 1 266-274 O - 78 - 5 BIBB COUNTY BULLOCK COUNTY BUTLER COUNTY CALHOUN COUNTY CHAMBERS COUNTY CHOCTAW COUNTY CLARKE COUNTY CLAY COUNTY CLEBURNE COUNTY COLBERT COUNTY CCNECUH COUNTY C O O S A COUNTY C O V I N G T O N COUNTY CULLMAN COUNTY DALE COUNTY D A L L A S COUNTY ESCAMBIA C O U N T Y E T O W A H COUNTY FAYETTE COUNTY GENEVA C O U N T Y G R E E N E COUNTY HALE COUNTY LAWRENCE COUNTY LIMESTONE COUNTY LOWNOES COUNTY MACON COUNTY MADISON C O U N T Y MARENGO C O U N T Y MARSHALL C O U N T Y MCNROE C O U N T Y MORGAN C O U N T Y PERRY COUNTY PICKENS COUNTY PIKE COUNTY RANDOLPH COUNTY RUSSELL C O U N T Y TALLADEGA C O U N T Y TALLAPOOSA C O U N T Y WILCOX COUNTY WINSTON COUNTY BLUE S P R I N G S TOWN C L A Y T O N TOWN C L I O TOWN E U F A U L A CITY L O U I S V I L L E TOWN PAGE OF THE TREASJRY i 05/23/73 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY rE!ST (ELIGIBLE GOVERNMENTS) STATE TITLE 1 BRENT TOWN 1 CENTREVILLE CITY 1 MIOWAY TOWN i UNION SPRINGS CITY 1 G E O R G I A N A TOWN 1 GREENVILLE CITY 1 MCKENZIE TOWN 1 ANNISTON CITY 1 BLUE M O U N T A I N TOWN 1 H 0 8 S 0 N CITY TOWN 1 JACKSONVILLE CITY 1 OHATCHEE TOWN 1 O X F O R D TOWN 1 PIEDMONT CITY 1 W E A V E R TOWN 1 F I V E P O I N T S TOWN 1 LAFAYETTE CITY 1 L A N E T T CITY 1 M A P L E S V I L L E TOWN 1 T H O R S B Y TOWN 1 GILBERTOtfN TOWN 1 S I L A S TOrfN 1 TGXEY TOWN 1 PENNINGTON TOWN 1 F U L T O N TOWN 1 G R O V E HILL TOWN 1 J A C K S O N CITY 1 THQMASVILLE CITY 1 EDWARDSVILLE TOWN 1 LEIGHTON TOWN 1 L I T T L E V I L L E TOWN 1 SHEFFIELD CITY 1 T U S C U M 6 K CITY 1 C A S T L E B E R R Y TOWN 1 EVERGREEN CITY 1 R E P T O N TOWN 1 GOODWATER CITY 1 RCCKFGRD TOWN 1 ANOALUSIA CITY 1 F L O R A L A CITY 1 H E A T H TG*N I L C C K H A R T TOWN I OPP C I T Y I RIVER F A L L S TOWN L B A B B I E CITY I C A R O L I N A TOWN OF THE TREASURY 05/23/78 AT 31:25 U . S . D E P A R T M E N T OF THE DISTRESSED AREA ELIGIBILITY TLiST (ELIGIBLE GOVERNMENTS) STATE TITLE 1 GAN1T TOWN 1 HORN HILL TOWN 1 LIbERTYVILLE TOWN 1 O N Y C H A TOWN 1 S A N F O R D TOWN 1 G A R D E N CITY TOWN 1 H A N C E V I L L E TOWN 1 S O U T H V I N E N G N T TOWN 1 F A I R V I E W TOWN 1 G O O D HOPE TOWN 1 B A I L E Y T C N TOWN 1 A R I T O N TOWN 1 M I D L A N D CITY TOWN 1 N E W T O N TOWN 1 O Z A R K CITY 1 P I N C K A R D TOWN 1 D A L E V I L L E TOWN 1 LEVEL PLAINS TOWN 1 G R I M E S TOWN 1 N A P I E R FIELD TOWN 1 C L A Y H A T C H E E TOWN 1 ORRVILLE TOWN 1 SELMA CITY 1 H A M M O N D V I L L E TOWN 1 S H I L O TO*N 1 A T M O R E CITY 1 B R E W T O N CITY 1 E A S T BREWTON TOWN 1 F L O M A T O N TOWN 1 P C L L A R O TOWN 1 RIVERVIEW TOWN 1 ALTOONA TOWN 1 A T T A L L A CITY 1 G A D S O E N CITY 1 G L E N C O E TOrfN 1 RAINBOW CITY TOWN 1 REECE CITY TOWN 1 WALNUT G R O V E TOWN 1 M G U N T A I N 3 G R 0 TOWN 1 S A R D I S CITY TOWN I R I D G E V I L L E TOWN 1 F A Y E T T E CITY 1 H C O G E S TOWN 1 BLACK RRED U S S EBAY L LTOrfN V ICITY LLE CITY PAGE TREASURY 3 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 1 CCFFEE SPRINGS TOWN 1 GENEVA CITY 1 HARTFORD TOWN 1 MALVERN TOWN 1 SAMSON CITY 1 SL0C0M8 TOWN 1 EUNOLA TOWN 1 BOLIGEE TOWN 1 EUTAW CITY 1 F C R K L A N D T3WN 1 AKRON TOWN 1 GREENSBORO CITY 1 NEW3ERN TOWN 1 HEADLAND C I T Y 1 BRIDGEPORT CITY 1 8ESSEMER CITY 1 BIRMINGHAM C I T Y 1 D E T R O I T TOWN 1 ST FLORIAN TOWN 1 C C U R T L A N 3 TOWN 1 H I L L S B O R O TOWN 1 TCWN CREEK TOWN 1 ARDMGRE TOWN 1 A T H E N S CITY 1 E L K M O N T TOWN 1 MCORESVILLE TOWN 1 LESTER TOWN 1 FORT D E P O S I T TOWN 1 8ENT0N TOWN 1 H A Y N E V I L L E TOWN 1 NOTASULG* TOWN 1 TUSKEGLE C I T Y 1 F R A N K L I N TOWN 1 HUNTSVILLE C I T Y 1 MAOISON TCWN 1 GURLEY TOWN i TRIANA TOWN L O W E N S CROSS RCAOS TOWN L D A Y T O N TOWN L D E M O P O L I S CITY L F A U N S D A L E TOWN L LINDEN CITY THOMASTON TOWN MYRTLEwOOD TOWU SWEETWATER TOWN P R O V I D E N C E TOWN PAGE OF THE TREASURY 4 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 1 BEAR CREEK TOWN 1 BRILLIANT TOWN 1 G U I N TUWN 1 HACKLEaURG TOWN 1 AL8ERTVILLE CITY 1 ARAB CITY 1 G R A N T TOWN 1 GUNTERSVILLE CITY 1 U N I O N G R O V E TOWN 1 B A Y O U LA 3 A T R E T O W N 1 PRICHARO CITY 1 M O U N T V E R N O N TOWN 1 W I L M E R TOWN 1 BEATRICE TOWN 1 E X C E L TOWN 1 F R I S C O CITY TO^N I MCNROEVILLE CITY STATE = l: 201 RECORDS PAGE OF THE TREASURY 5 PAGE 05/2 3/78 A T ^ : 2 ^pARTMENT 0F THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 1 VRE0EN8URGH TOWN STATE = l: 1 RECORDS TREASURY 6 0 5 / 2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 1 DECATUR CITY 1 FALKtflLLE TOWN 1 HARTSELLE CITY 1 EVA TOWN 1 M A R I O N CITY 1 U M C N T O W N TOWN 1 ALICEVILLE CITY 1 C A R R O L L T O N TOWN 1 G O R D O TOWN 1 R E F O R M TOWN 1 E T H E L S V I u L E TOWN 1 PICKENSVILLE TOWN 1 MC M U L L E N TOWN 1 M E M P H I S TOWN 1 B A N K S TOWN 1 B R U N O I D G E TOWN 1 TROY CITY 1 R C A N O K E CITY 1 * A O L E Y TOW.M 1 W E D O W E E TOWN 1 W O O D L A N D TOWN 1 H U R T S B O R O TOWN 1 P H E N I X CITY 1 B C N AIR TOWN 1 C H l L D E R S i U R G TOWN 1 G A N T T S QUARRY TOWN 1 L I N C O L N TOWN 1 SYLACAUGA CITY 1 TALLADEGA CITY 1 T A L L A D E G A S P R I N G S TOWN 1 ALEXANDER CITY CITY 1 CAMP HILL TOWN 1 D A D E V I L L E TOWN 1 OAVISTON TOWN 1 C A R B O N HILL C I T Y 1 C C R O O V A CITY 1 DCRA TOWN 1 OAKMAN TOWN 1 P A R R I S H TOWN 1 OAK HILL T O W N 1 PINE APPLE TOWN 1 PINE HILL TOWN 1 A O D I S O N TOWN 1 DCUBLE SPRINGS TOWN 1 HALEYVILLE CITY 1 L Y N N TOWN OF THE TREASURY 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T OF THE PAGE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) TITLE STATE ARLEY TOWN STATE = l: 47 RECORDS TEST 8 0 5 / 2 3 / 7 8 AT 31 :25 U.S. DEPARTMENT D I S T R E S S E D AREA PAGE OF 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 TITLE KCDIAK I S L A N D * 0 R 0 TOTAL FOR 3ARR0W TOTAL FOR K O D I A K SAXMAN CITY OLD HARBOR C I T Y O U Z I N K I E CITY PORT L I O N S C I T Y AKHIOK CITY LARSEN BAY C I T Y EAGLE CITY KAKE CITY SAINT MARYS CITY AKOLMIUT CITY MEKORYUK C I T Y PILOT STATION C I T Y SCAMMON BAY CITY SHAKTOOLIK C I T Y TELLER CITY W A L E S CITY AKIAK CITY D I O M E D E CITY G C L O V I N CITY KCYUK CITY TULUKSAK C I T Y PORT HEIOEN CITY ALEKNAGI* CITY H U G H E S CITY KCBUK CITY PORT A L E X A N D E R C I T Y STATE = 2: 29 RECORDS TREASURY ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE THE TEST 05/23/76 AT 31:25 U.S. DEPARTMENT PAGE 10 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 3 WILLIAMS CITY 3 HAYDEN TOWN 3 AVONDALE CITY 3 TOLLESON CITY 3 GILA BEN3 TOWN 3 SOUTH TUCSON TOWN 3 COOLIDGE CITY 3 MAMMOTH TOWN 3 WELLTON TCWN STATE = 3: 9 RECORDS TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE 11 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE STATE 4 4 4 4 4 <• 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 TITLE ASHLEY COU NTY BRADLEY CO UNTY CALHOUN CO JNTY CHICOT COU NTY CLARK COUN TY CLAY COUNT Y CLEVELAND COUNTY CONWAY COU NTY OALLAS COU NTY OESHA COUN TY FULTON COU NTY HOT SPRING COUNTY JACKSON CO UNTY LAFAYETTE COUNTY LEE COUNTY LINCOLN CO UNTY LITTLE RIV ER COUNTY LCGAN COUN TY MADISON CO UNTY MILLER COU NTY MISSISSIPP I COUNTY MONTGOMERY COUNTY NLVAOA COU NTY 0UACHI1A C OUNTY PHILLIPS C OUNTY POINSETT C OUNTY POLK COUNT Y PRAIRIE CO UNTY ST FRANCIS COUNTY SCOTT COUN TY SEARCY COU NTY HAMBURG CI TY BANKS TCWN WARREK CIT Y HAMPTON CI TY THORNTON T OWN HARRELL TO WN TINSMAN CI TY DERMOTT CI TY EUOORA CIT Y LAKE VILLA GE CITY AMITY CITY ARKADELPHI A CITY GURDON CIT Y OKOLONA TO WN WHELEN SPR INGS TOWN GOVERNMENTS) TEST 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 TITLE GUM SPRINGS TOWN CADDO VALLEY TOWN DATTO TOWN GREENWAY CITY KNOBEL TOWN NIMMONS TCWN PEACH ORCHARD TOWN PIGGOTT CITY POLLARD TOWN ST FRANCIS CITY SUCCESS TOWN MC DOUGAL TOWN KING SLA NO CITY RISON CITY MORRILTON CITY MENIFEE TOWN MULBERRY CITY EARLE CITY GILMORE TOWN NCRVELL TOWN CARTHAGE CITY SPARKMAN TOWN ARKANSAS CITY TOWN DUMAS CITY MCGEHEE CITY REED TOWN MITCHELLVILLE CITY GUY TOWN ALTUS CITY BRANCH CITY DENNING TOWN MAMMOTH SPRING TOW SALEM CITY VIOLA TOWN POYEN TOWN OELAPLAINE TOWN FRIENDSHIP TOWN PERLA TOWN AfAGON TOWN GRUBBS TOWN NEWPORT CITY SWIFTON CITY TUCKtRMAN CITY TUPELO TOWN JACKSONPORT TOWN WELDON TOWN PAGE 12 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TLiST (ELIGIBLE GOVERNMENTS) STATE TITLE 4 BEEDEVILLE TOWN 4 3 R A 0 L E Y CITY 4 B U C K N E R CITY 4 LEWISVILLE CITY 4 S T A M P S CITY 4 ALICIA TOWN 4 BLACK ROCK C I T Y 4 MINTURN TOWN 4 SEDGWICK T O W N 4 S M I T H V I L L E TOWN 4 LYNN TOWN 4 MARIANNA C I T Y 4 MORO TOWN 4 RONDO TOWN 4 AUBREY TOWN 4 G C U L O CITY 4 GRADY TOWN 4 STAR CITY CITY 4 A S H D O W N CITY 4 F O R E M A N CITY 4 OGDEN TOWN 4 H I L T O N TOWN 4 W I N T H R O P TOWN 4 8LJE M O U N T A I N TOWN 4 BOONEVILLE CITY 4 MAGAZINE TOWN 4 P A R I S CITY 4 RATCLIFF C I T Y 4 S C R A N T O N TOWN 4 S U 3 I A C 0 TOWN 4 C A U L K S V I L L E TOWN 4 ST PAUL TOWN 4 G A R L A N O TOWN 4 F O U K E TOWN 4 TEXARKANA C I T Y 4 JOINER CITY 4 LUXORA TOWN 4 BURDETTE CITY 4 B A S S E T T TOWN 4 CLARENDON CITY 4 MOUNT IDA C I T Y 4 NCRMAN TOWN 4 ODEN TOWN <• BLACK S P R I N G S TOWN 4 EMMET CITY 4 PRESCOTT CITY PAGE OF THE TREASURY 13 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT TO< -. c ,.ov OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 TITLE BLUFF CITY BODCAW TOWN RCSSTCN TOWN CALE TOWN W I L L I S V I L L E TOWN BEARDEN TOWN CAMDEN CITY C H I D E S T E R CITY LOUANN TOWN S T E P H E N S CITY EAST CAMDEN TOWN CASA TOWN F C U R C H E TOWN H O U S T O N TOWN PERRY TOWN E L A I N E CITY HELENA CITY MARVELL CITY WEST HELENA CITY LAKE VIEW TOWN ANTOINE TCWN O E L I G H T CITY MURFREES80R0 CITY F I S H E R TOWN HARRISBURG C I T Y MARKED TREE CITY TRUMANN CITY TYRONZA TOWN WEINER CITY WALDENBURG TOWN COVE TOWN HATFIELD TOWN MENA CITY W I C K E S TOWN VANDERVOORT TOWN G R A N N I S TOWN DE V A L L S B L U F F TOWN H A Z E N CITY ULM TOWN B I G G E R S TOWN F O R R E S T CITY C I T Y H U G H E S CITY MADISON CITY PALESTINE TOWN W H E A T L E Y TOWN W I D E N E R TOWN TREASURY PAGE 14 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA PAGE OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 4 4 4 4 4 4 4 4 4 4 4 <• 4 4 4 TITLE C A L O W E L L TOWN W A L D R O N CITY G I L B E R T TOWN HACKETT CITY HUNTINGTON C I T Y E V E N I N G S H * D E TOWN SIDNEY TOWN G R I F F I T H V I L L E TOWN HIGGINSCN TOWN JUDSONIA CITY RUSSELL TOWN WEST POINT TOWN GARNER TOWN C O T T O N PLANT C I T Y PATTERSON TOWN STATE = 4: 199 RECORDS TREASURY TEST 15 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TE1ST (ELIGIBLE GOVERNMENTS) STATE TITLE 5 ALAMEDA COUNTY 5 CCLUSA COUNTY 5 KINGS COUNTY 5 LASSEN COUNTY 5 LOS ANGELES COUNTY 5 SAN BERNARDINO COUNTY 5 YUBA COUNTY 5 ALBANY CITY 5 BERKELEY CITY 5 HAYWARO CITY 5 OAKLAND CITY 5 PIEDMONT CITY 5 I ONE CITY 5 GRIDLEY CITY 5 WILLIAMS CITY 5 HERCULES TOWN 5 PITTSBURG CITY 5 RICHMOND CITY 5 SAN PA3L0 CITY 5 CLAYTON CITY 5 LAFAYETTE CITY 5 SANGER CITY 5 RIO DELL CITY 5 BRAWLEY CITY 5 IMPERIAL CITY 5 MARICOPA CITY 5 TEHACHAPI CITY 5 MCFARLAND CITY 5 ALHAMBRA CITY 5 AZUSA CITY 5 BALDWIN PARK CITY 5 BELL CITY 5 BURBANK CITY 5 CCMPTON CITY 5 EL MONTE CITY 5 EL SEGUNDO CITY 5 GARDENA CITY 5 HAWTHORNE CITY 5 HUNTINGTON PARK CITY 5 INGLEWOOD CITY 5 LAKEWOOD CITY 5 LA PUENTE CITY 5 LCNG BEACH CITY 5 LOS ANGELES CITY 5 LYNWOOD CITY 5 MAYWOOD CITY TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE OF DISTRESSED AREA ELIGIBILITY TEtST (ELIGIBLE GOVERNMENTS) STATE TITLE 5 MONROVIA CITY 5 PALOS VERDES ESTATES CTY 5 POMONA CITY 5 SAN F E R N A N D O C I T Y 5 SAN GABRIEL CITY 5 SAN MARINO C I T Y 5 SIERRA M ^ D R E C I T Y 5 SIGNAL HILL CITY 5 S C U T H GATE C I T Y 5 SCUTH P A S A D E N A C I T Y 5 VERNON CITY 5 BELLFLOWER CITY 5 BRADBURY C I T Y 5 D U A R T E CITY 5 INDUSTRY C 1 T Y 5 IRWINDALE C I T Y 5 NORwALK CITY 5 PARAMOUNT C I T Y 5 PICO RIVERA CITY 5 SANTA fL S P R I N G S C I T Y 5 SOUTH EL M O N T E C I T Y 5 WALNUT CITY 5 ARTESIA CITY 5 CCMMERCE CITY 5 LAWNDALE CITY 5 ROLLING HILLS CITY 5 BELL G A R D E N S C I T Y 5 C U D A H Y CITY 5 LA MIRADA C I T Y 5 RGSErfEAD C I T Y 5 L A N C A S T E R CITY 5 HAWAIIAN G A R D E N S 5 HIDDEN H I L L S C I T Y 5 L C M I T A CITY 5 PALMOALE CITY 5 C A R S O N CITY 5 LA CANADA F L I N T R I D G E C I T Y 5 S E A S I D E CITY 5 MARINA CITY 5 NEVADA CITY CITY 5 C C L F A X CITY 5 BANNING CITY 5 BEAUMONT CITY 5 8LYTHE CITY 5 CCACHELLA C I T Y 5 SACRAMENTO C I T Y 266-274 O - 78 - 6 THE TREASURY 17 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U . S . D E P A R T M E N T OF THE DISTRESSED P A G E 18 TREASURY AREA E L I G I B I L I T Y (ELIGIBLE GOVERNMENTS) STATE TITLE 5 SAN JUAN BAUTISTA CITY 5 B A R S T O W CITY 5 C O L T O N CITY 5 O N T A R I O CITY 5 SAN B E R N A R O I N O C I T Y 5 KONTCLAIR CITY 5 R A N C H C C U C A M O N G A CITY 5 AOELANTO CITY 5 IMPERIAL BEACH CITY 5 NATIONAL CITY CITY 5 SAN F R A N C I S C O C I T Y 5 L O M P O C CITY 5 S A N T A MARIA CITY 5 LCYALTUN CITY 5 D C R R I S TOWN 5 W E E D CITY 5 V A L L E J O CITY 5 N E W M A N CITY 5 *ATERFQRD CITY 5 LIVE OAK C I T Y 5 SANTA PAULA CITY 5 WHEATLANO CITY ST ATE =5: 114 RECORDS TEST 05/23/78 AT 01:25 U.S. DEPARTMENT DISTRESSED PAGE 19 OF THE AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 6 6 6 6 6 6 6 6 6 6 6 6 6 6 b 6 6 6 6 6 6 b 6 6 6 6 6 b 6 b TITLE CONEJOS COUNTY CROWLEY COUNTY DCLORES COUNTY HUERFANO COUNTY LAS ANIMAS COUNTY MINERAL COUNTY OTERO COUNTY ArUQNITO TOWN LA JARA TOWN ROMEO TOWN SANFORD TOWN SAN LUIS TOWN SUGAR CITY TOWN LA VETA TOWN WALSEN8URG CITY AGUILAR TOWN COKEOALE TOWN STARKVILLE TOWN TRINIDAD CITY KIM TOWN CREEDE TOWN NUCLA TOWN CHERAW TOWN FCWLER TOWN LA JUNTA CITY MANZANOLA TOWN ROCKY FORD CITY SWINK TOWN RYE TOWN BOONE TOWN STATE = 6: TREASURY 30 RECORDS TEST 0 5 / 2 3 / 7 8 AT 0 1 : 2 5 U*S. DEPARTMENT DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE BRIDGEPORT CITY B R I S T O L CITY HARTFORD CITY NEW BRITAIN C I T Y BANTAM B O R O U G H LITCHFIELD BOROUGH TORRINGTON CITY MIODLETOWN CITY ANSGNIA CITY DERBY CITY MERIOEN CITY NAUGATUC* B O R O U G H NEW HAVEN CITY WATEReURY CITY M I L F O R D CITY WEST HAVEN C I T Y WCODMONT BOROUGH JEwETT CITY B O R O U G H NORWICH CITY OANIELSCN 30ROUGH PUTNAM CITY W I L L I M A N T I C CITY STRATFORD TOWN EAST H A R T F O R D TOWN H A R T L A N D TOWN P L A I N V I L L E TOWN W E T H E R S F I E L D TOWN B A R K H A M S T E D TOWN CANAAN TOWN C C L E 3 R 0 C K TOWN G C S H E N TOWN H A R W I N T O N TOWN L I T C H F I E L D TOWN MORRIS TOWN NCRFOLK TOWN NCRTH CANAAN TOWN PLYMOUTH TOWN SALISBURY TOWN S H A R O N TOWN T H O M A S T O N TOWN WATERTOWN TOWN W I N C H E S T E R TOWN C L I N T O N TOWN M I D D L E F I E L D TOWN P C R T L A N D TOWN B R A N F O R D TOWN OF THE _ TREASURY P A G £ Z0 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 7 EAST HAVEN TOWN 7 HAMDEN TOWN 7 MADISON TCWN 7 NCRTH BRANFORD TOWN 7 NORTH HAVEN TOWN 7 ORANGE TOWN 7 OXFORD TOWN 7 SEYMOUR TOWN 7 BLZRAH TOWN 7 F R A N K L I N TOWN 7 GRISWOLD TOWN 7 L I S B O N TOWN 7 SPRAGUE TOWN 7 VOLUNTOWN TOWN 7 B R O O K L Y N TOWN 7 CANTERBURY TOWN 7 C H A P L I N TOWN 7 E A S T F O R D TOWN 7 KILLINGLY TOWN 7 PLAINFIELO TOWN 7 POMFRET TCWN 7 PUTNAM TOWN 7 SCOTLAND TOWN 7 STERLING TOWN 7 T H O M P S O N TOWN 7 WINDHAM TOWN STATE = 7: 72 RECORDS P A G E 21 OF THE TREASURY PAGE 22 05/23/78 AT 31:25 U.S. DEPARTMENT TorA<;iiPY OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE 8 8 8 8 8 8 8 8 8 d 8 8 8 8 6 6 8 6 TITLE NEW CASTLE COUNTY BOWERS TOWN FELTON TOWN HARRINGTON CITY HARTLY TOWN HOUSTON TOWN KENTON TOWN LEIPSIC TOWN LITTLE CREEK TOWN WYOMING TOWN BELLEFONTE TOWN ELSMERE TOWN MIDDLETOWN TOWN NEW CASTLE CITY NEWPORT TOWN ODESSA TOWN WILMINGTON CITY ARDENTOWN VILLAGE STATE = 3: 18 RECORDS 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 10 BREVARD COUNTY 10 DE SOTO C O U N T Y 10 FRANKLIN COUNTY 10 GAOSDEN COUNTY 10 GULF COUNTY 10 HIGHLANDS COUNTY 10 LAFAYETTE C O U N T Y 10 LIBERTY C O U N T Y 10 MADISON COUNTY 10 PUTNAM COUNTY 10 TAYLOR COUNTY 10 COCOA CITY 10 COCOA 3EACH CITY 10 MELBOURNE CITY 10 RCCKLEDGE CITY 10 TITUSVILLE C I T Y 10 MELBOURNE V I L L A G E TOWN 10 SATELLITE BEACH TOWN 10 W MELBOURNE TCWN 10 IhDIAN H A R B O U R 10 CAPE CANAVERAL C I T Y 10 PALM SHORES TOWN 10 ISLANDIA C I T Y 10 ARCADIA CITY 10 APALACHICOLAi C I T Y 10 CARRABELLE C I T Y 10 C H A T T A H O O C H E E CITY 10 G R E E N S G O R O TOWN 10 GRETNA TOWN 10 HAVANA TOWN 10 OUINCY CITY 10 PORT ST JOE TOWN 10 WEWAHITCHKA CITY 10 WARD RIDGE C I T Y 10 AVON PARK CITY 10 PLANT CITY C I T Y 10 MCNTICELLO C I T Y 10 MAYO TOWN 10 CLERMONT CITY 10 GROVELAND CITY 10 LADY LAKE TOWN 10 MASCOTTE C I T Y 10 MINNEOLA TOWN 10 BRISTOL CITY 10 GREENVILLE TOWN 10 LEE TOWN PAGE OF THE TREASURY 23 P A G E 24 05/23/78 ^'DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 10 TITLE MAOISON CITY KEY WEST C I T Y CRESTVIEW CITY EATONVILLE TOWN OAKLAND TOWN LAKE BUENA VISTA CITY BELLE GLADE CITY PAHOKEE CITY ST LEO TOWN SAN ANTONIO CITY FROSTPROOF C I T Y C R E S C E N T C I T Y CITY IINTERLACHEN TOWN PALATKA CITY POMONA PARK TOWN HASTINGS TOWN FORT PIERCE CITY ST LUCIE V I L L A G E PERRY CITY WASAU TOWN S T A T E = 10: 66 RECORDS 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 11 ATKINSON COUNTY 11 BAKER COUNTY 11 BANKS COUNTY 11 BARROW C O U N T Y 11 BIBB COUNTY 11 BLECKLEY COUNTY 11 BRANTLEY C O U N T Y 11 BROOKS COUNTY 11 BPYAN COUNTY 11 BURKE COUNTY 11 CALHOUN COUNTY 11 CHATHAM C O U N T Y 11 CHATTAHOOCHEE COUNTY 11 CHATTOOGA C O U N T Y 11 CLAY COUNTY 11 CLINCH COUNTY 11 CCLOUITT COUNTY 11 COOK COUNTY 11 COWETA C O U N T Y 11 CRAWFORD C O U N T Y 11 DAWSON COUNTY 11 DCDGE COUNTY 11 OCOLY COUNTY 11 DOUGHERTY COUNTY 11 EARLY COUNTY 11 EFFINGHAM C O U N T Y 11 F A N N I N COUNTY 11 F L O Y D COUNTY 11 GLASCOCK COUNTY 11 GRADY COUNTY 11 G R E E N E COUNTY 11 HALL CCUNTY 11 HANCOCK C O U N T Y 11 HART COUNTY 11 JEFFERSON COUNTY 11 J E N K I N S COUNTY 11 JONES COUNTY 11 LAURENS COUNTY 11 LCNG COUNTY 11 MCINTOSH C O U N T Y 11 MACON COUNTY 11 MERIWETHER C O U N T Y 11 MITCHELL COUNTY 11 MCNTGCMERY C O U N T Y 11 OGLETHORPE C O U N T Y 11 PIERCE C O U N T Y PAGE OF THE TREASURY 25 ,*. o C 05/23/78 *J »«» PAGE M R T H E M I of THE T R E A S U R Y DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 11 POLK COUNTY 11 PULASKI COUNTY U PUTNAM COUNTY 11 QUITMAN COUNTY 11 RANDOLPH C O U N T Y 11 SCHLEY COUNTY 11 STEWART COUNTY 11 SUMTER COUNTY 11 TALBOT COUNTY 11 TALIAFERRO C O U N T Y 11 TELFAIR COUNTY 11 TERRELL COUNTY 11 TREUTLEN C O U N T Y 11 TROUP COUNTY 11 TURNER COUNTY 11 T W I G G S COUNTY 11 UPSON COUNTY 11 WARE COUNTY 11 WAYNE COUNTY 11 WHEELER COUNTY 11 WILCOX COUNTY 11 W I L K E S COUNTY 11 PEARSON CITY 11 KlLLACQOCHEE TOWN 11 NEWTON CITY 11 HOMER TOrfN 11 AUBURN TOWN 11 BETHLEHEM TOWN 11 CARL TOWN 11 RUSSELL CITY 11 STATHAM TOWN 11 WINDER CITY 11 EMERSON CITY 11 WHITE TCWN 11 FITZGERALD CITY 11 NASHVILLE CITY 11 MACON CITY 11 PAYNE CITY 11 COCHRAN CITY 11 HOBOKEN CITY U MORVEN TOWN 11 QUITMAN CITY 11 PEMBROKE C I T Y 11 GIRARD VILLAGE 11 MIOVILLE CITY 11 SARDIS TOWN 26 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE 27 OF THE DISTRESSED AREA ELIGIBILITY TEST . (ELIGIBLE GOVERNMENTS) STATE TITLE 11 WAYNESBORO CITY 11 LEARY TOWN 11 MORGAN CITY 11 GARDEN CITY TOWN 11 SAVANNAH CITY 11 THUNDERBOLT TOWN 11 CUSSETA TOWN 11 LYERLY TOWN 11 MENLO TOWN 11 SUMMERVILLE CITY 11 TRION TOWN 11 BLUFFTON TOWN 11 FORT GAINES CITY 11 DU PONT TOWN 11 DOUGLAS CITY 11 NICHOLLS CITY 11 OOERUN CI1Y 11 ELLENTON TOWN 11 FUNSTON TOWN 11 MOULTRIE CITY 11 NORMAN PARK TOWN 11 GROVETOWN CITY 11 ACEL CITY 11 CECIL TCWN 11 LENOX TCWN 11 SPARKS TOWN 11 GRANTVILLE CITY 11 HARALSON TOWN 11 MORELAND TOWN 11 NEWNAM CITY 11 SENOIA CITY 11 SHARPSbURG TOWN 11 TURIN TOWN 11 ROBERTA CITY 11 ARABI TCWN 11 CCRDELE CITY U DAWSONVILLE TOWN 11 CHAUNCEY TOWN 11 CHESTER TOWN 11 U M D I L L A TOWN 11 ALBANY CITY 11 8LAKELY CITY 11 DAMASCUS TOWN 11 GUYTON CITY 11 RINCON TOWN 11 NUNEZ TOWN TREASURY 05/23/78 AT 31:25 U.S. D E P A R T M E N T OF THE T R E A S U R Y DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 11 STILLMORE TOWN 11 SWAINSBORO C I T Y 11 SUMMERTOrfN C I T Y 11 MCCAYSVILLE CITY 11 MORGANTON TOWN 11 CAVE SPRING CITY 11 ROME CITY 11 LAVONIA CITY 11 ATLANTA CITY 11 MITCHELL TOWN 11 FAIRMOUNT CITY 11 CAIRO CITY 11 WHIGHAM CITY 11 GREENSBORO C I T Y 11 UNION POINT TOWN 11 CCRNELIA CITY 11 CLERMONT TOWN 11 SPARTA CITY 11 TALLAPOOSA CITY 11 90WERSVILLE TOWN 11 HARTWELL C I T Y 11 PERRY CITY 11 OCILLA CITY 11 COMMERCE CITY 11 JEFFERSON CITY 11 NICHOLSON TOWN 11 AVERA TOWN 11 BARTOW TOWN 11 LCUISVILLE C I T Y 11 STAPLETON TOWN 11 WAOLEY TOWN 11 WRENS TOWN 11 MILLEN CITY 11 GRAY CITY 11 ALDCRA TOWN 11 BARNESVILLE CITY 11 CADWELL TOWN 11 DUBLIN CITY 11 MCNTROSE TOWN 11 RENTZ TOWN 11 RICEBORO C I T Y 11 L U D O W I C I CITY 11 OAHLONEGA CITY 11 OARIEN MIDEAL A R S H A LTOWN LCITY V I L L E CITY PAGE -8 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 11 MONTEZUMA CITY 11 OGLETHORPE CITY 11 GAY TOWN 11 GREENVILLE CITY 11 L O N E OAK C I T Y 11 LUTHERSVILLE TOWN 11 WARM S P R I N G S C I T Y 11 WOODBURY CITY 11 BACONTON CITY 11 C A M I L L A CITY 11 PELHAM CITY 11 SALE CITY C I T Y 11 A L S T O N TOWN 11 MOUNT VERNON C I T Y 11 T A R R Y T O W N TOWN 11 HIGGSTON CITY 11 BIBB CITY TOWN 11 COLUMBUS CITY 11 B I S H O P TOWN 11 NORTH HIGH S H O A L S TOWN 11 W A T K I N S V I L L E TOWN 11 LEXINGTON CITY 11 MAXEYS TOWN 11 ARNOLDSVILLE TOWN 11 BLACKSHEAR CITY 11 P A T T E R S O N TOWN 11 ROCKMART CITY 11 CEDARTOWN CITY 11 ARAGON CITY 11 VAN WERT T O W N 11 HAWKINSVILLE CITY 11 EATONTON CITY 11 G E O R G E T O W N TOWN 11 C L A Y T O N CITY 11 M C U N T A I N C I T Y TOWN 11 TIGER TOWN 11 CUTHBERT CITY 11 SHELLMAN CITY 11 ELLAVILLE CITY 11 G R I F F I N CITY 11 M A R T I N TOWN 11 T O C C O A CITY 11 L U M P K I N CITY 11 RICHLAND CITY 11 OMAHA CITY 11 AMERICUS CITY PAGE OF THE TREASURY 29 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T P A G E OF THE DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE TITLE AKDERSCNVILLE CITY OE SOTO VILLAGE LESLIE VILLAGE PLAINS TOWN GENEVA TOWN JUNCTION C I T Y TOWN TALBOTTON CI TY WOODLAND C I T Y C R A W F O R D V I L L E CITY SHARON CITY HELENA TOWN JACKSONVILLE TOWN LUMBER CITY MCRAE CITY BRONWOOO TOWN DAWSON CITY PARROTT TOWN THOMASVILLE CITY L Y O N S CITY SCPERTON CITY HOGANSVILLE CITY LA GRANGE CITY ASHBURN CITY REBECCA TOWN SYCAMORE CITY JEFFERSCNVILLE C I T Y THE ROCK TOWN YATESVILLE TOWN WAYCROSS CITY JESUP CITY ODUM TOWN SCREVEN CITY G L E N W O G D CITY HELEN TOWN ABBEVILLE CITY PINEVIEW TOWN P I T T S CITY ROCHELLE CITY TIGNALL TOWN RAYLE CITY STATE = 11: 270 RECORDS TREASURY 50 05/23/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE GOVERNMENTS) STATE TITLE 13 CLEARWATER COUNTY 13 FRANKLIN COUNTY 13 GEM COUNTY 13 ONEIDA C O U N T Y 13 SHOSHONE COUNTY li BLOOMINGTON VILLAGE 13 P A R I S CITY 13 ST C H A R L E S V I L L A G E 13 P L A C E R V I L L E CITY 13 S A N D P C I N T CITY 13 MCYIE S P R I N G S CITY 13 SPENCER VILLAGE 13 ELK RIVER V I L L A G E 13 O R O F I N O CITY 13 PIERCE CITY 13 W E I P P E CITY 13 L C S T RIVER V I L L A G E 13 CLAYTON VILLAGE 13 CLIFTON VILLAGE 13 DAYTON V I L L A G E 13 F R A N K L I N CITY 13 OXFORD VILLAGE 13 P R E S T O N CITY 13 EMMETT CITY 13 KOOSKIA CITY 13 STITES VILLAGE 13 WHITE BIRD C I T Y 13 ROBERTS VILLAGE 13 DIETRICH VILLAGE 13 SHOSHONE CITY 13 MALAO CITY 13 K E L L O G G CITY 13 MULLAN CITY 13 0S8URN CITY 13 SMELTERVILLE CITY 13 W A L L A C E CITY 13 WARDNER CITY 13 PINEHURST CITY STATE = 13: 38 RECORDS PAGE OF THE TREASURY ELIGIBILITY TEST 31 05/23/78 AT 31:25 U.S- DEPARTMENT OF THE OISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 14 ALEXANDER COUNTY 14 BOND COUNTY 14 CALHOUN COUNTY 14 CARROLL COUNTY 14 CASS COUNTY 14 CLAY COUNTY !<• F A Y E T T E C U U N T Y 14 FORD COUNTY 14 FULTON COUNTY 14 GALLATIN COUNTY 14 GREENE COUNTY 14 HAMILTON COUNTY 14 HARDIN COUNTY 14 IROQUOIS COUNTY 14 JERSEY COUNTY 14 JO D A V I E S S C O U N T Y 14 KANKAKEE COUNTY 14 KNOX C O U N T Y 14 LA S A L L E C O U N T Y 14 LCGAN COUNTY 14 MADISON COUNTY 14 MASSAC COUNTY 14 MONROE COUNTY 14 MCNTGOMERY COUNTY 14 PERRY COUNTY 14 PIKE C O U N T Y 14 POPE C O U N T Y 14 PULASKI COUNTY 14 RICHLAND COUNTY 14 ST C L A I R C O U N T Y 14 SHELBY COUNTY 14 UNION COUNTY 14 VERMILION COUNTY 14 WARREN C O U N T Y 14 WAYNE COUNTY 14 WHITE COUNTY 14 WILLIAMSON COUNTY 14 WINNEBAGO COUNTY 14 LA P R A I R I E V I L L A G E 14 LIMA V I L L A G E 14 O U I N C Y CITY 14 C A I R O CITY 14 TAMMS VILLAGE 14 THEBES VILLAGE 14 E A S T CAPE G I R A R D E A U 14 GREENVILLE CITY VILLAGE TREASURY PAGE 32 P A G E 33 0 5 / 2 3 / 7 6 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE M U L B E R R Y GRO VE V I L L A G E OLD RIPLEY V ILLAGE P O C A H O N T A S V ILLAGE S M I T H B O R G VI L L A G E S C R E N T O VILL AGE C A P R O N VILLA GE PCPLAR G R O V E V I L L A G E RIPLEY VILLA GE BUOA V I L L A G E DEPUE VILLAG E BATCHTOWN VI L L A G E B R U S S E L S VIL LAGE HAMBURG VILL AGE H A R D I N VILLA GE K A M P S V I L L E V ILLAGE LANARK CITY MT CARROLL C ITY SAVANNA CITY SHANNON V I L L AGE ARENZVILLE V ILLAGE A S H L A N D VILL AGE BEARDSTOWN C ITY CHANDLERVILL E VILLAGE VIRGINIA CIT Y RANTOUL VILL AGE UR3ANA CITY TCVEY VILLAG E PANA CITY CLAY CITY VI LLAGE FLORA CITY IOLA V I L L A G E L O U I S V I L L E V ILLAGE S A I L O R SPRIN GS V I L L A G E XENIA VILLAG E B A R T E L S O VIL LA3E BECKEMEYER V ILLAGE DAMIANSVILLE VILLAGE B E L L W O O O VIL LAGE BRIDGEVIEW V ILLAGE BROADVIEW VI L L A G E C H I C A G O CITY C H I C A G O HGHT S CITY C I C E R O TOWN HARVEY CITY LEMONT VILLA GE MCCOOK VILLA GE TEST 05/23/78 A ^ n : ^ ^ ^ ^ ^ Qf DISTRESSED AREA ELIGIBILITY TEST (ELIGI8LE GOVERNMENTS) STATE TITLE 14 MARKHAM CITY 14 HAYWOOD VILLAGE 14 M E L R O S E PARK V I L L A G E 14 MIDLOTHIAN VILLAGE 14 ROBBINS VILLAGE 14 RCSEMONT VILLAGE 14 SCHILLER PARK VILLAGE 14 SOUTH CHICAGC H G H T S VILL 14 STONE PARK V I L L A G E 14 SUMMIT V I L L A G E 14 BURBANK CITY 14 PALESTINE VILLAGE 14 DE K A L 8 CITY 14 MALTA V I L L A G E 14 GARRETT VILLAGE 14 HINDSBORO VILLAGE 14 BINGHAM VILLAGE 14 BROWNSTOWN VILLAGE 14 FARINA V I L L A G E 14 RAMSEY V I L L A G E 14 ST ELMO CITY 14 ST PETER V I L L A G E 14 VANDALIA C I T Y 14 BUCKNER VILLAGE 14 HANAFOPD VILLAGE 14 NORTH CITY V I L L A G E 14 O R I E N T CITY 14 S E S S E R CITY 14 VALIER V I L L A G E 14 WEST F R A N K F O R T C I T Y 14 ZEIGLER CITY 14 ASTORIA TCWN 14 AVON V I L L A G E 14 BANNER V I L L A G E 14 BRYANT V I L L A G E 14 CANTON CITY 14 CUBA CITY 14 DUNFERMLINE VILLAGE 14 ELLISVILLE VILLAGE 14 FARMINGTON CITY 14 IPAVA V I L L A G E 14 LEWISTOWN CITY 14 LONDON MILLS VILLAGE 14 MARIETTA V I L L A G E 14 NCRRIS VILLAGE 14 ST D A V I D V I L L A G E ^ TR£ASJRY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 PAGE OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE TABLE GROVE V I L L A G E VERMONT VILLAGE EQUALITY VILLAGE JUNCTION VILLAGE NEW HAVEN V I L L A G E OLD S H A W N E E T C W N V I L L A G E OMAHA V I L L \ G E RIOGWAY V I L L A G E S H A W N E E T O W N CITY CARROLLTON CITY ELORED VILLAGE GREENFIELD CITY HILLVIEW VILLAGE KANE V I L L A G E WILMINGTON VILLAGE ROCKBRIDGE VILLAGE R C O O H O U S E CITY WHITE HALL C I T Y BRACEVILLE VILLAGE C A R B O N HILL T I L L A G E SO W I L M I N G T O N V I L L A G E B E L L E PRAIRIE CITY TOWN BROUGHTON VILLAGE MACEDONIA V I L L A G E M C L E A N S B O R C CITY BASCO VILLAGE 8 E N T L Y TOWN PCNTQOSUC VILLAGE CAVE IN ROCK V I L L A G E ELIZABETHTOWN VILLAGE ROSICLARE CITY LOKAX V I L L A G E PAPINEAU VILLAGE WOOOLAWN V I L L A G E FIDELITY VILLAGE G R A F T O N CITY J E R S E Y V I L L E CITY O T T E R V I L L E TOWN APPLE RIVER V I L L A G E ELIZABETH VILLAGE HANOVER VILLAGE NCRA V I L L A G E STOCKTON VILLAGE BELKNAP VILLAGE CYPRESS VILLAGE SIMPSON V I L L A G E TE»ST 35 ° ^ / 2 3 / 7 8 AT 3 l : ? s "•^DEPARTMENT OF THE TREASURY ''" " DISTRESSED AREA ELIGIBILITY TEST ELIGIBLE GOVERNMENTS) STATE Jj . * J }4 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 iU 14 TITLE NCRTH AURORA VILLAGE PINGREE GROVE VILLAGE AROMA PARK V I L L A G E BCURBONNAIS VILLAGE BRADLEY VILLAGE ESSEX VILLAGE G R A N T PARK V I L L A G E IRWIN V I L L A G E KANKAKEE CITY MANTENO VILLAGE M C M E N C E CITY ST ANNE V I L L A G E U N I O N HILL V I L L A G E PEMBROKE VILLAGE ALTONA V I L L A G E E GALESBURG VILLAGE GALESBUKG CITY MACUON V I L L A G E ST A U G U S T I N E V I L L A G E VICTORIA VILLAGE WILLIAMSFIELD VILLAGE fATES CITY V I L L A G E DANA V I L L A G E EARLVILLE CITY G R A N O RIDGE V I L L A G E KANGLEY VILLAGE LA SALLE C I T Y LELAND VILLAGE LEONORE VILLAGE LOSTANT VILLAGE MARSEILLES CITY MENDOTA CITY NAPLATE VILLAGE O G L E S B Y CITY OTTAWA CITY PERU CITY RANSOM VILLAGE RUTLAND VILLAGE TCNICA V I L L A G E TROY GROVE V I L L A G E D I X O N CITY SAUNEMIN VILLAGE ATLANTA CITY BROADWELL V I L L A G E ELK HART C I T Y TOWN EMOEN VILLAGE 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 TITLE HARTSBURi V I L L A G E LATHAM VILLAGE LINCOLN CITY MIDDLETOWN V I L L A G E MT PULASKI C I T Y NEW HOLLAND VILLAGE CCLCHESTER C I T Y SCIOTA VILLAGE TENNESSEE VILLAGE DECATUR CITY OREANA VILLAGE BENLD CITY EAGERVILLE V I L L A G E HETTICK VILLAGE MCUNT OLIVE CITY NILWOOD VILLAGE SCOTTVILLE VILLAGE STANOARD CITY V I L L A G E WHITE CITY V I L L A G E WILSONVILLE VILLAGE ALHAMBRA VILLAGE ALTON CITY BETHALTO VILLAGE EAST ALTON VILLAGE GRANITE CITY GRANTFORK V I L L A G E HAMEL VILLAGE HARTFORD VILLAGE HIGHLAND CITY LIVINGSTON V I L L A G E MAOISON CITY MARINE VILLAGE NEW DOUGLAS VILLAGE ROXANA VILLAGE TROY CITY VENICE CITY WILLIAMSON V I L L A G E WCOD RIVER CITY WCRDEN VILLAGE PCNTOON BEACH V I L L A G E SOUTH ROXANA V I L L A G E JUNCTION C I T Y V I L L A G E KELL VILLAGE ODIN VILLAGE WALNUT HILL VILLAGE BROOKPORT CITY PAGE OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEST 37 0 5 / 2 3 / 7 6 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 TITLE JOPPA V I L L A G E METROPOLIS CITY COLUMBIA C I T Y FULTS VILLAGE MAEYSTOWN V I L L A G E WATERLOO C I T Y BUTLER V I L L A G E CCALTON VILLAGE DCNNELLSON VILLAGE FARMERSVILLE VILLAGE FILLMORE VILLAGE HILLSBORO C I T Y IRVING V I L L A G E LITCHFIELD CITY N C K O M I S CITY RAYMOND VILLAGE SCHRAM CITY V I L L A G E TAYLOR S P R I N G S V I L L A G E WAGGONER VILLAGE WITT CITY OHLMAN VILLAGE JACKSONVILLE CITY WCODSON V I L L A G E ADELINE VILLAGE CRESTON VILLAGE BARTONVILLE VILLAGE BRIMFIELD VILLAGE CUTLER V I L L A G E QU QUOIN C I T Y P I N C K N E Y V I L L E CITY ST JOHNS V I L L A G E TAMAROA V I L L A G E BAYLIS VILLAGE DETROIT VILLAGE EL DARA V I L L A G E FLORENCE VILLAGE G R I G G S V I L L E CITY HULL V I L L A G E KINDERHOOK VILLAGE MILTON V I L L A G E NEBO V I L L A G E NEW CANTON TOWN NEW SALEM TOWN PEARL V I L L A G E PERRY V I L L A G E PITTSFIELD CITY PAGE OF THE TREASURY 38 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T OF DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 TITLE PLEASANT HILL VILLAGE TIME V I L L A G E V A L L E Y CITY V I L L A G E EDDYVILLE VILLAGE GOLCONUA CITY HAMLETSBURG VILLAGE NEW GRAND C H A I N V I L L A G E KARNAK V I L L A G E M O U N D CITY C I T Y M O U N D CITY OLMSTEAD VILLAGE PULASKI VILLAGE ULLIN VILLAGE MAGNOLIA T O W N CALHOUN VILLAGE CLAREMONT VILLAGE NCBLE VILLAGE O L N E Y CITY PARKERSBURG VILLAGE BROOKLYN VILLAGE EAST ST L O U I S C I T Y FAIRMONT CITY VILLAGE FAYETTEVILLE VILLAGE L E B A N O N CITY NATIONAL CITY VILLAGE ST LIBGRY V I L L A G E SWANSEA V I L L A G E WASHINGTON PARK VILLAGE FAIRVIEW H E I G H T S CITY CARRIER MILLS VILLAGE ELDORADO CITY HARRIS3URG CITY EXETER V I L L A G E CCWDEN VILLAGE FINDLAY VILLAGE HERRICK VILLAGE MCWEAQUA VILLAGE OCONEE VILLAGE S H E L B Y V I L L E CITY S I G E L TOWN STEWARDSON VILLAGE STRASBUR3 VILLAGE TOWER HILL V I L L A G E RIDOTT V I L L A G E WINSLOW V I L L A G E ALTO PASS V I L L A G E THE TREASURY PAGE 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE ANNA CITY CC30EN VILLAGE DCNGOLA V I L L A G E JCNESBORO CITY MILL CREEK V I L L A G E ALLERTON VILLAGE BELGIUM VILLAGE DANVILLE CITY FITHIAN VILLAGE GEORGETOWN C I T Y H L O P E S T G N CITY IKDIANOLA V I L L A G E MUNCIE VILLAGE POTOMAC V I L L A G E RANKIN V I L L A G E ROSSVILLE V I L L A G E SIDELL V I L L A G E TILTON VILLAGE WESTVILLE VILLAGE LITTLE YORK V I L L A G E MONMOUTH CITY ROSEVILLE V I L L A G E RAOOM V I L L A G E CISNE VILLAGE FAIRFIELD CITY JEFFEPSONVILLE VILLAGE JOHNSONVILLE VILLAGE MT E R I E V I L L A G E S I M S VILLAGE WAYNE CITY V I L L A G E KEENES VILLAGE BURNT P R A I R I E V I L L A G E CARMI CITY CROSSVILLE VILLAGE ENFIELD VILLAGE MAUNIE V I L L A G E MILL S H C A L S V I L L A G E SPRINGERTON VILLAGE PHILLIPSTOWN VILLAGE LYNDON VILLAGE BUSH V I L L A G E CAMBRIA VILLAGE C A R T E R V I L L E CITY COLP VILLAGE CRAINVILLE VILLAGE C R E A L S P R I N G S CITY TEST 40 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA PAGE OF TREASURY ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 14 ENERGY VILLAGE 14 H E R R I N CITY 14 HURST CITY 14 J O H N S T O N C I T Y CITY 14 MARION CITY 14 PITTSBURG V I L L A G E 14 SPILLERTOWN VILLAGE 14 WHITEASH VILLAGE 14 L C V E S PARK C I T Y 14 RCCKFORD CITY 14 SOUTH BELOIT C I T Y 14 WINNEBAGO VILLAGE 14 BEVERLY TOWNSHIP 14 HCUSTON TOWNSHIP 14 LIBERTY TOWNSHIP 14 QUINCY T O W N S H I P 14 BURGESS TOWNSHIP 14 CENTRAL TOWNSHIP 14 LAGRANGE TOWNSHIP 14 MULBERRY GROVE TOWNSHIP 14 OLD RIPLEY T O W N S H I P 14 SHOAL CREEK T O W N S H I P 14 TAMALCO T O W N S H I P 14 BONUS TOWNSHIP 14 BOONE T O W N S H I P 14 FLORA T O W N S H I P 14 LEROY TOWNSHIP 14 MANCHESTER T O W N S H I P 14 P O P L A R GROVE T O W N S H I P 14 SPRING TOWNSHIP 14 RIPLEY T O W N S H I P STATE = 14: 445 RECORDS THE TEST 41 PAGE <*Z 05/23/78 '^DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 14 CHERRY GROVE TOWNSHIP STATE = 1A: 1 RECORDS 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE OF DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 14 ELKHORN GROVE TOWNSHIP 14 FAIRHAVEN TOWNSHIP 14 LIMA T O W N S H I P 14 MT C A R R O L L T O W N S H I P 14 RCCK CREEK T O W N S H I P 14 SALEM T O W N S H I P 14 SAVANNA T O W N S H I P 14 WCODLAND TOWNSHIP 14 ARENZVILLE TOWNSHIP 14 ASHLAND TOWNSHIP 14 BEAROSTOWN TOWNSHIP 14 CHANOLERVILLE TOWNSHIP 14 HAGENER TOWNSHIP 14 NEWMANSVILLE TOWNSHIP 14 PANTHER CREEK TOWNSHIP 14 PHILADELPHIA TOWNSHIP 14 SANGAMON VALLEY TOWNSHIP 14 VIRGINIA T O W N S H I P 14 COLFAX TOWNSHIP 14 CUNNINGHAM TOWNSHIP 14 KERR T O W N S H I P 14 LUDLOW T O W N S H I P 14 RANTOUL T O W N S H I P 14 URBANA T O W N S H I P 14 DARWIN T O W N S H I P 14 DOUGLAS TOWNSHIP 14 B I B L E GROVE T O W N S H I P 14 BLAIR TOWNSHIP 14 CLAY CITY T O W N S H I P 14 HARTER TOWNSHIP 14 HCOSIER TOWNSHIP 14 LOUISVILLE TOWNSHIP 14 OSKALOOSA TOWNSHIP 14 PIXLEY TOWNSHIP 14 XENIA T O W N S H I P 14 3R00KSIDE TOWNSHIP 14 CLEMENT TOWNSHIP 14 LOOKING GLASS TOWNSHIP 14 PLEASANT GROVE TOWNSHIP 14 CALUMET TOWNSHIP 14 LEMONT T O W N S H I P 14 STICKNEY TOWNSHIP 14 MALTA T O W N S H I P 14 TEXAS TOWNSHIP 14 AVENA T O W N S H I P 14 BEAR GROVE T O W N S H I P THE TREASURY *3 05/23/76 AT 3 1 : 2 5 U.S. DEPARTMENT PAGE OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 GOVERNMENTS) TITLE 3CWLING GREEN TOWNSHIP CARSON TOWNSHIP HURRICANE TOWNSHIP KASKASKIA TOWNSHIP LA C L E O E T O W N S H I P LCNE GROVE T O W N S H I P LOUDON TOWNSHIP OTEGO TOWNSHIP POPE TOWNSHIP RAMSEY TOWNSHIP SEFTON TOWNSHIP ShARON TOWNSHIP SCUTH HURRICANE TOWNSHIP VANDALIA TOWNSHIP WILBERTON TOWNSHIP FRANKFORT TOWNSHIP MLRTHERN TOWNSHIP SIX MILE T O W N S H I P ASTORIA TOWNSHIP BUCKHEART TOWNSHIP CANTON TOWNSHIP CASS TOWNSHIP DEERFIELD TOWNSHIP FARMERS TCWNSHIP FARMINGTON TOWNSHIP HARRIS TOWNSHIP ISABEL TOWNSHIP LEE TOWNSHIP LEWISTOWN TOWNSHIP PLEASANT TOWNSHIP POTMAN T O W N S H I P UNION TOWNSHIP VERMONT TOWNSHIP NATERFORD TOWNSHIP WCODLANO TOWNSHIP ASBURY TOWNSHIP BCWLESVILLE TOWNSHIP E A G L E CREEK T O W N S H I P EQUALITY TOWNSHIP G C L O HILL T O W N S H I P NEW HAVEN T O W N S H I P M C R T H FORK T O W N S H I P GMHA TOWNSHIP RIDGWAY TOWNSHIP SHAWNEE TOWNSHIP CARROLLTON TOWNSHIP 44 05/2 3/78 AT 3 1 : 2 5 U.S. DEPARTMENT O I S T R E S S E D AREA (ELIGIBLE STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 P A G E <»5 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE KANE TOWNSHI P L I N D E R TOWNS HIP RCCK8RIDGE T OWNSHIP RCODHOUSE TO WN R U B I C O N TOWN SHIP WALKERVILLE TOWNSHIP WHITE HALL T O W N S H I P W O O D V I L L E TO W N S H I P BPACEVILLE T OWNSHIP ERIENNA TOWN SHIP BEAVER CREEK T O W N S H I P C R O O K TOWNSH IP C R O U C H TOWNS HIP K N I G H T PRAIR IE T O W N S H I P MCLEANSBORO TOWNSHIP M A Y B E R R Y TOW N S H I P SCUTH C R O U C H T O W N S H I P S C U T H FLANNI GAN T O W N S H I P SOUTH TWIGG T O W N S H I P TWIGG TOWNSH IP W I L C O X TOWNS HIP LCMAX TOWNSH IP M A R T I N T O N TO W N S H I P MILKS GROVE T O W N S H I P CARBONDALE T OWNSHIP JERSEY TOWNS HIP MISSISSIPPI TOWNSHIP O T T E R CREEK T O W N S H I P QUARRY TOWNS HIP R I C H W O O D TOW N S H I P R C S E O A L E TOW N S H I P RUYLE TOWNSH IP APPLE RIVER T O W N S H I P B E R R E M A N TOW N S H I P COUNCIL HILL TOWNSHIP D E R I N D A TOWN SHIP E L I Z A B E T H TO W N S H I P G U I L F C R D TOW N S H I P H A N O V E R TOwN SHIP NORA TOWNSHI P P L E A S A N T VAL LEY T O W N S H I P RICE TOWNSHI P RUSH TOWNSHI P S T O C K T O N TOW N S H I P THOMPSON TOW N S H I P V I N E G A R HILL T O W N S H I P TElST 05/2 3/78 AT 31:25 U.S. D E P A R T M E N T DISTRESSED AREA PAGE OF TREASURY ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE THE TITLE 14 WC0D8INE T O W N S H I P 14 AROMA TOWNSHIP 14 6CURB0NNAIS TOWNSHIP 14 ESSEX TOWNSHIP 14 GANEER TOWNSHIP 14 KANKAKEE T O W N S H I P 14 LIMESTONE TOWNSHIP 14 MANTENO TOWNSHIP 14 MCMENCE TOWNSHIP 14 OTTO TOWNSHIP 14 PEMBROKE T O W N S H I P 14 ROCKVILLE TOWNSHIP 14 ST ANNE TOWNSHIP 14 SALINA TOWNSHIP 14 YELLOWHEAO TOWNSHIP 14 CEDAR TOWNSHIP 14 CHESTNUT TOWNSHIP 14 COPLEY TOWNSHIP 14 ELBA TOWNSHIP 14 GALESBURa T O W N S H I P 14 HAW CREEK TOWNSHIP 14 LYNN TOWNSHIP 14 MAQUON TOWNSHIP 14 RIC TOWNSHIP 14 SALEM TOWNSHIP 14 TRURO TOWNSHIP 14 VICTORIA T O W N S H I P 14 WALNUT GROVE TOWNSHIP 14 GALESBURG CITY T O W N S H I P 14 ADAMS TOWNSHIP 14 ALLEN TOWNSHIP 14 BROOKFIELD T O W N S H I P 14 BRUCE TOWNSHIP 14 DEER PARK T O W N S H I P 14 DIMMICK TOWNSHIP 14 EAGLE TOWNSHIP 14 EARL TOWNSHIP 14 EDEN TOWNSHIP 14 FARM RIDGE T O W N S H I P 14 FREEOOM TOWNSHIP 14 GROVELAND T O W N S H I P 14 HOPE TOWNSHIP 14 LA SALLE T O W N S H I P 14 MANLIUS TOWNSHIP 14 MENOOTA TOWNSHIP 14 MERIDEN T O W N S H I P TEST 46 05/2 3/78 DISTRESSED 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 OF THE AREA (ELIGIBLE STATE PAGE AT 3 1 : 2 5 U.S. D E P A R T M E N T TREASURY ELIGIBILITY GOVERNMENTS) TITLE OPHIR TOWNSHIP OSAGE T O W N S H I P OTTAWA T O W N S H I P O T T E R CREEK T O W N S H I P PERU T O W N S H I P RICHLAND TOWNSHIP RUTLAND TOWNSHIP SERENA T O W N S H I P S O U T H OTTAWA T O W N S H I P TROY GROVE T O W N S H I P VERMILION TOWNSHIP WALLACE TOWNSHIP WALTHAM T O W N S H I P AETNA T O W N S H I P ATLANTA T O W N S H I P BROADWELL T O W N S H I P CHESTER TOWNSHIP CORWIN TOWNSHIP EAST L I N C O L N T O W N S H I P E L K H A R T TOWN EMINENCE TOWNSHIP HURLBUT TOWNSHIP LAENNA T O W N S H I P LAKE FORK T O W N S H I P MT PULASKI T O W N S H I P ORAN T O W N S H I P ORVIL T O W N S H I P SHERIDAN TOWNSHIP WEST L I N C O L N T O W N S H I P BETHEL TOWNSHIP CHALMERS TOWNSHIP COLCHESTER TOWNSHIP ELDORADO TOWNSHIP EPMET T O W N S H I P L A M D I N E TW? MACOMB T O W N S H I P TENNESSEE TOWNSHIP HARRISTOWN TOWNSHIP BARR T O W N S H I P CAHOKIA TOWNSHIP ALTON T O W N S H I P CHOUTEAU TOWNSHIP CCLLINSVILLE TOWNSHIP FCRT RUSSELL T O W N S H I P GODFREY TOWNSHIP G R A N I T E CITY T O W N S H I P TEST 47 05/23/78 A P A G E 48 S ;;s; ^pARTM£Nr 0F DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 14 HELVETIA T O W N S H I P 14 JARVIS TOWNSHIP 14 MCRO TOWNSHIP 14 NAMEOKI TOWNSHIP 14 NEW DOUGLAS TOWNSHIP 14 OLIVE TOWNSHIP 14 OfPHGHENT TOWNSHIP 14 PIN OAK TOWNSHIP 14 SALINE TOWNSHIP 14 VENICE TOWNSHIP 14 WOOD RIVER T O W N S H I P 14 FOSTER TOWNSHIP 14 MEACHAM TOWNSHIP 14 ODIN TOWNSHIP 14 SANDOVAL T O W N S H I P 14 STEVENSON TOWNSHIP 14 AUDUBON TOWNSHIP 14 3CIS D ARC TOWNSHIP 14 BUTLER GROVE TOWNSHIP 14 EAST FOR* TOWNSHIP 14 FILLMORE T O W N S H I P 14 GRISHAM TOWNSHIP 14 HARVEL TOWNSHIP 14 HILLSBORO TOWNSHIP 14 IRVING TOWNSHIP 14 NOKOMIS TOWNSHIP 14 N LITCHFIELD TOWNSHIP 14 PITMAN TOWNSHIP 14 RAYMOND TOWNSHIP 14 RCUNTREE TOWNSHIP 14 SC LITCHFIELD T O W N S H I P 14 WITT TOWNSHIP 14 DEMENT TOWNSHIP 14 EAGLE POINT TOWNSHIP 14 LINCOLN TOWNSHIP 14 MT MORRIS TOWNSHIP 14 WHITE ROCK TOWNSHIP 14 ATLAS TOWNSHIP 14 CHAMBERS3URG TOWNSHIP 14 CINCINNATI TOWNSHIP 14 DERRY TOWNSHIP 14 FAIRMOUNT T O W N S H I P 14 F L I N T TOWNSHIP 14 HADLEY GRIGGSVILLE HARDIN TOWNSHIP TOWNSHIP THE T R E A S U R Y 05/23/78 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA PAGE OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 14 266-274 O - 78 - 8 TREASURY TITLE KINDERHOOK T OWNSHIP L E V E E TOWNSH IP MARTINSBURG TOWNSHIP MCNTESUMA TO W N S H I P NEWBURG TOWN SHIP NEW SALEM TO W N S H I P PEARL TOWNSH IP PERRY TOWNSH IP PITTSFIELD T OWNSHIP P L E A S A N T HIL L T O W N S H I P P L E A S A N T VAL E T O W N S H I P ROSS TOWNSHI P SPRING CREEK T O W N S H I P B O N P A S TOWNS HIP DENVER TOWNS HIP GERMAN TOWNS HIP MADISON TOWN SHIP NC3LE TOWNSH IP OLNEY TOWNSH IP C A N T E E N TOWN SHIP CASEYVILLE T OWNSHIP CENTREVILLE TOWNSHIP E A S T ST LOUI S T O W N S H I P P R A I R I E DU L ONG T O W N S H I P S T I T E S TOWNS HIP S U G A R LOAF T O W N S H I P EAST ELDORAD 0 T O W N S H I P LONG BRANCH T O W N S H I P MOUNTAIN TOW N S H I P RECTOR TOWNS HIP ASH GROVE TO WNSHIP DRY POINT TO WNSH IP HERRICK TOWN SHIP H O L L A N D TOWN SHIP L A K E W O O D TOW N S H I P MCWEAQUA TOW N S H I P OCONEE TOWNS HIP OKAW TOWNSHI P PENN TOWNSHI P PICKAWAY TOW N S H I P PRAIRIE TOWN SHIP RICHLAND TOW N S H I P RIDGE TOWNSH IP ROSE TOWNSHI P RURAL TOWNSH IP SHELBYVILLE TOWNSHIP TEIST 49 05/23/7B U S -- AT 31:25 0E ""N£MT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 14 SIGEL TOWNSHIP 14 T L W E R HILL T O W N S H I P 14 WINDSOR TOWNSHIP 14 JEFFERSON TOWNSHIP 14 LANCASTER TOWNSHIP 14 ONECO TOWNSHIP 14 RIDOTT TOWNSHIP 14 RCCK G R O V E T O W N S H I P 14 BLOUNT TOWNSHIP 14 BUTLER TOWNSHIP 14 CARROLL TOWNSHIP 14 CATLIN TOWNSHIP 14 DANVILLE TOWNSHIP 14 ELWOOD TOWNSHIP 14 GEORGETOWN TOWNSHIP 14 GRANT TOWNSHIP 14 JAMAICA TOWNSHIP 14 LOVE T O W N S H I P 14 MCKENDREE TOWNSHIP 14 MIDOLEFORK TOWNSHIP 14 NEWELL TOWNSHIP 14 PILOT TOWNSHIP 14 ROSS T O W N S H I P 14 SIDELL TOWNSHIP 14 C0LD8R00K TOWNSHIP 14 ELLISON TOWNSHIP 14 FLOYD TOWNSHIP 14 HALE T O W N S H I P 14 KELLY TOWNSHIP 14 MONMOUTH TOWNSHIP 14 POINT PLEASANT TOWNSHIP 14 ROSEVILLE TOWNSHIP 14 SUMNER T O W N S H I P 14 SWAN T O W N S H I P 14 OU B O I S T O W N S H I P 14 ARRINGTON TOWNSHIP 14 BARNHILL TOWNSHIP 14 BEDFORD TOWNSHIP 14 BERRY TOWNSHIP 14 BIG MOUND T O W N S H I P 14 ELM RIVER T O W N S H I P 14 G A R D E N HILL T O W N S H I P 14 GFOVER TOWNSHIP 14 H I C K O R Y HILL T O W N S H I P 14 INDIAN P R A I R I E T O W N S H I P 14 KEITH TOWNSHIP PAGE 50 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA P A G E 51 OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 14 LAMARD TOWNSHIP 14 MT E R I E T O W N S H I P 14 ORCHARD TOWNSHIP 14 OREL T O W N S H I P 14 BURNT P R A I R I E T O W N S H I P 14 CARMI T O W N S H I P 14 EMMA T O W N S H I P 14 EKFIELD TOWNSHIP 14 GRAY T O W N S H I P 14 HAWTHORNE T O W N S H I P 14 HERALDS PRAIRIE TOWNSHIP 14 INDIAN CREEK T O W N S H I P 14 MILL S H O A L S T O W N S H I P 14 PHILLIPS TOWNSHIP 14 LYNDON TOWNSHIP 14 USTICK T O W N S H I P 14 BURRITT TOWNSHIP 14 HARRISON TOWNSHIP 14 RCCKFORD TOWNSHIP 14 WINNEBAGO TOWNSHIP STATE = 14: 3 38 RECORDS TREASURY TEST PAGE 05/23/78 A T J l ' » p A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 15 BLACKFORD COUNTY 15 CRAWFORD COUNTY 15 DAVIESS COUNTY 15 DEARBORN COUNTY 15 DELAWARE C O U N T Y 15 ELKHART COUNTY 15 F A Y E T T E C O U N T Y 15 FOUNTAIN COUNTY 15 FRANKLIN COUNTY 15 G R E E N E COUNTY 15 JAY COUNTY 15 JEFFERSON C O U N T Y 15 LAWRENCE COUNTY 15 MARTIN C O U N T Y 15 MIAMI COJNTY 15 NOBLE COUNTY 15 OHIO COUNTY 15 ORANGE C O U N T Y 15 OWEN COUNTY 15 PARKE COUNTY 15 PERRY COUNTY 15 PUTNAM C O U N T Y 15 RANDOLPH COUNTY 15 RIPLEY C O U N T Y 15 RUSH COUNTY 15 ST J O S E P H C O U N T Y 15 S C O T T COUNTY 15 SHELBY C O U N T Y 15 VERMILLION COUNTY 15 VIGO COUNTY 15 WAYNE COUNTY 15 F C R T WAYNE C I T Y 15 HARTFORD CITY 15 MCNTPELIEP CITY 15 LLGANSPORT CITY 15 ROYAL CENTER TOWN 15 CHARLESTOWN CITY 15 NEW P R O V I O E N C L TOWN 15 C C L F A X TOWN 15 K I R K L I N TOWN 15 M U L B E R R Y TOWN 15 ALTON TOWN 15 E N G L I S H TOWN 15 L E A V E N W O R T H TOWN 15 MARENGO TCWN 15 ALFORDSVILLE TOWN 0F THE TREASURY 52 05/2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 TITLE CANNELBURG TOWN ELNORA TOWN MONTGOMERY TOWN ODON TOWN PLAINVILLE TOWN WASHINGTON CITY AURORA CITY O I L L S B O R O TOWN GREENDALE TOWN LAWRENCE3URG CITY MOORES HILL TOWN ST LEON TOWN WEST HARRISON TOWN ALBANY TOWN EATON TOWN MUNCIE CITY E L K H A R T CITY CONNERSVILLE CITY NEW ALBANY C I T Y ATTICA CITY KINGMAN TOWN WALLACE TOWN BROOKVILLE TOWN CEOAR GROVE TOWN LAUREL TOWN MOUNT CARMEL TOWN OLOENBURi TOWN G A S CITY C I T Y MARION CITY MATTHEWS TOWN BLOOMFIELO TOWN JASONVILLE CITY LINTON CITY L Y O N S TOWN NEWBERRY TOWN SWITZ CITY TOWM W O R T H I N G T O N TOWN CORYDON TOWN LACONIA CORP MAUCKPORT TOWN NEW AMSTERDAM TOWN NEW MIDDLETOWN TOWN BLOUNT SVILLE 1 TOWN K M G H T S T O W N TOWN MOORELAND TOWN NEW C A S T L E : C I T Y P A G E 53 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEST nt./o?/7fl 05/*5/™ A T 01:25 ^ ^ 0 E p A R T M E N T P A G E 54 0F DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 15 HUNTINGTON CITY 15 MOUNT ETNA TOWN 15 CROTHERSVILLE TOWN 15 MEDORA TOWN 15 SEYMOUR CITY 15 BRYANT TOWN 15 PENNVILLE TOWN 15 REDKEY TOWN 15 SALAMONIA TOWN 15 BR00KS8URG TOWN 15 HANOVER TOWN 15 MADISON CITY 15 DUPONT TOWN 15 BICKNELL CITY 15 DECKER TOWN 15 EDWARDSPORT TOWN 15 OAKTOWN TOWN 15 VINCENNES CITY 15 WHEATLAND TOWN 15 BRUCEVILLE TOWN 15 SHIPSHEWANA TOWN 15 TOPEKA TOWN 15 EAST CHICAGO C I T Y 15 LAKE STATION C I T Y 15 GARY CITY 15 CEDAR LAKE TOWN 15 KINGSBURY TOWN 15 WESTVILLE TOWN 15 BEDFORD CITY 15 MITCHELL CITY 15 OOLITIC TCWN 15 ALEXANDRIA CITY 15 ANDERSON CITY 15 ELWOOD CITY 15 INGALLS TOWN 15 LAPEL TOWN 15 ORESTES TOWN 15 U D I A N A P O L I S CITY 15 LYNHURST TOWN 15 LCOGOOTEE CITY 15 SHOALS TOWN 15 CRANE TOWN 15 DENVER TOWN 15 NORTH GPOVE TOWN 15 PERU CITY 15 BLOOMINGTON CITY THE TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE 55 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 15 STINESVILLE TOWN 15 ALAMO TOWN 15 WAVELAND TOWN 15 ALBION TOWN 15 CROMWELL TOWN 15 KENDALLVILLE CITY 15 LIGONIER CITY 15 ROME CITY TOWN 15 RISING SUN CITY 15 FRENCH LICK TOWN 15 ORLEANS TOWN 15 PAOLI TOWN 15 WEST BADEN TOWN 15 GOSPORT TOWN 15 SPENCER TOWN 15 BLOOMINGDALE! TOWN 15 JUDSON TOWN 15 MARSHALL TOWN 15 MONTEZUMA TOWN 15 ROCKVILLE TOWN 15 ROSEDALE TOWN 15 MECCA TOWN 15 CANNELTON CITY 15 TELL CITY CITY 15 TROY TOWN 15 BAINBRIDGE TOWN 15 CLOVERDALE TOWN 15 GREENCASTLE CITY 15 ROACHDALE TOWN 15 RUSSELLVILLE TOWN 15 LYNN TOWN 15 RIDGEVILLE TOWN 15 SARATOGA TOWN 15 UNION CITY CITY 15 WINCHESTER CITY 15 LOSANTVILLE TOWN 15 MILAN TOWN 15 OSGOOD TOWN 15 SUNMAN CIVIL TOWN 15 NAPOLEON TOWN 15 HOLTON TOWN 15 CARTHAGE TOWN 15 RUSHVILLE CITY 15 LAKEVILLE TOWN 15 NORTH LIBERTY TOWN 15 SOUTH BEND CITY TREASURY 05/23/„ » J J » » „ R „ M I or IHE IRE,SURr DISTRESSED AREA ELIGIBILITY TELST (ELIGIBLE GOVERNMENTS) STATE TITLE 15 KALKERTCN TOWN 15 SCOTTSBURG C I T Y 15 AUSTIN TOWN 15 SHELBYVILLE CITY 15 NCRTH JUDSON TOWN 15 PATRIOT TOWN 15 CAYUGA TOWN 15 CLINTON CITY 15 DANA TOWN 15 FAIRVIEW PARK TOWN 15 NEWPORT TOWN 15 PERRYSVILLE TOWN 15 RILEY TOWN 15 SEELYVILLE C I V I L TOWN 15 TERRE HAUTE CITY 15 WEST TERRE HAUTE CITY 15 LAGRO TCWN 15 NCRTH MANCHESTER TOWN 15 ROANN TOWN 15 WABASH CITY 15 CAMBRIDGE CITY TOWN 15 CENTERVILLE TOWN 15 DUBLIN TOWN 15 ECONOMY TOWN 15 F O U N T A I N C I T Y TOWN 15 HAGERSTOWN TOWN 15 MILTON TOWN 15 MCUNT AUBURN TOWN 15 RICHMOND C I T Y 15 8LUFFT0N CITY 15 PCNETO TOWN 15 VERA CRUZ TOWN 15 B U R N E T T S V I L L E TOWN 15 MILAN TOWN 15 SPRINGFIELD T O W N S H I P 15 WAYNE TOWNSHIP 15 WASHINGTON T O W N S H I P 15 ADAMS TOWNSHIP 15 CLINTON TOWNSHIP 15 EEL TOWNSHIP 15 JEFFERSON T O W N S H I P 15 NOBLE TOWNSHIP 15 CHARLESTOWN TOWNSHIP 15 OREGON TOWNSHIP 15 WASHINGTON T O W N S H I P 15 MADISON T O W N S H I P "" " 05/23/76 AT 31:25 U.S. DEPARTMENT OF THE PAGE 57 TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 TITLE BOONE TOWNSH IP JENNINGS TOW NSHIP JOHNSON TOWN SHIP LI8ERTY TOWN SHIP OHIO TOWNSHI P PATOKA TOWNS HIP STERLING TOW NSHIP UNION TOWNSH IP WHISKEY RUN TOWNSHIP BARR TOWNSHI P BOGARD TOWNS HIP ELMORE TOWNS HIP HARRISON TOW NSHIP MADISON TOWN SHIP REEVE TOWNSH IP STEELE TOWNS HIP VANBUREN TOW NSHIP VEALE TOWNSH IP WASHINGTON T OWNSHIP CAESAR CREEK TOWNSHIP CENTER TOWNS HIP CLAY TOWNSHI P HARRISON TOW NSHIP HCGAN TOWNSH IP JACKSON TOWN SHIP KELSO TOWNSH IP LAWRENCE3URG TOWNSHIP LOGAN TOWNSH IP MANCHESTER T OWNSHIP MILLER TOWNS HIP SPARTA TOWNS HIP WASHINGTON T OWNSHIP YORK TOWNSHI P CENTER TOWNS HIP DELAWARE TOW NSHIP UNION TOWNSH IP BAUGC TOWNSH IP CONCORD TOWN SHIP HARRISON TOW NSHIP COLUMBIA TOW NSHIP CCNNERSVILLE TOWNSHIP HARRISON TOW NSHIP JACKSON TOWN SHIP WATERLOO TOW NSHIP DAVIS TOWNSH IP LOGAN TOWNSH IP TEST 05/23/76 A ;.s!SDEPARTM£NT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 15 MILLCREEK TOWNSHIP 15 BATH TOWNSHIP 15 BLOOMING GROVE T O W N S H I P 15 BROOKVILLE T O W N S H I P 15 F A I R F I E L ) T O W N S H I P 15 HIGHLAND T O W N S H I P 15 LAUREL TOWNSHIP 15 METAMORA T O W N S H I P 15 PCSEY TOWNSHIP 15 RAY TOWNSHIP 15 SALT CREEK T O W N S H I P 15 SPRINGFIELD TOWNSHIP 15 WHITEWATER T O W N S H I P 15 CENTER T O W N S H I P 15 FRANKLIN TOWNSHIP 15 JEFFERSON T O W N S H I P 15 MILL TOWNSHIP 15 RICHLAND T O W N S H I P 15 BEECH CREEK T O W N S H I P 15 CASS T O W N S H I P 15 CENTER TOWNSHIP 15 FAIRPLAY TOWNSHIP 15 GRANT TOWNSHIP 15 HIGHLAND T O W N S H I P 15 JACKSON TOWNSHIP 15 JEFFERSON TOWNSHIP 15 RICHLAND T O W N S H I P 15 STOCKTON TOWNSHIP 15 TAYLOR T O W N S H I P 15 WASHINGTON T O W N S H I P 15 WRIGHT T O W N S H I P 15 BOONE TOWNSHIP 15 HARRISON T O W N S H I P 15 WEBSTER T O W N S H I P 15 BLUE RIVER T O W N S H I P 15 HOWARD TOWNSHIP 15 DALLAS TOWNSHI* 15 HUNTINGTON TOWNSHIP 15 UNION TOWNSHIP 15 WARREN T O W N S H I P 15 CARR T O W N S H I P 15 JACKSON T O W N S H I P 15 PERSHING TOWNSHIP 15 VERNON T O W N S H I P 15 BEAR CREEK T O W N S H I P 15 JEFFERSON TOWNSHIP TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 TITLE PENN T O W N S H I P RICHLAND TOWNSHIP WA8ASH TOWNSHIP GRAHAM TOWNSHIP HANOVER TOWNSHIP LANCASTER TOWNSHIP MAOISON TOWNSHIP MILTON T O W N S H I P MONROE T O W N S H I P SALUOA T O W N S H I P SHELBY TOWNSHIP SKYRNA T O W N S H I P DECKER TOWNSHIP VIGO T O W N S H I P WASHINGTON TOWNSHIP 8L0CMFIELC TOWNSHIP CALUMET TOWNSHIP GALENA TOWNSHIP HUDSON TOWNSHIP KANKAKEE TOWNSHIP NEW DURHAM T O W N S H I P WASHINGTON TOWNSHIP BONO T O W N S H I P GUTHRIE TOWNSHIP INDIAN CREEK T O W N S H I P MARION T O W N S H I P MARSHALL TOWNSHIP PERRY T O W N S H I P P L E A S A N T RUN T O W N S H I P SHAWSWICK T O W N S H I P SPICE VALLEY T O W N S H I P ANDERSON TOWNSHIP F A L L CREEK T O W N S H I P LAFAYETTE TOWNSHIP PIPE CREEK T O W N S H I P UNION T O W N S H I P CENTER TOWNSHIP WARREN TOWNSHIP CENTER T O W N S H I P HALBERT TOWNSHIP L C S T RIVER T O W N S H I P MITCHELTREE TOWNSHIP PERRY T O W N S H I P RUTHERFORD T O W N S H I P BUTLER T O W N S H I P PERRY TOWNSHIP PAGE OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEST 59 0 5 / 2 3/78 AT 3 1 : 2 5 U . S . D E P A R T M E N T OF THE DISTRESSED AREA (ELIGIBLE STATE 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 PAGE TREASURY ELIGIBILITY GOVERNMENTS) TITLE PERU TOWNSHI P I P E CREEK T O W N S H I P PERRY TOWNSH IP BROWN TOWNSH IP C L A R K TOWNSH IP A L 3 I 0 N T O W N S HIP E L K H A R T TOWN SHIP ORANGE T O W N S HIP PERRY TCWNSH IP C A S S TOWNSHI P PIKE TOWNSHI P U N I O N TCWNSH IP F R E N C H LICK T O W N S H I P GREENFIELD T OWNSHIP JACKSON TOWN SHIP N O R T H E A S T TO WNSHIP N O R T H W E S T TO W N S H I P ORANGEVILLE TOWNSHIP O R L E A N S TOWN SHIP P A O L I TOWNSH IP S O U T H E A S T TO WNSHIP S T A M P E R S C RE EK T O W N S H I P CLAY TOWNSHI P F R A N K L I N TOW N S H I P H A R R I S O N TOW NSHI P JACKSON TOWN SHIP J E F F E R S O N TO W N S H I P J E N N I N G S TOW NSHI P LAFAYETTETOW NSHIP MARION TOWNS HIP MCNTGOMERY T OWNSHIP MORGAN TOWNS HIP TAYLOR TOWNS HIP WASHINGTON T OWNSHIP WAYNE TOWNSH IP A D A M S TOWNSH IP F L O R D I A TOWN SHIP H O W A R D TOWNS HIP J A C K S O N TOWN SHIP L I 8 E R T Y TOWN SHIP PENN TOWNSHI P R A C C O O N TCWN SHIP R E S E R V E TOWN SHIP SCHOOL SUGAR CREEK T O W N S H I P UNION TOwNSH IP W A B A S H TOWNS HIP TE«ST SO 05/2 3/76 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA PAGE OF 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 15 TITLE WASHINGTON T OWNSHIP A N O E R S O N TOW N S ^ I P C L A R K TOWNSH IP L E O P O L C TOWN SHIP OIL T O W N S H I P T O B I N TOWNSH IP TROY TOWNSHI P UNION TOWNSH IP RICH GROVE T O W N S H I P TIPPECANOE T OWNSHIP C L I N T O N TOWN SHIP CLCVERDALE T OWNSHIP F R A N K L I N TOW N S H I P GREENCASTLE TOWNSHIP J E F F E R S O N TO W N S H I P M A O I S C N TCWN SHIP MARION TOWNS H I ° MONROE TOWNS HIP RUSSELL TOWN SHIP WARREN TOWNS HIP WASHINGTON T OWNSHIP F R A N K L I N TOW NSHI P GREENSFORK T OWNSHIP JACKSON TOWN SHIP WARD TOWNSHI P WAYNE TOWNSH IP WHITE RIVER T O W N S H I P ADAMS TOWNSH IP BROWN TOWNSH IP C E N T E R TOWNS HIP D E L A W A R E TOW N S H I P F R A N K L I N TOW N S H I P JACKSON TOWN SHIP L A U G H E R Y TOW N S H I P O T T E R CREEK T O W N S H I P SHELBY TOWNS HIP A N D E R S O N TOW N S H I P C E N T E R TOWNS HIP JACKSON TOWN SHIP NOBLE TOWNSH IP ORANGE TOWNS HIP PCSEY TOWNSH IP RICHLAND TOW N S H I P RIPLEY TOWNS HIP RUSHVILLE TO WNSH IP U N I O N TOWNSH IP TREASURY ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE THE TEST 51 PAGE 05/23/78 A : J/;; ^pARTMENT DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 15 WALKER T O W N S H I P 15 WASHINGTON T O W N S H I P 15 GREENE TOWNSHIP 15 LINCOLN T O W N S H I P 15 PENN TOWNSHIP 15 PCRTAGE TOWNSHIP 15 FINLEY T O W N S H I P 15 JENNINGS T O W N S H I P 15 JCHNSON T O W N S H I P 15 LEXINGTON T O W N S H I P 15 ADDISON T O W N S H I P 15 BRANDYWINE C I V I L TWP 15 L I B E R T Y T O W N S H I P 15 DAVIS TOWNSHIP 15 RAILROAD T O W N S H I P 15 WAYNE TOWNSHIP 15 BROWNSVILLE T O W N S H I P 15 UNION TOWNSHIP 15 CLINTON TOWNSHIP 15 EUGENE TOWNSHI^ 15 HELT T O W N S H I P 15 HARRISON T O W N S H I P 15 PRAIRIETON T O W N S H I P 15 RILEY TOWNSHIP 15 SUGAR CREEK T O W N S H I P 15 CHESTER TOWNSHIP 15 NCBLE TOWNSHIP 15 PLEASANT T O W N S H I P 15 PINE T O W N S H I P 15 STEUBEN TOWNSHIP 15 WARREN T O W N S H I P 15 OALTON T O W N S H I P 15 FRANKLIN TOWNSHIP 15 GREENE TOWNSHIP 15 JACKSON TOWNSHIP 15 JEFFERSON TOWNSHIP 15 NEW GARDEN T O W N S H I P 15 WASHINGTON TOWNSHIP 15 WAYNE T O W N S H I P 15 JACKSON TOWNSHIP 15 WEST POINT T O W N S H I P STATE - 15: 501 RECORDS OF THE TREASURY 62 ^ t:l;TrwMMMCy 0 5 / 2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA PAGE OF THE T R E A S U R Y ELIGIBILITY (ELIGIBLE GOVERNMENTS) STAT E lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb TITLE ADAMS COUNTY APPANOOSE COUNTY AUDU80N COUNTY DECATUR CCUNTY RINGGOLD COUNTY TAYLOR COUNTY WAYNE COUNTY O R I E N T TOWN C A R B O N TOWN N O D A W A Y TOWN PRESCOTT TOWN CENTERVILLE CITY C I N C I N N A T I TOWN E X L I N E TDW^ M O R A V I A TCWN M C U L T O N TOWN M Y S T I C CITY NUMA TOWN P L A N C TOWN R A T H B U N TOWN U D E L L TOWN U N I O N V i L L E TOWN B R A Y T O N TOWN G R A Y TOWN L U T H E R TOWN J C L L E Y TOWN D E L M A R TOWN D A V I S CITY TOWN DECATUR CITY TOWN GAROEN GRCVE TOWN G R A N D RIVER TOWN L A M O N I CITY LEON CITY LE ROY TOWN PLEASANTON TOWN W E L D O N TOWN C A S E Y TOWN D U N L A P TOWN hn.GNOLIA T C W N HURSTVILLE TOWN MONMOUTH CITY C O L F A X CITY D E L T A TOWN H A R P E R TOWN K E S W I C K TOWN K E O K U K CITY TEST 63 05/23/78 A Jj;S^pARTHENT DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE lb DERBY TOrfN lb L U C A S TOWN lb W I L L I A M S O N TOWN lb BEVINGTCN TOWN lb B A R N E S CIT Y TOWN lb BEACON TOW N lb NEW SHARON TOWM lb RCSE HILL TOWN lb U N I V E R S I T Y PARK TOWN lb KEOMAH CIT Y lb MITCHELL T OWN lb 8LANCHARD TOWN lb CLARINDA C ITY lb O I A G O N A L T OWN lb K E L L E R T O N TCWN lb MALOY TOWN WN lb REDOING TO WN lb T I N G L E Y TO WN lb EARLING TO TOWN lb WESTPHALIA TOWN lb ATHELSTAN OWN lb B L O C K T O N T N lb CCNWAY TOW TOWN lb SHARPS8URG TOWN lb FARMINGTON N lb MILTON TOW LING TOWN lb MOUNT STER OWN lb E L D O N TOWN TOWN lb S T AHTUEM E S=T Olb: N T WN77 R E C O R D S lb MILLERTON lb SEYMOUR TO 0F THE T R E A S U R Y 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT OISTRESSEO AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 17 ANDERSON COUNTY 17 ATCHISON COUNTY 17 C H A S E COUNTY 17 CHAUTAUQUA COUNTY 17 CHEROKEE COUNTY 17 CRAWFORD COUNTY 17 ELK COUNTY 17 LABETTE COUNTY 17 WYANDOTTE COUNTY 17 C O L O N Y CITY 17 G R E E L E Y CITY 17 LONE ELM C I T Y 17 WESTPHALIA CITY 17 ATCHISON CITY 17 LANCASTER CITY 17 MAPLETON CITY 17 FAIRVIEW CITY 17 H O R T O N CITY 17 M O R R I L L CITY 17 ROBINSON CITY 17 W I L L I S CITY 17 C E D A R POINT CITY 17 COTTONWOOD FALLS CITY 17 E L M D A L E CITY 17 CHAUTAUQUA CITY 17 E L G I N CITY 17 PERU CITY 17 SEDAN CITY 17 BAXTER S P R I N G S C I T Y 17 COLUMBUS CITY 17 GALENA CITY 17 T R E E C E CITY 17 WEIR CITY 17 RGSELAND CITY 17 G R I D L E Y CITY 17 W A V E R L Y CITY 17 CAMBRIDGE CITY 17 U O A L L CITY 17 ARCADIA CITY 17 ARMA CITY 17 CHEROKEE CITY 17 GIRARD CITY 17 H E P L E R CITY 17 KCCUNE CITY 17 MULBERRY C I T Y 17 PITTSBURG C I T Y PAGE OF THE TREASURY 65 05/2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 TITLE WALNUT CITY ENTERPRISE CITY HCPE CITY MANCHESTER CITY ELK F A L L S C I T Y H O W A R D CITY L C N G T O N CITY M C L I N E CITY F A L L RIVER C I T Y SEVE.RY CITY V I R G I L CITY COOLIDGE CITY BLUFF CITY C I T Y DANVILLE CITY PENALOSA CITY ALTAMCNT CITY C H E T O P A CITY EDNA CITY L A B E T T E CITY MOUND VA.LEY C I T Y O S W E G O CITY P A R S O N S CITY L A N S I N G CITY B U R N S CITY LINCOLNVILLE CITY RAMONA CITY TAMPA CITY A X T E L L CITY C I T Y BLUE R A P I D S C I T Y SUMMERFIELD CITY LATIMER CITY W H I T E CITY C I T Y CENTRALIA CITY C O R N I N G CITY GCFF CITY O N E I D A CITY W E T M O R E CITY B A Z I N E CITY TESCOTT CITY A L D E N CITY O A M A R CITY LIEBENTHAL CITY RUSH C E N T E R C I T Y PARADISE CITY C E D A R CITY CONWAY SPRINGS CITY PAGE OF THE TREASURY 6b 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 PAGE OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE ALMA CITY ESKRIDGE CITY M C F A R L A N D CITY P A X I C O CITY A L T O O N A CITY B U F F A L O CITY COYVILLE CITY NEW ALBANY C I T Y NEOSHO FALLS CITY T O R O N T O CITY EDWARDSVILLE CITY K A N S A S CITY C I T Y I N D I A N CREEK T O W N S H I P LINCOLN TOWNSHIP LONE ELM T O W N S H I P OZARK T O W N S H I P PUTNAM T O W N S H I P REEDER TOWNSHIP UNION TOWNSHIP WALKER T O W N S H I P WASHINGTON TOWNSHIP WESTPHALIA TOWNSHIP CENTER TOWNSHIP FRANKLIN TOWNSHIP MILL CREEK T O W N S H I P WALNUT TOWNSHIP MISSION TOWNSHIP CEDAR TOWNSHIP COTTONWOOD TOWNSHIP DIAMOND CREEK TOWNSHIP FALLS TOWNSHIP MATFIELD TOWNSHIP BELLEVILLE TOWNSHIP CANEYVILLE TOWNSHIP HARRISON TOWNSHIP HENDRICKS TOWNSHIP SALT CREEK T O W N S H I P SEDAN T O W N S H I P SUMMIT T O W N S H I P WASHINGTON TOWNSHIP CHEROKEE TOWNSHIP CRAWFORD TOWNSHIP LYON T O W N S H I P MINERAL TOWNSHIP NEOSHC T O W N S H I P PLEASANT VIEW T O W N S H I P TEST 67 05/23/78 A J^5205EpARTMENT DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 17 ROSS TOWNSHIP 17 SALAMANCA T O W N S H I P 17 AVON T O W N S H I P 17 LIBERTY TOWNSHIP 17 ROCK CREEK T O W N S H I P 17 STAR T O W N S H I P 17 CEDAR TOWNSHIP 17 GRANT TOWNSHIP 17 OMNIA T O W N S H I P 17 RICHLAND TOWNSHIP 17 WINDSOR TOWNSHIP 17 LINCOLN TOWNSHIP 17 SHERIDAN TOWNSHIP 17 SHERMAN T O W N S H I P 17 WALNUT TOWNSHIP 17 UNION TOWNSHIP 17 ELK F A L L S T O W N S H I P 17 HOWARD TOWNSHIP 17 LIBERTY TOWNSHIP 17 O A K VALLEY T O W N S H I P 17 UNION CENTER TOWNSHIP 17 O T T E R CRll^ TOWNSHIP 17 SALEM TOWNSHIP 17 CANADA T O W N S H I P 17 FAIRVIEW TOWNSHIP 17 HACK9ERRY TOWNSHIP 17 HOWARD T O W N S H I P 17 LABETTE TOWNSHIP 17 LIBERTY TOWNSHIP 17 MONTANA TOWNSHIP 17 M O U N D VALLEY T O W N S H I P 17 NEOSHO TOWNSHIP 17 OSAGE T O W N S H I P 17 OSWEGO TOWNSHIP 17 RICHLAND TOWNSHIP 17 RENO T O W N S H I P 17 PAXTCN TOWNSHI" 17 FAIRPLAY TOWNSHIP 17 O K E T O TOrfNSHIP 17 T O W N S H I P NO 9 17 T O W N S H I P NO 5 17 ADAMS TOWNSHIP 17 CAPIOMA TOWNSHIP 17 CENTER TOWNSHIP 17 C L E A R CREEK T O W N S H I P 17 OILMAN TOKNSHIP 0F THE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 17 TITLE GRANADA T O W N S H I P HARRISON TOWNSHIP HOME T O W N S H I P ILLINOIS TOWNSHIP MARION T O W N S H I P NEUCHATEL T O W N S H I P REILLY T O W N S H I P RICHMOND TOWNSHIP RCCK CREEK T O W N S H I P WETMORE TOWNSHIP HIGHPOINT TOWNSHIP JACKSON TOWNSHIP HENRY T O W N S H I P VALVEROE T O W N S H I P ALMA T O W N S H I P KAW TOWNSHIP CLIFTON TOWNSHIP DUCK CREEK T O W N S H I P F A L L RIVER T O W N S H I P LIBERTY TOWNSHIP TCRONTO TOWNSHIP STATE = 17: 205 RECORDS PAGE OF THE TREASURY 69 05/23/78 AT 31:25 U.S. D E P A R T M E N T OF DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 16 BRACKEN COUNTY 18 BUTLER COUNTY 18 CALDWELL COUNTY 18 CAMPBELL COUNTY 18 CARLISLE COUNTY 18 FLEMING COUNTY 18 FULTON COUNTY 18 GALLATIN COUNTY 18 GARRARD COUNTY 18 GREEN COUNTY 18 JACKSON COUNTY 18 LEE COUNTY 18 LEWIS COUNTY 18 LINCOLN COUNTY 18 LOGAN COUNTY 16 MARION COUNTY 18 MARSHALL C O U N T Y 18 MCNROE COUNTY 16 MORGAN COUNTY 18 NELSON COUNTY 18 OWSLEY COUNTY 18 ROBERTSON COUNTY 18 SPENCER COUNTY 13 WASHINGTON C O U N T Y 18 AUGUSTA CITY 18 BROOKSVILLE CITY 18 FOSTER CITY 16 MORGANTOWN C I T Y 18 FREOONIA CITY 18 PRINCETON CITY 18 BELLEVUE CITY 18 CALIFORNIA CITY 16 CRtSTVIEW CITY 18 DAYTON CITY 18 HIGHLAND H E I G H T S CITY 18 NEWPORT CITY 18 SILVER GROVE C I T Y 18 SCUTHGATE CITY 18 WILDER CITY 18 MELBOURNE CITY 18 ARLINGTON CITY 18 BARDWELL CITY 18 FULTON CITY 18 HICKMAN CITY 18 WARSAW CITY 18 GLENCOE CITY THE TREASURY PAGE 0 5 / 2 3/78 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 18 18 18 18 18 16 18 18 18 13 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 16 18 OF THE ELIGIBILITY GOVERNMENTS) TITLE L A N C A S T E R CITY C A M P B E L L S B URG C I T Y E M I N E N C E C ITY SMITHFIELD CITY C O L U M B U S C ITY MC K E E CIT Y B R O M L E Y CI TY C C V I N G T C N CITY L U D L O W CIT Y V A N C E B U R G CI TY TCLLESBORO CITY CRAB ORCHA RD C I T Y H U S T O M V I L L E CITY S T A N F O R D C ITY A U B U R N CIT Y R U S S E L L V I L LE- C I T Y B R A D F O R D S V ILLE C I T Y L G R E T T O CI TY B E N T O N CIT Y H A R D I N CIT Y C A L V E R T CI TY TCMPKINSVI LLC CITY G A M A L I E L C ITY BLOOMFIELD CITY NEW HAVEN C I T Y F A I R F I E L D CI TY CLAY CITY CI TY MOUNT OLIV ET C I T Y JAMESTOWN CI TY R U S S E L L SP R I N G S C I T Y T A Y L O R S V I L LE C I T Y MACKVILLE CITY WILLIS8URG CITY S T A T E = 18: 79 TREASURY RECORDS TE»ST 71 PAGE 05/23/78 A Jj;S^PARTM£NT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 TITLE ALLEN PARISH AVOYELLES PARISH BIENVILLE PARISH CADDO PARISH CALCASIEU PARISH CATAHOULA PARISH CLAIBORNE PARISH CONCORDIA PARISH OE SCTO PARISH EAST CARROLL PARISH EAST FELICIANA PARISH EVANGELINE PARISH FRANKLIN PARISH IBERVILLE PARISH P O L I C L JURY JACKSON PARISH POLICL JURY JEFFERSON DAVIS PARISH MADISON PARISH POLICE JURY MCREHCUSE PARISH NATCHITOCHES P A R I S H PCINTE COUPEE PARISH RAPIDES PARISH RED RIVER PARISH RICHLANO PARISH ST JAMES PARISH ST LANDRY PARISH TANGIPAHOA PARISH TENSAS PARISH VERNON PARISH WASHINGTON PARISH xEBSTER PARISH WEST CARROLL PARISH WEST FELICIANA P A R I S H WINN PARISH KINDER TOWN OAKDALE CITY OBERLIN CITY REEVES VILLAGE ELIZABETH TOWN OONALDSONVILLE C I T Y SCRRENTC VILLAGE BUNKIE TOWN HESSMER VILLAGE MARKSVILLE TOwN MOREAUVILLE VILLAGE PLAUCHEVILLE V I L L A G E SIMMESPORT TCWN TREASURY 72 05/23/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE OF DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 19 ARCADIA TOWN 19 8IENVILLE VILLAGE 19 G I B S L A N D TflWN 19 RINGGOLD TOWN 19 SALINE VILLAGE 19 BRYCELAND VILLAGE 19 CASTOR VILLAGE 19 MOUNT L E B A N O N TCWN 19 JAMESTOWN VILLAGE 19 LUCKY VILLAGE 19 M C O R I N G S P O R T TOWN 19 OIL CITY TOWN 19 SHREVEPORT CITY 19 V I V I A N TOWN 19 BLANCHARD VILLAGE 19 BELCHER VILLAGE 19 G I L L I A M TOWN 19 H C S S T O N TOWN 19 IDA TOWN 19 RCOESSA TCWN 19 DE OUINCY C I T Y 19 LAKE C H A R L E S C I T Y 19 V I N T O N TOWN 19 WESTLAKE TOWN 19 CLARKS VILLAGE 19 HARRISONBURG VILLAGE 19 J C N E S V I L L E TOWN 19 S I C I L Y ISLAND V I L L A G E 19 ATHENS VILLAGE 19 H A Y N E S V I L L E TOWN 19 H O M E R TOWN 19 LISBON VILLAGE 19 CLAYTON VILLAGE 19 FERRIOAY TOWN 19 V I O A L I A TCWN 19 R I D G E C R E S T TOWN 19 L O G A N S P O R T TOWN 19 MANSFIELD CITY 19 SOUTH MANSFIELD VILLAGE 19 STANLEY VILLAGE 19 STONEWALL VILLAGE 19 LAKE P R O V I D E N C E TOWN 19 C L I N T O N TOWN 19 J A C K S O N TOWN 19 NORWOOD V I L L A G E 19 WILSON V I L L A G E THE TREASURY 73 05/2 3/78 AT 31:25 U.S. D E P A R T M E N T PAGE OF DISTRESSED AREA ELIGIBILITY FEIST (ELIGIBLE GOVERNMENTS) STATE 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 TITLE BASILE TOWN MAMOU TOWN VILLE PLATTE TOWN TURKEY CREEK VILLAGE PINE PRAIRIE VILLAGE CHATAIGNIER VILLAGE GILBERT VILLAGE WINNSBORO TOWN WISNER TOWN BASKIN VILLAGE CCLFAX TOWN DRY PRONG VILLAGE GEORGETOWN VILLAGE MCNTGCNERY TOWN POLLOCK TOWN MARINGOUIN TOWN PLAQUEMINE TOWN CHATHMAN TOWN HODGE VILLAGE JCNESBORO TOWN NORTH HODGE VILLAGE EAST HODaE TOWN ELTON TOWN FENTON VILLAGE JENNINGS CITY LAKE ARTHUR TOWN WELSH TOWN LIVINGSTON VILLAGE WALKER TOWN FRENCH SETTLEMENT VILLAGE OELTA VILLAGE MOUND VILLAGE TALLULAH VILLAGE RICHMOND VILLAGE 8ASTR0P CITY BCNITA VILLAGE CCLLINSTON VILLAGE MER ROUGE VILLAGE OAK RIDGE VILLAGE CAMPTI VILLAGE CLARENCE VILLAGE GOLCONNA VILLAGE NATCHITOCHES CITY PROVENCAL VILLAGE RCBELINE VILLAGE ASHLAND TOWN THE TREASJRY 74 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 19 POWHATAN TOWN STATE = 19: 139 RECORDS PAGE 75 TREASURY PAGE 76 05/23/78 ^ s 2 5 D £ p A R T M E N T 0F T HE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 19 NATCHEZ VILLAGE STATE = 19* 1 RECORDS TREASURY 05/2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 TITLE NEW O R L E A N S CITY NEW ROADS TOWN FORDOCHE VILLAGE ALEXANDRIA CITY BOYCE TOWN C H E N E Y V I L L E TOWN FOREST HILL V I L L A G E GLENMORA TOWN LECOMPTE TOWN WOOOWORTH V I L L A G E CCUSHATTA TOWN EDGEFIELD V I L L A G E MARTIN VILLAGE DELHI TOWN MANGHAM TOWN RAYVILLE TOWN GRAMERCY TOWN LUTCHER TOWN GRAND COTEAU TOWN KROTZ SPRINGS V I L L A G E LEONVILLE VILLAGE MELVILLE T O W N OPELOUSAS CITY PALMETTO VILLAGE PCRT BARRE TOWN SUNSET TOWN WASHINGTON TOWN CANKTON V I L L A G E MADISCNVILLE TOWN SUN VILLAGE A M T E CITY TOW* HAMMOND CITY INDEPENDENCE TOWN K E N T W O O O TOWN PONCHATOULA TOWN RCSELAND TOWN TICKFAW V I L L A G E TANGIPAHOA V I L L A G E WOODHAVEN V I L L A G E NEWELLTON TOWN ST JOSEPH TOWN WATERPROOF TOWM HORNBECK TOWN LEESVILLE TOWN NEWLLANO V I L L A G E RCSEPINE V I L L A G E PAGE 77 OF THE TREASURY ELIGIBILITY GOVERNMENTS) FE'ST P A G E 78. 05/23/78 AT n « « M R T M E N T op TH£ TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE GOVERNMENTS) TITLE 19 SIMPSON VILL AGE 19 ANGIE VILLAG E 19 BCGALUSA CIT Y 19 FRANKLINTON TOWN 19 VARNADO VILL ACE 19 COTTON VALLE Y TOWN 19 CULLEN TOWN GE 19 HEFLIN VILLA 19 MINDEN CITY ACE 19 SAREPTA VILL ITY 19 SPRINGHILL C LLAGE 19 DIXIE INN VI LLAGE 19 SHONGALOO VI LLAGE 19 EPPS VILLAGE WN 19 KILBOURNE VI AGE 19 CAK GROVE TO GE 19 PIONEER VILL LLE TOWN 19 FOREST VILLA GE 19 ST FRANCISVI E 19 DCOSON VILLA TY 19 STATE SIKES= 19: VILLAGb 8 RECORDS 19 WINNFIELD CI — £ 05/2 3/78 AT 31:25 U.S. DEPARTMENT DISTRESSED OF THE TREASURY AREA ELIGIBILITY TE«ST (ELIGIBLE STATE PAGE 79. TITLE 20 ANDROSCOGGIN COUNTY 20 AROOSTOOK COUNTY 20 KENNEBEC COUNTY 20 LINCOLN COUNTY 20 OXFORD COUNTY 20 PENOBSCOT COUNTY 20 PISCATAQUIS COUNTY 20 SAGADAHOC COUNTY 20 SCMERSET COUNTY 20 WALDO COUNTY 20 AUBURN CITY 20, LEWISTON CITY 20 PRESQUE ISLE CITY 20 CARIBOU CITY 20 PORTLAND CITY 20 SCUTH PORTLAND CITY 20 WESTBROO< CITY 20 AUGUSTA CITY 20 GARDINER CITY 20 HALLOWELL CITY 20 WATERVILLE CITY 20 RCCKLANO CITY 20 BANGOP CITY 20 BFEWER CITY 20 OLD TCWN CITY 20 BATH CITY 20 BELFAST CITY 20 CALAIS CITY 20 EASTPORT CITY 20 BIDDEFORD CITY 20 DURHAM TOWN 20 GREENE TCWN 20 LEEDS TOWN 20 LISBON TOWN 20 LIVERMORE TOWN 20 LIVERMORE FALLS TOWN 20 TURNER TOWNSHIP 20 WALES TO*N 20 SABATTUS TOWN 20 ALLAGASH PLANTATION 20 AMITY TOWN 20 ASHLANO TOWN dO BANCROFT TOWN 20 BLAINE TOWN 20 BRIDGEWATER TOWN 20 CARY PLANTATION GOVERNMENTS) 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 20 CASTLE HILL TOWN 20 CASWELL PLANTATION 20 CHAPMAN TOWN 20 C R Y S T A L TOWN 20 CYR PLANTATION 20 DYER BROOK TOWN 20 E PLANTATION 20 EAGLE LAKE TOWN 20 E A S T O N TOWN 20 FORT F A I R F I E L D T O W N 20 FORT KENT TOWN 20 F R E N C H V I L L E TOWN 20 GARFIELD P L A N T A T I O N 20 GLENWOOD PLANTATION 20 GRAND ISLE TOWN 20 HAMLIN TOWN 20 HAMMOND P L A N T A T I O N 20 H A Y N E S V I L L E TOWN 20 HCDGDCN TOWN 20 H C U L T O N TOWN 20 LIMESTONE TOWN 20 L I N N E U S TOWM 20 LITTLETON TOWN 20 LUDLOW TOWN 20 MACWAHOC P L A N T A T I O N 20 MADAWASKA TOWN 20 MARS HILL TOWN 20 MASARDIS TOWN 20 MCNTICELLO TOWN 20 MCRC P L A N T A T I O N 20 NEW CANADA P L A N T A T I O N 20 NEW LIMERICK TOWN 20 NEW SWEDEN TOWN 20 O A K F I E L D TOWN 20 ORIENT TOWN 20 OXBOW PLANTATION 20 PERHAM TOWN 20 REED PLANTATION 20 ST AGATHA TOWN 20 ST FRANCIS TOWN 20 ST JOHN P L A N T A T I O N 20 STOCKHOLM TOWN 20 VAN BUREN TOwN 20 WADE TOWN 20 WALLAGRASS PLANTATION 20 W A S H B U R N TOWN PAGE OF THE TREASURY 80 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE OF DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 20 WESTFIELD TOWN 20 WESTMANLAND PLANTATION 20 W E S T O N TOWN 20 WINTERVILLE PLANTATION 20 W O O D L A N D TOWN 20 BRUNSWICK TOWN 20 C A P E E L I Z A 3 E T H TOWN 20 H A R P S W E L L TOWN 20 E U S T I S TOWN 20 I N D U S T R Y TOWN 20 MADRID TOWN 20 RANGELEY P L A N T A T I O N 20 RANGELEY T O W N 20 STRONG TOWN 20 WILTON TOWN 20 C A R R A B A S S E T T V A L L E Y TOWN 20 A t H E R S T TOWN 20 BAR HARBOR TCWN 20 O R L A N D TOWN 20 GREAT POND P L A N T A T I O N 20 S T O N I N G T O N TOWN 20 SULLIVAN TOWN 20 BENTON TOWN 20 C H E L S E A TOWN 20 F A R M I N G C A L E TOWN 20 F A Y E T T E TOWN 20 L I T C H F I E L D TOWN 20 MONMOUTH TOWN 20 P I T T S T O N TOWN 20 R A N D O L P H TOWN 20 WAYNE TOWN 20 WEST G A R D I N E R TOWN 20 W I N D S O R TOWN 20 ALNA T O W N S H I P 20 B C O T H B A Y TOWN 20 B G O T H B A Y H A R B O R TOWN 20 B R E M E N TOWN 20 DRESDEN TOWN 20 E D G E C O M B TOWN 20 NEWCASTLE TOWN 20 N O B L E B O R O U G H TOWN 20 SOMERVILLE TOWN 20 S C U T H B R I S T O L TOWN 20 SCUTHPORT TOWN 20 WESTPORT I S L A N D TOWN 20 WHITEFIELD TOWN THE TREASURY 81 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T OF THE ^t TREASURY PAG ^ 82 DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 20 WISCASSET TOWN 20 ANDOVER TOWN 20 BETHEL TOWN 20 BROWNFIELD TOWN 20 BUCKFIELD TOWN 20 BYRON TOWN 20 CANTON TOWN 20 DENMARK TOWN 20 DIXFIELD TOWN 20 FRYEBURC TOWN 20 GILEAD TOWN 20 GREENW003 TOWN 20 HANOVER TOWN 20 HARTFORD TOWN 20 HEBRON TOWN 20 HIRAM TOWN 20 LINCOLN PLANTATION 20 LCVELL TOWN 20 MAGALLOWAY P L A N T A T I O N 20 MEXICO TOWN 20 NEWRY TOWN 20 NCRWAY TOWN 20 OXFORD TOWN 20 PARIS TOWN 20 PERU TOWN 20 PORTER TOWN 20 RCXBURY TOWN 20 RUMFORD TOWN 20 STONEHAM TOWN 20 STOW TOWN 20 SUMNER TOWN 20 SWEDEN TOWN 20 UPTON TOWN 20 WATERF0R3 TOWN 20 WCODSTOCK TOWN 20 WEST PARIS TOWN 20 BRADFORD TOWN 20 BURLINGTON TOWN 20 CARMEL TOWN 20 CHARLESTON TOWN 20 CHESTER TOWN 20 CORINNA TOWN 20 CORINTH TOWN 20 OEXTER TOWN 20 DIXMONT TOWN 20 DREW PLANTATION ^mm \ 05/2 3/73 AT 3 1 : 2 5 U.S. D E P A R T M E N T OF DISTRESSED AREA (ELIGIBLE STATE 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 PAGE THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE E D O I N G T C N TOWN E N F I E L D TOWN ETNA TOWN EXETER TOWN G A R L A N D TOWN GLENBURN TOWN GRAND FALLS PLANTATION HERMON TOWN H O L D E N TOWN H C W L A N D TOWN HUDSON TOWN K E N D U S K E A G TOWN LAKEVILLE PLANTATION LEE TOWN LEVANT TOWN L I N C O L N TOWN LOWELL TOWN MATTAWAMKEAG TOWN MAXFIELD TOrfN NEWBURGH TOWN NEWPORT TOWN ORONO TOWN O R R I N G T O N TOWN PASSADUMKEAG TOWN PATTEN TOWN P L Y M O U T H TOWN PRENTISS PLANTATION SEBOEIS PLANTATION S P R I N G F I E L D TOWN STETSON TOWN VEAZIE TOWN WE3STER PLANTATION WINN TOWN W O O D V I L L E TOWN CARROLL PLANTATION ABBOT TOWN ATKINSON TOWN BARNARD P L A N T A T I O N BLANCHARD P L A N T A T I O N BCWERBANK TOWN BROWNVILLE TOWN DOVER F O X C R O F T TOWN ELLIOTTSVILLE PLANTATION GREENVILLE TOWN GUILFORD TOWN KINGSEURY PLANTATION TEST 83 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 TITLE LAKE VIEW P L A N T A T I O N MILO TOWN MCNSON TOWN PARKMAN TOWN SANGERVILLE TOWN SEBEC TOWN SHIRLEY TOWN WELLINGTON TOWM WILLMANTIC TOWN MEDFORD TOWN BEAVER COVE PLANTATION ARROWSIC TOWN BCWDOIN TOWN 8GWD0INHAM TOWN GEORGETOWN PHIPPSBURG TOWN RICHMOND TOWN TCPSHAM TOWN WEST BATH TOWN WOOLWICH TOWN ANSON TOWN ATHENS TOWN BINGHAM TOWN BRIGHTON P L A N T A T I O N CAMBRIDGE TOWN CANAAN TOWN CARATUNK P L A N T A T I O N CORNVILLE TOWN DENNISTOWN P L A N T A T I O N OETROIT TCWN EHBDEN TOWN FAIRFIELD TOWN HARMONY TOWN HARTLAND TOWN HIGHLAND PLANTATION JACKMAN TOWN MADISCN TOWN MOOSE RIVER TOWN NEW PORTLAND TOWN NCRRIDGEWCCK TOWN PALMYRA TOWN PITTSFIELD TOWN PLEASANT RIDGE PL MERCER TOWN RIPLEY TOWN ST ALBANS TCWN p A G E 84 05/2 3/78 AT 31:25 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 20 SKOWHEGAN TOWN SMITHFIELD TOWN SOLON TOWN S T A R K S TOWN THE FORKS P L A N T A T I O N WEST FORKS P L A N T A T I O N 8 E L M 0 N T TOWN B R O O K S TOWN BURNHAM TOWN FRANKFORT TOWN F R E E D O M TOWN ISLESBORO TOWN J A C K S O N TOWN KNOX TOWN LIBERTY TOWN L I N C O L N V I L L E TOWN MONROE TOWN MCNTVILLE TOWN MORRILL TOWN NORTHPORT TOWN PALERMO TOWN PROSPECT TOWN SEARSMONT TOWN SEARSPORT TOWN S T O C K T O N S P R I N G S TOWN SWANVILLE TOWN THORNDIKE TOWN TROY TOWN UNITY-TCWN WALDO TOWN WINTERPORT TOWN COOYVILLE P L A N T A T I O N CRAWFORD TOWN CUTLER TOWN LUBEC TOWN MACHIASPORT TOWN MILBRIDGE TOWN NORTHFIELD TOWN TALMADGE TOWN WHITING TOWN WHITNEYVILLEi TOWN ACTON TOWN ALFRED TOWN BUXTON TOWN CCRNISH TOWN DAYTON TOWN PAGE 85 OF THE TREASURY 05/2 3/78 AT 31:25 U.S. DEPARTMENT DISTRESSED OF THE TREASURY AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 20 HCLLIS TOWN 20 KENNEBUNKPORT TOWN 20 LEBANON TOWN 20 LIMERICK TOWN 20 LIMINGTON TOWN 20 LYMAN TOWN 20 NEWFIELD TOWN 20 NCRTH BERWICK TOWN 20 ARUNDEL TOWN 20 OLD ORCHARD BEACH TCWN 20 PARSONSFIELO TOWN 20 SANFORD TOWN 20 SHAPLEIGH TOWN 20 WATERBCR3 TOWN STATE = 20: 33b RECORDS PAGE 8b TEST 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 21 ALLEGANY COUNTY 21 CAROLINE COUNTY 21 C E C I L COUNTY 21 DCRCHESTER COUNTY 21 KENT COUNTY 21 SOMERSET COUNTY 21 WASHINGTON COUNTY 21 B A R T O N TOWN 21 CUMBERLAND CITY 21 FROSTBURG CITY 21 LCNACONING TOWN 21 LUKE TOWN 21 MIOLANO TOWN 21 W E S T E R N P O R T TOWN 21 BALTIMORE CITY 21 FE0ERALS3URG TOWN 21 G C L D S B O R O TOWN 21 G R E E N S B O R O TOWN 21 H E N O E R S O N TOWN 21 H I L L S B O R O TOWN 21 MARYOEL TOWN 21 RIDGELY TOWN 21 TANEYTOWM C I T Y 21 C E C I L T O N TOWN 21 C H A R L E S T O W N TOWN 21 C H E S A P E A K E C I T Y TOWN 21 E L K T C N TOWN 21 NORTH EAST TOWN 21 PERRYVILLE TOWN 21 PCRT D E P O S I T TOWN 21 BROOKVIEW TOWN 21 CAMBRIDGE CITY 21 EAST NEW MARKE T TOWN 21 E L D O R A D O TOWN 21 G A L E S T O W N TOWN 21 HURLOCK TOWN 21 SECRETARY TCWN 21 VIENNA TOWN 21 B U R K I T T S V I L L E TOWN 21 DEER PARK TCWN 21 FRIENDSVILLEi TOWN 21 K I T Z M I L L E R V I L L E TOWN 21 O A K L A N D TOWN 21 8 E T T E R T 0 N TOWN 21 C H E S T E R T O W N TOWN 21 GALENA TOWN PAGE OF THE TREASURY 87 05/23/78 AT 31:25 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE GOVERNMENTS) STATE TITLE 21 ROCK HAL. TOWN 21 BARCLAY TOWN 21 CENTREVILLE TOWN 21 CHURCH HILL TOWN 21 OUEENSTOWN TOWN 21 SUDLERSVILLE: TOWN 21 TEMPLEVILLE TOWN 21 CRISFIELD CITY 21 PRINCESS ANNE TOWN 21 CLEAR SPRING TOWN 21 FUNKSTOWN TOWN 21 HAGERSTOWN CITY 21 HANCOCK TOWN 21 SHARPS8URG TOWN 21 SMITHS8URG TOWN 21 WILLIAMSPORT TOWN 21 DELMAR TOWN 21 FRUITLAND TOWN 21 HEBRON TOWN 21 MARDELA SPRINGS TOWN 21 PITTSVILLE TOWN 21 SALISBURY CITY 21 SHARPTOWN TOWN 21 BERLIN TOWN 21 PCCOMOKE CITY 21 SNOW HILL TOWN ST ATE = 21: 72 RECORDS PAGE 88 OF THE TREASURY ELIGIBILITY TE'ST 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 22 BERKSHIRE COUNTY 22 BRISTOL COUNTY 22 ESSEX COUNTY 22 FRANKLIN COUNTY 22 HAMPDEN C O U N T Y 22 MIDOLESEX C O U N T Y 22 WORCESTER C O U N T Y 22 NCRTH ADAMS CITY 22 PITTSFIELD C I T Y 22 ATTLEBORO CITY 22 FALL RIVER C I T Y 22 NEW BEDFORD CITY 22 TAUNTON CITY 22 B E V E R L Y CITY 22 GLOUCESTER CITY 22 HAVERHILL CITY ZZ LAWRENCE CITY 22 LYNN CITY 22 NEWBURYPORT CITY 22 PEA30DY CITY 22 SALEM CITY 22 CHICOPEE CITY 22 H O L Y O K E CITY 22 S P R I N G F I E L D CITY 22 NCRTHAMPTCN CITY 22 CAMBRIDGE CITY 22 EVERETT CITY 22 LOWELL CITY 22 MALDEN CITY 22 MEDFORD CITY 22 MELROSE CITY 22 SOMERVILLE C I T Y 22 WALTHAM CITY 22 WOBURN CITY 22 OUINCY CITY 22 BOSTON CITY 22 CHELSEA CITY 22 REVERE CITY 22 FITCHBURG CITY 22 GARDNER CITY 22 WORCESTER CITY 22 BOURNE TOWN 22 ADAMS TOWN 22 CLARKSBURG TOWN 22 LEE TOWN 22 LENOX TOWN PAGE OF THE TREASURY 89 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE 90 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 TITLE ACUSHNET TOWN BERKLEY TOWN OARTMOUTH TOWN DIGHTON TOWN FAIRHAVEN TOWN FREETOWN TOWN NCRTH ATTLE30R0UGH TOWN NORTON TOWN RAYNHAM TOWN REHOBOTH TOWN SEEKONK TOWN SOMERSET TOWN WESTPCRT TOWN AMESBURY TOWN DANVERS TOWN GROVELAND TOWN MERRIMAC TOWN METHUEN TOWN MIDDLETON TO»N NAHANT TOWN NCRTH ANDOVER TOWN SALISBURY TOWN SAUGUS TOWN ASHFIELD TOWN BUCKLANO T3WN CCLRAIN TOWN ERVING TOWN GREENFIELD TOWN LEVERETT TOWN LEYDEN TOWN MONROE TOWN MONTAGUE TOWN NORTHFIELD TOWN ORANGE TOWN WENDELL TOWN AGAWAM TOWN BRIMFIELO TOWN EAST LQNGMEAOOW TOWN GRANVILLE TOWN HAMPDEN TOWN HOLLAND TOWN LUOLOW TOWN MONSON TOWN PALMER TOWN WEST SPRINGFIELD TOWN GRANBY TOWN TREASURY 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 22 ZZ 22 22 22 22 22 22 22 22 22 22 TITLE S C U T H H A D L E Y TOWN WARE TOWN W I L L I A M S 3 U R G TOWN ASHBY T O W N S H I P A S H L A N D TOWN AYER TOWN S H I R L E Y TOWN STONEHAM TOWN W A K E F I E L 3 TOWN WATERTOWN TOWN W I L M I N G T O N TOWN AVON TOWN BELLINGHAM TOWN DEOHAM TOWN F 0 X B 0 R 0 U 3 H TOWN F R A N K L I N TOWN HCLBROOK TOWN MEDWAY TOWN WALPOLE TOWN WEYMOUTH TOWN W R E N T H A M TOWN H A N O V E R TOWN H A N S O N TOWN HULL TOWN K I N G S T O N TOWN L A K E V I L L E TOWN MARION TOWN MARSHFIELO TOWN M A T T A P O I S E T T TOWN M I D D L E B O R O U G H TOWN P E M B R O K E TOWN ROCHESTER TOWN R O C K L A N D TOWN SCITUATE TOWN WINTHROP TOWN ASHBURNHAM TOWN ATHCL TOWN BARRE TOWN B L A C K S T C N E TOWN C L I N T O N TCWN DUDLEY TOWN HARDWICK TOWN HARVARD TOWN H C P E D A L E TOWN LANCASTER TOWN L U N E N B U R i TOWN 05/2 3/78 A T ^ 3 i : 2 5 p A R T M E N T DISTRESSED AREA ELIGIBILITY TE*ST (ELIGIBLE GOVERNMENTS) STATE 22 22 22 22 22 22 22 22 ZZ 22 TITLE MILLVILLE TOWN N O R T H B R I D G E TOWM P H I L L I P S T O N TOWN ROYALSTON TOwN S C U T H B R I D G E TOWN T E M P L E T O N TOWN UXBRIDGE TOWN WARREN TOWN W E B S T E R TOWN W I N C H E N D O N TOWN STATE = 22: 1^8 RECORDS ^ ^ ^ ^ PAGE 92 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 23 ALGER COUNTY 23 ALLEGAN COUNTY 23 BARAGA C O U N T Y 23 BARRY COUNTY 23 BAY COUNTY 23 BERRIEN C O U N T Y 23 BRANCH COUNTY 23 CALHOUN COUNTY 23 C A S S COUNTY 23 GENESEE COUNTY 23 G L A D W I N COUNTY 23 G O G E B I C COUNTY 23 GRATIOT COUNTY 23 HOUGHTON COUNTY 23 HURON COUNTY 23 INGHAM COUNTY 23 IONIA COUNTY 23 IRON COUNTY 23 JACKSON COUNTY 23 KEWEENAW C O U N T Y 23 LAPEER COUNTY 23 LENAWEE COUNTY 23 LUCE COUNTY 23 MANISTEE C O U N T Y 23 MENOMINEE COUNTY 23 MIDLAND COUNTY 23 MONTCALM C O U N T Y 23 MUSKEGON C O U N T Y 23 OCEANA C O U N T Y 23 ONTONAGON COUNTY 23 PRESQUE ISLE C O U N T Y 23 ST CLAIR C O U N T Y 23 ST JOSEPH C O U N T Y 23 SCHOOLCRAFT C O U N T Y 23 SHIAWASSEE C O U N T Y 23 WAYNE COUNTY 23 MUNISING C I T Y 23 ALLEGAN CITY 23 D C U G L A S VILLAGE 23 F E N N V I L L E CITY Zl H O P K I N S VILLAGE 23 MARTIN VILLAGE 23 PLAINWELL CITY 23 SAUGATUCK V I L L A G E 23 WAYLAND CITY 23 CENTRAL LAKE V I L L A G E PAGE OF THE TREASURY 93 PAGE 05/23/78 ^U.SIIEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE BARAGA V I L L A G E LANSE V I L L A G E FREEPORT VILLAGE HASTINGS CITY MIODLEVILLE VILLAGE NASHVILLE V I L L A G E WOODLAND VILLAGE BAY CITY ELBERTA V I L L A G E THOMPSONVILLE VILLAGE B E N T O N H A R B O R CITY BERRIEN SPRINGS VILLAGE BRIDGMAN C I T Y BUCHANAN C I T Y COLOMA CITY EAU CLAIRE V I L L A G E GALIEN V I L L A G E MICHIANA V I L L A G E NEW BUFFALO CITY N I L E S CITY ST JOSEPH CITY STEVENSVILLE VILLAGE THREE OAKS V I L L A G E WATERVLIET C I T Y B R O N S O N CITY C G L D W A T E R CITY AL3I0N CITY ATHENS VILLAGE B A T T L E CREEK C I T Y 8URLINGT0N VILLAGE HOMER V I L L A G E MARSHALL C I T Y S P R I N G F I E L D CITY TEKONSHA VILLAGE CASSOPOLIS VILLAGE DOWAGIAC CITY MARCELLUS V I L L A G E 8GYNE F A L L S V I L L A G E CHARLEVOIX CITY C H E B O Y G A N CITY SAULT SAINTE MARIE CITY GRAYLING CITY ESCANAOA CITY GLADSTONE CITY NORWAY CITY PETOSKEY CITY 94 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA PAGE OF 23 Z3 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 ZZ 23 23 Zl 23 23 23 23 23 23 23 23 23 23 23 23 23 23 Zl 23 23 23 23 23 23 23 23 TITLE C L I O CITY O A V I S O N CITY F E N T O N CITY F L I N T CITY FLUSHING CITY MCNTROSE VILLAGE MCUNT M O R R I S C I T Y OTISVILLE VILLAGE S W A R T Z CREEK C I T Y B U R T O N CITY BEAVERTON CITY G L A D W I N CITY BESSEMER CITY IRONWOOD C I T Y WAKEFIELD CITY ALMA CITY ASHLEY VILLAGE PERRINTON VILLAGE ST L O U I S C I T Y ALLEN VILLAGE HILLSDALE CITY WALDRON VIuLAGE CALUMET VILLAGE C O P P E R CITY V I L L A G E HANCOCK CITY HOUGHTON CITY LAKE L I N D E N V I L L A G E LAURIUM VILLAGE S O U T H RANGE V I L L A G E BAD AXE CITY CASEVILLE VILLAGE ELKTON VILLAGE H A P B O R BEACH C I T Y KINDE V I L L A G E PIGEON VILLAGE PORT A U S T I N V I L L A G E PORT HOPE V I L L A G E SEBEWAINi VILLAGE UBLY V I L L A G E L A N S I N G CITY CLARKSVILLE VILLAGE HU8BARDST0N VILLAGE IONIA CITY MUIR V I L L A G E PEWAMC V I L L A G E ALPHA V I L L A G E TREASURY ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE THE TEST 95 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 Zl 23 23 23 Zl 23 23 23 23 23 23 23 23 23 23 23 Zl 23 23 TITLE CASPIAN CITY CRYSTAL FALLS CITY GAASTPA CITY IRON RIVER C I T Y STAMBAUGH CITY BROOKLYN VILLAGE CCNCORO VILLAGE G R A S S LAKE V I L L A G E HANOVER VILLAGE J A C K S O N CITY PARMA V I L L A G E SPRINGPORT V I L L A G E KALAMAZOO CITY AHMEEK V I L L A G E ALMONT VILLAGE CLIFFORD VILLAGE COLUMBIAVILLE VILLAGE DRYDEN VILLAGE IMLAY CITY LAPEER CITY METAMORA V I L L A G E NCRTH BRANCH V I L L A G E O T T E R LAKE V I L L A G E ADRIAN CITY CLAYTON VILLAGE H U O S O N CITY MORENCI CITY ONSTED VILLAGE TECUMSEH CITY NEWBERRY VILLAGE ST IGNACE C I T Y ARMADA V I L L A G E CENTER LINE CITY E R A S E R CITY NEW B A L T I M O R E C I T Y NEW HAVEN V I L L A G E RICHMOND VILLAGE R C S E V I L L E CI TY WARREN CITY BEAR LAKE V I L L A G E COPEMISH VILLAGE EAST LAKE V I L L A G E KALEVA V I L L A G E MANISTEE CITY ONEKAMA V I L L A G E MARQUETTE CITY PAGE OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEST 9b 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE 97 OF THE DISTRESSED AREA ELIGIBILITY TE«ST (ELIGIBLE GOVERNMENTS) STATE TITLE 23 NEGAUNEE CITY 23 LUDINGTON CITY 23 MORLEY VILLAGE 23 MENOMINEE CITY 23 POWERS VILLAGE 23 STEPHENSON CITY 23 CCLEMAN CITY 23 SANFORD VILLAGE 23 LUNA PIER CITY 23 CARSON CITY 23 EDMORE VILLAGE 23 GREENVILLE CITY 23 HOWARD CITY VILLAGE 23 LAKEVIEW VILLAGE 23 MCBRIDE VILLAGE 23 PIERSON VILLAGE 23 SHERIDAN VILLAGE 23 STANTON CITY 23 FRUITPORT VILLAGE 23 MONTAGUE CITY 23 MUSKEGON CITY 23 MUSKEGON HEIGHTS CITY 23 NORTH MUSKEGON CITY 23 RAVENNA VILLAGE 23 ROOSEVELT PARK CITY 23 WHITEHALL CITY 23 LAKEWOOD CLUB VILLAGE 23 NORTON SHORES CITY 23 BERKLEY CITY 23 BINGHAM FARMS VILLAGE 23 BIRMINGHAM CITY 23 CLAWSON CITY 23 FERNDALE CITY 23 HAZEL PARK CITY 23 HOLLY VILLAGE 23 HUNTINGTON WOODS CITY 23 KEEGO HARBOR CITY 23 LAKE ORION VILLAGE 23 LEONARD VILLAGE 23 MADISON HEIGHTS CITY 23 MILFORD VILLAGE 23 ORTONVILLE VILLAGE 23 OXFORD VILLAGE 23 PLEASANT RIDGE CITY 23 PCNTIAC CITY 23 SOUTH LYON CITY TREASURY 05/23//8 A T J l : Z 5 p A R i M E N T QF DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 23 SYLVAN LAKE CITY 23 W A L L E D LAKE CITY 23 WOLVERINE LAKE VILLAGE 23 BEVERLY HILLS VILLAGE 23 FRANKLIN VILLAGE 23 HART CITY 23 PENTWATER V I L L A G E 23 SHELBY VILLAGE 23 WALKERVILLE VILLAGE 23 RCTH8URY VILLAGE 23 ONTONAGON VILLAGE 23 VANDERBILT V I L L A G E 23 MILLERSBURG VILLAGE 23 ONAWAY CITY 23 PCSEN V I L L A G E 23 ROGERS CITY CITY 23 SAGINAW CITY 23 ALGONAC CITY 23 CAPAC VILLAGE 23 EKMETT V I L L A G E 23 MARINE CITY 23 MARYSVILLE CITY 23 PORT HURON C I T Y Zl ST C L A I R C I T Y 23 YALE CITY 23 BURR OAK V I L L A G E 23 CENTREVILLE VILLAGE 23 COLON VILLAGE 23 CCNSTANTINE VILLAGE 23 MENOON VILLAGE 23 S T U R G I S CITY 23 THREE RIVERS CITY 23 W H I T E PIGEON V I L L A G E 23 CARSONVILLE VILLAGE 23 M I N D E N CITY V I L L A G E 23 PECK V I L L A G E 23 MANISTIQUE CITY 23 BANCROFT VILLAGE 23 BYRON V I L L A G E 23 C O R U N N A CITY 23 O U R A N D CITY 23 LAINGSBURG CITY 23 MGRRICE VILLAGE 23 NEW L O T H R O P V I L L A G E 23 O w O S S O CITY 23 PERRY CITY ^ „,„„„.. PA " 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE VERNON V I L L A G E G A G E T O W N V I L L A GE BLOOMINGDALE V ILLAGE B R E E D S V I L L E VI L L A G E DECATUR VILLAG E HARTFORD CITY PAW PAW V I L L A G E S C U T H HAVEN CI TY YPSILANTI CITY D E T R O I T CITY E C O R S E CITY G A R D E N CITY CI TY HAMTRAMCK C I T Y H I G H L A N D PARK CITY I N K S T E R CITY RIVER ROUGE CI TY WAYNE CITY WYANDOTTE CITY TAYLOR CITY R O M U L U S CITY HARRIETTA VILL AGE H A R R I S V I L L E TO W N S H I P HAYNES TOWNSHI P L I M E S T O N E TQiWN SHIP M A T H I A S T O W N S H IP A L L E G A N T O W N S H IP CASCO TOWNSHIP C H E S H I R E T O W N S HI P CLYDE TOWNSHIP DORR T O W N S H I P FILLMORE TOWNS HIP G A N G E S TOWNSHI P G U N P L A I N T O W N S HIP H O P K I N S TOWNSH IP LEE T O W N S H I P L E I G H T O N T O W N S HIP M A N L I U S T O W N S H IP MARTIN TOWNSHI P M C N T E R E Y T O W N S HI P OTSEGO TOWNSHI P OVERISEL TOWNS HIP SALEM T O W N S H I P SAUGATUCK TOWN SHIP T R O W B R I D G E TOW N S H I P VALLEY T O W N S H I P WATSON T O W N S H I P PAGE OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEST 99 05/23/78 A J^;-^pARTMENT of DISTRESSED AREA ELIGIBILITY TElST (ELIGI8LE GOVERNMENTS) STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE WAYLANO TOWNSHIP ALPENA TOWNSHIP MAPLE RIDGE TOWNSHIP WILSON TOWNSHIP KEARNEY TOWNSHIP ADAMS TOWNSHIP MASON TOWNSHIP WHITNEY TOWNSHIP ARVON TOWNSHIP BARAGA TOWNSHIP COVINGTON T O W N S H I P LANSE TOWNSHIP SPURR TOWNSHIP ASSYRIA TOWNSHIP BALTIMORE TOWNSHIP BARRY TOWNSHIP CARLTON TOWNSHIP CASTLETON TOWNSHIP HASTINGS T O W N S H I P HOPE TOWNSHIP IRVING TOWNSHIP JOHNSTOWN T O W N S H I P MAPLE GROVE TOWNSHIP ORANGEVILLE TOWNSHIP PRAIREVILLE TWP RUTLANO TOWNSHIP THORNAPPLE T O W N S H I P WCODLAND T O W N S H I P YANKEE S P R I N G S T O W N S H I P 3ANG0R TOWNSHIP BEAVER TOWNSHIP GARFIELD TOWNSHIP MOUNT FOREST T O W N S H I P PORTSMOUTH T O W N S H I P WILLIAMS TOWNSHIP C R Y S T A L LAKE T O W N S H I P G I L M O R E TOWNSHIP HOMESTEAD T O W N S H I P JOYFIELD TOWNSHIP WELDON TOWNSHIP BAINBRIDGE T O W N S H I P BENTON TOWNSHIP BERRIEN TOWNSHIP TOWNSHIP COLOMA CHIKAMING BERTRAND T OT WO NW SN HS IH IP P JHE TREASURY PAGE100 ^ 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE101 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 Zl 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE GALIEN TOW NSHIP HAGAR TOWN SHIP LAKE TOWNS HI P LINCOLN TO WNSHIP NEW BUFFAL 0 TOWNSHIP NILES TOWN SHIP ORONOKO TO WNSHIP PIPESTONE TOWNSHIP ST JOSEPH TOWNSHIP SCDUS TOWN SHIP THREE OAKS TOWNSHIP WATERVLIET TOWNSHIP WEESAW TOW NSHIP ALGANSEE T OWNSHIP BETHEL TOW NSHIP BRONSON TO WNSHIP 8UTLER TOW NSHIP CALIFORNIA TOWNSHIP GILEAD TOW NSHIP KINDERHOOK TOWNSHIP MATTESON T OWNSHIP UNION TOWN SHIP ALBION TOW NSHIP ATHENS TOW NSHIP BATTLE CRE EK TOWNSHIP BEDFORD TO WNSHIP BURLINGTON TOWNSHIP CLARENCE T OWNSHIP CLARENDON TOVNSHIP CONVIS TOW NSHIP ECKFORO TO WNSHIP EMMETT TOW NSHIP FREDONIA T OWNSHIP HOMER TCWN SHIP LEE TOWNSH IP LE ROY TOW NSHIP MARENGO TO WNSHIP MARSHALL T OWNSHIP NEWTON TOW NSHIP PENNFIELD TOWNSH IP SHERIDAN T OWNSHIP TEKONSHA T OWNSHIP HOWARD TOW NSHIP LA GRANGE TOWNSHIP MILTON TOW NSHIP NEWBERG TO WNSHIP GOVERNMENTS) „ , -,« AT ^1 -?s 05/23/78 A J j ; - ^ p PAGE102 A R T M E N T OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 23 PCKAGON TOWNSHIP 23 BGYNE VALLEY T O W N S H I P 23 MELROSE TOWNSHIP 23 PEAINE TOWNSHIP 23 CHIPPEWA T O W N S H I P 23 HULBERT TOWNSHIP 23 PICKFORD TOWNSHIP 23 REODING T O W N S H I P 23 WINTERFIELD T O W N S H I P 23 BREEN TOWNSHIP 23 WEST BRANCH T O W N S H I P 23 ARGENTINE T O W N S H I P 23 ATLAS TOWNSHIP 23 CLAYTON T O W N S H I P 23 DAVISON T O W N S H I P 23 FLINT TOWNSHIP 23 FOREST TOWNSHIP 23 GAINES TOWNSHIP 23 GENESEE T O W N S H I P 23 MCNTROSE T O W N S H I P 23 MCUNT MORRIS T O W N S H I P 23 MUNDY TOWNSHIP 23 RICHFIELD T O W N S H I P 23 THETFORD T O W N S H I P 23 VIENNA T O W N S H I P 23 BEAVERTON T O W N S H I P 23 BENTLEY T O W N S H I P 23 BILLING T O W N S H I P 23 BCURRETT T O W N S H I P 23 BUCKEYE TOWNSHIP 23 BUTMAN T O W N S H I P 23 CLEMENT T O W N S H I P 23 GLAOWIN T O W N S H I P 23 GRIM TOWNSHIP 23 G R O U T TOWNSHIP 23 HAY TOWNSHIP 23 SAGE TOWNSHIP 23 SECORD T O W N S H I P 23 SHERMAN T O W N S H I P 23 TOBACCO T O W N S H I P 23 BESSEMER T O W N S H I P 23 ERWIN TOWNSHIP 23 IRONWCOD T O W N S H I P 23 MARENISCO T O W N S H I P 23 WAKEFIELD T O W N S H I P 23 WATERSMEET T O W N S H I P ^ 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 23 23 23 23 23 23 23 23 23 Zl Zl 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE LONG LAKE T O W N S H I P ARCADA T O W N S H I P BETHANY TOWNSHIP ELBA T O W N S H I P EMERSON TOWNSHIP FULTON TOWNSHIP HAMILTON TOWNSHIP NEWARK T O W N S H I P NEW HAVEN T O W N S H I P NORTH SHADE T O W N S H I P N C R T H STAR T O W N S H I P PINE RIVER T O W N S H I P SEVILLE TOWNSHIP SUMNER T O W N S H I P WASHINGTON TOWNSHIP WHEELER TOWNSHIP ADAMS TOWNSHIP ALLEN T O W N S H I P CAMBRIA T O W N S H I P HILLSDALE TOWNSHIP LITCHFIELD TOWNSHIP RANSOM TOWNSHIP WC0D8RID3E TOWNSHIP WRIGHT TOWNSHIP ADAMS TOWNSHIP CALUMET TOWNSHIP CHASSELL TOWNSHIP D U N C A N TOWNSHIP ELM RIVER T O W N S H I P FRANKLIN TOWNSHIP HANCOCK TOWNSHIP LAIRD TOWNSHIP OSCEOLA T O W N S H I P PCRTAGE TOWNSHIP QUINCY T O W N S H I P SCHOOLCRAFT TOWNSHIP STANTON TOWNSHIP T O R C H LAKE T O W N S H I P 3INGHAM T O W N S H I P BLOOMFIELD TOWNSHIP BROOKFIELD TOWNSHIP CHANDLER TOWNSHIP COLFAX T O W N S H I P DWIGHT T O W N S H I P FAIRHAVEN TOWNSHIP GORE T O W N S H I P PAGE103 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TE»ST 05/23/78 A ;^--2D5EpARTMENT PAGE104 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 Zl 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE GRANT TOWNSHIP HUME T O W N S H I P H U R O N TOWNSHIP LINCOLN TOWNSHIP MCKINLEY T O W N S H I P MEADE TOWNSHIP PARIS TOWNSHIP PCINTE AUX B A R Q U E S TWP PORT AUSTIN T O W N S H I P RUBICON T O W N S H I P SAND BEACH T O W N S H I P SEBEWAING T O W N S H I P SHERIDAN T O W N S H I P SHERMAN TOWNSHIP S I G E L TOWNSHIP VERONA T O W N S H I P WINSOR TOWNSHIP ALAIEDON TOWNSHIP AURELIUS TOWNSHIP BERLIN TOWNSHIP EASTON T O W N S H I P IONIA TOWNSHIP KEENE TOWNSHIP NORTH PLAINS T O W N S H I P ORANGE TOWNSHIP OTISCO T O W N S H I P ALABASTER T O W N S H I P AU SABLE T O W N S H I P OSCODA T O W N S H I P RENO TOWNSHIP 8ATES TOWNSHIP HEMATITE T O W N S H I P IRON RIVER T O W N S H I P . DENVER TOWNSHIP FREMONT TOWNSHIP G I L M O R E TOWNSHIP LINCOLN TOWNSHIP VERNON T O W N S H I P WISE TOWNSHIP BLACKMAN T O W N S H I P CCLUMBIA T O W N S H I P CONCORD TOWNSHIP G R A S S LAKE T O W N S H I P HANOVER TOWNSHIP HENRIETTA T O W N S H I P LEONI TOWNSHIP >= 05/23/78 AT 01:25 U.S. DEPARTMENT PAGE105 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 Zl 23 23 Zl 23 23 23 23 23 23 23 Zl 23 23 23 23 23 23 23 TITLE NAPOLEON TOW NSHIP NCRVELL TOWN SHIP PARMA TOWNSH IP PULASKI TOWN SHIP RIVES TOWNSH IP SANDSTONE TO WNSHIP SPRING ARBOR TOWNSHIP SPRINGPORT T OWNSHIP SUMMIT TOWNS HIP TCMPKINS TOW NSHI P WATERLOO TOW NSHIP ALLOUEZ TOWN SHIP EAGLE HARBOR TOWNSHIP GRANT TOWNSH IP HCUGHTON TOW NSHI P SHERMAN TOWN SHIP ELK TOWNSHIP ALMONT TOWNS HIP ARCADIA TOWN SHIP ATTICA TOWNS HIP BURLINGTON T OWNSHIP BURNSIDE TOW NSHIP DEERFIELD TO WNSH IP ORYDEN TOWNS HIP ELBA TOWNSHI P GCODLAND TOW NSHIP HAOLEY TOWNS HIP IMLAY TOWNSH IP LAPEER TOWNS HIP MARATHON TOW NSHIP MAYFIELD TOW NSHIP METAMORA TOW NSHIP NORTH BRANCH TOWNSHIP OREGON TOWNS HIP RICH TOWNSHI P EMPIRE TOWNS HIP SOLON TOWNSH IP ADRIAN TOWNS HIP CAMBRIOGE TO WNSHIP CLINTON TOWN SHIP DEERFIELD TO WNSHIP DOVER TOWNSH IP FAIRFIEL3 TO WNSHIP FRANKLIN TOW NSHIP HUDSON TOWNS HIP MACON TOWNSH IP TEST PAGElOb 05/23/78 A S Ls! OE%ARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 Zl Zl TITLE MADISON TOWNSHIP MEOINA TOWNSHIP OGDEN TOWNSHIP PALMYRA TOWNSHIP RAISIN TOWNSHIP RIGA TOWNSHIP ROLLIN TOWNSHIP ROME TOWNSHIP SENECA TOWNSHIP TECUMSEH .TOWNSHIP WOODSTOCK TOWNSHIP CONWAY TOWNSHIP PENTLAND T O W N S H I P HENDRICKS T O W N S H I P HUDSON TOWNSHIP MARQUETTE TOWNSHIP MCRAN TOWNSHIP ARMADA TOWNSHIP CHESTERFIELD T O W N S H I P LENOX TOWNSHIP MACOMB TOWNSHIP RICHMOND T O W N S H I P ARCADIA TOWNSHIP BEAR LAKE T O W N S H I P BROWN TOWNSHIP CLEON TOWNSHIP DICKSON TOWNSHIP FILER TOWNSHIP MANISTEE T O W N S H I P MAPLE GROVE TOWNSHIP MARILLA TOWNSHIP NORMAN TOWNSHIP ONEKAMA TOWNSHIP PLEASANTON T O W N S H I P SPRINGOALE T O W N S H I P STRONACH T O W N S H I P EWING TOWNSHIP HUMBOLDT T O W N S H I P REPUBLIC T O W N S H I P SANDS TOWNSHIP AMBER TOWNSHIP EDEN TOWNSHIP PERE MARQUETTE T O W N S H I P SHERIDAN T O W N S H I P AETNA TOWNSHIP CHIPPEWA T O W N S H I P TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE FAITHORN TOWNSHIP HOLMES TOWNSHIP INGALLSTON T O W N S H I P LAKE T O W N S H I P MEYER TOWNSHIP NADEAU TOWNSHIP SPALOING TOWNSHIP EDENVILLE T O W N S H I P GENEVA T O W N S H I P GREENDALE TOWNSHIP HOMER TOWNSHIP HCPE T O W N S H I P JASPER T O W N S H I P JEROME T O W N S H I P LARKIN T O W N S H I 0 LEE TOWNSHIP LINCOLN TOWNSHIP MIDLAND T O W N S H I P MILLS T O W N S H I P MCUNT HALEY T O W N S H I P PORTER TOWNSHIP WARREN T O W N S H I P AETNA T O W N S H I P ENTERPRISE TOWNSHIP RICHLAND T O W N S H I P ERIE T O W N S H I P EXETER TOWNSHIP MONROE TOWNSHIP BELVIOERE T O W N S H I P BLOOMER TOWNSHIP BUSHNELL TOWNSHIP CATO T O W N S H I P CRYSTAL T O W N S H I P DAY TOWNSHIP DCUGLASS TOWNSHIP EUREKA TOWNSHIP EVERGREEN T O W N S H I P FAIRPLAIN TOWNSHIP F E R R I S TOWNSHIP HOME T O W N S H I P MAPLE VALLEY T O W N S H I P MCNTCALM TOWNSHIP PIERSON T O W N S H I P PINE T O W N S H I P REYNOLDS T O W N S H I P RICHLAND TOWNSHIP PAGE137 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEIST °5'25"9 'I.IVHWHM Of THE m.SURt '"OE10', DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 23 SIDNEY TOWNSHIP 23 WINFIELD T O W N S H I P 23 BLUE LAKE T O W N S H I P 23 CASNOVIA T O W N S H I P 23 CEDAR CREEK TOWNSHIP 23 DALTON TOWNSHIP 23 EGELSTON T O W N S H I P 23 FRUITLAND T O W N S H I P 23 FRUITPORT T O W N S H I P 23 HOLTON TOWNSHIP 23 LAKETON TOWNSHIP 23 MONTAGUE T O W N S H I P 23 MOORLAND T O W N S H I P 23 MUSKEGON T O W N S H I P 23 RAVENNA TOWNSHIP 23 SULLIVAN T O W N S H I P 23 WHITEHALL T O W N S H I P 23 WHITE RIVER T O W N S H I P 23 ASHLAND TCWNSHIP 23 BRIDGETON T O W N S H I P 23 DAYTON TOWNSHIP 23 DENVER TOWNSHIP 23 GCODWELL T O W N S H I P 23 MERRILL TOWNSHIP 23 NORWICH T O W N S H I P 23 SHERIDAN T O W N S H I P 23 SHERMAN TOWNSHIP 23 ADDISON TOWNSHIP 23 BRANDON TCWNSHIP 23 COMMERCE T O W N S H I P 23 GROVELANO T O W N S H I P 23 HIGHLAND T O W N S H I P 23 HOLLY TOWNSHIP 23 INDEPENDENCE T O W N S H I P 23 MILFORO TOWNSHIP 23 ORION TOWNSHIP 23 OXFORO T O W N S H I P 23 ROSE T O W N S H I P 23 SOUTHFIELD T O W N S H I P 23 SPRINGFIELD TOWNSHIP 23 WATERFORD T O W N S H I P 23 WHITE LAKE T O W N S H I P 23 BENONA T O W N S H I P 23 CLAYBANKS TOWNSHIP 23 COLFAX TOWNSHIP 23 CRYSTAL TOWNSHIP "N 0 5 / 2 3 / 7 6 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 23 EL6RIDGE TOWNSHIP 23 FERRY TOWNSHIP 23 G O L D E N TOWNSHIP 23 GRANT TOWNSHIP 23 GREENWOOD T O W N S H I P 23 HART TOWNSHIP 23 LEAVITT TOWNSHIP 23 NEWFIELD T O W N S H I P 23 OTTO TOWNSHIP 23 PENTWATER T O W N S H I P 23 SHELBY TOWNSHIP 23 WEARE TOWNSHIP 23 BERGLANO T O W N S H I P 23 BCHEMIA T O W N S H I P 23 CARP LAKE T O W N S H I P 23 GREENLAND TOWNSHIP 23 HAIGHT TOWNSHIP 23 INTERIOR T O W N S H I P 23 MCMILLAN T O W N S H I P 23 MATCHWOOD T O W N S H I P 23 ONTONAGON T O W N S H I P 23 ROCKLAND T O W N S H I P 23 STANNARD T O W N S H I P 23 HIGHLAND T O W N S H I P 23 SYLVAN TOWNSHIP 23 ALLIS TOWNSHIP 23 BEARINGER T O W N S H I P 23 BELKNAP TOWNSHIP 23 BISMARCK T O W N S H I P 23 CASE TOWNSHIP 23 KRAKOW TOWNSHIP 23 METZ TOWNSHIP Zl MOLTKE TOWNSHIP 23 NORTH ALLIS TOWNSHIP 23 OCQUEOC TOWNSHIP 23 POSEN TOWNSHIP 23 PRESQUE ISLE T O W N S H I P 23 PULAWSKI T O W N S H I P 23 ROGERS TOWNSHIP 23 BERLIN TOWNSHIP 23 BROCKWAY T O W N S H I P 23 BURTCHVILLE TOWNSHIP 23 CASCO TOWNSHIP 23 CHINA TOWNSHIP 23 CLAY TOWNSHIP 23 CLYDE TOWNSHIP PAGE109 OF THE TREASURY PAGE110 05/23/78 A Jj; S ^ p A R T K E N T OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 TITLE COTTRELLVILLE TOWNSHIP EAST CHINA T O W N S H I P EMMETT TOWNSHIP FORT GRATIOT T O W N S H I P GRANT TOWNSHIP GREENWOOD T O W N S H I P IRA TOWNSHIP KENOCKEE T O W N S H I P KIMBALL TOWNSHIP LYNN TOWNSHIP MUSSEY TOWNSHIP PORT HURON T O W N S H I P RILEY TOWNSHIP ST CLAIR T O W N S H I P WALES TOWNSHIP BURR OAK T O W N S H I P COLON TOWNSHIP CONSTANTINE T O W N S H I P FA3IUS TOWNSHIP FAWN RIVER T O W N S H I P FLORENCE T O W N S H I P FLOWERFIELD T O W N S H I P LEONIDAS TOWNSHIP LCCKPORT T O W N S H I P MENDON TOWNSHIP MOTTVILLE T O W N S H I P NCTTAWA TOWNSHIP STURGIS TOWNSHIP WHITE PIGEON T O W N S H I P ARGYLE TOWNSHIP AUSTIN TOWNSHIP DELAWARE T O W N S H I P ELK TOWNSHIP ELMER TOWNSHIP F L Y N N TOWNSHIP GREENLEAF T O W N S H I P MARION TOWNSHIP MINDEN TOWNSHIP MOORE TOWNSHIP WHEATLAND T O W N S H I P MUELLER T O W N S H I P ANTRIM T O W N S H I P BENNINGTON T O W N S H I P BURNS TOWNSHIP CALEDONIA T O W N S H I P FAIRFIELO T O W N S H I P s* 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T DISTRESSED AREA PAGE1U OF Zl 23 23 23 23 23 23 23 Zl 23 23 23 23 23 23 23 23 23 23 23 23 23 23 23 Zl 23 23 TITLE HAZELTON TOWNSHIP MID0LE3URY T O W N S H I P NEW HAVEN T O W N S H I P OWOSSO T O W N S H I P PERRY TOWNSHIP RUSH TOWNSHIP SCIOTA TOWNSHIP SHIAWASSEE T O W N S H I P VENICE TOWNSHIP VERNON TOWNSHIP WCODHULL TOWNSHIP AKRON TCWNSHIP ALMER TOWNSHIP ELMWOOD T O W N S H I P INDIANFIELDS T O W N S H I P TUSCOLA TOWNSHIP WATERTOWN T O W N S H I P W E L L S TOWNSHIP BLOOMINGDALE T O W N S H I P COVERT TOWNSHIP ANTIOCH T O W N S H I P BOON T O W N S H I P CLAM LAKE T O W N S H I P HARING TOWNSHIP HENDERSON TOWNSHIP SLAGLE TOWNSHIP S C U T H 8RANCH TOWNSHIP STATE = 23: 855 RECORDS TREASURY ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE THE TEST PAGE112 05/23/78 A : ;j; ^ p A R T M ENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 24 CARLTON COUNTY 24 CLEARWATER C O U N T Y 24 KANABEC COUNTY 24 KOOCHICHING COUNTY 24 LAKE OF THE WOODS C O U N T Y 24 MORRISON C O U N T Y 24 ROSEAU COUNTY 24 ST L O U I S C O U N T Y 24 TODD COUNTY 24 WINONA COUNTY 24 AITKIN VILLAGE 24 TAMARACK V I L L A G E 24 CALLAWAY V I L L A G E 24 OGEMA VILLAGL 24 WOLF LAKE V I L L A G E 24 BEMIDJI CITY 24 F U N K L E Y VILLAGE 24 KELLIHER V I L L A G E 24 TURTLE RIVER V I L L A G E 24 8ARNUM VILLAGE 24 CARLTON VILLAGE 24 CLOQUET CITY 24 CROMWELL V I L L A G E 24 KETTLE RIVER V I L L A G E 24 MOOSE LAKE V I L L A G E 24 SCANLON VILLAGE 24 THOMSON VILLAGE 24 WRENSHALL CITY 24 WRIGHT VILLAGE 24 BACKUS VILLAGE 24 BOY RIVER V I L L A G E 24 CASS LAKE VILLAGE 24 PILLAGER V I L L A G E 24 8AGLEY VILLAGE 24 CLEARBROOK V I L L A G E 24 GCNVICK V I L L A G E 24 LEONARD VILLAGE 24 SHEVLIN VILLAGE 24 CROSBY VILLAGE 24 FIFTY LAKES VILLAGE 24 AKELEY VILLAGE 24 PARK RAPIDS V I L L A G E 24 BCVEY VILLAGE 24 CALUMET VILLAGE 24 CGLERAINE V I L L A G E 24 NASHWAUK V I L L A G E TREASURY 0 5 / 2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA PAGE113 OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 TITLE ZEMPLE VIL L A G E G R A S S T O N V ILLA GE MORA VILLA GE O G I L V I E VI LLAG QUAMBA VIL LAGE BIG FALLS VILL AGE MIZPAH VIL L A G E N C R T H O M E V ILLA GE B A U D E T T E V ILLA GE BUCKMAN VI LLAG E E L M D A L E VI LLAG E F L E N S B U R G VILL AGE HARDING VI LLAG E H I L L M A N VI LLAG E L A S T R U P VI LLAG r RANDALL VI LLAG E S O B I E S K I V ILLA GE ASKOV VI-L AGE DENHAM VIL LAGE F I N L A Y S O N VILL AGE H E N R I E T T E VILL AGE K E R R I C K VI LLAG E PINE CITY VILL AGE SANDSTONE VILL AGE S T U R G E O N L AKE V I L L A G E WILLOW FIV ER V ILLAGE H A T F I E L D V ILLA GE MCRRISTOWN VIL LAGE BAOGER VIL L A G E STRATHCONA VIL LAGE AURORA VIL L A G E B A B B I T T VI LLAG E BIWABIK CI TY B R O O K S T O N VILL AGE BUHL VILLA GE C H I S H O L M C ITY COOK VILLA ELY CITY E V E L E T H CI TY FLCODWOCD VILLAGE F R A N K L I N V ILLAGE G I L B E R T CI TY HIBBING VI L L A G E HCYT LAKES V I L L A G E IRON JUNCT ION V I L L A G E KINNEY VIL LAGE TREASURY TEST PAGE114 05/2 3/78 AT 31:25 U.S. DEPARTMENT TDCACIIDV OF THE DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 TITLE LEONIDAS CITY MCKINLEY VILLAGE MEAOOWLANDS VILLAGE PROCTOR VILLAGE TOWER CITY VIRGINIA WINTON VILLAGE FREEPCRT VILLAGE HOLDINGFDRD VILLAGE NEW MUNICH VILLAGE RICHMOND VILLAGE ROSCOE VILLAGE ST ANTHONY VILLAGE ST CLOUD CITY ST ROSA VILLAGE SAUK CENTRE CITY BROWERVILLE CITY ALTURA VILLAGE MINNESOTA CITY VILLAGE RCLLINGSTONE VILLAGE STOCKTON VILLAGE UTICA VILLAGE WINONA CITY WAVERLY VILLAGE BALL BLUFF TOWNSHIP CORNISH TOWNSHIP FLEMING TOWNSHIP IDUN TOWNSHIP KIMBERLY TOWNSHIP LAKESIDE TOWNSHIP LEE TOWNSHIP LOGAN TOWNSHIP MACVILLE TOWNSHIP MALMO TOWNSHIP PLINY TOWNSHIP RICE RIVER TOWNSHIP SALO TOWNSHIP SEAVEY TOWNSHIP SPENCER TOWNSHIP TURNER TOWNSHIP VEROON TOWNSHIP WHITE PINE TOWNSHIP WILLIAMS TOWNSHIP CALLAWAY TOWNSHIP MAPLE GROVE TOWNSHIP OSAGE TCWNSHIP TREASURY 05/23/76 AT 01:25 U.S. DEPARTMENT PAGE115 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 24 PINE POINT TOWNSHIP 24 RICEVILLE TOWNSHIP 24 RCUNO LAKE TOWNSHIP 24 SHELL LAKE TOWNSHIP 24 SPRING CREEK TOWNSHIP 24 BENVILLE TOWNSHIP 24 8UZZLE TOWNSHIP 24 CCRMANT TOWNSHIP 24 HAGALI TOWNSHIP 24 HAMRE TOWNSHIP 24 MINNIE TOWNSHIP 24 NEBISH TOWNSHIP 24 PCRT HOPE TOWNSHIP 24 RCOSEVELT TOWNSHIP 24 SHOTLEY TOWNSHIP 24 TAYLOR TWP 24 ATKINSON TOWNSHIP 24 AUTOMBA TOWNSHIP 24 BARNUM TOWNSHIP 24 BESEMAN TOWNSHIP 24 BLACKHOOF TOWNSHIP 24 HCLYOKE TOWNSHIP 24 KALEVALA TOWNSHIP 24 LAKEVIEW TOWNSHIP 24 MAHTOWA TOWNSHIP 24 MCOSE LAKE TOWNSHIP 24 SILVER TOWNSHIP 24 SKELTCN TOWNSHIP 24 SPLIT ROCK TOWNSHIP 24 THOMPSON TOWNSHIP 24 TWIN LAKES TOWNSHIP 24 WRENSHALL TOWNSHIP 24 PERCH LAKE TWP 24 BEULAH TOWNSHIP 24 BCY LAKE TOWNSHIP 24 DEERFIELD TOWNSHIP 24 GOULD TOWNSHIP 24 INGUADONA TOWNSHIP 24 LEECH LAKE TOWNSHIP 24 MCKINLEY TOWNSHIP 24 MEADOW BROOK TOWNSHIP 24 PINE LAKE TOWNSHIP 24 POPLAR TOWNSHIP 24 REMER TOWNSHIP 24 ROGERS TOWNSHIP 24 SHINGOBEE TOWNSHIP V TREASURY PAGEllb 05/23/78 A ^0s;:^pARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 24 THUNDER LAKE TOWNSHIP 24 BEAR CREEK TOWNSHIP 24 CLOVER TOWNSHIP 24 COPLEY TOWNSHIP 24 DUDLEY TOWNSHIP 24 EDDY TOWNSHIP 24 FALK TOWNSHIP 24 GREENWOOD T O W N S H I P 24 HANGAARD T O W N S H I P 24 HOLST TCWNSHIP 24 ITASCA TOWNSHIP 24 LA PRAIRIE T O W N S H I P 24 LEON TOWNSHIP 24 MINERVA TOWNSHIP 24 MOOSE CREEK TOWNSHIP 24 NORA TOWNSHIP 24 PINE LAKE TOWNSHIP 24 POPPLE TOWNSHIP 24 RICE TOWNSHIP 24 SHEVLIN TOWNSHIP 24 SINCLAIR T O W N S H I P 24 WINSOR TOWNSHIP 24 DEAN LAKE T O W N S H I P 24 LITTLE PINE TOWNSHIP 24 OAK LAWN T O W N S H I P 24 ROSS LAKE TOWNSHIP 24 TIMOTHY TOWNSHIP 24 BELVIOERE T O W N S H I P 24 GOODHUE TOWNSHIP 24 BADOURA TCWNSHIP 24 CROW WINS LAKE TWP 24 LAKE ALICE T O W N S H I P 24 LAKE EMMA T O W N S H I P 24 LAKE GEORGE TOWNSHIP 24 MANTRAP TOWNSHIP 24 ARDENHURST T O W N S H I P 24 BEARVILLE T O W N S H I P 24 BIGFORK T O W N S H I P 24 BLACKBERRY T O W N S H I P 24 FEELEY TOWNSHIP 24 GOOD HOPE T O W N S H I P 24 GOODLANO TOWNSHIP 24 KINGHURST T O W N S H I P 24 MAX TOWNSHIP 24 NCRE T O W N S H I P 24 SAND LAKE T O W N S H I P ^* 05/23/73 AT 31:25 U.S. DEPARTMENT PAGE117 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE<ST (ELIGIBLE STATE 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 2-4 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 TITLE SPANG TOWNSHIP STOKES TOWNSHIP THIRD RIVER TOWNSHIP ANN LAKE TOWNSHIP ARTHUR TOWNSHIP BRUNSWICK TOWNSHIP CCMFORT TOWNSHIP FCRD TOWNSHIP GRASS LAKE TOWNSHIP HAY BROOK TOWNSHIP HILLMAN TOWNSHIP KANABEC TOWNSHIP K M F E LAKE TOWNSHIP KROSCHEL TOWNSHIP PEACE TOWNSHIP POMROY TOWNSHIP SCUTH FORK TOWNSHIP 8EJ0U TOWNSHIP GREGORY TOWNSHIP HEIER TOWNSHIP LAKE GROVE TOWNSHIP OAKLANO TOWNSHIP AUGS8URG TOWNSHIP GRAND PLAIN TOWNSHIP MOYLAN TOWNSHIP VALLEY TOWNSHIP BUCKMAN TOWNSHIP BUH TOWNSHIP CLOUGH TOWNSHIP CULDRUM TOWNSHIP CUSHING TOWNSHIP HILLMAN TOWNSHIP LAKIN TOWNSHIP LEIGH TOWNSHIP RAIL PRAIRIE TOWNSHIP RICHARDSON TOWNSHIP SWANVILLE TOWNSHIP ADAMS TOWNSHIP BENNINGTON TOWNSHIP CLAYTON TOWNSHIP FRANKFORD TOWNSHIP GRAND MEADOW TOWNSHIP LOOI TOWNSHIP MARSHALL TOWNSHIP PLEASANT VALLEY TWP CLOVER LEAF TOWNSHIP GOVERNMENTS) 05/23/78 AT 3 1 : 2 5 ^ ^ ^ op ^ DISTRESSED AREA ELIGIBILITY TE«ST (ELIGIBLE GOVERNMENTS) STATE 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 24 TITLE GOODRIDGE TOWNSHIP HIGHLANDING TOWNSHIP SILVERTON TOWNSHIP BROOK PARK TOWNSHIP OANFORTH TOWNSHIP HINCKLEY TOWNSHIP KERRICK TOWNSHIP MISSION CREEK TOWNSHIP NEW DOSEY TOWNSHIP NICKERSON TOWNSHIP NORMAN TOWNSHIP STURGEON LAKE TOWNSHIP AETNA TOWNSHIP ALTONA TOWNSHIP ELMER TOWNSHIP ROCK TOWNSHIP GERVAIS TOWNSHIP LAMBERT TOWNSHIP LOUISVILLE TOWNSHIP WYLIE TOWNSHIP MCRRISTOWN TOWNSHIP NCRTHFIELD TOWNSHIP SHIELDSVILLE TOWNSHIP BARNETT TOWNSHIP BARTO TOWNSHIP DIETER TOWNSHIP ENSTROM TOWNSHIP HEREIM TOWNSHIP LINO TOWNSHIP MICKINOCK TOWNSHIP MOOSE TOWNSHIP PCPLAR GROVE TOWNSHIP REINE TOWNSHIP SKAGEN TOWNSHIP STAFFORD TOWNSHIP STOKES TOWNSHIP ALANGO TOWNSHIP ALBORN TOWNSHIP ALDEN TOWNSHIP ANGORA TOWNSHIP ARROWHEAD TOWNSHIP AULT TOWNSHIP BASSETT TOWNSHIP BIWABIK TOWNSHIP BREITUNG TOWNSHIP 8REVAT0R TOWNSHIP ^ ^ PAGEU8 05/23/78 AT 01:25 U.S. DEPARTMENT PAGE119 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 24 CANOSIA TOWNSHIP 24 CEDAR VALLEY TOWNSHIP 24 CHERRY TOWNSHIP 24 CCLVIN TOWNSHIP 24 COTTON TOWNSHIP 24 CULVER TOWNSHIP 24 DULUTH TOWNSHIP 24 ELLSBURG TOWNSHIP 24 ELMER TOWNSHIP 24 EMBARRASS TOWNSHIP 24 FAIRBANKS TOWNSHIP 24 FIELD TOWNSHIP 24 FINE LAKES TOWNSHIP 24 FLOOOWOCD TOWNSHIP 24 GNESEN TOWNSHIP 24 HALOEN TOWNSHIP 24 INDUSTRIAL TOWNSHIP 24 KELSEY TOWNSHIP 24 KUGLER TOWNSHIP 24 LAKEWOOO TOWNSHIP 24 LAVELL TOWNSHIP 24 LINDEN GROVE TOWNSHIP 24 MCDAVITT TOWNSHIP 24 MEADOWLANDS TOWNSHIP 24 MIDWAY TOWNSHIP 24 MISSABE MOUNTAIN TWP 24 MORCOM TOWNSHIP 24 MORSE TOWNSHIP 24 NESS TOWNSHIP 24 NEW INOEPENOENCE TWP 24 NORMANNA TOWNSHIP 24 NCRTHLAND TOWNSHIP 24 OWENS TOWNSHIP 24 PAYNE TOWNSHIP 24 PIKE TOWNSHIP 24 PCRTAGE TOWNSHIP 24 PRAIRIE LAKE TOWNSHIP 24 RICE LAKE TOWNSHIP 24 SANDY TOWNSHIP 24 SOLWAY TOWNSHIP 24 STONEY BROOK TOWNSHIP 24 STUNTZ TOWN 24 STURGEON TOWNSHIP 24 TOIVOLA TOWNSHIP 24 VAN BUREN TOWNSHIP 24 VERMILION LAKE TOWNSHIP TREASURY PAGE120 05/23/78 A T n : ^ ^ ^ ^ Qf DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 24 WAASA TCWNSHIP 24 WHITE TCWNSHIP 24 WILLOW VALLEY TOWNSHIP 24 ASHLEY TOWNSHIP 24 CROW LAKE TOWNSHIP 24 KRAIN TOWNSHIP 24 RCCKVILLE TOWNSHIP 24 BERTHA TOWNSHIP 24 BIRCHDALL TOWNSHIP 24 BRUCE TOWNSHIP 24 EAGLE VALLEY TOWNSHIP 24 FAWN LAKE TOWNSHIP 24 GERMANIA TOWNSHIP 24 LESLIE TOWNSHIP 24 MORAN TOWNSHIP 24 REYNOLDS TOWNSHIP 24 OFESBACH TOWNSHIP 24 ELBA TCWNSHIP 24 FREMONT TOWNSHIP 24 HART TOWNSHIP 24 HILLSDALE TOWNSHIP 24 MOUNT VERNON TOWNSHIP 24 PLEASANT HILL TOWNSHIP 24 RCLLINGSTONE TOWNSHIP 24 ST CHARLES TOWNSHIP 24 SARATOGA TOWNSHIP 24 UTICA TOWNSHIP 24 WISCOY TOWNSHIP STATE = 24: 396 RECORDS m TREASlJRY 05/23/78 AT 01:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 25 ADAMS COUNTY 25 ALCORN COUNTY 25 AMITE COUNTY 25 ATTALA COUNTY 25 BENTON COUNTY 25 BOLIVAR COUNTY 25 CALHOUN COUNTY 25 CARROLL COUNTY 25 CHICKASAW COUNTY 25 CHOCTAW COUNTY 25 CCAHOMA COUNTY 25 COPIAH COUNTY 25 FRANKLIN COUNTY 25 GEORGE COUNTY 25 GREENE COUNTY 25 GRENADA COUNTY 25 HOLMES COUNTY 25 HUMPHREYS COUNTY 25 JASPER COUNTY 25 JEFFERSON COUNTY 25 JEFFERSON DAVIS COUNTY 25 JCNES COUNTY 25 KEMPER COUNTY 25 LAUDERDALE COUNTY 25 LAWRENCE COUNTY 25 LEFLORE COUNTY 25 LINCOLN COUNTY 25 MADISON COUNTY 25 MARION COUNTY 25 MONROE COUNTY 25 MONTGOMERY COUNTY 25 NEWTON COUNTY 25 NCXUBEE COUNTY 25 PANOLA COUNTY 25 PEARL RIVER COUNTY 25 PIKE COUNTY 25 QUITMAN COUNTY 25 SHARKEY COUNTY 25 SIMPSON COUNTY 25 SUNFLOWER COUNTY 25 TALLAHATCHIE COUNTY 25 TATE COUNTY 25 TISHOMINGO COUNTY 25 TUNICA COUNTY 25 WALTHALL COUNTY 25 WARREN COUNTY PAGE121 TREASURY PAG El 22 05/23/78 A : ^^ ^pARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 25 WASHINGTON COUNTY 25 WAYNE COUNTY 25 WILKINSON COUNTY 25 WINSTON COUNTY 25 YALOBUSHA COUNTY 25 YAZOO COUNTY 25 NATCHEZ CITY 25 CORINTH CITY 25 KOSSUTH VILLAGE 25 RIENZI TOWN 25 GLOSTER TOWN 25 LIBERTY TOWN 25 ETHEL TOWN 25 KOSCIUSKO CITY 25 MCCOOL TOWN 25 SALLIS TOWN 25 ASHLAND TOWN 25 HICKORY FLAT VILLAGE 25 ALLIGATOR TOWN 25 BENOIT TOWN 25 BEULAH TOWN 25 BOYLE TOWN 25 CLEVELAND CITY 25 DUNCAN TOWN 25 GUNNISON TOWN 25 MERIGOLO TOWN 25 MOUND BAYOU TOWN 25 PACE TOWN 25 RCSEOALE CITY 25 SHAW TOWN 25 SHEL8Y CITY 25 WINSTONVILLE TOWN 25 BIG CREEK VILLAGE 25 BRUCE TOWN 25 CALHOUN CITY TOWN 25 DERMA TOWN 25 SLATE SPRINGS VILLAGE 25 VARDAMAN TOWN 25 HCULKA TOWN 25 HCUSTON CITY 25 OKOLONA CITY 25 WCOOLAND VILLAGE 25 ACKERMAN TOWN 25 WEIR TOWN 25 CLARKSOALE CITY 25 FRIARS POINT TOWN 05/23/76 AT 31:25 U.S. DEPARTMENT PAGE123 OF THE OISTRESSEO AREA ELIGIBILITY TEiST (ELIGIBLE GOVERNMENTS) STATE TITLE 25 JONESTOWN TOWN 25 LULA TOWN 25 LYON TOWN 25 BEAUREGARD VILLAGE 25 CRYSTAL SPRINGS CITY 25 GEORGETOWN TOWN 25 HAZLEHURST CITY 25 WESSON TOWN 25 BUDE TOWN 25 ROXIE TOWN 25 LUCEOALE TOWN 25 LEAKESVILLE TOWN 25 MCLAIN TOWN 25 GRENADA CITY 25 BAY ST LOUIS CITY 25 BILOXI CITY 25 CRUGER TOWN 25 OURANT TOWN 25 GCODMAN TOWN 25 LEXINGTON CITY 25 PICKENS TOWN 25 TCHULA TOWN 25 WEST TOWN 25 BELZONI CITY 25 LOUISE TOWN 25 SILVER CITY TOWN 25 BAY SPRINGS TOWN 25 HEIDEL8ERG TOWN 25 LOUIN TOWN 25 MCNTR05E TOWN 25 FAYETTE TOWN 25 BASSFIELD TOWN 25 PRENTISS TOWN 25 SCSO TOWN 25 OE KALB TOWN 25 SC003A TOWN 25 MERIDIAN CITY 25 MARION CITY 25 NEWHEBRON VILLAGE 25 GUNTOWN TOWN 25 GREENWOOD CITY 25 ITTA BENA TOWN 25 SIOON TOWN 25 MORGAN CITY TOWN 25 SCHLATER TOWN 25 BROOKHAVEN CITY TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 25 CANTON CITY 25 FLORA TOWN 25 C O L U M B I A CITY 25 HCLLY S P R I N G S CITY 25 ABERDEEN CITY 25 AMORY CITY 25 GATTMAN V I L L A G E 25 SMITHVILLE TOWN 25 DUCK HILL TOWN 25 KILMICHAEL TOWN 25 WINONA CITY 25 D E C A T U R TOWN 25 HICKORY TOWN 25 NEWTON CITY 25 B R O O K S V I L L E TOWN 25 MACON CITY 25 SHUGUALA* TOWN 25 BATESVILLE CITY 25 COURTLAND VILLAGE 25 POPE VILLAGE 25 S A R D I S TOWN 25 PICAYUNE CITY 25 P C P L A R V I L L E CITY 25 MCCCMB CITY 25 MAGNOLIA C I T Y 25 OSYKA TOWN 25 SUMMIT TOWN 25 LAMBERT TOWN 25 M A R K S CITY 25 S L E D G E TOWN 25 F A L C O N TOWN 25 ANGUILLA T O W N 25 CARY TOWN 25 RCLLING FORK TOWN 25 BRAXTON V I L L A G E 25 DLO TCWN 25 D C D D S V I L L E TOWN 25 DREW CITY 25 INDIANOLA C I T Y 25 INVERNESS TOWN 25 MCORHEAD TOWN 25 RULEVILLE TOWN 25 SUNFLOWER TOWN 25 CHARLESTON CITY 25 GLENDORA VILLAGE 9^ <;ilMWFB TflUN PAGE124 OF THE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED (ELIGIBLE GOVERNMENTS) STATE TITLE 25 TUTWILER TOWN 25 WEB8 TOWN 25 COLDWATER TOWN 25 SENATCBIA CITY 25 IUKA CITY 25 PADEN VILLAGE 25 GOLDEN VILLAGE 25 TUNICA TOWN 25 MYRTLE TOWN 25 NEW ALBANY C I T Y 25 VICKSBURG CITY 25 ARCOLA TOWN 25 GREENVILLE CITY 25 HOLLANOALE C I T Y 25 LELAND CITY 25 WAYNESBORO C I T Y 25 W C O O V I L L E TOWN 25 LCUISVILLE CITY 25 NCXAPATER TOwN 25 C O F F E E V I L L E TOWN 25 WATER VALLEY C I T Y 25 TILLATOBA V I L L A G E 25 8ENT0NIA TOWN 25 EDEN VILLAGE 25 SATARTIA V I L L A G E 25 YAZOO CITY C I T Y STATE = 25: 210 RECORDS AREA PAGE125 OF THE TREASURY ELIGIBILITY TEST PAGE12G 05/23/78 A ^ 3 : s ; ^pARTMENT OF THE OISTRESSEO AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 2b ATCHISCN COUNTY 2b BARTON COUNTY 2b BUCHANAN COUNTY 2b CARROLL COUNTY 2b CLARK COUNTY 2b COOPER COUNTY 2b DAVIESS COUNTY 2b DOUGLAS COUNTY 2b GRUNDY COUNTY 2b HENRY COUNTY 2b HCWARD COUNTY 2b JACKSON COUNTY 2b JASPER COUNTY 2b JOHNSON COUNTY 2b KNOX COUNTY 2b LACLEDE COUNTY 2b LINN COUNTY 2b LIVINGSTON COUNTY 2b MACON COUNTY 2b MAOISON COUNTY 2b MARIES COUNTY 2b MARION COUNTY 2b MERCER COUNTY 2b MISSISSIPPI COUNTY 2b MONITEAU COUNTY 2b MONROE COUNTY 2b OREGON COUNTY 2b PEMISCOT COUNTY 2b PETTIS COUNTY 2b PIKE COUNTY 2b PULASKI COUNTY 2b RANDOLPH COUNTY 2b RIPLEY COUNTY 2b ST FRANCOIS COUNTY 2b SCHUYLER COUNTY 2b SHANNON COUNTY 2b SULLIVAN COUNTY 2b TEXAS COUNTY 2b WASHINGTON COUNTY 2b RCCKPORT CITY 2b TARKIO CITY 2b WATSON TOWN 2b WESTBORO TOWN 2S FARBER CITY 2b BURGESS TOWN 2b GOLDEN CITY CITY TREASURY 05/23/78 AT 01:25 U.S. DEPARTMENT PAGE127 OF THE DISTRESSED AREA ELIGIBILITY FEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 2b LIBERAL CITY 2b MINDENMINES CITY 2b AMORET CITY 2b FOSTER TOWN 2b HUME TOWN 2b MERWIN TOWN 2b PASSAIC TOWN 2b LUTESVILLE CITY 26 SEDGEWICKVILLE TOWN Zb ZALMA TOWN 2b AGENCY VILLAGE 2b OE KALB TOWN 2b RUSHVILLE TOWN 2b ST JOSEPH CITY 2b NEELYVILLE TOWN 2b POPLAR BLUFF CITY 2b BCGARO TOWN 2b BOSWORTH CITY 2b CARROLLTON TOWN 2b WAKENDA TOWN Z6 ELLSINORE TOWN 2b ELOORAOO SPRINGS CITY 2b BRUNSWICK CITY 2b DALTON TOWN 2b ROTHVILLE TOWN 2b ALEXANDRIA TOWN Zb KAHOKA CITY 2b LURAY TOWN 2b WAYLAND CITY 2b WYACONDA CITY 2b BOONVILLE CITY 2b BUNCETON CITY 2b OTTERVILLE CITY 2b PILOT GROVE CITY 2b WOOLDRIDGE TOWN 2b ALTAMONT TOWN 2b COFFEY CITY 2b JAMESON TOWN Zi> LOCK SPRING VILLAGE Z6 PATTONSOURG CITY 2b AVA CITY Zt CAMPBELL CITY 2b HORNERSVILLE CITY 2b KENNETT CITY 2b SENATH CITY 2b BERGER CITY TREASURY 05/23/78 A ;j;S^pART„eNT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 2b NEW HAVEN CITY 2b WASHINGTON CITY 2b BLAND CITY 2b GASCONADE CITY 2b OWENSVILLE CITY 2b ROSEBUD CITY 2b BRIMSON TOWN 2b GALT CITY Zb SPICKARDSVILLE C I T Y 2b TINDALL TOWN 2b TRENTON CITY 2b CALHOUN CITY 2b WINDSOR CITY 2b ARMSTRONG CITY 2b FAYETTE CITY 2b FRANKLIN TOWN 2b KANSAS CITY 2b SUGAR CREEK CITY 2b SIBLEY TOWN 2b TARSNEY L A K E S TCWN 2b LCNEJACK TOWN 2b ASBURY TOWN 26 AVILLE TOWN 2b CARTHAGE CITY 2b JASPER CITY 2b JOPLIN CITY 2b ORONOGO CITY 2b PURCELL CITY 2b WACO TOWN 2b WEBB CITY CITY 2b DUENWEG CITY 2b DUQUESNE VILLAGE 2b BROOKLYN H E I G H T S VILLAGE: 2b FIDELITY TOWN 2b CENTERVIEW TOWN Zb HOLDEN CITY 2b KINGSVILLE TOWN 2b KNOB NOSTER CITY Zb LA TOUR TOWN 2b LEETON CITY 2b WARRENSBURG CITY 2b BARING TOWN 2b KNOX CITY CITY 2b NEWARK TOWN Zb NOVELTY TOWN 2b CONWAY CITY TREASURY 05/2 3/78 AT 31 :25 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE TITLE 26 L E B A N O N CITY 2b P H I L L I P S 3 U R G TOWN 2b F R E I S T A T T TOWN 2b MILLER CITY Zb PIERCE CITY CITY 2b VERONA TOWN 2b HALLTOWN V I L L A G E 26 HC8ERG V I L L A G E 2b CANTON CITY 2b LA B E L L E C I T Y Zb LA GRANGE CITY 26 BROOKFIELD CITY 2b . B U C K L I N CITY 2b L A C L E D E CITY 2b L I N N E U S CITY 26 MARCELINE CITY 2b P U R D I N TOWN 2b CHULA CITY 2b LUDLOW TOWN 2b ANDERSON CITY 2b S C U T H WEST C I T Y TOWN 2b ATLANTA CITY 2b BEVIER CITY 2b C A L L A O CITY 2b E L M E R TOWN 2b MACON CITY Zb NEW CAMBRIA TOWN 2b SOUTH G I F F O R Q TOWN Zb FREDERICKTOWN CITY 2b MARQUAND TOWN 2b C C 8 A L T CITY V I L L A G E 2b JUNCTION C I T Y V I L L A G E 2b VIENNA TOWN 2b PRINCETON C I T Y Zb CHARLESTON C I T Y 2b EAST PRAIRIE C I T Y 2b WYATT CITY 2b ...LSON CITY TOWN 2b ANNISTON TOWN 2b CALIFORNIA C I T Y 2b CLARKS8URG CITY 2b JAMESTOWN C I T Y 2b L U P U S TOWN Zb TIPTON CITY 2b MADISON CITY 2b S T O U T S V I L L E TOWN PAGE129 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEIST 05/23/78 AT u ^s;:^pARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 26 SYRACUSE TOWN 26 VERSAILLES C I T Y 2b ARKOE TOWN 26 BURLINGTON J U N C T I O N C I T Y 26 CLEARMGNT TOWN 26 CLYDE TCWN 26 CONCEPTION J U N C T I O N TOWN 26 ELMO TOWN 26 GUILFORD TOWN 26 HOPKINS CITY 26 PARNELL CITY 26 PICKERING TCWN 26 QUITMAN TOWN 26 RAVENWOCD CITY 26 SKIDMORE CITY 26 ALTON CITY 26 KCSHKONONG CITY 26 THAYER CITY 26 CHAMOIS CITY 26 META CITY 26 CARUTHERSVILLE C I T Y 26 HAYTI CITY 26 HOLLAND TOWN 26 STEELE CITY 26 WARDELL TOWN 26 COOTER TOWN 26 HCMESTOWN CITY 2b BRAGG CITY TOWN 2b HAYTI HEIGHTS CITY 2b PASCOLA TOWN 2b NORTH WARDELL V I L L A G E 2b G R E E N RIDGE TOWN 2b HLUSTONIA CITY 2b LA MONTE C I T Y Zb SEDALIA CITY Zb SMITHTON CITY 2b HUGHESVILLE V I L L A G E Zb BOWLING GREEN CITY 2b CURRYVILLE TOWN 2b FRANKFORD CITY 2b LOUISIANA CITY 2b ANNADA TOWN 2b ECLIA VILLAGE STATE = 2b: 227 RECORDS TREASURY 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T PAGE131 OF THE DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 2b PAYNESVILLE TOWN STATE = 2b: 1 RECOROS TREASURY PAGE132 05/23/78 A Jj; ;2 0t %ARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 2b 2b 2b 2b 2b 2b 2b 2b 2b 2b 2b 2b 2b 2b 2b 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 TITLE CROCKER CITY RICHLAND CITY ST ROEERT CITY CLIFTON HILL TOWN HUNTSVILLE CITY JACKSONVILLE TOWN RENICK TOWN DCNIPHAN CITY NAYLOR CITY BISMARCK CITY BCNNE TERRE CITY DESLOGE CITY ELVINS CITY ESTHER CITY FAIRVIEW ACRES VILLAGE FARMINGTON CITY FLAT RIVER CITY HIGHLEY HEIGHTS VILLAGE RIVERMINES TOWN LEAOINGTON VILLAGE LEADWOOD CITY BELLA VILLA CITY BEL RIDGE VILLAGE BERKELEY CITY BRECKENRIDGE HILLS VILL BRIDGETON TERRACE CITY COOL VALLEY VILLAGE DELLWOOD CITY EDMUNDSON VILLAGE ELLISVILLE CITY FERGUSON CITY HANLEY HILLS VILLAGE HAZELWOOD CITY HILLSDALE VILLAGE JENNINGS CITY KINLOCH CITY MAPLEWOCD CITY NCRMANDY TOWN OVERLAND CITY PAGEDALE CITY PINE LAWN CITY RIVERVIEW VILLAGE RCCK HILL CITY ST ANN CITY ST JOHN CITY SCHUERMANN H E I G H T S VILLAGE TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE133 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE STATE 26 26 26 26 26 26 26 26 26 26 26 26 26 26 2b 2b Zb Zb 2b 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 2b TITLE TIMES BEACH CITY VALLEY PARK CITY VELDA VILLAG E VINITA PARK CITY WELLSTON CIT Y WINCHESTER C ITY WCODSON TERR ACE CITY ST LOUIS CIT Y GRAND PASS T OWN MARSHALL CIT Y MOUNT LEONAR D TOWN SWEET SPRING S CITY DOWNING CITY GLENWOOD VIL LAGE LANCASTER CI TY QUEEN CITY C ITY BIRCH TREE C ITY EMINENCE CIT Y WINONA CITY CLARENCE CIT Y GREENCASTLE CITY GREEN CITY C ITY HARRIS TOWN HUMPHREYS TO WN MILAN CITY NEWTOWN TOWN OSGOOD TOWN HCUSTON CITY LICKING CITY RAYMONDVILLE TOWN CALEDONIA TO WN IRONDALE CIT Y MINERAL POIN T TOWN POTOSI CITY PIEDMONT CIT MILL SPRING VILLAGE SEYMOUR CITY ALLENDALE TO WN DENVER TOWN GRANT CITY WORTH TOWN GOLDEN CITY TOWNSHIP NASHVILLE TO WNSHIP NEWPORT TCWN SHIP OZARK TOWNSH IP CARROLLTON T OWNSHIP GOVERNMENTS) 05/23/78 A ; j J : ^ p A R T H E N T QF DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 2b COMBS TOWNSHIP 2b EGYPT TOWNSHIP 2b EUGENE TOWNSHIP 2b HILL TOWNSHIP 2b HURRICANE TOWNSHIP 2b MIAMI TOWNSHIP 2b RIDGE TOWNSHIP 2b RCCKFORD T O W N S H I P 2b STOKES MOUND T O W N S H I P 2b SUGARTREE T O W N S H I P 2b TROTTER TOWNSHIP 2b VAN HORN T O W N S H I P 2b WAKENDA TOWNSHIP 26 BEE BRANCH T O W N S H I P 26 BRUNSWICK TOWNSHIP 26 CLARK TOWNSHIP 26 CCCKRELL T O W N S H I P 26 MISSOURI T O W N S H I P 26 BENTON TOWNSHIP 26 HARRISON T O W N S H I P 26 JACKSON TOWNSHIP 26 JEFFERSON T O W N S H I P 26 LIBERTY TOWNSHIP 2b LINCOLN TOWNSHIP 2b MARION TOWNSHIP 2b SALEM TOWNSHIP 2b SHERIDAN T O W N S H I P 2b WASHINGTON T O W N S H I P 26 CLAY TOWNSHIP 26 FREEBORN T O W N S H I P 26 INDEPENDENCE TOWNSHIP 26 SALEM TOWNSHIP 26 FRANKLIN T O W N S H I P 26 JEFFERSON T O W N S H I P 26 LIBERTY TOWNSHIP 26 LINCOLN TCWNSHIP 26 MARION TOWNSHIP 26 MYERS TOWNSHIP 26 TAYLOR TOWNSHIP 26 TRENTON TOWNSHIP 26 BIG CREEK T O W N S H I P 26 OSAGE TOWNSHIP 26 SHAWNEE T O W N S H I P 26 TEBG TOWNSHIP 26 WHITE OAK T O W N S H I P 26 W I N O S O R TOWNSHIP THE TREASURY PAGE135 0 5 / 2 3 / 7 8 AT 0 1 : 2 5 U.S. D E P A R T M E N T OF THE D I S T R E S S E D AREA (ELIGIBLE STATE 26 26 26 26 26 26 2b 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 26 TREASURY ELIGIBILITY GOVERNMENTS) TITLE BENTON TOWNS HIP BROOKFIELO T O W N S H I P ENTERPRISE T O W N S H I P GRANTSVILLE TOWNSHIP J A C K S O N TOWN SHIP JEFFERSON TO WNSHIP L C C U S T CREEK T O W N S H I P MARCELINE TO WNSHIP BLUE MOUND T OWNSHIP CREAM RIDGE T O W N S H I P GRAND RIVER T O W N S H I P JACKSCN TCWN SHIP MEDICINE TOW NSHIP MONROE TOWNS HIP HARRISON TOW NSHI P MAOISON TOWN SHIP MARION TOWNS HIP MEDICINE TOW NSHIP MORGAN TOWNS HIP SOMERSET TOW NSHIP A T C H I S O N TOW NSHIP GRANT TOWNSH IP G R E E N TOWNSH IP H O P K I N S TOWN SHIP INDEPENDENCE T O W N S H I P J A C K S O N TOWN SHIP JEFFERSON TO WNSHIP MCWROE TOWNS HIP UNION TOWNSH IP WASHINGTON T O W N S H I P BOWMAN TOWNS HIP BUCHANAN TOW NSHIP CLAY TOWNSHI P JACKSON TOWN SHIP LIBERTY TOWN SHIP MORRIS TOWNS HIP PENN TOWNSHI P PLEASANT HIL L T O W N S H I P POLK TOWNSHI P TAYLOR TOWNS HIP UNION TOWNSH IP 800NE TCWNSH IP BURDINE TOWN SHIP CARROLL TOWN SHIP CASS TOWNSHI P C L I N T O N TOWN SHIP TEST PAGE136 05/23/78 A ;/s; s2 5 D EpARTMENT OF THE DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE 26 26 26 26 26 2b 2b 26 26 26 26 26 TITLE CURRENT TOWNSHIP DATE TOWNSHIP JACKSON TOWNSHIP LYNCH TOWNSHIP MORRIS TOWNSHIP OZARK TOWNSHIP PIERCE TOWNSHIP PINEY TOWNSHIP ROUBIDOUX TOWNSHIP SARGENT TOWNSHIP SHERRILL T O W N S H I P UPTON TOWNSHIP STATE = 2b: 19b RECORDS TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 27 27 27 Z7 27 27 27 27 27 27 27 27 27 27 27 27 27 27 27 27 Z7 27 27 27 27 27 27 27 27 27 27 TITLE CARTER COUNTY DEER L0D3E COUNTY GARFIELD COUNTY GLACIER COUNTY GRANITE COUNTY LINCOLN COUNTY MEAGHER COUNTY PETROLEUM COUNTY RAVALLI COUNTY SILVER BOW COUNTY EKALAKA TOWN ANACONOA CITY DRUMMOND TOWN PHILIPSBURG CITY BCULDER TOWN ST IGNATIUS TOWN EUREKA TOWN LIBBY CITY TROY TOWN REXFORD TOWN ENNIS TOWN WHITE SULPHUR SPRGS CITY WINNETT TOWN BROADUS TOWN DARBY TOWN HAMILTON CITY STEVENSVILLE) TOWN HOT SPRINGS TOWN BUTTE CITY WALKERVILLE CITY JUOITH GAP CITY STATE = 27: 31 RECORDS TREASURY 05/23/78 A .« oc Jj;:^pARTM£NT PAGE138 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 28 BLAINE COUNTY 28 BCONE COUNTY 28 BURT COUNTY 26 CHERRY COUNTY 28 GRANT COUNTY 28 GREELEY COUNTY 28 JOHNSON COUNTY 28 KEYA PAHA COUNTY 28 KNOX COUNTY 28 MCPHERSON COUNTY 28 RICHAROSON COUNTY 28 SIOUX COUNTY 28 THURSTON COUNTY 28 WAYNE COUNTY 28 WHEELER COUNTY 28 PR05SER VILLAGE 28 BREWSTER VILLAGE 28 OUNNING VILLAGE 28 PETERSBURG VILLAGE 28 PRIMROSE VILLAGE 28 CRAIG VILLAGE 28 OAKLAND CITY 28 GARRISON VILLAGE 28 OCTAVIA VILLAGE 28 SURPRISE VILLAGE 28 ALVO VILLAGE 28 AVOCA VILLAGE 28 GREENWOOD VILLAGE 28 OOERT V I L L A G E 28 CCDY VILLAGE 28 KILGORE VILLAGE 28 MERRIMAN VILLAGE 28 WOOD LAKE VILLAGE 28 ANSLEY VILLAGE 28 DIXON VILLAGE 28 BLUE SPRINGS VILLAGE 28 GREELEY CENTER VILLAGE 28 SCOTIA VILLAGE 28 SPALOING VILLAGE 28 CAIRO VILLAGE 28 CUSHING VILLAGE 28 DILLER VILLAGE 28 HARBINE VILLAGE 28 STEELE CITY VILLAGE 28 CRAB ORCHARD VILLAGE 26 BURTON VILLAGE TREASURY 05/23/78 AT 01:25 U.S. DEPARTMENT PAGE139 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 28 CROFTON VILLAGE 28 VERDIGRE VILLAGE 28 GANDY- VILLAGE 28 BROADWATER CITY 28 GENOA CITY 28 BROCK VILLAGE 28 8R0WNVILLE VILLAGE 28 JULIAN VILLAGE 28 NEMAHA VILLAGE 28 PERU CITY 28 DUBOIS VILLAGE 28 STEINAUER VILLAGE 28 ATLANTA VILLAGE 26 HADAR VILLAGE 28 MCLEAN VILLAGE 28 PIERCE CITY 28 BARAOA VILLAGE 28 PRESTON VILLAGE 28 RULC CITY 28 SALEM VILLAGE 28 SHUBERT VILLAGE 28 STELLA VILLAGE 28 VALPARAISO VILLAGE 28 8EE VILLAGE 28 TAMORA VILLAGE 28 HARRISON VILLAGE 28 PENDER VILLAGE 28 ROSALIE VILLAGE 28 THURSTON VILLAGE 28 WALTHILL VILLAGE 28 WINNEBAGO VILLAGE 28 ARCADIA VILLAGE 28 ELYRIA VILLAGE 28 NORTH LOUP VILLAGE 28 HCSKINS VILLAGE 28 WAYNE CITY 28 GUIDE ROCK VILLAGE 28 BARTLETT VILLAGE 28 ERICSON VILLAGE 28 ARIZONA TOWNSHIP 28 CRAIG TOWNSHIP 28 DECATUR TOWNSHIP 28 LGGAN TOWNSHIP 28 OAKLAND TOWNSHIP 28 PERSHING TOWNSHIP 28 RIVERSIDE TOWNSHIP TREASURY 05/23/78 A J ^ 5 2 D 5 E p A R T M E N T OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE TITLE 28 SILVER CREEK TOWNSHIP 28 LINWOCC TCWNSHIP 28 OAK CREEK T O W N S H I P 28 PLUM CREEK TOWNSHIP 28 BISMARK TCWNSHIP 28 BLAINE TOWNSHIP 28 CUMING TOWNSHIP 28 ELKHORN TOWNSHIP 28 GARFIELD T O W N S H I P 28 GRANT TOWNSHIP 28 LCGAN TOWNSHIP 28 MONTEREY TOWNSHIP 28 NELIGH TOWNSHIP 28 SHERMAN TOWNSHIP 28 ALGERNON TOWNSHIP 28 ANSLEY TOWNSHIP 28 CLIFF TCWNSHIP 28 CCMSTOCK TOWNSHIP 28 DELIGHT TOWNSHIP 23 DOUGLAS GROVE TOWNSHIP 28 EAST CUSTER TOWNSHIP 28 LILLIAN TOWNSHIP 26 LOUP TOWNSHIP 28 RYNO TOWNSHIP 28 SPRING CREEK TOWNSHIP 28 VICTORIA T O W N S H I P 28 WESTERVILLE TCWNSHIP 26 CONCORD TOWNSHIP 28 LOGAN TOWNSHIP 28 BLUE SPRINGS T O W N S H I P 28 HOOKER TOWNSHIP 28 ISLAND GROVE TOWNSHIP 28 MIOLAND TOWNSHIP 28 RIVERSIOE TOWNSHIP 28 HARRISON T O W N S H I P 28 LAKE TOWNSHIP 28 MARTIN TOWNSHIP 28 MAYFIELD T O W N S H I P 28 CHAMBERS T O W N S H I P 28 CGLEMAN TOWNSHIP 28 FRANCIS TOWNSHIP 28 GREEN VALLEY TOWNSHIP Zd HCLT CREEK T O W N S H I P 28 STUART TOWNSHIP 28 ADOISON TOWNSHIP 28 BOHEMIA TOWNSHIP 05/23/78 AT 31:25 U.S. DEPARTMENT DISTRESSED OF THE TREASURY AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 28 CREIGHTON TOWNSHIP 28 DOLPHIN TOWNSHIP 26 DCWLING TOWNSHIP 28 EASTERN TOWNSHIP 28 FRANKFORT TOWNSHIP 28 HERRICK TOWNSHIP 28 HILL TOWNSHIP 28 JEFFERSON TOWNSHIP 28 LOGAN TOWNSHIP 28 PEORIA TOWNSHIP 28 RAYMOND TOWNSHIP 28 SPADE TOWNSHIP 28 SPARTA TOWNSHIP 28 VALLEY TOWNSHIP 28 VERDIGRE TOWNSHIP 28 WALNUT GROVE TOWNSHIP 28 WASHINGTON TOWNSHIP 28 WESTERN TOWNSHIP 28 GENOA TOWNSHIP 28 CHESTER TOWNSHIP 28 ANDERSON TOWNSHIP 28 BLACKBIRD TOWNSHIP 28 BRYAN TOWNSHIP 28 DAWES TOWNSHIP 28 FLOURNOY TOWNSHIP 28 MERRY TOWNSHIP 28 OMAHA TOWNSHIP 28 PENDER TOWNSHIP 28 PERRY TOWNSHIP 28 THAYER TOWNSHIP 28 WINNEBAGO TOWNSHIP 28 ARCADIA TOWNSHIP 28 NCRTH LOUP TOWNSHIP 28 GERANIUM TOWNSHIP ST ATE = 28: 172 RECORDS PAGE141 TUST PAGEU2 05/23/78 A ;/s;S^pARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 29 NYE COUNTY 29 WHITE PINE COUNTY 29 NORTH LAS VEGAS CITY 29 YERINGTON CITY 29 GA8BS CITY 29 LOVELOCK CITY 29 ELY CITY STATE = 29: 7 RECORDS TREASURY 05/2 3/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED 30 30 50 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 30 TITLE CCOS COUNTY BERLIN CITY MANCHESTER CITY NASHUA CITY CHATHAM TOWN CLARKSVILLE TOWN CCLEBROOK TOWN OUMMER TOWN ERROL TOWN GORHAM TOWN LANCASTER TOWN NORTHUMBERLAND TOWN STRATFORD TOWN EASTON TOWN LINCOLN TOWN LISBON TOWN LITTLETON TOWN ORFORD TOUN WOODSTOCK TOWN SUGAR HILL TOWN STATE = 30 TREASURY AREA ELIGIBILITY (ELIGIBLE STATE PAGE143 20 RECORDS GOVERNMENTS) TEST .,r ^« .OCL 05/23/78 A J/5;-^pARTM£NT PAGE144 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 31 ATLANTIC COUNTY 31 BERGEN COUNTY 51 CAMDEN COUNTY 31 CUMBERLAND COUNTY 31 ESSEX COUNTY 31 GLOUCESTER COUNTY 31 HUDSON COUNTY 51 MIDDLESEX COUNTY 31 MORRIS COUNTY 31 PASSAIC COUNTY 31 SALEM COUNTY 31 UNION COUNTY 31 WARREN COUNTY 31 ABSECON CITY 31 ATLANTIC CITY CITY 31 BRIGANTINE CITY 31 BUENA BOROUGH 31 CORBIN CITY CITY 31 EGG HARBOR CITY 31 ESTELL MANOR CITY 31 FOLSOM BOROUGH 51 HAMMONTON TOWN 31 MARGATE CITY 31 NCRTHFIELD CITY 31 PLEASANTVILLE CITY 31 ALLENDALE 30R0UGH 31 BERGENFIELD BOROUGH 31 BOGOTA BOROUGH 31 CARLSTADT 30R0UGH 31 CLOSTER 30R0UGH 31 CRESSKILL BOROUGH 31 DEMAREST BOROUGH 31 DUMONT BOROUGH 31 ELMWOOD PARK BOROUGH 31 EAST RUTHERFORD BOROUGH 31 EDGEWATER 80R0UGH 31 EFERSON BOROUGH 31 ENGLEWOOD CITY 31 FAIR LAWN 30R0UGH 31 FAIRVIEW BOROUGH 31 FRANKLIN LAKES BOROUGH 31 GARFIELD CITY 31 GLEN ROCK BOROUGH 31 HACKENSACK CITY 31 HARRINGTON PARK BOROUGH 31 HASBROUCK HEIGHTS BORO TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGEU5 OF THE DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 31 HAWORTH BOROUGH 31 HILLSDALE 30R0UGH 31 HC-HO-KUS BORO 31 LEONIA BOROUGH 31 LITTLE FERRY BOROUGH 31 LODI BOROUGH 31 MAYWOOD BOROUGH 31 MIDLAND PARK BOROUGH 31 MCNTVALE BOROUGH 31 MOONACHIE 30R0UGH 31 NEW MILFORD BOROUGH 31 NCRTH ARLINGTON BOROUGH 31 NORTHVALE 3CR0UGH 31 NORWOOD BOROUGH 31 OAKLAND 30R0UGH 31 ORADELL BOROUGH 31 PALISADES PARK BOROUGH 31 PARAMUS BOROUGH 31 RAMSEY BOROUGH 31 RIOGEFIELD BOROUGH 31 RIOGEFIELD PARK VILLAGE 31 RIDGEWGOD VILLAGE 31 RIVER EDGE BOROUGH 31 ROCKLEIGH HOROUGH 31 RUTHERFORD BOROUGH 31 TENAFLY BOROUGH 31 TETERE0R3 30R0UGH 31 WALDWICK BOROUGH 31 WALLINGTON BOROUGH 31 WESTWOOD BOROUGH 31 WOOD RIDGE BOROUGH 31 BEVERLY CITY 31 BURLINGTON CITY 31 FIEL0S3ORO BOROUGH 31 PALMYRA BOROUGH 31 PEMBERTON BOROUGH 31 RIVERTON BOROUGH 31 WRIGHTSTOWN BOROUGH 31 AUDUBON 30ROUGH 31 AUDUBON PARK BOROUGH 31 BARRINGTON 80R0UGH 31 BELLMAWR BOROUGH 31 BERLIN BOROUGH 31 BROOKLAWN 30R0UGH 31 CAMDEN CITY 31 CHESILHURST BOROUGH TREASURY PAGE14G 05/23/78 A J^ 1: ^PARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 31 COLLINGSWOOD BOROUGH 31 GIBBSBORO BOROUGH 31 GLOUCESTER CITY CITY 31 HADOONFIELD BOROUGH 31 HADDON HEIGHTS BOROUGH 31 HI-NELLA BOROUGH 31 LAWNS1DE BOROUGH 31 MAGNOLIA BOROUGH 31 MERCHANTVILLE BOROUGH 31 MCUNT EPHRAIM 30R0UGH 31 OAKLYN BOROUGH 31 PINE VALLEY BOROUGH 31 RUNNEMEDE 30R0UGH 31 STRATFORD 3QR0UGH 31 TAVISTOCK BOROUGH 31 WOOO LYNNE BOROUGH 31 CAPE MAY CITY 31 WILDWCOD CITY 31 WOODBINE BOROUGH 31 BRIDGETON CITY 31 MILLVILLE CITY 31 SHILOH BOROUGH 31 VINELAND CITY 31 BELLEVILLE TOWN 31 8L00MFIEL0 TOWN 31 EAST ORANGE CITY 31 IRVINGTCN TOWN 31 MCNTCLAIR TOWN 31 NEWARK CITY 31 ORANGE CITY 31 CLAYTON 30R0UGH 31 GLASSBORO 30R0UGH 31 NATIONAL PARK 30R0UGH 31 NEWFIELD BOROUGH 31 PAULSBORO BOROUGH 31 PITMAN BOROUGH 31 SWEDESBORC BOROUGH 31 WENCNAH 30R0UGH 31 WESTVILLE 30R0UGH 31 WOODBURY CITY 31 WOODBURY HEIGHTS BOROUGH 31 BAYONNE CITY 31 EAST NEWARK BOROUGH 31 GUTTEN3ERG TOWN 31 HARRISON TOWN 31 HOBOKEN CITY TREASURY 05/23/78 AT 0 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE STATE 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 PAGE147 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE JERSEY CITY CITY SECAUCUS TOWN UNIGN CITY CITY WEST NEW YORK TOWN GLEN GARDNER B O R O U G H LAMBERTVILLE C I T Y TRENTON C ITY CARTERET B O R O U G H DUNELLEN B O R O U G H HELMETTA B O R O U G H H I G H L A N D PARK 30R0UGH METUCHEN B O R O U G H MIDDLESEX 3 0 R 0 U G H NEW BRUNSWICK CITY PERTH AM30Y CITY SAYREVILLE B O R O U G H SCUTH AM30Y CITY SOUTH PLAINFIELD BOROUSH' SOUTH RIVER 30R0UGH ASBURY PARK CITY EATONTOWN 3 0 R 0 U G H KEYPORT 30R0UGH UNION BEACH B O R O U G H BCONTON TOWN BUTLER BOROUGH CHATHAM BOROUGH CHESTER 30R0UGH DCVER TCWN FLORHAM PARK B O R O U G H LINCOLN PARK B O R O U G H MADISON BOROUGH MORRIS P L A I N S BOROUGH MORRISTOWN TOWN MCUNTAIN L A K E S 30R0UGH MCUNT ARLINGTON BOROUGH NETCONG 30R0UGH RIVERDALE 3 0 R 0 U G H ROCKAWAY B O R O U G H VICTORY GARDENS BOROUGH WHARTON BOROUGH SOUTH TOMS RIVER BOROUGH C L I F T O N CITY HALEDON BOROUGH HAWTHORNE 3 0 R 0 U G H PASSAIC CITY PATERSON CITY TEST 05/23/78 AT 31:25 U.S. DEPARTMENT TDITAQIIPV OF THE DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 TITLE PCMPTON LAKES 30R0UGH PROSPECT PARK 3CR0UGH TOTOWA BOROUGH WANAQUE 30R0UGH WEST PATERSON BOROUGH ELMER 80RCUGH PENNS GROVE 30R0UGH SALEM CITY WOODSTOWN 30R0UGH PEAPACK GLADSTONE B O R O U G H FRANKLIN BOROUGH ELIZABETH CITY FANWOOD BOROUGH GARWOOD 30RGUGH KENILWORTH BOROUGH LINDEN CITY MOUNTAINSIDE BOROUGH NEW PROVIDENCE BOROUGH PLAINFIELD CITY RAHWAY CITY RCSELLE BOROUGH RCSELLE PARK BOROUGH SUMMIT CITY ALPHA BOROUGH PHILLIPS8URG TOWN BUENA VISTA TOWNSHIP EGG HARBOR TOWNSHIP GALLOWAY TOWNSHIP HAMILTON T O W N S H I P MULLICA TOWNSHIP WEYMOUTH TOWNSHIP LYNDHURST TOWNSHIP ROCHELLE PARK TOWNSHIP SADDLE BROOK TOWNSHIP SO HACKENSACK TOWNSHIP WASHINGTON TOWNSHIP WYCKOFF TOWNSHIP BASS RIVER T O W N S H I P 3URLINGT0N TOWNSHIP CHESTERFIELD TOWNSHIP DELANCO TOWNSHIP FLORENCE TOWNSHIP HAINESPORT TOWNSHIP MOORESTCWN T O W N S H I P NEW HANOVER TOWNSHIP NCRTH HANOVER TOWNSHIP TREASURY PAGEU8 05/2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA PAGE149 OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 31 TREASURY TITLE RIVERSIDE TO WNSHIP SPRINGFIELD TOWNSHIP WASHINGTON T O W N S H I P WESTAMPTON T OWNSHIP WILLINGBORO TOWNSHIP W C O D L A N D TOW N S H I P BERLIN TOWNS HIP GLOUCESTER T OWNSHIP HADDON TOWNS HIP PENNSAUKEN T O W N S H I P WINSLOW TOWN SHIP COMMERCIAL T O W N S H I P DEERFIELD TO WNSHIP DCWNE TOWNSH IP F A I R F I E L D TO WNSH IP H O P E W E L L TOW NSHIP LAWRENCE TOW NSHIP MAURICE RIVE R T O W N S H I P U P P E R DEERFI ELD T O W N S H I P O E P T F C R D TOW NSHIP ELK TOWNSHIP F R A N K L I N TOW NSHIP G R E E N W I C H TO WNSHIP H A R R I S O N TOW N S H I P LCGAN TOWNSH IP MANTUA TOWNS HIP MONROE TOWNS HIP SOUTH H A R R I S ON T O W N S H I P WASHINGTON T OWNSHIP W C O L W I C H TOW N S H I P NCRTH BERGEN T O W N S H I P WEEHAWKEN TO WNSHIP OLD BRIDGE T WP MONROE TOWNS HIP PISCATAWAY T O W N S H I P E D I S O N TOWNS HIP WCODBRIDGE T OWNSHIP NEPTUNE TOWN SHIP HAZLET TOWNS HIP BCONTON TOWN SHIP CHATHAM TOWN SHIP D E N V I L L E TOW N S H I P HARDING TOWN SHIP MINE HILL TO W N S H I P MORRIS TOWNS HIP P A S S A I C TOWN SHIP TE'ST 05/23/78 ^,-<^ ;j;^E5pARTMENT 4T A PAGE150 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 31 PEQUANNCCK TOWNSHIP 31 RCCKAWAY TOWNSHIP 31 ROXBURY TOWNSHIP 51 LITTLE FALLS T O W N S H I P 31 WEST MILFORD T O W N S H I P 31 ALLCWAY TOWNSHIP 31 ELSINBORO T O W N S H I P 31 LCWER ALLOWAYS CREEK TWP 31 PENNSVILLE TOWNSHIP 31 OLDMANS TOWNSHIP 31 PITTSGROVE T O W N S H I P 31 CARNEYS POINT TWP 31 UPPER PITTSGROVE TWP 31 FRANKLIN T O W N S H I P 31 BERKELEY H E I G H T S T O W N S H I P 31 CLARK TOWNSHIP 31 HILLSIDE T O W N S H I P 31 SCOTCH PLAINS T O W N S H I P 31 SPRINGFIELD T O W N S H I P 31 UNION TOWNSHIP 31 WINFIELD T O W N S H I P 31 BLAIRSTOWN T O W N S H I P 31 FRANKLIN T O W N S H I P 31 GREENWICH T O W N S H I P 31 HARDWICK T O W N S H I P 31 HOPE TOWNSHIP 31 INDEPENDENCE T O W N S H I P 31 KNOWLTON T O W N S H I P 31 MANSFIELD T O W N S H I P 31 OXFORD T O W N S H I P 31 PAHAQUARRY T O W N S H I P 31 POHATCONa T O W N S H I P STATE = 31: 308 RECORDS TREASURY 05/23/78 AT 31:25 U.S. D E P A R T M E N T DISTRESSED AREA (ELIGIBLE GOVERNMENTS) STATE TITLE 32 CATRON COUNTY 52 DE BACA COUNTY 32 GUADALUPE COUNTY 32 MCRA COUNTY 32 OTERO COUNTY 32 QUAY COUNTY 32 ROOSEVELT COUNTY 32 SAN MIGUEL C O U N T Y IZ SOCORRO COUNTY 52 RESERVE VILLAGE 32 CIMARRON VILLAGE 52 MAXWELL VILLAGE 32 SPRINGER TOWN IZ FORT SUMNER V I L L A G E 52 HATCH V I L L A G E 32 L A S CRUCES C I T Y 32 BAYARD VILLAGE 32 CENTRAL VILLAGE IZ SANTA ROSA CITY IZ VAUGHN TOWN 32 C O L U M B U S VILLAGE 52 WAGON MOUND VILLAGE 32 ALAMOGORDO CITY 32 CLOUDCROFT V I L L A G E 52 TULAROSA V I L L A G E 52 SAN JON VILLAGE 52 TOCUMCARI CITY 52 ELIOA TOWN 52 PORTALES CITY 52 DORA VILLAGE 52 FLOYD V I L L A G E 52 L A S VEGAS CITY 52 PECOS VILLAGE 32 MAGDALENA V I L L A G E 32 S O C O R R O CITY 32 E N C I N O VILLAGE IZ MOUNTAINAIR TOWN 32 GRANTS TOWN 32 MILAN VILLAGE STATE = 32: 39 RECORDS OF THE TREASURY ELIGIBILITY TEIST PAGE152 oc 05/23/78 A ;^ : 2 ^ p A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 55 ALBANY COUNTY 53 ALLEGANY C O U N T Y 35 BROOME COUNTY 55 CATTARAUGUS C O U N T Y 55 CAYUGA COUNTY 55 CHAUTAUQUA C O U N T Y 55 CHEMUNG COUNTY 55 CHENANGO C O U N T Y 55 COLUMBIA C O U N T Y 55 CCRTLAND C O U N T Y 55 DELAWARE C O U N T Y 53 ERIE COUNTY 35 ESSEX COUNTY 33 FRANKLIN C O U N T Y 35 F U L T O N COUNTY 55 GENESEE COUNTY 55 HERKIMER C O U N T Y 55 JEFFERSON COUNTY 33 L E W I S COUNTY 35 MCNROE COUNTY 55 MCNTGOMERY C O U N T Y 53 NASSAU COUNTY 33 NIAGARA COUNTY 33 ONEIDA COUNTY 33 ONONDAGA C O U N T Y 35 ORANGE COUNTY 55 ORLEANS COUNTY 53 O T S E G O COUNTY 35 RENSSELAER C O U N T Y 55 ST LAWRENCE COUNTY 35 SCHENECTADY COUNTY 53 SCHOHARIE COUNTY 35 SCHUYLER COUNTY 55 SENECA COUNTY 53 STEU3EN COUNTY 35 SULLIVAN C O U N T Y 33 ULSTER COUNTY 33 WARREN COUNTY 35 WASHINGTON C O U N T Y 55 WAYNE COUNTY 55 WYOMING COUNTY 53 YATES COUNTY II ALBANY CITY 55 C C H O E S CITY 55 COLONIC VILLAGE 53 G R E E N ISLAND V I L L A G E OF THE T R E A S U R Y 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE153 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 35 53 33 33 33 33 33 33 35 33 33 55 53 35 33 35 55 55 53 35 55 55 55 55 53 35 53 55 53 33 33 35 33 35 55 55 55 35 55 53 35 53 33 35 53 35 TITLE WATERVLIET CITY ALFRED VIL LAGE ALMOND VIL LAGE ANDOVER VI LLAGE ANGELICA V ILLAGE BELMONT VI LLAGE BOLIVAR VI LLAGE CANASERAGA VILLA GE CUBA VILLA GE FILLMORE V ILLAGE RICHBURG V ILLAGE WELLSVILLE VILLA GE BINGHAMTON CITY ENOICOTT V ILLAGE JCHNSCN CI TY VIL LAGE LISLE VILL AGE PORT DICKI NSON V ILLAGE WINDSOR VI LLAGE ALLEGANY V ILLAGE CATTARAUGU S VILL AGE OELEVAN VI LLAGE EAST RANDO LPH VI LLAGE ELLICCTTVI LLE VI LLAGE FRANKLINVI LLE VI LLAGE LIMESTONE VILLAG E LITTLE VAL LEY VI LLAGE OLEAN CITY PORTVILLE VILLAG E SALAMANCA CITY SOUTH DAYT ON VIL LAGE AUBURN CIT Y AURORA VIL LAGE CATO VILLA GE CAYUGA VIL LAGE FAIR HAVEN VILLA GE MERIDIAN V ILLAGE MCRAVIA VI LLAGE PORT BYRON VILLA GE UNION SPRI NGS VI LLAGE WEEDSPORT VILLAG E 6EMUS POIN T VILL AGE BROCTCN VI LLAGE CASSADAGA VILLAG E CELORON VI LLAGE CHERRY CRE EK VIL LAGE DUNKIRK CI TY TEST 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 35 FALCONER VILLAGE 35 FREDONIA V I L L A G E 35 JAMESTOWN CITY 53 LAKEWOOD V I L L A G E 35 MAYVILLE V I L L A G E 55 PANAMA VILLAGE 55 SHERMAN VILLAGE 55 SILVER CREEK V I L L A G E 53 SINCLAIRVILLE V I L L A G E 35 WESTFIELD V I L L A G E 55 ELMIRA CITY 55 ELMIRA H E I G H T S V I L L A G E 53 HCRSEHEADS V I L L A G E 35 MILLPORT V I L L A G E 55 VAN ETTEN V I L L A G E 55 WELLSBURG V I L L A G E 55 AFTON VILLAGE 35 BAIN8RIDGE V I L L A G E 55 GREENE VILLAGE 53 NEW BERLIN V I L L A G E 35 NORWICH CITY 53 OXFORD VILLAGE 33 SHERBURNE V I L L A G E 33 SMYRNA VILLAGE 55 DANNEMORA V I L L A G E 33 CHATHAM V I L L A G E 35 HUDSON CITY 11 KINDERHOOK V I L L A G E 33 PHILMONT V I L L A G E 33 VALATIE V I L L A G E H CORTLAND C I T Y H HCMER VILLAGE 33 MCGRAW VILLAGE 35 MARATHON V I L L A G E 55 ANDES VILLAGE 33 DELHI VILLAGE 33 FLEISCHMANNS VILLAGE 35 FRANKLIN V I L L A G E 53 HANCOCK V I L L A G E 33 HOBART VILLAGE 33 MARGARETVILLE VILLAGE 33 SIDNEY VILLAGE 33 STAMFCRO V I L L A G E 33 WALTON VILLAGE 33 8EACCN CITY 33 PCUGHKEEPSIE CITY PAGE154 OF THE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE155 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE 35 11 33 35 35 55 55 33 35 55 53 35 55 53 33 35 55 53 33 33 35 53 33 33 35 53 55 55 55 55 55 55 55 55 53 35 53 33 11 55 33 33 35 55 53 33 TITLE AKRON V I L L A G E ALDEN V I L L A G E ANGOLA V I L L A G E BLASOELL VILLAGE BUFFALO CITY FARNHAM V I L L A G E KENMORE VILLAGE LACKAWANNA CITY LANCASTER VILLAGE NCRTH C O L L I N S V I L L A G E SLOAN V I L L A G E SPRINGVILLE VILLAGE TONAWANDA CITY BLOOMINGDALE VILLAGE ELIZABETHTOWN VILLAGE LAKE PLACID V I L L A G E PORT HENRY V I L L A G E TICONDEROGA V I L L A G E 8RUSHT0N VILLAGE BURKE V I L L A G E CHATEAUGAY VILLAGE MALONE VILLAGE TUPPER LAKE V I L L A G E GLOVERSVILLE CITY JOHNSTOWN C I T Y MAYFIELD VILLAGE NORTHVILLE VILLAGE ALEXANDER V I L L A G E BATAVIA CITY BERGEN VILLAGE CORFU VILLAGE ELBA V I L L A G E LE ROY VILLAGE OAKFIELD VILLAGE CATSKILL VILLAGE CCXSACKIE VILLAGE TANNERSVILLE VILLAGE COLD BROOK V I L L A G E FRANKFORT VILLAGE HERKIMER VILLAGE ILION V I L L A G E LITTLE F A L L S C I T Y MIODLEVILLE VILLAGE MCHAWK V I L L A G E NEWPORT V I L L A G E POLAND V I L L A G E GOVERNMENTS) 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT QF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE 33 35 55 53 II 35 35 53 35 33 53 35 53 33 11 33 33 35 55 53 35 55 53 35 55 55 55 53 33 33 35 33 33 35 55 55 33 11 II II 55 53 35 53 33 II GOVERNMENTS) TITLE WEST W I N F I E L O V I L L A G E ADAMS V I L L A G E ALEXANDRIA B A Y V I L L A G E ANTWERP VILLAGE BLACK RIVER V I L L A G E BROWNVILLE VILLAGE CAPE V I N C E N T V I L L A G E CARTHAGE VILLAGE CHAUMONT VILLAGE CLAYTON VILLAGE DEFERIET VILLAGE DEXTER VILLAGE ELLISBURG VILLAGE GLEN PARK V I L L A G E HERRINGS VILLAGE MANNSVILLE VILLAGE PHILADELPHIA VILLAGE SACKETS HARBOR VILLAGE THERESA VILLAGE WATERTOWN CITY WEST C A R T H A G E V I L L A G E EVANS MILLS VILLAGE CASTORLAND VILLAGE CCNSTABLEVILLE VILLAGE COPENHAGEN VILLAGE CROGHAN VILLAGE HARRISVILLE VILLAGE LOWVILLE VILLAGE LYONS FALLS VILLAGE PORT L E Y D E N V I L L A G E TURIN VILLAGE AVON V I L L A G E DANSVILLE VILLAGE LEICESTER VILLAGE MOUNT M O R R I S V I L L A G E CANASTOTA VILLAGE HAMILTON VILLAGE MADISON VILLAGE O N E I D A CITY EAST ROCHESTER VILLAGE ROCHESTER CITY AMES V I L L A G E AMSTERDAM CITY CANAJOHARIE VILLAGE FONDA VILLAGE FORT JOHNSON VILLAGE PAGE15G 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 33 33 35 55 55 35 53 33 35 33 35 53 35 53 35 55 55 35 55 53 35 53 33 33 33 35 55 53 33 11 33 33 33 33 33 33 35 35 53 11 55 55 55 53 33 11 FCRT PLAIN V I L L A G E FULTONVILLE VILLAGE HAGAMAN V I L L A G E NELLISTON VILLAGE P A L A T I N E B R I O G E VILLAGE ST J O H N S V I L L E V I L L A G E BAXTER E S T A T E S V I L L A G E 3ELLER0SE V I L L A G E BROOKVILLE V I L L A G E CEOARHURST V I L L A G E C E N T R E ISLAND V I L L A G E COVE NECK V I L L A G E EAST HILLS V I L L A G E EAST ROCKAWAY V I L L A G E EAST W I L L I S T O N V I L L A G E FARMINGDALE VILLAGE F L O R A L PK V I L L A G E F L O N E R HILL VILLAGE FREEPORT VILLAGE GLEN COVE CITY G R E A T NECK V I L L A G E G R E A T NECK E S T A T E S V I L L A G E G R E A T NECK PLAZA VILLAGE HEMPSTEAD V I L L A G E HEWLETT BAY PARK VILLAGE HEWLETT NECK V I L L A G E ISLAND PARK VILLAGE KENSINGTON VILLAGE LAKE SUCCESS V I L L A G E LATTINGTOWN VILLAGE LAUREL HOLLCW V I L L A G E LAWRENCE V I L L A G E LONG BEACH C I T Y LYNBRCOK V I L L A G E MALVERNE V I L L A G E MANORHAVEN V I L L A G E MASSAPEQUA PARK VILLAGE MATINECOCK V I L L A G E MILL NECK V I L L A G E MINEOLA V I L L A G E MUTTONTOWN V I L L A G E NEW HYDE PARK V I L L A G E NCRTH HILLS V I L L A G E OLD WEST3URY V I L L A G E OYSTER BAY C O V E VILLAGE PLANDOME V I L L A G E TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE158 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 33 PLANDOME HEIGHTS VILLAGE 33 PLANDCME MANOR V I L L A G E 35 PORT WASHINGTON N VILLAGE 33 RCCKVILLE CENTRE VILLAGE 35 ROSLYN VILLAGE 53 ROSLYN HARBOR VILLAGE 33 RUSSELL G A R D E N S VILLAGE 33 SAODLE ROCK VILLAGE 33 SEA CLIFF VILLAGE 35 SOUTH FLORAL PARK VILLAGE 53 STEWART MANOR VILLAGE 33 THOMASTON V I L L A G E 33 UPPER BROCKVILLE VILLAGE! 33 VALLEY STREAM V I L L A G E 35 WESTBURY V I L L A G E 53 WILLISTON PARK VILLAGE 33 WOODSBURGH V I L L A G E 33 ATLANTIC B E A C H 33 NEW YORK CITY 33 BARKER VILLAGE 33 L E W I S T O N VILLAGE 33 LCCKPORT CITY 33 MIDDLEPORT V I L L A G E 33 NIAGARA F A L L S CITY 33 NORTH TCNAWANDA CITY 33 W I L S O N VILLAGE 33 YOUNGSTOWN V I L L A G E 33 BOONVILLE V I L L A G E 53 B R I D G E W A T E R VILLAGE 11 CAMDEN VILLAGE 33 CLAYVILLE V I L L A G E 33 CLINTON VILLAGE SI HOLLAND PATENT VILLAGE 33 NEW HARTFORO V I L L A G E 33 NEW YORK M I L L S V I L L A G E 33 ONEIDA C A S T L E VILLAGE 33 O R I S K A N Y VILLAGE 33 ORISKANY F A L L S VILLAGE 33 P R O S P E C T VILLAGE 33 R E M S E N VILLAGE 33 ROME CITY II SHERRILL CITY 33 BARNEVELD VILLAGE 33 UTICA CITY 33 VERNON VILLAGE 33 WATERVILLE VILLAGE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE159 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 33 WHITES60RC VILLAGE 33 YORKVILLE V I L L A G E 33 SYLVAN BEACH V I L L A G E 35 BALDWINSVILLE VILLAGE 33 CAMILLUS VILLAGE 33 EAST SYRACUSE V I L L A G E 35 ELBRIOGE VILLAGE 55 FABIUS VILLAGE 33 FAYETTEVILLEi V I L L A G E 33 JORDAN VILLAGE 33 LIVERPOOL V I L L A G E 35 MARCELLUS V I L L A G E 55 MINOA V I L L A G E 53 NORTH SYRACUSE V I L L A G E 33 SOLVAY V I L L A G E 33 SYRACUSE CITY 35 TULLY V I L L A G E 33 C L I F T C N S P R I N G S VILLAGE 35 EAST B L O O M F I E L D VILLAGE 53 GENEVA CITY 35 PHELPS VILLAGE 55 CHESTER VILLAGE 55 CORNWALL VILLAGE 53 G R E E N W O O D LAKE V I L L A G E 33 HARRIMAN V I L L A G E 33 HIGHLAND FALLS VILLAGE 35 MAYBROOK V I L L A G E 55 MIDDLETOWN CITY 55 MONROE VILLAGE 55 MCNTGOMERY V I L L A G E 53 NEWBURGH C I T Y 35 PORT J E R V I S CITY 55 T U X E D O PARK V I L L A G E 33 UNIONVILLE VILLAGE 33 WALDEN V I L L A G E 33 WASHINGTONVILLE VILLAGE 33 K I R Y A S JOEL V I L L A G E 33 F U L T O N CITY 33 PHOENIX V I L L A G E 33 C H E R R Y VALLEY V I L L A G E 35 CCOPERSTOWN VILLAGE 33 GILBERTSVILLE VILLAGE 35 LAURENS VILLAGE 55 MILFORO V I L L A G E 55 MORRIS VILLAGE 55 ONEONTA CITY TREASURY 05/2 3/78 AT 31:25 U.S. DEPARTMENT DISTRESSED PAGE160 OF THE AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TREASURY TITLE OTEGO VILLAGE 53 RICHFIELD SPRINGS VILLAGE 33 SCHENEVUS VILLAGE 33 UNADILLA VILLAGE 33 COLD SPRING VILLAGE 33 CASTLEION ON HUDSON VILL 33 HOOSICK FALLS VILLAGE 33 NASSAU VILLAGE 33 RENSSELAER CITY 33 SCHAGHTICOKE VILLAGE 33 TROY CITY 33 VALLEY FALLS VILLAGE 53 HILL3URN VILLAGE 11 NYACK VILLAGE 33 CANTON VILLAGE 35 EDWARDS VILLAGE 33 GCUVERNEJR VILLAGE 33 HAMMOND VILLAGE 33 HERMON VILLAGE 33 HEUVELTON VILLAGE 53 MASSENA VILLAGE 35 MORRISTOWN VILLAGE 33 NORWOOD VILLAGE 33 0GDENS3URG CITY 33 POTSDAM VILLAGE 33 RENSSELAER FALLS VILLAGE 33 RICHVILLE VILLAGE 35 WAODINGTON VILLAGE 53 CORINTH VILLAGE 33 HECHANICVILLE ^ J T Y 33 SCHUYLERVILLE " L L A G E 33 SOUTH GLENS FALLS VILLAGE 35 VICTORY TOWN 53 WATERFORL) VILLAGE 33 RCUNO LAKE VILLAGE 33 DELANSON VILLAGE 33 SCHENECTADY CITY 11 SCOTIA VILLAGE SI CCBLESK1LL VILLAGE 35 ESPERANCE VILLAGE 33 MIODLEBURGH VILLAGE 33 M D VILLAGE R rC HMC^VILLE 33 <;rnGHARlE VILLAGE 33 S ^ R O N SPRINGS VILLAGE 33 RURDETT VILLAGE 33 B U M GN?OUR FALLS VILLAGE 33 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE TITLE 33 WATKINS GLEN VILLAGE 35 INTERLAKEN V I L L A G E 53 LODI V I L L A G E 35 OVID V I L L A G E 33 SENECA F A L L S V I L L A G E SI WATERLOO VILLAGE 33 ADDISON VILLAGE 33 ARKPORT V I L L A G E 33 AVOCA V I L L A G E 35 BATH VILLAGE 53 CANISTEC VILLAGE 33 CORNING CITY 33 HAMMONDSPORT V I L L A G E 35 HORNELL CITY 33 NORTH HORNELL V I L L A G E 33 P A I N T E D POST V I L L A G E 35 RIVERSIDE V I L L A G E 55 SAVONA VILLAGE 55 SCUTH CORNING V I L L A G E 55 WAYLAND VILLAGE 33 WCODHULL VILLAGE 35 GREENPORT V I L L A G E 53 PATCHOGUE V I L L A G E 35 BL00MING8URGH VILLAGE 55 JEFFERSGNVILLE VILLAGE 55 LIBERTY VILLAGE 55 MCNTICELLO V I L L A G E 53 WOOORIOGE V I L L A G E 35 WURTSOORO V I L L A G E 53 FREEVILLE VILLAGE 35 ITHACA CITY 55 TRUMANSBURG V I L L A G E 33 ELLENVILLE VILLAGE 33 KINGSTON CITY 35 NEW PALTZ V I L L A G E 33 PINE HILL V I L L A G E SI RCSENDALE V I L L A G E 11 SAUGERTIES V I L L A G E 35 G L E N S FALLS 55 ARGYLE VILLAGE 55 CAMBRIDGE V I L L A G E 53 F C R T ANN V I L L A G E 33 FCRT EDWARD V I L L A G E 33 / GRANVILLE V I L L A G E 33 GREENWICH VILLAGE 33 HUDSON F A L L S V I L L A G E PAGE161 OF THE TREASURY 05/23/78 A J j ; S ^ p A R T M E N T PAGE1S2 QF DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 35 SALEM VILLAGE 55 WHITEHALL V I L L A G E 53 CLYDE VILLAGE 33 L Y O N S VILLAGE 33 NEWARK VILLAGE 35 PALMYRA V I L L A G E 53 RED CREEK V I L L A G E 55 SAVANNAH V I L L A G E 35 SODUS VILLAGE 55 WCLCOTT V I L L A G E 33 ELMSFORD V I L L A G E 35 MOUNT KISCO V I L L A G E 55 MOUNT VERNON C I T Y 55 NEW R O C H E L L E C I T Y 53 NORTH TARRYTOWN V I L L A G E 35 OSSINING V I L L A G E 55 PORT CHESTER V I L L A G E 55 Y C N K E R S CITY 55 ATTICA VILLAGE 55 CASTILE V I L L A G E 55 PIKE VILLAGE 55 DRESDEN V I L L A G E 55 DUNDEE VILLAGE 55 PENN YAN V I L L A G E 55 COLONIE TOWN 55 G R E E N ISLAND TOWN 55 ALFRED TOWN 55 ALLEN TCWN 55 ALMA TOWN 53 ALMOND TOWN 35 AMITY TOWN 53 ANDOVER TOWN II ANGELICA TOWN 35 BELFAST TOWN 55 3IRDSALL TOWN 55 BOLIVAR TCWN 35 BURNS TOWN 55 CANEADEA TOWN 55 C E N T E R V I L L E TOWN 55 CLARKSVILLIE TOWN 55 CU3A TOWN 55 F R I E N D S H I P TOWN 53 G E N E S E E TOWN 35 GRANGER TOWN 55 GROVE TOWN 53 HUME TOWN THE TREASURY 0 5 / 2 3/78 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 35 53 33 33 35 53 35 55 53 33 33 35 55 53 35 55 55 55 55 55 53 35 55 53 33 35 55 53 53 55 55 55 55 33 33 33 35 55 53 35 55 53 35 53 35 53 TITLE I N D E P E N D E N C E TOWN NEW HUDSON TOWN RUSHFORD TOWN SCIO TOWN WARD TOWN W E L L S V I L L E TOWN WEST ALMOND TOWN W I L L I N G TCWN WIRT TOWN BARKER TOWN B I N G H A M T O N TOWN C H E N A N G O TOWN D I C K I N S O N TOWN KIRKWOOD TOWN MAINE TOWN S A N F O R D TOWN UNION TOWN W I N D S O R TOWN ALLEGANY T O W N A S H F O R D TOWN C A R R O L L T O N TOWN C G L D S P R I N G TOWN CONEWANGO TOWN D A Y T O N TOWN EAST OTTO TOWN E L L I C O T T V I L L E TOWN F A R M E R S V I L L E TOWN F R A N K L I N V I L L E TOWN F R E E O O M TOWN G R E A T VALLEY TOWN HINSDALE TOWN HUMPHREY TOWN ISCHUA TOWN LEON TOWN LITTLE VALLEY TOWN LYNDON TOWN M A C H I A S TOWN MANSFIELD TOWN NAPOLI TOWN NEW ALBION TOWN OLEAN TOWN OTTO TUWN PERRYS8URG TOWN PERSIA TOWN PORTVILLE TOWN RANDOLPH TOWN PAGE163 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TEIST 0 5 / 2 3 / 7 8 AT 31:25 U.S. DEPARTMENT DISTRESSED 33 35 11 11 35 55 35 53 33 33 33 33 35 53 55 53 33 33 33 35 11 11 11 11 55 55 55 55 55 53 33 35 53 33 33 35 11 55 55 53 35 53 11 33 35 55 OF THE TREASURY AREA ELIGIBILITY (ELIGIBLE STATE PAGE164 TITLE RED HOUSE TOWN SALAMANCA TOWN S C U T H VALLEY TOWN Y O R K S H I R E TOWN AURELIUS TOWN 8 R U T U S TOWN C A T O TOWN CONQUEST TOWN F L E M I N G TOWN G E N O A TOWN IRA TOWN L E D Y A R D TOWN L O C K E TOWN MENTZ TOWN MCNTEZUMA TOWN MORAVIA TOWN N I L E S TGWN OWASCO TOWN S C I P I O TOWN S E M P R O N I U S TOWN S E N N E T T TOWN S P R I N G P O R T TOWN STERLING TOWN SUMMERHILL TOWN T H R O O P TOWN V E N I C E TOWN V I C T O R Y TOWN A R K W R I G H T TOWN 8USTI TOWN C A R R O L L TOWN C H A R L O T T E TOWN C H A U T A U Q U A TOWN C H E R R Y CREEK TOWN CLYMER TOWN D U N K I R K TOWN E L L E R Y TOWN E L L I C O T T TOWN E L L I N G T O N TOWN F R E N C H CREEK TOWN G E R R Y TOWN H A N O V E R TOWN H A R M O N Y TOWN KIANTONE TOWN MINA TOWN N C R T H H A R M O N Y TOWN P O L A N D TOWN GOVERNMENTS) TEST 0 5 / 2 5 / 7 3 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 55 POMFRET TOWN 53 P O R T L A N D TUWN 35 RIPLEY TOWN 53 S H E R I D A N TOWN II SHERMAN TOWN 33 STOCKTON TOWN 35 VILLENOVA TOWN 53 WESTFIELD TOWN 35 ASHLAND TOWN 55 B A L D W I N TOWN 53 CATLIN TOWN 33 CHEMUNG TOWN 33 ELMIRA TOWN 33 ERIN TOWN 35 H C R S E H E A D S TOWN 53 SCUTHPOKT TOWN 55 VAN ETTEN TOWN 11 VETERAN TOWN 55 AFTON TCWN 55 BAINBRIDGE TOWN 55 C O L U M B U S TOWN 55 C O V E N T R Y TOWN 55 GERMAN TOWN 55 G R E E N E TOWN 53 G U I L F O R D TOWN 35 L I N C K L A E N TOWN 35 MCDONOUGH TOWN 55 NEW BERLIN TOWN 55 NCRTH NORWICH TOWN 55 NORWICH TOWN 53 OTSELIC TOWN 33 OXFORD TOWN 33 PHARSALIA TOWN 33 PITCHER TOWN 33 PLYMOUTH TOWN 33 PRESTON TOWN 35 SHERBURNE TOWN 55 SMITHVILLE TOWN 55 SMYRNA TOWN 55 ALTONA TOWN 53 BLACK BROOK TOWN 35 C L I N T O N TOWN 53 DANNEMURA TOWN 33 ELLENBUR3 TOWN 35 ANCRAM TOWN 55 A U S T E R L I T Z TOWN PAGE165 OF THE TREASURY 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 53 CANAAN TOWN 35 CHATHAM TOWN 55 CLAVERAC* TOWN 55 CLERMONT TOWN 53 COPAKE TOWN 55 GERMANTOWN TOWN 55 GHENT TOWN 55 GREENPORT TOWN 55 HILLSDALE TOWN 33 KINDERHOOK TOWN 35 LIVINGSTON TOWN 55 NEW LEBANON TOWN 53 STOCKPORT TOWN 35 STUYVESANT TOWN 55 TAGHKANIC TOWN 55 C I N C I N N A T U S TOWN 35 CCRTLANDVILLE TOWN 53 CUYLER TOWN 35 FREETOWN TOWN 55 HARFORD TCWN 33 HOMER TOWN 35 LAPEER TOWN 55 MARATHON TOWN 55 PREBLE TOWN 55 SCOTT TOWN 55 SOLON TOWN 55 TAYLOR TOWN 53 TRUXTCN TOWN 33 VIRGIL TOWN 33 WILLET TOWN 33 ANOES TOWN 35 80VINA TOWN 55 COLCHESTER TOWN 53 DAVENPORT TOWN 33 DELHI TOWN 35 DEPOSIT TOWN 35 FRANKLIN TOWN 55 HAMDEN TOWN 33 HANCOCK TOWN 33 HARPERSFIELD. TOWN 33 KORTRIGHT TOWN 11 MASONVILLE TOWN 33 MEREOITH TOWN 33 MIODLETOWN TOWN 33 ROXBURY TOWN 35 SIDNEY TOWN PAGElbb OF THE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TE«ST (ELIGIBLE GOVERNMENTS) STATE TITLE 35 STAMFCRD TOWN 33 T O M P K I N S TOWN 35 WALTON TOWN 33 AMENIA TOWN 35 D C V E R TOWN 55 P O U G H K E E P S I E TOWN 55 A L D E N TOWN 53 AURORA TOWN 35 BOSTON TOWN 55 BRANT TOWN 55 C H E E K T O W A G A TOWN 33 CLARENCE TOWN 11 CCLOEN TOWN 35 C O L L I N S TOWN 55 C O N C O R D TOWN 55 EOEN TOWN 53 ELMA TOWN 33 E V A N S TOWN 35 G R A N D ISLAND TOWN 55 HAMBURG TOWN 33 H O L L A N O TOWN 53 L A N C A S T E R TOWN 33 MARILLA TOWN 35 NEWSTEAD TOWN 53 NCRTH C O L L I N S TOWN 35 SAROINIA TOWN 55 TCNAWANDA TOWN 55 W A L E S TOWN 55 WEST SENECA TOWN 55 C H E S T E R F I E L D TOWN 55 CROWN POINT TOWN 53 E L I Z A B E T H T O W N TOWN SI E S S E X TCWN 33 JAY TCWN 35 KEENE TOWN 55 L E W I S TOWN 55 MINERVA TOWN 53 MORIAH TOWN 33 NEWCOMB TOWN 35 NORTH ELBA TOWN 55 NCRTH HUDSON TOWN 33 ST ARMAND TOWN 35 S C H R O O N TOWN 53 T I C O N D E R O G A TOWN 35 W E S T P O R T TOWN 55 WILLSBORO TOWN PAGE167 OF THE TREASURY 05/25/76 A ^;:2E%ARTM£Nf DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 55 55 55 55 55 35 55 55 55 55 55 55 33 11 33 35 33 35 55 55 55 55 55 53 33 35 55 53 II 11 33 33 35 53 33 35 53 33 35 55 55 55 55 35 53 TITLE WILMINGTON TOWN ALTAMONT TOWN BANGOR TOWN BELLMONT TOWN BCMBAY TOWN BRANDON TOWN BRIGHTON TOWN BURKE TCWN CHATEAUGAY TOWN CONSTABLE TOWN DICKINSON TOWN DUANE TOWN FORT COVINGTON TOWN FRANKLIN TOWN HARRIETSTOWN TOWN MALONE TOWN MCIRA TOWN SANTA CLARA TOWN WAVERLY TOWN WESTVILLE TOWN BLEECKER TOWN BROADALBIN TOWN CAROGA TOWN EPHRATAH TOWN JOHNSTOWN TOWN MAYFIELD TOWN NORTHAMPTON TOWN OPPENHEIM TOWN PERTH TOWN STRATFORD TOWN ALABAMA TOWN ALEXANDER TOWN BATAVIA TOWN BERGEN TOWN BETHANY TOWN BYRON TOWN DARIEN TOWN ELBA TOWN LE ROY TOWN OAKFIELD TOWN PAVILION TOWN PEMBROKE TOWN LONG WINDHAM BENSON STAFFORO LAKE TOWN TOWN TOWN TOWN Qfr J H E TREASURY PAGE168 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE G O V E R N M E N T S ) STATE TITLE 35 55 53 33 35 33 33 33 33 33 35 33 55 53 35 55 55 35 53 33 11 11 33 33 35 55 55 53 33 35 55 55 53 35 55 55 55 33 35 53 35 33 35 55 53 35 MOREHOUSE TOWN W E L L S TOWN C O L U M B I A TOWN DANUBE TOWN F A I R F I E L D TOWN F R A N K F O R T TOWN GERMAN F L A T T S TOWN HERKIMER TOWN L I T C H F I E L D TOWN LITTLE F A L L S TOWN MANHEIM TOWN NEWPORT TOWN NORWAY TOWN OHIO TOWN RUSSIA TOWN SALISBURY TOWN S C H U Y L E R TOWN STARK TOWN WARREN TOWN WEBB TOWN W I N F I E L O TOWN ADAMS TOWN ALEXANDRIA TOWN A M W E R P TOWN 6R0WNVILLE TOWN CAPE VINCENT TOWN C H A M P I O N TOWN C L A Y T O N TOWN ELLISBURG TOWN HENDERSON TOWN HOUNSFIELO TOWN LE RAY TOWN LORRAINE TOWN LYME TOWN O R L E A N S TOWN PAMELIA TOWN PHILADELPHIA TOWN RODMAN TOWN RUTLAND TOWN THERESA TOWN WATERTOWN TOWN WILNA TOWN WORTH TCWN CROGHAN TOWN DENMARK TOWN DIANA T C M N PAGE169 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE170 OF THE DISTRESSED AREA ELIGIBILITY TElST (ELIGI8LE GOVERNMENTS) STATE TITLE 33 GREIG TOWN 33 HARRISBURG TOWN 33 LEWIS TCWN 33 LEYOEN TOWN 33 LOWVILLE TOWN 33 LYONSDALE TOWN 33 MARTINSBURG TOWN 33 MONTAGUE TOWN 33 NEW 8REHEM TOWN 33 OSCEOLA TOWN 35 PINCKNEY TOWN 53 TURIN TOWN 33 WATSON TOWN 33 WEST TURIN TOWN 33 CALEDONIA TOWN 35 GROVELAND TOWN 53 LEICESTER TOWN 33 MOUNT MORRIS TOWN 33 NORTH DANSVILLE TOWN 35 OSSIAN TOWN 53 WEST SPARTA TOWN 35 YORK TOWN 53 8R00KFIELD TOWN 11 DE RUYTER TOWN 35 FENNER TOWN 55 GEORGETOWN TOWN 55 HAMILTON TOWN 53 LENOX TOWN 33 NELSON TOWN 33 SMITHFIELD TOWN 35 CLARKSON TOWN 55 RUSH TOWN 33 AMSTERDAM TOWN 33 CANAJOHARIE TOWN 33 CHARLESTON TOWN 35 FLORIDA TOWN 33 GLEN TOWN 33 MINOEN TOWN 35 MOHAWK TOWN 55 PALATINE TOWN 33 RCOT TOWN 33 ST JOHNSVILLE TOWN 33 HEMPSTEAD TOWN 33 NORTH HEMPSTEAD TOWN 35 OYSTER BAY TOWN 53 CAMBRIA TOWN TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 33 HARTLAND TOWN 33 L E W I S T O N TOWN 35 L C C K P O R T TOWN 53 NEWFANE TOWN 35 NIAGARA TOWN 55 PENDLETON TOWN 55 PORTER TOWN 55 R G Y A L T O N TOWN 55 S O M E R S E T TOWN 55 W H E A T F I E L D TOWN 55 WILSON TOWN 55 ANNSVILLE TOWN 53 AUGUSTA TCWN 35 AVA TCWN 53 BOONVILLE TOWN 33 B R I D G E W A T E R TOWN 33 CAMDEN TOWN 33 DEERFIELD TOWN 35 F L O R E N C E TOWN 55 FLOYD TOWN 33 F O R E S T P O R T TOWN 33 K I R K L A N D TOWN 35 LEE TOWN 33 MARCY TOWN 35 MARSHALL TOWN 55 NEW HARTFORD TOWN 53 P A R I S TOWN 33 REMSEN TOWN 35 S A N G E R F I E L D TOWN 55 S T E U B E N TOWN 55 T R E N T O N TOWN 55 VERNON TOWN 55 VERONA TOWN 55 VIENNA TOWN 53 WESTERN TOWN 35 W E S T M O R E L A N D TOWN 11 WHITESTOWN TOWN 33 C A M I L L U S TOWN 11 C I C E R O TOWN 35 DE WITT TOWN 33 ELBRIDGE TOWN 35 F A B I U S TOWN 53 G E D D E S TOWN 11 L A F A Y E T T E TOWN 11 L Y S A N D E R TOWN 11 MARCELLUS TOWN PAGE17L OF THE TREASURY 05/23/78 AT ^ ' 2 | p A R T M E M T QF DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 33 ONONDAGA TOWN 33 OTISCC TOWN 33 PCMPEY TOWN 33 SALINA TOWN 33 SKANEATELES TOWN 33 SPAFFORD TOWN 33 TULLY TOWN 33 VAN BUREN TOWN 53 GCRHAM TOWN 35 HOPEWELL TOWN 33 BLOOMING GROVE TOWN 35 CHESTER TOWN 33 CORNWALL TOWN 33 CRAWFORD TOWN 33 DEERPARK TOWN 33 GREENVILLE TOWN 33 HIGHLANDS TOWN 35 MONROE TOWN 53 MONTGOMERY TOWN 33 MOUNT HOPE TOWN 35 NEWBURGH TOWN 33 NEW WINDSOR TOWN 33 TUXEDO TOWN 33 WALLKILL TOWN 33 WAWAYANDATOWN 33 BARRE TOWN 53 CARLTON TOWN 33 CLARENDON TOWN 33 GAINES TOWN II MURRAY TOWN 33 RIDGEWAY TOWN 33 SHELBY TOWN 33 80YLSTON TOWN 33 NEW HAVEN TOWN 35 BURLINGTON TOWN 33 BUTTERNUTS TOWN 33 CHERRY VALLEY TOWN 35 DECATUR TOWN 53 EOMESTON TOWN 33 EXETER TOWN 33 HARTWICK TOWN 33 LAURENS TOWN 35 MARYLAND TOWN 33 MIDDLEFIELD TOWN 53 M1LFORD TOWN *7 MH3RTS TOWN THE TRE,SURY ' 05/2 3/78 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 35 53 33 33 33 35 53 35 33 33 35 55 55 53 33 35 53 35 53 33 33 55 53 55 55 53 35 55 55 55 53 33 33 33 35 55 55 55 55 55 55 55 53 35 55 55 TITLE NEW LISBON TOWN O K E O N T A TOWN OTEGO TOWN OTSEGO TOWN P I T T S F I E L D T OWN P L A I N F I E L D T OWN RICHFIELD TO WN ROSEBOOM TOW N S P R I N G F I E L D TOWN UNADILLA TOW N W E S T F O R D TOW N W O R C E S T E R TO WN BERLIN TOWN BRUNSWICK TO WN G R A F T O N TOWN HOOSICK TOWN NASSAU TOWN NCRTH GREENB USH TOWN PETERSBRUG T OWN PITTSTOWN TO WN POESTENKILL TOWN SAND LAKE S C H A G H T I C O K E TOWN SCHCDACK TOW N S T E P H E N T 3 W N TOWN BRASHER TOWN CANTON TOWN CLARE TOWN C L I F T O N TCWN COLTON TOWN DE KALB TOWN DE PEYSTER TOWN E D W A R D S TOWN FINE TOWN F O W L E R TOWN GCUVERNEUR T OWN HAMMONO TOWN HERMON TOWN H C P K I N T O N TO WN LAWRENCE TOW N LISBON TOWN L O U I S V I L L E T OWN MACOMB TOWN MADRID TOWN MASSENA TOWN MORRISTOWN TOWN PAGE173 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TE'ST 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 33 33 35 33 33 33 33 35 53 33 33 33 35 11 11 11 35 53 33 33 33 33 35 33 33 11 33 33 35 53 IS IS SS 33 11 11 33 35 53 33 33 33 33 33 33 33 NORFOLK TOWN OSWEGATCHIE TOWN PARISHVILLE TOWN PIERCEFIELD TOWN PIERREPONT TOWN PITCAIRN TOWN POTSDAM TOWN RCSSIE TOWN RUSSELL TOWN STOCKHOLM TOWN WADDINGTON TOWN CORINTH TCWN ROTTERDAM TOWN BLENHEIM TOWN BROOME TOWN CARLISLE TOWN COBLESKILL TOWN CONESVILLE TOWN ESPERANCE TOWN FULTON TOWN GILBOA TOWN JEFFERSON TOWN MIDDLEBURGH TOWN RICHMONOVILLE TOWN SCHOHARIE TOWN SEWARD TOWN SHARON TOWN SUMMIT TOWN WRIGHT TOWN CATHARINE TOWN CAYUTA TOWN OIX TOWN HECTOR TOWN MCNTOUR TOWN ORANGE TOWN READING TOWN TYRONE TOWN COVERT TOWN FAYETTE TOWN JUNIUS TOWN LCDI TOWN OVID TOWN ROMULUS TOWN SENECA FALLS TOWN TYRE TOWN VARICK TOWN 0 5 / 2 3 / 7 8 AT 31:25 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 35 33 35 53 35 55 55 53 53 33 35 55 55 55 55 53 55 55 53 33 35 55 55 53 IS 35 53 55 53 35 55 55 55 53 35 33 35 33 33 35 53 33 35 55 53 35 WATERLOO TOWN ADDISON TOWN AVOCA TOWN BATH TOWN BRADFORD TOWN CAMERON TCWN C A M P B E L L TOWN CA.NISTEO TOWN CATCN TOWN CORNING TOWN DANSVILLE TOWN ERWIN TOWN F R E M O N T TOWN GREENWOOD TOWN HARTSVILLE TOWN HCRNBY TOWN HORNELLSVILLE TO HOWARD TOWN JASPER TOWN LINDLEY TOWN PRATTS8URG TOWN PULTENEY TOWN RATHBONE TOWN T H U R S T O N TOWN TROUPSBURG TOWN TUSCAPORA TOWN UR8ANA TOWN WAYLAND TOWN WAYNE TCWN WEST UNION TOWN WHEELER TOWN WOODHULL TOWN BA8YL0N TOWN BETHEL TOWN C A L L I C O O N TOWN CCCHECTON TOWN DELAWARE TOWN FALLSBURJ TOWN F O R E S T B U R G H TOWN FREMONT TOWN HIGHLAND TOWN LIBERTY TOWN MAMAKATING TOWN NEVERSINK TOWN ROCKLAND TOWN THOMPSON TOWN PAGE175 OF THE TREASURY 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T OF THE TREASURY D I S T R E S S E D AREA E L I G I B I L I T Y TEIST (ELIGIBLE STATE 55 55 55 53 35 55 33 11 11 IS IS 35 33 33 35 53 33 SS 33 55 SS SS SS 53 33 35 53 35 53 SS 35 53 35 55 53 33 35 53 35 55 33 33 33 33 35 55 TITLE DANBY TOWN E N F I E L D TOWN G R O T O N TOWN ITHACA TOWN U L Y S S E S TOWN D E N N I N G TOWN E S O P U S TOWN G A R D I N E R TOWN H A R D E N B E R G H TOWN HURLEY TOWN K I N G S T O N TOWN LLOYD TOWN MARBLETOwN TOWN M A R L B O R O U G H TOWN NEW PALTZ TOWN OLIVE TOWN P L A T T E K I L L TOWN ROCHESTER TOWN ROSENDALE TOWN S A U G E R T I E S TOWN SHANOAKEN TOWN SHAWANGUNK TOWN U L S T E R TOWN WAWARSING TOWN WOODSTOCK TOWN B O L T O N TOWN LAKE GEORGE TOWN C H E S T E R TOWN HAGUE TOWN H C R I C O N TOWN JOHNSBURG TOWN LAKE L U Z E R N E TOWN QUEENSBURY TOWN STONY CREEK TOWN THURMAN TOWN W A R R E N S B U R G TOWN ARGYLE TOWN CAMBRIOGE TOWN D R E S D E N TOWN E A S T O N TOWN F O R T ANN TOWN F C R T EDWARD TOWN G R A N V I L L E TOWN G R E E N W I C H TOWN H A M P T O N TOWN H A R T F O R D TOWN GOVERNMENTS) PAGE17G 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA PAGE177. OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 53 33 33 35 53 35 55 33 33 35 53 35 33 35 55 53 33 33 35 55 55 53 35 55 55 53 33 33 35 55 55 55 33 33 33 TITLE HEBRON TOW N J A C K S O N TO WN KINGSBURY TOWN PUTNAM TOW N SALEM TOWN WHITE CREE K TOWN WHITEHALL TOWN ARCADIA TO WN GALEN TOWN HURON TOWN L Y O N S TOWN PALMYRA TO WN W I L L I A M S O N TOWN W C L C O T T TO WN OSSINING T OWN RYE TOWN ATTICA TOW N BENNINGTON TOWN C A S T I L E TO WN C C V I N G T C N TOWN GAINESVILL E TOWN PERRY TOWN PIKE TOWN SHELDON TO WN WARSAW TOW N WETHERSFIE LD. TOWN BARRINGTON TOWN BENTON TOW N ITALY TCWN JERUSALEM TOWN MIDDLESEX TOWN MILC TOWN POTTER TOW N S T A R K E Y TO WN TCRREY TOW N S T A T E = 33: 1185 TREASURY RECORDS TEST 05/2 3/78 AT 31:25 U.S. DEPARTMENT PAGE178. OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 34 ALAMANCE COUNTY 34 ASHE COUNTY 34 AVERY COUNTY 54 BERTIE COUNTY 34 BLADEN COUNTY 34 CABARRUS COUNTY 34 CALDWELL COUNTY 34 CASWELL. COUNTY 34 CHATHAM COUNTY 34 CHEROKEE COUNTY 34 CHOWAN COUNTY 54 DUPLIN COUNTY 34 EDGECOMBE COUNTY 34 FRANKLIN COUNTY 34 GATES COUNTY 54 GRAHAM COUNTY 54 GRANVILLE COUNTY 54 GREENE COUNTY 54 HALIFAX COUNTY 34 HAYWOOD COUNTY 34 HERTFORO COUNTY 34 HOKE COUNTY 34 JCHNSTON COUNTY 34 JCNES COUNTY 54 MARTIN COUNTY 34 MITCHELL COUNTY 34 MCNTGOMERY COUNTY 34 NORTHAMPTON COUNTY 34 PAMLICO COUNTY 34 PENDER COUNTY 34 PERQUIMANS COUNTY 34 PERSON COUNTY 34 RICHMOND COUNTY 34 ROBESON COUNTY 34 RUTHERFORD COUNTY 34 STANLY COUNTY 34 TYRRELL COUNTY 34 VANCE COUNTY 34 WARREN COUNTY 34 BURLINGTON CITY ]l ELON COLLEGE TOWN 34 GRAHAM CITY 3^ JEFFERSON TOWN 34 LANSING TOWN II BANNER ELK TOWN 34 CROSSNORL TOWN TREASURY 05/2 3/78 AT 31:25 U.S. DEPARTMENT OF THE PAGE179. TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 54 ELK PARK TOWN 34 NEWLAND TOWN 34 KELFORD TOWN 34 WCODVILLE TOWN 34 BLADENBORO TOWN 34 WHITE LAKE TOWN 34 EAST ARCADIA TOWN 34 GLEN ALPINE TOWN 34 CONCORD CITY 34 GRANITE FALLS TOWN 34 MILTON TOWN 34 BROOKFORD TOWN 34 ANDREWS TOWN 34 MURPHY TOWN 34 EDENTON TOWN 34 LATTIMORE TOWN 34 BOLTON TOWN 34 CHADBOURN TOWN 34 FAIR BLUFF TOWN 34 TABOR CITY TOWN 34 FALCON TOWN 34 LEXINGTON CITY 34 THOMASVILLE CITY 34 CALYPSO TOWN 34 FAISON TOWN 34 MAGNOLIA TOWN 34 ROSE HILL TOWN 34 TEACHEY TOWN 34 WALLACE TCWN 34 WARSAW TOWN 34 GREENEVERS TOWN 34 PINETCPS TOWN 34 LEGGETT TOWN 34 BUNN TOWN 34 FRANKLINTON TOWN 54 LOUISBURG TOWN 54 CENTERVILLE TOWN 54 CREEDMOOR CITY 54 OXFORD CITY 54 STEM TOWN 54 STOVALL TOWN 54 HOOKERTON TOWN 54 SNOW HILL TOWN 54 WALSTONBURG TOWN 34 ENFIELD TOWN 34 HALIFAX TOWN TEST 05,23/ " •J.'.JIJr.RiNO.i or n c rmsuir OISTRESSEO AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE TITLE 34 HCBGOOD TOWN 54 RCANOKE RAPIDS CITY 34 SCOTLAND NECK TOWN 34 WELDON TOWN 34 LITTLETON TOWN 34 AHOSKIE TOWN 34 WINTON TOWN 34 CCFIELD TOWN 34 CCMO TOWN 34 HARMONY TOWN 34 BENSON TOWN 34 KENLY TOWN 34 SELMA TOWN 34 MAYSVILLE TOWN 34 LINCOLNTON TOWN 34 HASSELL TOWN 34 JAMESVILLE TOWN 34 OAK CITY TOWM 34 PARMELE TCWN 34 ROBERSCNVILLE TOWN 34 WILLIAMSTON TOWN 34 BEARGRA5S TOWN 34 MOUNT GILEAC TOWN 34 STAR T W N 34 CCNWAY TOWN 34 GARYSBURG TOWN 34 GASTON TOWN 34 LASKER TOWN 34 RICH SQUARE TOWN 34 SEABOARO TOWN 34 SEVERN TOWN 34 WOODLAND TOWN 34 RICHLANDS TOWN 34 SWANSBORO TOWN 34 BAYBORO TOWN 34 ORIENTAL TOWN 34 VANDEMERE TOWN 34 ALLIANCE TOWN 34 ARAPAHOE TOWN 34 MESIC TOWN 34 MINNESOTT 3EACH TOWN 34 STONEWALL TOWN 34 ELIZABETH CITY 34 ATKINSON TOWN 34 WATHA TOWN 34 TOP SAIL BEACH TOWN P ""9° 05/2 3/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY FEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 34 RANDLEMAN TOWN 54 SEAGROVE TOWN 54 STALEY TOWN 34 ELLERBE TOWN 54 HAMLET CITY 54 ROCKINGHAM TOWN 54 HOFFMAN TOWN 54 NORMAN TOWN 54 FAIRMONT TOWN 54 LUMBERTCN CITY 34 ORRUM TOWN 34 PARKTON TOWN 34 PEMBROKE TOWN 34 PROCTCRVILLE TOWN 34 RED SPRINGS TOWN 34 ROWLAND TOWN 34 ST PAULS TOWN 34 MCOONALD TOWN 34 RAYNHAM TOWN 34 MAYODAN TOWN 34 EDEN CITY 34 CLEVELAND TOWN 34 EAST SPENCER TOWN 54 FAITH TOWN 54 FOREST CITY TOWN 54 SPINDALE TOWN 54 EAST LAURINBURG TOWN 54 GIBSON TOWN 54 LAURINBURG CITY 54 WAGRAM TOWN 54 AL8EMARLE CITY 54 NORWOOD TOWN 54 COLUMBIA TOWN 34 HENDERSCN CITY 34 MIDDLEeURG TOWN 34 WARRENTON TOWN 34 GCLDSBORO CITY 34 BURNSVILLE TOWN STATE = 34: 17b RECORDS PAGE131 TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE132 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE 35 35 35 35 35 35 35 35 35 35 35 55 55 55 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 55 55 55 55 55 55 55 55 TITLE KIDDER COUNTY MCHENRY COUNTY WING CITY OAWSON VILLAGE PETTI80NE VILLAGE ROBINSON CITY STEELE CITY TAPPEN CITY TUTTLE VILLAGE ANAMOOSE CITY BALFOUR CITY BERGEN VILLAGE BERWICK CITY OEERING VILLAGE DRAKE CITY GRANVILLE CITY KARLSRUHE CITY KIEF VILLAGE UPHAM CITY VELVA CITY CLEAR LAKE TOWNSHIP CROFTE TOWNSHIP ORISCOLL TOWNSHIP ECKLUND TOWNSHIP ESTHERVILLE TOWNSHIP FLORENCE LAKE TWP GLENVIEW TOWNSHIP HARRIETT TOWNSHIP HAZEL GROVE TOWNSHIP LEIN TOWNSHIP MORTON TOWNSHIP SIBLEY BUTTE TOWNSHIP STEIBER TOWNSHIP SCHRUNK TOWNSHIP TAFT TOWNSHIP WILSON TOWNSHIP HARDING TOWNSHIP MCCULLEY TOWNSHIP LARK TOWNSHIP ALLEN TOWNSHIP ATWOOO TOWNSHIP BAKER TOWNSHIP BUCKEYE TOWNSHIP BUNKER TOWNSHIP CHESTINA TOWNSHIP CLEAR LAKE TOWNSHIP GOVERNMENTS) 05/2 5/78 AT 3 1 : 2 5 U.S. DEPARTMENT PA5E183 OF THE TREASURY OISTRESSEO AREA ELIGIBILITY TE*ST (ELIGIBLE STATE 55 55 35 35 35 35 35 35 35 35 35 35 35 55 55 55 55 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 35 55 GOVERNMENTS) TITLE CROWN HILL T O W N S H I P C R Y S T A L SPRI NGS TOWNSHIP E X C E L S I O R TO WNSHIP F R E T T I M TOWN SHIP GRAF TOWNSHI P H A Y N E S TOWNS HIP LAKE WILLIAM S T O W N S H I P MANNING TOWN SHIP PEACE TOWNSH IP PETERSVILLE TOWNSHIP PETTI80NE TO WNSHIP REXINE TWP SI3LEY TOWNS HIP STEWART TOWN SHIP TANNER TOWNS HIP TUTTLE TOWNS HIP VALLEY TOWNS HIP WEISER TOWNS HIP W E S T F O R D TOW NSHIP W I L L I A M S TOW NSHIP QUINBY TOWNS HIP MERKEL TOWNS HIP NORTHWEST TO WNSHIP ANAMOOSE TOW NSHIP BALFOUR TOWN SHIP 3ANTRY TOWNS HIP BERWICK TOWN SHIP 3J0RNS0N TOW NSHI P BROWN TOWNSH IP COTTONWOOD L AKE TWP DEEP RIVER T O W N S H I P D E E R I N G TOWN SHIP EGG CREEK TO WNSHIP FALSEN TOWNS HIP G I L M O R E TOWN SHIP HENDRICKSCN TOWNSHIP KARLSRUHE TO WNSHIP KOTTKE VALLE Y T O W N S H I P LAKE GEORGE T O W N S H I P LAKE HESTER T O W N S H I P LAND TOWNSHI P L A Y T C N TOWNS HIP LE3AN0N TOWN SHIP LITTLE DEEP T O W N S H I P MOUSE RIVER T O W N S H I P NEWPORT TOWN SHIP 05/23/78 AT 3 1 : 2 5 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEtST (ELIGIBLE GOVERNMENTS) STATE 35 35 35 35 35 55 55 55 55 55 55 TITLE NORMAL T O W N S H I P ODIN T O W N S H I P PRATT TOWNSHIP RIGA TOWNSHIP ROUND LAKE T O W N S H I P SALINE T O W N S H I P SCHILLER T O W N S H I P VELVA TOWNSHIP VILLARD T O W N S H I P FAIRVIEW T O W N S H I P SLOPE CENTER TWP S T A T E = 35: 103 „ TREASURY t RECORDS PAGE134 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE185 OF THE DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE Sb ADAMS COUNTY 5b ALLEN COUNTY 5b ASHLAND COUNTY 5b ASHTABULA COUNTY 5b ATHENS COUNTY 5b BELMONT COUNTY 5b BUTLER COUNTY 3b CLARK COUNTY 3b COLUMBIANA COUNTY 3b COSHOCTON COUNTY Sb CRAWFORD COUNTY 5b CUYAHOGA COUNTY 5b DEFIANCE COUNTY 3b ERIE COUNTY Sb FAYETTE COUNTY 5b FULTON COUNTY 3b GREENE COUNTY 3b GUERNSEY COUNTY 3b HAMILTON COUNTY 3b HARDIN COUNTY 3b HOCKING COUNTY 3b HURON COUNTY Sb JACKSON COUNTY 5b KNOX COUNTY 5b LICKING COUNTY 5b LUCAS COUNTY 5b MAHONING COUNTY 3b MARION COUNTY 3b MIAMI COUNTY Sb MONROE COUNTY 5b MONTGOMERY COUNTY 5b MUSKINGUM COUNTY 5b NOBLE COUNTY 5b OTTAWA COUNTY 5b PAULDING COUNTY 5b PCRTAGE COUNTY 5b PREBLE COUNTY 5b PUTNAM COUNTY 5b RICHLAND COUNTY 5b RCSS COUNTY 5b SANDUSKY COUNTY 5b SCIOTO COUNTY 3b SENECA COUNTY 3b STARK COUNTY 3b SUMMIT COUNTY 3b TRUMBULL COUNTY TREASURY 0 5 / 2 5 / f 8 AT 3 1 : 2 5 U.S. DEPARTMENT PAGEIBb OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE Sb TUSCARAWAS COUNT Y Sb VAN MERT COUNTY Sb WARREN COUNTY ib WAYNE COUNTY Sb W I L L I A M S COUNTY Sb CHERKY FORK VILLAGE Sb W A N C H E S U R VILLAGE Sb P E E B L E S VILLAGE Sb RC1E VILLAGE 3b SEAMAN VILLAGE 5b NEST UNION VILLAGE 5b WINCHESTER VILLAGE 5b BEAVERDAM V I L L A G E Jb B L U F F T U N VILLAGE 3b C A I R O VILLAGE 5b H A R R O O VILLAGE 3b LAFAYETTE VILLAGE ib LIMA LITY 3b SPENCERVIL.E' VILLAGE 3b FCRT SHAWNEE VILLAGE 3b ASHLAND CITY 3b J E R C M E S V I L L E VILLAGE 36 MIFFLIN VILLAGE 3b P E R R Y S V I . L E VILLAGE 36 SAVANNAH VILLAGE 36 ASHTABULA CITY 3o CCNNEAUT CITY 36 JEFFERSON VILLAGE 36 RCCK CREEK VILLAGE 36 ALBANY VILLAGE 36 AMESVILLE VlLLAoE 36 A T H E N S CITY 36 BUCHTEL VILLAGE 3 6 3b CHAUNCEY VILLAGE 3b CCOLVILLE VILLAGE 3b G L O U S T E R VILLAGE Sb JACKSONVILLE ULAGE Sb NELSONVILLE CITY Sb TRIMBLE TILLAGE 56 TNKSTENR°VILL cf 5T Sb CITY MARYS Sb Sb "BARNESVILLE * l £ f, L VILLAGE Sb Sb TREASURY 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 3b 3b 3b Sb 5b 5b 5b 5b 5b 5b 5b 3b 3b 3b lb 5b 5b 5b 5b 5b 3b 3b 3b lb 5b 5b 3b 3b 3b PAGE187 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE BELLAIRE CITY BELMONT VILLAGE BRIDGEPORT VILLAGE BROOKSIOE VILLAGE FLUSHING VILLAGE HOLLOWAY VILLAGE MARTINS FERRY CITY POWHATAN POINT VILLAGE SHADYSIDE CITY FAYETTEVILLE VILLAGE MOUNT ORAB V I L L A G E RIPLEY V I L L A G E RUSSELLVILLE VILLAGE HAMILTON CITY JACKSONBURG VILLAGE MIDDLETOWN CITY MILLVILLE VILLAGE NEW MIAMI V I L L A G E OXFORD VILLAGE S E V E N MILE V I L L A G E SOMERVILLE VILLAGE T R E N T O N CITY DELLROY VILLAGE LEESVILLE VILLAGE SHERROUSVILLE VILLAGE CHRISTIANSiURG VILLAGE WCODSTOCK VILLAGE CATAW8A VILLAGE DCNNELSVILLE VILLAGE NORTH H A M P T O N V I L L A G E S P R I N G F I E L D CITY T R E M O N T CITY V I L L A G E COLUMBIANA VILLAGE EAST L I V E R P O O L C I T Y EAST P A L E S T I N E C I T Y L E E T O N IA V I L L A G E LISBON VILLAGE NEW W A T E R F O R D V I L L A G E ROGERS VILLAGE SALINEVILLE VILLAGE SUMMITVILLE VILLAGE WELLSVILLE CITY NELLIE VILLAGE B U C Y R U S CITY CHATFIELD VILLAGE C R E S T L I N E CITY TEST 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY FE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 3b GALION CITY Sb NEW WASHINGTON VILLAGE 5b TIRO VILLAGE 5b BEDFORD CITY 5b BEREA CITY 3b BROOK PARK CITY 3b CLEVELAND CITY 5b CUYAHOGA HGHTS VILLAGE 5b EAST CLEVELAND CITY 5b GARFIELD HGHTS CITY 5b LINNDALE VILLAGE 5b MAPLE HGHTS CITY 5b NEWBURGH HEIGHTS VILLAGE 5b SHAKER HGHTS CITY 5b SCUTH EUCLID CITY 5b VALLEY VIEW VILLAGE 5b WARRENSVILLE HGTS CITY 5b DEFIANCE CITY 3b HICKSVILLE VILLAGE 3b NEY VILLAGE 3b SHERWOOD VILLAGE Sb KELLEYS ISLAND VILLAGE 5b SANDUSKY CITY 5b MILLEOGEVILLE VILLAGE 5b OCTA VILLAGE 3b WASHINGTON CITY Sb ARCH80LD VILLAGE 5b DELTA VILLAGE 3b FAYETTE VILLAGE 3b LYONS VILLAGE Sb METAMORA VILLAGE 3b SWANTCN VILLAGE Sb WAUSECN VILLAGE 5b BURTON VILLAGE Sb 8ELLBR00K CITY Sb 6CWERSVILLE VILLAGE lb CEDARVILLE VILLAGE Sb CLIFTON VILLAGE Sb SPRING VALLEY VILLAGE 3b YELLOW SPRINGS VILLAGE Sb BYESVILLE VILLAGE 5b CAMBRIOGE CITY 5b CUMBERLAND VILLAGE lb FAIRVIEW VILLAGE 5b KIM80LT0N VILLAGE 5b LORE CITY VILLAGE PAGE188 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T D I S T R E S S E D AREA PAGE189 OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 3b PLEASANT CITY VILLAGE Sb QUAKER CITY VILLAGE 5b SALESVILLE V I L L A G E 5b SENECAVILLE VILLAGE 5b OLD W A S H I N G T O N V I L L A G E 5b ARLINGTON H G T S V I L L A G E 5b C H E V I O T CITY 5b CINCINNATI CITY Sb DEER PARK CITY 3b FAIRFAX V I L L A G E 3b GOLF MANOR V I L L A G E 3b GREENHILLS CITY 3b LCCKLAND C I T Y 3b MADEIRA CITY Sb MOUNT HEALTHY CITY 5b NORTH COLLEGE HILL CITY 5b NCRWOCD CITY 5b REAOING CITY 5b ST BERNARD C I T Y 5b SILVERTON CI TY STATE = 5b: 204 RECORDS TREASURY TEST 05/23/78 "U'.TEPARTMENT OF THE TREASURY OlSTRESSEO AREA ELIGIBILITY TElST IELIGIBLE GOVERNMENTS) STATE 3b TITLE TERRACE PARK VILLAGE STATE = 3b: 1 RECORDS 0 5 / 2 3/78 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 3b 3b Sb 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 3b 3b Sb 5b 5b 3b 3b 3b Sb 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b Sb 5b 5b 5b 5b 5b 5b 5b 5b PAGE191 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE W O O C L A W N V I L L A GE SPRINGDALE CIT Y BENTON RIDGE V I L L A G E JENERA V I L L A G E M O U N T B L A N C H A R D VILLAGE MCUNT CORY VIL L A G E VANLUE VILLAGE ALGER V I L L A G E DUNKIRK VILLAG FOREST VILLAGE K E N T O N CITY M C G U F F E Y V I L L A GE P A T T E R S O N VILL AGE DESHLER VILLAG E HOLGATE VILLAG E MCCLURE VILLAG E NAPOLEON CITY NEW BAVARIA VI LLAGE L A U R E L V I L L E VI L L A G E LCGAN CITY MURRAY CITY VI LLAGE G R E E N W I C H VILL AGE M C N R O E V I L L E VI L L A G E NEW L O N D O N VIL LAGE NCRTH FAIRFIEL D VILLAGE NORWALK CITY W I L L A R U CITY CCALTCN VILLAG J A C K S O N CITY OAK H I L L V I L L A GE WELLSTON CITY A M S T E R D A M VILL AGE BLOOMINGDALE V ILLAGE B R I L L I A N T VILL AGE D I L L O N V A L E VIL LAGE I R O N D A L E V I L L A GE NEW A L E X A N D R I A V I L L A G E S T R A T T O N VILLA GE GANN V I L L A G E C E N T E R B U R G V I L LAGE D A N V I L L E V I L L A GE FFEDERICKTOWN VILLAGE GAM8IER VILLAG E M A R T I N S B U R G VI L L A G E MOUNT VERNON C ITY G R A N D RIVER VI L L A G E TE'ST 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T D I S T R E S S E D AREA (ELIGIBLE GOVERNMENTS) STATE TITLE 5b NCRTH PERRY VILLAGE 5b WICKLIFFE CITY 5b CHESAPEAKE VILLAGE Sb COAL GROVE V I L L A G E 5b IRONTON CITY 5b KIRKERSVILLE VILLAGE 5b NEWARK CITY 5b ST L O U I S V I L L E V I L L A G E 5b UTICA VILLAGE 5b 8ERKEY VILLAGE 3b TCLEDC CITY 3b MIDWAY VILLAGE 3b SCUTH SOLON VILLAGE Sb BELOIT VILLAGE STATE = 3b: bD RECORDS OF THE TREASURY ELIGIBILITY TEST 0 5 / 2 3 / 7 8 AT 31:25 U.S. DEPARTMENT PAGE193 OF THE DISTRESSED AREA ELIGIBILITY TEfST (ELIGIBLE GOVERNMENTS) STATE TITLE 3b CAMPBELL CITY STATE = 5b: 1 RECORDS TREASURY PAGE194 05/23/78 « »/ypARTHENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 3b CRAIG BEACH VILLAGE 3b LOWELLVILLE VILLAGE 3b POLAND VILLAGE 3b SEBRING VILLAGE 3b STRUTHERS CITY 5b YCUNGSTOWN CITY 5b GREEN CAMP VILLAGE 5b MARION CITY 5b MORRAL VILLAGE 5b CASSTCWN VILLAGE 5b COVINGTON VILLAGE 5b LUDLOW FALLS VILLAGE 5b PIQUA CITY 5b POTSDAM VILLAGE 5b ANTIOCH VILLAGE 3b BEALLSVILLE VILLAGE Sb CLARINGTON VILLAGE 5b GRAYSVILLE VILLAGE 5b JERUSALEM VILLAGE 5b LEWISVILLE VILLAGE 5b MILTONSBURG VILLAGE 5b STAFFORD VILLAGE 3b WCOOSFIELD VILLAGE 3b CLAYTON VILLAGE Sb DAYTON CITY 5b FARMERSVILLE VILLAGE 3b KETTERING CITY 5b MIAMISBURG CITY 5b RIVERSIDE VILLAGE 5b VANDALIA CITY 5b MORAINE CITY 5b CHESTERVILLE VILLAGE 3b EDISON VILLAGE 3b SPARTA VILLAGE Sb ADAMSVILLE VILLAGE 5b FRAZEYSBURG VILLAGE 3b NEW CONCORD VILLAGE 3b NORWICH VILLAGE 3b PHILO VILLAGE 3b FULTONHAM VILLAGE 3b ZANESVILLE CITY Sb BATESVILLE VILLAGE 5b BELLE VALLEY VILLAGE 5b CALDWELL VILLAGE 5b OEXTER CITY VILLAGE 5b SARAHSVILLE VILLAGE 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT D I S T R E S S E D AREA PAGE195 OF THE ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 5b 5b 3b Sb 3b 3b Sb 5b 5b 5b 5b 5b 5b 3b 3b 3b 3b Sb 5b 5b 5b 5b 5b 5b 5b 5b 3b 3b 3b Sb 5b 5b 5b 5b 5b 5b 5b 3b 5b 5b 3b 3b 3b 3b Sb 5b TREASURY TITLE SUMMERFIELD V I L L A G E CLAY CENTER V I L L A G E ELMORE VILLA GE GENOA VILLAG E MARBLEHEAD V ILLAGE PORT CLINTON C I T Y PUT IN BAY V ILLAGE ROCKY RIDGE VILLAGE ANTWERP VILL AGE BROUGHTON VI LLAGE H A V I L A N O VIL LAGE MELROSE VILL AGE OAKWOOD VILL AGE PAULDING VIL LAGE PAYNE VILLAG E CORNING VILL AGE HEMLOCK VILL AGE SHAWNEE VILL AGE BEAVER VILLA GE BRADY LA<£ V ILLAGE HIRAM VILLAG E KENT CITY MANTUA VILLA GE RAVENNA CITY WINDHAM VILL AGE S T R E E T S B O R H CITY EATON CITY LEwISBURG VI LLAGE NEW PARIS VI L L A G E WEST ELKTCN VILLAGE WEST MANCHES TER VILLAGE BELMORE VILL AGE C L O V E R D A L E V ILLAGE C O L U M B U S GRO VE V I L L A G E DUPONT VILLA GE GLANDORF VIL LAGE L E I P S I C VILL AGE MILLER CITY V I L L A G E OTTOVILLE VI LLACE WEST LEIPSIC V I L L A G E BELLVILLE VI L L A G E BUTLER VILLA GE L U C A S VILLAG E MANSFIELD CI TY SHILOH VILLA GE ONTARIO VILL AGE TEST 05/2 3/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 3b 3b 5b 5b 5b 5b 5b 3b Sb 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 3b 3b 3b lb 5b 5b 5b 3b 3b 3b lb 3b 3b TITLE AOELPHI VILLAGE BAINBRIDGE VILLAGE C H I L L I C O T H E CITY CLARKSBURG V I L L A G E FRANKFORT V I L L A G E KINGSTON VILLAGE SCUTH SALEM V I L L A G E BURGOON V I L L A G E CLYDE VILLAGE F R E M O N T CITY GIBSONBURG V I L L A G E HELENA VILLAGE NEW BOSTON V I L L A G E OTWAY VILLAGE PORTSMOUTH C I T Y RARDEN VILLAGE SOUTH WEBSTER V I L L A G E ATTICA VILLAGE NEW RIEGEL V I L L A G E TIFFIN CITY LCCKINGTON C O R P O R A T I O N PORT J E F F E R S O N V I L L A G E SIDNEY CITY RUSSIA VILLAGE ALLIANCE CITY CANTON CITY LIMAVILLE V I L L A G E MASSILLON CITY MEYERS LAKE VILLAGE WAYNESBURG V I L L A G E AKRON CITY 8ARBERT0N CITY LAKEMORE V I L L A G E NORTHFIELO V I L L A G E MACEDCNIA CITY RICHFIELD V I L L A G E GIRARD CITY NEWTON F A L L S C I T Y STATE = 5b: 150 RECORDS PAGE19G OF THE TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE PAGE197 TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 3b TITLE WARREN CITY STATE = 3b: 1 RECORDS TEST 05/2 3/78 AT 3l:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST ELIGIBLE GOVERNMENTS) STATE 3b 3b 3b 5b 5b 5b 5b 3b 5b 5b 3b 3b 3b 3b lb lb 5b 5b 3b lb lb lb lb lb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb Sb lb TITLE YANKEE LAKE VILLAGE BALTIC VILLAGE 8ARNHILL VILLAGE OENNISON VILLAGE DOVER CITY GNADENHUTTEN VILLAGE MIOVALE VILLAGE MINERAL CITY VILLAGE NEWCOMERSTOWN VILLAGE NEW PHILADELPHIA CITY PORT WASHINGTON VILLAGE RCSWELL VILLAGE STONE CREEK VILLAGE STRASBURG VILLAGE SUGARCREEK VILLAGE TUSCARAWAS VILLAGE UHRICHSVILLE CITY ZCAR VILLAGE MILFORD CENTER VILLAGE ELGIN VILLAGE MIODLEPOINT VILLAGE OHIO CITY VILLAGE VAN WERT CITY VENEDOCIA VILLAGE WILLSHIRE VILLAGE WREN VILLAGE HAMOEN V I L L A J G E WILKESVILLE VILLAGE ZALESKI VILLAGE BUTLERVILLE VILLAGE HARVEYSBURG VILLAGE MAINEVILLE VILLAGE PLEASANT PLAIN VILLAGE SOUTH LE3AN0N VILLAGE WAYNESVILLE VILLAGE GELPRE CITY LOWELL VILLAGE LOWER SALEM VILLAGE MARIETTA CITY BURBANK VILLAGE CRESTON VILLAGE FREDEFICKS3URG VILLAGE MOUNT EATON VILLAGE ORRVILLE CITY WEST SALEM VILLAGE ALVORDTON VILLAGE TREASURY PAGE198 05/25/78 AT 3 1 : 2 5 U.S. DEPARTMENT PAGE199 OF DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 5b BLAKESLEE VILLAGE 5b 8RYAN CITY 5b EDGERTON VILLAGE 5b STRYKER V I L L A G E 5b CUSTAR VILLAGE 5b HCYTVILLE VILLAGE 3b MILTON CENTER VILLAGE 3b NORTH B A L T I M O R E V I L L A G E 3b PORTAGE VILLAGE 3b TCNTOGANY V I L L A G E lb WEST M I L L G R O V E V I L L A G E 5b BRATTON T O W N S H I P 5b BRUSH CREEK T O W N S H I P 5b FRANKLIN TOWNSHIP 3b GREEN TCWNSHIP lb JEFFERSON TOWNSHIP 5b LIBERTY TOWNSHIP 5b MANCHESTER T O W N S H I P 5b MEIGS TCWNSHIP 5b MONROE T O W N S H I P 5b OLIVER TOWNSHIP 5b SCOTT TOWNSHIP 3b SPRIGG T O W N S H I P 3b TIFFIN TOWNSHIP lb WAYNE TOWNSHIP 5b WINCHESTER TOWNSHIP 5b APANDA T O W N S H I P 5b AUGLAIZE TOWNSHIP 5b 3ATH T O W N S H I P 5b JACKSON TOWNSHIP 5b MONROE T O W N S H I P 5b PERRY TOWNSHIP 3b RICHLAND TOWNSHIP 5b SPENCER TOWNSHIP 5b SUGAR CREEK T O W N S H I P 5b C L E A R CREEK T O W N S H I P 5b VERMILLION TWP 3b ASHTABULA T O W N S H I P lb AUSTINBURG TOWNSHIP 5b C H E R R Y VALLEY T O W N S H I P 5b CCLEBROOK TOWNSHIP 5b DENMARK T O W N S H I P 5b JEFFERSON TOWNSHIP 5b LENOX T O W N S H I P 3b MONROE T O W N S H I P 3b MORGAN TOWNSHI** THE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE200 OF DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE lb 5b 5b 5b 5b 5b 5b 5b 3b lb 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b 5b lb TITLE PLYMOUTH T O W N S H I P SAYBROOK T O W N S H I P SHEFFIELD T O W N S H I P WINDSOR T C W N S H I P ALEXANDER TOWNSH IP AMES TOWNSHIP ATHENS TOWNSHIP BERN T O W N S H I P CANAAN TOWNSHIP CARTHAGE T O W N S H I P DOVER TOWNSHIP LEE TOWNSHIP LODI TOWNSHIP ROME TOWNSHIP TRIM3LE TOWNSHIP TROY TOWNSHIP WATERLOO T O W N S H I P YCRK TOWNSHIP GOSHEN TOWNSHIP LOGAN TOWNSHIP NOBLE TOWNSHIP ST MARYS T O W N S H I P SALEM TOWNSHIP CCLERAIN T O W N S H I P FLUSHING TOWNSHIP GOSHEN TOWNSHI^ KIRKWOOD TOWNSHIP MEAD TOWNSHIP PEASE TOWNSHIP PULTNEY TOWNSHIP SPITH TOWNSHIP SOMERSET T O W N S H I P UNION TOWNSHIP WARREN TOWNSHIP WASHINGTON T O W N S H I P WHEELING TOWNSHIP YORK TOWNSHIP PIKE TOWNSHIP PLEASANT T O W N S H I P UNION TOWNSHIP WASHINGTON T O W N S H I P H A N O V E R TOWNSHIP LEMON T O W N S H I P LIBERTY TOWNSHIP MADISON T O W N S H I P MILFORO T O W N S H I P THE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 3b MORGAN TOWNSHIP 3b OXFORD T O W N S H I P 3b REILY TOWNSHIP 3b RCSS T O W N S H I P 3b ST C L A I R T O W N S H I P 3b UNION TOWNSHIP lb WAYNE TOWNSHIP 5b EAST T O W N S H I P 5b FOX TOWNSHIP 5b HARRISON T O W N S H I P 5b LEE TOWNSHIP 5b MONROE TOWNSHIP 5b ORANGE TOWNSHIP 5b ROSE T O W N S H I P 5b UNION TOWNSHIP 3b ADAMS TOWNSHIP 3b CCNCORD TOWNSHIP 3b JACKSON T O W N S H I P 3b MAD RIVER T O W N S H I P lb SALEM TOWNSHIP 5b UNION TOWNSHIP 5b BETHEL TOWNSHI 1 * 5b MAD RIVER T O W N S H I P 5b PIKE T O W N S H I P 5b S P R I N G F I E L D TOWNSHIP 5b J A C K S O N TOWNSHIP 5b MONROE TOWNSHIP 5b WAYNE TOWNSHIP 5b BUTLER T O W N S H I P 5b CENTEP T O W N S H I P 5b ELKRUN TOWNSHIP 5b FAIRFIELD T O W N S H I P 5b FRANKLIN TOWNSHIP 5b HANOVER T O W N S H I P 5b KNOX T O W N S H I P 3b LIVERPOOL T O W N S H I P 3b MADISON T O W N S H I P 3b MIDDLETON T O W N S H I P 3b ST CLAIR T O W N S H I P 3b SALEM T C W N S H I P 3b UNITY TOWNSHIP 3b WASHINGTON T O W N S H I P 3b WAYNE TOWNSHIP lb WEST TOWNSHIP 5b YELLOW CREEK T O W N S H I P 5b BEOFORD TOWNSHIP PAGE201 OF THE TREASURY 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 5b 5b 5b 5b 3b lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb lb C L A R K TOWNSH IP N E W C A S T L E TO W N S H I P PERRY TOWNSH IP T I V E R T O N TOW N S H I P TUSCARAWAS T OWNSHIP VIRGINIA TOW N S H I P AUBURN TOWNS HIP B U C Y R U S TOWN SHIP C H A T F I E L D TO W N S H I P C R A N B E R R Y TO W N S H I P D A L L A S TOWNS HIP H C L M E S TOWNS HIP J A C K S O N TOWN SHIP L Y K E N S TOWNS HIP POLK TOWNSHI P S A N D U S K Y TOW N S H I P TEXAS TOWNSH IP TCO TOWNSHIP VERNON TOWNS HIP WHETSTONE TO WNSHIP D E F I A N C E TOW N S H I P DELAWARE TOW N S H I P HICKSVILLE T OWNSHIP MARK TOWNSHI P BERLIN TOWNS HIP OXFORD TOWNS HIP P E R K I N S TOWN SHIP C O N C O R D TOWN SHIP G R E E N TOWNSH IP JASPER TOWNS HIP MADISON TCWN SHIP PAINT TOWNSH IP PERRY TOWNSH IP UNION TOWNSH IP WAYNE TOWNSH IP AK80Y TOWNSH IP CHESTERFIELD TOWNSHIP C L I N T O N TOWN SHIP OCVER TOWNSH IP F R A N K L I N TOW N S H I P F U L T O N TOWNS HIP GERMAN TOWNS HIP GCRHAM TOWNS HIP PIKE TOWNSHI P ROYALTCN TOW NSHIP SWAN CREEK T O W N S H I P OF THE TREASURY PAGE202 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 3b YORK TOWNSHIP 3b PARKMAN T O W N S H I P 3b TROY TOWNSHIP lb BATH TOWNSHIP 3b BEAVER CREEK T O W N S H I P 3b C A E S A R S CREEK TWP 3b CEOARVILLE T O W N S H I P 3b JEFFERSON TOWNSHIP 3b MIAMI TOWNSHIP 3b ROSS T O W N S H I P lb SPRING VALLEY T O W N S H I P 5b SUGAR CREEK TOWNSHIP 5b XENIA TOWNSHIP 5b CAMBRIDGE T O W N S H I P 3b CENTER TOWNSHIP 3b JACKSON T O W N S H I P 3b JEFFERSON T O W N S H I P 5b KNOX T O W N S H I P 3b L I B E R T Y TOWNSHIP 3b L O N D O N D E R R Y TOWNSHIP 3b MADISON TOWNSHIP 3b MILLWOOD T O W N S H I P 5b MONROE TOWNSHIP 5b OXFORO TOWNSHIP 3b RICHLAND T O W N S H I P 3b SPENCER TOWNSHIP 3b VALLEY TOWNSHIP 3b WASHINGTON T O W N S H I P 3b WESTLAND T O W N S H I P 3b WHEELING T O W N S H I P 3b W I L L S TCWNSHIP lb COLUMBIA T O W N S H I P 5b G R E E N TOWNSHIP 5b WHITEWATER T O W N S H I P 5b BLANCHARD T O W N S H I P 5b MADISON T O W N S H I P 5b BLANCHARD T O W N S H I P 5b BUCK TOWNSHIP 5b CESSNA TOWNSHIP 5b JACKSON T O W N S H I P 3b MARION TOWNSHIP 3b WASHINGTON T O W N S H I P 3b NAPOLEON T O W N S H I P 3b PLEASANT T O W N S H I P lb BENTON TOWNSHIP 5b F A L L S TOWNSHIP PAGE203 OF THE TREASURY °5'23"8 'S.'SJ'SEHI.THC.I OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 5b GOOD HOPE TOWNSHIP 5b GREEN TOWNSHIP 5b LAUREL T O W N S H I ^ 5b MARION TOWNSHIP 5b PERRY TOWNSHIP 5b SALT CREEK T O W N S H I P 5b STARR TOWNSHIP 5b WARD TOWNSHIP 5b WASHINGTON T O W N S H I P 5b BRONSON TOWNSHIP 5b CLARKSFIELD T O W N S H I P 5b FITCHVILLE TOWNSHIP 5b GREENFIELD TOWNSHIP 5b GREENWICH T O W N S H I P 5b HARTLAND T O W N S H I P 3b NEW LONDON T O W N S H I P 5b NORWALK TOWNSHIP 5b NORWICH T O W N S H I P 5b PERU TOWNSHIP 5b RICHMOND T O W N S H I P 5b RIPLEY TOWNSHIP 5b SHERMAN TOWNSHIP 5b TOWNSEND T O W N S H I P 5b BLOOMFIELD T O W N S H I P 5b COAL T O W N S H I P 3b FRANKLIN T O W N S H I P 3b HAMILTON T O W N S H I P 3b JACKSCN T O W N S H I P lb JEFFERSON T O W N S H I P 3b LI8ERTY T O W N S H I P 3b LICK TOWNSHIP 5b MADISON T O W N S H I P 5b MILTON TOWNSHIP 5b SCIOTO T O W N S H I P 5b WASHINGTON T O W N S H I P 5b RCSS TOWNSHIP 5b SALINE TOWNSHIP 5b BERLIN TOWNSHIP 5b BROWN TOWNSHIP 5b BUTLER TOWNSHIP 5b CLAY TOWNSHIP 5b C L I N T O N TOWNSHIP 5b C O L L E G E TOWNSHIP 5b HARRISON T O W N S H I P 5b HILLIAR T O W N S H I P 5b HOWARD TOWNSHIP """"' 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE205 OF THE DISTRESSED AREA ELIGIBILITY TE»ST (ELIGIBLE GOVERNMENTS) STATE TITLE 3b JACKSON TOWNSHIP 3b JEFFERSON TOWNSHIP 3b LIBERTY TOWNSHIP Sb MIDDLEBURY TOWNSHIP 5b MILFORD TOWNSHIP 5b MILLER TOWNSHIP 5b MONROE TOWNSHIP 5b MORGAN TOWNSHIP 5b MORRIS TOWNSHIP 5b PIKE TOWNSHIP 5b PLEASANT TOWNSHIP 5b UNION TOWNSHIP 5b WAYNE TCWNSHIP 5b LEROY TOWNSHIP 5b PAINESVILLE TOWNSHIP 5b PERRY TOWNSHIP 5b HAMILTON TOWNSHIP 5b SYMMES TOWNSHIP 5b UPPER TOWNSHIP 5b BOWLING GREEN TOWNSHIP 5b HARRISON TOWNSHIP 5b LICKING TOWNSHIP 5b MCKEAN TOWNSHIP 5b UNION TOWNSHIP 5b WASHINGTON TOWNSHIP 5b HARDING TOWNSHIP 5b PROVIDENCE TOWNSHIP 5b RICHFIELD TOWNSHIP 5b SPENCER TOWNSHIP 5b DEER CREEK TOWNSHIP 5b FAIRFIELD TOWNSHIP 5b MONROE TOWNSHIP 5b OAK RUN TCWNSHIP 5b PAINT TOWNSHIP 5b RANGE TOWNSHIP 5b SOMERFORD TOWNSHIP 5b STOKES TOWNSHIP 5b UNION TOWNSHIP 5b AUSTINTOWN TOWNSHIP 5b BEAVER TOWNSHIP Sb BERLIN TOWNSHIP Sb COITSVILLE TOWNSHIP 3b ELLSWORTH TOWNSHIP Sb GOSHEN TOWNSHIP 5b GREEN TOWNSHIP 5b JACKSON TOWNSHIP TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE20G OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 5b MILTON TOWNSHIP 3b POLAND TOWNSHIP Sb SMITH TOWNSHIP 5b BIG ISLAND TOWNSHIP 5b BOWLING GREEN TOWNSHIP 5b GREEN CAMP TOWNSHIP 5b MARION TOWNSHIP 5b PLEASANT TOWNSHIP 5b SALT ROCK TOWNSHIP 5b LAFAYETTE TOWNSHIP 5b BETHEL TOWNSHIP 5b BROWN TCWNSHIP 5b ELIZABETH TOWNSHIP 5b NEWBERRY TOWNSHIP 5b NEwTON TOWNSHIP 5b SPRING CREEK TOWNSHIP 5b STAUNTON TOWNSHIP 5b WASHINGTON TOWNSHIP 5b ADAMS TOWNSHIP 3b BENTON TOWNSHIP 3b BETHEL TOWNSHIP 3b CENTER TOWNSHIP 3b FRANKLIN TOWNSHIP Sb GREEN TOWNSHIP 5b JACKSON TOWNSHIP 5b LEE TOWNSHIP 5b MALAGA TOWNSHIP 5b OHIO TOWNSHIP 5b PERRY TOWNSHIP 5b SALEM TOWNSHIP 5b SUMMIT TOWNSHIP 5b SUNS8URY TOWNSHIP 5b WASHINGTON TOWNSHIP 5b WAYNE TOWNSHIP 5b BUTLER TOWNSHIP 5b JACKSON TOWNSHIP 5b JEFFERSON TOWNSHIP 5b MADISON TOWNSHIP 5b MAD RIVER TOWNSHIP 5b MIAMI TOWNSHIP 5b ADAMS TOWNSHIP 5b BLUE ROCK TOWNSHIP 5b BRUSH CREEK TOWNSHIP 5b CLAY TOWNSHIP 5b HARRISON TOWNSHIP 5b HOPEWELL TOWNSHIP TREASURY 0 5 / 2 5 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE207 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 5b JACKSON TOWNSHIP 5b MAOISON T O W N S H I P 5b M E I G S TOWNSHIP 5b NEWTON TOWNSHIP 5b SALEM T O W N S H I P 5b SALT CREEK T O W N S H I P 5b SPRINGFIELD TOWNSHIP 5b UNION TOWNSHIP 5b WASHINGTON TOWNSHIP 5b WAYNE TOWNSHIP 3b BEAVER TOWNSHIP 3b BROOKFIELD TOWNSHIP Sb BUFFALO TOWNSHIP 5b CENTER TOWNSHIP 5b ELK TOWNSHIP 5b ENOCH TOWNSHIP 5b J A C K S O N TOWNSHIP 5b JEFFERSON T O W N S H I P 5b MARION TOWNSHIP 5b NCBLE TCWNSHIP 5b OLIVE TOWNSHIP 5b SENECA TOWNSHIP 5b SHARON TOWNSHIP 5b STOCK T O W N S H I P 5b ALLEN T O W N S H I P 5b BAY TOWNSHIP 5b BENTON TOWNSHIP 5b CARROLL TOWNSHIP 5b CATAWBA ISLAND T O W N S H I P 5b CLAY T O K N S H I P 5b DANBURY TOWNSHIP 5b ERIE T O W N S H I P 5b HARRIS TOWNSHIP 5b PORTAGE T O W N S H I P 5b PUT IN BAY T O W N S H I P 5b SALEM T O W N S H I P 5b BROWN TOWNSHIP 5b CRANE T O W N S H I P 5b PAULDING T O W N S H I P 5b WASHINGTON T O W N S H I P 5b MONROE TOWNSHIP 5b JACKSON TOWNSHIP 5b PEE PEE T O W N S H I P 5b PERRY TCWNSHIP 5b SCIOTO T O W N S H I P 5b ATWATER T O W N S H I P TREASURY PAGE208 1 05/23/78 A I j l - . J ^ ^ ^ Qp DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 3b BRIMFIELD TOWNSHIP 5b CHARLESTOWN T O W N S H I P 5b DEERFIELD T O W N S H I P 5b EDINBURG T O W N S H I P 5b FRANKLIN T O W N S H I P 5b FREEDOM TOWNSHIP 5b HIRAM TOWNSHIP 3b MANTUA TOWNSHIP 3b NELSON TOWNSHIP 3b PALMYRA TOWNSHIP 3b PARIS TOWNSHIP 3b RANDOLPH T O W N S H I P 5b RAVENNA T O W N S H I P 5b ROOTSTOWN T O W N S H I P 5b SHALERSVILLE< T O W N S H I P 5b SUFFIELD T O W N S H I P 5b WINDHAM TOWNSHIP 5b HARRISON T O W N S H I P 5b JEFFERSON TOWNSHIP 5b LANIER TOWNSHIP 5b TWIN TOWNSHIP 5b JENNINGS T O W N S H I P 5b MONTEREY T O W N S H I P 5b OTTAWA TCWNSHIP 3b PALMER TOWNSHIP 3b PERRY TOWNSHIP 3b PLEASANT T O W N S H I P 5b VAN BUREN TOWNSHIP 5b CASS TOWNSHIP 5b FRANKLIN T O W N S H I P 5b MAOISON T O W N S H I P 5b SANDUSKY T O W N S H I P 5b SHARON TOWNSHIP 5b SPRINGFIELD T O W N S H I P 5b BUCKSKIN T O W N S H I P 5b COLERAIN T O W N S H I P 5b CCNCORO TOWNSHIP 5b DEERFIELD T O W N S H I P 5b FRANKLIN T O W N S H I P 5b GREEN TOWNSHIP 5b HARRISON T O W N S H I P 5b HUNTINGTON T O W N S H I P 3b JEFFERSON TOWNSHIP Sb LIBERTY TOWNSHIP 5b PAINT TOWNSHIP 5b PAXTON TOWNSHIP ^ TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT PAGE209 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE Sb SCIOTO TOWNSHIP 5b SPRINGFIELD TOWNSHIP 3b TWIN T O W N S H I P 3b UNION TCWNSHIP 3b BALLVILLE T O W N S H I P Sb G R E E N CREEK T O W N S H I P 5b JACKSON TOWNSHIP 3b MAOISON T O W N S H I P Sb RICE TOWNSHIP 5b RILEY T O W N S H I P 5b SANDUSKY T O W N S H I P 5b TCWSEND TOWNSHIP 5b WASHINGTON T O W N S H I P 5b YCRK T O W N S H I P 5b BLOOM TOWNSHIP 5b BRUSH CREEK T O W N S H I P 5b CLAY TOWNSHIP 5b G R E E N TOWNSHIP 5b HARRISON TOWNSHIP 5b JEFFERSON T O W N S H I P lb MADISON T O W N S H I P lb MORGAN T O W N S H I P 5b NILE TOWNSHIP 5b PORTER TOWNSHIP 5b RARDEN T O W N S H I P 5b RUSH TOWNSHIP 5b UNION TOWNSHIP 5b VALLEY TOWNSHIP 5b VERNON T O W N S H I P 5b WASHINGTON T O W N S H I P 5b ADAMS TOWNSHIP 5b BIG SPRING T O W N S H I P 5b REED T O W N S H I P 5b SENECA TOWNSHIP 5b CLINTCN TOWNSHIP 5b LCRAMIE T O W N S H I P 5b PERRY TOWNSHIP 5b WASHINGTON T O W N S H I P 5b CANTON TOWNSHIP 5b LEXINGTON T O W N S H I P 5b MARLBORO T O W N S H I P 5b COVENTRY T O W N S H I P 5b FRANKLIN TOWNSHIP 5b RICHFIELD T O W N S H I P 5b SPRINGFIELD TOWNSHIP 5b BLOOMFIELO T O W N S H I P TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE210 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 5b 8RACEVILLE TOWNSHIP 5b CHAMPION TOWNSHIP 5b GREENE TOWNSHIP 5b HOWLANO TOWNSHIP 3b MESOPOTAMIA TOWNSHIP 3b NEWTON TOWNSHIP 3b WARREN TOWNSHIP 5b WEATHERSFIELD TOWNSHIP 5b AUBURN TOWNSHIP 5b BUCKS TOWNSHIP 5b CLAY TOWNSHIP 5b OOVER TOWNSHIP 5b FAIRFIELD TOWNSHIP 5b FRANKLIN TOWNSHIP 5b GCSHEN TOWNSHIP 5b JEFFERSON TOWNSHIP 5b MILL TOWNSHIP 5b OXFORD TOWNSHIP 5b PERRY TOWNSHIP 5b RUSH TOWNSHIP 5b SALEM TOWNSHIP 5b SANDY TOWNSHIP 5b SUGAR CREEK TOWNSHIP 3b UNION TOWNSHIP 3b WARREN TOWNSHIP 3b WARWICK TCWNSHIP 3b WASHINGTON TOWNSHIP 3b WAYNE TOWNSHIP lb HARRISON TOWNSHIP 5b JACKSON TOWNSHIP 5b JENNINGS TOWNSHIP 3b LIBERTY TOWNSHIP 3b PLEASANT TOWNSHIP 3b WASHINGTON TOWNSHIP 3b WILLSHIRE TOWNSHIP 3b YORK TOWNSHIP 3b BROWN TCWNSHIP lb CLINTON TOWNSHIP 5b EAGLE TOWNSHIP 5b MAOISON TOWNSHIP 5b WILKESVILLE TOWNSHIP 5b HAMILTON TWP 5b HARLAN TOWNSHIP 5b MASSIE TOWNSHIP 5b TURTLE CREEK TOWNSHIP 3b UNION TOWNSHIP TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT OISTRESSEO AREA (ELIGIBLE GOVERNMENTS) STATE TITLE 3b ADAMS TOWNSHIP 3b GRANOVIEW T O W N S H I P lb INDEPENDENCE TOWNSHIP 5b LIBERTY T O W N S H I P 5b LUOLOW T O W N S H I P 5b SALEM TOWNSHIP 5b WATERTOWN T O W N S H I P 5b CANAAN T O W N S H I P 5b CLINTON TOWNShIP 5b CCNGRESS TOWNSHIP 5b EAST UNION T O W N S H I P 5b MILTON TOWNSHIP 5b PAINT TOWNSHIP 5b SALT CREEK T O W N S H I P 3b JEFFERSON TOWNSHIP 3b MILL CREEK T O W N S H I P lb NORTHWEST T O W N S H I P 5b ST JOSEPH T O W N S H I P 5b SPRINGFIELD TOWNSHIP 5b SUPERIOR TOWNSHIP 5b MILTON TOWNSHIP 5b WEBSTER TOWNSHIP STATE = 5b: b20 RECORDS PAGE211 OF THE TREASURY ELIGIBILITY TEIST 05/25/78 AT 31:25 U.S. DEPARTMENT PAGE212 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 57 ATOKA COUNTY 57 CHOCTAW COUNTY 57 CCAL COUNTY 57 CRAIG COUNTY 57 GREER COUNTY 57 HARMON COUNTY 57 HASKELL COUNTY 57 HUGHES COUNTY 57 JACKSON COUNTY 57 KIOWA CCUNTY 57 LATIMER COUNTY 57 MURRAY COUNTY 57 OKFUSKEE COUNTY 57 OKMULGEE COUNTY 57 OTTAWA COUNTY 17 PITTSBURG COUNTY 57 PUSHMATAHA COUNTY 57 ATOKA CITY 57 CANEY TOWN 57 STRINGTOWN TOWN 57 TUSHKA TOWN 57 ANADARKO CITY 57 BRIDGEPORT CITY 57 CARNEGIE TOWN 57 CEMENT TOWN 57 CYRIL TCWN 57 HEALDTON TOWN 57 WILSON CITY 57 TATUMS TOWN 37 TAHLEQUAH CITY 37 BCSWELL TOWN 17 FCRT TOWSON TOWN 17 HUGO CITY 37 SCPER TOWN 17 CENTRAHOMA CITY 57 CCALGATE CITY 57 LEHIGH CITY 57 PHILLIPS TOWN 57 TUPELC CITY 57 DEVOL CITY 57 BLUEJACKET TOWN 57 ELMORE CITY TOWN 17 MAYSVILLE TOWN 17 WYNNEWOCD CITY 57 GRANITE CITY 37 WILLOW TOWN TREASURY 05/23/78 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TE«ST (ELIGIBLE GOVERNMENTS) STATE TITLE 17 GOULD TOWN 57 B U F F A L O TOWN 37 LAVERNE TOWN 17 MAY TOWN 57 KINTA TOWM 37 M C C U R T A I N TOWN 37 S T I G L E R CITY 37 TAMAHA TOWN 37 CALVIN TOWN 37 D U S T I N TOWN 37 GERTY TOWN 37 LAMAR TOWN 37 STUART TOWN 17 WETUMKA CITY 57 YEAGER TOWN 57 BLAIR TOWN 57 DUKE TOWN 57 ELMER TOWN 57 O L U S T E E TCWN 57 RYAN CITY 57 TERRAL TOWN 57 K I L D A R E TOWN 57 NARDIN TOWN 57 NEWKIRK CITY 57 GCTEBO TOWN 57 HCBART CITY 57 LONE WCLF TOWN 57 MOUNTAINVIEW 57 ROOSEVELT TOwN 57 SNYDER TOWN 57 RED OAK TCWN 37 G A R V I N TOWN 37 HAWORTH TOWN 37 CHECOTAH CITY 37 EUFAULA CITY 37 HANNA TOWN 37 MADILL CITY 57 D O U G H E R T Y TOWN 57 S U L P H U R CITY 57 H I C K O R Y TCWN 57 DELAWARE TOWN 57 L E N A P A H TOWN 57 30LEY TOWN 57 CASTLE TOWN 57 OKEMAH CITY 57 PADEN TCWN PAGE213 OF THE TREASURY 05/2 3/78 AT 31:25 U.S. D E P A R T M E N T OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 37 37 17 S7 37 57 57 57 57 57 57 57 57 S7 S7 37 37 37 37 37 57 57 57 37 37 37 37 57 57 57 57 57 57 57 57 TITLE WELEETKA CITY MIDWEST CITY CIT BEGGS CITY BRYANT TOWN DEWAR CITY HENRYETTA CITY HOFFMAN TOWN MORRIS CITY OKMULGEE CITY GRAYSON TOWN COMMERCE CITY PICHER CITY QUAPAW TOWN WYANDOTTE TOWN PEORIA TOWN BLACKBURN TOWN MARAMEC TOWN SKEOEE TOWN ALDERSON TOWN ASHLAND TOWN CANADIAN TOWN CROWDER TOWN HAILEYVILLE CITY HARTSHORNE CITY INDIANOLA TOWN KIOWA TOWN KREBS CITY MCALESTER CITY PITTSBURG TOWN QUINTON TOWN SAVANNA TOWN BYNG TOWN ALBION TOWN ANTLERS TOWN CLAYTON TOWN STATE = 57: 127 RECORDS TEST 0 5 / 2 5 / 7 8 AT 31:25 U.S. D E P A R T M E N T OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 37 RATTAN TOWN STATE = 37: 1 RECORDS PAGE215 TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T PAGE21G OF THE TREASURY D I S T R E S S E D AREA E L I G I B I L I T Y (ELIGIBLE GOVERNMENTS) STATE TITLE 37 KONAWA TOWN 37 SASAKWA TOWN 37 WEWOKA CITY 37 MARBLE CITY TCWN 37 MCFFETT TOWN 57 PARADISE HILL TOWN 57 TEXHOMA TOWN 57 GRANDFIELD CITY 37 HOLLISTER TOWN STATE = 37: 9 RECORDS TEST 05/23/78 AT 31:25 U.S. DEPARTMENT DISTRESSED TREASURY AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 38 BAKER COUNTY 38 CLATSOP COUNTY 38 COOS COUNTY 38 GRANT COUNTY 38 LAKE COUNTY 38 WASCO COUNTY 58 WHEELER COUNTY 58 BAKER CITY 58 HAINES TOWN 38 HALFWAY TOWN 38 RICHLANO TOWN 58 SUMPTER CITY 58 UNITY CITY 58 GREENHORN CITY 58 ASTORIA CITY 58 GEARHART CITY 58 HAMMOND TOWN 58 SEASIDE CITY 58 BANDON CITY 58 COOS BAY CITY 58 COOUILLE CITY 58 EASTSIDE CITY 58 MYRTLE POINT CITY 58 POWERS CITY 58 LAKESIDE CITY 58 PORT ORFJRO CITY 58 DAYVILLE TOWN 58 LCNG CREEK TOWN 58 SENECA CITY 58 LAKEVIEW TOWN 58 PAISLEY TCWN 38 NYSSA CITY 38 JORDAN VALLEY TOWN 38 GARIBALDI CITY 38 NEHALEM TOWN 38 ANTELOPE CITY 38 MAUPIN TOWN 38 THE DALLES CITY 56 FOSSIL TOWN 58 MITCHELL TOWN 58 SPRAY TOWN STATE = 58: 41 RECORDS PAGE217 OF THE 0 5 / 2 3 / 7 8 AT 31:25 U.S. DEPARTMENT PAGE218 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 ADAMS COUNTY 39 ARMSTRONG COUNTY 39 BEDFORD COUNTY 39 BERKS COUNTY 39 BLAIR COUNTY 39 BRADFORD COUNTY 39 6UTLER COUNTY 39 CAMBRIA COUNTY 39 CAMERON COUNTY 39 CARBON COUNTY 39 CLEARFIELD COUNTY 39 CLINTON COUNTY 39 COLUMBIA COUNTY 39 CRAWFORD COUNTY 39 DELAWARE COUNTY 39 ELK COUNTY 59 ERIE COUNTY 59 FAYETTE COUNTY 39 FOREST COUNTY 39 FRANKLIN COUNTY 39 FULTON COUNTY 39 GREENE COUNTY 39 HUNTINGDON COUNTY 39 JUNIATA COUNTY 39 LACKAWANNA COUNTY 39 LAWRENCE COUNTY 59 LUZERNE COUNTY 59 LYCOMING COUNTY 39 MCKEAN COUNTY 39 MERCER COUNTY 39 MIFFLIN COUNTY 39 MCNROE COUNTY 39 MONTGOMERY COUNTY 39 MONTOUR COUNTY 39 NORTHUMBERLAND COUNTY 39 POTTERCOUNTY 39 SCHUYLKILL COUNTY 39 SOMERSET COUNTY 39 SULLIVAN COUNTY 59 TIOGA COUNTY 59 VENANGO COUNTY 59 WARREN COUNTY 39 WASHINGTON COUNTY 39 WAYNE COUNTY 39 WESTMORELAND COUNTY 39 WYOMING COUNTY TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 AB80TTST0WN BOROUGH 39 BENDERSVILLEi BOROUGH 39 BIGLERVILLE BOROUGH 39 EAST BERLIN BOROUGH 39 FAIRFIELD 30R0UGH 39 GETTYSBURG BOROUGH 39 LITTLESTOWN BCROUGH 39 MCSHERRYSTOWN BOROUGH 59 NEW OXFORD BOROUGH 59 YORK SPRINGS BOROUGH 59 BCNNEAUVILLEi BOROUGH 59 CARROLL VALLEY BORO 59 AVALON BOROUGH 59 BALDWIN 30R0UGH 59 BLAWNOX BOROUGH 59 8RACKENRIDGE BOROUGH 59 BRADDOCK BOROUGH 59 BRADDOCK HILLS BOROUGH 59 CASTLE SHANNON BOROUGH 59 CCRAOPOLIS BOROUGH 59 CRAFTON BOROUGH 59 DCRMONT 30R0UGH 59 E PITTSBURGH BOROUGH 59 ELIZABETH 30R0UCH 59 EMSWORTH BOROUGH 59 ETNA BOROUGH 59 HOMESTEAO BOROUGH 59 INGRAM BOROUGH 59 MCKEESPORT CITY 59 MCKEES ROCKS BOROUGH 59 MILLVALE BOROUGH 59 MOUNT OLIVER BOROUGH 59 NORTH BRADDOCK BOROUGH 59 PITCAIRN BOROUGH 59 PITTSBURGH CITY 59 RANKIN BOROUGH 59 SHARPS8URG BOROUGH 59 SPRINGDALE BOROUGH 59 SWISSVALE BOROUGH 59 TARENTUM BOROUGH 59 VERONA BOROUGH 59 VERSAILLES BOROUGH 59 WEST VIEW BOROUGH 59 WHITAKER BOROUGH 59 WILMEROING BOROUGH 59 LINCOLN BOROUGH PAGE219 TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 SEWICKLEY HILLS BOROUGH 39 HAYSVILLE BOROUGH 39 APOLLO BOROUGH 39 APPLEWOLD BOROUGH 39 DAYTON BOROUGH 39 ELDERTON BOROUGH 39 FORD CITY 30R0UGH 39 FORD CLIFF BOROUGH 39 KITTANNING 80R0UGH 39 LEECHBURG 30R0UGH 39 MANORVILLE BOROUGH 39 NCRTH APOLLO, BOROUGH 39 PARKER CITY 39 RURAL VALLEY BOROUGH 39 SCUTH BETHLEHEM BOROUGH 39 WEST KITTANNING BOROUGH 39 WCRTHINGTON BOROUGH 39 BEAVER FALLS CITY 39 BRIDGEWATER 3CR0UGH 39 EAST ROCHESTER BOROUGH 39 FALLSTON BOROUGH 39 HCMEWOOD BOROUGH 39 KOPPEL BOROUGH 39 NEW BRIGHTON BOROUGH 39 SHIPPINGPORT 80R0UGH 39 8IG BEAVER BOROUGH 39 BEDFORD 30R0UGH 39 CCALDALE BOROUGH 39 EVERETT 30R0UGH 39 HOPEWELL BOROUGH 39 HYNDMAN 30R0UGH 39 MANNS CHOICE BOROUGH 39 NEW PARIS BOROUGH 39 PLEASANTVILLE 30R0UGH 39 RAINS8URG 30R0UGH 39 ST CLAIRSVILLE BOROUGH 39 SAXTON BOROUGH 39 SCHELLSBURG BOROUGH 39 W0008URY BOROUGH 39 CENTERPORT BOROUGH 39 LAURELDALE BOROUGH 39 LENHARTSVILLE BOROUGH 39 LYONS 80R0UGH 39 MOHNTON 30R0UGH 59 READING CITY 59 ST LAWRENCE BOROUGH PAGE220 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 SHOEMAKERSVILLE BOROUGH 39 STRAUSSTOWN BOROUGH 39 ALTOONA CITY 39 8ELLW00D BOROUGH 39 DUNCANSVILLE BOROUGH 39 HCLLI0AYS3URG 30R0UGH 39 MARTINSBJRG 3CR0UGH 39 NEWRY 80R0UGH 39 ROARING SPRING BOROUGH 39 TYRONE BOROUGH 39 WILLIAMS3URG BOROUGH 39 ALBA BOROUGH 39 ATHENS BOROUGH 39 BURLINGTON BOROUGH 39 CANTON BOROUGH 39 LE RAYSVILLE BOROUGH 39 MONROE BOROUGH 39 NEW ALBANY BOROUGH 39 ROME BOROUGH 39 SAYRE 30R0UGH 39 SCUTH WAVERLY BOROUGH 39 SYLVANIA BOROUGH 39 TOWANDA BOROUGH 39 TROY BOROUGH 39 WYALUSING BOROUGH 39 BRISTOL BOROUGH 39 MORRISVILLE BOROUGH 39 PENNDEL BOROUGH 39 RICHLANDTOWN BOROUGH 39 TRUMBAUERSVILLE BOROUGH 39 BRUIN BOROUGH 39 BUTLER CITY 39 CALLERY 30R0UGH 39 CHERRY VALLEY BOROUGH 39 CCNNOCUENESSING BOROUGH 39 EAST BUTLER 30R0UGH 39 EAU CLAIRE BOROUGH 39 EVANS CITY BOROUGH 39 FAIRVIEW BOROUGH 39 HARMONY BOROUGH 39 HARRISVILLE BOROUGH 39 KARNS CITY BOROUGH 39 MARS BOROUGH 39 PETROLIA BOROUGH 39 PCRTERSVILLE BOROUGH 39 PROSPECT BOROUGH PAGE221 05/2 3/78 AT 31:25 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 59 59 59 59 59 59 59 59 59 39 39 PAGE222 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE SLIPPERY ROCK BOROUGH VALENCIA BOROUGH WEST LIBERTY BOROUGH WEST SUN3URY BOROUGH ZELIENOPLE BOROUGH CHICORA 30R0UGH ASHVILLE BOROUGH BARNES80RC BOROUGH BROWNSTOWN BOROUGH CARROLLTOWN 30R0UGH CASSANDRA BOROUGH CHEST SPRINGS BOROUGH CRESSON BOROUGH OAISYTOWN 30R0UGH DALE BOROUGH EAST CONEMAUGH BOROUGH EBENSBURG 30RCUGH FERNDALE BOROUGH GALLITZIN BOROUGH GEISTCWN BOROUGH HASTINGS BOROUGH JOHNSTOWN CITY LILLY BOROUGH LCRAIN BOROUGH LCRETTO BOROUGH NANTY GLO BOROUGH PATTON BOROUGH PORTAGE BOROUGH SANKERTOWN BOROUGH SCALP LEVEL BOROUGH SOUTH FORK BOROUGH SOUTHMONT BOROUGH SPANGLER BOROUGH SUMMERHILL BOROUGH TUNNELHILL BOROUGH VINTQNDALE BOROUGH WESTMONT BOROUGH WILMORE BOROUGH EHRENFELD 30R0UGH DRIFTWOOD BOROUGH EMPORIUM BOROUGH BEAVER MEADOWS BOROUGH JIM THORPE BOROUGH LANSFORO BOROUGH LEHIGHTON BOROUGH PALMERTON BOROUGH TEST 05/23/78 AT 01:25 U.S. DEPARTMENT PAGE223 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 PARRYVILLE BOROUGH 39 SUMMIT HILL 3OR0UGH 39 WEISSPORT 30R0UGH 39 NESQUEHONING BOROUGH 39 BELLEFONTE BOROUGH 39 HOWARD BOROUGH 39 MILESBUR5 30R0UGH 39 MILLHEIM BOROUGH 39 PHILIPSBURG 80R0UGH 39 PCRT MATILDA BOROUGH 39 SNOW SHOE BOROUGH 39 S PHILIPSBURG BOROUGH 39 U M O N V I L L E BOROUGH 39 AVQNDALE BOROUGH 39 COATESVILLE CITY 39 MOUENA BOROUGH 39 OXFORD BOROUGH 39 8RISBIN BOROUGH 39 CHESTER HILL BOROUGH 39 CLEARFIELD BOROUGH 39 COALPORT BOROUGH 39 CURWENSVILLE BOROUGH 59 OU 80IS CITY 59 GLEN HOPE 3DR0UGH 59 GRAMPIAN BOROUGH 59 HOUTZDALE 30RCUGH 59 IRVONA BOROUGH 59 MAHAFFEY BOROUGH 59 NEWBURG 30R0UGH 59 NEW WASHINGTON 80R0UGH 39 OSCEOLA BOROUGH 39 RAMEY BOROUGH 39 TROUTVILLE BOROUGH 39 WALLACETON BCROUGH 39 WESTOVER BOROUGH 39 AVIS BOROUGH 39 BEECH CREEK 30R0UGH 39 FLEMINGTON 80R0UGH 39 LCCK HAVEN CITY 39 LOGANTON BOROUGH 39 MILL HALL BOROUGH 39 RENOVO BOROUGH 39 SCUTH RENOVO BOROUGH 39 BENTON BOROUGH 39 BERWICK BOROUGH 39 BL00MS8URG TOWN TREASURY 05/23/76 AT 31:25 U.S. DEPARTMENT PAGE224 OF THE DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 BRIAR CREEK BOROUGH 39 CATAWISSA BOROUGH 59 CENTRALIA BOROUGH 59 MILLVILLE 30R0UGH 59 ORANGEVILLE BOROUGH 59 STILLWATER BOROUGH 59 BLOOMING VALLEY 80R0UGH 59 CAMBRIDGE SPRGS BOROUGH 59 CENTERVILLE 30R0UGH 59 COCHRANTON BOROUGH 59 CCNNEAUT LAKE BOROUGH 59 CCNNEAUTVILLE 80R0UGH 59 HYOETOWN BOROUGH 59 LINESVILLE BOROUGH 59 MEADVILLE CITY 59 SAEGERTOWN BOROUGH 59 SPARTANS3URG BOROUGH 59 SPRING3CR0 BOROUGH 39 TITUSVILLE CITY 39 TOWNVILLE 30R0UGH 39 VENANGO 30R0UGH 39 WOODCOCK BOROUGH 39 BERRYS8UPG BOROUGH 39 ELIZABETHVILLE BOROUGH 39 HALIFAX BOROUGH 39 HARRIS8URG CITY 39 LYKENS BOROUGH 59 MILLERSBURG 30R0UGH 59 WILLIAMSTOWN BOROUGH 59 BROOKHAVEN BOROUGH 59 CHESTER CITY 59 CLIFTON HEIGHTS BOROUGH 59 COLLINGDALE BOROUGH 59 COLWYN BOROUGH 59 DARBY BOROUGH 59 EAST LANSDOWNE BOROUGH 39 EODYSTONE BOROUGH 39 FCLCRCFT BOROUGH 39 GLENOLDEN 30R0UGH 39 LANSDCWNE BOROUGH 39 MARCUS HOOK BOROUGH 39 MEDIA BOROUGH 39 MILLBOURNE BOROUGH 39 MORTON BOROUGH 39 NORWOOD BOROUGH 39 PARKSIOE BOROUGH TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE 266-274 O - 78 - 19 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 TITLE PROSPECT PARK 30R0UGH RIOLEY PARK BOROUGH ROSE VALLEY BOROUGH RUTLEDGE BOROUGH SHARON HILL BOROUGH TRAINER 30R0UGH UPLAND BOROUGH YEADON BOROUGH JCHNSCNBURG BOROUGH RIDGWAY BOROUGH ST MARYS BOROUGH ALBION BOROUGH CCRRY CITY EAST SPRINGFIELD BOROUGHI EDIN30R0 BOROUGH ELGIN BOROUGH ERIE CITY FAIRVIEW BOROUGH MC KEAN 30R0 MILL VILLAGE BORO NORTH EAST BOROUGH PLATEA BOROUGH UNION CITY BOROUGH WATERFORD 30R0UGH WATTSBURG 30RCUGH WESLEYVILLE BOROUGH BELLE VERNON BOROUGH CONNELLSVILLE CITY OAWSON BOROUGH DUNBAR 80R0UGH EVERSON BOROUGH FAIRCHANCE BOROUGH FAYETTE CITY BOROUGH MARKLEYS3URG BOROUGH MASONTOWN 30R0UGH NEWELL BOROUGH OHIOPYLE BOROUGH PERRYOPOLIS BOROUGH POINT MARION BORO' ^H S CONNEL.SVILLE BOROUGH UNICNTOWN CITY VANDERBILT BOROUGH TIONESTA BOROUGH CHAM8ERS3URG BOROUGH MCNT ALTO 30R0UGH ORRSTOWN 80R0UGH PAGE225 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 WAYNESBORO BOROUGH 39 MC CONNELLSBURG BOROUGH 39 CLARKSVILLE BOROUGH 39 GREENS80R0 BOROUGH 39 JEFFERSON BOROUGH 39 RICES LANDING BOROUGH 39 WAYNESBURG BOROUGH 39 ALEXANDRIA BOROUGH 39 BIRMINGHAM BOROUGH 39 BROAD TOP CITY BOROUGH 39 CASSVILLE 30R0UGH 39 COALMONT BOROUGH 39 DUDLEY BOROUGH 39 HUNTINGDON BOROUGH 39 MAPLETON BOROUGH 59 MARKLESBURG BOROUGH 59 MILL CREEK BOROUGH 59 MOUNT UNION BOROUGH 59 ORBISONIA BOROUGH 59 PETERSBURG BOROUGH 59 RCCKHILL BOROUGH 59 SALTILLO 30R0UGH 59 SHADE GAP 30R0UGH 59 SHIRLEYBURG BOROUGH 59 THREE SPRINGS 30R0UGH 59 MIFFLIN 30R0UGH 39 MIFFLINTOWN BOROUGH 39 PORT ROYAL BOROUGH 39 THOMPSONTOWN BOROUGH 39 ARCHBALD BOROUGH 39 BLAKELY 80R0UGH 39 CARBONOALE CITY 39 CLARKS SUMMIT 30R0UGH 39 DICKSON CITY BOROUGH 39 DUNMORE BOROUGH 39 JERMYN BOROUGH 39 MAYFIELD BOROUGH 39 MCOSIC BOROUGH 39 MOSCOW BOROUGH 39 OLD FORGE 30R0UGH 39 OLYPHANT BOROUGH 39 SCRANTON CITY 39 TAYLOR BOROUGH 39 THROOP BQPOUGH 39 VANDLING BOROUGH 39 JESSUP BOROUGH PAGE22G 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 ADAMSTOWN 30R0UGH 39 LANCASTER CITY 39 MARIETTA BOROUGH 39 TERRE HILL BOROUGH 39 BESSEMER BOROUGH 39 ELLPORT BOROUGH 39 ENON VALLEY BOROUGH 39 NEW CASTLE CITY 39 NEW WILMINGTON BOROUGH 39 SOUTH NEW CASTLE BOROUGH 39 VOLANT BOROUGH 39 WAMPUM BOROUGH 39 LEBANON CITY 39 ALENTCWN CITY 39 ASHLEY BOROUGH 39 AVOCA BOROUGH 39 CCURTDALE 30RCUGH 39 DALLAS BOROUGH 39 DUPONT BOROUGH 39 DURYEA BOROUGH 39 EDWARDSVILLE BOROUGH 39 EXETER BOROUGH 39 FORTY FORT BOROUGH 39 FREELAND BOROUGH 39 HAZLETON CITY 59 HUGHESTOWN BOROUGH 59 JEDDO BOROUGH 59 KINGSTON 30R0UGH 59 LAFLIN 80R0UGH 59 LARKSVILLE BOROUGH 59 LAUREL RUN BOROUGH 59 LUZERNE BOROUGH 59 NANTICOKE CITY 59 NESCOPECK BOROUGH 59 NEW COLUMBUS BOROUGH 59 PITTSTON CITY 59 PLYMOUTH BOROUGH 59 PRINGLE 30R0UGH 59 SHICKSHINNY 30R0UGH 59 SUGAR NOTCH BOROUGH 59 SWOYERSVILLE BOROUGH 59 WARRIOR RUN BOROUGH 59 WEST HAZLETON BOROUGH 59 WEST PITTSTON BOROUGH 39 WEST WYOMING BOROUGH 39 WHITE HAVEN BOROUGH PAGE227 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 WILKES BARRE CITY 39 WYOMING 30R0UGH 39 YATESVILLE BOROUGH 39 HARVEYS LAKE BOROUGH 39 PENN LAKE PARK 60R0 39 DUBOISTOWN BOROUGH 39 HUGHESVILLE 30ROUGH 39 JERSEY SHORE BOROUGH 39 MONTGOMERY BOROUGH 39 MONTOURSVILLE 30R0UGH 59 MUNCY BOROUGH 59 PICTURE ROCKS 30R0UGH 59 SALLADAS8URG BOROUGH 59 S WILLIAMSPORT BOROUGH 59 WILLIAMSPORT CITY 39 BRADFORO CITY 59 ELORED BOROUGH 59 KANE BOROUGH 39 LEWIS RUN BOROUGH 39 MOUNT JEWETT BOROUGH 39 PORT ALLEGANY BOROUGH 39 SMETHPORT 30RCUGH 39 CLARK BOROUGH 39 FARRELL CITY 39 FREDONIA BOROUGH 39 GREENVILLE BOROUGH 39 GROVE CITY BOROUGH 39 JACKSON CENTER BOROUGH 39 JAMESTOWN 30R0UGH 39 MERCER BOROUGH 39 NEW LEBANON BOROUGH 39 SANOY LAKE BOROUGH 39 SHARON CITY 39 SHARPSVILLE 30R0UGH 39 SHEAKLEYVILLE BOROUGH 39 STONEBORO 3CR0 39 WHEATLAND BOROUGH 39 BURNHAM BOROUGH 39 KISTLER BOROUGH 39 LEWJSTOWN 30ROUCH 39 MCVtYTOWN 10ROUGH 39 NEWTON HAMILTON BOROUGH 39 JUNIATA TERRACE 80RO 59 E STROUDSBURG BOROUGH 59 MOUNT POCONO BOROUGH 59 STROUDSBURG SOROUGH PAGE228 05/23/78 AT 01:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 AMBLER BOROUGH 39 BRIDGEPORT BOROUGH 39 BRYN ATHYN 80R0UGH 39 CCNSHOHCCKEN BOROUGH 39 E GREENVILLE! BOROUGH 39 GREENLANE 30R0UGH 59 HATBORO BOROUGH 39 HATFIELD BOROUGH 39 JENKINTOWN BOROUGH 39 NARBERTH BOROUGH 39 NCRRISTOWN BOROUGH 39 NORTH WALES BOROUGH 39 PENNSEURG 30R0UGH 39 PCTTSTOWN 30ROUGH 39 RED HILL BOROUGH 39 ROCKLEOGE 30ROUGH 39 ROYERSFORD BOROUGH 39 SCHWENKSVILLE BOROUGH 39 SCUDERTON BOROUGH 39 W CONSHOHOCKEN BOROUGH 39 DANVILLE BOROUGH 39 BANGOR BOROUGH 39 EASTON CITY 59 FREEMANS3URG BOROUGH 59 N CATASAUQUA BOROUGH 59 RCSETO BOROUGH 59 TATAMY BOROUGH 59 WILSON BOROUGH 59 KULPMONT BOROUGH 59 MC EWENSVILLE BOROUGH 59 MARION HEIGHTS BOROUGH 59 MILTON BOROUGH 59 MOUNT CARMEL BOROUGH 39 NORTHUMBERLAND BOROUGH 59 RIVERSIDE 30ROUGH 59 SHAMOKIN CITY 59 SNYDERTOWN BOROUGH 59 SUNBURY CITY 59 WATSONTOWN BOROUGH 59 PHILADELPHIA CITY 59 MATAMORAS 30R0UGH 59 AUSTIN BOROUGH 59 COUDERSPORT BOROUGH 59 GALETON BOROUGH 59 ULYSSES BOROUGH 59 OSWAYO BOROUGH PAGE229 05/25/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE*ST (ELIGIBLE GOVERNMENTS) STATE TITLE 59 SHINGLEHOUSE BOROUGH 59 ASHLAND 30R0UGH 59 AUBURN BOROUGH 59 COALDALE BOROUGH 59 CRESSONA BOROUGH 59 OEER LAKE BOROUGH 59 FRACKVILLE BOROUGH 59 GILBERTON 30R0UGH 59 GIRARDVILLE BOROUGH 59 GORDON BOROUGH 59 LANDINGVILLE BOROUGH 39 MC ADOO 30R0UGH 39 MAHANOY CITY BOROUGH 39 MECHANICSVILLE BOROUGH 39 MIDDLEPORT BOROUGH 39 MINERSVILLE BOROUGH 39 MCUNT CARBON BOROUGH 39 NEW PHILA 30R0UGH 39 NEW RINGGOLD: BOROUGH 59 PALO ALTO 30R0UGH 59 PINE GROVE BOROUGH 59 PORT CAR30N BOROUGH 59 PORT CLINTON BOROUGH 59 POTTSVILLE CITY 59 RINGTOWN BOROUGH 59 ST CLAIR BOROUGH 39 SCHUYLKILL HAVEN BOROUGH 39 SHENANDOAH BOROUGH 39 TAMAQUA 30R0UGH 39 TOWER CITY BOROUGH 39 TREMONT 30R0UGH 39 BEAVERTOWN BOROUGH 39 FREEBURG BOROUGH 39 SELINSGRCVE 30R0UGH 39 MC CLURE BOROUGH 39 ADDISON BOROUGH 39 8ERLIN BOROUGH 59 BOSWELL 30R0UGH 59 CASSELMAN 30R0UGH 59 CENTRAL CITY BOROUGH 59 CONFLUENCE BOROUGH 59 GARRETT BOROUGH 39 HOOVERSVILLEi BOROUGH 39 JENNERTOWN BOROUGH 39 MEYERSDALE BOROUGH 39 NEW BALTIMORE BOROUGH PAGE230 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 NEW CENTERVILLE BOROUGH 39 PAINT BOROUGH 39 RCCKWOOD BOROUGH 39 SALISBURY 30R0UGH 39 SHANKSVILLE 30R0UGH 39 SOMERSET BOROUGH 39 STOYSTOWN BOROUGH 39 URSINA BOROUGH 39 WELLERSBURG BOROUGH 59 WINDBER 30R0UGH 59 CALLIMONT 30R0UGH 59 SEVEN SPRINGS BOROUGH 59 DUSHORE BOROUGH 59 EAGLES MERE BOROUGH 59 FCRKSVILLE BOROUGH 59 LAPORTE BOROUGH 59 BLOSSBURG 30R0UGH 59 ELKLAND BOROUGH 59 KNOXVILLE 30R0UGH 59 LAWRENCEVILLE BOROUGH 59 LIBERTY BOROUGH 59 MANSFIELD BOROUGH 59 ROSEVILLE 30R0UGH 59 TIOGA BOROUGH 59 WELLSBORO 30R0UGH 59 WESTFIELD 30R0UGH 59 HARTLETON 30R0UGH 59 LEWISBURG BOROUGH 59 CLINTONVILLB BOROUGH 59 CCOPERSTOWN BOROUGH 59 EMLENTON BOROUGH 59 FRANKLIN CITY 59 OIL CITY 39 PLEASANTVILLE 30R0UGH 39 POLK BOROUGH 39 ROUSEVILLE BOROUGH 39 UTICA BOROUGH 39 BARKEYVILLE BOROUGH 39 SUGARCREEK BOROUGH 39 BEAR LAKE BOROUGH 39 CLARENOON BQRO 39 TIOIOUTE BOROUGH 39 YOUNGSVILLE BOROUGH 39 CALIFORNIA 80R0UGH 39 CANONSBURG BOROUGH 39 CENTREVILLE BOROUGH PAGE231 05/23/73 A ;J; S ^ P A R T M E N T OF T H E DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 COKEBURG BOROUGH 39 DONORA BOROUGH 39 ELCO BOROUGH 39 FINLEYVILLE BOROUGH 39 HOUSTON BOROUGH 39 MARIANNA BOROUGH 39 MIDWAY BOROUGH 39 MONONGAHELA CITY 39 NCRTH CHARLEROI BOROUGH 39 ROSCOE BOROUGH 39 SPEERS BOROUGH 39 TWILIGHT BOROUGH 59 WASHINGTON CITY 59 WEST ALEXANDER BOROUGH 39 BETHANY 30R0UCH 39 HAWLEY BOROUGH 39 HONESDALE 30R0UGH 39 PROMPTCN BOROUGH 39 STARRUCCA BOROUGH 59 WAYMART BOROUGH 59 ARNOLD CITY 59 ARONA BOROUGH 59 AVONMORE BOROUGH 39 BCLIVAR BOROUGH 39 DERRY 30RCUGH 39 DONEGAL 30R0UGH 39 EAST VANDERGRIFT BQRO 39 EXPORT BOROUGH 39 GREENSBURG CITY 39 HUNKER BOROUGH 39 HYDE PARK 30R0UGH 39 IRWIN 80R0UGH 39 JEANNETTE CITY 39 LATROBE BOROUGH 39 LIGONIER BOROUGH 39 MANOR BOROUGH 39 MCNESSEN CITY 39 MOUNT PLEASANT 80R0UGH 39 NEW ALEXANDRIA BOROUGH 39 NEW FLORENCE BOROUGH 39 NEW KENSINGTON CITY 39 N BELLE VERNON BORO 39 NORTH IRWIN BOROUGH 59 OKLAHOMA BOROUGH 39 PENN BOROUGH 59 SCOTTOALE 30R0UGH TREASljRY 05/23/78 AT 01:25 U.S. DEPARTMENT PAGE233 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 SEWARD BOROUGH 39 SMITHTON BOROUGH 39 SOUTH GREENS8URG BOROUGH! 39 S W GREENS3URG BORO 39 VANDERGRIFT BOROUGH 39 WEST LEECH3URG BOROUGH 39 WEST NEWTON BOROUGH 39 YOUNGSTOWN BOROUGH 39 YOUNGWOOD 30R0UGH 39 LCWER BURRELL CI TY 39 NEW STANTON BOROUGH 59 FACTORYVILLE BOROUGH 59 LACEYVILLE BOROUGH 59 MESHOPPEN 3CR0UGH 59 NICHOLSON 30ROUGH 59 TUNKHANNOCK BOROUGH 39 D£LTA BOROUGH 59 EAST PROSPECT 30ROUGH 59 FAWN GROVE BOROUGH 59 FRANKLINTCWN BOROUGH 59 HALLAM 80R0UGH 59 HANOVER BOROUGH 59 NORTH YORK BOROUGH 39 RAILROAD BOROUGH 39 RED LION BOROUGH 39 WEST YORK 80R0UGH 39 WRIGHTSVILLG BOROUGH 39 YORK CITY 39 YCRKANA BOROUGH 39 BERWICK TOWNSHIP 39 BUTLER TOWNSHIP 39 CONEWAGO TOWNSHIP 39 CUMBERLAND TOWNSHIP 59 FRANKLIN TOWNSHIP 59 FREEDOM TOWNSHIP 59 GERMANY TOWNSHIP 59 HAMILTON3AN TOWNSHIP 59 HIGHLAND TOWNSHIP 59 HUNTINGTON TOWNSHIP 59 LATIMORE TOWNSHIP 59 MENALLEN TOWNSHIP 59 MT JOY TOWNSHIP 59 MOUNT PLEASANT TOWNSHIP 39 OXFORD TOWNSHIP 59 READING TOWNSHIP 59 STRABAN TOWNSHIP TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 TYRONE TOWNSHIP 39 UNION TOWNSHIP 39 COLLIER TOWNSHIP 39 CRESCENT TOWNSHIP 59 EAST DEER TOWNSHIP 59 FAWN TOWNSHIP 59 INDIANA TOWNSHIP 59 KILBUCK TOWNSHIP 39 PENN HILLS TOWNSHIP 39 RESERVE TOWNSHIP 39 S FAYETTE TOWNSHIP 39 S VERSAILLES TOWNSHIP 39 SPRINGOALE TOWNSHIP 39 STOWE TOWNSHIP 59 WEST OEER TOWNSHIP 59 BETHEL TOWNSHI? 59 BCGGS TOWNSHIP 59 BRADYS EEND TOWNSHIP 59 BURRELL TOWNSHIP 39 CADOGAN TOWNSHIP 39 COWANSHANNOCK TOWNSHIP 39 EAST FRANKLIN TOWNSHIP 39 GILPIN TOWNSHIP 39 HCVEY TOWNSHIP 39 KISKIMINETAS TOWNSHIP 39 KITTANNING TOWNSHIP 39 MAOISON TOWNSHIP 39 MAHONING TOWNSHIP 39 MANOR TOWNSHIP 39 NORTH BUFFALO TOWNSHIP 39 PARKS TOWNSHIP 39 PERRY TOWNSHIP 39 PINE TOWNSHIP 39 PLUMCREEK TOWNSHIP 39 RAYBURN TOWNSHIP 39 REOBANK TOWNSHIP 39 SOUTH BEND TOWNSHIP 39 SOUTH BUFFALO TOWNSHIP 39 SUGARCREEK TOWNSHIP 39 VALLEY TOWNSHIP 39 WEST FRANKLLN TOWNSHIP 39 MARION TOWNSHIP 39 N SEWICKLEY TOWNSHIP 39 PULASKI TOWNSHIP 39 BEDFORD TOWNSHIP 39 BLOCMFIELD TOWNSHIP THE TREASJRY PArr9l/ r btZ5 * * 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE235 OF THE DISTRESSED AREA ELIGIBILITY FEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 59 BROAD TOP TOWNSHIP 59 COLERAIN TOWNSHIP 59 CUMBERLAND VALLEY TWP 59 E PROVIDENCE TOWNSHIP 59 E ST CLAIR TOWNSHIP 59 HARRISON TOWNSHIP 59 HCPEWELL TOWNSHIP 39 JUNIATA TOWNSHIP 39 KIMMELL TOWNSHIP 39 KING TOWNSHIP 39 LIBERTY TOWNSHIP 39 LINCOLN TOWNSHIP 39 LONDONDERRY TOWNSHIP 39 MANN TOWNSHIP 39 MONRCE TOWNSHIP 39 NAPIER TOWNSHIP 39 SNAKE SPRG VALLEY TWP 39 SOUTHAMPTON TOWNSHIP 39 SOUTH WO0D3URY TOWNSHIP 39 UNION TOWNSHIP 39 W PROVIDENCE TOWNSHIP 59 W ST CLAIR TOWNSHIP 59 BERN TOWNSHIP 59 EARL TOWNSHIP 59 EXETER TOWNSHIP 59 LONGSWAMP TOWNSHIP 59 MAIOENCREEK TOWNSHIP 59 MARION TOWNSHIP 59 N HEIDEL3ERG TOWNSHIP 39 ONTELAUNEE TOWNSHIP 39 S HEIDELBERG TOWNSHIP 39 TULPEHOCKEN TOWNSHIP 39 UNION TOWNSHIP 39 ALLEGHENY TCWNSHIP 39 ANTIS TOWNSHIP 39 BLAIR TOWNSHIP 39 CATHARINE TOWNSHIP 39 FREEDOM TOWNSHIP 39 GREENFIELD TOWNSHIP 39 HUSTON TOWNSHIP 39 JUNIATA TOWNSHIP 39 LCGAN TOWNSHIP 59 NCRTH WC008URY TOWNSHIP 59 SNYDER TOWNSHIP 39 TAYLOR TOWNSHIP 39 TYRONE TOWNSHIP TREASURY 05/23/78 AT 01:25 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 39 39 39 39 39 39 39 39 39 59 59 59 39 59 59 59 59 59 59 59 59 59 59 59 59 39 39 39 39 39 39 39 39 39 39 39 59 39 39 39 39 59 59 59 39 39 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE WOODBURY TOWNSHIP ARMENIA TOWNSHIP ASYLUM TOWNSHIP ATHENS TOWNSHIP BURLINGTON TOWNSHIP CANTON TOWNSHIP COLUMBIA TOWNSHIP FRANKLIN TOWNSHIP GRANVILLE TOWNSHIP HERRICK TOWNSHIP LEROY TOWNSHIP LITCHFIELD TOWNSHIP MONROE TOWNSHIP N TOWANDA TOWNSHIP ORWELL TOWNSHIP OVERTON TOWNSHIP PIKE TOWNSHIP RIDGEBURY TOWNSHIP ROME TOWNSHIP SHESHEQUIN TOWNSHIP SMITHFIELO TOWNSHIP S CREEK TOWNSHIP SPRINGFIELD TOWNSHIP STANDING STONE TOWNSHIP STEVENS TOWNSHIP TERRY TOWNSHIP TOWANDA TOWNSHIP TROY TOWNSHIP TUSCARORA TOWNSHIP ULSTER TOWNSHIP WARREN TOWNSHIP WELLS TOWNSHIP W BURLINGTON TOWNSHIP WILMOT TOWNSHIP WINDHAM TOWNSHIP WYALUSING TOWNSHIP BRISTOL TOWNSHIP FALLS TOWNSHIP LCWER SOUTHAMPTON TWP MIODLETOWN TOWNSHIP ADAMS TOWNSHIP ALLEGHENY TOWNSHIP BRADY TOWNSHIP BUTLER TOWNSHIP CENTER TOWNSHIP CHERRY TOWNSHIP TEST PAGE23G 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE237 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 CLAY TOWNSHIP 39 CLEARFIELD TOWNSHIP 39 CLINTON TOWNSHIP 59 CONCORD TOWNSHIP 39 CONNOQUENESSING TWP 39 CRANBERRY TOWNSHIP 39 FAIRVIEW TOWNSHIP 39 FORWARD TOWNSHIP 39 FRANKLIN TOWNSHIP 39 JEFFERSON TOWNSHIP 39 LANCASTER TOWNSHIP 39 MARION TOWNSHIP 59 MERCER TOWNSHIP 59 MIDDLESEX TOWNSHIP 59 MUDDYCREEK TOWNSHIP 59 OAKLANO TOWNSHIP 59 PARKER TOWNSHIP 59 PENN TOWNSHIP 59 SUMMIT TOWNSHIP 39 VENANGO TOWNSHIP 39 WASHINGTON TOWNSHIP 39 WINFIELD TOWNSHIP 39 WORTH TOWNSHIP 39 ADAMS TOWNSHIP 39 ALLEGHENY TOWNSHIP 39 8ARR TOWNSHIP 39 CAMBRIA TCWNSHIP 39 CLEARFIELD TOWNSHIP 39 CONEMAUGH TOWNSHIP 39 CRESSON TOWNSHIP 39 CROYLE TOWNSHIP 39 DEAN TOWNSHIP 39 EAST CARROLL TOWNSHIP 39 EAST TAYLOR TWONSHIP 39 ELOER TOWNSHIP 39 GALLITZIN TOWNSHIP 39 LOWER YODER TOWNSHIP 59 MIDDLE TAYLOR TOWNSHIP 59 MUNSTER TOWNSHIP 59 PORTAGE TOWNSHIP 59 STONYCREEK TOWNSHIP 59 SUMMERHILL TOWNSHIP 59 SUSQUEHANNA TOWNSHIP 59 UPPER YODER TOWNSHIP 59 WASHINGTON TOWNSHIP 59 WEST CARROLL TOWNSHIP TREASURY 05/2 3/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE S9 WEST TAYLOR TOWNSHIP 39 WHITE TOWNSHIP 39 GIBSON TOWNSHIP 39 GROVE TOWNSHIP 39 LUMBER TOWNSHIP 39 PORTAGE TOWNSHIP 39 SHIPPEN TOWNSHIP 39 BANKS TOWNSHIP 39 LAUSANNE TOWNSHIP 39 LEHIGH TOWNSHIP 39 COLLEGE TOWNSHIP 39 HAINES TOWNSHIP 39 LIBERTY TOWNSHIP 39 PENN TOWNSHIP 39 RUSH TOWNSHIP 39 SNOW SHOE TOWNSHIP 39 SPRING TOWNSHIP 39 WORTH TOWNSHIP 39 EAST BRANDYWINE TOWNSHIP 39 EAST VINCENT TOWNSHIP 39 EAST WHITELAND TOWNSHIP 39 NEWLIN TOWNSHIP 39 PCCOPSON TOWNSHIP 39 UPPER OXFORD TOWNSHIP 39 WEST NANTMEAL TOWNSHIP 39 WEST SADSBURY TOWNSHIP 39 BECCARIA TOWNSHIP 39 BELL TOWNSHIP 39 BIGLER TOWNSHIP 39 BCGGS TOWNSHIP 39 8RADF0R0 TOWNSHIP 39 BRADY TOWNSHIP 39 BURNSIDE TOWNSHIP 39 CHEST TOWNSHIP 39 COOPER TOWNSHIP 39 DECATUR TOWNSHIP 39 FERGUSON TOWNSHIP 59 GIRARD TOWNSHIP 59 GOSHEN TOWNSHIP 59 GRAHAM TOWNSHIP 59 GREENWOOD TOWNSHIP 59 GULICH TOWNSHIP 39 JORDAN TOWNSHIP 39 KARTHAUS TOWNSHIP 39 KNOX TOWNSHIP 39 LAWRENCE TOWNSHIP TREASURY PAGE238 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 59 59 59 59 59 59 59 59 59 59 59 59 39 59 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 59 59 59 39 39 39 39 39 39 39 39 39 PAGE259 OF THE TREASURY ELIGIBILITY GOVERNMENTS) TITLE MORRIS TOWNSHIP PENN TCWNSHIP PIKE T O W N S H I P SANDY TOWNSHIP U N I O N TOWNSHIP WOODWARD T O W N S H I P PINE T O W N S H I P ALLISON T O W N S H I P BALD EAGLE T O W N S H I P BEECH CREEK TOWNSHIP CASTANEA T O W N S H I P CHAPMAN T O W N S H I P CCLEBROOK T O W N S H I P CRAWFORD T O W N S H I P OUNNSTABLE TOWNSHIP EAST KEATING T O W N S H I P GALLAGHER TOWNSHIP G R E E N E TOWNSHIP GRUGAN T O W N S H I P LAMAR TOWNSHIP LEIDY TCWNSHIP LOGAN TOWNSHIP N C Y E S TCWNSHIP PINE CREEK T O W N S H I P PORTER TOWNSHIP WAYNE TCWNSHIP WEST KEATING T O W N S H I P WCODWARC T O W N S H I P BEAVER TOWNSHIP BENTON TOWNSHIP BRIAR CREEK TOWNSHIP CATAWISSA T O W N S H I P CLEVELAND TOWNSHIP CCNYNGHAM T O W N S H I P F I S H I N G CREEK TWP FRANKLIN TOWNSHIP GREENWOOD TOWNSHIP HEMLOCK T O W N S H I P JACKSON TOWNSHIP LOCUST TOWNSHIP MADISON T O W N S H I P MAIN TOWNSHIP MIFFLIN T O W N S H I P MOUNT PLEASANT T O W N S H I P ORANGE TOWNSHIP PINE TOWNSHIP TEIST 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE2*0 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 RCARINGCREEK TOWNSHIP 59 SCOTT TOWNSHIP 59 SUGARLOAF TOWNSHIP 59 NCRTH CENTER TOWNSHIP 59 SCUTH CENTER TOWNSHIP 59 ATHENS TOWNSHIP 59 BEAVER TOWNSHIP 59 BLOOMFIELO TOWNSHIP 59 CAMBRIDGE TOWNSHIP 59 CCNNEAUT TOWNSHIP 59 CUSSEWAGO TOWNSHIP 59 EAST FAIRFIELD TOWNSHIP 59 EAST FALLOWFIELD TWP 59 EAST MEAD TOWNSHIP 59 FAIRFIELD TOWNSHIP 59 GREENWOOD TOWNSHIP 59 HAYFIELO TOWNSHIP 59 NORTH SHEN4NG0 TWP 59 OIL CREEK TOWNSHIP 59 PINE TOWNSHIP 59 RANDOLPH TOWNSHIP 39 RICHMOND TOWNSHIP 39 ROME TOWNSHIP 39 SADSBURY TOWNSHIP 39 SPARTA TOWNSHIP 39 SPRING TOWNSHIP 39 STEUBEN TOWNSHIP 39 SUMMERHILL TOWNSHIP 39 SUMMIT TOWNSHIP 59 TROY TOWNSHIP 59 UNION TOWNSHIP 39 VENANGO TOWNSHIP 39 VERNON TOWNSHIP 39 WAYNE TOWNSHIP 39 WEST FALLOWFIELD TWP 39 WEST MEAD TOWNSHIP 39 WEST SHENANGO TOWNSHIP 39 WOODCOCK TOWNSHIP 39 MIFFLIN TOWNSHIP 39 RUSH TOWNSHIP 39 WICONISCO TOWNSHIP 39 WILLIAMS TOWNSHIP 39 ASTON TOWNSHIP 39 CHESTER TOWNSHIP 59 DARBY TOWNSHIP 59 LOWER CHICHESTER TWP TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 MARPLE TOWNSHIP 39 MIDDLETOWN TOWNSHIP 39 NEWTOWN TOWNSHIP 39 RIDLEY TOWNSHIP 39 TINICUM TOWNSHIP 39 UPPER CHICHESTER TWP 39 UPPER DARBY TCWNSHIP 39 BENEZETTE TOWNSHIP 39 BENZINGER TOWNSHIP 59 FOX TOWNSHIP 59 HIGHLAND TOWNSHIP 59 HORTON TOWNSHIP 59 JAY TOWNSHIP 39 JONES TOWNSHIP 39 MILLSTONE TOWNSHIP 39 R.IOGWAY TOWNSHIP 39 SPRING CREEK TOWNSHIP 39 AHITY TOWNSHIP 39 CCNCORO TCWNSHIP 39 CCNNEAUT TOWNSHIP 39 ELK CREE< TOWNSHIP 39 GIRARD TOWNSHIP 39 GREENE TOWNSHIP 39 GREENFIELD TOWNSHIP 39 LAWRENCE PARK TOWNSHIP 39 LE BOEUF TOWNSHIP 39 MCKEAN TOWNSHIP 39 NCRTH EAST TOWNSHIP 39 SPRINGFIELD TOWNSHIP 39 SUMMIT TOWNSHIP 39 UNION TOWNSHIP 39 VENANGO TOWNSHIP 39 WASHINGTON TOWNSHIP 39 WATERFORD TOWNSHIP 39 WAYNE TOWNSHIP 39 BROWNSVILLE TOWNSHIP 39 BULLSKIN TOWNSHIP 39 CONNELLSVILLE TOWNSHIP 39 DUNBAR TOWNSHIP 39 FRANKLIN TOWNSHIP 39 GEORGES TOWNSHIP 39 GERMAN TOWNSHIP 39 HENRY CLAY TOWNSHIP 39 JEFFERSON TOWNSHIP 39 LOWER TYRONE TOWNSHIP 39 LUZERNE TOWNSHIP PAGE241 TREASURY 05/23/78 AT 3 u# s ;S^pARTMENT 0F THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 MENALLEN TOWNSHIP 39 NICHOLSON TOWNSHIP 39 NORTH UNION TOWNSHIP 39 PERRY TOWNSHIP 39 REDSTONE TOWNSHIP 59 SALTLICK TOWNSHIP 59 SOUTH UNION TOWNSHIP 39 SPRINGFIELD TOWNSHIP 39 SPRINGHILL TOWNSHIP 39 STEWART TOWNSHIP 39 UPPER TYRONE TOWNSHIP 39 WASHINGTON TOWNSHIP 39 WHARTCN TOWNSHIP 39 GREEN TOWNSHIP 39 HARMONY TOWNSHIP 39 HOWE TOWNSHIP 3 9 JENKS TOWNSHIP 39 KINGSLEY TOWNSHIP 39 TIONESTA TOWNSHIP 39 QUINCY TOWNSHIP 39 WARREN TOWNSHIP 39 AYR TCWNSHIP 39 BELFAST TOWNSHIP 39 3ETHEL TOWNSHIP 39 BRUSH CREEK TOWNSHIP 39 DUBLIN TOWNSHIP 39 LICKING CREEK TOWNSHIP 39 TAYLOR TOWNSHIP 39 THOMPSON TOWNSHIP 39 TODD TOWNSHIP 39 WELLS TOWNSHIP 59 ALEPPO TOWNSHIP 59 CENTER TOWNSHIP 59 CUMBERLAND TOWNSHIP 39 OUNKARD TOWNSHIP 39 FRANKLIN TOWNSHIP 39 FREEPORT TOWNSHIP 39 GILMORE TOWNSHIP 39 GRAY TGWNSHIP 39 GREENE TOWNSHIP 39 JACKSON TOWNSHIP 39 JEFFERSON TOWNSHIP 39 MONONGAHELX TOWNSHIP 39 MORGAN TOWNSHIP 39 MORRIS TOWNSHIP 39 PERRY TOWNSHIP TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TE«ST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 RICHHILL TOWNSHIP 39 SPRINGHILL TOWNSHIP 39 WASHINGTON TOWNSHIP 39 WAYNE TOWNSHIP 39 WHITELEY TOWNSHIP 39 BARREE TOWNSHIP 39 BRAOY TOWNSHIP 39 CARBON TOWNSHIP 59 CASS TOWNSHIP 59 CLAY TOWNSHIP 39 CROMWELL TOWNSHIP 39 DUBLIN TOWNSHIP 39 FRANKLIN TOWNSHIP 39 HENDERSON TOWNSHIP 59 HOPEWELL TOWNSHIP 59 JACKSON TOWNSHIP 59 JUNIATA TOWNSHIP 59 LINCOLN TOWNSHIP 59 LOGAN TOWNSHIP 59 MILLER TOWNSHIP 59 MORRIS TCWNSHIP 59 ONEIDA TOWNSHIP 59 PENN TOWNSHIP 59 PORTER TOWNSHIP 59 SHIRLEY TOWNSHIP 59 SMITHFIELD TOWNSHIP 59 SPRINGFIELD TOWNSHIP 39 SPRUCE CREEK TOWNSHIP 39 TELL TOWNSHIP 39 TOD TOWNSHIP 39 UNION TOWNSHIP 39 WALKER TOWNSHIP 39 WARRIORS MARK TWP 59 WEST TOWNSHIP 59 WOOD TOWNSHIP 59 BEALE TOWNSHIP 59 DELAWARE TOWNSHIP 59 FAYETTE TOWNSHIP 59 FERMANAGH TOWNSHIP 59 GREENWOOD TOWNSHIP 59 LACK TOWNSHIP 59 MILFORD TOWNSHIP 59 MONROE TOWNSHIP 59 SPRUCE HILL 'TOWNSHIP 59 SUSQUEHANNA TOWNSHIP 39 TURBETT TOWNSHIP PAGE243 TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE2<»4 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 TUSCARORA TOWNSHIP 39 WALKER TOWNSHIP 39 ABINGTON TOWNSHIP 39 BENTON TOWNSHIP 39 CARBONDALE TOWNSHIP 39 CLIFTON TOWNSHIP 39 COVINGTON TOWNSHIP 39 ELMHURST TOWNSHIP 39 FELL TOWNSHIP 39 GLENBURN TOWNSHIP 39 GREENFIELD TOWNSHIP 39 JEFFERSON TOWNSHIP 39 LA PLUME TOWNSHIP 39 LEHIGH TOWNSHIP 39 MAOISON TOWNSHIP 39 NEWTON TOWNSHIP 39 NCRTH ABINGTON TOWNSHIP 39 RANSOM TOWNSHIP 39 RCARING BROOK TOWNSHIP 39 SCOTT TOWNSHIP 39 SOUTH ABINGTON TOWNSHIP 39 SPRING BROOK TOWNSHIP 39 WEST ABINGTON TOWNSHIP 39 EARL TOWNSHIP 39 EPHRATA TOWNSHIP 39 LEACOCK TCWNSHIP 39 MANOR TOWNSHIP 39 PARADISE TOWNSHIP 39 PENN TOWNSHIP 39 WEST EARL TOWNSHIP 39 WEST HEMPFIELD TOWNSHIP 39 WEST LAMPETER TOWNSHIP 39 HICKORY TOWNSHIP 39 LITTLE BEAVER TOWNSHIP 39 MAHONING TOWNSHIP 39 NESHANNOCK TOWNSHIP 39 PERRY TOWNSHIP 39 PLAIN GROVE TOWNSHIP 39 PULASKI TOWNSHIP 39 SCOTT TOWNSHIP 39 SHENANGO TOWNSHIP 59 SLIPPERY ROCK TOWNSHIP 59 TAYLOR TOWNSHIP 59 UNICN TOWNSHIP 59 WASHINGTON TOWNSHIP *Q WAYNE TOWNSHIP TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE245 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 WILMINGTON TOWNSHIP 39 BLACK CREEK TOWNSHIP 39 BUTLER TOWNSHIP 39 CONYNGHAM TOWNSHIP 39 DENNISON TOWNSHIP 39 DORRANCE TOWNSHIP 39 EXETER TOWNSHIP^ 39 FAIRMONT TOWNSHIP 39 FAIRVIEW TOWNSHIP 39 FOSTER TOWNSHIP 39 FRANKLIN TOWNSHIP 39 HANOVER TOWNSHIP 39 HAZLE TOWNSHIP 39 HOLLENBACK TOWNSHIP 39 HUNTINGTON TOWNSHIP 39 JACKSON TOWNSHIP 39 JENKINS TOWNSHIP 39 KINGSTON TOWNSHIP 39 LAKE TOWNSHIP 39 NESCOPECK TOWNSHIP 39 NEWPORT TOWNSHIP 39 PITTSTON TOWNSHIP 39 PLAINS TOWNSHIP 39 PLYMOUTH TOWNSHIP 39 RCSS TOWNSHIP 39 SLOCUM TOWNSHIP 39 UNION TOWNSHIP 39 WILKES B4RRE TOWNSHIP 39 WRIGHT TOWNSHIP 39 ANTHONY TOWNSHIP 39 ARMSTRONG TOWNSHIP 39 BASTRESS TOWNSHIP 39 BRADY TOWNSHIP 39 BROWN TOWNSHIP 39 CASAOE TOWNSHIP 39 CLINTON TOWNSHIP 39 COGAN HOUSE TOWNSHIP 39 CUMMINGS TOWNSHIP 39 ELDRED TOWNSHIP 39 FRANKLIN TOWNSHIP 39 GAMBLE TOWNSHIP 39 HEPBURN TOWNSHIP 39 JACKSON TOWNSHIP 39 JORDAN TOWNSHIP 39 LEWIS TOWNSHIP 39 LIMESTONE TOIWNSHIP TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE24G OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 39 39 39 39 39 39 39 39 39 39 39 39 39 59 59 39 39 59 59 59 59 59 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 59 59 59 59 59 TITLE LOYALSOCK TOWNSHIP LYCOMING TOWNSHIP MCHENRY TOWNSHIP MCINTYRE TOWNSHIP MCNETT TOWNSHIP MIFFLIN TOWNSHIP MILL CREEK TOWNSHIP MORELAND TOWNSHIP MUNCY CREEK TOWNSHIP NIPPENOSE TOWNSHIP OLD LYCOMING TOWNSHIP PENN TOWNSHIP PIATT TOWNSHIP PINE TCWNSHIP PLUNKETTS CREEK TOWNSHIP PORTER TOWNSHIP SHREWSBURY TOWNSHIP SUSQUEHANNA TOWNSHIP UPPER FAIRFIELD TOWNSHIP WASHINGTON TOWNSHIP WATSON TOWNSHIP WOLF TOWNSHIP WOODWARD TOWNSHIP ANNIN TOWNSHIP BRADFORD TOWNSHIP CERES TOWNSHIP CCRYOON TOWNSHIP ELDRED TOWNSHIP FOSTER TOWNSHIP HAMILTON TOWNSHIP HAMLIN TOWNSHIP KEATING TOWNSHIP LAFAYETTE TOWNSHIP LIBERTY TOWNSHIP NORWICH TOWNSHIP OTTO TOWNSHIP SERGEANT TOWNSHIP WETMORE TOWNSHIP CCOLSPRING TOWNSHIP DEER CREEK TOWNSHIP DELAWARE TOWNSHIP FAIRVIEW TOWNSHIP FINDLEY TOWNSHIP FRENCH CREEK TOWNSHIP GREENE TOWNSHIP HEMPFIELD TOWNSHIP TREASURY 05/25/78 AT 31:25 U.S. DEPARTMENT PAGE2d7 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 59 39 39 39 39 39 39 59 59 59 59 39 39 39 39 39 39 59 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 TITLE HERMITAGE TWP JACKSON TOWNSHIP JEFFERSON TOWNSHIP LACKAWANNOCK TOWNSHIP LAKE TOWNSHIP MILL CREEK TOWNSHIP NEW VERNON TOWNSHIP OTTER CREEK TCWNSHIP PERRY TOWNSHIP PINE TOWNSHIP PYMATUNING TOWNSHIP SALEM TOWNSHIP SANDY CREEK TOWNSHIP SANDY LAKE TOWNSHIP SHENANGO TOWNSHIP SOUTH PYMATUNING TWP SPRINGFIELO TOWNSHIP SUGAR GROVE TOWNSHIP WEST SALEM TOWNSHIP WILMINGTON TOWNSHIP WOLF CREEK TOWNSHIP WORTH TOWNSHIP ARMAGH TOWNSHIP 3RATT0N TOWNSHIP BROWN TOWNSHIP DECATUR TOWNSHIP DERRY TOWNSHIP GRANVILLE TOWNSHIP MENNO TOWNSHIP OLIVER TOWNSHIP UNION TOWNSHIP WAYNE TOWNSHIP BARRETT TOWNSHIP CHESTNUTHILL TOWNSHIP COOLBAUGH TOWNSHIP ELDRED TOWNSHIP HAMILTON TOWNSHIP JACKSON TOWNSHIP MIODLE SMITHFIELD TWP PARADISE TOWNSHIP PCCONO TOWNSHIP POLK TOWNSHIP PRICE TOWNSHIP ROSS TOWNSHIP SMITHFIELO TOWNSHIP STROUD TOWNSHIP TEST 05/2 3/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 TCBYHANNA TOWNSHIP 39 TUNKHANNCCK TOWNSHIP 39 ABINGTON TOWNSHIP 39 EAST NORRITON TOWNSHIP 39 FRANCONIA TOWNSHIP 39 HATFIELD TOWNSHIP 39 LIMERICK TOWNSHIP 39 LOWER FREDERICK TWP 39 MONTGOMERY TOWNSHIP 39 NEW HANOVER TOWNSHIP 39 PERKIOMEN TOWNSHIP 39 PLYMOUTH TOWNSHIP 39 SALFORO TOWNSHIP 39 SKIPPACK TOWNSHIP 39 SPRINGFIELD TOWNSHIP 39 TCWAMENCIN TOWNSHIP 39 UPPER 0U3LIN TOWNSHIP 39 UPPER FREDERICK TWP 39 UPPER GWYNEDO TOWNSHIP 39 UPPER HANOVER TOWNSHIP 39 UPPER MGRELA<ND TOWNSHIP 39 UPPER POTTSGROVE TWP 39 UPPER PROVIDENCE TWP 39 UPPER SALFORD TOWNSHIP 59 WEST NORRITON TOWNSHIP 39 WEST POTTSGROVE TWP 39 WHITEMARSH TOWNSHIP 39 WORCESTER TOWNSHIP 39 MAHONING TOWNSHIP 39 LCWER MT BETHEL TWP 39 PLAINFIELD TOWNSHIP 39 WILLIAMS TOWNSHIP 59 COAL TOWNSHIP 59 DELAWARE TOWNSHIP 39 EAST CAMERON TOWNSHIP 39 JACKSON TOWNSHIP 39 JORDAN TOWNSHIP 39 LEWIS TOWNSHIP 39 LITTLE MAHANOY TOWNSHIP 39 LOWER AUGUSTA TOWNSHIP 39 LCWER MAHANOY TOWNSHIP 39 MOUNT CARMEL TOWNSHIP 39 POINT TOWNSHIP 39 RALPHO TOWNSHIP 39 ROCKEFELLER TOWNSHIP 39 RUSH TOWNSHIP P *GE2*8 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE PAGE249 TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 59 59 59 59 59 39 59 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 39 GOVERNMENTS) TITLE SHAMCKIN TOWNSHIP TURBUT TOWNSHIP UPPER AUGUSTA TOWNSHIP UPPER MAHANOY TOWNSHIP WASHINGTON TOWNSHIP WEST CAMERON TOWNSHIP WEST CHILLISQUAOUE TWP ZERBE TOWNSHIP LEHMAN TOWNSHIP ABBOTT TOWNSHIP ALLEGANY TOWNSHIP BINGHAM TOWNSHIP CLARA TOWNSHIP EULALIA TOWNSHIP GENESEE TOWNSHIP HARRISON TOWNSHIP HEBRON TOWNSHIP HECTOR TOWNSHIP HOMER TOWNSHIP KEATING TOWNSHIP OSWAYO TOWNSHIP PIKE TOWNSHIP PLEASANT VALLEY TOWNSHIP PORTAGE TOWNSHIP RCULETTE TOWNSHI P SHARON TOWNSHIP STEWARDSON TOWNS HIP SUMMIT TOWNSHIP SWEDEN TOWNSHIP SYLVAMIA TOWNSHI P ULYSSES TOWNSHIP WEST BRANCH TCWN SHIP WHARTON TOWNSHIP BARRY TOWNSHIP BLYTHE TOWNSHIP BRANCH TOWNSHIP BUTLER TOWNSHIP CASS TOWNSHIP OELANO TOWNSHIP EAST BRUNSWICK TOWNSHIP EAST NORWEGIAN TOWNSHIP EAST UNION TOWNSHIP ELDREO TOWNSHIP FOSTER TOWNSHIP FRAILEY TOWNSHIP HEGINS TOWNSHIP 05/23/?e « » • « „ , , „ « „ 0F ,„ E DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 HUBLEY TOWNSHIP 39 KLINE TCWNSHIP 39 MAHANOY TOWNSHIP 39 NEW CASTLE T O W N S H I P 39 NCRTH MANHEIM T O W N S H I P 39 NCRTH UNION TOWNSHIP 39 NORWEGIAN T O W N S H I P 39 PINE GROVE TWP 39 PORTER TOWNSHIP 39 REILLY TOWNSHIP 39 RYAN TOWNSHIP 39 SCHUYLKILL T O W N S H I P 39 TREMONT TOWNSHIP 39 UNION TOWNSHIP 39 UPPER MAHANTONGO T O W N S H I P 39 WASHINGTON T O W N S H I P 39 WAYNE TOWNSHIP 39 WEST BRUNSWICK T O W N S H I P 39 WEST MAHANOY T O W N S H I P 39 WEST PENN T O W N S H I P 39 BEAVER TOWNSHIP 39 JACKSON TOWNSHIP 39 PENN TOWNSHIP 39 ADOISON T O W N S H I P 39 ALLEGHENY T O W N S H I P 39 BROTHERSVALLEY TOWNSHIP 39 CONEMAUGH T O W N S H I P 39 ELK LICK T O W N S H I P 39 FAIRHOPE T O W N S H I P 39 GREENVILLE T O W N S H I P 39 JEFFERSON T O W N S H I P 39 JENNER TOWNSHIP 39 LARIMER T O W N S H I P 39 LOWER TURKEYFOOT TWP 39 NORTHAMPTON TOWNSHIP 39 PAINT TOWNSHIP 39 SHADE TOWNSHIP 39 SOMERSET T O W N S H I P 39 SOUTHAMPTON TOWNSHIP 39 SUMMIT TOWNSHIP 39 CHERRY TOWNSHIP 39 CCLLEY TOWNSHIP 39 DAVIOSON T O W N S H I P 39 ELKLAND T O W N S H I P 39 F O R K S TCWNSHIP 39 FOX TOWNSHIP tRE ,suRr P,CE "° 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 HILLSGROVE TOWNSHIP 39 LAPORTE TOWNSHIP 39 SHREWSBURY TOWNSHIP 39 8L0SS TOWNSHIP 39 BROOKFIELD TOWNSHIP 39 CHARLESTON TOWNSHIP 39 CHATHAM TOWNSHIP 39 CLYMER TOWNSHIP 39 COVINGTON TOWNSHIP 39 0EERFIEL3 TOWNSHIP 39 DELMAR TCWNSHIP 39 DUNCAN TOWNSHIP 39 ELK TOWNSHIP 39 ELKLANO TOWNSHIP 39 FARMINGTON TOWNSHIP 39 GAINES TOWNSHIP 39 HAMILTON TOWNSHIP 39 JACKSON TOWNSHIP 39 LAWRENCE TOWNSHIP 39 LIBERTY TOWNSHIP 39 MIDDLEBURY TOWNSHIP 39 MORRIS TCWNSHIP 59 NELSON TOWNSHIP 59 OSCEOLA TOWNSHIP 59 PUTNAM TOWNSHIP 59 RICHMOND TOWNSHIP 59 RUTLAND TOWNSHIP 59 SHIPPEN TOWNSHIP 59 SULLIVAN TOWNSHIP 59 TIOGA TOWNSHIP 59 UNION TOWNSHIP 59 WARD TOWNSHIP 59 WESTFIELD TOWNSHIP 39 KELLY TOWNSHIP 39 CANAL TOWNSHIP 39 CHERRYTREE TOWNSHIP 39 CLINTON TOWNSHIP 39 CORNPLANTER TOWNSHIP 39 CRANBERRY TOWNSHIP 39 IRWIN TOWNSHIP 39 JACKSON TOWNSHIP 59 MINERAL TOWNSHIP 59 OILCREEK TOWNSHIP 39 PINEGROVE TOWNSHIP 59 PLUM TOWNSHIP 59 PRESIDENT TOWNSHIP PAGE251 TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGL252 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 39 RICHLAND TOWNSHIP 39 ROCKLAND TOWNSHIP 39 VICTORY TOWNSHIP 59 CHERRY GROVE TOWNSHIP 59 COLUMBUS TOWNSHIP 39 CCNEWANGO TOWNSHIP 39 ELK TOWNSHIP 39 GLAOE TOWNSHIP 39 MEAD TOWNSHIP 39 PLEASANT TOWNSHIP 39 SHEFFIELD TOWNSHIP 39 SCUTHWEST TOWNSHIP 39 SPRING CREEK TOWNSHIP 39 SUGAR GROVE TOWNSHIP 59 TRIUMPH TOWNSHIP 59 WATSON TOWNSHIP 59 CANTON TOWNSHIP 59 CECIL TOWNSHIP 59 CROSS CREEK TOWNSHIP 59 EAST BETHLEHEM TOWNSHIP 59 EAST FINLEY TCWNSHIP 59 FALLOWFIELD TOWNSHIP 59 INDEPENDENCE TOWNSHIP 59 MCUNT PLEASANT TOWNSHIP 59 NORTH FRANKLIN TOWNSHIP 59 SMITH TOWNSHIP 59 BERLIN TOWNSHIP 59 BUCKINGHAM TCWNSHIP 59 CANAAN TOWNSHIP 59 CHERRY RIDGE TOWNSHIP 59 CLINTON TOWNSHIP 39 DAMASCUS TOWNSHIP 39 DREHER TOWNSHIP 39 DYBERRY TOWNSHIP 39 LAKE TOWNSHIP 39 LEBANON TOWNSHIP 39 MANCHESTER TOWNSHIP 39 MCUNT PLEASANT TOWNSHIP 39 PAUPACK TOWNSHIP 39 PPESTON TOWNSHIP 39 SALEM TOWNSHIP 39 SCOTT TOWNSHIP 39 SOUTH CANAAN TOWNSHIP 39 STERLING TOWNSHIP 39 TEXAS TOWNSHIP 39 ALLEGHENY TOWNSHIP TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE253 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 39 BELL TOWNSHIP 39 COOK TOWNSHIP 39 DERRY TOWNSHIP 39 OONEGAL TOWNSHIP 39 EAST HUNTINGDON TOWNSHIP 39 FAIRFIEL3 TOWNSHIP 39 LIGONIER TOWNSHIP 39 LCYALHANNA TOWNSHIP 39 MOUNT PLEASANT TOWNSHIP 59 PENN TOWNSHIP 59 RCSTRAVER TOWNSHIP 59 ST CLAIR TOWNSHIP 59 SALEM TOWNSHIP 59 SEWICKLEY TOWNSHIP 59 SOUTH HUNTINGDON TWP 59 UNITY TOWNSHIP 59 UPPER 8URRELL TOWNSHIP 59 WASHINGTON TOWNSHIP 59 BRAINTRIM TOWNSHIP 39 CLINTON TCWNSHIP 39 EATCN TCWNSHIP 39 EXETER TOWNSHIP 39 FALLS TOWNSHIP 39 FORKSTON TOWNSHIP 39 LEMON TOWNSHIP 39 MEHOOPANY TOWNSHIP 39 MESHOPPEN TOWNSHIP 39 MONROE TOWNSHIP 39 NICHOLSON TOWNSHIP 39 NORTH BRANCH TOWNSHIP, 39 NCRTHMORELAND TOWNSHIP 39 NCXEN TOWNSHIP 39 OVERFIELD TOWNSHIP 39 TUNKHANNOCK TOWNSHIP 59 WASHINGTON TOWNSHIP 59 WINDHAM TOWNSHIP 59 CCNEWAGO TOWNSHIP 39 EAST HOPEWELL TOWNSHIP 39 WEST MANCHESTER TOWNSHIP STATE = 39: 1649 RECORDS TEST 05/23/78 AT 31:25 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE GOVERNMENTS) STATE TITLE 40 WARWICK CITY 40 CENTRAL FALLS CITY 40 CPANSTON CITY 40 PAWTUCKET CITY 40 PROVIDENCE CITY 40 WCONSOCKET CITY 40 EAST PROVIDENCE CITY 40 BARRINGTON TOWN 40 BRISTOL TOWN 40 WARREN TOWN 40 COVENTRY TOWN 40 WEST GREENWICH TOWN 40 WEST WARWICK TOWN 40 BURRILLVILLE; TOWN 4C CUMBERLAND TOWN 40 GLOCESTER TOWN 40 JGHNSTON TOWN 40 NCRTH PROVIDENCE TOWN 40 NCRTH SMITHFIELD TOWN 40 SMITHFIELD TOWN 40 EXETER TOWN kO NCRTH KINGSTOWN TOWN 40 SOUTH KINGSTOWN TOWN 40 NEW SHOREHAM TOWN STATE = 40: 24 RECORDS OF THE TREASURY ELIGIBILITY TEST PAGE254 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 41 ABBEVILLE COUNTY ALLENDALE COUNTY BAMBERG COUNTY BARNWELL C O U N T Y CHESTER COUNTY CHESTERFIELD COUNTY CLARENDON COUNTY COLLETON COUNTY DARLINGTON C O U N T Y DILLON COUNTY F A I R F I E L D COUNTY GEORGETOWN C O U N T Y JASPER COUNTY KERSHAW COUNTY LANCASTER COUNTY L A U R E N S COUNTY LEE COUNTY MCCORMICK COUNTY MARLBORO C O U N T Y NEWBERRY C O U N T Y OCONEE COUNTY SALUDA COUNTY SUMTER COUNTY UNION COUNTY ABBEVILLE CITY CALHOUN F A L L S TOWN OONALDS TOWN OUE WEST TOWN LOWNDESVILLE' TOWN NEW ELLENTON TOWN WAGENER TOWN ALLENDALE TOWN FAIRFAX TOWN SYCAMORE TOWN ULMER TOWN ANDERSON CITY BELTON CITY IVA TCWN WEST PELZER TCWN BAMBERG TOWN DENMARK CITY GOVAN TOWN OLAR TOWN BLACKVILLE TOWN ELKO TOWN HILDA TOWN PAGE255 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE25G OF THE DISTRESSED AREA ELIGIBILITY TE«ST (ELIGIBLE GOVERNMENTS) STATE TITLE 41 KLINE TOWN 41 SNELLING TOWN 41 ST STEPHEN TOWN 41 JAMESTOWN TOWN 41 CHESTER CITY 41 FCRT LAWN TOWN 41 LOWRYS TOWN 41 RICHBURG TOWN 41 GREAT FALLS TOWN 41 CHERAW TOWN 41 CHESTERFIELD TOWN 41 JEFFERSON TOWN 41 MCBEE TOWN 41 MOUNT CROGHAN TOWN 41 PAGELANO TOWN 41 PATRICK TOWN 41 RUBY TOWN 41 COTTAGEVILLE TOWN 41 LCDGE TOWN 41 SMOAKS TOWN 41 WALTERBORO TOWN 41 WILLIAMS TOWN 41 EDISTC BEACH TOWN 41 DARLINGTON CITY 41 HARTSVILLE CITY 41 LAMAR CITY 41 SOCIETY HILL TOWN 41 DILLON CITY 41 LAKEVIEW TOWN 41 LATTA TCWN 41 RIDGEWAY TOWN 41 WINNSBORO TOWN 41 LAKE CITY TOWN 41 TIMMONSVILLE; TOWN 41 FURMAN TOWN 41 LURAY TOWN 41 YEMASSEE TOWN 41 GIFFORD TOWN 41 RIDGELAND TOWN 41 BETHUNE TOWN 41 CAMDEN CITY 41 HEATH SPRINGS TOWN 41 CLINTON CITY 41 CROSS HILL TOWN «U GRAY COURT TOWN 41 LAURENS CITY TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OISTRESSEO STATE TITLE 41 WATERLOO TOWN 41 BISHOPVILLE TOWN 41 LYNCHBURG TOWN 41 MCCORMICK TOWN 41 MOUNT CARMEL TOWN 41 PARKSVILLE TOWN 41 PLUM BRANCH TOWN 41 BENNETTSVILLE CITY 41 BLENHEIM TOWN 41 CLIO TOWN 41 MCCOLL TOWN 41 TATUM TOWN 41 LITTLE MOUNTAIN TOWN 41 PEAK TOWN 41 POMARIA TOWN 41 SENECA TOWN 41 WALHALLA TOWN 41 WESTMINSTER TOWN 41 WEST UNION TOWN 41 BRANCHVILLE TOWN 41 NORWAY TOWN 41 RCWESVILLE TOWN 41 SANTEE TOWN 41 RIDGE SPRING TOWN 41 SALUDA TOWN 41 WARDS TOWN 41 MAYESVILLE TOWN 41 PINEWOOD TOWN 41 CARLISLE TOWN 41 UNION CITY 41 ROCK HILL CITY 41 YORK TOWN 266-274 O - 78 - 21 OF THE TREASURY AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE = 41: 124 RECORDS PAGE257 TEST 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE258 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 42 BUTTE COUNTY 42 CORSON COUNTY 42 HARDING COUNTY 42 HYDE COUNTY 42 WALWORTH COUNTY 42 WASHABAUGH COUNTY 42 ZIEBACH COUNTY 42 VIRGIL TOWN 42 FRUITDALE TOWN 42 NISLAND TOWN 42 MOUND CITY TOWN 42 PCLLOCK TOWN 42 HENRY TOWN 42 WALLACE TOWN 42 MCINTOSH CITY 42 MCLAUGHLIN CITY 42 MGRRISTOWN TOWN 42 GRENVILLE TOWN 42 LOYALTON TOWN 42 ONAKA TOWN 42 ORIENT TOWN STATE = 42: 21 RECORDS TREASURY 05/23/78 AT 01:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 42 BUFFALO TOWN STATE = 42: 1 RECOROS PAGE259 05/2 3/78 AT 31:25 U.S. DEPARTMENT PAGE260 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 42 kZ 42 42 42 42 42 42 42 42 TITLE BELVIDERE TOWN HILLSVIEW TOWN WETONKA TOWN EGAN CITY WARD TOWN WHITE ROCK TOWN AGAR TOWN GLENHAM TOWN JAVA CITY LCWRY TOWN M08RIDGE CITY LESTERVILLE TOWN DUPREE TOWN BRISTOL TOWNSHIP CRYSTAL LAiKE TOWNSHIP EUREKA TOWNSHIP PALATINE TOWNSHIP PLEASANT VALLEY TOWNSHIP BELLE PRAIRIE TOWNSHIP BONILLA TOWNSHIP BROADLAND TOWNSHIP CARLYLE TCWNSHIP FOSTER TOWNSHIP IOWA TOWNSHIP LIBERTY TOWNSHIP LOGAN TOWNSHIP NANCE TOWNSHIP SAND CREEK TOWNSHIP EAGLE TOWNSHIP HIGHLAND TOWNSHIP OLA TCWNSHIP PLEASANT GROVE TOWNSHIP RICHLAND TOWNSHIP SMITH TCWNSHIP WILBUR TOWNSHIP ELVIRA TOWNSHIP COTTONWOOD TOWNSHIP HOWARD TOWNSHIP LAWRENCE TOWNSHIP MOORE TOWNSHIP PLAIN CENTER TOWNSHIP REE TOWNSHIP EDEN TOWNSHIP GRACELAND TOWNSHIP WAVERLY TOWNSHIP DELANEY TOWNSHIP TREASURY 05/25/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 42 FAIRVIEW TOWNSHIP 42 GRAND VALLEY TOWNSHIP 42 LAKE TOWNSHIP 42 LINCOLN TOWNSHIP 42 MCLAUGHLIN TOWNSHIP 42 MAHTO TCWNSHIP 42 PIONEER TOWNSHIP 42 PLEASANT RIDGE TOWNSHIP 42 PRAIRIE VIEW TOWNSHIP 42 RIDGELAND TOWNSHIP 42 RIVERSIDE TOWNSHIP 42 ROLLING GREEN TOWNSHIP 42 SHERMAN TOWNSHIP 42 THUNDER HAWK TOWNSHIP 42 TWIN BUTTE TOWNSHIP 42 WAKPALA TOWNSHIP 42 WALKER TOWNSHIP 42 WATAUGA TOWNSHIP 42 MISSION TOWNSHIP 42 FARMINGTON TOWNSHIP 42 GRENVILLE TOWNSHIP 42 HIGHLAND TOWNSHIP 42 NUTLEY TOWNSHIP 42 OAK GULCH TOWNSHIP 42 RACINE TOWNSHIP 42 VALLEY TOWNSHIP 42 HOLLAND TCWNSHIP 42 CLEVELAND TOWNSHIP 42 CLOYD VALLEY TOWNSHIP 42 COTTONWOOD LAKE TOWNSHIP 42 GLOVER TOWNSHIP 42 HCSMER TOWNSHIP 42 NORTH BRYANT TOWNSHIP 42 ODESSA TOWNSHIP 42 POWELL TOWNSHIP 42 COTTONWOOO TOWNSHIP 42 PROVO TOWNSHIP 42 ARCADE TOWNSHIP 42 CENTERVILLE TOWNSHIP 42 ENTERPRISE TOWNSHIP 42 FAIRVIEW TOWNSHIP 42 ZELL TOWNSHIP 42 ELLSTON TOWNSHIP 42 FAIRFAX CIVIL TOWNSHIP 42 LANDING CREEK TOWNSHIP 42 PLEASANT VALLEY TOWNSHIP PAGE2&1 TREASURY 05/25/78 AT 31:25 U.S. DEPARTMENT PAGE262 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 42 STAR VALLEY TOWNSHIP 42 ALDEN TOWNSHIP 42 FAIRVIEW TOWNSHIP <t2 FLORENCE TOWNSHIP 42 HOWELL TOWNSHIP 42 LOGAN TOWNSHIP 42 MCNDAMIN TOWNSHIP 42 ONTARIO TOWNSHIP 42 PARK TOWNSHIP 42 ROSE HILL TOWNSHIP 42 SPRING TOWNSHIP 42 SPRING HILL TOWNSHIP 42 CROSS PLAINS TOWNSHIP 42 FAIR TOWNSHIP 42 LIBERTY TOWNSHIP 42 MILLTOWN TOWNSHIP 42 WITTENBERG TOWNSHIP 42 LINCOLN TOWNSHIP 42 VALLEY TOWNSHIP 42 WASHINGTON TOWNSHIP 42 Wf HAMILTON TGWNSHIP 42 LITTLE BUFFALO TOWNSHIP 42 ANINA TOWNSHIP 42 BLAINE TOWNSHIP 42 CROW TOWNSHIP 42 FRANKLIN TOWNSHIP 42 MARLAR TOWNSHIP 42 PLEASANT TOWNSHIP 42 CLARNO TOWNSHIP 42 BROOKFIELD TOWNSHIP 42 JEFFERSON TOWNSHIP 42 UNION TOWNSHIP 42 LINCOLN TOWNSHIP 42 WACKER TOWNSHIP 42 BUFFALO TOWNSHIP 42 DUMARCE TOWNSHIP 42 EDEN TOWNSHIP 42 FORT TOWNSHIP 42 PLEASANT VALLEY TOWNSHIP 42 SISSETON TOWNSHIP 42 CORN CREEK TOWNSHIP 42 MCSHER TOWNSHIP 42 NCRRIS TOWNSHIP 42 GRAFTON TOWNSHIP 42 MINER TOWNSHIP 42 ROCK CREEK TOWNSHIP TREASURY 05/2 5/76 AT 31:25 U.S. DEPARTMENT OF THE PAGE26J TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 42 ANDERSON TOWNSHIP 42 FLAT CREEK TOWNSHIP 42 STROOL TOWNSHIP 42 VROOMAN TOWNSHIP 42 DRY WOOD LAKE TWP 42 LAKE TOWNSHIP 42 LEE TOWNSHIP 42 AFTON TOWNSHIP 42 BENEDICT TOWNSHIP 42 JACKSON TOWNSHIP 42 LETCHER TOWNSHIP 42 LOGAN TOWNSHIP 42 ONEIDA TOWNSHIP 42 GARFIELD TOWNSHIP 42 STAR PRAIRIE TOWNSHIP 42 DGLTON TOWNSHIP 42 HURLEY TOWNSHIP 42 MARINOAHL TOWNSHIP H2 UTICA TOWNSHIP STATE = 42: 157 RECORDS TEST 05/25/78 AT 31:25 U.S. DEPARTMENT PAGE2&4 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 TITLE BEOFORD COUNTY CAMPBELL COUNTY CARROLL COUNTY CCFFEE COUNTY CROCKETT COUNTY CUMBERLAND COUNTY DECATUR COUNTY DYER COUNTY FAYETTE COUNTY FENTRESS COUNTY FRANKLIN COUNTY GI3S0N COUNTY GILES COUNTY GRAINGER COUNTY GREENE COUNTY GRUNDY COUNTY HAMBLEN COUNTY HAMILTON COUNTY HANCOCK COUNTY HARDEMAN COUNTY HAYWOOD COUNTY JACKSON COUNTY LAKE COUNTY LINCOLN COUNTY LOUDON COUNTY MCMINN COUNTY MARSHALL COUNTY MAURY COUNTY MEIGS COUNTY MONROE COUNTY MCORE COUNTY MORGAN COUNTY OVERTON COUNTY PICKETT COUNTY POLK COUNTY PUTNAM COUNTY ROANE COUNTY SCOTT COUNTY STEWART COUNTY VAN BUREN COUNTY WAYNE COUNTY WHITE COUNTY LAKE CITY TOWN SHELBYVILLE TOWN WARTRACE TOWN CLEVELAND CITY TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE265 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 43 JELLICO CITY 43 LA FOLLETTE CITY 43 CARYVILLE TOWN 43 JACKSBORO TOWN 43 AUBURNTOWN TOWN 43 ATWOOD CITY 43 BRUCETON TOWN 43 HCLLOW ROCK TOWN 43 HUNTINGDON TOWN 43 MCKENZIE CITY 43 MCLEMCRESVILLE TOWN 43 TREZEVANT TOWN 43 CLARKSBURG TOWN 43 ELIZABETHTON CITY 43 WATAUGA CITY 43 NEWPORT TOWN 43 PARROTTSVILLE TOWN 43 MANCHESTER CITY 43 ALAMO TOWN 43 BELLS TOWN 45 MAURY CITY TOWN 45 CRQSSVILLE CITY 45 PLEASANT HILL TOWN 43 CRAB ORCHARD CITY 43 DECATURVILLE TOWN 43 PARSONS TOWN 45 ALEXANDRIA TOWN 45 DCWELLTOWN TOWN 45 LIBERTY TOWN 43 TRIMBLE TCWN 43 LA GRANGE TOWN 43 MOSCOW TOWN 43 OAKLAND TOWN 43 ROSSVILLE TOWN 43 SOMERVILLE TOWN 43 GALLAWAY CITY 43 WILLISTON CITY 43 BRADEN TOWN 43 JAMESTOWN TOwN 43 ALLARDT TCWN 43 COWAN TOWN 43 DECHERD TOWN 43 HUNTLAND TOWN 43 WINCHESTER CITY 43 BRADFORD TOWN 45 DYER CITY TREASURY 05/25/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 43 45 43 43 43 45 43 TITLE GIBSON TOWN HUMBOLDT CITY MEDINA TOWN MILAN CITY RUTHERFORD TOWN TRENTON CITY YCRKVILLE TOWN ARDMORE CITY ELKTON TOWN LYNNVILLE TOWN PULASKI CITY MINOR HILL CITY RUTLEDGE CITY BAILEYTON GREENEVILLE TOWN TUSCULUM CITY MCSHEIM TOWN ALTAMONT TOWN PALMER TOWN TRACY CITY TOWN CCALMONT TOWN 8EERSHEBA SPRINGS TOWN MORRISTOWN TOWN CHATTANOOGA CITY LAKESITE CITY SNEEDVILLE TOWN BOLIVAR CITY HICKORY VALLEY TOWN HCRNSBY TOWN MIDOLETON TOWN SILERTON TOWN TOONE TOWN WHITEVILLE TOWN SALTILLO CITY SAVANNAH TOWN BROWNSVILLE TOWN STANTON CITY SARDIS TOWN GAINES80R0 TOWN JEFFERSON CITY TOWN WHITE PINE TOWN RIDGELY TOWN TIPTONVILLE CITY GATES TOWN HENNING TOWN IRON CITY TOWN PAGE2&G 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 43 FAYETTEVILLE CITY 43 LENOIR CITY CITY 43 L O U D O N TOWN 43 GREENBACK C I T Y 43 PHILADELPHIA C I T Y 43 A T H E N S CITY 43 ENGLEW003 TOWN 43 ETOWAH TOWN 43 NIOTA CITY 43 C A L H O U N CITY 43 RAMER CITY 43 MICHIE TOWN 43 S T A N T O N V I L L E TOWN 43 F I N G E R TOWN 43 DENMARK TOWN 43 C O R N E R S V I L L E TOWN 43 LEWISBURG TOWN 43 MOUNT P L E A S A N T TOWN 43 DECATUR TOWN 43 MADISONVILLE TOWN 43 SWEETWATER C I T Y 43 T E L L I C O P L A I N S TOWN <*3 VCNORE TOWN 45 LYNCHBURG TOWN 45 OAKDALE TOWN 43 LIVINGSTON TOWN 43 BYROSTOWN TOWN 43 BENTON CITY 43 DUCKTOWN CITY 43 ALGOOD TOWN 43 BAXTER TOWN 43 MONTEREY TOWN 43 D A Y T O N CITY 43 HARRIMAN CITY <*S K I N G S T O N C I T Y 43 RCCKWOOD C I T Y 43 ONEIDA CITY 43 HUNTSVILLE TOWN 43 CUMBERLAND C I T Y TOWN 43 D O V E R TOWN 43 SPENCER TOWN 43 MCMINNVILLE CITY 43 VIOLA TCWN 43 CLIFTON CITY TOWN 43 COLLINWOOD C I T Y 43 WAYNESBORO C I T Y OF THE TREASURY PAGE267 5/23/ '8 '^DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TE-ST (ELIGIBLE GOVERNMENTS) STATE TITLE A3 43 SPARTA CITY OCYLE TOHN STATE = <»3: 186 RECOROS 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 44 BEE COUNTY 44 BOWIE COUNTY 44 BREWSTER COUNTY 44 BROOKS COUNTY 44 BURLESON COUNTY 44 CALDWELL COUNTY 44 CAMP COUNTY 44 COLEMAN COUNTY 44 COLLINGSWORTH COUNTY 44 COMAL COUNTY 44 CCMANCHE COUNTY 44 CCNCHO COUNTY 44 CULBERSON COUNTY 44 DELTA COUNTY 44 QE WITT COUNTY 44 DICKENS COUNTY 44 DUVAL COUNTY 44 EASTLAND COUNTY 44 EDWARDS COUNTY 44 FANNIN COUNTY 44 FAYETTE COUNTY 44 GLASSCOC< COUNTY 44 GOLIAD COUNTY 44 GCNZALES COUNTY 44 GRAYSON COUNTY 44 HAMILTON COUNTY 44 HILL COUNTY 44 HCPKINS COUNTY 44 HOUSTON COUNTY 44 HUNT COUNTY 44 IRION COUNTY 44 JEFF DAVIS COUNTY 44 JIM HOGG COUNTY 44 JIM WELLS COUNTY 44 KENEDY COUNTY 44 KINNEY COUNTY 44 KLEBERG COUNTY 44 LAMAR COUNTY 44 LA SALLE COUNTY 44 LIVE OAK COUNTY 44 MCCULLOCH COUNTY 44 MCMULLEN COUNTY 44 MARION COUNTY 44 MASON COUNTY 44 MENARD COUNTY 44 MILAM COUNTY PAGE269 TREASURY ° 5 / " " 8 'I.^DEP.RTHENT OF THE TRE.SURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 44 MILLS COUNTY 44 MOTLEY COUNTY 44 NEWTON COUNTY 44 NCLAN COUNTY 44 PALO PINTC COUNTY 44 PRESIDIO COUNTY <»4 REAL COUNTY <t4 RED RIVER COUNTY 44 REEVES COUNTY 44 ROBERTSON COUNTY 44 RUNNELS COUNTY 44 SABINE COUNTY 44 SAN AUGUSTINE COUNTY 44 SAN SABA COUNTY 44 SHELBY COUNTY 44 TRINITY COUNTY 44 VAL VERDE COUNTY 44 WASHINGTON COUNTY 44 WILLACY COUNTY 44 ZAVALA COUNTY 4* BURKE CITY 44 HUDSON CITY 44 SAN FELIPE TOWN 44 BASTROP CITY 44 ELGIN CITY 44 BEEVILLE CITY 44 MERIDIAN CITY 44 MORGAN CITY 44 WALNUT SPRINGS CITY 44 DE KAL3 TOWN 44 HOOKS CITY 44 NEW BOSTON TOWN 44 TEXARKANA CITY 44 LEARY CITY 44 ALPINE TOWN 44 FALFURRIAS CITY 44 CALDWELL CITY 44 SNOOK CITY 44 LULING CITY 44 BLOOMBURG TOWN 44 HUGHES SPRINGS TOWN 44 MARIETTA TOWN 44 NOVICE CITY 44 SANTA ANNA TOWN 44 DODSON TOWN 44 WELLINGTON CITY P "E2"> 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE TREASURY OISTRESSEO AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 TITLE NEW B R A U N F E L S CIT COMANCHE C I T Y DE LEON CITY GUSTINE TOWN EDEN CITY VAN HORN TOWN TEXLINE TOWN HEREFORD C I T Y C O O P E R CITY PECAN GAP CITY CUERO CITY D I C K E N S CITY SPUR CITY HEDLEY TOWN 8ENAVIDES CITY C A R B O N TOWN CISCO CITY EASTLANO C I T Y GORMAN CITY RANGER CITY RISING STAR TOWN R O C K S P R I N G S TOWN BAILEY CITY BCNHAM CITY DCDD CITY TOWN ECTOR TOWN HONEY GROVE CITY LADONIA TOWN L E O N A R D CITY SAVOY TOWN TRENTON TOWN WINDOM TOWN F A Y E T T E V I L L E TOWN SCHULENBURG CITY CARMINE CITY STREETMAN TOWN WCRTHAM TOWN SEAGRAVES CITY GALVESTON CITY G O N Z A L E S CITY NIXON CITY WAELDER CITY MCLEAN CITY BELLS TOWN CCLLINSVILLEi TOWN OENISON CITY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE272, OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 44 «t4 44 44 44 44 44 44 TITLE GUNTER TOWN HOWE TOWN POTTSBORO TOWN TIOGA TOWN VAN ALSTYNE TOWN WHITES80R0 TOWN WHITEWRIGHT TOWN TCM BEAN TOWN SCUTHMAYD TOWN DORCHESTER TOWN SADLER CITY HAMILTON CITY CHILLICCTHE CITY CHANNING TOWN OBRIEN CITY ABBOTT TOWN HILLSBORO CITY ITASCA CITY MOUNT CALM TOWN PENELOPE TOWN CCMO TOWN CUMBY CITY CROCKETT CITY KENNARD TOWN CADDO MILLS CITY CELESTE TOWN COMMERCE CITY GREENVILLE CITY QUINLAN CITY WOLFE CITY CITY WEST TAWAKONI TOWN NEYLANDVILLE TOWN CAMPBELL TOWN BRYSON CITY VALENTINE TOWN PORT ARTHUR CITY ALICE CITY PREMONT CITY BRACKETTVILLE CITY SPOFFORD CITY KINGSVILLE CITY BENJAMIN CITY GCREE CITY PARIS CITY TOCO TOWN LCMETA TOWN TEST 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE273 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 44 CCTULLA CITY 44 GEORGE WEST CITY 44 THREE RIVERS CITY 44 MELVIN TOWN 44 JEFFERSON CITY 44 MENARD TOWN 44 CAMERON CITY 44 ROCKOALE CITY 44 BUCKHOLTS CITY ST ATE = 44: 193 RECORDS TREASURY PAGE274* 05/2 3/78 *5J!*"PARTMEMT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 44 MILAMO TOKN STATE = <*<*'• 1 RECOROS 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 44 GOLDTHWAITE CITY 44 MATADOR TOWN 44 CUSHING TOWN 44 GARRISON TOWN 44 CHI RE NO CITY 44 DAWSON CITY 44 KERENS TOWN 44 BARRY CITY 44 EMHOUSE TOWN 44 RICHLAND CITY 44 NEWTON CITY 44 BLACKWELL TOWN 44 SWEETWATER CITY 44 AGUA DULCE CITY 44 DRISCOLL CITY 44 RCBSTOWN CITY 44 GORDON TOWN 44 GRAFORD TOWN 44 MINGUS CITY 44 STRAWN CITY 44 MARFA CITY 44 CAMP WOOD CITY 44 LEAKEY CITY 44 ANNONA TOWN 44 AVERY TOWN 44 BGGATA TOWN 44 CLARKSVILLE CITY 44 PECOS CITY 44 BALMORHEA CITY 44 WOGDSBORO CITY 44 BREMOND CITY 44 CALVERT CITY 44 HEARNE CITY 44 WINTERS CITY 44 HEMPHILL CITY 44 PINELAND CITY 44 8R0NS0N CITY 44 SAN AUGUSTINE CITY 44 BROADDUS TOWN 44 SAN SA8A CITY 44 CENTER CITY 44 JOAQUIN TOWN 44 TIMPSON CITY 44 HUXLEY CITY 44 MEADOW TOWN ;T Atf = /./.• /. c; ocrnonc PAGE275 TREASURY PAGE27G. 05/23/78 A ^^ S ^p A R T M E N T OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 44 TITLE WELLMAN TOWN STATE = 44: 1 RECORDS TREASURY 05/2 3/78 AT 31:25 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE STATE 44 44 44 44 44 44 44 <#4 44 44 44 44 44 44 44 44 44 44 TITLE THROCKMORTON CITY GROVETON CITY TRINITY CITY WOODVILLE TOWN COLMESNEIL TOWN DEL RIO CITY GRAND SALINE CITY VAN CITY EDOM CITY BARSTOW TOWN GRANDFALLS TOWN WHARTON CITY VERNON CITY LYFORD TOWN RAYMONDVILLE CITY STOCKDALE CITY PLAINS TOWN CRYSTAL CITY CITY STATE = 44: 18 RECORDS PAGE277 OF THE TREASURY ELIGIBILITY TE'ST GOVERNMENTS) PAGE278 X 05/23/78 ^ # » » p A R T H E N T 0jr T H E DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 45 GARFIELD COUNTY 45 PIUTE COUNTY 45 RICH COUNTY 45 SANPETE COUNTY 45 MINERSVILLE TOWN 45 DEWEYVILuE ; TOWN 45 GARLAND CITY 45 MANTUA TOWN 45 PLYMOUTH TOWN 45 SNOWVILLE TOWN 45 ESCALANTE TOWN i»5 HATCH TOWN 45 EUREKA CITY <»5 NEPHI CITY 45 HOLDEN TOWN 45 KANOSH TOWN 45 LEAMINGTON TOWN 45 LYNNDYL TOWN 45 MEADOW TOWN 45 SCIPIO TOWN 45 CIRCLEVILLE TOWN 45 JUNCTION TOWN 45 KINGSTON TOWN 45 MARYSVALE TOWN 45 LAKETOWN TOWN 45 RANDOLPH TOWN d5 WOODRUFF TOWN 45 CENTERFIELD TCWN 45 EPHRAIM CITY 45 FAIRVIEW CITY 45 FAYETTE TOWN 45 FOUNTAIN GREEN C I T Y 45 GUNNISON CITY 45 MANTI CITY 45 MAYFIELD TOWN 45 MORONI CITY 45 MCUNT PLEASANT CITY 45 SPRING CITY 45 STERLING TOWN 45 WALES TOWN 45 HENEFER TOWN 45 SOLDIER SUMMIT TOWN 45 UINTAH BICKNELL TOWNCITY OGDEN HARRISVILLE CITY TOWN TREASURY 05/23/78 AT 31:25 U.S. OEPARTMEN T OF THE PAGE279. TREASURY DISTRESSED ARE A ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE STATE = 45: 46 RECORDS 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE280 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b GOVERNMENTS) TITLE 3ENNINGT0N COUNT FRANKLIN C OUNTY GRAND ISLE COUNT RUTLAND CO UNTY WINDHAM CO UNTY WINDSOR CO UNTY MANCHESTER VILLA GE NORTH 8ENN INGTON VILLAGE OLD 3ENNIN GTON V ILLAGE READS80R0 VILLAG E ENOSBURG F ALLS V ILLAGE RICHFORD V ILLAGE ST ALBANS CITY ALBURG VIL LAGE AL8ANY VIL LAGE BARTON VIL LAGE DERBY CENT ER VIL LAGE DER3Y LINE VILLA GE NEWPORT CI TY ORLEANS VI LLAGE POULTNEY V ILLAGE RUTLAND CI TY BELLOWS FA LLS VI LLAGE NEWFANE VI LLAGE N WESTMINS TER VI LLAGE SAXTONS RI VER VI LLAGE WESTMINSTE R VILL AGE LUDLOW VIL LAGE PERKINSVIL LE VIL LAGE PROCTORSVI LLE VI LLAGE ARLINGTON TCWN BENNINGTON TOWN DORSET TOW N LANDGROVE TOWN MANCHESTER TOWN PERU TOWN POWNAL TOW N READSBORO TOWN RUPERT TOW N SANDGATE T OWN SEARSBURG TOWN SHAFTSBURY TOWN STAMFORD T OWN SUNOERLAND TOWN WINHALL TO WN WOODFORD T OWN 05/2 3/78 AT 31:25 U.S. DEPARTMENT DISTRESSED 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b 4b OF THE TREASURY AREA ELIGIBILITY TEIST (ELIGIBLE STATE PAGE281 GOVERNMENTS) TITLE BARNET TOW N HARDWICK T OWN ST JOHNSBU RY TOWN BLOOMFIELO TOWN CANAAN TOW N GUILDHALL TOWN LEMINGTON TOWN 8AKERSFIEL 0 TOWN BERKSHIRE TOWN ENOSBURG T OWN FAIRFAX TO WN FAIRFIEL3 TOWN FLETCHER T OWN FRANKLIN T OWN GEORGIA TO WN HIGHGATE T OWN MCNTGOMERY TOWN RICHFORD T OWN ST AL8ANS TOWN SHELDON TO WN ALBURG TOW N ISLE LA MO TTE TOWN NORTH HERO TOWN BARTON TOW N BROWNINGTO N TOWN JAY TOWN TROY TOWN BENSON TOW N BRANOON TO WN CASTLETON TOWN CHITTENDEN TOWN CLARENDON TOWN DANBY TOWN FAIR HAVEN TOWN HUBBARDTON TOWN IRA TOWN MENDON TOW N MIDDLETOWN SPRINGS TOWN MOUNT H O L L Y TOWN PAWLET TOW N PITTSFIELD TOWN POULTNEY T OWN PROCTOR TO WN SHERBURNE TOWN SHREWSBURY TOWN SUDBURY TO WN 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE232 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 4b TINMCUTH TOWN 4b WALLINGFORD TOWN 4b WELLS TOWN 4b WEST HAVEN TOWN 4b WEST RUTLAND TOWN 4b ATHENS TOWN 4b BRATTLE80R0 TOWN 4b GRAFTON TOWN 4b LONDONDERRY TOWN 4b NEWFANE TOWN 4b PUTNEY TOWN 4b ROCKINGHAM TOWN 4b WESTMINSTER TOWN 4b WINDHAM TOWN 4b BALTIMORE TOWN 4b CAVENDISH TOWN 4b CHESTER TOWN 4b LUDLOW TOWN 4b READING TOWN 4b SPRINGFIELD TOWN 4b WEATHERSFIELD TOWN 4b WESTON TOWN 4b WEST WINDSOR TOWN 4b WINDSOR TOWN STATE = 4b: 1 lb RECORDS TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 47 ALLEGHANY COUNTY 47 BATH COUNTY 47 BLAND COUNTY 47 BRUNSWICK COUNTY 47 BUCKINGHAM COUNTY 47 CARROLL COUNTY 47 CHARLOTTE COUNTY 47 FLOYD COUNTY 47 GILES COUNTY 47 GREENSVILLE COUNTY 47 HIGHLAND COUNTY 47 KING AND QUEEN COUNTY 47 LUNENBURG COUNTY 47 NORTHAMPTON COUNTY 47 NORTHUMBERLAND COUNTY 47 NCTTOWAY COUNTY 47 PATRICK COUNTY 47 RICHMOND COUNTY 47 RCCKBRIDSE COUNTY 47 SHENANDOAH COUNTY 47 SMYTH COUNTY 47 SURRY COUNTY 47 SUSSEX COUNTY 47 IRON GATE TOWN 47 ALBERTA TOWN 47 LAWRENCEVILLE TOWN 47 CHARLOTTE TOWN 47 DRAKES BRANCH TOWN 47 KEYSVILLE TOWN 47 PHOENIX TOWN 47 BCYCE TOWN 47 FLOYD TOWN 47 GLEN LYN TOWN 47 NARROWS TOWN 47 PEARIS3URG TOWN 47 PEMBROKE TOWN 47 RICH CREEK TOWN 47 IRVINGTON TOWN 47 KENBRIDGE TOWN 47 VICTORIA TOWN 47 CAPE CHARLES TOWN 47 CHERITON TOWN 47 NASSAWADOX TOWN 47 BLACKSTGNE TOWN 47 BURKEVILLE TOWN 47 GCRDONSVILLE TOWN PAGE283 TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT DISTRESSED AREA (ELIGIBLE GOVERNMENTS) STATE TITLE 47 STANLEY TOWN 47 WARSAW TOWN 47 GLASGOW TOWN 47 GOSHEN TOWN 47 EDIN8URG TOWN 47 MOUNT JACKSON TOWN 47 NEW MARKET TOWN 47 TOMS BROOK TOWN 47 WOODSTOCK TOWN 47 CHILHOWIE TOWN 47 MARION TOWN 47 CLAREMONT TOWN 47 DENDRON TOWN 47 SURRY TOWN 47 STONY CREEK TOWN 47 WAKEFIELD TOWN 47 WAVERLY TOWN 47 MCNTROSS TOWN 47 BUENA VISTA CITY 47 CCVINGTON CITY 47 DANVILLE CITY 47 LEXINGTON CI TY 47 PETERSBURG CITY 47 RADFORD CITY 47 SCUTH BOSTON CITY 47 WAYNESBORO CITY STATE = 47: 72 RECORDS PAGE28 OF THE TREASURY ELIGIBILITY TE'ST 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 48 COLUMBIA COUNTY 48 COWLITZ COUNTY <#8 GARFIELD COUNTY 48 GRAYS HARBOR COUNTY 48 JEFFERSCN COUNTY 48 KING COUNTY 48 KITTITAS COUNTY 48 PACIFIC COUNTY 48 PIERCE COUNTY 48 SNOHOMISH COUNTY 48 WALLA WALLA COUNTY 48 LIND TOWN 48 RITZVILLE CITY 48 WASHTUCNA TOWN 48 LEAVENWORTH CITY 48 DAYTON CITY 48 STARBUCK CITY 48 KALAMA TOWN 46 KELSO CITY 48 LCNGVIEW CITY 48 PCMEROY CITY 46 CCULEE CITY TOWN 48 ELECTRIC CITY 48 EPHRATA CITY 46 HARTLINE TOWN 48 MCSES LAKE CITY 48 QUINCY TOWN 48 WILSON CREEK TOWN 48 MATTAWA TOWN 48 GEORGE CITY 48 ABERDEEN CITY 48 COSMOPOLIS TOWN 48 HCQUIAM CITY 48 MC CLEARY TOWN 48 OAKVILLE TOWN 48 WESTPORT CITY 48 PORT TOW.NSEND CITY 48 ALGONA CITY 48 AUBURN CITY 48 BEAUX ARTS VILLAGE 48 BOTHELL CITY 46 CARNATION TOWN 48 CLYDE HILL TOWN 48 DUVALL TOWN 48 ENUMCLAW CITY 48 HUNTS POINT TOWN PAGE265 TREASURY 05/23/76 AT 31:25 U.S. DEPARTMENT PAGE28G OF THE DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 48 ISSAQUAH CITY 48 KENT CITY 48 MEDINA CITY 48 PACIFIC TOWN 48 RENTON CITY 48 SEATTLE CITY 48 SKYKOMISH TOWN 48 SNOQUALMIE TOWN 48 TUKWILA CITY 48 BLACK DIAMOND TOWN 48 DES MOINES CITY 48 YARROW POINT TOWN 48 MERCER ISLAND CITY 48 LAKE FOREST PARK CITY 48 BREMERTON CITY 48 PCRT ORCHARD CITY 48 CLE ELUM CITY 48 ELLENSBURG CITY 48 KITTITAS TOWN 48 ROSLYN CITY 48 8INGEN TOWN 48 WHITE SALMON TOWN 48 TOLEDO TOWN 46 OROVILLE TOWN 48 TWISP TOWN 48 RAYMOND CITY 48 SCUTH BENO CITY 48 ICNE TOWN 48 3CNNEY LAKE TOWN 48 BUCKLEY CITY 48 CARBONADO TOWN 48 OUPONT CITY 48 GIG HARBOR TOWN 48 ORTING TOWN 48 PUYALLUP CITY 48 RCY CITY 48 SCUTH PRAIRIE TOWN 48 SUMNER CITY 48 TACOMA CITY 48 WILKESON TOWN 48 FIFE TOWN 46 LA CONNER TOWN 48 LYMAN TOWN 48 NCRTH BONNEVILLE TOWN 48 ARLINGTON CITY 48 DARRINGTON TOWN TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE287 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 48 EDMONOS CITY 48 EVERETT CITY 48 GOLD BAR TOWN 48 GRANITE FALLS TOWN 48 INDEX TOWN 48 MARYSVILLE CITY 48 MONROE CITY 48 MCUNTLAKE TERRACE CITY 48 MUKILTEO CITY 48 SNOHOMISH CI TY 48 STANWOOD CITY 48 SULTAN TOWN 46 WOODWAY TOWN 48 LYNNWOOD CITY 48 LAKE STEVENS TOWN 48 BRIER CITY 48 CHENEY CITY 48 MEDICAL LAKE TOWN 48 SPOKANE CITY 48 NCRTHPORT CITY 48 COLLEGE P U C E TOWN 48 WALLA nALLA CITY 48 GRANGER CITY 48 TOPPENISH CITY 48 YAKIMA CITY STATE = 48: 117 RECORDS TEST 05/23/78 AT 01:25 U.S. DEPARTMENT PAGE288 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 49 BERKELEY COUNTY 49 BRAXTON COUNTY 49 CABELL COUNTY 49 CALHOUN COUNTY 49 CLAY COUNTY 49 DODDRIDGE COUNTY 49 FAYETTE COUNTY 49 GILMER COUNTY 49 GRANT COUNTY 49 GREENBRIER COUNTY 49 HARRISON COUNTY 49 JACKSON COUNTY 49 LEWIS COUNTY 49 LINCOLN COUNTY 49 MARION COUNTY 49 MARSHALL COUNTY 49 MASON COUNTY 49 MINGO COUNTY 49 MONONGALIA COUNTY 49 MONROE COUNTY 49 MORGAN COUNTY 49 COUNTY OF OHIO 49 PENOLETCN COUNTY 49 POCAHONTAS COUNTY 49 PRESTON COUNTY 49 RANDOLPH COUNTY 49 RITCHIE COUNTY 49 ROANE COUNTY 49 SUMMERS COUNTY 49 TAYLOR COUNTY 49 TUCKER COUNTY 49 TYLER COUNTY 49 WAYNE COUNTY 49 WEBSTER COUNTY 49 WETZEL COUNTY 49 WIRT COUNTY 49 WOOD COUNTY 49 HEDGESVILLE TOWN 49 MARTINS6URG CITY 49 BURNSVILLE TOWN 49 FLATWOODS TOWN 49 GASSAWAY TOWN 49 SUTTON TOWN 49 HUNTINGTON CITY 49 CLAY TOWN 49 WEST UNION TOWN TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE2B9 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 49 TITLE ANSTED TOW N FAYETTEVIL LE; TOWN MEADOW BRI DGE TOWN MCUNT HOPE CITY PAX TOWN THURMOND T OWN GLENVILLE TOWN LAYOPOLIS TOWN FALLING SP RINGS TOWN QUINWOOD T OWN RAINELLE T OWN RONCEVERTE CITY CLARKSBURG CITY LOST CREEK TOWN LUMBERPORT TOWN NUTTER FOR T TOWN SALEM CITY ST0NEW003 TOWN ANMOORE TO WN RAVENSWOOD TOWN RIPLEY CIT Y JANE LEW T OWN WESTON CIT Y HAMLIN TOW N ANAWALT TO WN FAIRMONT C ITY FAIRVIEW T OWN FARMINGTON TOWN GRANT TCWN TOWN MANNINGTON CITY MONONGAH T OWN RIVESVILLE TOWN WORTHINGTO N TOWN BARRACKVIL LE TOWN BENWOOD CI TY CAMERON CI TY MCMECHEN C ITY MOUNDSVILL E CITY HARTFORD T OWN HENDERSON TOWN LEON VILLA GE MASON TOWN NEW HAVEN TOWN POINT PLEA SANT CITY BRAMWELL T OWN MATOAKA TO WN TREASURY )5/23/78 AT 31:25 U.S. DEPARTMENT PAGE290 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 TITLE OAKVALE TO WN PIEDMONT C ITY RIDGELEY T OWN GILBERT TO WN MATEWAN TO WN WILLIAMSON CITY MCRGANTOWN CITY OSAGE TOWN PETERSTOWN TOWN U M O N TOWN BATH TOWN PAW PAW TO WN RICHWOOD C ITY CASS TOWN DURBIN TOWN HILLSBORO VILLAGE MARLINTON TOWN ALBRIGHT T OWN BRANDONVIL LE CORPORATION NEWBURG TO WN ROWLESBURG TOWN TUNNELTON TCWN BEVERLY TO WN ELKINS CIT Y TCWN HARMA N HUTTONSVIL LE TOWN MILL CREEK TOWN MONTROSE C ORPORATION WCMELSOORF F TOWN AUBURN TOW N CAIRO TCWN ELLENBORO TOWN HARRISVILL E TOWN PENNSBORO CITY PULLMAN TO WN REEDY TOWN SPENCER CI TY HINTON CIT Y FLEMINGTON TOWN GRAFTON CI TY DAVIS TOWN HAMBLETON TOWN HENDRICKS TOWN PARSONS CITY THOMAS TOWN FRIENDLY TOWN TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE291 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE GOVERNMENTS) STATE TITLE 49 MIDDLE80URNE TOWN 49 CEREDO TOWN 49 FORT GAY TOWN 49 KENOVA CITY 49 WAYNE TOWN 49 ADDISON TOWN 49 CAMDEN ON GAULEY 49 COWEN TOWN 49 HUNDRED TOWN 49 LITTLETON TOWN 49 NEW MARTINSVILLE 49 PINE GROVE TOWN 49 SMITHFIELD TOWN 49 ELIZABETH TOWN STATE = 49: 152 RECORDS TOWN CITY TEST 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE292 OF THE OISTRESSEO AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 ASHLAND COUNTY 50 8AYFIEL0 COUNTY 50 BUFFALO COUNTY 50 CHIPPEWA COUNTY 50 COLUMBIA COUNTY 50 CRAWFORD COUNTY 50 DOUGLAS COUNTY 50 FLORENCE COUNTY 50 FOREST COUNTY 50 GREEN LAKE COUNTY 50 IOWA COUNTY 50 IRON COUNTY 50 KEWAUNEE COUNTY 50 LAFAYETTE COUNTY 50 MARQUETTE COUNTY 50 MONROE COUNTY 50 RICHLAND COUNTY 50 RUSK COUNTY 50 SAUK COUNTY 50 SHAWANO COUNTY 50 VERNON COUNTY 50 WASHBURN COUNTY 50 ASHLAND CITY 50 BUTTERNUT VILLAGE 50 MELLEN CITY 50 BAYFIELD CITY 50 CABLE VILLAGE 50 MASON VILLAGE 50 WASHBURN CITY 50 FOUNTAIN CITY CITY 50 MCNDOVI CITY 50 BLOOMER CITY 50 CAOOTT VILLAGE 50 CHIPPEWA FALLS CITY 50 CORNELL CITY 50 STANLEY CITY 50 CAMBRIA VILLAGE 50 CCLUMBUS CITY 50 DOYLESTOWN VILLAGE 50 FALL RIVER VILLAGE 50 FRIESLAND VILLAGE 50 LCDI CITY 50 PORTAGE CITY 50 PCYNETTE VILLAGE 50 RIO VILLAGE 50 WYOCENA VILLAGE TREASURY 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 BELL CENTER VILLAGE 50 EASTMAN V I L L A G E 50 G A Y S MILLS V I L L A G E 50 LYNXVILLE V I L L A G E 50 P R A I R I E 3U C H I E N CITY 50 SOLOIERS GROVE VILLAGE 50 STEUBEN V I L L A G E 50 WAUZEKA V I L L A G E 50 FOX LAKE C I T Y 50 KEKOSKEE V I L L A G E 50 OLIVER VILLAGE 50 S U P E R I O R CITY 50 BRANDON V I L L A G E 50 RIPCN CITY 50 MT CALVARY V I L L A G E 50 CRANDON CITY 50 KINGSTON VILLAGE 50 PRINCETGN CITY 50 AVQCA V I L L A G E 50 DCDGEVILLE CITY 50 LINDEN VILLAGE 50 REWEY VILLAGE 50 RIDGEWAY V I L L A G E 50 HURLEY CITY 50 MONTREAL C I T Y 50 MERRILLAN V I L L A G E 50 ALGOMA CITY 50 CASCO VILLAGE 50 KEWAUNEE CITY 50 ARGYLE VILLAGE 50 BENTON VILLAGE 50 DARLINGTON C I T Y 50 GRATIOT V I L L A G E 50 SHULLSBURG C I T Y 50 MERRILL CITY 50 TWO RIVERS C I T Y 50 8R0KAW VILLAGE 50 ELDERON V I L L A G E 50 FENWOOO VILLAGE 50 STRATFORD V I L L A G E 50 ENDEAVOR V I L L A G E 50 MCNTELLO C I T Y 50 OXFORD VILLAGE 50 WESTFIELD V I L L A G E 50 MILWAUKEE CITY 50 KENDALL VILLAGE PAGE293 OF THE TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE294 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 MELVINA VILLAGE 50 WILTON VILLAGE 50 WYEVILLE VILLAGE 50 WARRENS VILLAGE 50 GILLETT CITY 50 LENA VILLAGE 50 OCONTO CITY 50 OCONTO FALLS CITY 50 CENTURIA VILLAGE 50 LUCK VILLAGE 50 YU8A VILLAGE 50 BELOIT CITY 50 FOOTVILLE VILLAGE 50 BRUCE VILLAGE 50 CONRATH VILLAGE 50 GLEN FLORA VILLAGE 50 HAWKINS VILLAGE 50 INGRAM VILLAGE 50 LADYSMITH CITY 50 TCNY VILLAGE 50 WEYERHAEUSER VILLAGE 50 BARABOO CITY 50 IRONTON VILLAGE 50 LAKE OELTON VILLAGE 50 LA VALLE VILLAGE 50 LIME RIDGE VILLAGE 50 LOGANVILLE VILLAGE 50 MERRIMAC VILLAGE 50 NORTH FREEDOM VILLAGE 50 PLAIN VILLAGE 50 REEOSBURG CITY 50 ROCK SPRINGS VILLAGE 50 SAUK CITY VILLAGE 50 SPRING GREEN VILLAGE 50 CCUDERAY VILLAGE 50 MATTOON VILLAGE 50 SHAWANO CITY 50 TIGERTON VILLAGE 50 CASCADE VILLAGE 50 GLENBEULAH VILLAGE 50 LUBLIN VILLAGE 50 GENOA VILLAGE 50 LA FARGE VILLAGE 50 ONTARIO VILLAGE 50 READSTOWN VILLAGE 50 VIROQUA CITY TREASURY 05/23/78 AT 01:25 U.S. DEPARTMENT OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 5G 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 TITLE WESTBY CITY EAGLE RIVER CITY DELAVAN CITY S H A R O N VILLAGE W I L L I A M S B<VY V I L L A G E BIRCHWOOD V I L L A G E MINONG VILLAGE SHELL LAKE C I T Y S P O O N E R CITY BIG FALLS V I L L A G E C L I N T O N V I L L E CITY OGDENSBURG V I L L A G E HANCOCK VILLAGE LOHRVILLE VILLAGE PLAINFIELD VILLAGE WAUTOMA CITY AGENDA TOWN ASHLAND TOWN CHIPPEWA TOWN G I N G L E S TCWN G O R D O N TOWN J A C O B S TOWN LA POINTE TOWN MARENGO TOWN MORSE TOWN PEEKSVILLE TOWN SANBGRN TOWN SHANAGOLDEN TOWN WHITE RIVER TOWN BARKSDALE TOWN BARNES TOWN B A Y F I E L D TOWN BAYVIEW TOWN BELL TOWN CABLE TCWN CLOVER TOWN DELTA TOWN DRUMMOND TOWN EILEEN TOWN H U G H E S TOWN IRON RIVER TOWN KELLY TCWN K E Y S T O N E TOWN LINCOLN TOWN MASON TOWN NAMAKAGON TOWN PAGE295 0 5 / 2 3 / 7 8 AT 3 1 : 2 5 U.S. D E P A R T M E N T DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 ORIENTA TOWN 50 OULU TOWN 50 PILSEN TOWN 50 PCRT WING TOWN 50 GRANDVIEW TOWN 50 RUSSELL TOWN 50 TRIPP TOWN 50 WASHBURN TOWN 50 ALMA TOWN 50 BELVIOERE TOWN 50 CANTON TOWN 50 C R O S S TOWN 50 DOVER TOWN 50 GILMANTON TOWN 50 LINCOLN TOWN 50 MAXVILLE TOWN 50 MILTON TOWN 50 MGDENA TOWN 50 MONTANA TOWN 50 WAUMANDEE TOWN 50 ANDERSON TOWN 50 BLAINE TOWN 50 GRANTS8URG TOWN 50 LA FOLLETTE TOWN 50 LINCOLN TOWN 50 ROOSEVELT TOWN 50 WCOD RIVER TOWN 50 ARTHUR TOWN 50 AUBURN TOWN 50 C O O K S VALLEY TOWN 50 OELMAR TOWN 50 EDSON TOWN 50 ESTELLA TOWN 50 G O E T Z TOWN 50 RUBY TOWN 50 W C O D M O H R TOWN 50 ARLINGTON TOWN 50 CALEDONIA TOWN 50 C C L U M B U S TOWN 50 C C U R T L A N D TOWN 50 DEKORRA TOWN 50 FORT W I N N E 3 A G 0 TOWN 50 F O U N T A I N P R A I R I E TOWN 50 H A M P D E N TOWN >0 LEEDS TOWN >0 LEWISTON TOWN PAGE29G OF THE TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE297 OF THE TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE STATE 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 TITLE LOWVILLE TOWN MARCELLON TOWN NEWPORT T OWN OTSEGO TO WN PACIFIC T OWN RANDOLPH TOWN SCOTT TOW N WYOCENA T OWN CLAYTON T OWN FREEMAN T OWN SCOTT TOW N UTICA TOW N WAUZEKA T OWN CLYMAN TO WN ELBA TOWN EMMET TOW N FOX LAKE TOWN LEBANON T OWN LEROY TOW N PORTLAND TOWN SHIELDS T OWN THERESA T OWN PARKLANO TOWN AURORA TO WN COMMCNWEA LTH TOWN FENCE TOW N FERN TOWN HOMESTEAD TOWN TIPLER TO WN ASHFORD T OWN ELOORADO TOWN EMPIRE TO WN SPRINGVAL E TOWN WAUPUN TO WN ALVIN TOW N ARGONNE T OWN ARMSTRONG CREEK BLACKWELL TOWN CASWELL T OWN CRANDCN T OWN FREEDOM T OWN HILES TOW N LAONA TOW N LINCOLN T OWN NASHVILLE TOWN POPPLE RI VER TCWN GOVERNMENTS) 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE298 OF THE DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 ROSS TOWN 50 WABENO TOWN 50 GREEN LAKE TOWN 50 MACKFORD TOWN 50 MARQUETTE TOWN 50 ST MARIE TOWN 50 SENECA TOWN 50 ARENA TOWN 50 8RIGHAM TOWN 50 CLYOE TOWN 50 OCDGEVILLE TOWN 50 HIGHLANO TOWN 50 LINDEN TOWN 50 MIFFLIN TOWN 50 MINERAL POINT TOWN 50 MOSCOW TOWN 50 PULASKI TOWN 50 WALDWICK TOWN 50 ANDERSON TOWN 50 CAREY TOWN 50 GURNEY TOWN 50 KIMBALL TOWN 50 KNIGHT TOWN 50 PENCE TOWN 50 SAXON TOWN 50 AHNAPEE TOWN 50 CARLTON TOWN 50 CASCO TOWN 50 FRANKLIN TOWN 50 LINCOLN TOWN 50 LUXEMBURG TOWN 50 RED RIVER TOWN 50 WEST KEWAUNEE TOWN 50 ARGYLE TOWN 50 BENTON TOWN 50 DARLINGTON TOWN 50 ELK GROVE TOWN 50 FAYETTE TOWN 50 KENOALL TOWN 50 LAMONT TOWN 50 NEW DIGGINGS TOWN 50 SEYMOUR TOWN 50 SHULLSBURG TOWNSHIP 50 WAYNE TOWN 50 WHITE OAK SPRINGS TOWN 50 WILLOW SPRINGS TOWN TREASURY 05/23/78 AT 31:25 U.S. DEPARTMENT PAGE299 OF THE DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 WIOTA TOWN 50 NEVA TOWN 50 NORWOOD TOWN 50 PECK TOWN 50 VILAS TOWN 50 HARDING TOWN 50 RUSSELL TOWN 50 SCMO TOWN 50 CATO TOWN 50 KOSSUTH TOWN 50 LIBERTY TOWN 50 MANITOWOC TOWN 50 MISHICOT TOWN 50 TWO CREEKS TOWN 50 TWO RIVERS TOWN 50 BERLIN TOWN 50 8RIGHT0N TOWN 50 CASSEL TOWN 50 CLEVELAND TOWN 50 DAY TOWN 50 EASTON TOWN 50 EAU PLEINE TCWN 50 EMMET TOWN 50 FRANZEN TOWN 50 GREEN VALLEY TOWN 50 HALSEY TOWN 50 HEWITT TOWN 50 HCLTON TOWN 50 HULL TOWN 50 JOHNSON TOWN 50 MAINE TOWN 50 MARATHON TOWN 50 RIB FALLS TOWN 50 REITBROC* TOWN 50 SPENCER TOWN 50 WAUSAU TOWN 50 WIEN TOWN 50 BUFFALO TOWN 50 CRYSTAL LAKE TOWN 50 DOUGLAS TOWN 50 HARRIS TOWN 50 NESHKORO TOWN 50 NEWTON TOWN 50 OXFORD TOWN 50 PACKWAUKEE TCWN 50 SHIELDS TOWN TREASURY .,^a AT ^i-7S 05/25/78 A ; / s ; - ^ p A R T M E N T PAGE300 0F THE DISTRESSED AREA ELIGIBILITY TE'ST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 SPRINGFIELD TOWN 50 ANGELO TOWN 50 CLIFTON TOWN 50 GLENDALE TOWN 50 GRANT TCWN 50 GREENFIELD TOWN 50 JEFFERSON TOWN 50 LAFAYETTE TOWN 50 NEW LYME TOWN 50 PORTLAND TOWN 50 RIDGEVILLE TOWN 50 SCOTT TOWN 50 SHELDON TOWN 50 SPARTA TOWN 50 WELLINGTON TOWN 50 WELLS TCWN 50 WILTON TOWN 50 BAGLEY TOWN 50 BRAZEAU TOWN 50 LENA TOWN 50 LITTLE RIVER TOWN 50 MAPLE VALLEY TOWN 50 OCONTO FALLS TOWN 50 SPRUCE TOWN 50 STILES TOWN 50 UNOERHILL TOWN 50 CLAM FALLS TOWN 50 CLEAR LAKE TOWN 50 FARMINGTON TOWN 50 MCKINLEY TOWN 50 AKAN TOWN 50 BLOOM TOWN 50 8UENA VISTA TOWN 50 OAYTON TOWN 50 EAGLE TOWN 50 FOREST TOWN 50 HENRIETTA TOWN 50 ITHACA TOWN 50 MARSHALL TOWN 50 RICHWOOD TOWN 50 ROCKBRIDGE TOWN 50 SYLVAN TOWN 50 WESTFORD TOWN 50 AVON TOWN 50 CENTER TOWN 50 JANESVILLE TOWN TREASURY 05/23/78 AT 0 1 : 2 5 U.S. DEPARTMENT PAGE301 OF THE TREASURY DISTRESSED AREA ELIGIBILITY (ELIGIBLE STATE 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 50 TITLE JOHNSTOWN TOWN LIMA TOWN NEWARK TOWN PORTER TOWN ROCK TOWN SPRING VALLElY TOWN ATLANTA TOWN BIG BEND TOWN BIG FALLS TOWN CEOAR RAPIDS TOWN DEWEY TOWN FLAMBEAU TOWN GRANT TOWN GROW TCWN HAWKINS TOWN HUBBARD TOWN LAWRENCE TOWN MURRY TOWN RICHLAND TOWN RUSK TOWN SOUTH FORK TOWN STRICKLAND TOWN STUBBS TOWN THORNAPPLE TOWN TRUE TOWN WASHINGTON TOWN WILKINSON TOWN WILLARD TCWN WILSON TOWN BARA800 TOWN BEAR CREEK TOWN DELLONA TCWN DELTON TOWN EXCELSIOR TOWN FAIRFIELJ TOWN FRANKLIN TOWN FREEDOM TOWN GREENFIELD TOWN HONEY CREEK TOWN IRONTON TOWN LA VALLE TOWN MERRIMAC TOWN SPRING GREEN TOWN SUMPTER TOWN TROY TOWN WASHINGTON TOWN GOVERNMENTS) TEST ^ .«.oc 05/23/76 A T H . 2 5 p A R [ M £ N T PAGE332 op DISTRESSED AREA ELIGIBILITY TEIST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 WESTFIELD TOWN 50 WINFIELD TOWN 50 WOODLANO TOWN 50 RADISSON TOWN 50 WEIRGOR TOWN 50 BELLE PLAINE TOWN 50 FAIRBANKS TOWN 50 GRANT TOWN 50 GREEN VALLEY TOWN 50 HERMAN TOWN 50 MORRIS TOWN 50 NAVARINO TOWN 50 PELLA TOWN 50 RED SPRING TOWN 50 SENECA TOWN 50 WAUKECHCN TOWN 50 HUTCHINS TOWN 50 GFEENBUSH TOWN 50 LIMA TOWN 50 MOSEL TOWN 50 AURORA TOWN 50 CLEVELAND TOWN 50 GOODRICH TOWN 50 GRCVER TOWN 50 HCLWAY TOWN 50 MCKINLEY TOWN 50 MAPLEHURST TOWN 50 MCLITCR TOWN 50 TAFT TOWN 50 CLINTON TOWN 50 COON TOWN 50 FOREST TOWN 50 GENOA TOWN 50 JEFFERSON TOWN 50 LIBERTY TOWN 50 STARK TOWN 50 STERLING TOWN 50 UNION TOWN 50 VIROQUA TOWN 50 WHEATLAND TOWN 50 WHITESTOWN TOWN 50 LAC DU FLAMBEAU TOWN 50 PHELPS TOWN 50 DELAVAN WASHINGTON DARIEN TOWN TOWNTOWN ^ TREASURy 05/23/78 AT 31:25 U.S. DEPARTMENT OF THE PAGE303 TREASURY DISTRESSED AREA ELIGIBILITY TEST (ELIGIBLE GOVERNMENTS) STATE TITLE 50 GENEVA TOWN 50 SHARON TOWN 50 BARRONETT TOWN 50 BASHAW TOWN 50 BASS LAKE TOWN 50 BEAVER BROOK TOWN 50 BIRCHWOOD TOWN 50 BROOKLYN TOWN 50 CASEY TOWN 50 CHILOG TOWN 50 CRYSTAL TOWN 50 EVERGREEN TOWN 50 FROG CREEK TOWN 50 GULL LAKE TOWN 50 LONG LAKE TOWN 50 MINCNG TOWN 50 SARONA TOWN 50 SPOONER TOWN 50 SPRINGBROOK TOWN 50 STINNETT TOWN 50 STONE LAKE TOWN 50 BEAR CREEK TOWN 50 OUPONT TOWN 50 LARRABEE TOWN 50 LITTLE WOLF TOWN 50 MATTESON TOWN 50 UNION TOWN 50 WEYAUWEGA TOWN 50 WYOMING TOWN 50 AURORA TOWN 50 3L00MFIELD TOWN 50 COLOMA TOWN 50 DEERFIELD TOWN 50 LEON TOWN 50 OASIS TOWN 50 PCYSIPPI TOWN 50 ROSE TOWN 50 WARREN TOWN STATE = 50: 544 RECORDS FINAL TOTALS: 12142 RECORDS U. S. GOVERNMENT PRINTING OFFICE : 1978 O - 266-274 FOR IMMEDIATE RELEASE May 26, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY ACTS ON ANTIDUMPING CASES INVOLVING IMPORTS OF STEEL WIRE STRAND FROM JAPAN AND INDIA The Treasury Department said today that it has tentatively determined that steel wire strand for prestressed concrete from Japan is being sold in the United States at less than fair value. In another action, the Treasury Department announced that it has made a final determination that steel wire strand for prestressed concrete from India is being sold here at less than fair value. Appraisement is being withheld on imports from both countries. Under the Antidumping Actf the Secretary of the Treasury is required to withhold appraisement whenever he has reasonable cause to believe or suspect that "sales at less than fair value" are taking place. Sales at less than fair value, as defined by the Antidumping Act, generally occur when imported merchandise is sold in the United States for less than in the home market or in third countries. Withholding of appraisement means that the valuation for customs duty purposes of the goods is suspended until completion of the investigation, thus allowing any dumping duties that are ultimately imposed to be levied on those imports. The Indian case is being referred to the U. S. International Trade Commission (ITC), which must decide within 90 days whether a U. S. industry is being, or is likely to be, injured by these sales. If the ITC finds that one is, dumping duties will be assessed. A final Treasury decision in the Japanese case must be made by August 31, 1978. Notice of these actions will appear in the Federal Register of May 31, 1978. Imports of steel wire strand for prestressed concrete from Japan amounted to $19.6 million during the period June-November 1977. Imports of this merchandise from India were valued at $249,000 during the period January-June 1977. B-947 o0o mtment of theJREASURY HNGTON, D.C. 20220 TELEPHONE 566-2041 FOR R E L E A S E TUESDAY, M A Y 30, 1978 AMs S T A T E M E N T BY S E C R E T A R Y OF T H E T R E A S U R Y W. MICHAEL BLUMENTHAL The A p p r o p r i a t i o n s C o m m i t t e e of the H o u s e of R e p r e s e n t a t i v e s t h i s p a s t w e e k r e p o r t e d the F o r e i g n A s s i s t a n c e and R e l a t e d P r o g r a m s A p p r o p r i a t i o n s Bill, including $2,628 m i l l i o n for the i n t e r n a t i o n a l f i n a n c i a l i n s t i t u t i o n s — the W o r l d B a n k f a m i l y , the I n t e r - A m e r i c a n D e v e l o p m e n t B a n k , the A s i a n D e v e l o p m e n t B a n k and the A f r i c a n D e v e l o p m e n t F u n d . This figure is $876 million less than the Adm i n i s t r a t i o n ' s r e q u e s t . W e b e l i e v e that the C o m m i ttee's r e c o m m e n d a t i o n is the a b s o l u t e m i n i m u m a m o u n t w h i c h is c o n s i s t e n t w i t h t h e i n t e r e s t s of the U n i t e d States in the d e v e l o p i n g w o r l d , and w i t h our d e s i r e to bring a b o u t c o n s t r u c t i v e p o l i c y c h a n g e s in the international f i n a n c i a l i n s t i t u t i o n s . W e w i l l u r g e the House of R e p r e s e n t a t i v e s to r e s i s t a n y a d d i t i o n a l r e d u c t i o n s w h i c h m a y b e p r o p o s e d o n the f l o o r . The Administration strongly supports the international f i n a n c i a l i n s t i t u t i o n s . W e b e l i e v e that these o r g a n i z a t i o n s e f f e c t i v e l y s e r v e a b r o a d r a n g e of U . S . p o l i t i c a l , s e c u r i t y , e c o n o m i c and h u m a n i t a r i a n interests b e c a u s e : — they are extremely effective channels of dev e l o p m e n t a s s i s t a n c e to the p o o r e s t in the w o r l d ; countries — they assure burden-sharing among donor countries; o t h e r s p u t up $3 for e v e r y $1 c o n t r i b u t e d by the United S t a t e s ; — they spend $2 in the United States for every $1 w e p a y into them. We have therefore urged the Congress, both in formal t e s t i m o n y and in i n f o r m a l d i s c u s s i o n s w i t h B-948 FOR IMMEDIATE RELEASE May 26, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY ACTS ON ANTIDUMPING CASES INVOLVING IMPORTS OF STEEL WIRE STRAND FROM JAPAN AND INDIA The Treasury Department said today that it has tentatively determined that steel wire strand for prestressed concrete from Japan is being sold in the United States at less than fair value. In another action, the Treasury Department announced that it has made a final determination that steel wire strand for prestressed concrete from India is being sold here at less than fair value. Appraisement is being withheld on imports from both countries. Under the Antidumping Act, the Secretary of the Treasury is required to withhold appraisement whenever he has reasonable cause to believe or suspect that "sales at less than fair value" are taking place. Sales at less than fair value, as defined by the Antidumping Act, generally occur when imported merchandise is sold in the United States for less than in the home market or in third countries. Withholding of appraisement means that the valuation for customs duty purposes of the goods is suspended until completion of the investigation, thus allowing any dumping duties that are ultimately imposed to be levied on those imports. The Indian case is being referred to the U. S. International Trade Commission (ITC), which must decide within 90 days whether a U. S. industry is being, or is likely to be, injured by these sales. If the ITC finds that one is, dumping duties will be assessed. A final Treasury decision in the Japanese case must be made by August 31, 1978. Notice of these actions will appear in the Federal Register of May 31, 1978. Imports of steel wire strand for prestressed concrete from Japan amounted to $19.6 million during the period June-November 1977. Imports of this merchandise from India were valued at $249,000 during the period January-June 1977. B-947 o0o mmentoftheJREASURY NGTON, D.C. 20220 TELEPHONE 566-2041 FOR R E L E A S E TUESDAY, MAY 30, 1978 AMs S T A T E M E N T BY S E C R E T A R Y OF T H E T R E A S U R Y W. MICHAEL BLUMENTHAL The A p p r o p r i a t i o n s C o m m i t t e e of the H o u s e of R e p r e s e n t a t i v e s this p a s t w e e k r e p o r t e d the F o r e i g n A s s i s t a n c e and R e l a t e d P r o g r a m s A p p r o p r i a t i o n s Bill, including $2,628 m i l l i o n for the i n t e r n a t i o n a l f i n a n c i a l i n s t i t u t i o n s — the W o r l d B a n k family, the I n t e r - A m e r i c a n D e v e l o p m e n t B a n k , the A s i a n D e v e l o p m e n t B a n k and the A f r i c a n D e v e l o p m e n t F u n d . This figure is $876 million less than the Adm i n i s t r a t i o n ' s r e q u e s t . W e b e l i e v e that the C o m m i ttee's r e c o m m e n d a t i o n is the a b s o l u t e m i n i m u m a m o u n t w h i c h is c o n s i s t e n t w i t h the i n t e r e s t s of the U n i t e d States in the d e v e l o p i n g w o r l d , and w i t h our d e s i r e to bring a b o u t c o n s t r u c t i v e p o l i c y c h a n g e s in the international f i n a n c i a l i n s t i t u t i o n s . W e w i l l u r g e the House of R e p r e s e n t a t i v e s to r e s i s t any a d d i t i o n a l r e d u c t i o n s w h i c h m a y be p r o p o s e d o n the f l o o r . The Administration strongly supports the international f i n a n c i a l i n s t i t u t i o n s . W e b e l i e v e that these o r g a n i z a t i o n s e f f e c t i v e l y s e r v e a broad r a n g e of U . S . p o l i t i c a l , s e c u r i t y , e c o n o m i c and h u m a n i t a r i a n interests b e c a u s e : — they are extremely effective channels of dev e l o p m e n t a s s i s t a n c e to the p o o r e s t in the w o r l d ; countries — they assure burden-sharing among donor countries; o t h e r s p u t up $3 for e v e r y $1 c o n t r i b u t e d by the United S t a t e s ; — they spend $2 in the United States for every $1 w e pay into them. We have therefore urged the Congress, both in formal t e s t i m o n y and in i n f o r m a l d i s c u s s i o n s w i t h B-948 - 2 many individual members, to support a level of appropriations as close as possible to the Administration's request of $3 ,5 05 million. In its report, the Appropriations Committee also decided not to recommend any legislative restrictions on the use of U.S. funds by the international financial institutions. Under provisions of their charters, the banks cannot accept restricted funds. Passage of legislation with such restrictions would have the effect of taking the United States out of the development banks. This, in turn, could remove the banks from the international development process. The Committee's decision in this respect was particularly significant, and is gratifying because of the high priority the Administration places on continued U.S. participation and support for the international financial institutions. oOo tpartmentoftheTREASURY SHINGTON, D.C. 20220 TELEPHONE tr6p>041 Contact: FOR IMMEDIATE RELEASE Carolyn M. Johnston (202) 634-5377 May 23, 1978 SELLARS REAPPOINTED CHAIRMAN OF SAVINGS BONDS COUNCIL Richard B. Sellars, Chairman of the Finance Committee of the Board, Johnson § Johnson, New Brunswick, N.J., has accepted reappointment as the National Chairman of the Savings Bonds Volunteer State Chairmen's Council through December 3 1 , 1979. The appointment was made by Secretary of the Treasury W. Michael Blumenthal. Mr. Sellars first became National Chairman of the Savings Bonds Council on January 1, 1977. On reappointing Mr. Sellars, Secretary Blumenthal said, "Encouraging millions of Americans to save for themselves through the U.S. Savings Bonds program is as important today as ever to help reduce the inflationary pressures in our economy. I thank you for your outstanding leadership and support in th:is vital effort." £? ^ m The 51-member Savings Bonds Volunteer State liftawjnen Council consists of leading businessmen who head tJLelvolo>i£.teer program for the sale and retention of Savings Bonds in t'fw&ir state. They are appointed to two-year terms by the Secretary of the Treasury. - ^ J o^< Sellars, a 39-year veteran of Johnson § Johnson, has been President of Johnson § Johnson Worldwide and ChaTrman of the Board and Chief Executive Officer, Johnson § Johnson. In J addition to his present business activity, he is active in many civic and professional groups. B-949 o FOR RELEASE AT 4:00 P.M. May 30, 1978 TREASURY'S WEEKLY BILL OFFERING The Department of the Treasury, by this public notice, invites tenders for two series of Treasury bills totaling approximately $5,600 million, to be issued June 8, 1978. This offering will not provide new cash for the Treasury as the maturing bills are outstanding in the amount of $ 5,600 million. The two series offered are as follows: 91-day bills (to maturity date) for approximately $2,200 million, representing an additional amount of bills dated March 9, 1978, and to mature September 7, 1978 (CUSIP No. 912793 T2 2), originally issued in the amount of $3,407 million, the additional and original bills to be freely interchangeable. 182-day bills for approximately $3,400 million to be dated June 8, 1978, and to mature December 7, 1978 (CUSIP No. 912793 U7 9). Both series of bills will be issued for cash and in exchange for Treasury bills maturing June 8, 1978. Federal Reserve Banks, for themselves and as agents of foreign and international monetary authorities, presently hold $2,909 million of the maturing bills. These accounts may exchange bills they hold for the bills now being offered at the weighted average prices of accepted competitive tenders. The bills will be issued on a discount basis under competitive and noncompetitive bidding, and at maturity their par amount will be payable without interest. Except for definitive bills in the $100,000 denomination, which will be available only to investors who are able to show that they are required by law or regulation to hold securities in physical form, both series of bills will be issued entirely in book-entry form in a minimum amount of $10,000 and in any higher $5,000 multiple, on the records either of the Federal Reserve Banks and Branches, or of the Department of the Treasury. Tenders will be received at Federal Reserve Banks and Branches and at the Bureau of the Public Debt, Washington, 0. C. 20226, up to 1:30 p.m., Eastern Daylight Saving time, Monday, June 5, 1978. Form PD 4632-2 (for 26-week series) or Form PD 4632-3 (for 13-week series) should be used to submit tenders for bills to be maintained on the book-entry records of the Department of the Treasury. B-950 -2Each tender must be for a minimum of $10,000. Tenders over $10,000 must be in multiples of $5,000. In the case of competitive tenders the price offered must be expressed on the basis of 100, with not more than three decimals, e.g., 99.925. Fractions may not be used. Banking institutions and dealers who make primary markets in Government securities and report daily to the Federal Reserve Bank of New York their positions in and borrowings on such securities may submit tenders for account of customers, if the names of the customers and the amount for each customer arie furnished. Others are only permitted to submit tenders for their own account. Payment for the full par amount of the bills applied for must accompany all tenders submitted for bills to be maintained on the book-entry records of the Department of the Treasury. A cash adjustment will be made on all accepted tenders for the difference between the par payment submitted and the actual issue price as determined in the auction. No deposit need accompany tenders from incorporated banks and trust companies and from responsible and recognized dealers in investment securities for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, or for bills issued in bearer form, where authorized. A deposit of 2 percent of the par amount of the bills applied for must accompany tenders for such bills from others, unless an express guaranty of payment by an incorporated bank or trust company accompanies the tenders. Public announcement will be made by the Department of the Treasury of the amount and price range of accepted bids. Competitive bidders will be advised of the acceptance or rejection of their tenders. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and the Secretary's action shall be final. Subject to these reservations, noncompetitive tenders for each issue for $500,000 or less without stated price from any one bidder will be accepted in full at the weighted average price (in three decimals) of accepted competitive bids for the respective issues. Settlement for accepted tenders for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, and bills issued in bearer form must be made or completed at the Federal Reserve Bank or Branch or at the Bureau of the Public Debt on June 8, 1978, in cash or other immediately available funds or in Treasury bills maturing June 8, 1978. Cash adjustments will be made for differences accepted in exchange between the andpar thevalue issueof price the maturing of the new bills bills. -3Under Sections 454(b) and 1221(5) of the Internal Revenue Code of 1954 the amount of discount at which these bills are sold is considered to accrue when the bills are sold, redeemed or otherwise disposed of, and the bills are excluded from consideration as capital assets. Accordingly, the owner of these bills (other than life insurance companies) must include in his or her Federal income tax return, as ordinary gain or loss, the difference between the price paid for the bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made. Department of the Treasury Circulars, No. 418 (current revision), Public Debt Series - Nos. 26-76 and 27-76, and this notice, prescribe the terms of these Treasury bills and govern the conditions of their issue. Copies of the circulars and tender forms may be obtained from any Federal Reserve Bank or Branch, or from the Bureau of the Public Debt. oOo FOR IMMEDIATE RELEASE Tuesday, May 30, 1978 Contact: Alvin Hattal 566-8381 TREASURY ANNOUNCES PRELIMINARY COUNTERVAILING DUTY ACTIONS AGAINST CERTAIN TEXTILE PRODUCTS FROM EIGHT COUNTRIES The Treasury Department today announced its preliminary determination that seven countries are subsidizing their exports of textile mill products and men's and boys' apparel. Those countries are Argentina, Brazil, Colombia, India, Republic of China, Philippines and Uruguay. The Treasury Department investigation was undertaken as a result of a petition filed by the Amalgamated Clothing and Textile Workers' Union in November 1977. Under the Countervailing Duty Law, the Treasury Secretary is required to assess an additional Customs duty that equals the amount of a "bounty or grant" (subsidy) that has been found to be paid on imported merchandise. Treasury's preliminary investigation found a variety of subsidies subject to countervailing duties, ranging from export subsidies to regional aids, preferential export financing, and special income tax benefits for export enterprises. Some tentative determinations were made without the detailed information necessary from the foreign government concerned to make a definitive decision on whether the programs providing a subsidy are being used by that countryfs textile industry. The Treasury must make a final determination no later than November 7, 1978. The Republic of Korea was also found to be subsidizing its textile exports but the amounts received are so inconsequential that the assessment of countervailing duties would not be warranted. Notice of this action will appear in the Federal Register of June 1, 1978. Import volume by value is not available at this time but is estimated to be approximately $700 million in 1977. 0 o 0 B-9S1 tyartmentoftheTREASURY \SHINGTON, D.C. 20220 TELEPHONE 566-2041 FOR IMMEDIATE RELEASE May 2 7 , 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY DEPARTMENT DENIES IT HAS WITHDRAWN PROPOSED FIREARMS REGULATIONS The Treasury Department today denied reports that it has withdrawn its proposals for firearms regulations to m a k e it easier to trace firearms used in crimes and to identify those selling guns to the criminal m a r k e t . Assistant Secretary of the Treasury Richard J. Davis said, "The Treasury Department has not w i t h d r a w n or revised the proposed regulations it published o n M a r c h 2 1 . B e c a u s e of great public interest in the issue and b e c a u s e of the widespread incorrect information about the n a t u r e of these proposals that has been generated by some g r o u p s , w e h a v e extended the comment period on them until June 3 0 . Davis repeated,what Jie said in his May 4 testimony.±>.aT ... fore the House Judiciary Subcommittee on C r i m e : that n o funds ± o implement these regulations w e r e . included__in the-fiscal year 1979 Administration b u d g e t and that any decision to implement them would require jseekinq funds from Conaress to do. so. This position w a s also communicated to Senator L a w t o n Chiles (D-Fla.), Chairman of the Treasury A p p r o p r i a t i o n s Subcommittee by Treasury Deputy Secretary Robert Carswell when, in a May 2 3 , 1 9 7 8 , l e t t e r , h e w r o t e : "If a d e c i s i o n is made to implement any of [these regulations] , it w o u l d b e necessary to seek either a supplementary a p p r o p r i a t i o n for 1979 or include a request for such funds in our 1980 s u b m i s sion. We w i l l not implement these p r o p o s a l s w i t h o u t securing from Congress the funds to do s o . " B-952 tyartmentoflheJREASURY IASHINGTON, D.C. 20220 TELEPHONE 566-2041 May 31, 1978 FOR IMMEDIATE RELEASE RESULTS OF AUCTION OF 4-YEAR 1-MONTH TREASURY NOTES The Department of the Treasury has accepted $2,257 million of $5,026 million of tenders received from the public for the 4-year 1-month notes, Series H-1982, auctioned today. The range of accepted competitive bids was as follows: Lowest yield Highest yield Average yield 8.24%1/ 8.28% 8.27% x The interest rate on the notes will be 8-1/4%. the above yields result in the following prices: Low-yield price 100.013 High-yield price Average-yield price At the 8-1/4% rate, 99.877 99.911 The $2,257 million of accepted tenders includes $508 million of noncompetitive tenders and $1,749 million of competitive tenders from private investors, including 9 % of the amount of notes bid for at the high yield. In addition to the $2,257 million of tenders accepted in the auction process, $300 million of tenders were accepted at the average price from Federal Reserve Banks as agents for foreign and international monetary authorities for new cash. 1/ Excepting 6 tenders totaling $3,560,000 B-953 Contact: FOR IMMEDIATE RELEASE Carolyn Johnston (202) 634-5377 JUNE 1, 1978 TREASURY SECRETARY BLUMENTHAL NAMES ROGER W. MULLIN, JR. SAVINGS BONDS CHAIRMAN FOR PENNSYLVANIA Roger W. Mullin, Jr., Chairman of the Board, Mack Trucks, Inc., Allentown, has been appointed Volunteer State Chairman for the Savings Bonds Program by Secretary of the Treasury W. Michael Blumenthal, effective immediately. He succeeds Henry J. Nave, former Chairman of the Board, Mack Trucks, Inc., Allentown. Mr. Mullin will head a committee of business, labor, financial, media, and governmental leaders who — in cooperation with the Savings Bonds Division — assist in promoting the sale of Savings Bonds. Mr. Mullin received an L.L.B. Degree from Fordham University Law School, and an L.L.M. Degree from George Washington University Law School. During World War II, he was with the U.S. Army Military Intelligence Service, and later joined several New York law firms. Mr. Mullin joined Mack Trucks, Inc. in 1961 as Executive Assistant to the President. He was elected Vice President, Secretary, and General Counsel in 1962, and joined the Mack Board of Directors in 1967. He became Vice Chairman in August 1974, and assumed his present position in August 1976. B-954 kpormentoftheTREASURY | LEPHONE 566-2041 WASHINGTON, OX. 20220 June 1, 1978 FOR IMMEDIATE RELEASE RESULTS OF TREASURY'S 20-DAY BILL AUCTION Tenders for $6,005 million of 20-day Treasury bills to be issued on June 2, 1978, and to mature June 22, 1978, were accepted at the Federal Reserve Banks today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: Price High - 99.609 Low 99.604 Average 99.605 Discount Rate 7.038% 7.128% 7.110% Investment Rate (Equivalent Coupon-Issue Yield) 7. 7.26% Tenders at the low price were allotted 80%. TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTS: Location Received Accepted Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco $ 91,000,000 9,647,000,000 $ 85,800,000 4,764,200,000 69,000,000 219,000,000 15,000,000 1,076,000,000 40,000,000 35,000,000 32,000,000 47,000,000 101,000,000 4,000,000 229,800,000 27,000,000 35,000,000 27,000,000 1,061,000,000 684,000,000 TOTAL $12,285,000,000 $6,004,800,000 B-955 FOR IMMEDIATE RELEASE June 2, 1978 Contact: Robert E. Nipp 202/566-5328 TREASURY ANNOUNCES EXTENSION OF DUMPING INVESTIGATION The Treasury announced today that it was extending for three months its investigation of alleged dumping of certain steel mill products from six European countries. A petition filed in December 1977 by National Steel Corporation claimed that cold rolled and galvanized sheet was being imported into the United States at less than "fair value" within the meaning of the Antidumping Act from Belgium, Holland, Germany, Italy, France and the United Kingdom. More than 30 companies are involved in the sales of this merchandise and the added time will be needed to analyze the volumnious data being developed. The announcement also notes that on May 31, 1978, National Steel withdrew, without prejudice to possible later reinstatement, its claims that the products under investigation were being sold at less than their cost of production. A copy of the Antidumping Notice of Extension of Investigatory Period is attached. B-956 DEPARTMENT OF THE TREASURY OFFICE OF THE SECRETARY COLD ROLLED AND GALVANIZED CARBON STEEL SHEETS FROM THE UNITED KINGDOM, WEST GERMANY, FRANCE, ITALY, THE NETHERLANDS AND BELGIUM ANTIDUMPING NOTICE OF EXTENSION OF INVESTIGATORY PERIOD AGENCY: U.S. Treasury Department ACTION: Extension of Antidumping Investigatory Period SUMMARY: This notice is to advise the public that the Secretary of the Treasury has determined that a tentative determination as to whether sales at less than fair value of cold rolled and galvanized carbon steel sheet from the United Kingdom, West Germany, France, Italy, the Netherlands and Belgium have occurred cannot reasonably be made in six months. This decision will be made in not longer than nine months from the date of the initiation of the investigation. EFFECTIVE DATE: (Date of publication in the FEDERAL REGISTER) FOR FURTHER INFORMATION CONTACT: Mr. David P. Mueller, U.S. Customs Service, Office of Operations, Duty Assessment Division, Technical Branch, 1301 Constitution Avenue, NW., Washington, D.C. 20229, telephone 202 (566-5492). -2SUPPLEMENTARY INFORMATION: On October 25, 1977, information was received in proper form pursuant to sections 153.26 and 153.27, Customs Regulations (19 CFR 153.26 and 153.27) from counsel on behalf of National Steel Corporation indicating that cold rolled and galvanized carbon steel sheets from Italy, Belgium, France, West Germany, the Netherlands and the United Kingdom are being, or are likely to be, sold at less than fair value within the meaning of the Antidumping Act, 1921 as amended (19 U.S.C. 160 et. seq.) (hereinafter referred to as "the Act"). On the basis of this information and subsequent preliminary investigation by the Customs Service, an "Antidumping Proceeding Notice" was published in the FEDERAL REGISTER of December 2, 1977. That notice stated that: "If? during the course of the investigation being initiated it is found that actual home market, or if appropriate, third country transactions, have been at prices below the Davignon Plan or list prices for these products, a comparison of these lower prices will be made with the cost of production. If below cost sales have occurred in substantial quantities and over an extended period of time at prices not permitting the recovery of all costs within a reasonable period of time, then a cost of production investigation would be deemed appropriate and would be initiated. The Customs Service will, accordingly, be directed to solicit information relevant to these considerations as promptly as possible from all interested persons." Petitioner thereafter filed supplemental information supporting its claims of sales below cost. On May 31, 1978, petitioner submitted a letter withdrawing the cost of production (but -3not the pricing) allegations made in its petition and in supplemental information filed on January 16, 1978, without prejudice to a subsequent filing of these claims. For purposes of this notice, the term "cold rolled and galvanized carbon steel sheets" means those items provided for in item number 608.87, 608.94, and 608.95 of the Tariff Schedules of the United States. The merchandise in question is made and sold in a large number of sizes and forms in numerous individual transactions by 30 separate companies in the European countries involved and in the United States. Further, a variety of claims for adjustments have been made with respect to many of the transactions to be compared. Additional time is needed to analyze this data. Accordingly pursuant to section 201(b)(2) of the Act (19 U.S.C. 160(b)(2)), notice is hereby given that the determination provided for in section 201(b)(1) of the Act (19 U.S.C. 160(b)(1)) cannot reasonably be made within six months. The determination under section 201(b)(1) of the Act (19 U.S.C. 160(b)(1)) will therefore be made within no more than nine months. This notice is published pursuant to section 201(b)(2) of the Act (19 U.S.C. 160(b)(2)). inefal Counsel of the Treasury -JUN 2 1978 FOR IMMEDIATE RELEASE June 2, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY EXTENDS RECORD-KEEPING DEADLINE FOR CERTIFICATES OF DEPOSIT The Treasury Department today announced that it is delaying until June 19 enforcement of its regulations requiring banks and other financial institutions to maintain records of certificates of deposit. Enforcement had been scheduled to start June 1. Under Secretary Bette B. Anderson said the delay was granted after a number of banks indicated they would need additional time to change their recordkeeping procedures. Several thousand banks and savings and loan associations will be affected. The new provisions are intended to discourage the use of certificates of deposit, including so-called "honor" bonds, for illegal purposes. o B-957 0 o [4810-25] TITLE 31 - MONEY AND FINANCE: TREASURY Chapter 1 - Monetary Offices, Department of the Treasury Part 103 - FINANCIAL RECORDKEEPING AND REPORTING OF CURRENCY AND FOREIGN TRANSACTIONS NOTICE The Treasury Department announced today that the enforcement of those provisions in the May 9, 1978, amendment to 31 CFR 103.34, which require a financial institution selling or redeeming certificates of deposit to maintain additional records of the transactions beginning June 1, 1978, will not be enforced with respect to transactions completed prior to June 19. This policy announcement was made in response to requests made on behalf of a number of banks which have indicated that the publication of the amendment in the May 19 Federal Register did not allow them enough time to make necessary procedural changes before June 1. The delay is intended to provide relief for those financial institutions, as well as others that have been unable to meet the June 1 effective date. Date: ., " ** ; ':^g Bette B. Anderson Under Secretary of the Treasury FOR IMMEDIATE RELEASE June 2, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY ANNOUNCES TWO PRELIMINARY COUNTERVAILING DUTY ACTIONS ON CERTAIN CHEMICAL PRODUCTS FROM ISRAEL The Treasury Department today announced its preliminary determination that the Government of Israel is subsidizing its exports of diuron and bromine and brominated compounds. The action regarding diuron was taken pursuant to a petition filed by E. I. du Pont de Nemours in June 1977. The action regarding bromine and brominated compounds was taken pursuant to a petition filed by Velsicol Chemical Corporation in July 1977. Under the Countervailing Duty Law, the Secretary of the Treasury is required to assess an additional Customs duty that equals the amount of a "bounty or grant" (subsidy) found to have been paid on imported merchandise. Under the law, Treasury must make a final decision in the diuron case no later than June 13, 197 8, and in the bromine case no later than July 11, 1978. Treasury's preliminary investigation revealed subsidies that appear at this stage to be subject to countervailing duties including certain property tax rebates on export and regional aids. Notice of these actions will appear in the Federal Register of June 5, 1978. Imports of bromine and brominated compounds from Israel were valued at approximately $150,000 in 1976. Imports of diuron from Israel was valued at approximately $500,000 in 1976. o B-958 0 o FOR RELEASE ON DELIVERY EXPECTED AT 9:30 A.M., EST MONDAY, JUNE 5, 1978 REMARKS BY THE HONORABLE C. FRED BERGSTEN ASSISTANT SECRETARY OF THE TREASURY FOR INTERNATIONAL AFFAIRS BEFORE THE CONFERENCE BOARD NEW YORK, NEW YORK THE U.S. TRADE BALANCE AND AMERICAN COMPETITIVENESS IN THE WORLD ECONOMY The U.S. trade balance was in deficit by $31 billion in 1977. In the first quarter of 1978, imports exceeded exports by $11.2 billion — placing the trade deficit at an annual rate of $45 billion. Despite the fact that our huge earnings from international services transactions produce a much smaller deficit on current account, the size of the trade deficit and its persistency have raised serious concerns about the ability of U.S. industry to compete in world markets and I will focus on this basic question today. One of my conclusions will be that U.S. exporters, as of this date, have not suffered any noticeable loss in price competitiveness against other industrial country suppliers. The dollar depreciation of late 1977-early 1978 has offset the decline in U.S. competitiveness which was engendered by the dollar appreciation and relatively poor U.S. price performance of 1974-1975, and which has been adversely affecting U.S. trade performance during the past couple of years. However, price competitiveness is only one of a number of factors in a country's export performance. Several other important developments in the world economy — notably those ^elated to energy and to relative growth rates among the industrial countries — have adversely affected the U.S. trade balance. In addition, a number of dynamic advanced developing countries (ADCs) have been sharply increasing their B-959 - 2 international competitive position, cutting into the world market shares of the United States (and most other industrial countries as well). In any event, the sharp increase in our payments for imported oil means that we will have to export a larger share of our gross national product in the future in order to produce a sustainable position in our external accounts. Thus there is a great need for the United States to undertake major efforts to improve its export performance, to take full advantage of the competitive opportunities which seem to be available at this point in time. The President indicated on April 11 that such an effort will be undertaken. It is now in the final stages of planning and will be announced over the next few weeks. As background for that program, and because of the great importance of the trade balance both to the U.S. economy and to international economic stability, I would like to share with you in some detail our analysis of its recent evolution. Recent Trends in the Merchandise Trade Balance Since the recession of 1974-75 — and the resultant $9 billion trade surplus in 1975 — the U.S. trade balance has deteriorated sharply and continuously. In 1976, the balance shifted by about $18 billion to a deficit of $9 billion. This sharp swing was primarily the result of strong growth in the U.S. domestic economy. Coming out of the recession trough of early 1975, the economy grew by a strong 6 percent in GNP terms during 1976 while overall industrial production expanded 10 percent and production in manufacturing industries jumped 11 percent. Capacity utilization rates during 1976 improved significantly — up 7 percentage points (to 80 percent) according to the Federal Reserve series, and also up 7 points (to 87 1/2 percent) on the Wharton series. This solid growth in 1976 was accompanied by a sharp 26.5 percent rise in nominal imports. Only 3 percent of the rise resulted from price increases, while import volume surged 23 percent. An important part of this abnormally sharp growth was caused by inventory rebuilding following the destocking which occurred during the recession. By contrast, export growth was weak. Volume expanded about 3 1/2 percent while prices rose by a similar amount. This nominal export rise of 7 percent was considerably slower than the 10 percent global growth in world trade (excluding oil). Non-agricultural exports rose only 1 1/2 percent in volume terms between 1975 and 1976. - 3 The U.S. merchandise trade balance continued along these trends in 1977. Imports posted strong growth of 22 1/2 percent in value terms, 13 percent by volume. Non-petroleum imports surged 19 percent by volume. Export performance was again lack-luster. Total nominal exports grew only 5 percent, export volume less than 1 percent. Non-agricultural exports were virtually unchanged in volume terms. The combined effect was to produce the record trade deficit of $31 billion. The deficit again jumped sharply in the first quarter of 1978, hitting an annual rate of $45 billion. It featured an extraordinary surge in non-petroleum imports, however, which we believe represented a temporary aberration. This surge reflected J-curve effects, as non-petroleum import prices rose over 6 percent. In addition, import shipments appear to have accelerated as a result of last fall's anticipation of continuing dollar depreciation and fears of new U.S. import restrictions (including the February imposition of reference prices for steel imports), foreign country export constraints, the possibility of a West Coast dock strike this summer, and a prospective ocean freight rate increase. We believe that the first quarter deficit reflected a number of temporary factors, all of which tended to worsen the picture, and that the fourth quarter of last year and the first quarter of 1978 represent the peak deficits which the United States is likely to experience. The moderate pickup of exports in March and April and the accompanying 10 percent decline in the trade deficit were a modestly encouraging sign. For the near future, our current projections assume that foreign growth will accelerate in the second half of 1978 and edge higher in 1979. In addition, the effects on U.S. exports of the dollar depreciation in 1977 and the first quarter of 1978 are expected to grow as the year proceeds — rising by the end of 1979 to an annual rate gain of about $7-8 billion. Export performance will also benefit from improved conditions in specific foreign markets important to the United States — particularly in the developing countries such as Mexico, our fifth largest market. All of these developments must be placed in the longer run context of underlying international trends, however, to discern even tentative answers to the key questions surrounding the competitiveness of the United States in the world economy. Causes of the Trade Balance Decline Why has the trade balance deteriorated so badly? Will it continue to do so? What should American industry and the Government do about the decline? These are all - 4 questions of fundamental importance, which deserve answers as straightforward as are analytically possible. Last May, I addressed many of these same questions and outlined some tentative conclusions on them. More recent data and our continued analysis of the trade situation have produced some additional insights, while generally confirming the earlier analysis. One of the major factors in the deteriorating trade balance which I noted last year was of course the sharp growth in U.S. oil imports, which expanded by $18 billion from 1975 to 1977. To be sure, some increase in oil imports (and perhaps oil prices) inevitably accompanies economic growth. And increased U.S. exports to oil-producing countries have reduced the net impact of our oil imports on the trade balance. But energy imports are a discrete element which account for almost one-half of the deterioration in the U.S. trade balance during the past two years. A second major factor was the differing pace of economic recovery among the major industrial countries. This sharp divergence of recovery trends continued during 1977. Real GNP in the U.S. rose by nearly 5 percent, the second straight year of U.S. growth considerably in excess of our long-run potential. We closed the gap of excess capacity during the year and created three million additional jobs. By contrast, growth in our major markets was far less robust. Total GNP growth in the OECD area, excluding the United States, rose only 2.7 percent in 1977 — down sharply from the 4.7 percent growth rate of 1976 which itself was less than U.S. growth. In the past two years, the U.S. economy has expanded at an average rate of 5.6 percent while the rest of the OECD grew at an average rate of only 3 3/4 percent. Only in the United States, in fact, has there been any significant reduction in the rate of unemployment from the trough of the 1974-1975 recession among the larger OECD countries. This is a sharp reversal of historical patterns. During the 1960fs and early 1970's, the United States experienced average growth of 4.2 percent (vs. 5.6 percent recently) while the rest of the OECD area grew at 6 1/2 percent (vs. 3.75 percent more recently). This swing alone has had a major adverse impact on the U.S. trade balance, explaining perhaps $10-15 billion of the total swing of $40 billion from 1975 through 1977. Not only has the growth rate abroad slowed down, but its composition seems to be changing with further effects on the composition of demand for imports of these countries. Investment is not playing its traditional role - 5 in the growth of GNP and domestic demand abroad. partly as a cause and partly as a result, industrial production has grown particularly slowly. In the 18 months ending December 1977, industrial production in 13 other major OECD countries grew only 3.2 percent while their total GNP expanded 7.6 percent. In the 12 months ending December 1977, industrial production abroad did not grow at all while U.S. industry increased its output by about 5 percent. With no industrial production growth in our major markets, it is not very surprising that U.S. non-agricultural exports — which are comprised primarily of industrial supplies and capital equipment — were essentially flat last year. Clearly the relative performance of economies at home and abroad has been a major factor in the deteriorating U.S. trade balance since 1975. This factor should become less important in the months ahead. Growth in the United States is decelerating somewhat from the very strong pace of 1976 and 1977, while growth abroad is picking up somewhat this year and should do so especially in the second half. As a result, we are now expecting some convergence of growth rates among countries. While it is not yet clear what the medium-term relationship will be, I do not expect that U.S. growth rates will continue to be considerably faster than average rates abroad. In turn, this should lead to a pickup in the growth of our export volume relative to our import volume, with favorable effects on the U.S. trade balance — particularly over time, as this convergence in growth rates cumulatively produces higher levels of demand abroad relative to those at home. Another major factor determining a country's performance in world markets is its relative price competitiveness. In the sixties, with fixed exchange rates, relative prices provided quick and easy guides to the price competitiveness of a country's exports compared to some particular group of other countries. With today's more flexible exchange rate system, movements in relative domestic prices must be adjusted for exchange rate changes to discern changes in "real" exchange rates and changes in a country's price position. Such calculations are in no sense precise or absolute measures of competitiveness, but they are important indicators of trend developments. These changes in price competitiveness are not immediate reflected in trade flows. Empirical studies suggest that trade flows exhibit a lagged response to price movements of anywhere from one to five years. In our judgment, the !ag usually runs from eighteen months to three years. If this is so, trade flows in 1977 basically reflected changes in U.S. competitiveness dating from 1974-1975 — a - 6 period during which the U.S. competitive position experienced a serious decline. In the wake of the oil crisis, U.S. inflation accelerated rapidly and outpaced that of our competitors from early 1974 to early 1975. At the same time, the U.S. dollar was appreciating by some 8 percent on a trade-weighted basis, apparently because observers felt that the United States would weather the energy crisis better than other countries. This double whammy — appreciation coupled with poor price performance -- produced a sharp loss of something like 10 percent in the trade competitiveness of U.S. suppliers during the 1974-1975 period. Given the time lags involved, this exerted a major impact on 1977 trade flows. It may have been responsible for somewhere like $5-10 billion of the deterioration which occurred by Performance that year. U.S. Export In analyzing developments in the U.S. trade balance, it is important to distinguish between export performance and export competitiveness. Export performance is frequently measured by changes in export market shares -in a country's share of global exports. But market shares of today's world exports are actually the result of prior changes in export competitiveness. As already noted, trade flows tend to reflect changes in competitiveness fully only after a lag of two or three years. Thus today's U.S. export performance reflects changes in U.S. export competitiveness of as much as two or three years ago. A year ago, I noted that the U.S. share of world export markets had increased in 1973-75 from the historic lows of 1972. I observed that the 1976 position was somewhat below 1975, but that I did not believe we were experiencing a serious loss in market shares. Data for the first three quarters of 1977 tend to confirm that belief as the U.S. share of manufactured exports by industrial countries was essentially unchanged during 1977 from the 1976 position: — The U.S. share of total manufactured exports by 15 industrial countries hit its low point of 19.2 percent in 1972, and rose to 21.1 percent in 1975. The share then fell slightly, to 20.5 percent in 1976 and 20.4 percent in the third quarter of 1977 (the most recent period for which comparable data are available). -- The U.S. share of chemical exports from these countries rose steadily from 18.7 percent in 1972 to 20.6 percent in 1976, and jumped again to 22.6 percent in the third quarter of 1977. - 7 — Our non-electrical machinery share rose from the 1971 low of 25.1 percent to 26.8 percent in 1976, but declined to 25.2 percent in the third quarter of last year. — Electrical machinery climbed steadily from its 1972 low of 20.9 percent to 23.3 percent in 1976, and to 23.4 percent in the third quarter of 1977. — Basic manufactures rose from a 1972 low of 10.6 percent to 11.9 percent in 1976, and dropped slightly to 11.7 percent in 1977 III. — Only in transport equipment is the U.S. share lower today than in 1972, having fallen from 26.4 percent in 1972 to about 25.1 percent in 1976 and to 24.9 percent in 1977 III. In citing these data, it is essential to repeat that export performance measures such as shares of manufactured exports are not necessarily good measures of current trends or expected developments in the trade balance. Most importantly, they do not pick up recent changes in a country's competitive position. Indeed, the 1976-77 market shares just cited reflect the deterioration in U.S. price competitiveness dating from 1974-75 which I have already described. For the future, the price competitiveness of U.S. exports has experienced significant improvement. The exchange rate movements of the third quarter of 1977 and first quarter of 1978 reversed the earlier losses in our relative position resulting from the 8 percent dollar appreciation of 1974-75. Our competitiveness, as measured by price-adjusted exchange rates, is now about where it was compared to other major industrial countries in early 1973. This improvement should begin to be felt in our trade flows — both exports and imports — during the latter part of 1978 and into the next year or so. Developments Outside the Industrial Countries The available measures of market share typically compare the United States only to other industrial countries. One of the roost important and impressive developments in the world economy in the last few years has been the emergence of a group of advanced developing countries (ADCs), most notably Brazil, Korea, Hong Kong, Mexico, Singapore and Taiwan. Their export volume growth has remained in double digit levels for three straight years, and is growing more strongly than it did even during the 1968-72 global boom period. - 8 Several important structural changes in the global economy are being generated by this spectacular growth. First, the locus of production is shifting. Between 1960 and 1973, world wide industrial production growth averaged 6.8 percent. Industrial countries grew at 6 percent, LDCs were a bit more rapid at 6.8 percent and the non-market economies grew at a strong 9 percent average rate. The recession and its aftermath cut global production growth to 2.6 percent between 1973 and 1976, but growth in the LDCs and non-market economies barely slowed down from the torrid pace of the sixties. During 1973-76, LDC production increased 6.1 percent, while growth in the non-market economies continued at an impressive 8.4 percent rate. These growth rates have fostered changes in shares of global industrial production. In 1963, the six key ADCs — Brazil, Hong Kong, Korea, Mexico, Singapore, and Taiwan — together accounted for about 2.4 percent of world industrial production. All non-oil LDCs together produced about 10.4 percent of global output. By 1976, these ADCs had roughly doubled their combined share of global output to 4.7 percent and the total LDC share of global production had increased 3 percentage points, reaching a total of about 13 1/2 percent. Over the same period, Japan and the less industrialized OECD economies (Spain, Portugal, Turkey, Greece and Yugoslavia) increased their combined share of global production by 5 percentage points. In 1976, these countries accounted for some 13 percent of global production. The net effect of these developments was to reduce the share of global industrial production accounted for by Europe and North America by roughly 8 percentage points. This is a very sharp change in the locus of productive capacity for such a short time span. Not surprisingly, this increased productive capacity is being felt in global export market shares. In 1963, the six ADCs accounted for 1.5 percent of global manufactured exports. By 1976, their share had jumped 3 1/2 percentage points to 5 percent. This is an impressive increase. It represents successful development strategies in the ADCs, something that the United States and all of the other industrial countries have aimed for in their assistance programs and overall North-South policies. The manufactured exports are in a wide variety of product categories: steel, cameras and optical equipment, radios and television sets as well as the familiar shoes and textiles. Naturally U.S. exports to the non-OPEC LDCs have also grown as these countries progress along the path of industrialization. Total U.S. exports to these nations rose - 9 from $20 1/4 billion in 1970-72 to $27 3/4 billion in 1977. These countries now account for about one-quarter of our exports of manufactured goods. Indeed they are more important to our export trade than the entire European community. The growth in our exports to the non-oil LDCs has not, however, kept pace with the rise of imports. There was an adverse swing in our trade balance with this area of $5 billion. Eight developing nations suppliers (Brazil, Mexico, Taiwan, Hong Kong, Singapore, Phillipines, South Korea, and Malaysia) now account for $11 billion of the total $13 billion of U.S. manufactured imports from LDCs. Total U.S. imports from the non-oil LDCs grew from about $16 billion in 1972 to $38.5 billion in 1977 — an average annual growth rate of close to 25 percent. They have clearly become important factors in the world economy, and offer increased competition for the United Stated (and all other industrial countries) which we must consider carefully in assessing our own competitive position now and in the future. Conclusions This discussion of the adverse swing in the U.S. trade balance has focused on three factors: oil imports, relative growth rates and price competitiveness. In all three areas, we are making progress: — The energy bill is finally coming close to passage. — Relative growth rates are converging, as our major markets abroad pick up their growth while we slow down a bit. — U.S. price competitiveness has improved significantly over the last quarter of 1977 and the first quarter of 1978. — And the President's determination to control inflation will help to preserve our trade competitiveness. Nevertheless, more must be done to achieve the needed improvement in our external accounts and thereby assure continued stability for the dollar. We must continue and strengthen our determination to restrain inflationary Pressures. We must meet the trade challenge with aggressive sales efforts by U.S. firms both at home and in third markets, supported as necessary by the policies and programs of our government. It is clear that the competitive ADCs - 10 present a new challenge as well as a great opportunity, and we must insure that they are brought more fully into the global adjustment process. These changes will show up in the trade numbers only over time. We will not see dramatic changes immediately. But fundamental improvements are under way, and we intend to support them wherever we can do so effectively. A strong export performance is essential for our own economy and for the international position of the United States. It is a major policy objective which will be pursued vigorously by the administration, based on our analysis of the underlying strength and competitiveness of the U.S. economy as outlined today. It is an effort which — with hard work by both the private sector and Washington — we are confident can succeed. 0O0 pimntoftheTREASURY TELEPHONE 566-2041 IHINGTON, D.C. 20220 FOR IMMEDIATE RELEASE June 5, 1978 RESULTS OF TREASURY'S WEEKLY BILL AUCTIONS Tenders for $2,203 million of 13-week Treasury bills and for $3,401 million of 26-week Treasury bills, both series to be issued on June 8, 1978, were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: 13-week bills maturing September 7, 1978 Price 98.331a/ 98.324 98.325 High Low Average Discount Rate 6.603% 6.630% 6.626% 26-week bills maturing December 7, 1978 Investment [ Rate 1/ : Price 6.81% 6.84% 6.83% Discount Rate j: 96.421 : 96.409 : 96.413 7.079% 7.103% 7.095% Investment Rate 1/ 7.44% 7.47% 7.46% a/ Excepting 1 tender of $80,000. Tenders at the low price for the 13-week bills were allotted 80%. Tenders at the low price for the 26-week bills were allotted 74%. TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTSAND TREASURY: Location Received Boston $ New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco Treasury TOTALS Accepted Received 98, 595, 000 52,595,000 $ 39,460,000 $ 19,460,000 717,015,000 4,985,985,000 2,591,485,000 21,385,000 103,335,000 13,335,000 31,370,000 62,215,000 32,215,000 47, 560,000 18,205,000 11,205,000 22, 765,000 24,200,000 24,200,000 71, 800,000 716,680,000 483,360,000 18 250,000 43,535,000 16,275,000 22,155,000 25,175,000 24,135,000 20,640,000 22,000,000 21,650,000 17 815,000 7,285,000 7,025,000 150,110,000 330,250,000 150,630,000^ 5,895,000 5,895,000 9,125,000 $4,643,38 5,000 $2 , 2 02 , 58 5 , 000V $6, 384,220,000 $3,400,870,000£/ 666, 515, 000 21, 385, 000 101, 960, 000 51, 560, 000 23, 765, 000 224, 080, 000 45, 250, 000 25, 155, 000 22, 665, 000 18, 415, 000 334, 915, 000 9,125,000 ^ ncludes $364,120,000 noncompetitive tenders from the public. ncludes $213,505,000 noncompetitive tenders from the public. ./Equivalent coupon-issue yield. B-960 Accepted FOR RELEASE AT 4:00 P.M. TREASURY'S WEEKLY BILL OFFERING The Department of the Treasury, by this public notice, invites tenders for two series of Treasury bills totaling approximately $ 5,700 million, to be issued June 15, 1978. This offering will not provide new cash for the Treasury as the maturing bills are outstanding in the amount of $5,713 million. The two series offered are as follows: 91-day bills (to maturity date) for approximately $2,300 million, representing an additional amount of bills dated March 16, 1978, and to mature September 14, 1978 (CUSIP No. 912793 T3 0), originally issued in the amount of $3,402 million, the additional and original bills to be freely interchangeable. 182-day bills for approximately $3,400 million to be dated June 15, 1978, and to mature December 14, 1978 (CUSIP No. 912793 U8 7). Both series of bills will be issued for cash and in exchange for Treasury bills maturing June 15, 1978. Federal Reserve Banks, for themselves and as agents of foreign and international monetary authorities, presently hold $3,070 million of the maturing bills. These accounts may exchange bills they hold for the bills now being offered at the weighted average prices of accepted competitive tenders. The bills will be issued on a discount basis under competitive and noncompetitive bidding, and at maturity their par amount will be payable without interest. Except for definitive bills in the $100,000 denomination, which will be available only to investors who are able to show that they are required by law or regulation to hold securities in physical form, both series of bills will be issued entirely in book-entry form in a minimum amount of $10,000 and in any higher $5,000 multiple, on the records either of the Federal Reserve Banks and Branches, or of the Department of the Treasury. Tenders will be received at Federal Reserve Banks and Branches and at the Bureau of the Public Debt, Washington, D « C. 20226, up to 1:30 p.m., Eastern Daylight Saving time, Monday, June 12, 1978. Form PD 4632-2 (for 26-week series) or Form PD 4632-3 (for 13-week series) should be used to submit tenders for bills to be maintained on the book-entry records B-961 of the Department of the Treasury. -2Each tender must be for a minimum of $10,000. Tenders over $10,000 must be in multiples of $5,000. In the case of competitive tenders the price offered must be expressed on the basis of 100, with not more than three decimals, e.g., 99.925. Fractions may not be used. Banking institutions and dealers who make primary markets in Government securities and report daily to the Federal Reserve Bank of New York their positions in and Dorrowings on such securities may submit tenders for account of customers, if the names of the customers and the amount for each customer are furnished. Others are only permitted to submit tenders for their own account. Payment for the full par amount of the bills applied for must accompany all tenders submitted for bills to be maintained on the book-entry records of the Department of the Treasury. A cash adjustment will be made on all accepted tenders for the difference between the par payment submitted and the actual issue price as determined in the auction. No deposit need accompany tenders from incorporated banks and trust companies and from responsible and recognized dealers in investment securities for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, or for bills issued in bearer form, where authorized. A deposit of 2 percent of the par amount of the bills applied for must accompany tenders for such bills from others, unless an express guaranty of payment by an incorporated bank or trust company accompanies the tenders. Public announcement will be made by the Department of the Treasury of the amount and price range of accepted bids. Competitive bidders will be advised of the acceptance or rejection of their tenders. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and the Secretary's action shall be final. Subject to these reservations, noncompetitive tenders for each issue for $500,000 or less without stated price from any one bidder will be accepted in full at the weighted average price (in three decimals) of accepted competitive bids for the respective issues. Settlement for accepted tenders for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, and bills issued in bearer form must be made or completed at the Federal Reserve Bank or Branch or at the Bureau of the Public Debt on June 15, 1978, in cash or other immediately available funds or in Treasury bills maturing June 15, 1978. Cash adjustments will be made for differences between the par value of the maturing bills accepted in exchange and the issue price of the new bills. -3Under Sections 454(b) and 1221(5) of the Internal Revenue Code of 1954 the amount of discount at which these bills are sold is considered to accrue when the bills are sold, redeemed or otherwise disposed of, and the bills are excluded from consideration as capital assets. Accordingly, the owner of these bills (other than life insurance companies) must include in his or her Federal income tax return, as ordinary gain or loss, the difference between the price paid for the bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made. Department of the Treasury Circulars, No. 418 (current revision), Public Debt Series - Nos. 26-76 and 27-76, and this notice, prescribe the terms of these Treasury bills and govern the conditions of their issue. Copies of the circulars and tender forms may be obtained from any Federal Reserve Bank or Branch, or from the Bureau of the Public Debt. oOo mrmentoftheTREASURY JHINGTON, D.C. 20220 LEPHONE 566-2041 FOR R E L E A S E U P O N DELIVERY Expected at 3:00 p.m. June 7, 1 9 7 8 STATEMENT OF THE HONORABLE W. MICHAEL BLUMENTHAL SECRETARY OF THE TREASURY BEFORE THE SENATE COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS Mr. Chairman and members of this distinguished Committee: I appear before you to present the Administration's recommendations on the future Federal relationship to the financing of New York City. My testimony will cover three major areas: first, the events of the past two and a half years which underlie our discussions here today; second, New York City's budget and financing plans covering the 1979-1982 period; and third, the Administration's recommendations on financing assistance for the City during that period. Mr. Chairman, four important principles underlie the conclusions which I will present today. — Preserving New York City's Solvency: This Administration believes that the effects of a bankruptcy on the residents of the City and State, the market for all municipal securities and foreign confidence in the United States would be very serious. A concerted effort must be made to prevent bankruptcy. — Maximum Budget and "Financing Efforts by the Local Parties! Primary responsibility for New York City's financing rests with the local elected officials and the relevant private parties at the City level. Beyond that, the City is the responsibility of New York State. Any Federal financing assistance should be provided only under extraordinary circumstances and should be limited to a residual and transitional one. to " A Truly Balanced City Budget;is a Prerequisite Pr Ending this Crisis: New York City 1 ost access to B-962 - 2 conventional borrowing sources because it incurred large budget deficits and otherwise lost control of its finances. These deficits have been reduced, but not eliminated, and they remain the primary obstacle to restoring the City's access to the credit markets. Any post-June 30, 1978 financing plan, therefore, must be conditioned upon achievement over the plan period of a budget which is balanced in accordance with generally accepted accounting principles. T — ^e New York City Financing Crisis Should be~Resolved Once and For All: The only acceptable plan for future financing of the City is one which will restore permanently New York's ability to finance itself. Mr. Chairman, let me now begin a detailed discussion of the past and present situation and our legislative recommendations for the future. I. Review of the 1975-1978 Period During the early 1970's, New York City's fiscal condition was weakened by the migration of jobs and related tax revenues from the City, the 1974-1975 national recession as well as unsound budget and borrowing practices. The consequences of these became clear in early 1975, when the municipal bond market closed to New York City, and the City teetered on the edge of bankruptcy. The City's then budget of approximately $13 billion — by far the largest municipal budget in this country — was estimated to be $2.0 billion in deficit, and its accounting and financial control systems were archaic and unreliable. Not only did the public markets close to New York City, but even massive efforts in 1975 by the State of New York were insufficient to solve the entire City financing problem. The State created a Municipal Assistance Corporation (MAC), with authority to issue its own bonds, and to use the proceeds for making direct loans to the City and refinancing of City notes. The State also advanced $800 million of additional funds directly to the City. Yet, MAC was unable to borrow sufficient amounts in relation to the City's needs. Indeed, in the fall of 1975, the municipal bond market also closed to MAC, and the State was forced to take further action. It installed an Emergency Financial Control Board (EFCB) to exercise substantial control over the City's finances. - 3 These drastic steps were still insufficent, however, and imminent bankruptcy threatened. In that context the Congress passed the 1975 New York City Seasonal Financing Act. This legislation authorized the U.S. Treasury to provide shortterm loans to the City to meet cash flow imbalances occurring within the City's fiscal year. These loans were purely seasonal —they were extended and matured within the City's fiscal year — and were limited to $2.3 billion in any one year. This Federal lending program, which expires at the end of this month, has supplied New York City's short-term borrowing requirements since late 1975. From 1975 through June 30, 1978, the City's employee pension funds have purchased or are obligated to purchase $2.65 billion of long-term City and MAC debt, bringing their total holdings of such debt to 35 percent of their total assets. Such purchases have satisfied New York's long-term borrowing needs during this emergency period. The 1976-1978 Period Mr. Chairman, both the 1975 emergency State legislation and the Seasonal Financing Act required New York City to adhere to the three-year financial plan developed in 1975 and to take a series of other steps to improve its fiscal condition. These were designed to restore the City's access to conventional borrowing sources. A crucial aspect of today's discussion, then, concerns these steps — whether they have been taken and whether they were sufficient. As to the first point, Mr. Chairman, it is clear that New York City has done what it pledged to do in 1975. Let me quickly review the major steps taken, particularly because many here in Washington and elsewhere may be under the misapprehension that the fiscal condition of New York City has not improved since 1975. The City responded to the crisis by developing a threeyear financial plan to reduce expenditures in real terms while increasing revenues, so that by 1978 its budget would be "balanced" as that term is defined under New York State law. We expect this objective to have been met at the end of the City's current fiscal year. Taking into account all expense items still included in the capital budget, and the accrued pension liability, the City has reduced its deficit from approximately $2.0 billion in fiscal year 1975 to approximately $750 million estimated for fiscal year 1978. Table 1 presents summary budget data for these years. - 4 The City has achieved this improvement by reducing the City-funded work force by 60,000; by charging tuition for all students at City University for the first time; by sharply limiting wage increases for municipal employees through June 1978 and reducing employee fringe benefits; by withdrawing from mortgage financing of low- and middle-income housing projects? by reducing the number of beds in City operated hospitals; by raising the transit fare from 35 cents to 50 cents; and by reducing social services through closing 77 day-care centers and limiting reimbursement rates at other centers. The City also reduced its share of contributions to municipal union pension funds by requiring greater employee contributions, while the City increased the absolute amount of its contributions to increase the actuarial soundness of the funds. At the same time as it took these budgetary actions, the City also moved to reform its accounting and internal financial control systems. The City has begun phasing current expense items out of its capital budget and is now accelerating that phase-out for completion by the end of 1981. It has installed an integrated financial management system at a cost of $16 million. Furthermore, a consortium of independent certified public accountants is conducting an independent audit of the results of the City's current fiscal year and will do so in the future years. The State of New York also has taken important steps to restore the fiscal integrity of the City. It established the Emergency Financial Control Board with the Governor as Chairman to oversee implementation of the City's three-year plan. As I noted earlier, it created a State agency, the Municipal Assistance Corporation (MAC), to provide financing for the City. More than $3 billion of short-term City notes, which were outstanding in mid-1975, were converted into longterm MAC bonds. The State has continued to advance $800 million of aid each year to help meet the City's financing needs. The State has also undertaken greater responsibility in funding City services including assuming a larger role in funding City University and assuming financial responsibility for City courts. Currently the State has continued to assist the City. The Governor has provided needed leadership in guiding the bill through the legislature to extend the powers of the EFCB and enlarge MAC's borrowing authority. I should like to point out that by increasing the amount of debt which MAC is authorized to issue by $3 billion the State is really putting itself on the line for the City because the MAC bonds are backed by the - 5 so-called moral obligations of the State. In effect, therefore, the State wil be at least morally responsible for $8.8 billion of MAC debt issued on behalf of the City. I think this refutes any argument that the State has not supported or acted on behalf of the City. City Seasonal Borrowings From the Treasury The City has complied with all key provisions of the Federal seasonal loan program. Furthermore, the program has not cost the U.S. taxpayer anything. Table 2 provides a schedule of our total loans under the program. During fiscal year 1976, New York borrowed $1.26 billion and repaid it with interest, either on time or ahead of schedule. In fiscal 1977, $2.1 billion was borrowed and again repaid punctually. During this current year, the City has borrowed $1,875 billion, and already repaid $1.2 billion ahead of schedule I anticipate timely repayment of the remaining amount. Under the law, Treasury is required to charge the City one percent more than the rate on outstanding U.S. Government obligations of comparable maturity. As a result, this year's seasonal loan program will yield a net surplus of approximately $13 million. This amount will be returned, of course, to Treasury's general fund. The aggregate amount of interest received by the Treasury during the past two and one-half year period, over and above our borrowing costs, will be $30 million. II. New York City's Continuing Lack of Access to Conventional Lending Sources Although New York City has taken the important steps I have outlined, the municipal credit markets have not re-opened to the City. At the moment, its notes and bonds remain unsaleable in the public markets. A primary purpose of the Seasonal Financing Act — to restore New York's access to conventional lending sources — has not been achieved. There are at least two reasons for this lack of market access. The first concerns continuing budget deficits. To - 6 the extent that budget deficits originally caused the City's loss of market access, New York's smaller but continuing deficits remain a primary obstacle to regaining it. The second reason for New York's continuing lack of market access might be described as traditional investor skepticism. Once a major borrower - municipal or corporate - loses his credit standing and is nearly insolvent, the rating agencies and the public markets require a period of years before they are convinced that corrective steps have worked and that creditworthiness has been restored. This is a natural lag, and there are numerous examples of it in modern finance. The public financing difficulties of our airline industry, after its loss years of the early 1970's, are a representative example. It is not altogether surprising, therefore, that the credit markets did not re-open this past year to New York City. It is less than three years since the height of its fiscal crisis and its near bankruptcy. Market access generally is not regained that fast. The traditional skepticism of public markets is such that New York needs more time before it can rely on those markets for the full amounts of its borrowing needs. III. The City's Four-^Year Budget Outlook Most informed observers believe — and I concur in their conclusion — that if the obstacle of budget deficits could be eliminated, then investor caution would tend to dissipate. Accordingly, I asked City officials in November to prepare a four-year financial plan, covering budgets and financing, and aimed at achieving budget balance in accordance with generally accepted accounting principles at the end of the plan period. Treasury received this financial plan on January 20 and reviewed it intensively, together with our consultants — Arthur Andersen & Co. Our conclusions regarding this plan were central to the development of our proposed financing legislation as presented to Congress on March 2 and embodied in S. 2892. On April 27, 1978 the City presented its formal 1979 budget and an up-dated and revised four-year budget plan to the City Council and Board of Estimate. We have also studied this latest version carefully. I will now discuss the City's current condition, and then this most recent budget plan and our assessment of it. - 7 Parameters of The City's Budget New York does not have a conventional budget and cannot eliminate its deficits in one year. Let me explain why. New York City's budget is virtually unique in terms of its size and composition. At approximately $13.5 billion today, it is by far the largest municipal budget in the United States. Indeed, New York has the third largest overall governmental budget in this country — behind the Federal government and the State of California, but considerably larger than that of New York State. This enormous City budget reflects New York's huge population (7.5 million) and the large number of services for which the City, instead of a larger county or State, pays. Specifically, the City administers a wide range of State and national welfare programs, for which it must pay a large share of the costs. The City pays for 25 percent of the welfare and medicaid benefits provided to its residents. These alone involve $1.2 billion each year. New York is the only major U.S. city responsible for paying this high proportion of welfare and medicaid. Indeed, only 12 States require their localities to share any substantial amount of the costs of Federal welfare programs. In addition, the City funds a series of other services which, in other cities, are paid for by larger governmental units — a county or the State. This is partially because New York is so large, both in territory and population. It also reflects the historical division of financial responsibility between the City and the State whereby the City pays most of the costs of the municipal courts, hospitals, and public schools. New York City —A Reflection of Americans Urban Problems Consistent with this general fiscal situation, of course, New York suffers from a series of ills which afflict many other urban centers. The City's economy has declined sharply during the past decade, as have those of numerous other Northeast and Midwest cities. New York has lost approximately 510,000 jobs from 1969 through 1975, an amount which alone exceeds more than the total public and private employment of all but a handful of other cities. Moreover, the City faces a serious revenue/expenditure gap with revenues growing more slowly than inflation-driven expenditures. - 8 These problems are not unique to New York. They are common to a number of our larger American cities. The underlying cause is largely one of secular economic decline. Current trends include population loss, declining private sector employment and slower per capita income growth. Hence, the ability of the City to balance its budget over the four-year period is substantially impacted by the local and national economies. A declining local economy yields the equally unattractive choices of either raising taxes or cutting services. Each of these steps accelerates the deterioration of its economy. The only way to break the downward spiral is to rebuild the private sector base. Cognizant of these problems, the Administration already has taken steps to assist declining cities. On March 27, 1978, the President announced his urban policy package which provides a framework to guide federal policy decisions in all areas and to focus Federal resources on urban problems in the years to come. Included are a variety of specific administrative and legislative initiatives. Let me highlight three major ones. The President recommends replacing the expiring countercyclical program with a $1 billion Supplementary Fiscal Assistance program to aid fiscally distressed local governments. He is proposing the establishment of a National Development Bank to encourage the private sector to remain, expand and locate in distressed areas. His third major initiative is the proposed Labor Intensive Soft Public Works program, involving $1 billion per year over 3 years to rehabilitate and renovate public facilities. These are a few examples of a diverse set of programs, each designed to ameliorate one aspect of the multi-faceted problems facing our cities. The package totals approximately $8 billion in budgetary authority, guarantee authority and tax expenditures during the first year. It augments other significant Presidential proposals, such as the extension of the Comprehensive Employment and Training Act and the welfare reform program, which are under Congressional consideration now. The City's Four-Year Budget Plan The revised City four-year plan (the "Plan") is summarized in Table 3. Please note that this is a "plan", not a fourYear budget. No city or governmental unit, be it New York City - 9 or the U.S. Government, can formulate a detailed budget today, for 1980, let alone 1981 or 1982. In drawing up the revised Plan, City officials extrapolated trends in revenues and expenditures which are reflected in its FY 1979 budget. At my request this initial forecast also assumed that the practice of funding operating expenses through the capital budget be eliminated before the start of the last year of the Plan. I also insisted that the budget be balanced in accordance with generally accepted accounting principles. The revised New York City Plan projects a balanced budget for the City's next fiscal year. Over the 1980-1982 period, however, it forecasts annual deficits growing to a little more than $700 million by the end of the Plan period, $362 million in FY 1980, $593 million in FY 1981, and $702 million in FY 1982. The primary reason for these deficits is the phasing out of the practice of funding operating expenses with monies from the capital budget and the adjustment of the City's contribution to its pension funds to conform with generally accepted accounting principles. Looking at the budget plan on the basis of generally accepted accounting principles, the budget gap would be approximately $600 million for FY 1979 and would grow slightly, to the $702 million figure for FY 1982 mentioned above. The 1979 Budget On the Boa a balance Denween revenues ana expenairures in concrasi to t. January 20 estimate of a $457 million deficit. This balance was achieved through a variety of means, including the use of new expenditure and revenue baselines, the adoption of certain actions by the City to close the gap, and the passage of an aid package for the City by the State legislature. The January 20 Plan was based on revenue and expenditure patterns through September 1977. In drawing up the FY 1979 budget and the revised Plan the City relied on updated informa tion reflecting the January-March period. In particular, tax revenues, especially sales and personal income tax receipts, were running somewhat higher than forecast and thus are now estimated to be somewhat greater over the Plan period. In addition, the City actuary determined that pension fund costs were overestimated in the January 20 Plan, as were estimates °f the City's interest expense. The 1979 deficit reduction actions which the City is Vitiating will produce $174 million in budgetary savings - 10 (shown in Table 4 ) . The principal action involves attrition of 3 percent of the labor force over the next year, which will lower so-called personal service costs by $76 million. The other major actions involve a plan to sharply limit growth in expenditures for materials and supplies and to reduce costs of the Department of Social Services through reduced welfare eligibility, improved job placement of those on welfare and a reduction in medicaid expenditure. Included in the FY 1979 budget are $250 million of additional State aid over and above the amounts shown in the January 20 version of the Plan and I commend Governor Carey and the State legislature for taking these actions. These State actions, shown in Table 5, are composed primarily of increases in State revenue sharing ($76 million), State education aid ($60 million), and the State assumption of costs to the localities of the Supplemental Security Income program ($60 million). The remaining amounts of additional aid come from increased taxes on real property of Conrail and Amtrak passed through to the City ($12 million) and a tightening of procedures for the administration of several public assistance programs ($43 million). The Emergency Financial Control Board (the "EFCB") and the Special Deputy State Comptroller have identified approximately $100 million of potential revenue shortfalls or underestimates of expenditures in the FY 1979 budget. For the most part, these "soft" areas reflect uncertainty over certain State actions and over passage of the Administration's Supplementary Fiscal Assistance program. Reflecting its statutory responsibilities, the EFCB has asked Mayor Koch to identify $100 million of contingent deficit reduction steps to be taken in FY 1979 if the City's projections are not met. I concurred in this EFCB analysis and asked the Mayor to present the contingent FY 1979 budget actions to me before this testimony. The Mayor's stand-by deficit program for FY 1979 consists of possible actions to be taken in four principal areas. First, the City has identified 32 separate expenditure reduction steps in its agencies which would produce total savings of about $23 million. These reductions largely involve further attrition in each agency. Second, the maximum increase in the City's procurement budget would be held to an even lower level than contemplated in the January Plan — below 3 percent — to produce savings of $20 million. A third area consists of delays in hiring new workers during the 1979 fiscal year, yielding another $20 million of budgetary relief. The fourth step concerns the re-estimation of certain revenues and the resolution of certain accounting issues affecting them. The net revenue increase approximated $40 million. These actions are summarized in Table 6. - 11 Let me emphasize that the deficit reduction process reflected in this 1979 budget is the same approach which has been taken successfully by the City over each of the last three years. Working with the EFCB the City has budgeted for its operations in such a way as to produce a balance according to State law. In general, the operating results for the last three years have been better than expected, thus validating the City budget process. The FY 1980 - FY 1982 Part of thePlan Regarding the remaining three years of the Plan, you will note on Table 7 that several of its 1979 reduction steps will produce recurring and growing savings in the later years. In addition, the City plans to take additional actions in those years to narrow the projected gaps. Specifically, further attrition is planned for the 1980-1982 period, together with continued actions to contain other than personal service costs and management improvements. The total budgetary relief amounts to $125 million in FY 1980 and would rise to $422 million in FY 1982. When applied against the forecasted deficits for those years the gaps narrow to the amounts shown in the middle of Table 7. The City, as it has in the past, is continuing to work with State and Federal officials to identify specific programs that could be begun, modified, or expanded to close these gaps. Iv - Treasury's Assessment of the Four-Year Plan We have studied this Plan thoroughly together with our consultants, Arthur Andersen & Co. We are satisfied that the FY 1979 revenue and expenditure forecasts are reasonable, and that next year's budget thus will be balanced. Of course, budget balance" in this case reflects the permitted four Year phase-out of those operating expenses which are funded through the capital budget. Turning to the FY 1980-FY 1982 part of the Plan, it is our assessment that City's revenue estimates for that period are conservative — they involve little growth. Such estimates ver the past three years have been quite accurate and an examination of the assumption underlying the forecast for the J-an period confirm that the City continues to project conservatively. - 12 Expenditure estimates for the FY 1980 through FY 1982 period also appear to be generally reasonable, although we have identified a few areas of uncertainty. One uncertainty is, of course, the cost of labor contracts over this full four-year period. I will have more to say about this issue later. Regarding 1980, specifically, I have asked Mayor Koch, and he has agreed, to identify contingent deficit reduction steps to save $300 million in that year. We are not projecting a deficit of that magnitude but there are uncertainties in the City's Plan for that year and a supplemental budget plan should be available for implementation if needed. In response to my request Mayor Koch has identified $300 million of additional measures to close any potential budget gap for 1980. Since the January 20 Plan, the Administration has sent its proposed Supplementary Fiscal Assistance program to Congress and the City now estimates that it would receive $84 million more in 1980 than it earlier planned. Similarly, Governor Carey has indicated that the City may plan on $116 million more of 1980 State aid than is contained in its April 27 budget plan. Finally, many of the contingent actions outlined by the City for FY 1979 could be repeated in FY 1980, to produce an overall total of $300 million in gap-closing actions for that year. Together with the 1979 contingent plan, we think that such 1980 actions can ensure that the City achieves budget balance, as defined, during the next two years. Turning now to the 1981-1982 period, our judgment is that the City's budget can move into budget balance according to generally accepted accounting principles by FY 1982. This judgment reflects several factors. First, the City plans to take additional deficit reduction actions in those years to produce savings in the amounts shown in Table 7 (as I mentioned earlier). These will have the remaining gap of between $230 million and $330 million to be filled by additional State and Federal actions or through more City actions in those years. State actions potentially could close almost all of the prospective gaps in the two final years. As shown at the bottom of Table 7, the revised plan carries $250 million of increased State aid in FY 1979, but only $174 million of this is projected to recur in subsequent years. I met with Governor Carey and the State legislative leaders and emphasized the need for aid to the City to increase and to be of a recurring nature. The Governor provided me with estimates showing the amount of aid increasing up to $450 million by 1982. - 13 The difference between the $450 million promised by the Governor and the $174 million included in the revised plan is $276 million — about the size of the projected FY 1982 remaining gap. I recognize that the State legislature cannot commit in advance to specific amounts in future budgets. Yet, it is also clear that increased State aid beyond 1979 is a prerequisite to achieving true budget balance for the City. Our position is that amounts of at least this magnitude must be provided. The City's Plan for closing the budget gap also assumes moderate amounts of additional Federal fiscal assistance. Our general view is that the City has primary responsibility for its budget, and beyond that, the State has the principal responsibility. Nevertheless, the City's needs are such that some Federal residual budget assistance is clearly justified. Table 8 summarizes the history of Federal aid to the City in recent years and illustrates that New York has received growing amounts of Federal aid in these years. I do not believe it is unreasonable to assume that New York together with other cities will receive increases in Federal aid over the 1979-1982 period as the President's urban initiatives are implemented. Finally, I believe that the combination of Mayor Koch's commitment to attain the balance, the EFCB's statutory responsibilities in that area, and the terms of S. 2892 - which would require the attainment of true budget balance by 1982, will mean that New York will attain its four year budget goals. In my judgment, the City will take whatever fiscal steps are necessary in 1981 and 1982 to reach budget balance. The City's New Labor Contracts The City and its unions announced an agreement two days ago concerning new labor contracts for the 1979-1980 period. Treasury took no direct part in the negotiations — believing this to be an inherently local issue — but consistently stressed to the City that the budget effects of the final settlement would be of critical importance to the integrity of the City budget Plan. Specifically, we have consistently taken the position that the City must fully offset any increased labor costs with recurring revenues or true savings in other areas. - 14 The proposed settlement would cost the City budget approximately $757 million over those two years. Base wages would increase 4 percent beginning October 1978 and another 4 percent beginning October 1979, and "bonuses" (cost-of-living adjustments) of $750 per worker would be paid in each of the two years. These latter payments actually would be somewhat smaller than the cost of living adjustments paid during the past two years. The City's April 26 budget Plan proposed to finance any settlement with: (a) $69 million already budgeted in each year for cost-of-living adjustments; (b) the use of $170 million of its FY 1978 ending cash balance; and (c) the use of a contingency reserve established in the revised Plan amounting to $193 million in FY 1979 and $116 million in FY 1980. These items total $617 million. We think that the City's proposed financing of this settlement is sound with two exceptions. First, to state the obvious, the new agreement would cost $140 million more than the $617 million carried in the April Plan. Off-setting deficit reduction steps in this amount will be required, and the City's recently submitted 1979 and 1980 contingent budget plans should be sufficient in this regard. Second, the budget plan for FY 1981 and FY 1982 assumes the bonuses or costof-living adjustments will not be continued in those years, and this appears unrealistic. In general, this labor agreement appears fair. On the one hand, it is unreasonable to ask City workers to accept no increases for the next two years. On the other hand, the effective wage increase over the two years of approximately 6 percent (the 8 percent does not take full effect until FY 1981) is reasonably restrained in the context of other recent public and private sector labor settlements. All things considered, I conclude that this potential agreement is a responsible one. I am disappointed, however, that the labor agreement has not addressed the issue of obtaining increased productivity from the City work force. More specifically, the settlement does not include any provisions to bring about needed modifications in work rules, fringe and pension benefits, and unnecessarily rigid civil service rules. To an outsider, it seems clear that progress in those areas is essential to the ultimate recovery of the City. As I understand it, New York City's present work rules and benefits are considerably more generous than those that exist in typical cities across the country. It is difficult to see how they can be justified when the City faces the kind of financial difficulties that your Committee has been reviewing. The Congress may wish to consider whether it should take any action to facilitate progress in this area. - 15 V. New York City's Financing Outlook Let me now discuss New York's borrowing needs. Why New York Borrows Large Amounts Each Year Each year New York borrows large amounts through the issuance of both short- and long-term notes. During this current year, for example it has borrowed $1,875 billion on a seasonal basis and will have borrowed $1 billion on a 15-year basis. Seasonal needs arise because City expenditures are spread fairly evenly over the year while certain revenues, particularly State aid, are concentrated in the final months of the City's fiscal year. The City thus borrows during the first months of its fiscal year, in anticipation of revenues to be received during the final months of its fiscal year. New York, like all other municipalities, also must finance its capital budget. The City's capital budget includes expenditures for long-term assets, e.g. schools, roads, etc., that are traditionally financed with long-term debt. During each of the past two years, the City has sold $1 billion of long-term bonds to cover both traditional capital spending and operating expenses carried in the capital budget. Recent Financing History and Current Problems Since 1975, substantially all of the City's new borrowing needs have been satisfied from two sources. Treasury has provided short-term loans under the Seasonal Financing Act, and the City employee pension funds will have lent or are obligated to lend $2.65 billion during the intervening two and a half years. Both the Federal seasonal loan program and the City pension fund loan program expire on June 30, 1978. The City thus must develop new financing arrangements for both its short- and long-term needs. For this reason, I asked the City last November to develop an overall financing plan, to accompany its budget Plan. This also was submitted to me on January 20, and Treasury has been evaluating it since then. - 16 The City's Four^Year Financing Plan Regarding long-term financing, the City Plan projects $5.1 billion of financing, as set forth in Table 9. The crux of New York's long-term borrowing plan is a $2,025 billion program of Federal and State loan guarantees on a 90 percent - 10 percent basis for City bonds sold to the City and State pension funds. The City anticipates that the guarantee protection would last for at least ten years, although the City bonds would carry 20 or 25 year maturities. Its proposed guarantee automatically would lapse, however, if the pension funds resold the bonds. The City's Seasonal Financing Plan The City projects seasonal borrowings of $1.4 billion next year, declining to $1 billion in 1982. This reduction would be accomplished by selling MAC bonds to fund the $800 million advance that the State extends annually to the City. New York proposes an extended Federal seasonal loan program pursuant to which it would borrow $1.2 billion next year, $800 million in 1980, and $400 million in 1981. The remainder of its seasonal needs would be covered by a $600 million line of credit from the New York Clearing House Banks. Summary of City Financing Plan City officials believe that these financing arrangements will permit New York both to meet its full borrowing needs over the 1979-1982 period and to regain full access to conventional markets at the end of that period. Indeed, it projects selling $1 billion of City bonds to the public in 1983, as compared to only $250 million during the final year of the Plan period. Recent Developments - in New York City and State Local Financing Negotiations The Municipal Assistance Corporation has been negotiating with local financial institutions to obtain unguaranteed, longterm lending commitments to the City for the 1979-1982 period. Recently, it obtained commitments to buy MAC bonds over those four years in amounts of $500 million from the Clearing House - 17 banks, $250 million from a consortium of insurance companies and $250 million from a consortium of savings banks. Our view is that this $1 billion commitment represents a good first step toward assembling the necessary package of unguaranteed private lending commitments and planned public offerings. I believe that the Clearing House banks, in particular, should consider a larger commitment than the $500 million which they have pledged. They have the capacity to do so, and still keep the proportions of their investment portfolios invested in City or MAC securities well below 1976 and 1977 levels. The Municipal Assistance Corporation also has held discussions with representatives of City and State employee pension funds, concerning long-term lending commitments from them. Substantive negotiations with those entities have not yet begun, but we anticipate that they will commence shortly. Our position concerning the City pension funds is that they must commit to buy unguaranteed City or MAC securities over the next four years, just as the financial institutions have done. I real ize that the City funds have supplied all of New York's long-term borrowing needs since late 1975, and commend them for having done so. I obviously do not expect them to continue as sole lender, nor to increase the overall percentage of their assets invested in City and MAC securities. But, I should point out that if for the next four years, they simply reinvest the principal of maturing City obligations that they presently hold, the percentage of City's obligations that they hold will go down from 35 percent to 24 percent. This is the case because their total assets are projected to grow by approximately 34 percent over the next four years. New State Legislation Let me now review several recent developments in New York which relate to the conditions under which we would issue guarantees. The New York State legislature has enacted two bills that essentially meet the conditions regarding State legislation which underlie our proposed legislation. First, the State has enacted legislation to extend the life of the EFCB and to alter some of its powers. This legislation generally satisfies our requirement that the fiscal control and monitoring entity have powers no less extensive than the existing EFCB. - 18 The life of the EFCB has been extended for a period which could run 30 years. While a sunrise-sunset provision has been added, that provision is inapplicable so long as any Federal guarantees remain outstanding. Under this legislation, so long as Federal guarantees are outstanding, the EFCB has the power to: 1. Approve, disapprove, and in some cases formulate and adopt, the financial plan and any modifications thereto. The financial plan is now a rolling four-year plan which must be reviewed and approved each year. Revenue estimates presented by the City may be revised by the EFCB. Subject to certain narrow exceptions which will be discussed below, budgets must be balanced in accordance with GAAP for fiscal years beginning after June 30, 1981 and annual audits are required by independent public accountants. 2. Approve or disapprove contracts (including collective bargaining agreements of the City and the covered organization) and any proposed long-term or short-term borrowings. In this regard, new strict limitations on the issuance of short-term debt have been incorporated into the statute for the first time. 3. Maintain a separate fund through which the cash resources of the City and the covered organizations may be controlled in appropriate circumstances. In addition, a separate debt service fund has been created in the possession of the New York State Comptroller into which all real estate tax revenues and certain other revenues will be deposited and applied to the repayment of outstanding bonds and notes. In a related measure, MAC has been authorized to issue an additional $3 billion of its bonds which are backed by the moral obligation of New York State as well as $500 million in short-term notes maturing on June 30, 1978 which are not backed by the moral obligation of New York State but are secured by New York State aid payments. It is anticipated that these notes will be sold to the City pension funds to bridge their obligation to invest $683 million in long-term City bonds. The EFCB legislation provides two narrow exceptions to the requirement that budgets be balanced in accordance with GAAP. Changes in GAAP or changes in the rules of application of GAAP may be phased in with the approval of the EFCB if immediate application thereof would result in a substantial adverse impact on the delivery of essential services. - 19 Similarly, the EFCB may relieve the City from the requirement that its budget be balanced in accordance with GAAP if, after the beginning of a year in which a balanced budget has been adopted, an event occurs which would require so drastic a modification to the budget to achieve balance at year-end that a material adverse impact on the delivery of essential services would result. In the case of fiscal years ending after June 30, 1982, the amount of any deficit which results must be repaid in the next fiscal year. We believe both of these limited exceptions are appropriate given the long-term nature of the EFCB, and we would support an amendment to S. 2892 to accommodate them. The $683 million Long-term Pension Fund'Loan Scheduled by June30, 1978 At this point, I should comment on the matter of the remaining $683 million investment obligation of the City pension funds. In 1975, the pension funds agreed, in the Amended and Restated Agreement, to provide long-term financing for the City during the period ending June 30, 1978. That agreement was part of a package of arrangements among the several interested parties, including the United States, that met the City's financial crisis. Although a number of appropriate conditions were included in the Agreement, none of them related to the prospects for Federal financing assistance after June 1978. Yet certain pension fund trustees have recently indicated that they do not feel obligated to invest the $683 million because of uncertainties over the post-June 1978 period. Mr. Chairman, as you know, Congress relied upon the longterm financing commitments of the pension funds in authorizing Federal seasonal financing assistance. Treasury, in making individual loans under the Seasonal Financing Act, has relied upon the timely fulfillment of those commitments in order to provide needed funds for the City. I might note, parenthetically, that our proposal for guarantee authority over the next four years is premised upon the making and fulfillment of new lending commitments by the local parties, including the City pension funds. Treasury's General Counsel has advised me that the outstanding commitments of the pension funds are firm, binding contractual obligations, and I expect them to be fulfilled. We would, of course, not proceed with the program that has been proposed if this commitment is not kept. - 20 VI. The Administration's Financing Proposal Background Our evaluation of the City's financing plan is that it is well-conceived and should achieve its objective. We have, however, two reservations: First, our analysis of the Plan leads us to conclude that the City can adequately provide for its capital requirements by selling somewhat less — perhaps $4-1/2 billion — than the $5.1 billion in long-term securities during the years 1979-1982, which the Plan projects. Second, we believe that this reduced level of long-term financing can be assured with, more modest Federal assistance. I want to emphasize, however, that we have concluded that the City's solvency would not be assured in the absence of any Federal lending assistance beyond June 30, 1978. In this regard, therefore, we disagree with the conclusions of the Report recently issued by this Committee on New York City. While it is conceivable that if every contingency is favorably resolved, no additional Federal lending assistance to the City will be required, we do not believe it would be responsible to risk bankruptcy should events prove this judgment wrong. New York City in bankruptcy will prove far more expensive to this nation — both in expense and personal sacrifice — than any modest form of assistance. Let me now outline the reasons why I believe there must be some Federal long-term lending assistance. Any long-term financing plan for New York must rely on the sale to the public of large amounts of MAC bonds and City bonds. The City's own plan projects $1.85 billion of such public sales and your Committee Report forecasts only modestly lower amounts. The receptivity of public markets to those sales, however, is far from assured. Today there is no market for City bonds at all. Moreover, the market for MAC offerings in recent months has been quite limited, and last December's $250 million MAC offering was barely completed. It is entirely possible, therefore, that the public markets will not supply the amounts of long-term capital which New York needs to meet even its minimal capital needs. Unless there is a Federal backstop, to assure that these amounts can be obtained, the City's solvency simply cannot be assured. We believe local private parties primarily the City pension funds and the local financial institutions, can supply a large portion of the long-term needs of the City, but we cannot be certain that they will be able to supply all of such needs. - 21 - the seasonal loan program, on a reduced and self-liquidating bas does and Specific Proposal We proposed on March 2 that Congress (i) authorize the Secretary of the Treasury in the four years ending June 30, 1982, to guarantee up to $2 billion in aggregate principal amount of taxable New York City or MAC securities, such guarantees not to exceed 15 years, with a minimum annual guarantee fee of 1/2 percent per annum payable on any outstanding guaranteed securities; and (ii) amend PL 94-236 to permit the City and State employee pension funds to purchase City or MAC securities during the 1979-1982 period. On March 2, I testified that guarantees authorized by the Congress would be issued only under a set of detailed conditions. The current status of those conditions, and what has been done to satisfy them, is as follows: — For fiscal year 1979, I stipulated that the City would be required to adopt a four-year budget plan that by 1982 produces a budget balanced in accordance with Generally Accepted Accounting Principles (GAAP), and would continue to adopt and adhere to rolling four-year budget plans that for 1982 and thereafter are balanced in accordance with GAAP. The City periodically would submit to the Secretary financial statements as required. Our assessment of the City's recently revised four-year budget plan already has been described. — New York State recently has enacted the necessary legislation to ensure the existence of a fiscal control and monitoring entity with powers no less extensive than the current Emergency Financial Control Board (EFCB). This entity would be in existence for at least the life of the Federal guarantees. I expect that this legislation will be modified in a few areas described below. New York State also has enacted appropriate legislation to facilitate the public sale of MAC longterm securities, and to provide appropriate security and legal authority for such securities. Our position, - 22 -- however, is that the State also must enact legislation to expand the City's bonding authority as required for the four-year financing plan and to permit pension fund trustees to invest in City and MAC securities. Federal guarantees will be appropriately secured by Federal transfer payments to New York City and by such payments to New York State. The recently passed State legislation extending the EFCB will be modified to include a requirement that the City demonstrate that it has achieved market access for its securities before the emergency period can end and before the sunset provisions of the EFCB legislation are applicable. We understand that this modification is acceptable to all parties. The City will engage independent bond counsel of national reputation to pass upon the validity of the State legislation and any guarantee agreement entered into with the Federal Government. All parties recognize that this may require certain technical amendments to the legislation. In my earlier testimony, I indicated that Federal guarantees will be appropriately secured by Federal payments to the City and a State funded debt reserve account or the pledge of an appropriate amount of Federal transfer payments of the State. The bill before your Committee provides that the Secretary shall withhold first City and then State transfer payments in the event the Federal Government makes payment under the guarantees. Furthermore, upon payment under any guarantee, the Federal Government will be entitled to the security provided by the City on the guaranteed bonds and to a first priority on distributions from the fund controlled by the EFCB. Since we believe this security to be adequate, we have not required the creation of a State funded debt reserve fund. Role of the Guarantees in the City's 1979-1982 Long-term Financing Plan. A long-term financing plan for New York cannot work without the cooperation of the relevant local parties -- the City and State pension funds, the Clearing House banks and other local financial institutions, and others. The - 23 exact division of lending commitments among these parties is a matter for detailed negotiation over the near-term future in light of the prevailing conditions. It is clear, however, that each of these key parties must make a major lending contribution. In general, I think that up to $2 billion of MAC and City bonds can and should be sold to the public during the next four years on an unguaranteed basis and additional amounts to private lenders. Federal guarantees will be issued only to the extent that the public markets and private lenders do not provide the necessary funds on an unguaranteed basis. However, it would not be my intention to issue Federal guarantees unless other lenders to New York City make significant long-term lending commitments on an unguaranteed basis. The timing of the issuance of Federal guarantees and the size of purchases of non-guaranteed MAC or New York City long-term obligations by lenders will have to be worked out as part of an overall financing package. The precise form and coverage of the guarantees require further negotiation. Among other things, however, the guarantee would lapse if the guaranteed securities were sold by the original purchasers. It is clear to me, however, that Federal guarantees, on the order of $500 million, must be issued during the first year of the City's financing plan. This will be necessary to demonstrate a Federal commitment to New York's future. It will set the financial control mechanism in place and provide the impetus to obtain the necessary commitments from private lenders and the pension funds to purchase significant amounts of unguaranteed bonds from the City or MAC. It will be my intention, in the negotiations that will take place with potential lenders, to keep the length of Federal guarantees as short as feasible. Similarly, since we require that a "best efforts test" be met before any guarantees would be issued, we hope to avoid issuance of guarantees in the later years of the Plan when hopefully the City will regain access to the markets. Seasonal Financing My judgment is that New York can satisfy its own short-term borrowing needs, provided that Federal guarantee authority as outlined above is available concerning its long-term financing. Before Congress enacts guarantee - 24 legislation, however, New York should prepare a seasonal financing plan satisfactory to the Treasury. I have asked Mayor Koch to do so. If my judgment changes over the near-term future on New York's ability to meet its own short-term needs, I will report accordingly to Congress. Conclusion We look forward to working with Committee staff on the details of our proposed legislation. I also will be happy to answer now any questions you might have. 0O0 SUMMARY FY REVENUES OF THIS NEW YORK CITY B U D G E T ^ 1975 T H R O U G H FY 197 8 (ESTIMATED) ($ In Millions) FY 1975 F\" 1976 FY ' 1977 FY 1978 General Sources Sales Tax Personal Income Tax General Corporation Tax Water & Sewer Charges Stock Transfer Tax Financial Corporation Tax Other TOTAL GENERAL SOURCES Real Estate Tax Federal £> State Aid TOTAL REVENUES $ 791 466 268 238 185 ;i4 1,555 r~i7$Tr: $ $ 828 615 443 218 270 202 1,128 3,704 $ $ 867 742 519 206 279 149 1,205 3,967 $ $ 901 756 504 231 250 168 1,242 4,052 3,236 5,435 3,168 6,083 $12,009 $12,638 $13,303 987 1,269 $ 3,746 3,010 1,377 652 285 1,847 462 1,137 461 $ 3,774 2,481 1,325 669 292 1,747 597 1,209 873 $ 3,906 2,564 1,346 661 297 1,607 402 1,188 1,332 $12,033 $12,977 $12,967 $13,303 $ 968 $ 329 $ 2,000 $ 1,200 2,896 5,452 2,966 5,339 $11,965 3,482 2,345 1,187 654 282 1,827 • EXPENSES Social Services Education Health St Sanitation Police Fire Debt Service (2) MAC Debt service Pensions (2) Other TOTAL EXPENSES DEFICIT Estimated Adjusted Deficit Based on Treasury Estimates Using GAAP 68 $ 2,100 750 TABLE 2 NEW YORK CITY SEASONAL LOAN PROGRAM BORROWING AND REPAYMENT SCHEDULE CITY FISCAL YEARS 1976 - 1978 1976 Borrowing Date Repayment Date Amount (Millions) 12/18/75 12/31/75 1/15/76 2/11/76 2/17/76 2/17/76 3/01/76 3/15/76 4/20/76-i^ 5/2Q/76f' 4/2Q/76±/ S 130 240 140 250 80 100 250 70 6/30/76?/ 6/3Q/76-?, 6/30/76-/ $1,260 Interest Rate (%) Interest Due (Millions) 6.92 6.68 6.13 6.29 6.26 6.26 6.39 6.33 6.43 2.958 6.105 2.163 5.514 1.770 2.298 5.077 1.238 27.122 7.37 7.02 7.10 7.04 5.85 5.83 5.73 5.75 5.92 6.53 29.076 7.876 .827 .36 8 .315 .670 .526 4.874 4.466 88.398 6.65 6.80 6.85 6.93 7.36 7.38 7.46 7.54 7.58 7.75 7.73 7.75 7.26 15.796 5.142 8.670 10.063 2.490 5.297 12.518 2.376 14.791 6.274 1.842 7.814 93.075 1977 7/01/76 7/16/76 7/16/76 8/04/76 12/01/76 12/08/76 12/22/76 12/30/76 3/14/77 4/20/77-|^ 4/20/77 T V 5/20/77^ 6/20/77*/ 6/20/77.1/ 6/20/77i4 6/30/77J, 6/30/77- 7 $ 500 150 200 225 200 200 200 170 255 $2,100 1978 7/05/77 7/18/77 7/18/77 7/29/77 8/16/77 8/16/77 9/19/77 10/04/77 10/04/77 12/05/77 12/28/77 12/28/77 4/20/781/ 4/20/78 i? 5/20/787, 4/20/78-', 4/20/78 44 5/05/78 f/ 5/20/781/ 5/20/78 i/ 6/20/78 6/20/78 6/20/78 6/30/78 $ 300 100 150 200 50 100 250 50 275 150 50 200 T7875" 1) 2) 3) 4) 5) Repaid Repaid Repaid Repaid Repaid four days early. two days early. five days early. one day early. six days early. TABLE 3 New York City's Four-Year Financial Plan As Revised ($ In Millions) Fiscal Year 1980 1981 1979 1982 REVENUES 3,189 $ 3,137 $ 3,126 $ 3,156 General Property Taxes 3,325 3,466 3,209 3,150 Other Taxes 834 856 815 886 Miscellaneous Revenues 923 973 977 1,187 Unrestricted Federal & State Aid 1,985 1,990 2,014 2,429 Federal Grant: Categorical 1,994 2,021 1,970 2,191 State Grants: Categorical (100) (100) (100) (100) Less: Provision for Disallowances 379 251 109 529 Capital 435 443 426 417 Intra-City Revenues $13,878 $12,827 $12,773 $12,914 TOTAL REVENUES EXPENSES Personal Service Other Than Personal Service Debt Service MAC Debt Service Funding General Reserve TOTAL EXPENSES Gap To Be Closed 5,762 6,038 1,516 462 100 5,643 5,556 1,416 474 100 5,744 5,704 1,321 497 100 5,828 5,885 1,248 555 100 $13,878 $13,189 $13,366 $13,616 — $ (362) $ (593) $ (702) ACTIONS TO CLOSE GAP Federal & State Actions City Actions TOTAL ACTIONS TO CLOSE GAP 237 125 321 272 280 422 362 593 702 TABLE 4 NEW YORK CITY PROPOSED ACTIONS TO CLOSE FY 1979 BUDGET GAP Reductions of Revenue Expenditures Increases (City Funds) ($ In Millions) Total Savings From Attrition: Salaries Fringe Benefits Sub-Total $ $ — — $ 72.6 3.6 $ 76.2 $ $ 72.6 3.6 76.2 Other Savings & Revenues: Board of Education $ — Dept. of Social Service Debt Service — Indirect Cost Reimbursements on Fed. Grants 11.0 OTPS Cost Containment Improved Billing 6 Licensing Procedures 6.0 Other Actions 2.3 Sub-Total Other Savings & Revenues $19.3 Total Savings & Revenues $19.3 $ 15.7 24.0 15-0 $ 15 .7 24 .0 15 .0 23.0 11.0 23.0 1.5 6.0 3.8 $ 79.2 $ $155.4 $174.7 98.5 NEW YORK STATE ACTIONS TO CLOSE FY 19 79 BUDGET GAP Amount ($ in Willi Revenue Adjustments State Revenue Sharing $ *3.0 NYS Countercyclical Aid Real Property Tax (Conrail and Amtrakj Additional Social Service Review ".0 l^.u 22.0 $110.0 Expense Adjustments State Education Aid $ ^^ SSI Cost Assumption Wage Reporting Matchup Audits of Voluntary Hospitals Additional MMIS Savings Drug Abuse Program Assumption b Total 6 ^-^ !••> 10.0 6.0 5,5 $141.0 $251.0 TABLE 6 CITY FY 1979 CONTINGENT GAP-CLOSING ACTIONS (IN MILLIONS OF DOLLARS)' Specific Agency Expenditure Reductions Further City-wide Cost Containment of General Procurement Expenditures Hiring Lag Reestimation of Revenues and Expenditures (net, to be included in the General Reserve) TOTAL $ TABLE 7 Summary of Federal, State, and City Actions to Close Budget Gaps in Revised Plan ($ In Millions) 1979 Gap to Be Closed Fiscal Year 1980 1981 1982 362 593 702 62 22 172 46 285 71 41 54 66 125 272 422 City Actions Planned to Close Gap Work Force Reduction Other Than Personal Service Cost Containment Management Improvements TOTAL Remaining Gap to Be Closed To be eliminated through Federal & State Actions beyond those included in revised plan. State Actions Already in Revised Plan 250 Federal Actions Already in Revised Plan 83 TOTAL 333 174 174 174 180 180 180 FEDERAL A I D TO NEW YORK CITY CITY FISCAL YEARS 1973 - 1978 ($ Millions) TYPE OF AID 1973 1974 1975 1976 1977 1978 Categorical Aid $1,790 $1,783 $2,217 $2,262 $2,421 $2,808 Revenue Sharing (including ARFA) 259 267 257 263 290 479 Total $2,049 $2,050 $2,474 $2,525 $2,711 $3,287 Source: Temporary Commission on City Finances and City Comptroll CITY FINANCING PLAN USES OF FUNDS Amount Item True Capital Spending Funding of Operating Expenses MAC Restructuring MAC Capital Reserve Bonding of State Advance $ 522 .900 -560 -250 . -^" $5,100 SOURCES OF BORROWINGS City & State Pension Funds (USG Guaranteed) MAC Private Placement: local financial institutions MAC sales to public City bonds to public * 90% USG guaranteed - $2,025 $2.25 1.000 1.510 V340 $5,100 THE SECRETARY OF T H E T R E A S U R Y WASHINGTON 20220 June 2, 1978 Dear The government is making every effort to reduce the inflationary impulses of our economy. We recently pared back and delayed our proposed tax cut; we are fighting hard to reduce future budget deficits; we have taken steps to reduce inflation-creating regulations; we have directed our agencies to observe the principle of deceleration in all new or renegotiated Federal contracts. And we have initiated politically difficult and painful wage deceleration guidelines for Federal workers. On April 11, President Carter announced that he would order a freeze on the salaries of all Executive employees and seek to limit increases in Federal white collar salaries to 5.5% this year. The Congress is now considering imposing similar restraints in high level pay on itself and on the Judiciary. To be sure, we have much more to do. But government cannot do the job alone. We must ask the private sector — labor and business — to contribute to this critical effort if we are to begin turning back the tide of inflation. I am writing to ask you to implement within your own institution the principle of wage and salary deceleration that we are applying to Federal employees. In the past few weeks, General Motors, Ford and AT&T have announced their intention to put tight constraints on executive salaries and other salaries over which they have control. Other business firms have followed suit. We would like to hear a similar Pledge from your organization. We ask that you help us meet our objective of reducing the economy-wide average increase in total compensation — £ages and benefits (excluding legally mandated items such as social Security taxes) — by at least a percentage point per year, in particular, we seek to realize greater deceleration - 2 - in wages on the part of those workers who have experienced the greatest gains in recent yeairs. If we can pull down the rate of growth in these wages while preventing an acceleration in the wage gains of others, we will be able to reduce the average wage increase nationwide. I enclose a memo from the Council on Wage and Price Stability indicating how this can be accomplished within an institution such as yours. Please give this matter serious thought and notify me soon whether you will cooperate in this critical endeavor. I realize that this letter will hardly endear me to your fellow executives. Most industries can think of one or another reason for exempting themselves from this exercise. And individually, no one wants a salary freeze or a reduction in pay increases which they have become accustomed to. Yet everyone mus.t contribute to the fight against inflation if we are collectively to maintain healthy profits, a vigorous economy and a strong dollar. - Sincerely, tCU W. Michael Blumenthal IMPLEMENTATION OF WAGE DECELERATION "In order to reduce the average wage and salary increases nationwide iL will be necessary to achieve substantia^ deceleration in the rate of increase in wages and salaries for groups of workers who have achieved gains in recent years that substantially exceed the economy-wide average. We have no rigid guideline, -and the wage deceleration effort should be characterized by a flexibility that reflects the widely-varying o • recent wage and salary trends of. various groups of worker; .Furthermore, while some of the details of the program are specified below, its actual implementation will necessarily take slightly different forms in different industries, depending upon the institutional peculiarities involved in the wage determination process in each industry. For example, in industries such as banking and insurance, the focus of the deceleration effort should be on annual salaries since most workers are paid on that basis. Our objective is to hold increases in total compensation — wages or salaries and benefits (excluding legally mandated items such as Social Security taxes) — significantly below their average annual increase during the base period. For example, a firm with a total quarterly payroll cost for workers of $3.0 million would first deduct the cost of such items as Social Security taxes,'Unemployment Insurance, and Workmen's Compensation. If, in this hypothetical example, these items totalled $200,000, the difference -- $2.8 million — would represent the relevant total compensation expenditures for this employee unit, including both salaries and payments for private fringe benefits such as health insurance and pension plans. Total quarterly payroll cost $3.Cm Less- employment taxes (e.g., Social Security) 0.2m Total compensation $2.8m The firm would then examine its records and ascertain how rauch this total compensation figure had grown over the 1976-77 period. For nonunion workers the compound average annual rate QLAncrease over the two-year period would then be the basis against which 1978 performance would be compared. Suppose this compound annual average growth rate in compensation were 7.2 Percent. In this case compliance with the deceleration objective would be achieved if in 1978 the increase in compensation were ne ld to 6.2 percent. - 2 In situations where compensation is determined under the terms of a collective bargaining agreement, the .base period is the life of the contract rather than the calendar year 1976-77 period, and the relevant measure is the average annual increase in compensation over that contract term. The rate of increase should be figured separately for appropriate groups of recognized workers — recognized bargaining units where there is collective bargaining and traditional units of similar kinds of workers where there is no bargaining. In the case of executive salaries we are asking that the rate of increase during 1978 be held to 5 percent or less. June 6, 1978 [In response to inquiries concerning the report by the House Committee on Government Operations on "Foreign Tax Credits Claimed by U.S. Petroleum Companies"] The question of whether U.S. oil producers operating overseas could claim U.S. foreign tax credits for levies paid to foreign governments had been under consideration for many years before the Carter Administration assumed office, with no decision having been reached. A fresh review of the issue was immediately commenced and in January 1978 the 1955 ruling that permitted such credits to be taken was revoked. In view of the complexities of the question, the length of time taken to complete the review was not unreasonable. The decision was made exclusively on the basis of tax law considerations in the Internal Revenue Service and the Treasury Department and after a review by the Secretary of the Treasury who has the statutory responsibility for all tax matters. When an Internal Revenue Service ruling is revoked, the Service's normal practice, which is explicitly sanctioned in the Internal Revenue Code, is not to make the revocation retroactive but rather to give taxpayers a reasonable time to adjust their affairs in the light of the revocation. This was the principle followed in this case. ^ottmentoftheTREASURY BHINGTON, D.C. 20220 TELEPHONE 566-2041 "•• *!' M H M M i ADVANCE FOR RELEASE SUNDAY MORNING June 11, 1978 TREASURY SECRETARY W. MICHAEL BLUMENTHAL ON ECONOMIC POLICY Following is the transcript of an interview with Secretary of the Treasury W. Michael Blumenthal by Alfred H. Kingdon, Editor-in-Chief of Financial World magazine on May 17. The interview appears in the current issue of Financial World reaching subscribers tomorrow. * B-963 * * * * MR. KINGON: Mr. Secretary, for some reason this Administration hasn't won the full confidence of investors and businessmen. To what do you attribute this? What has gone wrong? MR. BLUMENTHAL: In the first place there is increasing evidence of a shift and of increasing confidence by the business and financial community that the Administration is following sound, sensible economic policies that are consistent and easily understandable-. The commitment to maintain a reasonable growth rate, the commitment to put a tight lid on Government spending, the identification in the April 11th speech by the President of inflation as public enemy no. 1, the recent decision to trim the size of the tax package in order to reduce the budget, the continuing commitment to bring the deficit down and move it toward balance — all of these are things that I think are creating greater business confidence. Obviously, also the fact that we not only had a good year in 1977, but all indications are that we will have a good one in 1978 and that the prospects for '79 look good...all of that is helpful. I think the fact that the stock market has been moving up and that the exchange markets have stabilized and the dollar has strengthened all contribute to that. So I think we are in a slightly different situation now than we were. In the past, I think there were a number of factors. One of them was simply the lack of familiarity with a new President and a new Administration. Secondly, no doubt the fact that many leaders in the business and financial community belong to a different party and did not support this President when he was a candidate, naturally caused some hesitation on their part and a kind^of wait and see attitude. And finally, I think the lack of confidence has been a reflection of some real factors, the real factors being that we had a fairly long period when we experienced high levels of inflation, high levels of unemployment, uncertainty in international markets, and a kind of a sense by the business community that we no longer are masters of our own economic fate in quite the way we used to be. That may at times get put in terms of a particular Administration, but it is really a general problem, and I remember as a member of the business community having the same sense during the Nixon and F °rd Administrations. So I understand it very well. That kind of uncertainty obviously is a fact of life, but I think the Puces as such are more clearly understood and the situation is improving. • K1NG0N: Sir, to get specific for a moment — the President, you, others in the Administration have stressed lately tn e tremendous need for capital formation and incentives for ^vestment. And yet when such a move, a direct move, emanates trom Congress,- and of course .I am referring to the Steiger Amendment, the President has you running to the Hill in ssence crying foul and threatening veto.upWhy? -2MR. BLUMENTHAL: It is important to stress that this Administration is vitally concerned with the problem of capital formation. That's been said repeatedly: I did it most clearly in the speech to the Financial Analysts in Bal Harbour a week ago. So it is not a question of whether, but how. The tax bill that is before the Congress reflects a major effort to increase the profitability of-business, to increase cash flow for business. It is profitability of business and cash flow that will cause more investment and hence greater capital formation. The decision to try to achieve that by an across-theboard reduction in the corporate tax rate of a significant amount was not taken lightly: it was not taken in a vacuum. It was based on literally hundreds of people with whom I personally consulted, large business and small business, in the financial world and in the business world. And while there are many ways of providing more resources to business, all of them agreed that the highest priority was to bring the corporate tax rate down. What I have been saying, and also in the recent letter that I sent to the Congress on the Steiger Amendment, was that in the first place we don't have unlimited resources available to us. If we were to give up more than $2 billion of revenue for the Steiger Amendment, we would not have it available for reducing the corporate tax rate. And we think the corporate tax rate — and business felt that way — is a better way of doing that. Secondly, the Steiger Amendment is a "fat-cat" amendment. The Steiger Amendment is an amendment that benefits more than 80 percent of those taxpayer groups who make more than $100,000 a year. In fact it is a very regressive way of changing the tax system because it actually reduces the effective tax rate for those above $200,000 as compared to those who earn less. You actually begin to pay less in taxes when you reach $200,000 than you do at an earlier rate. That is not the way to get capital formation: that is certainly not the best way to get it. Which does not mean that the question of the double taxation of dividends, the distinction between earned and unearned income taxation and capital gains taxation should not be reviewed at some point in the future. But not at the cost of taking away the revenue for across-the-board reduction in the corporate rate. MR. KINGON: You referred to that in your response and said the Steiger Amendment "would steal much of the revenue" earmarked for corporate tax reduction. But is it not fair to say that it could not equally steal from some other reforms that aren't regarded by the business and investment community as so important? I am sure you've seen the S. I. A. study, and Chase out out a study. Econometrics also and unless the Treasury economists are different, everyone seems to be concluding that the effect of reducing capital gains taxes would be increasing revenues. -3MR. BLUMENTHAL: If that were true, I would lead the parade of those who would call for a drastic reduction in the tax treatment of capital gains, because then we could in one fell swoop achieve capital formation and balance the budget at the same time. Unfortunately, reality is somewhat different. The S.I.A. study achieves its result in a very simple way by making certain assumptions, assumptions which ate not supported by either fact or logic and that are quite unrealistic. As you well know, what you get out of a computer depends very much on what you put into the computer. They assume that the effect of the Steiger Amendment would be: one to increase by 10 percent. I believe it is, the price of all stocks — an assumption which is off the wall. And two, they assume that those increases in stock values would be realized, which means that everybody would rush out to sell to realize those gains. That also is an assumption that is not based on fact. In fact in a previous study, which the same organization made but for a different client, they had very different assumptions. So unfortunately there is no basis that we know of for concluding, and the Treasury does have different views therefore, that by a reduction of capital gains taxes to the levels of pre-1969 we would gain more than we would give up in revenue. MR. KINGON: Can you tell me why the President and the Administration seemingly abandoned the program for sweeping away what Mr. Carter called "a disgrace to the human race," the personal income tax code, and substituted for it a whole series of reforms that are growing increasingly modest as a result of Congressional intransigence? Why did that happen? Was it a result of the conflict within the Administration? MR. BLUMENTHAL: The President remains committed to substantial reform of the tax system and I certainly agree with him wholeheartedly that this kind of reform is a highly desirable thing. We began the survey of what could be done when he first came into office by looking at all elements of the tax system that theoretically could be reformed. We selected from that list and that was a very long list — Congress being an incremental place and not an institution that easily, in one bill if you will, totally scraps a tax system and substitutes another one — clearly that whole long list could not be implemented in one fell swoop. What the President selected from that, in view of the fact that he felt that a tax bill was essential (and he still feels that way in this year of 1978), was a package of reforms, involving about $9 billion of gained revenue — that and some losses of revenue — that he felt was achievable in one year. This does not mean that at some point in the future you might not come back to attempting suggestions of additional reforms. That package has not changed. The Administration continues to feel that that is a sensible package and is continuing to fight to get it implemented. What has changed is the fact that there are many members of Congress who think that even that is -4too much; that the President's efforts to make a beginning on reducing the degree of disgrace to the human race inherent in the tax system is being too ambitious. And so the discussion at the moment between ourselves and the Congress is whether all, or if not what portion, of those reforms he is recommending can be adopted. But we have not scaled back. MR. KINGON: This brings to mind a larger question. Earlier this week I came across a corporate executive who was now thoroughly confused because of the reaction to the Steiger Amendment as to whether the Administration really is for tax incentives to stimulate investment now. I want to ask you why there have been so many confusing signals in the history of this Administration sent out to business and the investment community — and I am think of the capital gains tax thing and I'm thinking of the initial tax reform program when it seemed to change before the program was promulgated. There was a great deal of confusion about the Administration's attitude toward the dollar when it was declining, and the energy program as well. It seems to many that there is a great deal more confusion than in past administrations. I wonder if you could address yourself to that. MR. BLUMENTHAL: I most certainly can. And I would have to do so by taking issue with you that the Administration has changed the signals on the basic policies in the economic field that it wishes to follow. We never suggested that there should be a reduction in the capital gains tax treatment, so there's no change in signals. At no time did we ever suggest that that should be done. We did consider whether or not it would be possible this year to make a major move toward the elimination of the double taxation of dividends and to bring the marginal tax rates down substantially below 70 percent ideally down to the same level of 50 percent — and in thinking of the capital gains tax thing and I'm thinking of the initial tax reform that context eliminate preference for capital gains. We never suggested or even internally discussed that capital gains treatment should be reduced. Those three things, if they could be done together, would do a great deal to stimulate capital formation. So that it's not fair to say that we changed signals. Mr. Steiger sent up a signal, but we didn't. That's point number one. Secondly, on the energy legislation I am not aware of the fact that the Administration ever changed its view on the need for such legislation, on the nature of that legislation — that legislation was put forward last year in April. The Administration has been fighting as hard as possible to get it accepted by the Congress in a form as close as possible to what was suggested and we've been having great difficulty. But that has not been for lack of trying. I remain confident that with three pieces approved, the fourth already virtually agreed to and the fifth in the works, we will be able to achieve it. -5You mentioned a third point — the dollar. I think the key characteristic of our exchange rate policy has been its steadfastness. We have never changed signals on it. We said all along that in a world of floating exchange rates we cannot and will not step in to support a particular rate or a particular range within which the dollar should trade in relation to certain other currencies. We have never wavered in that regard and we always explained why supporting a particular rate was not a sensible. And we continued to follow that policy. We always said that we would obviously collaborate closely with other countries and other finance ministries and central banks to seek to eliminate disorderly movements in the exchange markets. That we have done. That we have continued to do. We always said that we were interested in a strong and stable dollar; we never said anything different. The perception in a nervous market where the dollar was declining for a variety of reasons may have been different, but not because of anything that we have said. Finally, what is important and what needs to be emphasized, and I hope you will do so, is the fact that from the beginning, although people didn't believe it and I hope they believe it now, the President said that he's going to do his darndest to balance that budget by the end of the first term. From the beginning he said, and he identified it very clearly again in the January economic message, that he is going to put a tight rein on Federal spending, which he is doing. He's said as recently as April 11th that he is going to veto any spending legislation outside of what he had proposed. From the beginning he said he is going to get Federal expenditures down to the traditional level of 21 percent of GNP, that he is going to keep taxation as a percentage of personal income down to moderate levels and that he is going to rely on the private sector to provide the jobs. Those are the basic things that we have always said and that we are doing. MR. KING0N: I suppose my question is not to the substantive merits of what you're saying but about certain changes that were made. For example, I believe at one time you were quoted about the double taxation of dividends. The Administration tax plan was going to do away with them. And when the final bill came out it seemingly disappeared, and now you're promising to reconsider it again. That's what I am referring to — changes as you go along to implement these programs after announcements to the contrary. MR. BLUMENTHAL: Well, I have never been associated with an organization in which you do not study a range of problems, consider various alternatives and make your selection based along certain general policy lines you have laid out for yourself as to how to achieve it. There will always be various alternatives and the newspapers and media will always be busy ferreting out information on what is being considered. As long as the basic line doesn't change these things are there. -6Now the reason why we did not choose to go forward with the double taxation of dividends is because it was always clear that that, together with the bringing down the high marginal rates and having the same rate of taxation for capital gains treatment, was a package. It has to be a package. These can't be handled in isolation. And it became clear that that was a sufficiently complicated .thing to do in one year since there was a lot of different opposition to different pieces of it, that it would take too much time to do it. So we took a more limited thing and we followed the advice of the business community, which is to go for a deep cut across-the-board. MR. KINGON: I presume what you are saying to me is that you still have every reason to expect the budget to be balanced by the 1981 budget; that you will at some point introduce the idea of doing away with the double taxation of dividends and I gather you are heading toward wiping out the distinction between earned and unearnned income. MR. BLUMENTHAL: I think you are overstating what I was saying, so let me be very specific. The President's commitment to work to achieve budget balance by the end of his first term remains strong — as strong as it has always been. In my judgment, the opportunity to move substantially toward that goal or to achieve it in an economy of our size — whether it's $5 billion of $10 billion either way doesn't really matter, but to get close to it — I think the opportunity to do that by fiscal '81, which is the end of his first term, remains good and I am optimistic that we can get quite close to it if not achieve it. I certainly personally believe that when this tax bill is finished, when this year is finished, the job of improving the tax system is not finished. We will have to review it, this Administration and future Administrations, in order to continue to make progress on it. I cannot tell you exactly what will be proposed the next time. I personally happen to believe that the double taxation of dividends, the high marginal rates on unearned income and the question of capital gains remains an issue, and I would like to see action on it at some future date. I know that the President feels the same way. Whether that will actually happen or not I cannot tell you and I hope you won't write that we're sending mixed signals again. MR. KINGON: Your colleague Mr. Strauss is reported again in the press to have said that he will need about eight months to see if this voluntary program, jawboning if you will, will, against a wage and price increase will work. Frankly, what possible evidence does he or you or the Administration have that a six-month jawboning program will make a dent in a two-generation inflationary consciousness? -7MR. BLUMENTHAL: I don't think anyone can pretend or has suggested that in six or eight months the deeply embedded problem of inflation in the United States economy will have been licked. I haven't seen the precise quote to which you refer, but I would be very dubious that Bob Strauss really said it in quite that way. I think what is a possibility is that within a period of time, such as six or eight or ten months, one can begin to see how much progress we are making, whether we are making any progress at all and I presume that's what he was referring to. think that in the course of this year, given the fact that the president has taken some very specific steps to show that the Government is going to do its part to deal with the inflation problem and we have a large responsibility in that area, the general promises of support that we have received from the buisness community and from labor will be translated into the specific decisions that have to be made in various labor negotiations and into price decisions on the part of the business community. MR. KINGON: Let me ask a more general question. Given the anticipated budget deficit for this year, approximately $50-plus billion, and the early indications of next year and last year's, is there really any possibility of gaining control over the inflationary forces without a much sterner fiscal policy? MR. BLUMENTHAL: I believe that we need a very stern fiscal policy. The President is committed to one. The recent action to reduce the size of the tax cut and the statement that he made in that regard clearly indicates his commitment to a very tough fiscal policy. I think that tough fiscal policy will reflect itself in steadily decreasing budget deficits in '80 and '81. And I think that that will be a significant contribution to dealing with the inflation problem, but it will not be the only thing that needs to be done. And I think there's a commitment to do that. MR. KINGON: Recently, Mr. Eizenstat criticized Mr. Miller and the Federal Reserve by noting that the steps taken to allow for interest rate rises and I am quoting here "aren't the ones we asked for" and "aren't the ones we have applauded." Do you share that feeling? MR. BLUMENTHAL: I think Mr. Eizenstat probably got a bum rap here; I don't think that he meant to criticize. Taken at its r ace value I agree with the statement. We did not ask for it and w e did not applaud it. I have followed the policy of not commenting either positively or negatively on actions which the federal Reserve takes. I followed that policy when Arthur Burns *as the chairman and I intend to and have followed it with Bill Miller and intend to continue to follow it. I don't either condemn it or applaud it. Nor do I ask for either a higher of a lower Federal funds rate. -8I understand what the Federal Reserve did and I understand the reasons for it and I am hopeful that as the fiscal policy of the Administration is increasingly tight, as it is going to be, the need for an every-tighter monetary policy will' abate for those two things are part of different ways of dealing with the same problem. But I don't really think that Mr. Eizenstat was seeking to criticize the Federal Reserve. If he was, you will have to talk to him. As far as I am concerned. I don't criticize them. I don't applaud them. I don't ask for particular action. They have their responsibility; they carry it out. I have enough responsibilities here that I am struggling with. MR. KINGON: Mr. Strauss made a speech in which he was quoted in part as excoriating the country's "I'll grab mine and run" psychology. What interested me was that he praised General Motors and Chrysler for promising to hold their price boosts to less than the average of the last two years. And this raises a question in my mind. Is this going to be a standard practice of the Administration, and more to the point if, say in response to free market conditions or added costs companies raise prices more than in recent history, will they be singled out for abuse? MR. BLUMENTHAL: I would certainly hope that the Administration abuses no one. That would be inappropriate. I would hope that no senior official in the Administration will ever be abusive. I do believe that the deceleration standard, which is a voluntary standard and which clearly has to be applied on a flexible basis depending on the circumstances of each individual price and wage decision, is a reasonable standard. I believe what Bob Strauss was saying was to indicate the appreciation of the Administration for the commitment by General Motors and Chrysler to try to live with this standard. I think you can expect that any company or union that makes that commitment or that lives by that standard can certainly count on the approval and approbation of the Administration similarly. I would think that those who could do so but fail to do so probably if it's a serious case will be criticized — not abused — but they will be criticized. And I think they should be criticized, for the fight against inflation is one that we must wage together. It is just not acceptable for labor and business to say it's all the fault of the Government, just as it would be quite inappropriate for us to say it's all the fault of big business or it's all the fault of some of those large unions. We are all in it together. We all have a role to play. I think it is the responsibility of the Government to approve of those who do their part and to voice concern about those who do not. MR. KINGON: Turning to the international area, are you satisfied now that the dollar has been effectively stabilized and quite apart from the obvious fact that it is trading where it ought be fairly by the valued? very nature of the market, are you satisfied that itto is -9MR. BLUMENTHAL: I am not in a position to indicate where I think the dollar ought to be and whether it is fairly valued or not. I have learned that the Secretary of the Treasury cannot be in that position. I am satisfied that the disorder which characterized exchange markets in the early part of the year, around January, seems to have been eliminated, seems to have abated. I think we have enough resources and a good enough system of cooperation and contact with the Germans and the Japanese and others to prevent that from happening in the future. I am obviously encouraged by the fact that the dollar has strengthened in relation to certain other currencies, which seems to indicate that the market judges the situation to be more positive and our policies to be reasonable. I see nothing in the future that is likely to change that, and I am encouraged by that. But I am not in a position to indicate that this level is the right or the wrong level. MR. KINGON: Even at this date the media reported that a lot of our allies abroad seem to be unhappy and distressed over American international economic policy — so-called pressures for them to reflate — and our lack of, for want of a better term, leadership among our friends. Do you think this criticism is fair? How would you assess the relationship now between the United States and its principal allies? MR. BLUMENTHAL: I think the relationship between ourselves and our principal allies is good. I think there is a large measure of agreement on what the problems are and how we must approach them together. It has to be understood that there are many strains and stresses which work on individual Governments, and that there is to some extent a sense of concern amongst all of us that individually or collectively it is very difficult to deal with these problems in the short run. Under those circumstances it is perhaps not surprising that some individuals in some of those countries tend to, with a certain sense of frustration, look to us as the largest economic power in the world and say to us: "why don't you do something?" But basically amongst the leaders of the world and the responsible officials, my counterparts — the ministers of finance — there is a considerable amount of agreement on what the problems are and what we ought to do about them. That was again reflected in the meeting of the ministers of finance at the IMF meetings in Mexico. I think you will again see it reflected in the summit meeting that will take place at Bonn in July. It relates to the absolute necessity of bringing the trade n egotiations to a successful conclusion this year, which is certainly something in which the leadership of the United States is widely acknowledged. -10It relates to the need to maintain a strong and stable dollar and to work together to prevent disorderly condition's in the exchange markets; that certainly is something that we are all agreed on and doing quite well together. It relates to the need to work on the fundamentals, each in our own country. We agree with our allies and friends that we need to bring inflation under control. We need to get that-energy legislation passed. We need to get the budget into balance. Everybody tells us that. We agree with it. There•is no problem there. The Japanese certainly agree that they need to get their surplus in their trade and current accounts down. Mr. Fukuda was here to see the President and strongly emphasized the point that he was doing all he could. And the Germans and we and others agree that they need a proper level of growth in order to play their part in Europe and in the world to bring the rest of the world out of the recession. The fact that this year the growth rate in Europe and in Germany will be faster than it was last year, and therefore the differential in growth rates between ourselves and the European countries is narrowing, is an indication that we are, broadly speaking, moving in the same direction and that we are following roughly analagous policies. It is understandable that at various times people who are not close to this — bankers or businessmen who get nervous when the dollar goes down too far — tend to say things which get reported in the media as being indications of great concern or lack of leadership. It is easier to call for leadership than to be specific about what is meant by it. MR. KINGON: If I had the opportunity to sit with you a year from today, what would you like to see changed in the American economic equation? MR. BLUMENTHAL: I would like to see the rate of inflation below 6 percent. I would like to see some further progress in reducing unemployment in the hard-core pockets where it is still very high — amongst the blacks in the inner city, other minorities, the very young people starting out. I would like to see the energy legislation enacted and active consideration being given to the next stage of energy legislation that will promote production of additional energy in this country. I would like to see a trade negotiation successfully completed so as to hold back the pressures for protectionism, and a relatively stable international exchange market. I would hope that a year from now we could anticipate another year of record corporate profits as we have had in '77 and likely to have in '78, look forward to one O00O in '79 and look with some equanimity at 1980 being another good year . FOR RELEASE ON DELIVERY EXPECTED AT 9:00 A.M., MST THURSDAY, JUNE 8, 1978 REMARKS BY H. DAVID ROSENBLOOM INTERNATIONAL TAX COUNSEL BEFORE MULTISTATE TAX COMMISSION DENVER, COLORADO FEDERAL INITIATIVES AND STATE TAX POLICIES I appreciate this opportunity to discuss federal initiatives and state tax policies. Since I am directly concerned with one particular aspect of this subject — Article 9(4) of the proposed income tax treaty with the United Kingdom — I have taken the liberty of limiting my remarks to that highly controversial matter. I do not expect these observations to quell the controversy, but perhaps a fresh examination of the issues may dispel some misunderstandings and thereby prove useful. Description of Article 9(4) The best place to begin, I think, is with a summary of Article 9 (4) . As you know, that provision is intended to limit the application of the so-called "unitary" method of determining the income subject to a state's taxation. The limitation applies where an enterprise doing business in a state is either: (1) a resident of the United Kingdom (i.e., a branch of a U.K. company) or (2) controlled directly or indirectly B-964 -2- by a U.K. resident (i.e., a U.S. subsidiary of a U.K. company). In either case, Article 9(4) declares that, except as otherwise provided in Article 9, a state seeking to determine the income of the enterprise may not take into account any income or expenses of related companies which are residents of the United Kingdom or of a third country. Article 9(4) does not preclude application of the unitary method to a single enterprise doing business in more than one state, and to any related U.S. company. Moreover, if the enterprise doing business in the state is a U.S. corporation, Article 9(4) does not prevent application of the unitary method to any related company to the extent that its capital is owned by that U.S. corporation. Finally, it should be clear that Article 9(4) does not apply at all if the enterprise doing business in a state is ultimately controlled by a resident of any country other than the United Kingdom. There are two other interesting aspects of this provision. First, Article 9(4) uses a "doing business" standard as the threshold for state taxation. This standard is very broad — much broader than the "permanent establishment" test required for federal taxation of British business income. The permanent establishment standard is, of course, the one currently employed in tax treaties throughout the world. Second, Article 9(4) begins with the words "except as specifically provided in this Article." Article 9(4) is, therefore, subject to the other specific provisions of Article 9, including Article 9(1), which reads as follows: "Where an enterprise of a Contracting State is related to another enterprise and conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from these which would have been made between independent enterprises, then any income, deduction, receipts, or outgoings which would, but for those conditions, have been attributed to one of the enterprises but by reason of those conditions have not been so attributed, may be taken into account in computing the profits or losses of that enterprise and taxed accordingly." -3- This is, of course, a restatement of the arm's length standard that appears in slightly different terms in section 482 of the Internal Revenue Code. It seems reasonably clear that, as long as a state is seeking to reach an arm's length result, and as long as a taxpayer is permitted to submit independent proof addressed to that point, formulas designed to approximate arm's length conditions are permissible within the contemplation of the Article. Background of the Treaty Provision For several years now, a number of capital exporting countries have questioned the application of the unitary method to international businesses based in their countries. They have argued that tax treaties generally provide that one Contracting State may not tax the business profits of an enterprise of the other Contracting State unless the income is attributable to a permanent establishment in the first Contracting State. They perceive the unitary system applied in the international context as reaching profits which not only may not be attributable to a permanent establishment located in the taxing state but which may have nothing whatever to do with the taxing state. Although existing U.S. treaties apply generally only with respect to the Federal income tax, foreign countries have suggested that some state practices violate the spirit of our agreements. In addition, foreign governments have noted the administrative burdens which compliance with unitary systems can impose in the international context. They have pointed out that the records of their worldwide business groups may not be maintained in dollars, or kept in English, that they may have only bare voting control of some subsidiaries, and that they may not have the personnel to keep pace with state requirements. As a result of such complaints, the Treasury sought for several years to achieve an informal resolution of the matter on a basis that would be satisfactory both to other countries and to states. We were not successful, however, and consideration was then given to a treaty resolution. The British made a strong case for Article 9(4), and they made major concessions in the proposed treaty concerning the treatment of dividends and recognition of the U.S. rules for allocating deductions. It was thus considered reasonable to include a limited provision dealing with the unitary method in the proposed treaty with the United Kingdom. -4- The Debate As a consequence, the past two years have witnessed an unparalleled debate over the proposed treaty — and specifically over Article 9(4). In my view this is a good and a healthy thing. This treaty, and specifically Article 9(4), raises major questions of tax policy and federal-state relations, and a rational discussion of these questions can only be beneficial. The issues raised by Article 9(4) can be stated in the form of two broad questions. First, whether as a matter of principle any federal involvement in state taxation practices is warranted. And second, assuming that some federal involvement is warranted, whether the specific provisions of Article 9(4) are reasonable and appropriate. On the first of these questions, the principle of federal involvement, I do not believe there is much room for doubt. State tax practices are not wholly immune from federal involvement. The principle of such involvement derives from a sound constitutional base and was clearly articulated in 1959 when Congress passed Public Law 86-272 (15 U.S.C. 381), establishing minimum jurisdictional standards for state taxation of multistate business. The principle of federal involvement with state tax practices through exercise of the treaty power was established even earlier—when the present treaty with the United Kingdom was ratified by the Senate in 1946. That treaty and many others since have prohibited states and municipalities from using 9J their tax systems to discriminate against nationals or residents of the treaty partner. Article 9(4) does not establish the precedent for federal involvement in state tax practices — that precedent exists already. What, then, concerns states so much in Article 9(4)? Perhaps it is the fear that Article 9(4) signals an era of ever more expansive federal involvement in their affairs. Although I cannot speak for Congress on this point, I assure you that the Treasury views Article 9(4) as a narrow response to a particular problem of international tax relations, and not as the opening shot in an ever widening campaign to restrict state tax policies. As Secretary Blumenthal has written to every state governor, "the Treasury has no intention of amplifying the provisions of Article 9(4) in treaties. We intend no broader limitation on state taxing -5- powcrs. Specifically, we have no intention of supporting limitations on the unitary method with respect to U.S. controlled multinational groups or with respect to income from purely domestic commerce." The Treasury stands by that commitment. We do intend, in appropriate cases, to negotiate other treaties with a provision similar to Article 9(4). In no event, however, will the provision be any broader than Article 9(4) itself. Moreover, I assure you that there will be ample public notice of all future treaty negotiations and I invite you now and in the future to work with us to refine and perfect the approach to be taken in any future treaty provision dealing with the unitary tax issue. I do not believe that we at the Treasury and you in state tax administration should be eternally at odds on this subject. Article 9(4) is- not symbolic of anything more profound than what it purports to be: a narrow and reasonable response to a real problem. It is true that the problem involves state tax practices, but it also involves international relations — an area where, I believe, the legitimacy of federal action cannot be questioned. So I say tc you: let us work together on this matter. If Article 9(4) can be improved, we are certainly open to your suggestions. I have indicated several times that I think Article 9(4) is both reasonable and appropriate. Let me now explain why I have come to that conclusion. I realize that some of these considerations have been articulated in the past, but it may nevertheless be helpful to consider them again in the present context. First, the arm's length standard, not the unitary method, is the internationally accepted method of dealing with the misallocation of income among related companies. This standard is reflected in the OECD Model treaty as well as in all of the income tax treaties to which the United States is a party. In fact, in the OECD Model treaty the rule is intended to apply to subsidiary levels of government, although U.S. treaties have not previously adopted the rule at the state and local level. Since most countries in the world use an arm's length standard to determine the income of an entity in a corporate group, they find it confusing when our states insist on a different standard. Furthermore, the use of a different method by one jurisdiction raises a real possibility of international double taxation. Other countries ask this -6- question, which I as a treaty negotiator find difficult to answer: If the United States as a nation finds it possible to accept the internation^l standard, why is it so unreasonable to ask the fifty states to tailor their internationally sensitive tax practices accordingly? Second, the particular complaints which foreign countries have raised—and which I have previously summarized—in regard to the international implications of the unitary method seem, at least in some cases, to be justified. The unitary method does assume that profit rates in different units of a corporate family will be more or less the same. This assumption is convenient, but it is also arbitrary and in the international area it does not seem justified. Application of the unitary method to multinational corporate groups does entail burdensome record-keeping and reporting requirements. Particularly when there is no transactional nexus between related corporate entities, the burden appears unnecessary. Since the complaining party*with respect to these problems is a foreign country concerned about the treatment^ of its residents in the United States, a treaty solution isT appropriate. Moreover, dealing with such a problem in the treaty context has definite advantages. It permits the United States to obtain concessions in return for concessions that it makes, and it permits the achievement of reciprocal. protection for*our citizens and residents. Furthermore, a treaty solution demonstrates to the world what the United States thinks appropriate in the area of international taxation — a particularly important point when we consider^ the arbitrary tax formulas that some countries have sought to apply to U.S. citizens and residents. 6 In addition to the seeming reasonableness of the British position in regard to the unitary method, and the appropriateness of a treaty provision to deal with this issue, it is worth emphasizing that the proposed treaty with the United Kingdom is, on the whole, highly advantageous to the United States—and by the "United States" I mean U.S. investors, the Treasury, and the states. One of its most important provisions obligates the United Kingdom to make substantial refunds of taxes to American investors in United Kingdom corporations. A transfer of these substantial sums—hundreds of millions of dollars—has the effect of lowering effective corporate rates in the United Kingdom and thereby generating far fewer excess foreign tax credits than -7- would otherwise be the case. Moreover, as Secretary Blumenthal has pointed out, large transfers from a foreign Treasury to the United States economy should help both our balance of payments and the value of the dollar in foreign currency markets. From the standpoint of international tax relations, the proposed treaty is equally significant. It is the first treaty ever to reconcile successfully a classical system of corporate taxation such as ours with the type of integrated system currently in place in many developed countries. Without such a reconciliation, United States investors encounter discriminatory taxation in countries having such integrated systems. We are hopeful that this aspect of the proposed treaty will serve as a model in our current treaty negotiations with France, Germany, Canada, and other countries that have integrated systems similar to that of the United Kingdom. Despite the limited scope of Article 9(4), despite the fact that it is addressed to a real problem, and in spite of the benefits of the treaty as a whole, many objections continue to be raised. Let us examine them. Most commonly heard is the point that states restricted by Article 9(4) will be unable to prevent tax avoidance by artificial pricing. It must be remembered, however, that Article 9(4) restricts the use of the unitary method only in limited situations. And in those instances where the limitation applies, the proposed treaty makes it clear that states may use the arm's length method for taxing foreign enterprises doing business within their borders. Not only is the arm's length method the one universally accepted in the international community and the one used by the federal government; I am under the impression that it is also the one used, with respect to international business income, by most of the states. Treasury recognizes that the administrative resources available to state governments may not permit them to make the same kind of intensive transfer price investigations that Federal tax authorities are able to undertake. For this reason we have repeatedly assured states that they will have access to data derived from federal tax audits. Furthermore, it seems reasonable to read the treaty in such a fashion that the United States competent authority can obtain information from the United Kingdom in order to ensure that Article 9(4) will not be abused. Thus, I do not believe the limitation in Article 9(4) materially impairs a state's tax audit ability. -8- It has also been argued that Article 9(4) will lead to a substantial loss of state tax revenues. This contention calls for some careful analysis. The information available to us indicates that the effect of the provision on state revenues has been overestimated. Some California authorities, for example, have estimated the effect in California to be $15-$20 million per year. Since the California corporate tax rate is 9 percent, and since Article 9 permits the states to tax the income taxed by the federal government, an estimate of a yearly $15-$20 million revenue loss implies that between $166 million and $222 million of income from United Kingdom investment in California is escaping all taxation in the United States every year. That does not seem correct. It may be added, parenthetically, that Article 9(4) does not have any negative revenue impact on most states because the great majority of states do not use the unitary method in a way that Article 9(4) limits. Finally, it has recently been alleged that Article 9(4) will stimulate foreign investment in U.S. farmland. We at Treasury do not understand this concern. The proposed treaty does not in any way create a tax preference for foreign ownership of U.S. farmland. The proposed treaty contains no provisions specifically addressed to the taxation of farmland. The treaty does provide in Article 6 that U.S. real property income is taxable in the United States under normal Federal tax rules. This would include income derived from farmland. Thus, the treaty most certainly would not prevent the states from taxing farm income. Nor can it plausibly be contended that Article 9(4) would erect a substantial impediment to such taxation. The wide market for agricultural products and the ready availability of arm's length prices for agricultural commodities preclude the artificial shifting of farm profits. In fact, farm income is surely one of the types for which application of the arm's length standard is easiest. In closing, let me express a personal view. I think a reservation on Article 9(4) would raise the substantial possibility of a large loss of benefits to the United States. A reservation would invite the British to review the new balance of concessions. I do not believe they will be eager to endorse, without change, a treaty in which Article 9(4) is missing. -9- This treaty is good and necessary for the United States. It has flaws — what complex document does not — but it represents an international agreement that our country should be happy to accept. Given the Treasury's assurance that Article 9(4) does not portend any greater federal initiative in state tax policies, given our willingness to assist you in seeing that Article 9(4) does not lead to abuses, given the commitment of our British colleagues that after ratification the treaty will be subject to continuing review, analysis, and—if necessary—correction, I submit that the proposed treaty is worthy of support as it stands. * * * FOR IMMEDIATE RELEASE June 7, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY DEPARTMENT STATEMENT Comment on the proposed firearms regulations ends on June 30. The Treasury intends to review all the materials received in order to determine whether or what revisions to these proposals are appropriate. The Treasury Department will continue to consult fully with Congress as it does so. If it is decided by the Treasury to promulgate these regulations or revised regulations, the Treasury would then request the necessary funds from Congress. The vote today on the rider to the Treasury's appropriations bill does not change this schedule. The rider, which prohibits the use of funds by the Treasury to implement the proposed regulations, was opposed by the Treasury. * * * Attached is a June 2 letter from Treasury Deputy Secretary Carswell to Representative Tom Steed, Chairman of the Treasury, Postal Service and General Government Subcommittee of the House Appropriations Committee. B-965 THE DEPUTY SECRETARY OF THE TREASURY WASHINGTON, D.C. 20220 JUN 21978 Pear Mr. Chairman: Last week the Senate Subcommittee on Appropriations decided to approve the budget of the Bureau of Alcohol, Tobacco and Firearms, substantially at the level requested by the President. Prior to the Senate Subcommittee's decision and in response to their request, we provided written assurances concerning the Treasury Department's plans regarding certain proposed firearms regulations. These assurances were consistent with those given in testimony by Assistant Secretary Richard J. Davis to the House Judiciary Committee. Specifically the proposed Fiscal Year 1979 budget contains no funds to implement certain proposed firearms regulations. Therefore, if a decision is made to implement any of these regulations, it would be necessary for the Department to seek either a supplemental appropriation for 1979 or include a request for such funds in our 1980 submission. In either event we cannot implement these proposals without receiving from Congress the funds to do so. I make these same assurances to you and to the committee. I would hope that in the coming weeks you and other members of the House Appropriations Committee would decide to restore the $4.2 million. Otherwise, there will have to be a serious curtailment of ATF's activities, both regulatory and enforcement. If there are any questions, please feel free to contact me. Sincerely, Robert Carswell The Honorable Tom Steed, Chairman Subcommittee on Treasury, Postal Service, and General Government Committee on Appropriations House of Representatives Washington D.C. 20515 FOR IMMEDIATE RELEASE June 9, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY DEPARTMENT EXTENDS PERIOD OF INVESTIGATION OF STEEL WIRE ROPE FROM KOREA The Treasury Department today said it will extend its antidumping investigation of steel wire rope from the Republic of Korea for an additional period not to exceed 60 days. Treasury said it needed more time to analyze and verify the data provided to determine whether the product is being sold in the United States at less than fair value. As defined by the Antidumping Act, "sales at less than fair value" generally occur when imported merchandise is sold here for less than in the home market or to third countries. If Treasury determines "sales at less than fair value" occur, the case is referred to the U. S. International Trade Commission to determine whether they are hurting a U. S- industry. An affirmative ITC decision would require dumping duties. Notice of this action appeared in the Federal Register of June 8, 1978. Imports of steel wire rope from the Republic of Korea were valued at approximately $13 million during calendar year 1976. o B-966 0 o FOR IMMEDIATE RELEASE June 9, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY SAYS PRELIMINARY INVESTIGATION INDICATES CANADA IS SUBSIDIZING OPTIC-LIQUID LEVEL-SENSING SYSTEMS The Treasury Department today announced its preliminary determination that the Government of Canada is subsidizing exports to the United States of optic-liquid level-sensing systems manufactured by Honeywell Ltd. This product is designed to prevent the overfilling of oil storage tanks and oil delivery trucks. The action results from a petition filed by Scully Electronics System, Inc., in November 1977. Under the law, Treasury must make a final decision by November 14, 197 8. The Countervailing Duty Law requires the Treasury to assess an additional Customs duty equal to the amount of a "bounty or grant" (subsidy) paid on imported merchandise. Treasury's preliminary investigation revealed that payments were made by the Canadian Government to partially defray costs incurred by Honeywell Ltd. in the commercial introduction of this product and that at this stage these payments appear to be subject to countervailing duties. Notice of this action will appear in the Federal Register of June 12, 1978. No public statistics regarding the value of imports of optic-liquid level-sensing systems manufactured by Honeywell Ltd. are available. o B-967 0 o FOR IMMEDIATE RELEASE June 9, 1978 Contact: James Parker 202/376-0872 ONE-CENT MELTING BAN REVOKED The Treasury Department announced today that the regulations prohibiting the exportation, melting or treating of one-cent pieces have been revoked. The ban on the exportation, melting or treating of one-cent coins was imposed by the Secretary of the Treasury in April 1974. The restrictions were placed into effect primarily because high copper prices at the time made it potentially profitable to melt one-cent coins for their metal content or to export them. Violations of the regulations carried a statutory penalty of up to $10,000 and/or 5 years imprisonment. Because of changed economic conditions, including stabilized copper prices and the large inventory of one-cent coins maintained by the Government, the Department has determined that the prohibitions are no longer necessary. The revocation became effective on June 7, 1978. o B-968 0 o FOR IMMEDIATE RELEASE June 9, 1978 Press Contact: Robert E. Nipp 202/566-5328 Non-Press Contact: 202/566-8235 566-8651 566-5286 STEEL TRIGGER PRICE HEARING ON GREAT LAKES DIVERSION CLAIMS The Treasury Department today announced the schedule for the hearing Monday, June 12 on steel mill imports in the Great Lakes region. The hearing will consider allegations that a secondary effect of the trigger price mechanism has been to divert steel imports from Great Lakes to East, West, and Gulf coast ports. Testimony will also be heard on a Treasury proposal to adjust the Gre?t Lakes freight rates used to calculate trigger prices for steel pl~ce and cold and hot rolled sheets. In addition, other proposals will be considered to correct the claimed diversionary effect. The hearing begins at 9:30 a.m. in Room 4121, Main Treasury Building. General Counsel Robert Mundheim and Deputy Assistant Secretary for Tariff Affairs Peter Ehrenhaft will preside. The hearing is open to the public. The tentative schedule of testimony is: 9:30 Welcome and Introduction Mr. Mundheim and Mr. Ehrenhaft 9:45 First Panel: (Each panelist to make 10 minute presentation and be available for questioning by hearing officers.) 1. Robert J. Lewis, Assistant Admix. dtor for Development, St. Lawrence Seavay Development Corp. 2. Robert D. McBride, President, National Steel Corp. B-969 -23. Leonard S. Baness, President, Wire Sales Co. 4. Raymond N. Carlen, Vice Chairman, Inland Steel 5. A. R. Hudson, Great Lakes Task Force 11:00 Second Panel 1. R. G. Criss and J. D. Heckerman, Republic Steel 2. Larry Williams, Director of Kurt Orban Co., American Institute for Imported Steel 3. W. V. Murphy, Vice President, McLouth Steel Corp. 4. Jim Fish, Great Lakes Commission 5. Thomas A. Cleary, Executive Vice President, Youngstown Sheet and Tube 6. Mike Moran, Director, Chicago Maritime Council Other testimony will be scheduled as time permits. Transcript of the hearing may be ordered from the MillerColumbian Reporting Service at (202)347-0224. All written submissions will be kept in a public reading file in the Treasury Department Library, Room 5030. The period for written comments has been extended to Monday, June 19. oOo CO 0) if) 3 CM E ID eral hnancmg DanK WASHINGTON, D.C. 20220 LT) co CM <D O FOR IMMEDIATE RELEASE June 9, 1978 SUMMARY OF FEDERAL FINANCING BANK ACTIVITY May 1-May 31, 1978 Federal Financing Bank activity for the month of May, 1978, was announced as follows by Roland H. Cook, Secretary: On May 1, the Federal Financing Bank (FFB) purchased Note #15 from the National Railroad Passenger Corporation (Amtrak) in the amount of $100 million. The note matures on October 1, 1978, and is guaranteed by the Department of Transportation (DOT). Amtrak made drawdowns against the note in the following amounts: Interest Date Amount Rate $69,684,000 7.145% 5/1 5,000,000 7.195% 5/4 3,000,000 7.275% 5/9 2,500,000 7.285% 5/12 7.275% 5,000,000 5/15 7.245% 4,500,000 5/17 7.255% 2,000,000 5/26 On May 1, the FFB advanced $121,196 to the Trustee of Chicago, Rock Island and Pacific Railroad at a rate of 8.475%. The Trusteefs certificate under which the advance was made is guaranteed by DOT and will mature on June 21, 1991. On May 1, the FFB advanced $1,900,216 to the Chicago and North Western Transportation Company at a rate of 8.523% on an annual basis. The note under which the advance was made matures on March 1, 1989 and is guaranteed by DOT. The U.S. Railway Association made the following drawdowns under notes guaranteed by DOT: Interest Maturity Note Amount Date NFn-i-o # # AmrmntMaturity Rate 5/5 5/9 5/31 B-970 8 13 8 $3,142,000 250,000 326,500 4/30/79 12/26/90 4/30/79 7.803% 8.125% 7.648% - 2On May 3, the FFB completed its original commitment to DOT to lend up to $12 million to the Missouri-Kansas-Texas Railroad (MKT) by advancing $45,515 to that railroad at an interest rate of 8.418%. On May 26, DOT and FFB agreed to increase the amount of the MKT loan by $4.5 million. The initial $12 million is payable in quarterly installments to 1997, and the additional $4.5 million will be repaid in 1997. This new loan is guaranteed by DOT pursuant to Section 511 of the Railroad Revitalization and Regulatory Reform Act of 1976. The FFB purchased the following notes from the Student Loan Marketing Association. The notes are guaranteed by the Department of Health, Education and Welfare. Interest Date Note Amount Maturity Rate $60,000,000 142 # 8/1/78 5/2 6.784% 8/8/78 6.788% 5/9 143 60,000,000 5/16 144 70,000,000 8/15/78 6.635% 5/23 145 60,000,000 8/22/78 6.800% 5/31 146 40,000,000 8/29/78 6.991% The above borrowings represent $210 million in rollovers of maturing SLMA notes and $80 million in new cash. On May 15, SLMA and FFB completed arrangements, subject to the guarantee of HEW, for SLMA to borrow up to $1 billion outstanding under a variable rate master note maturing on March 15, 1993. The interest rate on the note will vary each week based on the average of the most recent 91-day Treasury bill auction. The FFB advanced the following amounts to the Western Union Space Communications against a $687 million master note maturing on October 1, 1989. The repayment of the note is secured by the National Aeronautics and Space Administration's obligations to Western Union under a tracking and procurement contract. Interest Date Amount Rate 5/1 $23,350,000 8.526% 5/22 1,135,000 8.666% Interest payments on the above advances are made on an annual basis. The FFB pruchased participation certificates from the General Services Administration in the following amounts: Interest Date Series Amount Maturity Rate _ 5/1 5/9 5/10 5/15 5/31 K M L L K $2,745,559.47 6,484,716.10 189,688.00 3,239,360.11 1,836,266.19 7/15/04 7/31/03 11/15/04 11/15/04 7/15/04 8.556 8.617< 8.610* 8.596< 8.682< - 3The Federal Financing Bank advanced the following amounts to rural utility companies under notes guaranteed by the Rural Electrification Administration: Interest Date Borrower Amount Maturity Rate 9,200,000 457,000 4,266,000 500,000 12/31/12 12/31/12 12/31/12 5/1/80 8.464% 8.464% 8.464% 8.005% 25,192,000 6/30/80 8.025% Wolverine Elect. Coop. 601,000 5/14/80 8.005% 5/8 Gulf Telephone Co. 164,000 12/31/12 8.527% 5/9 5/9 5/9 North Florida Telephone Co. Basin Elect. Pwr. Coop. Wabash Valley Power Assn. 2,315,000 71,452,000 1,798,000 12/31/12 5/9/80 12/31/12 8.528% 8.074% 8.528% 5/10 Allegheny Elect. Coop. 1,662,000 12/31/12 8.527% 5/12 5/12 Arizona Elect. Pwr. Coop. Colorado-Ute Elect. Assn. 1,451,000 6,457,000 12/31/12 12/31/12 8.505% 8.505% 5/15 5/15 Arizona Elect. Pwr. Coop. Western Farmers Elect. Coop. 3,380,000 1,500,000 12/31/12 5/15/80 8.523% 8.093% 5/19 5/19 Tri-State Gen. § Trans. Assn. Big River Elect. Corp. 200,000 4,232,000 6/30/80 12/31/12 8.132% 8.526% 5/23 South Mississippi Elect. 1,152,000 5/26/80 8.162% 5/25 East Kentucky Power Coop. 5,897,000 12/31/12 8.541% 5/26 Southern Illinois Power Coop. 1,400,000 5/26/80 8.191% 5/31 5/31 5/31 5/31 Arkansas Elect. Coop. Tri-State Gen. § Trans. Assn. Basin Elect. Power Coop. Central Iowa Power Coop. 5,026,000 9,075,000 17,106,000 776,000 12/31/12 7/31/80 5/31/80 12/31/12 8.581% 8.201% 8.191% 8.581% 5/1 5/1 5/1 5/1 United Power Assn. Allied Tele. Co. of Arkansas Oglethorpe Elect. Membership Eastern Iowa Light § Power 5/4 Tri-State Gen. § Trans. Assn. 5/5 Interest payments on the ab ove advances are made on a quarterly basis. The FFB purchased the following Certificates of Beneficial Ownership (CBO's) from the Farmers Home Administration: Interest Date Amount Maturity Rate 5/9 $795,000,000 5/9/83 8.52% 5/26 175,000,000 5/26/83 8.61% Interest on th.p ntiove CB0Ts is paid on an annual basis. - 4 - The Tennessee Valley Authority sold notes to the FFB in the following amounts: Interest Date Note # Amount Maturity Rate 5/15 5/31 75 76 $ 45,000,000 460,000,000 8/31/78 8/31/78 6.9621 6.994% On May 24, the FFB purchased debentures from small business investment companies in the aggregate amount of $8,050,000, bearing interest at a rate of 8.5451 and a maturity of May 1, 1988. The FFB made the following advances under loans guaranteed by the Department of Defense: Date of Promissory Date of Interest Borrower Amount Maturity Note Advance Rate Argentina 6/30/76 6/30/76 5/16 5/22 China 6/30/77 Columbia 1,741.93 9,705,982.16 6/30/83 6/30/83 8.2351 8.296% 5/11 582,000.00 7/1/85 8.3001 6/10/76 5/11 575,867.19 6/30/83 8.2271 Costa Rica 9/30/77 5/2 492,110.00 4/10/83 8.1631 Ecuador 7/28/76 9/15/77 5/2 5/5 943,385.00 498,755.00 6/30/83 8/25/84 8.1631 8.1831 Greece 5/23/78 5/31 5,272,549.55 5/3/88 8.4901 Honduras Israel 9/30/77 9/30/77 9/30/77 7/1/76 9/30/77 2/15/78 5/11 5/22 5/3 5/16 5/31 5/23 80,567.00 7,750.00 100,322.00 645,398.33 1,603,782.02 25,170,417.92 10/7/82 10/7/82 9/20/86 6/30/83 9/20/86 1/12/08 8.194% 8.237% 8.280% 8.235% 8.452% 8.624% Jordan 5/26/76 5/25 98,652.47 11/26/85 8.402% Malaysia 9/30/77 9/30/77 5/19 5/31 260,099.00 3,367,000.00 3/20/84 3/20/84 8.296% 8.362% Morocco 9/28/77 5/5 222,535.23 9/10/85 8.210% Thailand 9/29/76 5/5 13,354.67 6/30/83 8.14% Tunisia 9/29/76 9/29/77 5/11 5/11 3,355.69 1,239.63 10/1/84 10/1/85 8.277% 8.254% Indonesia $ Federal Financing Bank holdings on May 31, 1978 totalled $43.9 billion. # 0 # ¥rimentoftheTREA$URY IfflpWo!) TELEPHONE 566-2041 GT0N.D.C.2022Q I FOR IMMEDIATE RELEASE June 12, 1978 RESULTS OF TREASURY'S WEEKLY BILL AUCTIONS Tenders for $2,304 million of 13-week Treasury bills and for $3,407 million of 26-week Treasury bills, both series to be issued on June 15, 1978, were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: 13-week bills matur:Lng September 14, 1978 P rice High Low Average Discount Rate 98 .330 98 .326 98 .327 6.607% 6.622% 6.618% 4 26-week bills :. maturine December 14, 1978 Investment Rate 1/ 6.81% 6.83% 6.82% Discount Rate Pr: Lee . 96.403 : 96.399 : 96.400 7.115% 7.123% 7.121% Investment Rate 1/ 7.48% 7.49% 7.49% Tenders at the low price for the 13-week bills were allotted 19%. Tenders at the low price for the 26-week bills were allotted TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTS AND TREASURY: Location Received Boston $ 29,040,000 New York 3,849,420,000 Philadelphia 18,705,000 Cleveland 53,345,000 Richmond 25,600,000 Atlanta 27,805,000 Chicago 368,645,000 St. Louis 48,765,000 30,505,000 Minneapolis Kansas City 33,630,000 Dallas 12,770,000 San Francisco 226,410,000 Treasury TOTALS 7,965,000 $4,732,605,000 Accepted $ ; Received 9,155,000 18,960,000 : $ 2,022,650,000 • 5,076,590,000 7,390,000 18,690,000 55,955,000 28,435,000 , 23,670,000 17,490,000 20,125,000 27,685,000 599,770,000 44,545,000 45,400,000 21,765,000 26,895,000 11,645,000 17,055,000 31,305,000 10,395,000 12,770,000 : 616,440,000 40,110,000 7,965,000 $2,304,015,000a/ 5,760,000 $6,514,600,000 -Includes $348,520,000 noncompetitive tenders from the public. -• ncludes $199,670,000 noncompetitive tenders from the public. -Equivalent coupon-issue yield. B-971 Accented $ 9,155,000 2,743,390,000 7,390,000 15,960,000 9,670,000 19,565,000 123,070,000 11,400,000 14,695,000 16,685,000 9,895,000 420,115,000 5,760,000 J $3,406,750,000b! Contact: Alvin Hattal 566-8381 June 12, 1978 FOR IMMEDIATE RELEASE TREASURY DEPARTMENT ANNOUNCES START OF ANTIDUMPING INVESTIGATION OF METHYL ALCOHOL FROM CANADA The Treasury Department said today that it will begin an antidumping investigation of methyl alcohol (methanol) from Canada. Treasury's announcement followed a summary investigation conducted by the U.S. Customs Service after receipt of a petition filed by the E.I. du Pont de Nemours & Company, alleging that this product is being dumped in the United States. The petition alleges that methyl alcohol is being exported from Canada at prices below those in the home market and cites Alberta Gas Chemicals, Ltd., Medicine Hat, Alberta, as the principal Canadian supplier. This case is simultaneously being referred to the U.S. International Trade Commission (ITC). Should the ITC find (within 30 days) that there is no reasonable indication of injury or likelihood of injury to a domestic industry, the investigation will be terminated. Otherwise, the Treasury will continue B-972 -2its investigation into the question of sales at less than fair value (Dumping occurs when there are both sales at less than fair value and injury to a U.S. industry). Notice of this action will be published in the Federal Register of June 14, 1978. Imports of methyl alcohol from Canada were valued at approximately $14 million during calendar year 1977. * * * p imntoftheTREASURY |HINGT0N,D.C.2O22O TELEPHONE 566-20*1 FOR IMMEDIATE RELEASE June 13, 1978 Contact: George G. Ross 202/566-2356 TREASURY ANNOUNCES PUBLIC MEETING TO DISCUSS USA-ITALY TAX TREATY ISSUES, ON JULY 21, 1978 The Treasury Department today announced that it will hold a public meeting on July 21, 1978, to solicit the views of interested persons regarding issues being considered during negotiations to develop a new income tax treaty between the United States and Italy. The public meeting will be held at the Treasury Department, at 2:00 p.m., in room 4121. Persons interested in attending are requested to give notice in writing, by July 17, 1978, of their intention to attend. Notices should be addressed to H. David Rosenbloom, International Tax Counsel, Department of the Treasury, Washington, D. C. 20220. Today's announcement of the July public meeting follows the recent conclusion of a further round of negotiations between representatives of the United States and Italy to develop a new income tax treaty for the avoidance of double taxation and the prevention of tax evasion. The income tax treaty presently in effect dates from 1955. In the course of the recent negotiations, many subjects of mutual concern were identified and discussed. Among the major issues being considered are: taxation of charitable and educational organizations; taxation of social security payments; taxation of corporations organized in one country but managed or controlled in the other country; taxation of partnerships; taxation of dividends, interest, and royalties; taxation of rentals of tangible personal property; the rules relating to permanent establishments; the taxes to be covered; and the taxation of directors' fees. The Treasury seeks the views of interested persons in regard to these issues, as well as other matters that may have relevance in the context of an income tax treaty between the United States and Italy. The July 21 public meeting is being held to provide an opportunity for an exchange of views, as well as for the purpose of discussing the United States position in regard to the issues presented in the negotiations. o 0 o B-973 FOR RELEASE AT 4:00 P.M. June 13, 1978 TREASURY'S WEEKLY BILL OFFERING The Department of the Treasury, by this public notice, invites tenders for two series of Treasury bills totaling approximately $5,600 million, to be issued June 22, 1978. This offering will result in a pay-down for the Treasury of about $6,010 million as the maturing bills are outstanding in the amount of $11,610 million ($6,005 million of which represents 20-day bills issued June 2, 1978). The two series offered are as follows: 91-day bills (to maturity date) for approximately $2,200 million, representing an additional amount of bills dated March 23, 1978, and to mature September 21, 1978 (CUSIP No. 912793 T4 8 ) , originally issued in the amount of $3,402 million, the additional and original bills to be freely interchangeable. 182-day bills for approximately $3,400 million to be dated June 22, 1978, and to mature December 21, 1978 (CUSIP No. 912793 U9 5). Both series of bills will be issued for cash and in exchange for Treasury bills maturing June 22, 1978. Federal Reserve Banks, for themselves and as agents of foreign and international monetary authorities, presently hold $3,597 million of the maturing bills. These accounts may exchange bills they hold for the bills now being offered at the weighted average prices of accepted competitive tenders. The bills will be issued on a discount basis under competitive and noncompetitive bidding, and at maturity their par amount will be payable without interest. Except for definitive bills in the $100,000 denomination, which will be available only to investors who are able to show that they are required by law or regulation to hold securities in physical form, both series of bills will be issued entirely in book-entry form in a minimum amount of $10,000 and in any higher $5,000 multiple, on the records either of the Federal Reserve Banks and Branches, or of the Department of the Treasury. Tenders will be received at Federal Reserve Banks and Branches and at the Bureau of the Public Debt, Washington, D « C 20226, up to 1:30 p.m., Eastern Daylight Saving time, Monday, June 19, 1978. Form PD 4632-2 (for 26-week series) or Form PD 4632-3 (for 13-week series) should be used to submit tenders for bills to be maintained on the book-entry records of the Department of the Treasury. B-974 -2Each tender must be for a minimum of $10,000. Tenders over $10,000 must be in multiples of $5,000. In the case of competitive tenders the price offered must be expressed on the basis of 100, with not more than three decimals, e.g., 99.925. Fractions may not be used. Banking institutions and dealers who make primary markets in Government securities and report daily to the Federal Reserve Bank of New York their positions in and borrowings on such securities may submit tenders for account of customers, if the names of the customers and the amount for each customer are furnished. Others are only permitted to submit tenders for their own account. Payment for the full par amount of the bills applied for must accompany all tenders submitted for bills to be maintained on the book-entry records of the Department of the Treasury. A cash adjustment will be made on all accepted tenders for the difference between the par payment submitted and the actual issue price as determined in the auction. No deposit need accompany tenders from incorporated banks and trust companies and from responsible and recognized dealers in investment securities for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, or for bills issued in bearer form, where authorized. A deposit of 2 percent of the par amount of the bills applied for must accompany tenders for such bills from others, unless an express guaranty of payment by an incorporated bank or trust company accompanies the tenders. Public announcement will be made by the Department of the Treasury of the amount and price range of accepted bids. Competitive bidders will be advised of the acceptance or rejection of their tenders. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and the Secretary's action shall be final. Subject to these reservations, noncompetitive tenders for each issue for $500,000 or less without stated price from any one bidder will be accepted in full at the weighted average price (in three decimals) of accepted competitive bids for the respective issues. Settlement for accepted tenders for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, and bills issued in bearer form must be made or completed at the Federal Reserve Bank or Branch or at the Bureau of the Public Debt on June 22, 1978, in cash or other immediately available funds or in Treasury bills maturing differences accepted June 22, in 1978. exchange between the Cash andpar the adjustments value issueof price the will maturing ofbe the made new bills for bills. -3Under Sections 454(b) and 1221(5) of the Internal Revenue Code of 1954 the amount of discount at which these bills are sold is considered to accrue when the bills are sold, redeemed or otherwise disposed of, and the bills are excluded from consideration as capital assets. Accordingly, the owner of these bills (other than life insurance companies) must include in his or her Federal income tax return, as ordinary gain or loss, the difference between the price paid for the bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made. Department of the Treasury Circulars, No. 418 (current revision), Public Debt Series - Nos. 26-76 and 27-76, and this notice, prescribe the terms of these Treasury bills and govern the conditions of their issue. Copies of the circulars and tender forms may be obtained from any Federal Reserve Bank or Branch, or from the Bureau of the Public Debt. ^m ptmentoftheTREASURY H5HINGT0N, D.C. 20220 TELEPHONE 566-2041 FOR IMMEDIATE RELEASE June 13, 1978 Contact: Mr. Robert Nipp 202/566-5328 TREASURY WAIVES DUTIES ON FISH SUBSIDIES BEING PAID BY THE CANADIAN GOVERNMENT The Treasury Department today announced a final determination that the Canadian Government has been subsidizing exports of fish to the United States, but waived the imposition of countervailing duties because of Canadian action to "substantially reduce" and by October 1 "almost entirely eliminate" the subsidies. The waiver applies to dutiable fish which would have been subject immediately to countervailing duties. Duties would be imposed on duty-free fish only if the U.S. International Trade Ccranission, to which the matter has been referred, finds injury or the threat of injury to a domestic industry. Hcwever, if that finding were made, the waiver would be extended to duty-free fish as well. The Treasury Department found subsidies by the Government of Canada and provincial governments consisting of cash payments to Canadian fishermen and fish processors on their fish catches, cash payments to fishermen for financing the construction of fishing vessels, grants for various facilities required in the fishing industry and loans for vessel construction and processing facilities. The amount of the subsidy on dutiable fish was estimated at 5 percent of the fob price for export to the United States. However, the Treasury Department also found that the Canadian government had reduced its subsidies by 68 percent as of March 31, 1978 and would achieve a 92 percent reduction by October 1, 1978. In addition, the Treasury Department found that imposition of duties would seriously jeopardize the achievement of trade agreements that would reduce or eliminate trade barriers and distortions. The Countervailing Duty Act requires the imposition of a duty equal to any bounty or grant (subsidy) paid on exports to the United States. The Statue also authorizes the Secretary of the Treasury to waive the duty if he determines that adequate steps B - 975 - 2 - have been taken to reduce substantially or eliminate the adverse effect of the subsidy and that imposition of the duty would jeopardize reasonable prospects for successful trade agreements to reduce or eliininate barriers and distortions to international trade. The waiver will expire as of January 4, 1979. Notice of the final determination and waiver will appear in the Federal Register of June 10, 1978. The types of fish covered by the investigation include cod, sole, haddock, and flounder. Canadian fish exports to the United States were valued at $200 million in 1977. 0 o 0 For Release Upon Delivery Expected at 10:00 a.m. STATEMENT OF DANIEL I. HALPERIN, TAX LEGISLATIVE COUNSEL DEPARTMENT OF THE TREASURY, OFFICE OF TAX POLICY BEFORE THE SUBCOMMITTEE ON MISCELLANEOUS REVENUE MEASURES OF THE COMMITTEE ON WAYS AND MEANS June 14, 1978 Mr. Chairman and Members of the Subcommittee: I am pleased to have the opportunity to present the views of the Treasury Department on the eleven miscellaneous bills under current consideration by the Subcommittee. The Treasury Department position on each of these bills is summarized in Exhibit A to this statement. This Subcommittee performs an important function in the tax legislative process. It provides a forum for the examination of legislative proposals important to one or more of the diverse sectors of society affected by our tax laws; proposals that might otherwise not receive adequate attention from the Congress. It also encourages continuous review of the application of the tax laws and thereby promotes an atmosphere in which necessary corrective changes may be identified and enacted expeditiously. A recent example of this aspect of the Subcommittee's work is provided by H.R. 12578, which contains noncontroversial technical recommendations of the Treasury, the American Bar Association and the American Institute of Certified Public Accountants. The Treasury believes that the following bills under current consideration fit into a similar category: H.R. 6897 (deficiency dividend procedure for certain regulated investment companies): The Treasury Department supports the bill and supports extension of the deficiency dividend procedure to all regulated investment companies. B-97S - 2 However, the deficiency dividend procedure should be conformed to that provided for real estate investment trusts by the Tax Reform Act of 1976 (see §§1601 (b)- (f) of P.L. 94455). H.R. 9192 (tax treatment of banks for cooperatives): The Treasury Department does not oppose the portion of the bill which grants to banks for cooperatives ordinary income treatment for gains and losses arising from the sale or exchange of bonds or other evidence of indebtedness. H.R. 10653 (tax treatment of transfer railroads under the Conrail reorganization): The Treasury Department does not oppose this bill which would permit extended net operating losses to be used against income realized by one member of an affiliated group from "certificates of value" issued as a result of the Conrail reorganization to another member of the group. H.R. 12200 (election to treat qualified stock options as nonqualified stock options): The Treasury Department does not oppose this bill which would permit taxpayers owning qualified stock options to elect to treat the options as nonqualified. However, in order to prevent windfall benefits to employers, we recommend the bill specifically provide that the employer's deduction, if any, is to be determined under the rules applicable to qualified stock options (section 421(b)). H.R. 12606 (tax deferred annuities for employees of Uniformed Services of the Health Sciences): Although the Treasury Department does not believe that section 403(b) represents sound tax policy, in the context of present law it does not oppose this bill which would extend section 403(b) treatment to civilian employees of the Uniformed Services University of the Health Sciences. In each of the foregoing cases, the process of technical and substantive review revealed a deficiency which ought to be corrected. Treasury believes it important that the Subcommittee address these types of issues. On the other hand, we continue to urge extreme caution in the use of the Subcommittee as a vehicle through which special exceptions to generally applicable rules are created for particular taxpayers. Legislative provisions of general applicability often require specific taxpayers to modify their activities in order to comply with the law. When this occurs, the affected taxpayers may seek legislative relief, - 3 on the ground either that such relief is equitable or that the activity in question does not present an abuse situation. Either claim must be carefully examined and reasonable people may reach opposite conclusions on the merits. However, we must all recognize that ad hoc solutions inevitably increase the complexity of the Code, invite other taxpayers to seek similar relief and, unless scrupulously drafted, may create new potentials for abuse. We do not believe that taxpayers should be encouraged to view the legislative process as a forum of first, rather than last, resort. H.R. 12592 is an example of this issue. That bill would exempt the Hormel Foundation of Minnesota from the self-dealing rules regarding certain trustee services furnished to private foundations. The Hormel Foundation serves as trustee of 21 irrevocable trusts in which it has remainder interests. Some or all of the trusts are "disqualified persons" with respect to the foundation. All of the trusts were irrevocable by 1954, and the trust instruments designate the foundation as trustee. To date, the foundation has not charged a trustee's fee against the trusts, although the trusts have reimbursed the foundation for expenses incurred in their administration. Pursuant to the Tax Reform Act of 1969, the furnishing of services by a foundation to a disqualified person is considered an act of self-dealing unless the services are functionally related to the foundation's exempt purposes and are furnished on a basis no more favorable than that on which such services are made available to the general public. State law prevents the Hormel Foundation from rendering trustee services to the general public. Moreover, even if the Foundation were capable of rendering such services, they would not be considered functionally related to the Foundation's exempt purposes. Consequently, the Internal Revenue Service issued a private ruling in July 1977 holding that the furnishing of trustee services by the Foundation is an act of self-dealing. The Hormel Foundation is presently in a situation that it could not have anticipated when it began acting as trustee. However, it is also true that the effective date of the provisions to which it will become subject were intentionally deferred for 10 years from the date of enactment for the specific purpose of enabling an orderly - 4 transition. The obvious nonlegislative solution to the ' problem is a petition for the appointment of a new trustee, a proceeding that is routine in most jurisdictions. We do not believe this Subcommittee should consider legislative relief until this course has been pursued. In the absence of a demonstration that judicial relief is unavailable, there is little merit to the legislation. The rendering of trustee services by the Hormel Foundation is not functionally related to the Foundation's exempt purpose and there is nothing unique about trustee services which requires that they be performed by the Foundation. As a result, we recommend that the Subcommittee defer consideration of H.R. 12592 until the Foundation has pursued its judicial remedies. A number of the bills presently before the Committee seek to extend a limited benefit (or special exception) to other taxpayers who are, or claim to be, in situations similar to the beneficiaries of present law. In many cases, only limited relief was provided initially because Congress was concerned that the policy underlying the exception might not be correct. An attempt to extend limited benefits or exceptions provides the Subcommittee with an opportunity to review the fundamental Congressional decision. The Subcommittee may decide that the underlying policy does not justify the special relief or if it does that the present case is sufficiently different so as not to warrant extension. In other cases, the Subcommittee may decide that the policy is valid but that the present rules require adjustment for it to be fully realized. The Treasury believes that the bills under consideration today illustrate all three situations. For example, H.R. 6989 would extend to two additional entities, the Maryland Savings-Share Insurance-Corpor«ation and the North Carolina Savings Guaranty Corporation, the exemption from income taxation currently granted to certain state-chartered mutual deposit guaranty organizations organized before September 1, 1957. Rather than further extend the present exemption, Treasury recommends its repeal. As originally enacted, section 501(c)(14)(B) granted tax exemption to certain mutual deposit guaranty organizations because they provided services to tax-exempt financial institutions. The financial institutions served by these organizations became taxable in 1951. However, the tax exemption for mutual deposit guaranty organizations continued and, indeed, was once extended to cover a similar organization founded in Ohio. - 5 The rationale for granting tax exemption to these institutions,disappeared when the institutions they served became taxable. Moreover, if the exemption were extended as proposed in this bill, there is reason to believe that additional organizations will be chartered and demand identical tax treatment. The proliferation of state chartered insurers, some of which may not exact the rigorous standards of Federal account insurance, could be expected to have an adverse impact upon the financial stability and credibility of the Federal Deposit Insurance Corporation and the Federal Savings and Loan Insurance Corporation. In this context it is clear that granting tax exemption to various statechartered insurance plans for financial institutions may not serve the public interest. The most even-handed way to deal with the problem is to repeal the present exemption. H.R. 11741, which would make contributions in aid of construction to regulated electric energy or gas public utilities eligible for treatment as nontaxable contributions to capital under section 118(b), raises a similar issue. While framed in the context of extension of the present law treatment accorded water or sewerage disposal facilities, the bill invites examination of the rationale for present law. Section 118(b), added by the Tax Reform Act of 1976, provides that amounts received after January 31, 1976 as contributions in aid of construction by a water or sewerage disposal utility which are used for qualified expenditures and which are not included in the rate base for ratemaking purposes are treated as nontaxable contributions to capital of the utility. In testimony before the Senate Finance Committee on July 20, 1976, the Administration opposed section 118(b) on the ground that it "would establish a precedent for similar designations of all manner of payments to telephone companies and electric and gas utilities. . . ." Indeed, an amendment to e t nd . ? ? section 118(b) treatment to electric and gas utilities was offered on the Senate floor and defeated. The relief was limited to water and sewerage utilities because it was felt that they were more significantly affected than were other utilities. Moreover, the revenue loss, measured from a base which treated contributions as taxable income, was manageable if confined to water and sewerage facilities but could be as high as $200 million if gas and electric utilities w ere included. - 6 The issue posed by H.R. 11741 is the appropriate tax treatment of contributions in aid of construction in general. The further question of what taxpayers other than water and sewerage disposal utilities should receive section 118(b) treatment must be dealt with as a separate issue only if it is decided that section 118(b) is correct as a general matter. Treasury believes that section 118(b) is incorrect. Contributions in aid of construction represent a present payment for services. As such, they constitute gross income to the recipient. Nontaxable treatment of such contributions can be justified on the theory that the contributor has made a loan of the contributed amount to the utility which is to be repaid through reduced charges for the services provided by the utility.* The loan analogy, of course, is not precise because the utility is not under a contractual obligation to return the contributor's capital plus interest through reduced charges over a finite time period. However, even if the loan analogy were precise, it is not a justification for the tax treatment sought. If the contribution is viewed as a loan, the contributor's return, the "interest" on the "loan", should be subject to income tax; but it is not because it is realized in the form of a rate reduction. It is as if the telephone company said to a consumer, "Pay me $1,000 and I will extend my telephone lines to your neighborhood. In addition, I will reduce your rates by an amount sufficient to give you an adequate return on your $1,000." It is obvious that it is virtually impossible to measure precisely the amount of income in this example. But it is equally obvious that the consumer is receiving income which under present law is not subject to tax. Unless this income is subject to tax, the present treatment accorded contributions in aid of construction under section 118(b), even if rationalized It may also be argued that the utility has sold property to the contributor. This analogy is not precise because title remains with the utility. Moreover, if there is a sale, there would be a profit element which should be taxed. Section 118(b) by excluding the receipt, eliminates the tax on the income. If section 118(b) were repealed as we recommend and the sale analogy is accepted, consideration could be given to an allowance for the cost of the Property "sold". - 7 on the loan theory, results in an unjustified aggregate revenue loss. Consequently, Treasury opposes the extension of section 118(b) to gas and electric utilities and would favor its repeal. H.R. 7207 and H.R. 12828 are also amendments expanding the scope of existing.tax exemptions. While we do not suggest that the existing exemptions be eliminated, we oppose their expansion in these circumstances. I will first discuss H.R. 7207. Under current law, only two categories of organizations that provide services to exempt organizations are exempt from tax; common investment funds of educational organizations (Section 501(f)), and organizations that provide hospital-related services to exempt hospitals, but only if the organization is operated cooperatively and distributes all net earnings for each taxable year to its patrons on the basis of the services performed for each patron during the taxable year (Section 501(e)). H.R. 7207 would create a new class of exempt organizations, those organized to provide data processing services or fiscal management services to participating social service organizations that are exempt under Section 501(c) (3) and affiliated with religious organizations exempt under Section 501(c)(3). While an eligible entity must be controlled by two or more of the organizations for which services are performed, not all purchasers of services need be members. Services are to be provided at "cost", defined to mean amounts (1) determined on the basis of use of services by each organization and (2) that do not "significantly exceed the actual cost (including straight line depreciation)" of services provided to each. The Treasury Department opposes H.R. 7207. Unlike hospital service organizations described in section 501(e) or educational collective investment funds described in section 501(f), the service organizations exempted by this legislation need not be cooperative. Moreover, the organizations would be exempt from tax even though services were provided to customers for charges in excess of actual cost. Thus, H.R. 7207 would permit qualifying organizations to derive a tax exempt profit from the provision of services. - 8 The substantive equivalent of federal tax exemption under section 501 can be achieved by the organizations covered by H.R. 7207 if they were organized and operated as member cooperatives under Subchapter T of the Code. The only remaining advantage to being exempt under section 501 would be that, in some states, it might simplify obtaining a state tax exemption. Securing a state tax exemption is not an appropriate reason to grant an otherwise unnecessary Federal income tax exemption and thereby complicate the Code. H.R. 12828 involves section 513(d) of the Code added by the Tax Reform Act of 1976. That section, among other things, exempts from the unrelated business income tax the income derived by "qualifying" section 501(c) (5) or section 501(c) (6) organizations from "convention and trade show activity" carried out in conjunction with a "qualified" convention. The Treasury's analysis of this bill is set forth in Exhibit B. To summarize, current law (section 513(d)) may not represent ideal tax policy. However, the distinctions it makes are at least arguably consistent with the purposes for which business leagues and trade associations are granted tax exemption, namely "to promote" the "common business interest" of the association members, and "not to engage in a regular business of a kind ordinarily carried on for profit". Regulations section 1.501(c) (6)-1. This consistency is implemented by restricting the trade show exemption to situations where one of the exempt purposes of the organization, and one of the organization's purposes in carrying on the show in question, is to stimulate interest and demand for the products of the organization's members. Since this rationale does not exist in the case of suppliers' shows carried on either by organizations described in section 501(c) (5) or 501(c) (6) or by organizations described in section 501(c)(3), the Treasury opposes H.R. 12828. The portion of H.R. 9192 which would extend to banks for cooperatives the section 595 nonrecognition treatment accorded certain thrift institutions upon foreclosure raises an entirely different concern namely, whether the provision whose extension is sought actually provides the desired result. - 9 A foreclosure results in immediate recognition of gain or loss for most taxpayers, but section 595 permits the specified thrift institutions to defer recognition of gain or loss until the disposition of the property. Therefore, under the law currently applicable to banks for cooperatives and taxpayers generally, property acquired at foreclosure must be valued at the time of foreclosure, whereas under section 595 there need not be any valuation until the property is sold. The banks for cooperatives have stated they need deferred recognition of foreclosure gains and losses to avoid the complexities of valuing items such as farm equipment before they are sold and to make certain that their losses on foreclosure will be ordinary rather than capital. These are worthwhile objectives and we could support the bill if this were clearly the result. In fact, however, it is not clear that section 595 treatment would simplify the taxation of banks for cooperatives. Section 595 and its regulations permit thrift institutions to deduct currently the difference between the outstanding debt amount and the fair market value of the acquired property as a worthless debt. If the losses are deducted currently, the property must be valued without a sale, resulting in the complexity which banks for cooperatives state they want to avoid. The Treasury Department would not object to extending the foreclosure treatment of section 595 to banks for cooperatives if this anomalous treatment in the current Code provision were remedied. That is, institutions (including thrift institutions) would be eligible for section 595 treatment only if they had not previously claimed a bad debt deduction with respect to the property acquired through foreclosure. Furthermore, once foreclosure took place the institutions would be prohibited from taking a bad debt loss on the property until it was sold. In addition to simplifying the operation of section 595, this amendment would eliminate the opportunity available under current law to whipsaw the Internal Revenue Service by claiming a current bad debt deduction and deferring recognition of gain until sale. I have attached as Exhibit C a memorandum stating the Treasury position with respect to H.R. 12352. I thank the members of the Subcommittee for your attention. I would be pleased to answer o 0 any o questions you may have concerning our recommendations and comments. Exhibit A Summary of Treasury Positions H.R. 6877 (small business regulated investment companies) — Supports with technical changes and supports extension to all regulated investment companies. H.R. 6989 (mutual deposit guaranty organizations) — Opposed. H.R. 7207 (exempt computer and fiscal management services) — Opposed. H.R. 9192 (banks for cooperatives) — Not opposed to ordinary income treatment for sales of notes, etc.; opposed to thrift institution foreclosure treatment unless section 595 is modified. H.R. 10653 (net operating losses in Conrail reorganization) Not opposed. H.R. 11741 (contributions in aid of construction) — — Opposed. H.R. 12200 (election to treat qualified stock options as nonqualified) — Not opposed with modifications. H.R. 12352 (source rules for railroad rolling stock) Opposed at this time. H.R. 12592 (exception from self-dealing rules) — this time. — Opposed at H.R. 12606 (extension of section 403(b) to employees of Uniformed Services University of the Health Sciences) Not opposed. i,R» 12828 (unrelated business tax exemption for certain trade shows) — Opposed. — Exhibit B Treasury Position on H.R. 12828 The Tax Reform Act of 1976 added section 513(d), which among other things exempts from the unrelated business income tax the income derived by "qualifying" section 501(c)(5) or section 501(c)(6) organizations from "convention and trade show activity" carried out in conjunction with a "qualified" convention. A "qualifying" section 501(c)(5) or (6) organization is one which "regularly conducts as one of its substantial exempt purposes a show which stimulates interest in, and demand for, products of a particular industry or segment of such industry." A "qualified" convention and trade show activity is an activity carried out in connection with a "convention, annual meeting, or show . . . if one of the purposes of such organization in sponsoring the activity is the promotion and stimulation of interest in, and demand for, the products and services of that industry in general." However, the term "convention and trade show activity" is defined somewhat more broadly, and arguably permits the lease or exhibition space not only to association members but also to suppliers of goods and services to the industry (so-called "suppliers" exhibits) even if the suppliers conduct sales activity. Thus, if a section 501(c)(5) or (6) organization regularly conducts a show designed to stimulate interest in and demand for the industry's products, and if the convention or trade show in question has as one of its purposes the promotion of interest in and demand for industry products, then income from the lease of display space to members of the organization, and to suppliers to the industry is exempt from the unrelated business income tax even if taking orders or making sales is permitted. However, tax exemption is accorded income from the lease of suppliers' exhibits only as an incident to a "qualifying" convention. H.R. 12828 would expand current law in three particulars. F irst, it would add organizations described in section ?Q1 (c) (3) to the list of qualifying organizations. Second, it would broaden the limitation on qualifying organizations to include those that regularly conduct as a substantial exempt purpose a "suppliers' show", that is, a show "which educates persons engaged in the industry in the development of new products and services or new rules and regulations effecting the industry." Finally, it would add that same language toactivity. the definition of a qualified convention and trade show - 2 Thus, the bill would permit section 501(c) (3) organizations — which are not typically regarded as carrying on shows or meetings to stimulate interest in and demand for the products of their members — to derive tax-free income from the lease of exhibition space to suppliers in connection with an annual meeting. It would also make the trade show exemption available to section 501(c)(5) organizations that do not presently meet the definition of qualifying organizations. Finally, the bill would permit trade associations to derive tax-free income from the lease of exhibition space in connection with a trade show, even where the show was not conducted to promote the common business interests of the association members by stimulating interest in and demand for their products. Current law may not represent ideal tax policy. However, the distinctions it makes are at least arguably consistent with the purposes for which business leagues and trade associations are granted tax exemption, namely "to promote" the "common business interest" of the assocation members, and "not to engage in a regular business of a kind ordinarily carried on for profit". Regulations section 1.501(c) (6)-l. This consistency is implemented by restricting the trade show exemption to situations where one of the exempt purposes of the organization, and one of the organisation's purposes in carrying on the show in question, is to stimulate interest and demand for the products of the organization's members. This rationale does not exist in the case of suppliers' shows carried on either by organizations described in section 501(c)(5) or 501(c)(6) or by organizations described in section 501(c)(3). To take a typical example, the proposed legislation would exempt income derived by a professional organization of physicians, which, in connection with its annual meeting, leased space to manufacturers of medical equipment and pharmaceuticals where the exhibitors were permitted to take orders and make sales. It may be argued that the lease of space under such circumstances promotes the exempt purposes of the professional organization by educating its members with respect to medical equipment and pharmaceuticals currently available. However, that is not the issue raised by this legislation. The professional association, under current law, may lease exhibition space to such manufacturers. This legislation - 3 would go further and would specifically permit the lessees of exhibition space to engage in active solicitation of orders and sales. Such sales activity is not substantially related to the exempt purpose of the physicians' association, but rather permits the organization to derive income from operation of a convenient shopping forum for its members. Such income properly should be taxed. Therefore, Treasury opposes H.R. 12828. Exhibit C Treasury Position on H.R". 12352 ^ • i f Under present law, income and loss from the rental of railroad rolling stock is treated as from United States sources to the extent that the rolling stock is used within the United States, and from sources outside the United States to the extent that the rolling stock is used outside the United States. Gain and loss from the sale of rolling stock purchased in the United States and sold outside the United States is generally from sources outside the United States. H.R. 12352 would change these source rules. It would provide, specifically, that income or loss from the rental of rolling stock, and gain or loss from the sale or other disposition of rolling stock, would be treated entirely as from sources within the United States, provided that the rolling stock is leased to a United States person and is not expected to be used outside the United States in excess of 90 days in any taxable year. The effect of this provision is to increase the availability of foreign tax credits to lessors of rolling stock. These are generally banks and other lenders who, unlike many railroads, are in a profit position and can use the investment tax credit associated with ownership of rolling stock. Leases of rolling stock typically generate tax losses to the lessor, at least in the early years. If these losses are treated as having a foreign source, the lessor's foreign source taxable income, and hence its foreign tax credit, is reduced. H.R. 12352 will prevent dilution of the lessor's foreign tax credit by treating the losses from leases and sales of rolling stock as having a United States source. Although the use and sale of rolling stock in Mexico is covered by H.R. 12352, it is our impression that the main issue presented is essentially a bilateral one between the United States and Canada. Since the issue basically involves only one foreign country, and since we have on going tax treaty negotiations with that country and this issue has been dealt with in the context of those negotiations, the Treasury prefers that this issue be resolved in the context of the tax treaty. The result achieved by H.R. 12352 is in the interests °f both Canada and United States lessors. The result is in the interests of United States lessors because it makes it easier to route rolling stock to Canada. The result is in Canada's interest because it ensures that Canadian - 2 foreign taxes on other Canadian income are allowed in full as a credit in the United States without dilution for losses attributable to leases and sales of rolling stock. Since the result achieved here is in Canada's interest, and since our tax treaty negotiations with Canada are fairly advanced, we are reluctant to give up any leverage that such an issue may have in those negotiations. For this reason, Treasury opposes the unilateral statutory resolution of the issue proposed in H.R. 12352 at this time.- FOR IMMEDIATE RELEASE June 14, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY DEPARTMENT FINDS SORBATES FROM JAPAN SOLD HERE AT LESS THAN FAIR VALUE The Treasury Department announced today that it has determined that sorbates imported from Japan are being sold in the United States at "less than fair value" as defined by the Antidumping Act. This affirmative determination affects only one of the four Japanese manufacturers investigated, Nippon Synthetic Chemical Industry Company. With respect to the other three companies investigated, Chisso Corporation and Daicel Ltd. are excluded from the determination on the basis of de minimis, or insignificant margins> and Ueno Fine Chemical Industries Ltd. is being given a discontinuance based upon minimal margins and assurances that all future sales will not be at less than fair value. The case is being referred to the U. S. International Trade Commission, which must decide, within 90 days, whether a U. S. industry is being, or is likely to be, injured by these sales. If the ITC's decision is affirmative, dumping duties will be collected on those sales found to be at "less than fair value." Sales at less than fair value generally occur when the prices of the merchandise sold for export to the United States are less than the prices of the same merchandise sold in the home market. Interested persons were offered the opportunity to present oral and written views prior to this determination. Notice of this action will be published in the Federal Register of June 16, 1978. Imports of sorbates from Japan were valued at $12 million during Calendar Year 1977. o B-977 0 o mtmentoftheJREASURY ££££&£ >«»«;?:« » TELEPHONE 566-2041 WASHINGTON, O.C. 20220 RELEASE FOR THURSDAY PMs JUNE 15,. 1978 REMARKS OF THE HONORABLE W. MICHAEL BLUMENTHAL SECRETARY OF THE TREASURY OF THE UNITED STATES AT THE MINISTERIAL MEETING OF OECD PARIS, FRANCE JUNE 15, 1978 Mr. Chairman: Ministers of Finance and Economics find themselves meeting in one international forum or another every few weeks. Their advisors gather even more frequently; their heads of state confer with increasing frequency. We are intensively engaged in international cooperation in all aspects of economic policy. In this economically interdependent world it is essential that this consultation process continue. Our consultations brought us to an increasing awareness of the complexity of today's economic problems. We are well informed about developments and policies in each other's economies which affect our own economic performance and the effectiveness of our own international policies. We know we share common problems: — In nearly all our economies, unemployment is too high, especially among our youth, with all that this means in terms of wasted economic and human resources. — Inflation is too high in nearly all our countries, distorting savings and investment decisions and exacerbating domestic social tensions. — Most of our countries are"experiencing rates of private investment so low as to have adverse implications for the rate of increase in employment and output for the longer run, as well as for the near-term prospect for self-sustaining growth. B-978 -2— Despite strong resistance by all our governments, protectionist pressures are unabated and continue to take new forms as political pressures mount to save jobs in sensitive industries or sectors. Our governments are tempted to act in ways which reduce the opportunities for foreign competition in domestic markets or give inappropriate aid to domestic firms to maintain or expand markets abroad. The financing of civil aircraft exports is an example of the type of practice which violates OECD sanctioned standards of conduct. — There is a strong temptation to export our problems, rather than taking steps to deal with them at home. It is always easier to postpone painful decisions. But in an increasing number of situations we have allowed supposedly temporary measures to prop up ailing industries or support employment in particular markets or sectors of the economy to become permanent features of our economies. — Our economies are still struggling to achieve the basic structural changes made necessary by the very abrupt disruptive move from cheap energy to relatively high cost energy. Our economies also face the need to adjust to the rapid expansion of production of manufactured goods in advanced developing countries. These developments in basic economics — divergent growth, high and diverse rates of inflation, protectionist moves and difficulties in achieving structural adjustment — have led to imbalances in international payments patterns, to substantial shifts in nominal exchange rates and at times of quite disorderly conditions in exchange markets. Erratic flucturations of rates have in turn tended to discourage investment and deter growth. Our understanding of these common problems has helped us in formulating and implementing policies to alleviate them. We should not underestimate the progress we have made. But much more can be done. Growth In the sphere of economic growth, we believe that a number of the countries represented here could expand internal demand over the next year or two at a more rapid rate than they achieved in 1977 without significantly increasing the risk of inflation or -3materially affecting the rate at which inflation is being reduced. The scope for such action varies from country to country but each of these nations is in position to take some action as befits the structure and traditions of its economy. There are a number of other countries among us which could accept the higher domestic growth rates that might result from an expansion of world markets leading to relaxation of a balance of payments constraint. Still others, however, must give priority to the strengthening of stabilization policies, since their primary constraint is domestic inflationary pressures. My own country falls in this last category. For more than three years the average rate of economic growth in the United States has been well in excess of the rate of increase in our potential output. We have added 9.7 million persons to our employment rolls in 38 months and our unemployment rate has dropped from a peak of 9.1 percent in May 1975 to 6.1 percent in May of this year despite an increase in the labor force. The unemployment rate for male heads of households has been reduced to 2.8 percent. We expect only a small further reduction before the year is out. Increasingly, we shall have to rely heavily on matching labor skills and locations to economic needs to achieve further reductions in unemployment without adding to inflation. The U.S. inflation rate, as measured by the consumer price index, dropped from 12.2 percent in 1974 to 6.8 percent last year. Recent rates have been even higher due to temporary factors. The underlying rate seems to be stuck between 6-1/2 and 7 percent. We are working hard to bring this so-called "underlying" rate down still further and are committed to doing so. But for all of 1978 it is likely that the inflation rate will be in the 7 percent range. Thus there are real limits to continued rapid expansion of U.S. domestic demand. jfoergy Energy is a problem. All of us know that if we are going to sustain growth over the medium and long-term, we must strengthen our programs to conserve energy and to develop new sources. No nation has a greater responsibility in this area than my own. We are making progress. Our new cars get better mileage. As a result of mandatory standards, the fuel economy of our 1985 -4automobile fleet will be roughly double, on average, its 1974 level. More and more Americans are insulating their homes and businesses, and installing fuel saving furnaces and thermostats. Such actions, together with corresponding efforts in the industrial sector, have reduced the energy required by our economy to produce a dollar of real output by more than 6 percent since 1973. Throughout the economy the trend is toward further energy-saving investments. But the comprehensive energy legislation which President Carter put before the Congress fourteen months ago has not yet been enacted. We are deeply frustrated and embarrassed by this inability of the Congress to act. We have recently redoubled our^ efforts to assure passage of this critical legislation this year.:i Progress is being made. Should it fail, the President has made clear that he will take administrative action under existing laws. Protectionism Our consultations have also made it obvious that we must work to resist protectionist pressures and reduce governmental interference in the flow of international trade. We have agreed to renew the OECD Trade Pledge. But there is more that we should do. For one thing, we need to complete the MTN this year with an, agreement that provides truly meaningful trade liberalization. Moreover, we need to go forward — if we are not to be forced backward — in reducing and eliminating destructive competitive practices in official export financing activities. The recently concluded Export Credit Arrangement, while good in its way, goes only part way to meeting the need. The first few months1 experience under it strongly suggests that it needs to bestrengthened and expanded. And it must be enforced — an agreement serves no purpose unless it is obeyed. The United States will join in the efforts, which should be undertaken immediantely, to improve the International Arrangement. But it should be understood that if there are no restraints agreed this year on predatory official export credit competition and such competition continues to escalate, there will be swift and effective U.S. reaction. -5The spread of governmental influence on trade has become extremely serious. Our new IMF Articles — Article IV — contain a prohibition against action to manipulate exchange rates and the monetary system in order to prevent effective balance of payments adjustment or to gain an unfair competitive advantage over other members. I believe we must now find equivalent means to insure that countries dp not manipulate the international trading system, through governmental regulation or subsidy or other actions which have the same effect. In the present situation, with growth still too low and unemployment still too high, there has been an accelerating, destructive tendency to subsidize production in inefficient plants and industries. Though frequently introduced for laudable purposes — maintaining employment and fostering longer term industrial development — such measures have also become a common means of avoiding structural adjustment. In the process, trade flows are affected and trading patterns become distorted, just as with more traditional protectionist measures such as tariffs or quotas. Thus I strongly support the proposals which have been developed for a policy stance favoring, rather than resisting, needed structural adjustment. We must actively promote the dynamic changes in our economies required by high energy costs, by the need for balance of payments adjustment, by technological change, and by world progress generally. Avoiding the short-term costs of structural change now merely multiplies the inevitable, eventual price we must pay. We must, in addition, adjust our economies to the very rapid surge of production of manufactured goods in the more advanced developing nations. We have for years encouraged the cry for "trade, not aid." Quite a number of nations are ready to take us up. We must keep our markets open to these nations and adjust our own production to supply the goods these nations seek. At the same time these countries must come to a better understanding of their responsibilities in opening their markets and reducing and eliminating their export subsidies. Many developing countries still have a need for resource inflows to support development programs which they are not in position to finance fully by borrowing from the private markets. !n fact, the magnitudes required continue, to increase, even though the number of countries requiring such aid is diminishing. -6Most of the members of this organization maintain bilateral aid programs and also provide funds to the international development lending institutions. Every effort should be made to increase the amount of these contributions. It is President Carterfs objective to increase the size of U.S. official assistance to LDCs substantially. U.S. aid commitments for the current fiscal year are expected to be $6.8 billion, an increase of $1.2 billion from FY 1977. Congressional approval of our FY 1979 budget request would lead to a further increase in commitments to $7.6 billion next year. Those nations among us who find their external payments positions in strong and persistent surplus should make a particular effort to expand their aid programs quickly and to untie their aid. These areas — non-inflationary growth, trade liberalization, positive adjustment, including export credit cooperation, energy, and aid — constitute the basic elements of an action program which would gradually ease the problems which plague the economic policy makers. Stability in Exchange Markets Adequate progress in these areas will also bring with it stability in foreign exchange markets and greater stability in exchange rates. Stability in foreign exchange markets will feed back on investment and trade prospects and help us to achieve our growth targets. Maintaining this stability is important to us all — as important to the United States as to any nation here. Thus the United States is prepared to work for exchange market stability. Markets can become disorderly, subject to great uncertainty, dominated by psychological factors and speculation- We have made clear that we are fully prepared to intervene in the markets to counter such disorders. We have intervened, at times in large amounts, for that purpose. And we have taken other steps, such as interest rate moves by the Fed and announcement of gold sales by the Treasury, that appear to have been useful in strengthening the tone of the market. The resources at our disposal for intervention are very large and we are prepared to use them if and as required to counter market disorders. -7But all of us know that the real key to reductions in the speed and extent of changes in foreign exchange rates and to stability in foreign exchange markets lies in better performance on the "fundamentals." The maldistribution of external payments balances has resulted from the simultaneous impact of widely divergent rates of inflation — and even more important — an unusually wide divergence in rates of growth and capacity utilization as well as the structural disruption of the oil price shock. When we collectively demonstrate to the financial community that growth will improve and that both the rate and the divergence in inflation rates among nations will diminish, there will be less movement of exchange rates and less risk of disorder in the foreign exchange markets. The IMF will be developing detailed procedures for implementing its new responsibilities for multilateral surveillance of the economic policies which provide the basis for exchange rate stability. Development of Political Will As finance or economic ministers, each of us has been seeking to put in place the policies which will best meet the problems of our respective countries. Each of us represents a sovereign nation, which of course makes its own decision within the framework of its own political system. Each must respond to the national self-interest, as perceived by his own electorate. The message I hope Ministers have drawn from all our consultations and all the information about developments elsewhere is that, in the long run, the national self-interest of each nation is best served by policies which foster a healthy world economy — a world economy of sustainable growth with reasonable price stability in the context of an open, liberal trade and payments system. Moreover, it requires that international implications be factored into the decision making in virtually all aspects of domestic economy policy — even in a country like the United States where exports are only 7-1/2 Percent of GNP. What it also means is that when national economic policies are properly coordinated they will be mutually reinforcing. If w e all move forward together, we will all move forward farther. I hope that this meeting will lay the basis for what the Secretariat has called a program of concerted action, with each Participant undertaking actions appropriate to his own situation but mutually reinforcing in the international context. -8We all know what should be done. Our common task is to explain the need for action to our own peoples and to build the domestic political support which will enable us to carry out the policies required to succeed individually and collectively. Our destinies a?e inextricably linked. We must go forward together or not at all. O00O Contact: Charles Arnold 566-2041 June 14, 1978 WILLIAM F. HAUSMAN, TREASURY OFFICIAL, DIES William F. Hausman, age 64, Director of the Office of Operations for the Assistant Secretary of the Treasury for Enforcement and Operations, died in Bethesda Naval Hospital June 12 of a pulmonary ailment. As a career United States Marine Corps officer, Mr. Hausman accumulated more than 4,000 flying hours as a military pilot before retiring as a colonel in 1963. He then joined the National Aeronautics and Space Administration as the Deputy Assistant Administrator for International Affairs. Later he joined the Commerce Department as Assistant Director, Division of Authorizations, Office of Foreign Direct Investment. He came to the Treasury Department in 1968 as an advisor on foreign assets control matters and liaison with other government agencies involving national security in relation to international financial matters. He assumed his operations responsibilities in the Treasury Department in 1969. Born and reared in Indianapolis, Indiana, Mr. Hausman was graduated with distinction from DePauw University, Greencastle, Indiana, in 1934 with a degree in political science. He was a member of Beta Theta Pi social fraternity and the alpha chapter of Sigma Delta Chi, the journalism honorary society. Under the name of Sparks Hausman, he wrote for the Saturday Evening Post and Liberty Magazine in the late 1930fs. As a Marine Corps officer, Mr. Hausman was Chief of Staff of the Fleet Marine Force, Atlantic, during the Cuban missile crisis. He headed aviation base and jet aircraft groups, an academic department at the National War College, Washington, D.C., an attache office in the U.S. Embassy in Colombia, and the nationwide Marine Aviation Reserve. In 1973 Mr. Hausman received the Treasury Department's Exceptional Service Award for his "outstanding contributions" for "the initiation and supervision of a number of critical programs and projects." He also received from the government of Colombia their highest award, The Crux Boyaca. Services will be held at 2 p.m. Friday, June 16, at the Fort Myer Chapel with burial in Arlington National Cemetery. The family requests that expressions of sympathy be in the form °* contributions to a favorite charity. B-979 - 2He is survived by his wife, Mary Jane; his brother, Robert, of Humble, Texas; a daughter, Karen P. Garver of Arlington, Virginia; two sons, Major W.F. Hausman, Jr., now stationed in Nuremberg, Germany, and Joseph Lee Hausman of Los Angeles, California, and six grandchildren, four in Arlington, and two in Germany. - o- VtfartmentoftheTREASURY WASHINGTON, D.C. 20220 TELEPHONE 566-2041 June 14, 1978 FOR RELEASE AT 4:00 P.M. TREASURY TO AUCTION $3,000 MILLION OF 2-YEAR NOTES The Department of the Treasury will auction $3,000 million of 2-year notes to refund $2,537 million of notes maturing June 30, 1978, and to raise $463 million new cash. The $2,537 million of maturing notes are those held by the public, including $350 million currently held by Federal Reserve Banks as agents for foreign and international monetary authorities. In addition to the public holdings, Government accounts and Federal Reserve Banks, for their own accounts, hold $794 million of the maturing securities that may be refunded by issuing additional amounts of the new notes at the j average price of accepted competitive tenders. Additional amounts of the new securities may also be issued at the average price, for new cash only, to Federal Reserve Banks as agents for foreign and international monetary authorities. Details about the new security are given in the attached highlights of the offering and in the official offering circular. oOo Attachment B-980 HIGHLIGHTS OF TREASURY OFFERING TO THE PUBLIC OF 2-YEAR NOTES TO BE ISSUED JUNE 30, 1978 Amount Offered; To the public Description of Security: Term and type of security Series and CUSIP designation Maturity date June 30, 1980 Call date Interest coupon rate June 14, 1978 $3,000 million 2-year notes Series Q-1980 (CUSIP No. 912827 HV 7) No provision To be determined based on the average of accepted bids Investment yield To be determined at auction Premium or discount To be determined after auction Interest payment dates December 31 and June 30 Minimum denomination available $5,000 Terms of Sale; Method of sale Yield auction Accrued interest payable by investor None Preferred allotment Noncompetitive bid for $1,000,000 or less Deposit requirement 5% of face amount Deposit guarantee by designated institutions Acceptable Key Dates; Deadline for receipt of tenders Settlement date (final payment due) a) cash or Federal funds b) check drawn on bank within FRB district where submitted c) check drawn on bank outside FRB district where submitted Delivery date for coupon securities. Tuesday, June 20, 1978, by 1;30 p.m., EDST Friday, June 30, 1978 Wednesday, June 28, 1978 Monday, June 26 , 1978 Friday, June 30, 1978 k.mttmentoftheJREASURY ^HlNGTON, D.C. 20220 TELEPHONE 566-2041 Wlw .A' ,*' pr > IT. pno PFT.F.ASE ON DELIVERY FftECTKU AT y:iu t.u.a.T. JUNE 15, 1978 TESTIMONY BY GARY- C. HUFBAUER BEFORE THE SUBCOMMITTEE ON INTERNATIONAL TRADE OF THE HOUSE COMMITTEE ON WAYS AND MEANS U.S. HOUSE OF REPRESENTATIVES WASHINGTON, D.C. Mr. Chairman, I am pleased to join in support of the President's request to extend the emigration waiver authority for Romania and Hungary under Section 4 02 of the Trade Act. Both the Department of the Treasury, and the East-West Foreign Trade Board, chaired by Secretary Blumenthal, also strongly support the President's recent decision to renew the U.S.-Romanian Trade Agreement for another three years. We believe that the U.S.-Romanian Trade Agreement has promoted the economic and political interests of both our countries. Renewal of the Agreement will allow us to build upon the foundations laid in the last three years. The recent visit of President Ceausescu to the United States underscores the importance which both of our nations attribute to strengthening U.S.-Romanian ties. We believe that it is in our interest to encourage Romania's independent policy orientation through further expansion of our bilateral relations. Renewal of the Trade Agreement is essential to this end. B-981 - 2 Romania has fulfilled the two conditions necessary for renewal of the Trade Agreement. First, a satisfactory balance of concessions in trade and services has been maintained. Romania has given most-favored-nation tariff treat- ment to U.S. products, and has been responsive to requests to facilitate U.'S. business activities in Romania. Secondly, we are also satisfied that Romania will reciprocate satisfactory U.S. reductions in tariffs and nontariff barriers in the Multilateral Trade Negotiations in Geneva. The exact amount of U.S. or Romanian concessions has not yet been established, but the Romanian government recently reaffirmed its Trade Agreement obligations to reciprocate U.S. concessions, taking into account its status as a developing nation. The Trade Agreement has contributed significantly to the growth of U.S.-Romanian Trade. Two-way trade grew from 5322 million in 1975, which was four times the value of trade in 1970, to $448 million in 1976, and reached a record $49 3 million in 19 77. The U.S. has continued to maintain a positive trade balance over this period. The few instances of threatened market disruption from Romanian Sports have been resolved with minimal difficulty. The further growth of U.S.-Romanian trade in such a favorable atmosphere depends on renewal of the Trade Agreement. - 3 The Treasury also supports the President's determina- tion that further extension of the emigration waiver authority. for Romania will substantially promote the objectives of Section 402 of the Trade Act. This extension is essential for renewal of the Trade Agreement. In order to earn hard currency, Romanian exports must have access to Western markets, including our own. The countries of Western Europe have granted most-favored-nation status to Romanian exports. If the United States does not continue to facilitate Romanian access to U.S. markets through MFN, it may lose potential exports to Romania as well. The President's emigration waiver will enable us to continue granting MFN to Romania thus improving Romania' s ability to earn hard currency to pay for imports. Extension of the waiver is also required for Romania to continue to utilize U.S. financing for its imports from the United States. Without the waiver, Eximbank would not be able to make loans or guarantees to Romania and U.S. exporters would be at a competitive disadvantage. Commodity Credit Corporation (CCC) credits, which have been instrumental in increasing U.S. agricultural exports to Romania, also cannot be extended without the waiver. Both forms of financing obviously benefit U.S. exporters. - 4 Mr. Chairman, our experience with the U.S.-Romanian Trade Agreement has convinced us of its continued importance. The Agreement has served as a cornerstone for the growth of U.S.-Romanian relations both economically and politically. We are satisfied that Romania has fulfilled the conditions of the Agreement and that its renewal would continue to strengthen U.S.-Romanian ties. We are aware of the concern expressed by several members of Congress regarding a Romanian decree which set arbitrary limits on compensation for confiscation of U.S. property in Romania. We share these concerns. We have raised this problem with the Romanian Government and will continue to press the Romanian authorities to live up to their repeated assurances to provide prompt, adequate and effective compensation in such cases. While not directly related to the renewal of the Trade Agreement or extension of MFN, the payment of prompt, adequate and effective compensation is a clear condition for Romania's continued enjoyment of GSP and we have made this link very clear to the Romanian government. In conclusion, Mr. Chairman, I believe that a threeyear renewal of the U.S.-Romanian Trade Agreement and a oneyear extension of the Presidential waiver is in our national interest. 0O0 FOR RELEASE AT 4:00 P.M. June 15, 1978 TREASURY'S 52-WEEK BILL OFFERING The Department of the Treasury, by this public notice, invites tenders for $ 2,750 million, or thereabouts, of 364-day Treasury bills to be dated June 27, 1978, and to mature June 26, 1979 (CUSIP No. 912793 V9 4). The bills, with a limited exception, will be available in book-entry form only, and will be issued for cash and in exchange for Treasury bills maturing June 27, 1978. This issue will provide $497 million new money for the Treasury as the maturing issue is outstanding in the amount of $ 2,253 million, of which $1,070 million is held by the public and $1,183 million is held by Government accounts and the Federal Reserve Banks for themselves and as agents of foreign and international monetary authorities. Additional amounts of the bills may be issued to Federal Reserve Banks as agents of foreign and international monetary authorities. Tenders from Government accounts and the Federal Reserve Banks for themselves and as agents of foreign and international monetary authorities will be accepted at the average price of accepted tenders. The bills will be issued on a discount basis under competitive and noncompetitive bidding, and at maturity their par amount will be payable without interest. Except for definitive bills in the $100,000 denomination, which will be available only to investors who are able to show that they are required by law or regulation to hold securities in physical form, this series of bills will be issued entirely in book-entry form on the records either of the Federal Reserve Banks and Branches, or of the Department of the Treasury. Tenders will be received at Federal Reserve Banks and Branches and at the Bureau of the Public Debt, Washington, D. C. 20226, up to 1:30 p.m., Eastern Daylight Saving time, Wednesday, June 21, 1978. Form PD 4632-1 should be used to submit tenders for bills to be maintained on the book-entry records of the Department of the Treasury. Each tender must be for a minimum of $10,000. be in multiples of $5,000. Tenders over $10,000 must In the case of competitive tenders, the price offered must be expressed on the basis of 100, with not more than three decimals, e -8-, 99.925. B-982 Fractions may not be used. (OVER) -2Banking institutions and dealers who make primary markets in Government securities and report daily to the Federal Reserve Bank of New York their positions with respect to Government securities and borrowings thereon may submit tenders for account of customers, provided the names of the customers are set forth in such tenders. Others will not be permitted to submit tenders except for their own account. Payment for the full par amount of the bills applied for must accompany all tenders submitted for bills to be maintained on the book-entry records of the Department of the Treasury. A cash adjustment will be made for the difference between the par payment submitted and the actual issue price as determined in the auction. No deposit need accompany tenders from incorporated banks and trust companies and from responsible and recognized dealers in investment securities, for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, or for definitive bills, where authorized. A deposit of 2 percent of the par amount of the bills applied for must accompany tenders for such bills from others, unless an express guaranty of payment by an incorporated bank or trust company accompanies the tenders. Public announcement will be made by the Department of the Treasury of the amount and price range of accepted bids. Those submitting competitive tenders will be advised of the acceptance or rejection thereof. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and his action in any such respect shall be final. Subject to these reservations, noncompetitive tenders for $500,000 or less without stated price from any one bidder*will be accepted in full at the average price (in three decimals) of accepted competitive bids. Settlement for accepted tenders for bills to be maintained on the records of Federal Reserve Banks and Branches must be made or completed at the Federal Reserve Bank or Branch on June 27, 1978, able funds or in Treasury bills maturing in cash or other immediately availJune 27, 1978. Cash adjustments will be made for differences between the par value of maturing bills accepted in exchange and the issue price of the new bills. Under Sections 454(b) and 1221(5) of the Internal Revenue Code of 1954 the amount of discount at which bills issued hereunder are sold is considered to accrue when the bills are sold, redeemed or otherwise disposed of, and the bills are excluded from consideration as capital assets. Accordingly, the owner of bills (other than life insurance companies) issued hereunder must -3include in his Federal income tax return, as ordinary gain or loss, the difference between the price paid for the bills, whether on original issue or on a subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made. Department of the Treasury Circulars, Public Debt Series - Nos. 26-76 and 27-76, and this notice, prescribe the terms of these Treasury bills and govern the conditions of their issue. Copies of the circulars and tender forms may be obtained from any Federal Reserve Bank or Branch, or from the Bureau of the Public Debt. oOo ADVANCE FOR RELEASE SUNDAY MORNING JUNE 18, 1978 TREASURY UNDER SECRETARY FOR MONETARY AFFAIRS ANTHONY M. SOLOMON ON FLEXIBLE EXCHANGE RATES, INTERVENTION, THE U.S. DOLLAR, INTERNATIONAL MONETARY SYSTEM, AND OTHER POINTS Following is the transcript of a filmed interview for the U.S. International Communication Agency, taped on Wednesday, June 6, with Under Secretary for Monetary Affairs, Anthony M. Solomon. B-983 Q. Mr. Secretary, does the United States feel that flexible exchange rates have been as favorable for world trade and economic growth as the old Bretton Woods system of fixed exchange rates? UNDER SECRETARY SOLOMON: Exchange stability is more helpful to world trade than major fluctuations in exchange rates. There's no doubt about it. On the other hand, it is important that there be some flexibility in exchange rates, to adjust for, to compensate for differentials in national inflation rates. Otherwise trade relationships would get very much out of line. Secondly, the events after the oil shock increase in 1973 resulted in large payments imbalances and started forcing structural readjustment which we still have not completed, which would have made Bretton Woods fixed exchange rates impossible and would have been very disruptive under the situation of these very unusual large payments imbalances. We needec the flexibility in the monetary system to cope with the special situation of the '70s. Q. But there seems to be disillusionment with flexible exchange rates and considerable sentiment for going back to a system of fixed rates. Do you think a trend in that direction would be at all feasible or at all desirable? UNDER SECRETARY SOLOMON: I do not believe that there is a feeling in governmental circles abroad that we should go back to fixed exchange rates. There is some disillusion with inordinately wide fluctuations in exchange rates. But the most that has been suggested in various circles has been that there be cooperative arrangements to limit the amount of movement, 'not return to Bretton Woods fixed exchange rates, and I know of no significant or highly prevalent attitudes among monetary officials to move to fixed exchange rates. Q. Some people overseas feel that the United States is not interested in supporting the value of the dollar. Is this true? And then why hasn't the United States been prepared to -2intervene in foreign exchange markets on a large scale when the value of the dollar was declining? UNDER SECRETARY SOLOMON: Well, we certainly are concerned about the value of the dollar, and we have attempted to support it in the only meaningful way, long term meaningful way, namely by taking action on domestic policies which will tend to reduce our deficit. And that means working on our inflation rate, getting our excessive energy import dependence under control, and trying to eliminate the large differences in growth rates. We have run a very high growth rate here, while abroad there have been near recession levels of economic activity, and this has resulted in a very major part of our trade deficit. Intervention is useful to a degree, but intervention, even on a massive scale, cannot cope with fundamental trends going in the wrong direction. We must take action on energy. We must take action, even though it will be gradual, on curbing our rate of inflation. We must promote exports. Other countries must achieve more satisfactory levels of growth for their own interests, as well as for the purposes of reducing imbalances in their payments positions. And therefore all this will make for stability in the monetary area. We will intervene, we have intervened, as we did in the first quarter of '78, when markets are disorderly, and our intervention was very large at times. But it is a mistake to think of intervention as the way of supporting the dollar. Q. Are wide swings in exchange rates among the major currencies harmful, in your view, to developing countries? UNDER SECRETARY SOLOMON: I think they cause some operating difficulties for developing countries, as well as for some other countries, industrialized countries. But without the flexibility of the exchange rate system that we saw in the '70s under these special circumstances, there would have been major trade restrictions which would have hurt the developing countries much more. The flexibility in the exchange rate system under the special circumstances of the '70s was absolutely essential to maintain an open trading system, and that is more important to the developing countries than the relatively modest operating difficulties they may have had from fluctuations in the rate. Q. So what, in your view, can and should the United States and its industrialized trading partners do about this? -3UNDER SECRETARY SOLOMON: Well, we are working on what I've called earlier fundamental policies which will reduce our deficit. In addition, we are intervening during periods that the markets are disorderly. As you know, the tone of the markets has improved recently and next year we expect to see, towards the end of next year, various factors which will make for a much healthier balance in the payments system. The trade deficit should begin trending down and in general I think we're on the right path. One has to view these exchange rate movements in perspective. The amount of the decline in the dollar since it came under pressure last year has been almost exactly the same amount on a trade weighted basis as the amount it appreciated in 1975, and in '76 it stayed stable. Now, even though some of the individual bilateral rate movements have been larger than that, one has to look at the extent to which they simply compensated for differences in inflation. If one looks at what we call the real exchange values of different key currencies, the movement has not been very significant. I think we're on the right policy, the right set of policies, the right path. We have to continue with persistence and we have to make much more clear, much more manifest, our determination to promote exports, get our current inflation rate down, and to curb excessive energy imports. Q. Can we turn now to the international scene a little bit more? Under the new international monetary system that went into effect this year, how important do you believe is the IMF's surveillance role? UNDER SECRETARY SOLOMON: There is a potential there for it to become the major force in promoting the global adjustement process. The IMF has both broad authority to promote the adjustment process under the new system, and it has specific authority to conduct surveillance of appropriate exchange rate policies by different countries. If member countries will support — and the United States, I pledge and commit ourselves to that support — the Secretary of the Treasury said so in a public statement at the last interim committee meeting. If other major countries join with us in supporting the IMF really effectively using its new surveillance authority, we believe will play a very major force, and we have made some specific suggestions on how the IMF can develop much more clout in this field. -4Q. In your view is the IMF now equipped to exert real leverage over members' exchange rate policies and domestic economic policies? UNDER SECRETARY SOLOMON: To some extent it will be an evolutionary development of strength. But even at the beginning phases we believe that the IMF can have a significant influence, and over a period of time, as it uses its authority to initiate consultations with member countries, where they believe that there may be inappropriate exchange policies being followed contrary to the principles agreed on in the new Article 4, that authority to initiate specific consultations is very important. The authority to report to the board of the IMF when the consultation has not worked out satisfactorily puts tremendous pressure on countries to take adjustment actions. Therefore, even though I would expect that over the long run the authority and the ability of the IMF to effectively survey these exchange policies will increase, I would give as my considered opinion that even in the beginning stages there is a substantial basis on which the IMF can build and which will be very helpful. Q. And in your view would the United States, and in 1 some respect even Congress, be willing to see our own domestic policies come under the scrutiny or the surveillance of the IMF? UNDER SECRETARY SOLOMON: We in the Executive Branch have already informed the Fund that we are prepared fully to have our policies come under their surveillance. We are prepared to give very serious consideration to their recommendations. The Congress has consistently supported the International Monetary Fund. The Congress has passed by a very wide margin the amended Articles of Agreement, in '76 actually, which created this new legal system and gave these surveillance authorities to the Fund. I would be very hopeful that the United States will be in the lead and will cooperate if other major countries do as well, with the Fund. Q. Does the United States see the need for further reform of the international monetary system, to deal with the growth and the composition of reserves? UNDER SECRETARY SOLOMON: That, I think, would distract attention from what are the fundamental policies needed to bring about a smoother global adjustment process. Two, mechanics. -5I don't think what the world needs now is a new set of mechanics in the monetary system, because they will not solve the basic payments imbalance problem. That will be solved in the way I've indicated. To distract attention through tinkering with the mechanics would be inappropriate and inadvisable at this point, in my opinion. We have a new legal system. It just went into effect in April. We've got to make it work. And it goes right to the heart of the fundamentals of the adjustment process. To come up with new mechanical devices, , whether crawling pegs or multilateral massive intervention swaps, or some other form of change in the mechanics in the system, does not go to the heart of the problem. Q. One of the aims of the new articles of agreement of the IMF is to increase the importance of special drawing rights as an international reserve asset. As the use of SDRs increase, wouldn't the relative significance of the dollar as a reserve asset decrease? UNDER SECRETARY SOLOMON: Well, we support the concept — in fact, we initiated it — of the special drawing right, in place of metallic gold as an international reserve asset. We encourage its evolution. It should be done on a cautious scale. And we're perfectly prepared to see, over the long run, a relative diminution of the role of the dollar as a reserve asset held by official institutions, central banks. I think that we have to move cautiously and see on the basis of practice, how we can enlarge the role of the special drawing right, so that it is more useful, more widely used. I do not see any major displacement of the dollar by the special drawing right. I think it would be a very useful additional reserve asset, and I would hope that we will have enough success in the evolution of the monetary system, as far as the special drawing right is concerned, that we can see that. But the United States has no particular objective in regard to either increasing or diminishing the role of the dollar as a reserve asset. Some people have argued that it is a burden for the United States. Other prople have argued that it is an advantage for the United States. Frankly, in the Treasury assessment, and we've done very careful analysis of this, we do not feel that it is either a significant special advantage nor a significant special burden. At times it puts us under more pressure. At times there are some advantages. We're perfectly prepared to see a change in the role of the dollar. The key thing is that it should, if it does come, be part of the evolution of a smooth and effective monetary system. And as I say, we'd be perfectly happy to continue with the dollar in its special role. If the ultimate evolution -6of the system is one which diminishes the role of the dollar, we're perfectly prepared to live with that, as long as we have a smoothly functioning monetary system. Q. Mr. Secretary, how does the United States view closer monetary ties among the European nations? UNDER SECRETARY SOLOMON: Well, we've always supported, of course, the concept of fuller European economic integration, and I think it's a decision for the Europeans themselves. It's perfectly compatible with the broad international monetary system as we know it today, and if the Europeans make that decision, or if it evolves in a more gradual way, I would assume from everything I know about the way these things tend to operate, that it would be perfectly compatible and therefore we would have no problem with it. Q. But what would happen if the creation of, say, a European currency could possibly rival the dollar internationally? UNDER SECRETARY SOLOMON: Well, that brings us bac| to the earlier question, in a sense. If other countries, if other currencies should develop more acceptance as reserve currencies, that is again, if it develops smoothly, that is a perfectly appropriate evolution from our point of view. r You must understand, though, that for other currencies to become meaningful reserve currencies, they have to open their capital markets the way the United States has, and they have been _ reluctant to do that to the degree that we have. There is^no way of having a really important reserve function for a currency unless it has large capital markets to which the rest of the world can have access, can borrow. The United States has played that role. We could not have had the postwar economic expansion in the entire world and the prosperity we've had unless the United States had been willing to do that. If other countries are willing to do that, or the European community as a whole develops monetary union and a unit of account and is willing to do everything that is required to — for that currency to develop that reserve currency role, then assuming that it is a smooth evolution, we would be perfectly happy with that. My own personal view is that there would be considerable reluctance to enter this role in any very rapid way, because I think the opening up of capital markets in Europe is something that most European governments would want to handle very, very cautiously. -7Q. Some U.S. officials often suggest that surplus nations should boost their growth rates as a contribution to a better balance of payments adjustment. But greater economic stimulus is likely to mean more inflation. Is the United States in* effect asking these countries to adjust their inflation rate upwards, toward the average for other industrial nations? UNDER SECRETARY SOLOMON: Definitely not. But there are some countries, surplus countries, where there is such slack in their economy, such idle productive capacity, such substantial levels of unemployment, that it is perfectly possible for them to expand their levels of economic activity without inflationary stimulus. We would not want to see countries, whether the United States or any other country, expand its economic activity in an inflationary way. But certainly all economists agree that one cannot identify expansion of economic activity when there are very slack underutilization conditions with inflationary stimulus. That is not — I thought that that belief was a 19th Century belief. Moving countries up from near recession levels, to more adequate levels of economic output and employment, does not introduce inflation in an economy. Q. The last question, Mr. Secretary. When national governments make decisions on domestic economic policies, they naturally tend to give top priority to domestic needs and internal political situations. This being so, how can any attempt at international coordination of growth policies have any real effect on the economic decisions of individual governments? UNDER SECRETARY SOLOMON: It's a very difficult question that you pose, and my own personal view is that the process that we are now engaged in of international consultation on what are basically perceived as domestic economic policy issues, is going to be an evolving one over a long period of time. If we're going to live in this increasingly interdependent world,we will increasingly recognize that what we have thought of in the past as domestic policy has a major impact, not only on other countries, but on the viability of trade and the international monetary system. And therefore, indirectly back on everybody's prosperity. Therefore, there must be coordination of global macro-economic policies and domestic macro-economic policies. Now, it's a very difficult process, adjusting one's own national actions, given the domestic political setting in each country, to the need to play a role in the adjustment move process same direction, in in thearight waywe that direction, arehelps all helping others even though each and thereby, other it may nationally, when not be wethe all and -8domestically politically as well. This process of consultation has gone on and is going on at the OECD level, at ministerial meetings, at the summit. It will be a continuing process with the more we understand each other's situation and the relevance of policies to needs, the better job we will do on international coordination. I would not look for dramatic results overnight. I would look, however, for evolution towards more and more cooperation over the next few years. FOR IMMEDIATE RELEASE JUNE 15, 1978 STATEMENT BY SECRETARY OF THE TREASURY W. MICHAEL BLUMENTHAL I am delighted by this morning's 15-0 Senate Banking Committee vote to provide $1.5 billion of guarantee authority for New York City long-term debt. This unanimous vote for long-term financing assistance means that the Administration, the House of Representatives and the Senate Committee all agree on this concept. The vote and the discussion in Committee this morning also underscores the necessity that the various private parties in New York assume a high level of responsibility for the financing of New York's capital needs in the next four years. The Committee will now be considering the more technical aspects of the bill, and we hope to work with them to insure that any conditions for the issuance of guarantee are consistent with the Administration's ultimate objective of assisting the City to regain access to the long-term capital markets. # B-984 # # MrtmentoftheJREASURY SHINGTON IQNE 566-2041 CONTACT Charles Arnold 202/566-2041 TEXT OF Press Conference with Secretary of the Treasury W. Michael Blumenthal and Council of Economic Advisers Chairman Charles L. Schultze The following press conference was held following the conclusion of the Organization for Economic Cooperation and Development Ministerial Meeting in Paris on June 15: SECRETARY BLUMENTHALI - "YES, I MIGHT SAY LADIES AND GENTLEMEN* BY WAY OF INTRODUCTION THAT WE ARE SATISFIED WITH THE OUTCOME OF THIS MEETING AFTER TWO DAYS OF WIDE-RANGING DISCUSSIONS ON ALL OF THE FUNDAMENTAL INTERNATIONAL ECONOMIC ISSUES. AS YOU KNOW, WE ATTACH VERY GREAT IMPORTANCE AND HIGH VALUE TO THE OECD AS THE PRINCIPAL ORGANIZATION IN WHICH THE INDUSTRIALIZED DEMOCRACIES CONSULT AND COORDINATE THEIR ECONOMIC POLICIES. WE ARE IN A PERIOD IN WHICH THE COORDINATION OF THESE ECONOMIC ISSUES, INCLUDING WHAT TRADITIONALLY HAS BEEN THE DOMESTIC, PURELY DOMESTIC POLICIES, IS INCREASINGLY IMPORTANT IN AN INTERNATIONAL CONTEXT, AND MEETINGS SUCH AS THIS ONE HELP ALL OF THE PARTICIPATING COUNTRIES TO LEARN HOW TO CONDUCT AND PERFECT THIS PROCESS. AND THIS MEETING WAS A VERY IMPORTANT STEP ALONG THIS WAY OF IMPROVING UPON IT. —"IT IS THEREFORE PART OF AN ON-GOING PROCESS OF MEETINGS AND WE'DID AT THIS MEETING I THINK ACHEIVE A BROAD FOUNDATION OF POLICY AGREEMENTS AMONG ALL OF THE OECD NATIONS UPON WHICH MEETINGS NEXT SFIED THAT THE —"MORE ARE SATI MONTH OFSPECIFICALLY, THE EUROPEAN WE COUNCIL IN BREMEN Atf> THE FOLLOWING OCCURED AT THIS MEETING: BONN SUMMITACHIEVEMENTS CAN BE BUILT. FIRST, AN AGREEMENT ON THE BROAD ELEMENTS OF A PROGRAM TO DEAL WITH THE MUTUAL PROBLEMS OF GROWTH, INFLATION, UNEMPLOYMENT, PAYMENT IMBALANCES, AND THE DEPENDENCE ON THE FOREIGN ENERGY SOURCES. SECOND, THE RENEWAL FOR ANOTHER YEAR OF T HE OECD TRADE PLEDGE, FIRST AGREED UPON IN 1974. THIRD , AN AGREEMENT ON CRITERIA WHICH WILL GUIDE MEMBER GOVERNMENTS IN NT THE -TO STRUCTURAL FORMULATINGAND CHANGES. POLICIES FOURTH,FOR AGREEMENT ADJUSTME 0N IMPORTANCE B-985 -2OF STRENGTHENING COOPERATION AMONG THE OECD MEMBERS IN THE DIALOGUE WITH THE DEVELOPING COUNTRIES INCLUDING SUCH KEY ELEMENTS AS A COMMITMENT TO AN OPEN MULTILATERAL TRADING SYSTEM, A READINESS TO ADJUST TO CHANGES IN THE PATTERN OF WORLD PRODUCTION AND TRADE^ A DECISION TO EXAMINE THE USEFULNESS AND PRACTICALITY OF INCREASING INVESTMENT FLOWS TO THE DEVELOPING COUNTRIES AND A REAFFIRMED INTENTION TO INCREASE DEVELOPMENT AID FLOWS EFFECTIVELY AND SUBSTANTIALLY. ALSO, A REAFFIRMATION OF THE IMPORTANCE OF ALL MEMBER OOUNTRIES, INCLUDING PARTICULARLY THE U.S., OF ADOPTING AND IMPLEMENTING SOUND ENERGY POLICIES, POLICIES WHICH WILL ENCOURAGE CONSERVATION AND THE DEVELOPMENT OF ALTERNATIVE SOURCES OF ENERGY. AND FINALLY, AGREEMENT ON THE IMPORTANCE OF CONVENING A CONFERENCE AS SOON AS POSSIBLE TO NEGOTIATE AN .AGREEMENT TO PREVENT ILLICIT PAYMENTS IN CONNECTION WITH INTERNATIONAL COMMERCIAL TRANSACTIONS. —"WE ALSO DISCUSSED, THE U.S. POINTED OUT, THE NEED FOR IMPROVING UPON THE AGREEMENT WHICH WAS REACHED IN THE CECD LAST FEBRUARY WITH REGARD TO LIMITATIONS ON EXPORT CREDITS, AND ON THAT POINT WE MADE OUR PROPOSAL IN THIS REGARD AND, AS THE COMMUNIQUE INDICATES, OTHER NATIONS NOTED IT, AND IN VIEW OF THE SHORTNESS OF TIME WERE NOT ABLE TO RESPOND BUT WE LOOK FORWARD TO THESE DISCUSSIONS AS SOON AS POSSIBLE SO THAT HOPEFULLY 90ME AGREEMENT ON FURTHER IMPROVEMENT CAN BE REACHED THIS YEAR. —"I'LL BE HAPPY TO TAKE ANY QUESTIONS THAT YOU MAY HAVE, EITHER FOR ME OR FOR MR. SCHULTZE. Qt CBS NEWSx CAN I ASK A QUESTION PREVIOUSLY ASKED AT THE OTHER PRESS CONFERENCE? WOULD THERE BE HOPE THAT THE RATHER VAGUE AND UNSPECIFIC PROMISES TO TAKE EXPANSIONARY ACTION WOULD BECOME MORE FRECISE IN THE BONN SUMMIT? A: BLUMENTHAL: WELL, THEY WILL MOST CERTAINLY BE DISCUSSED AT THE BONN SUMMIT. AND I WOULD EXPECT THAT NATIONS WILL WISH TO EXPRESS THEMSELVES AS CLEARLY AS POSSIBLE AT THAT TIME. IT, OF OOURSE, HAS A DIFFERENT MEMBERSHIP, LESS COUNTRIES ARE ^ " ^ P B E THERE. AS I SAID EARLIER THIS MEETING IS A VERY USEFUL WAY STATION ON THE WAY TO BONN AND THESE CONSULTATIONS WILL HOPEFULLY BE HELPFUL TO ALL OF US IN DEFINING MORE PRECISELY OUR POSITIONS ON THIS QUESTION. WOULD Qt YOU CBS THINK NEWS AGAIN: OF QUANTITATIVE DEFINING MORE GOALS?PRECISELY, . -3-. At BLUMENTHALl I DON'T THINK THERE WILL BE QUANTITATIVE GOALS. I THINK WHAT IS IMPORTANT IS THE RESULT THAT IS TO BE ACHIEVED RATHER THAN SPECIFIC QUANTITATIVE NUMBERS ONLY. Qt LONDON TlMESt LAST YEAR, YOU DID AGREE ON QUANTITATIVE GOALS AT THE OECD. WHY SHOULD WE THIS YEAR TAKE MORE SERIOUSLY THE VAGUER TARGETS YOU SET THAN THE SPECIFIC TARGETS YOU GAVE LAST YEAR? At BLUMENTHAL: I THINK THE PROCESS OF CONSULTATION THAT HAS OCCURED IN VARIOUS FORUMS, IN THE IMF MEETING MOST RECENTLY AND THEN AGAIN HERE TODAY, AND THE EXPERIENCE THAT WE HAVE ALL HAD, AND THE NECESSITY TO ADJUST OUR VARIOUS DOMESTIC PROGRAMS, HAS TAUGHT US THE IMPORTANCE OF AGREEING ON THE GENERAL OBJECTIVES THAT WE WISH TO ACCOMPLISH, AND OF FOCUSING ON THAT, AND ON THE KINDS OF PROBLEMS THAT STAND IN THE WAY, ACTIONS THAT NEED TO BE TAKEN, RATHETHAN ON TRYING TO AGREE ON SPECIFIC NUMBERS. WE FEEL THAT IF WE SPEND OUR EFFORTS MORE IN DEFINING THESE PROBLEMS AND IN WORKING ON THEM, THAT WE WILL GO FURTHER THAN IN TRYING TO DEFINE SPECIFIC GOALS AND TARGETS. A: SCHULTZEt MAY I ADD TO THAT THAT LAST YEAR MY RECOLLECTION WAS THAT THE TARGET WAS A NUMBER FOR, AN AGGREGATE NUMBER FOR A GROUP OF TWENTY-ODD NATIONS WHICH IN ITSELF MAY MEAN NOTHING IN TERMS OF SPECIFIC ACTIONS BY SPECIFIC NATIONS, WHEREAS IN THE COMMUNIQUE ISSUED TODAY THERE WAS AT LEAST SPECIFIC DIVISION AMONG NATIONS DOING ONE THING AND NATIONS DOING ANOTHER. Qt COULD WE COME BACK TO THAT, BECAUSE YOU DO HIT EIGHT NATIONS--COULD WE ASK ANOTHER QUESTION THAT WAS ASKED IN THE PREVIOUS PRESS CONFERENCE .. . OF THOSE EIGHT COUNTRIES, COULD YOU TELL US IN WHICH COUNTRIES MEASURES ARE NECESSARY AND ALSO WHAT WERE THE APPROPRIATE MEASURES. IN OTHER WORDS, DID YOU DISCUSS DETAIILED MEASURES FOR THESE COUNTRIES? At BLUMENTHALt WE DID NOT DISCUSS DETAILED MEASURES FOR INDIVIDUAL COUNTRIES. WE DID POINT OUT THAT, IN COUNTRIES IN WHICH THERE HAS BEEN SLOW GROWTH, IN WHICH THERE IS A CAPACITY FOR FURTHER GROWTH THIS SHOULD BE TAKEN INTO ACCOUNT. AM) THAT OTHER COUNTRIES, THE U.S. FOR EXAMPLE, WHICH HAS GROWN RATHER SUBSTANTIALLY OVER THE PAST TWO YEARS, AND IN WHICH THERE WERE INFLATIONARY PRESSURES, THE PR03LEM OF STABILIZATION WAS THE MORE PREDOMINANT FITTED OECD PROBLEM. MEMBERS IN.BUT EXACTLY WE DID WHERE NOT DEFINE EACH AMONG INDIVIDUAL THE VARIOUS COUNTRY -4Q: FIGAROt MAY I ASK YOU ABOUT PARAGRAPH 3, NUMBER 12, PAGE 5. THERE SEEMS TO BE SOME ELEMENT OF CONFLICT IN THE UNITED STATES AND CANADA'S POSITION AND OTHER PARTICIPANTS REGARDING GUIDELINES FOR EXPORT CREDITS, OTHER PARTICIPANTS WERE, I BELIEVE, HOT QUITE READY TO START RENEGOTIATING SOMETHING WHICH HAD BEEN NEGOTIATED NOT LONG AGO AND WANTED TO SEE HOW IT WORKED. HOW DO YOU SEE THIS PROBLEM. AND DO YOU THINK THERE IS A SORT OF AGREEMENT ALREADY FOR ANOTHER CONFERENCE TOWARD THE END OF THE YEAR? A: BLUMENTHAL: WELL, I THINK THIS PARTICULAR PARAGRAPH—SUBPARAGRAPH THREE OF PARAGRAPH TWELVE SPEAKS FOR ITSELF. AS FAR AS THE UNITED STATES IS CONCERNED WE FELT THAT THE AGREEMENT CONCLUDED IN FEBRUARY WAS FINE AS FAR AS IT WENT, BUT THAT THERE WAS ALREADY EVIDENCE THAT IT WOULD BE USEFUL TO ENTER INTO NEGOTIATIONS FOR FURTHER SUBSTANTIVE IMPROVEMENT OF THE EXISTING ARRANGEMENTS. OTHER PARTICIPANTS DID NOT DISPUTE THIS, BUT THEY DID NOT FEEL IN A POSITION TO AGREE TODAY THAT A SPECIFIC NEW NEGOTIATION BE STARTED. THIS INDICATES, THEY DID POINT OUT, THAT THERE IS A REGULAR REVIEW WHICH COMES UP IN THE AUTUMN. WE FELT WE OUGHT TO GET TOGETHER AS SOON AS POSSIBLE. WE FEEL THAT THIS AREA OF EXPORT CREDITS IS ONE THAT NEEDS TO BE REGULARIZED AS MUCH AS POSSIBLE FOR IT HAS THE POTENTIAL OF, POTENTIALLY DIVISIVE COMPETITION, AND WE THINK EVERYTHING NEEDS TO BE DONE TO AVOID THAT. Q: MR. SECRETARY, IN THIS CONNECTION IN YOUR OPENING REMARKS YOU THREATENED SWIFT AND EFFECTIVE ACTION. COULD YOU ELABORATE ON THAT PLEASE? A: BLUMENTHAL: WELL, I WAS REFERRING TO THE FACT THAT IN INSTANCES IN WHICH SOME COUNTRIES ENGAGE IN EXPORT CREDIT SUBSIDIZATION THAT GOES BEYOND THE EXISTING OECD GUIDELINES, OR THAT GOES AGAINST THE SPIRIT OF THOSE GUIDELINES, THE PRESSURE ON THE UNITED STATES THROUGH THE CONGRESS, AND ALSO BASED ON OUR OWN VIEWS IN THE EXECUTIVE BRANCH OF THE GOVERNMENT, TO INSURE THAT AMERICAN INDUSTRY IS NOT DISADVANTAGED BY THAT, IS SO SEVERE THAT I HAD TO TELL MY COLLEAGUES THAT WE WOULD HAVE TO MEET THOSE KINDS OF ADDITIONAL 'SUBSIDIZATIONS OF CREDIT TERMS WHERE THEY OCCUR. I, THEREFORE, FELT IHAl RATHER THAN COUNTRIES INDIVIDUALLY ENGAGING IN THAT Kit© OF COMPETITION, IT WAS BETTER FOR ALL OF US TO GET TOGETHER TO TRY TO ELABORATE ON THE ARRANGEMENT THAT HAS ALREADY BEEN NEGOTIATED. -5Qt MR. SECRETARY, AS FAR AS THE FEDERAL REPUBLIC OF GERMAN IS CONCERNED, ARE YOU SATISFIED BY THE ATTITUDE SHOWN BY THE FEDERAL GOVERNMENT, AND THE ffiOMISES GIVEN BY THE FEDERAL GOVERNMENT AT THIS CONFERENCE? At BLUMENTHAL: WELL, THIS WAS NOT A CONFERENCE AT WHICH INDIVIDUAL NATIONS MADE INDIVIDUAL SPECIFIC FROMISES. I AM SATISFIED THAT ALL OF THE COUNTRIES, INCLUDING OUR GERMAN COLLEAGUES, SHOWED A REMARKABLE DEGREE OF AGREEMENT, IN COMPREHENSION ON THE REQUIREMENTS FOR JOINT ACTION, AND AN INDICATION OF A WILLINGNESS TO CONSIDER WHAT EACH OF THEM SPECIFICALLY WOULD BE ABLE TO DO. I THINK THAT DID VERY MUCH APPLY TO OUR GERMAN COLLEAGUES. WE WILL HAVE TO SEE SPECIFICALLY HOW THAT WORKS OUT IN EACH INDICIDUAL CASE. Q: THE OECD STUDY ON CONCERTED ACTION STATES THAT IT IS UNLIKELY THAT OECD COUNTRIES CAN REACH FULL EMPLOYMENT BY 1980 AND THEY CAN ONLY REACH IT BY 1985 IF THEY DECIDE TO EXPAND THEIR GROWTH RATES IN 1979 AND THEY CAN ONLY KEEP UNEMPLOYMENT WHERE IT IS BY REACHING A FOUR PERCENT GROWTH RATE, IF THE BONN SUMMIT ISN'T GOING TO COME OUT WITH ANY QUANT IT I AT IV E TARGETS, WHAT KIND OF REASSURANCES ARE YOU GOING TO GIVE TO THE GROWING ARMIES OF THE UNEMPLOYED THAT THEY MAY GET SOME KIND'OF JOB BEFORE 1990, FOR EXAMPLE? At SCHULTZE: IN THE FIRST PLACE, WHAT I THINK IS VERY IMPORTANT IS THAT AT THIS MEETING, THERE WAS ADOPTED A FRAMEWORK OF ACTION, NOT SPECIFIC TARGETS COUNTRY BY COUNTRY, BUT A FRAMEWORK OF ACTION IN WHICH ALL OF OUR COUNTRIES AGREED UPON THE NECESSITY OF TAKING THE ACTIONS NECESSARY TO BEGIN MOVING BACK TO FULL EMPLOYMENT. I THINK THE FACT THAT THIS WAS WIDELY RECOGNIZED, AGREED UPON WITHOUT A DISSENT, IS IN ITSELF VERY IMPORTANT, NOT ONLY TO THOSE OF US WHO DEAL IN ECONOMIC POLICY, BUT GENERALLY TO WORKERS AND OTHERS WHO EITHER ARE UNEMPLOYED OR THREATENED BY UNEMPLOYMENT. IT IS THAT AGREEMENT UPON THE PRINCIPLES OF ACTION, RATHER THAN SPECIFIC PROMISES COUNTRY BY COUNTRY, AS I BELIEVE THE SECRETARY GENERAL INDICATED EARLIER IN HIS RESPONSE TO A SIMILAR QUESTION, THAT WE ARE DEALING NOT JUST WITH CHANGES BETWEEN NOW AND THE END OF 1978 OR THE END OF 1979, BUT WE'RE MOVING ON A NUMBER OF FRONTS TO SEE THAT GROWTH CAN BE IMPROVED AND THORUGH NOT ONLYAIMPROVED THE SHORT BUT IMPROVED NUMBER OFINPOLICIES ONRUN, A -6SUSTAINABLE BASIS. AND, AGAIN, FROM COUNTRIES WITH DIFFERENT INTERESTS AND DIFFERENT SITUATIONS THERE WAS REMARKABLE AGREEMENT ON THE KIND OF POLICIES THAT WE NEED. AND I THINK THAT WITHOUT TRANSLATING THAT INTO NUMEROLOGY, THIS ITSELF IS A VERY IMPORTANT DEVELOPMENT AND WILL, OVER TIME, BE TRANSLATED INTO SPECIFIC ACTIONS NEEDED TO MAKE IT WORK. 3: COULD YOU EXPLAIN WHY THE UNITED STATES WAS DISCUSSED SEPARATELY AND AT WHOSE SUGGESTION THIS WAS DONE? At I DON'T THINK THAT THE UNITED STATES WAS DISCUSSED SEPARATELY PER SE. IT CLEARLY WAS DISCUSSED SEPARATELY AS REGARDS THE ENERGY QUESTION. THAT IS NOT AT ALL SURPRISING, FOR THE ENERGY LEGISLATION WHICH HAS BEEN PENDING IN THE CONGRESS FOR 14 MONTHS HAS ON MANY OCCASIONS, NOT ONLY IN THE UNITED STATES BY THE ADMINISTRATION, BUT ALSO BY MANY OF THE FOREIGN COUNTRIES, BEEN POINTED TO AS A VERY, VERY IMPORTANT FACTOR. AS YOU KNOW, THE OBJECTIVE OF THAT LEGISLATION IS TO REDUCE THE DEPENDENCE OF THE UNITED STATES ON IMPORTED ENERGY. THE ACHIEVEMENT OF THAT GOAL HAS AN IMPACT ON ALL COUNTRIES, AND, THEREFORE, THE INTERESTS OF OTHER COUNTRIES IN OUR PASSING OF THAT LEGISLATION AND THUS IN MOVING TOWARD ACHIEVING THAT GOAL IS OF GREAT IMPORTANCE. WE, ON OUR OWN, REPORTED ON THE PROGRESS THAT WE THINK IS BEING MADE IN THAT REGARD, AND WE KNEW BEFORE WE CAME HERE THAT WAS A MATTER WE WOULD BE C'JESTIONED UPON AND ON WHICH WE WOULD HAVE TO COMMENT ON THE PART OF MANY COUNTRIES WHO WANTED TO PURSUE THIS. C: WAS THIS THE OUTSTANDING PROBLEM REGARDING THE UNITED STATES AT THIS CONFERENCE? A: BLUMENTHAL: I DON'T THINK THAT'S THE OUTSTANDING PROBLEM. THE OTHER PROBLEM THAT ALSO WAS MENTIONED WAS THE RATE OF INFLATION IN THE UNITED STATES. AND, AGAIN, WE WERE ABLE TO POINT TO THE POLICIES WHICH HAVE BEEN PUT INTO EFFECT IN THE UNITED STATES AND WHICH ARE NOW BEING IMPLEMENTED TO INSURE THAT THE RATE OF INFLATION IS BROUGHT IJJDER BETTER CONTROL AND THAT A DECELERATION IN THE RATE OF INCREASE OF PRICES OCCURS. Qt WHAT SPECIFIC AREAS OR ACTIONS OR PROGRAMS IN THE U.S. HAS THE U.S. IDENTIFIED AS FALLING WITHIN THE RESTRICTED PROGRAMS THAT MIGHT BE DEALT WITH IN THE POSITIVE POLICY? HAVE WE FACT •SO, GOT ..'E MIGHT ARE TO THE THOSE BE POINT A3LE THEADJUSTMENT TO OF SORT TAKE SAYING OF CARE THINGS THATOFWETHAT AS HAVE WELL CANSOME AND BE IN DONE IF THAT -7- UNILATERALLY OR ARE BILATERAL OR MULTILATERAL NEGOTIATIONS REQUIRED FOR THAT? At BLUMENTHAL: IN THE CASE OF THE UNITED STATES, WE HAVE, FIRST OF ALL, THE MAJOR POLICIES THAT WE MUST FOLLOW ARE THOSE OF CONTAINING INFLATION AND DEALING WITH THE ENERGY PROBLEM, SECONDLY, WE HAVE IN PLACE A SERIES OF PROGRAMS, INCLUDING ADJUSTMENT ASSISTANCE, THE EXPANDED ADJUSTMENT ASSISTANCE, IN ORDER TO INSURE THAT WORKERS ARE REIRAINED WHO LOSE THEIR J03S IN DECLINING INDUSTRIES AND THAT A PERIOD OF TRANSITION IS PROVIDED, SO THAT FOR INDUSTRIES THAT ARE IN DIFFICULTY, SO THAT INCREASING EFFICIENCY CAN BE ACHIEVED IN THESE INSTANCES IN THE UNITED STATES. AS FAR AS OUR COUNTRY IS CONCERNED, THESE ARE THE PRINCIPAL KINDS OF PROGRAMS THAT WE WOULD RESORT TO. Qt (NBC t.'EWS):MR.BOSWORTH OF THE COUNCIL OF WAGE AND PRICE STABILITY FORECAST A RECESSION UfLESS SOMETHING IS DONE ABOUT INFLATION THIS YEAR. NOW I REALIZE THAT PEOPLE WHO HOLD THE JOB THAT HE DOES ARE INFAMOUS FOR HOLDING PESSIMISTIC VIEWS. BUT IN YOUR OWN VIEW, IS THERE ANY CHANCE OF A RECESSION IN THE NEAR FUTURE IF INFLATION IS UNIMPEDED? A:(SCHULTZE) :YES. THAT'S THE NICE SHORT AN3WZR.LET ME ELABORATE A LITTLE BIT. IN THE FIRST FOUR MONTHS OF THIS YEAR, CONSUMER PRICES IN THE U.S. WERE RISING APPROXIMATELY, ALMOST TEN PER CENT A YEAR. FIRST, WE THINK IT IS VERY LIKELY THAT THAT RATE OF INFLATION WILL BE BROUGHT DOWN BECAUSE IT HAS A NUMBER OF TEMPORARY FACTORS IN IT. SECONDLY, IN THE LONGER RUN, LOOKING THEN BEYOf© 1979 AND 1980 THAT UNLESS WE CONTROL THE RATE OF INFLATION, FIRST TO PREVENT IT FROM ACCELERATING, THAT IS TO GET THE ADVANTAGE OF THOSE TEMPORARY FACTORS COMING-9FF WHICH WILL BRING US DOWN TO A LOWER RATE OF INFLATION, AND THEN PREVENT IT FROM ACCELERATING, IF WE DON'T DO THAT, I THINK THEN ONE MUST TAKE VERY SERIOUSLY THE POSSIBILITY OF RISING INTEREST RATES AND REDUCED CONFIDENCE TO THE POINT WHERE THE POSSIBILITY OF AT LEAST A GROWTH RECESSION BECOMES POSSIBLE, IF NOT SOMETHING EVEN MORE THAN THAT. 3D I WOULD AGREE WITHOUT TRYING TO PUT NUMBERS ON IT THAT IT IS VERY, VERY IMPORTANT TO CONTROL INFLATION, NOT JUST FOR THE SAKE OF CONTROLLING INFLATION, BUT THAT TO RESPONSIBLY LITERALLY, THROUGH RECESSION DO WE KEEPS ITTHE DOINAND THIS THE TOEFFECT AANDAVOID EVEN WAY--WHICH ECONOMY IN IN ON WORSE. A COORDINATION THROUGH WAY—AND CONFIDENCE, MOVING MAINTAINS I THINK THEWE FORWARD MONETARY WITH THINK TO IT'S MODERATE AVOID POLICIES BUT VERY IT SYSTEM DOES ISAGROWTH, IMPORTANT GROWTH POSSIBLE OFITAND -8- GOVERNMENTAL ACTION AND VOLUNTARY DECELERATION. ELABORATING ON THAT SHORT ANSWER, YES, IT IS A PROBLEM WF HAVE TO WORRY ABOUT. IT IS VERY IMPORTANT TO BRING INRATION DOWN. WE THINK WE HAVE A PROGRAM TO DO IT. WE HAVE BEGUN TO GET COOPERATION FROM A NUMBER OF FIRMS IN DECELERATING THEIR PRICES. QUITE FRANKLY, NEXT WE NEED TO MAKE SURE WE GET COOPERATION FROM LABOR IN THE MAJOR CONTRACTS WHICH WILL BE COMING UP LATER THIS YEAR, BUT PARTICULARLY IN L979 IN ORDER TO ACHIEVE THAT OBJECTIVE. Qt WHAT TIME FRAME ARE YOU TALKING ABOUT? ARE YOU SAYING IT IS POSSIBLE BY THE END OF THE YEAR? Al(SCHULTZE)t NO, I'M NOT TRYING TO PUT IT INTO A TIME FRAME. I'M TRYING TO MAKE THE GENERAL POINT WITHOUT TRYING TO FORECAST THE SPECIFIC TIME. THERE IS A RELATIONSHIP BETWEEN CONTROLLING INFLATION AND KEEPING GROWTH GOING. BUT I CAN'T PUT A TIME ON IT. I THINK THERE'S NOT SOMETHING I'M TALKING ABOUT L980 OR L98L. I'M TALKING ABOUT CLOSER TO HOME THAN THAT, BUT I'M NOT TALKING NEXT MONTH OR NECESSARILY SEPTEMBER. BUT IT IS SOMETHING OVER THE MEDIUM TERM WE DO HAVE TO WORRY ABOUT. MY COLLEAGUES BOTH WARN ME I SHOULD MAKE IT CLEAR I AM NOT FORECASTING A RECESSION. I AM MAKING A CONDITIONAL POINT THAT IN ORDER TO KEEP GROWTH GOING IN THE U.S. IT IS NECESSARY TO CONTROL INFLATION. Qt (NBC NEWS)t WOULD YOU NOTE THAT THERE IS A POSSIBILITY OF RECESSION IF INFLATION CONTINUES? At(SCHULTZE):.IF INFLATION IS NOT CONTROLLED. ?: (L.A.TIMES) t MAY I ASK A GENERAL FOLLOW-UP? IN VIEW OF THE DISCUSSION THE LAST FEW DAYS, WHAT KIND OF GENERAL ASSESSMENT ARE WE GOING TO HAVE OF THE ECONOMIC OUTLOOK FOR THE OECD AS A WHOLE BY THE TIME YOU MEET NEXT JUNE? A: (BLUMENTHAL) t I WOULD SAY THAT THE DEGREE OF CONSENSUS THAT HAS BEEN DEVELOPED THROUGH VARIOUS MEETINGS, AND SPECIFICALLY HIGHLIGHTED AT THIS MEETING, THAT CONCERTED, COORDINATED ACTION ON A VARIETY OF FRONTS IS NEEDED BY DIFFERENT COUNTRIES DEPENDING ON THEIR INDIVIDUAL CIRCUMSTANCES, IN SOME INSTANCES TO CONTROL INFLATION AND TO MAKE THAT A PRIORITY, IN OTHER INSTANCES TO INSURE ADEQUATE AND ACCELERATED GROWTH. AT THE SAME TIME, THE COMMITMENT WHICH HAS NOT BEEN MENTIONED HERE THIS EVENING BUT WHICH IS VERY IMPORTANT OF EVERYBODY --ALL OF THE OECD NATIONS, TO INSURE A SIGNIFICANT RESULT IN THE TRADE NEGOTIATIONS, SO AS TO COUNTERACT ANY TENDENCIES AND TOWHICH PROMOTE TOGETHER INCREASING WOULD WORLDTOWARD INDICATE TRADE,PROTECTIONISM, THAT THE ALL OF RECOVERY THESE THINGS WE -9- HAVE SEEN SINCE THE LAST TIME WE MET, IN THE OECD COUNTRIES WILL CONTINUE AND WILL CONTINUE AT A FASTER RATE THAN WOULD BE THE CASE IN THE ABSENCE OF THIS KIND OF OONSENSUS AND THIS KIND OF CONCERTED ACTION. I THINK, THEREFORE, THAT ONE OF THE GENERAL POINTS THAT ONE COULD MAKE ABOUT THE RESULT OF THIS MEETING IS THAT THIS CONSENSUS GIVES ONE GOOD CONFIDENCE THAT THERE WILL BE A DEGREE OF ACCELERATED GROWTH, THAT THERE WILL BE COOPERATION IN CONTROLLING INFLATION AND IN CONTINUED, THEREFORE, STABILITY IN THE EXCHANGE MARKETS, AND IN THIS WAY, GENERAL ECONOMIC CONDITIONS HAVE A GOOD CHANCE OF Q: THANK YOU, MR. SECRETARY. IMPROVING. For Release Upon Delivery Expected at 9:00 a.m. STATEMENT OF DANIEL I. HALPERIN, TAX LEGISLATIVE COUNSEL DEPARTMENT OF THE TREASURY, OFFICE OF TAX POLICY BEFORE THE SUBCOMMITTEE ON TAXATION AND DEBT MANAGEMENT OF THE SENATE FINANCE COMMITTEE June 19, 1978 Mr. Chairman and Members of the Subcommittee: We welcome the opportunity to present the Treasury Departments views on the 12 miscellaneous bills to be considered by your Subcommittee. The most far-reaching and important of these bills is S. 3134 (the only one of the 12 which has not been passed by the House) and I want to devote the bulk of my statement to a discussion of the Departmental position on that bill. The Treasury's views on the other 11 bills are summarized at the end of my statement and fully described in the appendix. However, before turning to S. 3134, I would like to comment briefly on what we see as the purpose to be served by consideration of these miscellaneous bills. It is extremely important to have a forum for the examination of legislative proposals that might bear on only one of the many sectors of our society; proposals that might otherwise not receive adequate attention from Congress. The existence of such a forum encourages continuous review of the law by both the Internal Revenue Service and groups in the private sector such as the American Bar Association and the American Institute of Certified Public Accountants. This continuous review promotes an atmosphere in which necessary corrective changes may be identified and enacted expeditiously. On the other hand, we urge extreme caution in the use of the miscellaneous bill procedure to create special exceptions to generally applicable rules for particular taxpayers. Opinions may differ as to whether such relief is B-986 - 2 equitable in the particular case involved. However, we should all recognize that special exceptions inevitably increase the complexity of the Code, invite other taxpayers to seek similar relief and, unless scrupulously drafted, may create new potential for abuse. As noted in the Appendix, the Treasury opposes H.R. 1920 and H.R. 2984 on their merits; but even if you disagree with us we urge the Subcommittee to consider these other factors — complexity and potential for abuse -- before approving these proposals. The guiding principle for the Treasury in our review of these miscellaneous bills is the continuing effort to further simplicity,' as well as equity, in the tax law. Thus, while we continue not to raise any objections to H.R. 5103, we are disappointed in the industry reaction to our alternative suggestion that warranty adjustments for taxes be eliminated in favor of a reduction in the original tax on tires.. I have read H.R. 5103 and the background material a number of times, and I will readily admit that I do not fully understand all its ramifications. If it is at all possible to eliminate a substantial administrative burden for both the IRS and the industry without an overall increase in tax, we should push as hard as we can to see if it is feasible. Let me now turn to S. 3134. This bill would provide an exemption from Federal income taxes for years 1970-77 for statutory subsistence allowances received by certain State police officers. The bill is intended to reverse as to prior years, the result of the November 1977 Supreme Court decision in Kowalski holding that meal allowances paid by New Jersey to its State troopers are includible in income. On the merits there is no justification for treating a portion of compensation as tax-free merely because it is designated as a subsistence allowance. Such a special tax exemption would be unfair to the overwhelming majority of American workers who must pay tax on the compensation out of which they buy their meals and meet their other subsistence needs. S. 3134 would recognize this by not allowing tax exemption for the future. Further, it allows tax exemption for 1970-76* only to those police officers who claimed the * For 1977, the relief would be available to all State police who received subsistence allowances. - 3 exclusion in a tax return filed prior to the Kowalski decision. The case for the bill must then rest on the supposed unfairness of applying the Kowalski decision for prior years to those who acted as if the subsistence allowance was tax exempt. In our opinion there is no support for this position. First, it must be understood that the idea that State troopers1 meal allowances are includible in income is not new. In 1954 Congress enacted an exemption for State and local police subsistence allowances of up to $5 a day. Within a few years, Congress found that amounts which constituted ordinary police salaries had been designated as subsistence allowances to obtain the benefits of the exemption. The Senate Finance Committee reported that a number of States and localities had altered, or were in the process of altering, the form of payment of compensation to their police officials in order to maximize utilization of the exemption. In 1958 the Finance Committee concluded that there was "no reason to provide what in effect is likely eventually to amount to a $5 a day tax exclusion for police officials." The Committee believed that the exclusion was "inequitable because there are many other individual taxpayers whose duties also require them to incur subsistence expenditures regardless of the tax effect." Therefore, to "bring the tax treatment of subsistence allowances for police officials in line with the treatment of such allowances in the case of other taxpayers," the Committee recommended that the exclusion be repealed. Congress promptly followed this advice. Second, the IRS has consistently taken the position that subsistence allowances were taxable. While it was not successful in several courts of appeal, the U.S. Court of Appeals for the First Circuit upheld the IRS position as long ago as 1969. Ever since 1970, the Internal Revenue Service has required States to withhold income taxes from State troopers' meal allowances and such taxes have been withheld. State troopers who owe taxes based on the Kowalski decision owe such taxes only because they claimed refunds of taxes withheld on meal allowances. Those refunds were claimed in disregard of the Internal Revenue Servicefs longstanding position. Most of the refunds were claimed by State troopers in New Jersey even though New Jersey troopers were - 4 aware that the IRS was contesting their position and were advised by their own association in 1974 to set aside additional money to pay income taxes that might be due. If the Supreme Court decision in Kowalski imposes hardship by requiring, in effect, that the refunds be repaid to the Federal Treasury, the risk of such hardship was voluntarily chosen. Third and most important, S. 3134, if enacted, would set a precedent which has very serious implications for administration of the tax law. Providing a tax exemption for only those allowances received in 1970 through 1976 for which tax refunds were claimed would provide about $6 million, all of which would go to State troopers who chose not to follow the Internal Revenue Service's interpretation of the law and most of which would go to State troopers in New Jersey.* We cannot administer the tax system if taxpayers who unsuccessfully contest an IRS position are liable for taxes only for years following the court decision. This is unfair to those who do not contest the position and it encourages everyone to take aggressive positions on their returns since they have nothing to lose and everything to gain by doing so. It should go without saying that we have sympathy for the plight of the New Jersey trooper but it is inequitable to expect taxpayers in the other 49 States to bail them out. As suggested in a New York Times editorial of May 18, 1978, "A fairer solution would be for New Jersey to grant the troopers bonuses pay raises in the o or O retroactive o amount of their tax debts." * Providing a tax exemption for all allowances received in 1977, as S. 3134 would also do, would provide an additional $2 million to State troopers in about 16 States. Summary of Treasury Department Positions 1- s» 3134 (police officer - subsistence allowances) — Opposed 2- H.R. 810 (foreign travel — government officials) — Not opposed in principle. Suggests limit to coach air fare 3. H.R. 1337 (constructive sales prices - trucks) — Supports. Suggests delay in effective date. 4. H.R. 1920 (repayment of liquor excise taxes) — Opposed. 5. H.R. 2028 (home production of beer and wine) — Not opposed, 6. H.R. 2852 (crop dusters) -- Supports refund to crop sprayer if farmer waives right in writing. 7. H.R. 2984 (trailers for farm use) -- Opposed. 8. H.R. 3050 (accounting for sale of magazines) — Supports in principle but recommends modification in treatment of prior year's adjustment for magazines. 9. H.R. 5103 (tire warranty adjustments) — Does not oppose. 10. H.R. 6635 (retirement bonds) — No objection if certain modifications are made. 11. H.R. 8535 (child care payments to relatives) — Not opposed 12. H.R. 8811 (Tax Court judge) — Supports. Appendi Treasury Department Recommendations on 11 Bills to be Considered by Subcommittee on Taxation and Debt Management 2. H.R. 810. The Tax Reform Act of 1969 added a provision to the Code (section 4941) which in general prohibits certain transactions between private foundations and certain "disqualified persons," by imposing a graduated series of excise taxes on the disqualified person (and in certain circumstances on the foundation manager). Government officials are "disqualified persons" for this purpose except for certain specifically set forth transactions including the payment of expenses of domestic travel. The bill would provide an additional excepti for payment or reimbursement of foreign travel expenses of a government official by a private foundation. The Treasury Department recommends that H.R. 810 be amended to limit the permitted amount of reimbursable transportation expenses to the cost of the lowest coach or economy air fare charged by a commercial airline. The recommended change would make the reimbursable amounts under the bill consistent with the limitation on deductions for attending foreign conventions under the Administration's 1978 tax program. Treasury would not oppose H.R. 810 if this change were made. - 2 - 3. H.R. 1337 Present law provides that for purposes of computing a manufacturer's excise tax on sales at retail of trucks, buses, and trailers the taxable price is the lower of (1) the price for which the article is sold or (2) the highest price at which competing articles are sold to wholesale distributors in the ordinary course of trade. If a manufacturer has an established practice of selling taxable articles in substantial quantities to wholesale distributors, the tax on his sales at retail ordinarily will be computed upon the highest price for which similar articles are sold by him to wholesale distributors. Where the manufacturer does not ordinarily sell trucks and trailers to wholesale distributors (and few do), the constructive price for sales at retail is 75% of the manufacturer's retail selling price. However, this constructive price cannot be less than the manufacturer's cost where the manufacturer has an established retail price, and cost plus 10% where (as in the case of custom work) he does not have an established retail price. H.R. 1337 would eliminate the use of an individual manufacturer's costs (or cost plus 10%) in determining a constructive price in the situation where the 75% rule is now applied, i.e., sales at retail where the manufacturer does not sell such articles to wholesale distributors, in addition, - 3 even if the manufacturer does sell such article to wholesale distributors, he would be required to adjust the price of his retail sales by the ratio generally prescribed for manufacturers who do not sell to wholesalers. The Treasury Department supports H.R. 1337. The not less than cost rule produces uncertainty at the time of sale as to the amount of the manufacturer's excise tax liability. Computing "costs" is always complicated, especially the problem of allocating overhead costs. A straight percentage of retail price would greatly simplify matters for the trade and the Internal Revenue Service. The Treasury Department recommends that the effective date of the bill be September 30, 1978 to eliminate the possible need to adjust taxes on sales made before enactment of the bill. Even though the not less than cost rule is deleted, we recommend repetition of the explanation in the report on H.R. 1337 by the House Committee on Ways and Means (H.R. No. 95-976) that the rule may continue to be prescribed for constructing a taxable price where a person makes and uses a taxable item (sec. 4218 of the Internal Revenue Code). Such item may be a specialized unit which is never sold, so that no market price is available from which to construct a manufacturer's price. In this case, cost of production is the °nly realistic tax base. - 44. H.R. 1920 The proposed bill would require the Treasury Department to repay the amount of internal revenue tax paid (or determined and customs duty paid on distilled spirits, wine, rectified products, and beer, which, while being held for sale, are lost, rendered unmarketable, or condemned by duly authorized official by reason of fire, flood, casualty, or other disaster, or breakage, destruction, or other damage (excluding theft) resulting from vandalism or malicious mischief. No reimbursement would be made for tax losses of less than $250 per occurrence, or for losses covered by insurance. Present law provides for similar payments for both alcoholic beverages and tobacco products (without the $250 minimum requirement) , only in the case of a "major disaster" a declared by the President. The Treasury Department is opposed to H.R. 1920. The dollar a business invests in inventory is a dollar of cost irrespective of the factors going to make up the cost, whether such factors be raw materials, wages, transportation, or taxes. Past Congressional policy as to casualty losses has recognized this fact and, as a consequence, losses by handlers of alcoholi beverages, except in the case of disasters of extraordinary severity, have been treated as ordinary business hazards to be borne by the holder of the beverages or his insurance company. - 5 - H.R. 1920 woul4 provide an exception to this general policy by, in effect, having the Federal government provide free insurance to dealers in alcoholic beverages for the portion of their inventory reflecting internal revenue tax and customs duty. By so doing, the Federal government would be treating those holding alcoholic beverages for sale on a more favorable basis than other merchants selling products subject to excise taxes and all merchants selling products not subject to excise taxes. H.R. 1920 would be difficult to administer. It would be quite difficult, often impossible, to make a factual determination as to the amount of loss by vandalism or malicious mischief as distinguished from theft or mishandling. And in the case of civil disorders, the circumstances often would make it virtually impossible to segregate the cause of losses. The present "major disaster" provision also provides dealers in alcoholic beverages and tobacco with free insurance that is not given to dealers in other products, both products subject to excise taxes and those not taxed. Since there is no reason why dealer's losses of alcoholic beverages and tobacco products should be treated differently than losses of other products, repeal of the "major disaster" provision is indicated. - 6 5. H.R. 2028 Under present law, the head of any family may, after registering, produce up to 200 gallons of wine a year for family use without payment of tax. An individual who is not the head of any family is not covered under this exemption. Existing law has no provision which authorizes the home production of beer. H.R. 2028 would permit any adult (an individual 18 years of age or older) to produce specified amounts of wine and beer for personal or family use and not for sale without payment of tax. Individuals would have to register before producing tax free beer and could not have more than 30 gallons of beer on hand at any time. The exemption under Federal law would not serve to authorize the home production of beer contrary to State law. The Treasury Department has no objection to the enactment of H.R. 2028. The deletion of the present law require- ment for registration by producers of wine for personal or family use reflects the fact that registration has proven of little use to the Bureau of Alcohol, Tobacco and Firearms and is burdensome to the public. However, for enforcement and revenue protection purposes, registration and the inventory limitation are necessary in the case of home brew, since the process entails the production of a mash fit for distillation. - 7 - 6. H.R. 2852 Under present law, when gasoline or special fuels are used on a farm for farming purposes by a custom operator, credit or refund of the tax on the fuel so used can be claimed only by the owner, tenant or operator of the farm. The bill would revise the law to provide that an aerial applicator (crop duster, etc.) would be entitled to the credit or refund of gasoline and special fuels excise taxes used in aerial applications on a farm. The restriction of the farm fuel tax refund to the owner, tenant or operator of a farm was intended by the Congress to assure that the farmer received the benefit of the refund. It was felt that if the refund were given directly to the custom operator, the farmer would not benefit through a lower price for the custom work. Over the years since the enactment of the credit or refund provision, it has been argued that the farmer hasn't gotten the benefit of the refund for custom work because the custom operator doesn't give him the information as to gallons used so that he (the farmer) can claim the refund. The instant bill would meet this argument by permitting an aerial applicator doing custom work to apply for the farm fuel refund without any consent from or notification to the farmer. This would not be consistent with the original intent of the Congress of making sure that the farmer received the benefit of the credit or refund of the tax on fuel used by the custom operator. - 8 - The Treasury Department would support H.R. 2852 if it were amended so that the farmer would have to waive in writing to the aerial applicator his right to a refund. This would put the farmer on notice as to the existence of the credit or refund provision and permit him to obtain the benefit of the credit or refund indirectly through a reduction in the fee paid to the aerial applicator or to apply himself for the credit or refund. The waiver provision was in a bill ordered reported out by the Ways and Means Committee in the mid-1960 's. That bill, although supported by Treasury and the Department of Agriculture, was never enacted. The Treasury Department also suggests that H.R. 2852 be extended to cover all custom work, not just aerial application, since plowing and harvesting is done by custom operators. - 9 - 7. H.R. 2984 The bill would exempt from the 10% manufacturer's excise tax on trucks, truck trailers, and buses/those trailers or semitrailers which are suitable for use with a towing vehicle having a gross vehicle weight of 10,000 pounds or less and which are designed to be used for farming purposes or for transporting horses or livestock. Provision also is made for refund of the tax to dealers holding tax-paid trailers exempted by the bill which they hold for sale on the day after the date of enactment of the bill. The Revenue Act of 1971 (Public Law 92-178) exempted from the manufacturer's excise tax trucks with a gross vehicle weight of 10,000 pounds or less and trailers and semitrailers with a gross vehicle weight of 10,000 pounds or less if suitable for use with a vehicle having a gross vehicle weight of 10,000 pounds or less. The proposed bill would remove the present 10,000 pound limit for the exemption of trailers and semitrailers provided they were designed to be used for farming purposes or for transporting horses and other animals. Because the trailers proposed to be exempted would have a gross vehicle weight in excess of 10,000 pounds, the exemption would be accorded to trailers with a gross vehicle weight at which single unit trucks are taxable. The proposed exemption for trailers thus would constitute an obvious discrimination against single unit trucks in the 10,000 to 20,000 Pound class. - 10 - The bill also would create a dual standard for trailers over 10,000 pounds gross vehicle weight which are suitable for use with pickup trucks. Those designed for farming purposes or the hauling of animals would be exempt, while trailers of the same capacity designed for hauling general merchandise, or supplies and equipment for mechanics, would continue to be taxable. The Treasury opposes H.R. 2984 because the bill would discriminate against single unit trucks and non-farm trailers and semitrailers of the same carrying capacity. It could also be expected that there would be problems in differentiating trailers and semitrailers "designed to be used for farming purposes" from similar vehicles designed for the carriage of general cargo. - 11 - 8. H.R. 3050 To ensure that retail outlets have an adequate number of copies of magazines, paperback books and records, publishers and distributors often distribute more copies of a magazine, book or record than it is anticipated the retailer can sell. When the retailer has sold as many of the particular items as will be likely, he returns the unsold merchandise to the publisher or distributor. The Internal Revenue Service has taken the position that accrual basis publishers and distributors must include the sale of the magazines, paperback books, and records in income when they are shipped to the retailers and may exclude from income the returns only when the merchandise is actually returned by the retailer during the taxable year. The bill would allow accrual basis publishers and distributors of magazines, paperbacks and records to elect to exclude from income amounts attributable to merchandise returned within a specified period of time after the close of the taxable year in which the publisher or distributor shipped the merchandise to retailers. The bill requires publishers and distributors of paperbacks and records who elect the new method to establish a suspense account to avoid a double deduction for the initial year under - 12 - the new method. In the case of returns of magazines, the bill permits taxpayers to amortize the deduction attributable to actual returns from prior years sales in the year the new method is elected over a five-year period. The Treasury Department believes that the special relief provided by the bill should be allowed only to those taxpayers who, in the year they elect the new method of accounting, establish a suspense account. The suspense account procedure essentially allows the new method of accounting for the future while delaying the deduction for the additional amount the taxpayer would have deducted for all past years under the new method as opposed to the old until there is a termination or decline in business. If this approach is not taken there would be an additional revenue loss ($86 million for books and records if the entire deduction were allowed in the year of change) which could prevent the adoption of what we believe are sound accounting procedures for those industries and others which may have similar problems. Current allowance of deductions denied in prior years may well provide a windfall gain to current owners since the tax burden may well have been borne by customers or prior owners. However, in the case of an election to account for magazine returns under the bill, if the Subcommittee believes amortization of the transitional adjustment is preferable to the - 13 establishment of a suspense account, the Treasury Department recommends that the normal ten-year amortization period for such an adjustment be used instead of the special five-year amortization period provided by H.R. 3050. The TreasuryDepartment would oppose amortization of the transitional adjustment for publishers and distributors of paperback books and records who elect the new method of accounting. - 14 9. H.R. 5103 The bill would provide credit or refund to the manufacturer or importer of the excise tax on tread rubber destroyed or scrapped in the retreading or recapping process or used in retreading or recapping a tire which is used or sold for purposes for which new tires may be used or sold tax free. Provision is made for credit or refund to the manufacturer or importer of the taxes on tread rubber or on new tires where the sales price of the recapped or new tire is later adjusted pursua to a warranty or guarantee. In addition, the bill modifies the statute of limitations so that claim for a credit or refund of the tread rubber or new tire taxes can be filed for a period of one year after the warranty or guarantee adjustment is made. Finally, the bill imposes the tax on tread rubber used in a foreign country to recap or retread tires which have been export from the United States and then reimported into the United State The Treasury Department has no objection to the enactment of H.R. 5103. The credit or refund provisions for tread rubber are intended to make the tax treatment of this product equivalent to the tax treatment of new tires. Because the tread rubber loses its identity when attached to a tire, it has not been possible under present law to grant credit or refund of tread rubber tax when the retreaded tire has been exported, sold to a - 15 - State or local government, or sold in any other transaction for which a new tire may be sold tax free. A tire which has been taxed in the United States can be exported and reimported into the United States without payment of the tire tax. If the tire has been retreaded, the tread rubber tax is not due because the tread rubber is considered to have lost its identity when attached to the retreaded tire. United States retreaders located near Canada or Mexico have complained that some United States dealers are shipping domestical used tires to Canada or Mexico for retreading to take advantage of this tax treatment. The bill would rectify this competitive inequity. The section granting a credit or refund of tax when the price of a new tire is readjusted pursuant to a warranty or guaranty is intended to codify procedures which have been permitted for a number of years even though present law limits the credit or refund of tax for warranty adjustments of products subject to manufacturers excise taxes to cases where the tax is an ad valorem tax. The bill would grant a credit or refund of tax proportionate to the price adjustment made with the ultimate consumer where the manufacturer's quarantee runs to the ultimate consumer; and proportionate to the price adjustment made with the immediate vendee where the manufacturer's guarantee runs only to his immediate vendee. In addition, a new approach is included in the bill whereby provision is made for the granting of a credit or refund for warranty adjustments of an average - 16 amount per tire based on some overall method (e.g., a sampling method) rather than computation on a tire-by-tire basis. The Ways and Means Committee report (H. Rep. No. 95-916) notes that this procedure would not permit an adjustment in the excise tax prior to the time the warranty or guarantee adjustment is made (or deemed to have been made) to the ultimate consumer. The extension of a credit or refund of the tread rubber tax to cases where the retreaded tires are adjusted pursuant to a warranty is consistent with the treatment of new tires. Since the guarantee on a tire may last for the life of the tire, a manufacturer could be prevented from obtaining refund or credit of tax for a warranty adjustment by the fact that section 6511 of the Code requires claims for overpayment of tax to be filed within 3-years from the time the returns wer filed or 2-years from the time the tax was paid, whichever expires the later. Accordingly, the bill proposes to modify the statute of limitations as indicated above as to allowance for claims for refund or credit or overpayment of tire or tread rubber taxes in the case of warranties. Some private brand dealers have requested that where the manufacturer's warranty or guarantee is extended only to his immediate vendee there be deleted the requirement in the bill that the prior granting of an adjustment to the ultimate consumer is a prerequisite to the allowance of a credit or refund of tax to the manufacturer or importer. Rulings under - 17 - present law have held that where the tire warranty runs only from the manufacturer to his immediate vendee, the adjustment by the manufacturer need only be made with his immediate vendee. This interpretation is based on the general rule for price readjustments in section 6416(b)(1) of the Code which requires the manufacturer, or importer, to make an adjustment with his immediate vendee to obtain a proportionate credit or refund.of tax. One way of retaining the general principle set forth in the bill of requiring adjustment of tax to the ultimate consumer before the manufacturer can claim credit or refund would be to state in your committee report that where the private dealer's warranty to the ultimate purchaser is as good or better than the manufacturer's warranty to the dealer, it then will be assumed that the required adjustment has been made to the ultimate consumer when the immediate vendee makes his request for credit or refund from the manufacturer. The effective date specified in the bill is April 1, 1978. This is the effective date of Part 1 of Revenue Ruling 76-423. Part 1 of this ruling specifies that the credit or refund of tax to the tire manufacturer for a warranty adjustment is to be proportional to the reduction in the price of the replacement tire that the manufacturer sells to his immediate vendee. - 18 The tire industry's practice where the tire warranty runs from the manufacturer to the ultimate consumer has been to take credit or refund of tax based on the proportionate reduction by the dealer in the price of the replacement tire to the ultimate consumer even though the manufacturer may reduce the price (exclusive of tax) of the replacement tire to the dealer by less than the proportionate reduction to the consumer, or perhaps not even reduce the price to the dealer at all. The bill would give statutory sanction to this practice and the April 1, 1978 effective date would insure that Part 1 of Rev. Rul. 76-423 would not be effective for the period of time between April 1, 1978 and the enactment of the bill. - 19 10. H.R. 6635 The bill would amend the Second Liberty Bond Act to allow the Secretary of the Treasury, with the approval of the President, to increase the investment yield on outstandin United States retirement plan bonds and individual retiremen bonds for each interest accrual period beginning after September 30, 1977, so that the investment yield on such bon is consistent with the investment yield on Series E savings bonds. Treasury would support H.R. 6635 if it is amended (1) to permit the interest rate on already issued retirement bonds to be changed to match the interest rate on new retirement bonds rather than to match the interest rate on Series E savings bonds and (2) to change the effective date to permit an increase in the investment yield for interest accrual periods beginning after the date of enactment rather than for periods beginning after September 30, 1977. The bill will help to assure that the rate of return to holders of retirement plan bonds and individual retirement bonds is maintained at a level commensurate with the rate of return on new retirement bonds. It will help maintain the competitiveness of retirement plan bonds and individual retirement bonds with other investment vehicles and, therefo will assist the Treasury in the exercise of its borrowing authority. - 20 11. H.R. 8535 Under present law, the child care credit is not allowed for amounts paid to a relative unless (a) neither the taxpayer nor the taxpayer's spouse is entitled to a dependency personal exemption deduction with respect to that relative, and (b) the services provided by the relative constitute "employment" within the meaning of the Social Security taxes definition. The bill would allow the child care credit for amounts paid for child care services performed by relatives of the taxpayer whether or not such services constitute "employment" within the meaning of the Social Security taxes definition of that term, provided neither the taxpayer nor the taxpayer's, spouse is entitled to a dependency personal exemption deduction with respect to that relative. The child care credit will not be allowed for amounts paid to a child (or stepchild) of the taxpayer under age 19. The Treasury Department does not oppose H.R. 8535. - 21 - 12. H.R. 8811 Under present law if a United States Tax Court judge elects to come under the Tax Court retirement system, he is required to make an irrevocable election which bars him from ever receiving any benefits under the Civil Service retirement system for any nonjudicial Federal service performed before or after his election is made, even though he served as a Tax Court judge for less than the minimum 10-year period required to qualify for retired pay under the Tax Court retirement system. The bill would amend section 7447 to allow a Tax Court judge to revoke an election to receive retired pay under the Tax Court retirement system at any time before the first day on which retired pay would begin to accrue with respect to that individual. The bill would also provide that no Civil Service retirement credit would be allowed for any service as a Tax Court judge, unless with respect to such service the amount required by the Civil Service retirement laws has been deposited, with interest, in the Civil Service Retirement and Disability Fund. The Treasury Department supports H.R. 8 811. June, 1978 BIOGRAPHICAL NOTES C. FRED BERGSTEN ASSISTANT SECRETARY FOR INTERNATIONAL AFFAIRS C. Fred Bergsten, 37, of Annandale, Va., signed the oath of office as Assistant Secretary for International Affairs on March 31, 1977, following confirmation March 29 by the Senate. He was nominated by President Carter on February 7 and was Acting Assistant Secretary from the outset of the Carter Administration. Dr. Bergsten graduated magna cum laude in 1961 from Central Methodist College in Missouri. He received M.A., M.A.L.D., and Ph.D. degrees from the Fletcher School of Law and Diplomacy, where he majored in international economics and international relations. Dr. Bergsten served President Carter as an advisor on international economics during the Presidential campaign, and was in charge of all aspects of international economic policy during the transition period. Shortly after President Carter's inauguration, Dr. Bergsten accompanied Vice President Mondale to all of the major European capitals and Tokyo. As Assistant Secretary for International Affairs, Dr. Bergsten has responsibility for the formulation and execution of a wide range of U.S. international economic and financial policies, including U.S. participation in such international development lending institutions as the World Bank. Dr. Bergsten was a Senior Fellow at the Brookings Institution from 1972 until joining the Carter/Mondale transition team and then the Department of the Treasury. He was a Visiting Fellow at the Council on Foreign Relations during 1971-72 and 1967-1969; Assistant for International Economic Affairs to Dr. Henry A. Kissinger at the National Security Council during 1969-1971; and B-987 an International Economist at the Department of State during 1963-1967. - 2 An energetic and prolific writer, Dr. Bergsten is the author or co-author of eight books and more than sixty articles on a wide range of international economic and monetary subjects. His The Dilemmas of the Dollar; The Economics and Politics of U.S. International Monetary Policy was published by the Council on Foreign Relations in early 1976. His latest volume, American Multinationals and American Interests. was published recently by the Brookings Institution. Dr. Bergsten was also the chief author of The Reform of International Institutions, a study for the Trilateral Commission, an organization dedicated to bringing about greater cooperation and new initiatives in North America, Europe, and Japan. Among his many honors, Dr. Bergsten is listed in Who's Who in America and was named one of Time Magazine's "200 Young American Leaders" in 1974. While at Brookings, he was a frequent witness before Congressional committees, testifying on such subjects as international monetary reform, overall U.S. foreign economic policy, commodities, trade, and international financial institutions. Dr. Bergsten was born on April 23, 1941, in Brooklyn, New York. He is married to Virginia Wood Bergsten. They have a son, Mark David. VtpartmentoftheTREASURY HNGTGN,D.C. 20220 TELEPHONE 566-20*1 June 19, 1978 FOR IMMEDIATE RELEASE RESULTS OF TREASURY'S WEEKLY BILL AUCTIONS Tenders for S 2,200 million of 13-week Treasury bills and for $3,400 million oi 26-veek Treasury bills, both series to be issued on June 22, 1978, were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: ANGE OF ACCEPTED COMPETITIVE BIDS: 13-week bills maturing September 21. 1978 Discount Rate Price 98.318 98.312 98.315 High Low Average Tenders at t Tenders at _ . V- »S . . C — 6.654% 6.678% 6.666% *s i. -L. < w N~ »% ^ scstcn -«ev :crtc Philadelphia Cleveland Richmond Atlanta Chicago -t. Louis Minneapolis Kansas City Dallas ia n Francisco treasury TOTALS 6.86% 6.89% 6.87% Discount Investment Price Rate Rate 1/ 96.351 7.218% 7.60% 96.342 96.346 7.236% 7.228% 7.61% 7.61% e for the 13-week bills were allotted 22% e for the 26-week bills were allotted 86% v. • - ID: ation Investment Rate 1/ 26-week bills maturing December 21f 1978 r\. e c e i. v e > $ 16 190,000 3,534 ,455,000 17.,410,000 40 280,000 29 ,705,000 22 ,065,000 231 ,140,000 30 ,705,000 11 ,130,000 20 ,710,000 15 ,620,000 335 ,575,000 6,,620,000 $4,311,,605,000 TENDERS RECEIVED AND ACCEPTED RESERVE DISTRICTS AND TREASURY: cce^tea 16 968 17 27 21 20 38 17 5 18 15 26 190,000 900,000 410,000 220,000 780,000 090,000 840,000 005,000 130,000 640,000 620,000 625,000 620,000 $2,200 070,000a/ ^eceivea n.cceotev $ $ 50,005,000 4,761,210,000 5,945,000 41,540,000 12,835,000 51,480,000 229,540,000 25,880,000 12,070,000 22,635,000 6,215,000 242,100,000 4,640,000 $5,466,095,000 he public includes $ 314,245,000 noncompetitive tenders :ro; ,b 1 i c ^/-"eludes $179,640,000 noncompetitive tenders fro: tpe i-- bivalent coupon-issue vield. B- 988 yi 25,005,000 3,187,300,000 5,445,000 26,540,000 8,695,000 18,930,000 28,300,000 12,880,000 5,070,000 20,735,000 6,215,000 50,610,000 4,640,000 $3,400,365,000b/ FOR IMMEDIATE RELEASE EXPECTED AT 12:00 NOON, EDT TUESDAY, JUNE 20, 1978 REMARKS BY THE HONORABLE C. FRED BERGSTEN ASSISTANT SECRETARY OF THE TREASURY FOR INTERNATIONAL AFFAIRS BEFORE THE FRENCH-AMERICAN CHAMBER OF COMMERCE NEW YORK, NEW YORK TRADE AND MONEY: THE NEED FOR PARALLEL PROGRESS During the past fifteen years, we have all come to appreciate the need for parallel efforts to improve the international trade and monetary systems to better meet the demands of our rapidly changing global economy. Major strides have been made in reforming the international monetary system, in large part due to the efforts of the United States and France. Much remains to be done to make the new monetary system work better, and all nations have committed themselves to that effort. It is now proceeding, in the International Monetary Fund and elsewhere. But progress in the trade area has been much slower. The pending conclusion of the Multilateral Trade Negotiations now provides an opportunity for the needed catchup. Meaningful agreements must be reached soon to preserve an adequate B-989 - 2 - basis for the continued expansion of world trade and investment which has been a major ingredient of our postwar economic prosperity. France has frequently pointed to the importance of parallel progress in monetary and trade relations. Indeed, such a view draws on a fundamental tenet of classical economic theory: that the maintenance of a monetary system which promotes effective adjustment of payments imbalances is a vital prerequisite for an open trading system. In the absence of such monetary arrangements, the competitive position of nations with overvalued exchange rates is progressively eroded and political support for open trade gives way to an ever larger circle of restrictive measures. Similarly, the economic structure of countries with undervalued exchange rates becomes excessively skewed toward exports — provoking constant pressures on their trading partners even long after the undervaluations have disappeared, and generating strong domestic pressures to retain an undervalued rate or to replace it with other export aids of similar magnitude. The Bretton Woods understanding, in the aftermath of World War II, was designed to promote monetary stability through the maintenance of relatively fixed rates of exchange. Changes were to be made in par values only after it became inescapably clear that a fundamental shift in economic - 3 relationships had occurred — suggesting that such changes might come too late, even under the best of circumstances. Even these changes were made with great difficulty, if at all, and major disequilibria were permitted to develop. For the United States, stability in exchange rates during the 1960s came to mean an appreciating U.S. dollar against the weighted average of other major currencies despite increasing balance of payments difficulties. Part of the problem lay with the unwillingness of surplus countries to initiate the needed adjustment measures from their side. But a fundamental contradiction pervaded the international economic policy of the United States: it sought to lead the world toward freer trade, but made little effort to lead the world toward a monetary system which promoted effective payments adjustment. Indeed, largely because of this policy contradiction, the United States faced an ironic paradox„ In the early 1960s, unemployment was extremely high in the United States but the country as a whole, including organized labor, was largely supportive of a liberal trade policy. Through the 1960s, profits rose to record levels and unemployment steadily declined to post-Korea lows — but protectionist pressures at home steadily increased, to a point where the "Mills bill" nearly passed the Congress; in 1970 and the Burke-Hartke bill became a serious matter for concern in 1971 and 1972. - *4 And when the United States decided in August 1971 that it wanted to adjust the exchange rate of the dollar, partly in belated realization that such a step was crucial to restore the prospects for a liberal trade policy, it found that the international monetary system made such action very difficult. The United States was caught in its own policy contradiction. The reverse paradox has, to some extent, characterized the 1970s. In large part because adjustment measures had been effectively carried out, and the international monetary system reformed in the nick of time, the Trade Act of 1974 could authorize U.S. participation in the widest ranging international trade negotiations in history despite the existence at the time of its passage of the highest rate of unemployment at home since the Great Depression. Monetary progress permitted a resumption of trade progress. Reform of the Monetary System The Smithsonian agreement and the generalized float of major currencies in 1973 represented the first major steps in reforming the international monetary regime. The subsequent agreements at Rambouillet and Jamaica paved the way for the creation of a new monetary system based on greater flexibility in exchange rate arrangements and a broader emphasis on stability in underlying economic and financial conditions. - 5 The new exchange rate provisions give members wide latitude in the choice of exchange rate practices best suited to their needs, and can accommodate a wide variety of exchange rate mechanisms — including freely or managed floating rates, rates pegged to a currency or basket of currencies, and the common margins arrangements of the EC snake. Under the newly amended IMF Articles of Agreement, each member undertakes a general obligation to direct its economic policies toward orderly growth with reasonable price stability, and a specific obligation to avoid manipulating exchange rates either to prevent balance of payments adjustment or to gain unfair competitive advantage. The IMF is given responsibility for conducting continuing surveillance over the operations of the international monetary system and members1 compliance with their obligations regarding exchange rate policies. This is the heart of the new system. It represents the potential both for a stronger IMF, and for a more effective and symmetrical operation of the balance of payments adjustment process. To date, the IMF's ability to influence national policies has been limited for the most part to those members borrowing in the IMF's credit tranches. The new provisions on IMF surveillance provide the potential for IMF influence on the policies of all members, in surplus and deficit alike, as they bear on the operation of the international adjustment process. - 6 The task before us now is to make this system work. This will require active cooperation among all the major nations. The IMF has been given the job of insuring that the obligations are respected. We intend to do what we can to support the IMF in that endeavor — both in our contacts with other nations and in our policies at home. Improving the Trading System The last round of international trade negotiations the Kennedy Round in the 1960s — — made substantial progress in reducing tariffs, but could not have been expected to deal effectively with the primary trade problems of the 1970s and 1980s. Today, trade reform lags monetary reform. Our immediate task is to secure a meaningful package of agreements in the Multilateral Trade Negotiations in Geneva, the "Tokyo Round." This package should further reduce tariffs, but must break new ground in reducing non-tariff barriers to trade and addressing the problems created by excessive government intervention. It must do so if our new monetary system, and indeed the world economy as a whole, is to continue to prosper — for trade interventions beget monetary interventions, just as surely as monetary interventions foster trade interventions. The objectives of the United States in these trade negotiations are quite specific: - 7 — The successful negotiation of a new international code to discipline the use of subsidies which distort international trade. This is a prerequisite for U.S. adherence to a new package of trade agreements. — Improved market access for U.S. agricultural products. — Reductions in tariffs by an average of 40 percent, with minimal exceptions, to be phased in over a period of eight to ten years. — Agreement on acceptable "safeguard" measures which may be taken by governments in emergency situations. This agreement should clearly limit the circumstances in which governments can impose restraints on trade, i.e., it should provide "safeguards against safeguards." — A new international understanding on the use of government procurement measures, with the broadest possible sectoral coverage and maximum transparency of contract offers and awards. — A new mechanism for dispute settlement which will assure both timely and meaningful resolution of trade conflicts in all of these areas. — Special and differential treatment for the developing nations, supplemented where feasible with their offering reciprocal commitments on tariffs or market access for specific products and an acceptance of greater - 8 responsiblity — in particular, among the advanced developing nations — for maintaining an open trading system. The Trade Effects of Government Intervention The key to a successful MTN, and more broadly to the future of an open trading system, lies in finding new understandings on the use of subsidies and other forms of government intervention at the microeconomic level. This is an area in which one must move carefully and delicately. Many of the new devices are not trade measures in the traditional sense; they are not applied at the national border to goods flowing into and out of the country. Their effects on trade may be direct and profound but, because such measures are applied internally, some governments tend to think of them as "domestic" in nature and therefore beyond the reach of any international agreement. A more basic difficulty stems from the fact that modern representative governments often feel that they must assume responsibility for trying to help some disadvantaged or unlucky sector of the national economy. When governments succumb to that pressure, they are often tempted to deal with the problem by exporting it — by laying the burden of the adjustment on foreigners. But - 9 with national economies now linked so closely to one another, the consequences of strategies of this sort are more visible than ever — inviting the kind of retaliation that we all have a stake in avoiding. We are particularly concerned about the growing involvement of European governments in assisting domestic industries while these same governments insist that we keep our own doors open to European goods. Two principles must be applied in these situations. First, adjustment ought to take place through internal national measures rather than through trade distorting devices. Labor must be retrained, obsolete equipment scrapped and other difficult but necessary measures taken at home to adjust for loss in competitiveness abroadSecond, if trade must be affected in order to cope with these adjustment needs, then the restrictions must be tailored to international rules and subject to careful international oversight. We strongly support the establishment of international guidelines in this area as a basis for avoiding future conflicts. The United States places top priority on reaching an agreement on subsidies and countervailing duties in the Multilateral Trade Negotiations which would: — Reinforce the commitment already accepted by most industrial countries not to use export subsidies for industrial products. - 10- — Create new international disciplines to guard against the disguised protection of domestic markets through internal or production subsidies, including improved discipline over subsidized competition (particularly in agricultural products) in third markets. — Recognize that countervailing duties should as a general rule be applied only when a subsidy threatens or causes injury to a domestic industry. — However, in cases where there is a specific commitment not to use certain subsidies, permit countries to take quick counteraction if that commitment is violated. — Effectively implement the rules on both subsidies and countervailing duties via strengthened provisions on dispute resolution. — Include the developing countries, but provide flexible means for them to assume the new responsibilities corresponding to their position on the development ladder. The advanced developing countries should accept increased obligations as their industries become internationally competitive, perhaps through an initial freeze on their existing export subsidies and a commitment to phase them out over a suitable period of time. - 11 Export Credits Officially supported export credits will not be a major topic in the new code because they are already covered by international understandings. Despite these understandings, however, in recent months we have observed striking examples of government intervention in international trade finance. For instance, we witnessed a triple derogation by the British (in respect to maturity, local cost financing and cash down payment requirements) of the OECD guidelines on export credits in the sale of Rolls Royce engines to Pan American. The recent Airbus-Eastern Airlines financing package may have contained some questionable elements in respect of excessively long maturities and a free sixmonth leasing period. Thus, beyond negotiation of the new codes, the international trading system requires the active support of national governments to curb destructive practices in official export financing activities. The recently concluded International Arrangement on Export Credits of the OECD is desirable and useful within i limits, but must be strengthened and expanded to stem predatory official export credit competition and other official inducements which otherwise can only lead to an export credit war. Indeed, our Congress is already calling for new negotiations of this type — and for - 12 stepped-up activity by our own Export-Import Bank to counter such competition. Further improvement in the International Arrangement is a necessary complement to the MTN package to bring the world trading rules into conformity with the needs and practices of the late 1970s and 1980s. Conclusion The further reduction of tariff and non-tariff barriers in the MTN; our success in achieving new codes on subsidies and countervailing duties, safeguards, government procurement and export credits; and our ability to create new mechanisms for dispute settlement will do much to provide a sound basis for international trade cooperation in the years ahead. We recognize that the problems of government intervention will not be definitively resolved, and that cooperation — indeed, probably negotiation as well — must remain an ongoing process in order to assure that the new codes and agreements work effectively. Our challenge in the next few months is to take the crucial initial steps to set the process of reform in motion and to seize the opportunity afforded by the MTN to help create a more responsible, flexible trading system for the future. The parallelism between monetary and trade relations in fact requires that reform in both areas proceed apace. We cannot have a smoothly functioning international monetary system if nations insist on avoiding needed domestic - 13 adjustment to basic structural changes, and instead impose import restraints and export aids to boost their competitive positions at the expense of others. Likewise, we cannot expect that a meaningful MTN and real trade reform can be sustained without the continuing evolution of an effective international monetary system. We must join hands in a common effort in both areas if either is to work properly, for the benefit of all nations and peoples. We have already made a good deal of progress in the monetary area. We are committed to making the new monetary system work better. We must now commit ourselves to make equal progress in trade, and see that agreements are reached in the MTN which set us well on the road to lasting trade reform. oOo Department of thefREASURY WASHINGTON, D.C. 20220 TELEPHONE 588-2041 , "" • •-. FOR RELEASE AT 4:00 P.M. June 19, 1978 TREASURY TO AUCTION $1,750 MILLION OF 15-YEAR 1-MONTH BONDS The Department of the Treasury will auction $1,750 million of 15-year 1-month bonds to raise new cash! Additional amounts of the bonds may be issued to Federal Reserve Banks as agents of foreignand international monetary authorities at ...the average price of accepted competitive tenders. accepted e i: s about tne °ew security are given in the tt u ^\ !" attached highlights of the offering and in the official ottering circular. oOo Attachment B-990 HIGHLIGHTS OF TREASURY OFFERING TO THE PUBLIC OF 15-YEAR 1-MONTH BONDS TO BE ISSUED JULY 11, 1978 Amount Offered; To the public Description of Security: Term and type of security Series and CUSIP designation Maturity date "August 15, 1993 Call date. . . , Interest coupon rate June 19, 1978 $1,750 million 15-year 1-month bonds Bonds of 1993 (CUSIP No. 912810 CB 2) No provision To be determined based on the average of accepted bids Investment yield.' - To be determined at auction Premium or discount To be determined after auction Interest payment dates February 15 and August 15 (first payment on February 15, 1979) Minimum denomination available $1,000 Terms of Sale; Method of sale Yield auction Accrued interest payable by investor None Preferred allotment Noncompetitive bid for $1,000,000 or less Deposit requirement 5% of face amount Deposit guarantee by designated institutions Acceptable Key Dates; Deadline for receipt of tenders Wednesday, June 28, 1978, by 1:30 p.m., EDST Settlement date (final payment due) a) cash or Federal funds Tuesday, July 11, 1978 b) check drawn on bank within FRB district where submitted Friday, July 7, 1978 c) check drawn on bank outside FRB district where submitted Thursday, July 6, 1978 Delivery date for coupon securities. Friday, July 14, 1978 STATEMENT BY THE HONORABLE C. FRED BERGSTEN ASSISTANT SECRETARY OF THE TREASURY FOR INTERNATIONAL AFFAIRS BEFORE THE SUBCOMMITTEE ON FAMILY FARMS, RURAL DEVELOPMENT, AND SPECIAL STUDIES OF THE HOUSE COMMITTEE ON AGRICULTURE Mr. Chairman, I welcome the opportunity to testify before this Subcommittee on the subject of foreign investment in U.S. farmland. The subject is one part of the overall question of foreign investment in the United States. Thus, I would like to lead off by outlining the Administration's basic policy on foreign investment. Shortly after taking office, this Administration undertook a review of U.S. policy on foreign investment. In July 1977 the Administration issued a statement which confirmed the long-standing U.S. commitment to an open international economic system. Specifically, the statement said: "The fundamental policy of the U.S. Government toward international investment is to neither promote nor discourage inward or outward investment flows or activities." Therefore, the Government "should normally avoid measures which would give special incentives or disincentives to investment flows or activities and should not normally B-991 - 2 intervene in the activities of individual companies regarding international investment. Whenever such measures are under consideration, the burden of proof is on those advocating intervention to demonstrate that it would be beneficial to the national interest." We are aware, of course, that certain exceptional investments might not be consistent with the national interest. For this reason, regarding inward investment flows, the Administration continued the procedures established in 1975 under Executive Order 11858 for the Committee on Foreign Investment in the United States to "review investments in the United States which in the judgment of the Committee might have major implications for the U.S. national interest." As Assistant Secretary of the Treasury for International Affairs, I chair that Committee under the terms of E.O. 11858. One important feature of these procedures is a provision for advance consultations with foreign governments on investments in the United States. Under this procedure, foreign governments have been requested to consult with the U.S. Government on any significant direct investments which they might be contemplating making in the United States. If the Committee concluded - 3 that a particular investment would be contrary to the national interest, the foreign government involved would be requested to refrain from making the investment or to modify it in an appropriate manner. While this procedure was established primarily to review major investments by foreign governments, the Committee may also review any major investments here by foreign private parties if those investments, appear to have major implications for the national interest. The members of the Committee are kept informed on investments in the United States by the Office of Foreign Investment in the United States, which was established in the Department of Commerce by the same Executive Order. Mr. Berger, who heads that Office, will testify later on this operation. As to foreign investment in U.S. farmland, you are well aware that the available data are quite sketchy. Most farmland investments involve smaller order of magnitude than industrial plants, and therefore do not attract the same degree of public notice. A representative from the Department of Agriculture is testifying on that Department's plans to improve our data in this area. - 4 In the meantime, the Administration believes that its policy of not discouraging foreign investment in general applies to foreign investment in U.S. farmland. At a meeting of the Committee on Foreign Investment in the United States held last week it was unanimously agreed that there was no basis at present for a departure from our basic policy in the case of farmland. Nevertheless, there has quite understandably been a good deal of concern expressed about the sharp rise in the price of farmland. This phenomenon is attributed in part to an increasing demand for U.S. farmland as investments by persons who are not directly involved in farming. The vast majority of absentee farmland owners are Americans; some are foreigners, though the very incomplete data now available suggest that this amount is no more than one percent of total land ownership in this country and much of this ownership is not of recent origin. Whether purchases by absentee owners have any significant effect on farmland prices is certainly a proper subject for examination. However, we see no basis at this point for differentiating between persons who may be absentee land owners on the basis of their nationality. The economic impact of land purchases does not vary with the geographic residence of the purchaser. - 5 There are two factors which are different for foreigners buying land in the United States as compared to U.S. residents. First, foreigners are subject to different tax laws. foreigners deal in a foreign currency — buying and selling U.S. land. Second, the dollar — when Neither of these factors, however, gives foreigners any inherent advantage over Americans in buying land here. The tax considerations involved are rather complex, and turn on the tax laws of the foreigner's residence as well as U.S. tax laws. I have an addendum to my statement which discusses these considerations. The upshot of this discussion is that whether or not a foreigner is better or worse off from a tax standpoint than an American when buying farmland depends on the particular circumstances of the two individuals. I want to emphasize, however, that there is no necessary advantage to foreigners merely because profits from sales of U.S. land are not subject to the U.S. capital gains tax. Foreigners subject to the tax laws of Canada, Germany, France, Japan and the United Kingdom, which are reportedly major sources of foreign demand for U.S. farmland, are subject to tax in those countries on capital gains they may derive in the United States and for some at least their tax result may not be too different from an American's. Also in cases where foreigners are not subject to capital gains - 6 tax, neither are they able to deduct capital losses resulting from land sales as U.S. residents can. In regard to the foreign currency aspect, it is sometimes said that foreigners have an advantage over Americans in that they can buy land with "cheap dollars". But the fact that the mark and the yen will buy more dollars today than in some previous period merely means that Germans and Japanese have more purchasing power in dollars than previously — whereas Canadian and British citizens, because of the weakening of their currencies, have less. Even residents of countries whose currencies have strengthened do not have an absolute advantage over Americans. In fact, in a world of floating exchange rates, having to deal in a foreign currency is an additional risk factor for foreigners buying land here, a risk which American land purchasers do not face. In addition, it should be noted that foreign investment in the United States reduces our balance of payments deficit and strengthens the dollar. Direct investment of a longer term nature is particularly welcome in this respect. It represents a constructive means of financing the sizable current account deficit which we are now running, and - 7 the current account surpluses of foreign countries. Mr. Chairman, you raised several specific questions about foreign investment in farmland in your letter to Secretary Blumenthal. In response to your questions on the economic impact of this investment, as I have already indicated, I see no reason to believe that it essentially differs from the impact of investment in farmland by Americans except for its effect on our balance of payments. You also asked whether restrictions on foreign investment would be detrimental to our international interests. They key point is that such restrictions would be detrimental to our national interests. The main reason that this and previous Administrations have followed a neutral policy on foreign investment is that the policy works in the best interests of the U.S. economy. The broader the amount of participation in any market, the greater the competition in and efficiency of the market. To exclude a certain sector of participants in the market purely on the basis of their nationality would have no economic rationale. If we restrict the ability of foreigners to invest in the United States, we also restrict the right of Americans to dispose of their property — for no apparent purpose — and we would also run a risk of retaliation against the sizable stock of American investments abroad. - 8 In summary, Mr. Chairman, unless it can be demonstrated that the national interest is adversely affected by foreign investments in U.S. land, there appears to be no basis for treating farmland purchases by foreigners any different than farmland purchases by Americans. The traditional U.S. policy of neutrality toward foreign investment, both inward and outward, should apply here as well. TAXATION OF INCOME FROM FOREIGN INVESTMENT IN U.S. Under U.S. tax laws, resident aliens generally are taxed on their income from all sources, both within and outside the United States, in the same manner as U.S. citizens. However, non-resident aliens normally are taxed only on their income from sources within the United States. Special rules apply to the taxing of the income of non-resident aliens, depending on whether such income is derived from passive investments or from the conduct of a business. In considering how the provisions of the Internal Revenue Code apply to foreign investments in U.S. farmland, it is necessary to consider the legal identity of the investor and the form of the investment. The foreign investor could either be a foreign corporation or an individual. The investment could be in the form of stock in a U.S. corporation, which in turn owns the farmland, or a direct purchase by the foreign investor. In the latter case it may be presumed that the U.S. farm will be operated as a branch of the foreign corporation or, in the case of the foreign individual, as a business with a U.S. manager. - 2 In the case of an indirect investment in farmland through a U.S. corporation, the farm income will first be subject to the U.S. corporate income tax. Distributions out of profits to non-resident aliens will be subject to a 30 percent withholding tax unless reduced through a bilateral income tax convention, which usually provides for a rate of 15 percent. This income will then be subject to the tax laws in the investor's country of residence. It is worth noting that major capital exporting countries such as Canada, Germany, France, 1/ Japan and the U.K. tax the worldwide income of their residents. The tax laws of these, and most other countries, allow residents to take a credit for U.S. withholding tax against their domestic tax liability. In the case of direct investments, foreign corporations with U.S. source income must file special tax returns (1120 F) with the IRS, and are subject to the same rate schedule as are U.S. corporations. Non-resident alien individuals with income effectively connected with the conduct of a trade or business are required to file a form 1040 NR even if the gross amount of income is less than $750. An investment in a U.S. farm would be considered a trade or a business. This income would be subject to the same 1/ French corporations, however, are in principle not subject to taxation on foreign source income. - 3 tax rate schedules as are applicable to U.S. taxpayers. Again, when the funds are transmitted abroad they will be subject to the tax laws in the investor's country of residence. Non-resident aliens not present in the United States for at least 183 days during the taxable year are not subject to U.S. tax on gains derived from the sale or exchange of capital assets within the United States. This exemption from taxation applies to all capital assets, however, not just farmland. Whether this constitutes an advantage to foreigners will depend on how they are taxed in their home countries. Canada, Germany, France, Japan and the U.K. tax the worldwide income of their residents including capital gains. To determine whether residents of these countries are subject to lighter or heavier taxes than Americans would require detailed comparisons of the various tax laws. It should also be noted that, in cases where a foreigner is not subject to a capital gains tax, neither is he able to deduct a capital loss from ordinary income as American taxpayers can. A common problem in determining the tax liability of business enterprises which operate in more than one tax - 4 jurisdiction involves "artificial transfer pricing." Under this practice business enterprises strive to minimize their tax liability by attributing as much of their income as possible to countries with low tax rates. To do this, they tend to sell products produced by their affiliates in high tax countries to their affiliates in low tax countries at artificially low prices rather than the "arm's-length" prices that would be charged to unaffiliated persons. Tax authorities in all countries have difficulty in preventing these practices because the products involved are frequently unique and the arm's-length or market price is difficult to establish. In the case of foreign-owned U.S. companies engaged in farming, however, the problem is minimal because agricultural products have a wide market and there is little difficulty in establishing an arm's-length price. In summary, few generalizations can be made as to whether foreigners have a tax advantage or disadvantage vis-a-vis Americans in buying, operating or selling U.S. farmland. The situation will vary in accordance with the individual circumstances of the taxpayers involved. FOR RELEASE ON DELIVERY EXPECTED AT 11:00 A.M. JUNE 21, 1978 STATEMENT OF THE HONORABLE R O B E R T H. MUNDHEIM GENERAL COUNSEL U . S . DEPARTMENT OF THE T R E A S U R Y BEFORE THE SUBCOMMITTEE ON FINANCIAL INSTITUTIONS COMMITTEE ON BANKING, H O U S I N G , A N D URBAN AFFAIRS UNITED STATES SENATE The International Banking Act of 1978 (H.R. 10899) Mr. Chairman and Members of this distinguished Subcommittee. I appreciate the opportunity to testify on behalf of the Administration on H.R. 1 0 8 9 9 , the International Banking Act of 1978. The Administration generally endorsed this legislation in the House of R e p r e s e n t a t i v e s last y e a r , and as passed by the House it incorporates a number of changes that we suggested. Subject to two m o d i f i c a t i o n s that I w i l l shortly d i s c u s s , we continue to favor enactment of the International Banking Act. The Growth of International Banking In view of the increasing importance of foreign bank operations in the United S t a t e s , we a g r e e that Congress should act in this area n o w . In our testimony before the House Banking Committee on this l e g i s l a t i o n , w e noted that foreign bank o p e r a t i o n s , although still small in relation to to the domestic banking industry, h a v e been growing in recent years. Total assets of the United States b r a n c h e s , agencies an <3 commercial lending companies of foreign banks have more than tripled during the past five y e a r s , increasing to $66 B-992 - 2 - billion at the end of February 1978, which represents roughly 6 percent of the total assets of all commercial banking operations in the United States. The growing operations of foreign banks in our economy is a natural outgrowth of expanding international trade and the increasing activity of foreign businesses in the United.States. Just as American banks began operating abroad to serve their domestic customers, foreign banks are opening offices in the United States to serve their customers here. Foreign banks contribute to competition in our domestic banking industry and facilitate increased international trade and finance. In determining a national policy, we must also keep in mind that our regulation of foreign banks may affect foreign government treatment of United States banks and other financial institutions operating overseas. The total assets of foreign branches of American banks at the end of February 1978 were $257 billion, almost four times the $66 billion amount just mentioned. The Principle of National Treatment The United States endeavors to offer an hospitable climate for foreign investment by following a policy of "national treatment", under which as few distinctions as possible are made between the treatment of businesses of foreign investors and the same business conducted by United States nationals. In line with this general policy, we believe that foreign banks doing business here should be supervised under the same rules and administrative structure as domestic banks; they should be afforded comparable competitive opportunities and be subject to comparable restraints. The national treatment concept is superior, in our opinion, to the alternative concept of "reciprocity" which some foreign banks would like us to adopt. Under a policy of reciprocity, we would allow a foreign bank to engage in the United States in all those activities in which American banks are permitted to engage in the home country of the foreign bank, even though we do not permit domestic banks to conduct such activities here. Since countries differ on which activities banks may engage in, - 3 - the United States under a policy of reciprocity would have to administer different sets of rules for various foreign banks operating in this country, dependi-ng on their nationality. This could be an administrative nightmare. Furthermore, the advantages we would have to afford foreign banks under a policy of reciprocity - such as the ability to engage in interstate branching, and a broad range of nonbanking activities - would result in unfair competitive pressures on domestic banks. Purpose of the Act The Administration supports the International Banking Act because, for the most part, it furthers the national treatment theme by treating foreign bank operations like operations of domestic banks. It brings branches and agencies of foreign banks within the dual banking system and establishes a framework for applying Federal banking policy to them. In those two sections where the bill departs from equal treatment of foreign and domestic banks, interstate branching and Treasury Guidelines, we recommend changes. Before discussing those changes, I should like to briefly reiterate our support for several of the bill's other provisions. Extension of the Dual Banking System Our existing laws and regulations covering foreign banks do not fully reflect the policy of national treatment. On the one hand, they deny foreign banks certain banking opportunities. For example, foreign banks are deterred from establishing national banks. In addition, our laws permit foreign banks to operate branches or agencies, but these operations are unable to obtain Federal deposit insurance. On the other hand, there is no Federal regulation or supervision of foreign bank branches and agencies, even though almost all domestic banks come under the regulation of either the Comptroller of the Currency, the Federal Reserve Board, or the Federal Deposit Insurance Corporation. ::' - 4 - This legislation will, for the first time, enable the Comptroller of the Currency to authorize Federal branches and agencies of foreign banks. It grants those institutions powers similar to those of national banks and permits them to operate in states where state law does not prohibit foreign bank branches and agencies, and where the particular foreign bank does not already have a state-approved facility. • In so doing, it extends Federal regulatory involvement into an important segment of banking activity in the United States presently regulated solely by the states. Foreign banks would then have the option of choosing between a Federal and a state regulatory framework. Such a choice would offer foreign institutions the same Federal and state alternatives now afforded their domestic counterparts. Federal Deposit Insurance We believe this legislation satisfactorily addresses the question of Federal deposit insurance for foreign bank branches. Currently, foreign bank branches do not qualify for FDIC insurance. The bill changes this policy in a manner that gives effect to the principle of national treatment: insurance is required for Federal branches and for state branches in those states where domestic state banks are required to obtain deposit insurance. However, we are inclined to support the suggestions of Chairman Miller that the coverage available should include deposits of foreign persons, not just United States citizens and residents. Nonbanking Activities Section 8 of the bill deals with the nonbanking activities of foreign banks in the United States. It generally subjects foreign banks maintaining United States branches or agencies to the restrictions on nonbanking activities of the Bank Holding Company Act of 1956, as amended. United States subsidiaries of foreign banks already come under the Bank Holding Company Act. - 5 - Under the Bank Holding Company Act prior Federal Reserve Board approval would be required before a foreign bank could engage in new nonbanking activities. Permitted activities for foreign banks would be the same as those authorized by the Board for domestic banks. Nonbanking activities of the foreign parent bank principally outside the United States would be exempt. In addition, all of a foreign bank's nonbanking activities engaged in on May 23, 1977 would be permanently grandfathered . The focus of much debate in this area has been the activities of United States securities affiliates of foreign banks. Several such organizations engage in securities underwriting activities which are prohibited to American banks or their affiliates. This bill would prevent foreign banks engaged in commercial banking in the United States from also engaging in the securities business here, either directly or through affiliates. However, existing securities operations would be permanently grandfathered. Such a grandfather provision is reasonable and appropriate, because these activities were undertaken in accordance with the existing legal framework and they have made a useful contribution to the capital of securities firms and to the viability of regional stock exchanges. Proposed Changes in the Bill Now, Mr. Chairman, let me turn to two portions of the International Banking Act that we believe warrant further change. Interstate Branching Except under limited circumstances, states do not permit branch operations by a bank chartered in another state. Similarly, interstate branching is not authorized for national banks because of the provisions of the McFadden Act. However, several states permit — indeed encourage — foreign bank branches, e ven if the same foreign bank has branches in other states. - 6 The International Banking Act would continue the ability of foreign banks to have interstate branches and would extend this ability even to Federal branches so long as expressly permitted by the state involved. It is in this respect that we disagree with the provisions of the bill. Consistent with our espousal of equal treatment for domestic and foreign banks, we believe that section 5 should be amended to make Federal foreign branches subject to the branching rules applicable to domestic national banks, and to make state foreign branches subject to the branching rules applicable to domestic state banks. In order to minimize disruption of existing banking services, we would favor permanent grandfathering of foreign interstate operations engaged in on May 23, 1977. Interstate branching raises a fundamental competitive question with long-term implications for banking structure in the United States. Technological developments, for example, in the area of electronic funds transfer have increased the urgency of answering that question. If because of the absence of prohibitory legislation, foreign banks develop sizable interstate networks, it may be difficult in the future to decide to terminate those operations, or alternatively not to grant domestic banks the same privilege. We would prefer that for the future branching by foreign banks be placed on the same competitive footing as that of domestic banks. The desirability of interstate branching should be judged on its own merits, with the decision equally applicable to foreign and and domestic guidelines Review banks. The Administration favors deletion of section 9 in its entirety. Section 9 is a carry-over from the concern expressed in some quarters several years ago that the Federal Government should review every potential foreign direct investment to be roade in the United States on a case-by-case basis to assure that ft was not injurious to the national interest. Thorough investment-policy review concluded that the Federal government should not intervene in private business transactions unless there is a clear public purpose to be served. The mere fact that foreign persons are involved is not a sufficient reason for such intervention. - 7 - Section 9 would require a new and, we believe, inappropriate Treasury and Federal role in the establishment of foreign bank operations in the United States: (1) The Secretary of the Treasury would be required to issue guidelines on foreign bank operations in the United States to assist bank regulators acting upon foreign bank applications; (2) state and Federal banking authorities would be required to solicit the views of the Secretaries of Treasury and State and of the Federal Reserve Board; and (3) state and Federal banking authorities would be prohibited from approving a foreign bank's application unless the foreign bank agreed in advance to conduct all its United States operations in full compliance with Federal and state anti-discrimination laws that apply to domestic banks. We strongly recommend that this remnant of attempts at Federal screening be eliminated from the bill, for several reasons: (1) it discriminates insofar as it applies to foreign-owned banks only; (2) it could set an unfortunate precedent for establishing similar procedures for foreign investment in other areas of our economy; (3) it could induce other countries to introduce or expand restrictions on American financial activities and investments abroad; and (4) it appears to contradict certain national treatment provisions in our foreign treaties. We are particularly concerned that Treasury, in preparing guidelines, is required to take account of the treatment afforded United States banks abroad. As I previously stated, we vigorously object to a policy of reciprocity. It could result in a reduction of permissible international banking activities, including those of United States banks abroad, and also create an administrative nightmare in enforcing different sets of rules for different foreign banks operating in this country. - -8 Furthermore, we believe the provision in section 9 requiring a specific pledge to obey domestic anti-discrimination laws before a foreign banking application can be approved is unnecessary and unwise. All domestic and foreign banking operations in the United States already are subject to our anti-discrimination laws. Conclusion Thank you, Mr. Chairman, for allowing us to testify on this important bill. We look forward to working with the Subcommittee as further questions arise. FOR RELEASE AT 4:00 P.M. June 20, 1978 TREASURY'S WEEKLY BILL OFFERING The Department of the Treasury, by this public notice, invites tenders for two series of Treasury bills totaling approximately $5,700 million, to be issued June 29, 1978. This offering will not provide new cash for the Treasury as the maturing bills are outstanding in the amount of $5,692 million. The two series offered are as follows: 91-day bills (to maturity date) for approximately $2,300 million, representing an additional amount of bills dated March 30, 1978, and to mature September 28, 1978 (CUSIP No. 912793 T5 5)# originally issued in the amount of $3,403 million, the additional and original bills to be freely interchangeable. 182-day bills for approximately $3,400 million to be dated June 29, 1978, and to mature December 28, 1978 (CUSIP No. 912793 V2 9) . Both series of bills will be issued for cash and in exchange for Treasury bills maturing June 29, 1978. Federal Reserve Banks, for themselves and as agents of foreign and international monetary authorities, presently hold $2,785 million of the maturing bills. These accounts may exchange bills they hold for the bills now being offered at the weighted average prices of accepted competitive tenders. The bills will be issued on a discount basis under competitive and noncompetitive bidding, and at maturity their par amount will be payable without interest. Except for definitive bills in the $100,000 denomination, which will be available only to investors who are able to show that they are required by law or regulation to hold securities in physical form, both series of bills will be issued entirely in book-entry form in a minimum amount of $10,000 and in any higher $5,000 multiple, on the records either of the Federal Reserve Banks and Branches, or of the Department of the Treasury. Tenders will be received at Federal Reserve Banks and Branches and at the Bureau of the Public Debt, Washington, D « C 20226, up to 1:30 p.m., Eastern Daylight Saving time, Monday, June 26, 1978. Form PD 4632-2 (for 26-week series) or Form PD 4632-3 (for 13-week series) should be used to submit tenders for bills to be maintained on the book-entry records of the Department of the Treasury. P ~ 993 -2Each tender must be for a minimum of $10,000. Tenders over $10,000 must be in multiples of $5,000. In the case of competitive tenders the price offered must be expressed on the basis of 100, with not more than three decimals, e.g., 99.925. Fractions may not be used. Banking institutions and dealers who make primary markets in Government securities and report daily to the Federal Reserve Bank of New York their positions in and borrowings on such securities may submit tenders for account of customers, if the names of the customers and the amount for each customer are furnished. Others are only permitted to submit tenders for their own account. Payment for the full par amount of the bills applied for must accompany all tenders submitted for bills to be maintained on the book-entry records of the Department of the Treasury. A cash adjustment will be made on all accepted tenders for the difference between the par payment submitted and the actual issue price as determined in the auction. No deposit need accompany tenders from incorporated banks and trust companies and from responsible and recognized dealers in investment securities for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, or for bills issued in bearer form, where authorized. A deposit of 2 percent of the par amount of the bills applied for must accompany tenders for such bills from others, unless an express guaranty of payment by an incorporated bank or trust company accompanies the tenders. Public announcement will be made by the Department of the Treasury of the amount and price range of accepted bids. Competitive bidders will be advised of the acceptance or rejection of their tenders. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and the Secretary's action shall be final. Subject to these reservations, noncompetitive tenders for each issue for $500,000 or less without stated price from any one bidder will be accepted in full at the weighted average price (in three decimals) of accepted competitive bids for the respective issues. Settlement for accepted tenders for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, and bills issued in bearer form must be made or completed at the Federal Reserve Bank or Branch or at the Bureau of the Public Debt on June 29, 1978, in cash or other immediately available funds or in Treasury bills maturing June 29, 1978. Cash adjustments will be made for differences between the par value of the maturing bills accepted in exchange and the issue price of the new bills. -3Under Sections 454(b) and 1221(5) of the Internal Revenue Code of 1954 the amount of discount at which these bills are sold is considered to accrue when the bills are sold, redeemed or otherwise disposed of, and the bills are excluded from consideration as capital assets. Accordingly, the owner of these bills (other than life insurance companies) must include in his or her Federal income tax return, as ordinary gain or loss, the difference between the price paid for the bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made. Department of the Treasury Circulars, No. 418 (current revision), Public Debt Series - Nos. 26-76 and 27-76, and this notice, prescribe the terms of these Treasury bills and govern the conditions of their issue. Copies of the circulars and tender forms may be obtained from any Federal Reserve Bank or Branch, or from the Bureau of the Public Debt. FOR IMMEDIATE RELEASE June 20, 1978 RESULTS OF AUCTION OF 2-YEAR NOTES The Department of the Treasury has accepted $3,007 million of $4,856 million of tenders received from the public for the 2-year notes, Series Q-1980, auctioned today. The range of accepted competitive bids was as follows: Lowest yield 8.25% 1/ Highest yield Average yield 8.33% 8.32% The interest rate on the notes will be 8-1/4%. At the 8-1/4% rate, the above yields result in the following prices: Low-yield price 100.000 High-yield price Average-yield price 99.855 99.873 The $3,007 million of accepted tenders includes $ 653 million of noncompetitive tenders and $2,344 million of competitive tenders from private investors, including 59% of the amount of notes bid for at the high yield. It also includes $10 million of tenders at the average price from Federal Reserve Banks as agents for foreign and international monetary authorities in exchange for maturing securities. In addition to the $3,007 million of tenders accepted in the auction process, $ 794 million of tenders were accepted at the average price from Government accounts and Federal Reserve Banks for their own account in exchange for securities maturing June 30, 1978, and $560 million of tenders were accepted at the average price from Federal Reserve Banks as agents for foreign and international monetary authorities for new cash. 1/ Excepting 5 tenders totaling $240,000 B-994 Treasury Contact: FOR IMMEDIATE RELEASE June 22, 1978 Customs Contact: Robert E. Nipp 202/566-5328 Brian Lee 202/566-5286 U.S. CUSTOMS TO PROVIDE ASSISTANCE TO SAUDI ARABIAN CUSTOMS DEPARTMENT The U.S. Customs Service will shortly be providing a wide range of technical, management, and manpower development assistance to Saudi Arabia1s Customs Department. Under the auspices of the U.S. - Saudi Arabian Joint Commission on Economic Cooperation, an agreement was signed in Riyadh, Saudi Arabia, on June 11 which calls for the U.S. Customs Service to provide four full-time Customs Advisors to the Saudi Customs Department in Riyadh, and to furnish orientation and training to up to 9 5 Saudi Customs officers a year in the United States. The new program will be the most all-inclusive agreement of its kind that the U.S. Customs Service has ever entered into with another nation. The four U.S. Advisors stationed in Riyadh will work with their foreign counterparts to improve Saudi Customs1 administrative, technical, and management skills. At the same time, the U.S. Customs Service will enroll up to 80 designated Saudi Customs officers a year in specially designed seminar programs to be held at a university location in the United States. As part of the program, the Saudi officers will observe Customs programs in operation at selected Regional offices. Up to 15 additional Saudi Customs officials a year will be enrolled in graduatelevel programs in Public Administration at various U.S. universities and colleges and will also participate in related work-study programs. This project is the fifteenth major project to be carried out by the U.S. - Saudi Arabian Joint Commission on Economic Cooperation, for which Secretary of the Treasury W. Michael Blumenthal and Saudi Arabian Finance Minister Muhammad Abalkhail are co-chairmen. Others include electrical equipment procurement and planning, agriculture development, vocational training, highway planning, and saline water research. All these projects are funded by B-995 the Saudi Arabian Government. Treasury offices in Washington - 2 and in Riyadh work with project action agencies such as the U.S. Customs Service and provide overall support for the more than 120 U.S. technicians now working in Saudi Arabia in connection with these activities. # # # FOR IMMEDIATE RELEASE June 20, 1978 Contact: Robert E. Nipp 202/566-5328 TREASURY ANNOUNCES RESULTS OF GOLD AUCTION The Department of the Treasury announced that 300,000 ounces of fine gold were sold today to 21 successful bidders at prices from $186.52 to $190.29 per ounce, yielding an average price of $186.91 per ounce. Gross proceeds from this sale were $56.1 million. Of the proceeds, $12.7 million will be used to retire Gold Certificates held by Federal Reserve banks. The remaining $43.4 million will be deposited into the Treasury as a miscellaneous receipt. These sales were made as the second in a series of monthly auctions being conducted by the General Services Administration on behalf of the Department of the Treasury. The next auction, at which another 300,000 ounces will be offered, will be held on July 18. A total of 165 valid bids were submitted by 31 bidders for a total amount of 1,036,000 ounces at prices ranging from $172.00 to $190.29 per ounce. The General Services Administration will release additional information, including the list of successful bidders and the amounts of gold awarded to each, after those bidders have been notified that their bids have been accepted. oOo B-996 WtmentoftheTREASURY TELEPHONE 566-20*1 I6T0N, D.C. 20220 FOR IMMEDIATE RELEASE June 21, 1978 RESULTS OF TREASURY'S 52-WEEK BILL AUCTION Tenders for $2,750 million of 52-week Treasury bills to be dated June 27, 1978, and to mature June 2 6 , 1979, were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: Investment Rate Price High Low Average - 92.265 92.217 92.237 Discount Rate (Equivalent Coupon-Issue Yield) 7.650% 7.697% 7.678% 8.24% 8.29% 8.27% Tenders at the low price were allotted 4 2 % . TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTS AND TREASURY: Location Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco Accepted Received 52-WEEK BILL RATES DATE: J u n e HIGHEST SINCE LAST MONTH LOWEST SINCE TODAY Treasury TOTAL $4,4ui,/JD,UUU $z,/^u,iy^,uuu The $2,750 million of accepted tenders includes $ 86 million of noncompetitive tenders from the public and $1,178 million of tenders from Federal Reserve Banks for themselves and as agents of foreign and ln ternational monetary authorities accepted at the average price. An additional $ 31 million of the bills will be issued to Federal Reserve Banks as agents of foreign and international monetary authorities for new cash. B-997 2 1 , l<j)78 kpartmentoftheTREASURY TELEPHONE S68-2P1 IINGTON, D.C. 20220 FOR IMMEDIATE RELEASE June 21, 1978 RESULTS OF TREASURY'S 52-WEEK BILL AUCTION / Tenders for $2,750 million of 52-week Treasury bills to be dated June 27, 1978, and to mature June 26, 1979, were accepted at the Federal Reserve Banks and Treasury today. The details are as follows: RANGE OF ACCEPTED COMPETITIVE BIDS: Price Discount Rate High - 92.265 7.650% Low 92.217 Average 92.237 Investment Rate (Equivalent Coupon-Issue Yield) 8.24% 7.697% 7.678% 8.29% 8.27% Tenders at the low price were allotted 42% TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTS AND TREASURY: Location Boston New York Philadelphia Cleveland Richmond Atlanta Chicago St. Louis Minneapolis Kansas City Dallas San Francisco Treasury TOTAL Received $ 31,790,000 3,709,365,000 2,820,000 65,195,000 36,740,000 7,685,000 212,515,000 18,545,000 17,605,000 6,505,000 11,370,000 278,120,000 3,480,000 Accepted $ 16,790,000 2,392,765,000 2,820,000 55,195,000 21,580,000 7,685,000 133,815,000 8,965,000 17,605,000 6,505,000 10,870,000 > 72,120,000 3,480,000 $4,401,735,000 $2,750,195,000 The $2,750 million of accepted tenders includes $ 86 million of noncompetitive tenders from the public and $1,178 million of tenders from Federal Reserve Banks for themselves and as agents of foreign and international monetary authorities accepted at the average price. An additional $ 31 million of the bills will be issued to Federal eserve Banks as agents of foreign and international monetary authorities *°r new cash. B-997 FOR IMMEDIATE RELEASE jjne 23, 1978 Contact: Robert E. Nipp 202/566-5328 TREASURY DEPARTMENT EXTENDS PERIOD OF INVESTIGATION OF CARBON STEEL WIRE ROD FROM THE UNITED KINGDOM The Treasury Department announced today it will extend its antidumping investigation of carbon steel wire rod from the United Kingdom until July 24, 1978. Treasury said it needed more time to consider information provided to determine whether the product is being sold in the United States at less than fair value. As defined by the Antidumping Act, "sales at less than fair value" generally occur when imported merchandise is sold here for less than in the home market. If Treasury determines "sales at less than fair value" occur, the case is referred to the U.S. International Trade Commission to determine whether they are hurting a U.S. industry. An affirmative ITC decision would require dumping duties. Notice of this action will appear in the Federal Register of June 27, 1978. Imports of carbon steel wire rod from the United Kingdom during the period January through June 19 77 were valued at $4 million. # B^99 # # Total Capital Gains and the Effective Tax Rate on Capital Gains for Returns with Met Capital Gains Only (1955-1976) Year ( Effective tax rate Taxes paid on capital gain income Total gains $ billions ) (.... percent ...) 12.0% 1955 $ 9.9 $1.2 1956 1957 1958 1959 1960 9,7 8.1 9.4 13.1 11.7 1.1 0.9 1.1 1.6 1.4 11.8 11.1 11.1 11.8 11.6 1961 1962 1963 1964 1965 16.3 13.5 14.6 17.4 21.5 2.0 1.6 1.7 2.2 2.8 12.4 11.8 11.9 12.7 13.1 1966 1967 1968 1969 1970 21.3 27.5 35.6 31.4 20.8 2.7 3.9 5.2 4.4 3.0 12.8 14.0 14.5 14.1 14.6 1971 1972 1973 1974 1975 28.3 35.9 35.8 30.2 30.9 4.3 5.6 5.3 4.3 4.5 15.2 15.7 14.9 14.3 14.4 1976 39.0 6.2 15.9 Office of the Secretary of the Treasury Office of Tax Analysis June 22, 1978 Distribution of Net Capital Gains (Returns with Met Capital Gain Only) Year Returns with Returns with adjusted gross income idjusted gross income less than $50.000 over $50.000 Percent of total Percent of total net gains net gains percent 1955 65.5% 34.5% 1956 1957 1958 1959 1960 65.3 67.8 68.7 65.8 65.3 34.7 32.2 31.3 34.2 34.7 1961 1962 1963 1964 1965 62.7 64.7 66.1 61.8 59.9 37.3 35.3 33.9 38.2 40.1 1966 1967 1968 1969 1970 60.8 57.6 55.1 52.6 59.9 39.2 42.4 45.0 47.4 40.1 1971 1972 1973 1974 1975 58.3 56.1 60.3 62.9 63.0 41.7 43.9 39.7 37.1 37.0 1976 62.0 38.0 °ffice of the Secretary of the Treasury Office of Tax Analysis June 22, 1978 FOR IMMEDIATE RELEASE June 23, 1978 Contact: Alvin M. Hattal 202/566-8381 TREASURY ANNOUNCES COUNTERVAILING DUTY INVESTIGATION OF IMPORTS OF VISCOSE RAYON STAPLE FIBER FROM SWEDEN The Treasury Department today said it is investigating whether the Government of Sweden is subsidizing exports of viscose rayon staple fiber. The Countervailing Duty Law requires the Secretary of the Treasury to collect an additional duty that equals the size of a "bounty or grant" (subsidy) paid on the exportation or manufacture of merchandise imported into the United States. A preliminary determination in this case must be made not later than October 25, 1978, and a final determination no later than April 25, 1979. This product from Sweden is also the subject of an investigation being conducted by the Treasury Department under the Antidumping Act. Should final determinations under the Antidumping Act and the Countervailing Duty Law be affirmative, the amount of additional duties will be determined so as to avoid double compensation for the simultaneous occurrence of dumping and export subsidization. Imports of the merchandise from Sweden were valued at approximately $2.1 million in 1977. Notice of this action will appear in the Federal Register on June 26, 1978. o B-1001 0 o FOR RELEASE ON DELIVERY Expected at 8:30 a.m. June 27, 1978 STATEMENT BY THE HONORABLE ROGER C. ALTMAN ASSISTANT SECRETARY FOR DOMESTIC FINANCE BEFORE THE SUBCOMMITTEE ON DOMESTIC MONETARY POLICY OF THE HOUSE COMMITTEE ON BANKING, FINANCE AND URBAN AFFAIRS Mr. Chairman and Members of the Committee: I welcome this opportunity to assist in your oversight of the authority of Federal Reserve Banks to purchase directly from the Treasury up to $5 billion of public debt obligations. As you know, the most recent extension of this authority expired on April 30, 1978. On April 19, 1978 this Subcommittee favorably reported House Joint Resolution 816, to extend this authority to April 30, 1979. The Resolution was adopted by the House of Representatives on May 1, but the Senate has not yet acted. The purpose of the direct-purchase authority is to facilitate the efficient management of the public debt. It was first granted in its present form in 1942, and it has been renewed for temporary periods on a number of occasions. The authority has lapsed, however, on five occasions in recent years -- from July 1 until August 14, 1973; from November 1, 1973 until October 28, 1974; from November 1 to November 12, 1975; from October 1 until November 7, 1977 and the current period. Borrowings from the Federal Reserve System under this authority have been for very short periods, the average length being from 2 to 7 days. Only twice in the past 35 years has the Treasury had to draw funds in this manner B-1002 - 2 for periods exceeding 13 consecutive days. I have appended a table which lists the instances of actual use. Borrowings under the authority are subject to the public debt limit, and its use is reported in the Daily Treasury Statement, the weekly Federal Reserve Statement, and in the Federal Reserve Board's Annual Report to the Congress. The existence of the direct purchase authority provides us with a margin of safety which permits us to let our cash balance fall to otherwise unacceptably low levels preceding periods of seasonally heavy revenues. This, in turn, results in balances that are not as high as they otherwise would be during the periods of high revenues that follow, allowing the public debt to be kept to a minimum and thus reducing interest costs to the Government. Moreover, there is always the possibility that unforeseen swings in our cash flows may suddenly deplete our cash balance and require a sudden borrowing. The direct-purchase authority is available to provide an immediate source of funds for temporary financing in the event of a national emergency on a broader scale. While this has never happened, it is conceivable that financial markets could be disrupted at a time when large amounts of cash had to be raised to maintain governmental functions and meet the emergency. Consequently, the directpurchase authority has for many years been a key element in the Treasury's financial planning for a national emergency. I want to emphasize that the direct-purchase authority is viewed by the Treasury as a temporary accommodation to be used only under unusual circumstances. The Treasury fully agrees with the general principle that our debt obligations should be floated in the market and that purchases of Treasury obligations by the central bank should normally be made through that same public market. The Treasury agrees also that the direct-purchase authority should not be considered a means by which the Treasury may independently attempt to influence credit conditions by usurping the authority of the Federal Reserve to engage in open market operations in Government securities. In that connection, it is important - 3 to emphasize that any direct recourse by the Treasury to Federal Reserve credit under this authority is subject to the discretion and control of the Federal Reserve itself. This concludes my prepared statement, Mr. Chairman. I will be happy to respond to any questions. Attachment oOo DIRECT BORROWING FROM FEDERAL RESERVE BANKS 1942 TO DATE Calendar Days Used Year 1942 1943 1944 1945 1946 1947 1948 1949 1950 1951 1952 1953 1954 1955 1956 1957 1958 1959 1960 1961 1962 1963 1964 1965 1966 1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 Note: Maximum Amount At Any Time (Millions) Number of Separate Times Used Maximum Number Of Days Used At Any One Time 6 $ 422 19 4 28 1,302 48 4 none 484 9 none none none 220 2 1 2 180 2 2 2 320 4 9 4 811 30 20 2 1,172 29 13 2 424 15 none none 207 none 2 none none none none none none 3 1 169 none 3 3 153 3 6 3 596 7 12 2 1,102 8 21 7 1 610 none 1 1 38 9 6 3 485 1 1 1 131 10 7 4 1,042 1 2,500 16 none 4 Federal Reserve direct purchase authority expired on April 30, 1978, Office of the Assistant Secretary (Domestic Finance) June 23, 1978 June 26, 1978 A number of inquiries have been received from the press concerning the Treasury Department's intention to initiate one or more "fast track" anti-dumping proceedings concerning imported steel mill products under the "Trigger Price Mechanism." The "grace period" for flat-rolled products and rods imported under fixed-term contracts concluded before January 9, 1978 ended on April 30th. Since that date, Customs reports both significant reductions in volume of imports of such products and virtually no imports of such products below applicable "trigger prices." However, some imports below "trigger price" have been identified. These are now being investigated by Customs. The suppliers questioned are claiming that all or most of their shipments either involved a related US importer and have been or will be resold at or above trigger prices (plus all costs of importation, storage, handling and resale in the US), or that delivery was delayed beyond the grace period due to uncontrollable events such as customs brokers' delays. All such claims are being examined carefully. In cases involving resale by a related importer, documentation of all resale invoices are being requested and reviewed to assure that the imported steel was sold to the customer at trigger price plus appropriate charges for importation, storage, handling and resale. -2After Customs has finished its preliminary investi gation of the facts, Treasury will determine whether initiation of a formal anti-dumping investigation is warranted. kfartment of theJREASURY HNGTON, D.C. 20220 TELEPHONE 566-2041 FOR IMMEDIATE RELEASE June 27, 1978 Contact: Robert E. Nipp 202/566-5328 BEET SUGAR DUMPING COMPLAINT INVOLVING THE EUROPEAN COMMUNITY The Treasury Department announced today that it has received a complaint from a group of beet sugar producers in Michigan claiming that about 50,000 tons of sugar from the European Community were being imported at prices substantially below those charged in European domestic markets and benefiting from subsidies paid by the Community exceeding the price at which the sugar was sold for export to the United States. Because portions of these shipments have begun to arrive in the United States through the Port of Savannah, the Customs Service began immediate preliminary investigations to determine whether proceedings should be initiated under the Antidumping Act of 1921 and the Countervailing Duty Law. Under the Antidumping Act, special dumping duties may be assessed on imports found to have been sold at less than "fair value"—generally the price at which merchandise is sold on the home market of the exporter—and such sales injure or threaten injury to a domestic industry. Under the countervailing duty law, special countervailing duties may be assessed on imports found to have benefited from "bounties" or "grants" paid to the producer or exporter by a foreign government. The size of the alleged shipments and the prices at which the sugar is claimed to have been sold have prompted Treasury to expedite consideration of the matter. o B-1003 0 o For Release Upon Delivery Expected at 10:00 a.m., E.S.T. STATEMENT OF DANIEL I. HALPERIN, TAX LEGISLATIVE COUNSEL OFFICE OF THE ASSISTANT SECRETARY OF TREASURY FOR TAX POLICY BEFORE THE SUBCOMMITTEE ON PRIVATE PENSION PLANS AND EMPLOYEE BENEFITS OF THE SENATE FINANCE COMMITTEE June 27, 1978 Mr. Chairman and Members of the Subcommittee: I am pleased to have the opportunity to appear before you today to discuss the Chairman's bill, S. 3140. The bill would combine the administrative simplicity of separate retirement funds for each employee (as under Individual Retirement Accounts (IRAs)) with the higher contribution level permitted for the self-employed when they adopt plans for their employees (so-called Keogh or H.R. 10 plans). For employers who choose to adopt the type of plan created under the bill, it will achieve simplification without detriment to the tax policies underlying the favored tax treatment of employee retirement plans. Therefore, we are pleased to support the bill and encourage its early enactment by the Congress. At the same time, we would urge one modification regarding integration with the Social Security system. We would also wish to raise one significant issue of retirement policy for the Subcommittee's consideration, namely, the impact of the proposal on the choice between a defined benefit and a defined contribution plan. I will discuss these matters and several other features of the bill in the remainder of this testimony after outlining the bill's provisions. Basic Outline of the Bill The bill builds upon the framework of the IRA provisions added to the Internal Revenue Code by ERISA. Current law (section 408(c)) provides for the establishment of group individual retirement accounts by employers or B-1004 - 2 associations of employees on behalf of employees. Deductible contributions to these IRAs, like contributions to all other IRAs, are made only by employees, and they are generally limited to the lesser of $1,500 or 15 percent of annual compensation. Deductible contributions cannot be made by an employee if he or she was an active participant in a qualified plan during any part of the taxable year. The bill would expand upon the concept of employermaintained IRAs, which have not been widely used up to now. It would authorize deductible employer contributions to such an IRA, with the employer contribution being limited to the lesser of 15 percent of gross income or $7,500. This conforms to the deductible limitation for employer contributions on behalf of a self-employed individual under a Keogh plan. In order to obtain this status, the simplified plan must be an employer-sponsored group IRA meeting a combination of requirements under the IRA provisions and the qualified plan provisions which would insure maximum security once the funds have been contributed and, further, would insure against discrimination in favor of highly-paid employees. Thus, for example, participation would have to be on a nondiscriminatory basis, an employee could not be denied participation on the basis of service once he or she has completed three years of service, and employer contributions would be fully and immediately vested. Another significant feature of the bill is that if an employer's contribution for an employee is less than the annual IRA limitation for that employee, the individual could make up the difference. From the employer's point of view, the bill proposes simplified reporting and disclosure requirements and the further simplification of the plan itself. Simplified plan design could be achieved either through adoption of a model plan or through an individually designed plan which would be simpler than the typical employer plan under present law. I would like to turn now to four specific considerations in connection with the bill. - 3 Discrimination The present Code provision for employer-sponsored IRAs does not contain any anti-discrimination rules. There have been suggestions that the provision be amended to add such rules. However, we have viewed such an amendment as a fruitless exercise within the framework of the current IRA provisions. Current law provides no incentive for an employer to establish a group IRA plan as opposed to individual plans. Therefore, anti-discrimination requirements for employer-sponsored plans could be circumvented by the simple technique of individual employees establishing IRAs, perhaps with the aid of the employer. The bill, however, does provide an incentive for the employer to establish the simplified plan. It accomplishes this by allowing substantial deductions for employer contributions to such plans. The bill also precludes the establishment of employer-sponsored IRAs on a discriminatory basis. Therefore, we believe the bill represents a meaningful effort to eliminate discrimination in this area. Employee Contributions The bill will allow an employee to contribute and deduct the difference between the employer's contribution and the deductible limitation for IRAs applicable to the employee under current law. This will alleviate a problem which has existed since the IRA provisions were enacted as part of ERISA. An employee may not make a deductible contribution to an IRA if he or she is an active participant in a qualified plan for any part of the taxable year. This has caused certain employees to view participation in a qualified plan as detrimental because employer contributions to a qualified plan on their behalf are quite small or because the employee does not expect to vest in a retirement benefit under the employer-maintained plan. Several proposals have been made in this Congress and the previous Congress to deal with this problem. In some cases, those proposals have contained defects either because they were extremely complicated or because they allowed extra IRA contributions on a discriminatory basis. In some cases, both defects were present. S. 3140 is much more satisfactory from this standpoint. First, the bill resolves the problem of an employee who changes jobs frequently and might never vest under an - 4 ordinary retirement plan. Under the simplified plan, that employee's benefits are always fully vested and fully portable. .Secondly, it is designed to encourage retirement savings for low-income persons. As an illustration, assume the employer maintains a simplified plan for the benefit of two employees, one of whom earns $30,000 while the other earns $10,000. An employer contribution of 10 percent of compensation on behalf of each will result in contributions of $3,000 and $1,000 respectively. The higher-paid employee will not be able to make an extra IRA contribution, because the employer contribution already exceeds the employee's $1,500 deductible limitation. On the other hand, the $10,000 employee can make an extra IRA contribution up to $500. Finally, and most importantly, it has a built-in overall $1,500 limit which would generally prevent excessive combining of IRA contributions with benefits under a qualified plan. I must caution, however, that this privilege could be abused if an employer establishes more than one plan. For example, if the employer maintains a profit-sharing plan to which it makes substantial contributions, the employer should not be able to adopt a simplified plan described in the bill and make very small contributions, thereby allowing highly-paid individuals to make deductible excess IRA contributions to almost the full extent of the IRA deduction limitation. Thus, the ability to deduct employee contributions should be limited to those who do not participate in a qualified plan other than the new simplified plan. More complex solutions should be avoided. IRAs are intended to be simple arrangements understandable by unsophisticated individuals who do not have access to advice from attorneys, accountants, and other advisors. Unfortunately, the existing IRA provisions are already extremely complicated and contain many traps for taxpayers who do not precisely follow the rules. We urge that these problems not be magnified by the adoption of complex rules under the bill. Integration As we understand it, the bill would allow a simplified plan to be integrated with Social Security under the current integration rules for Keogh plans. Integration is accomplished in a Keogh plan by taking into account Social Security taxes paid on behalf of employees as plan contributions by the employer for the employees. - 5 We have been concerned about the current integration rules. At their worst, they have resulted in qualified plans which benefit only highly-compensated employees. This undercuts the rationale reflected in the anti-discrimination rules for qualified plans — that is, tax benefits associated with qualified plans should serve as an incentive for an employer to provide retirement benefits for employees at all levels of income. These concerns led to the proposal for changes in the integration rules contained in the President's Tax Reform Program. Under the tax reform proposal, a plan could still be integrated with Social Security, but only if it provides substantial benefits for all participating employees.* A number of persons who have objected to the integration proposal have not done so on the merits. Rather, they have been concerned that a shift in the integration rules will necessitate relatively widespread plan amendments following closely upon the amendments which have just been made to meet the standards enacted by ERISA. For those people, the primary objection has been the cost and administrative problems associated with amendments rather than the ongoing costs of meeting the proposed ratio. Since S. 3140 would result in entirely new plans, the amendment problem would not exist. Therefore, we suggest to the Subcommittee that it consider allowing integration only where a simplified plan satisfies the President's integration proposal. Defined Benefit Plans As a practical matter, the approach taken by S. 3140 lends itself only to defined contribution plans. The employer contributes a specified percentage of pay which is deposited in each employee's account. The level of retirement benefits is not specified but will be the amount which can be derived from the sum contributed and the earnings thereon. In contrast a defined benefit plan provides for a specific benefit, example, $10 per month * Specifically, the proposal for for defined contribution plans is that the proportion of contributions allocable to compensation above the integration level may not be in a ratio greater than 1.8 times the proportion of contributions allocable to compensation below the integration level. As a result of testimony before various committees and discussion with interested persons, we are prepared to modify that proposal so that the basic ratio may be 2 to 1 rather than 1.8 to 1. - 6 per year of service, 1 percent of career average pay per year of service, 1 percent of average pay over the last five years of service per year of service. Since the employer's contribution to this type of plan is affected by the investment performance and the age of the participant and in some circumstances by changes in the compensation level, a defined benefit plan does not easily fit into the individual account pattern required for the simplified plan. Because it established minimum funding requirements, premium payments for plan termination insurance and in some cases employer liability upon plan termination, ERISA may have made defined benefit plans less attractive compared to defined contribution plans than they were prior to the enactment of the legislation. From one point of view this is a beneficial effect of ERISA. Some conceive of the employer's contribution to a pension plan as a payment in lieu of an increase in current salary and, therefore, each employee should have a nonforfeitable right to his or her proportionate share of the contribution. Others argue that defined contribution plans are more meaningful to those who spend less than a full career with one employer . Contributions under such plans tend to be a level percentage of pay regardless of age. If it is assumed salary will increase and that an adequate retirement income must be measured against earnings at the time of retirement, the contribution level will be higher than it would be if earnings were expected to remain steady.* Thus, the vested benefit under a defined contribution plan could include some provision for anticipated increases in earnings. Under a defined benefit plan the value of a vested benefit is determined by reference to earnings at the time of separation from service. Therefore, the amount of a lifetime pension, even if full vesting is achieved, will be less if the employee changes jobs than if he or she stays with one employer. A defined contribution plan could produce the same benefit in both situations. On the other hand, a defined benefit plan can more easily adjust for changes in salary and plan earnings. Particularly if it promises a specified percentage of Khif works out correctly if the rate of salary growth is both uniform among employees and correctly anticipated. It also ignores the difficulty of providing for past service under a defined contribution plan started or improved when the employee is in mid-career. - 7 pre-retirement pay, such a plan is much more meaningful to the employee in facilitating planning for retirement. Very few employees can estimate the adequacy of a benefit from a defined contribution plan. Therefore, on balance we think a shift in plan design toward defined contribution plans would be unfortunate. We believe there needs to be a study as to whether such a shift has taken place and if so whether it furthers the interests of providing retirement security for employees as a group. We do not think, however, that this word of caution should deter prompt action on S. 3140. o 0 o itjartmentoftheTREASURY 6T0N.D.C. 20220 TELEPHONE SS8-2041 FOR IMMEDIATE RELEASE June 26, 1978 RESULTS OF TREASURY'S WEEKLY BILL AUCTIONS Tenders for $2,300 million of 13-week Treasury bills and for $3,400 million of 26-week Treasury bills, both series to be issued on June 29, 1978, »<e:eaccepted at the Federal Reserve Banks and Treasury today. The details are as follows: .RANGE OF ACCEPTED 13-week bills (COMPETITIVE BIDS: maturing September 28, 1978 Price Discount Rate Investment Rate 1/ 98.245a/ 6.943% 7.17% High 98.237 6.975% 7.20% Low 6.967% 98.239 7.19% Average a/Excepting 3 tenders totaling $480,000 26-week bills maturing December 28, 1978 Discount Investment Price Rate 96.266b/ 96.258 96.261 Rate 1/ 7.78% 7.80% 7. 7.386% 7.402% 7.396% b/ Excepting 1 tender of $1,790,000 Tenders at the low price for the 13-week bills were allotted 97%. Tenders at the low price for the 26-week bills were allotted 52%. TOTAL TENDERS RECEIVED AND ACCEPTED BY FEDERAL RESERVE DISTRICTS AND TREASURY: Location Received Accepted Received Boston few York ^ladelphia Cleveland ichmond Atlanta Chicago St - Louis Minneapolis Ka nsas Citv Dallas $ $ $ San ^ancisco heasurv TOTALS 17,870,000 3,519,985,000 29,050,000 38,025,000 16,405,000 23,200,000 172,455,000 34,155,000 14,410,000 21,660,000 17,075,000 272,370,000 5,925,000 $4,182,585,000 17,720,000 1,891,125,000 29,050,000 23,025,000 14,405,000 23,100,000 118,240,000 23,155,000 11,320,000 20,860,000 11,075,000 111,470,000 5,925,000 $2,300,470,000c/. 11,160,000 4,720,340,000 7,545,000 57,260,000 29,655,000 30,290,000 310,105,000 33,170,000 12,550,000 14,850,000 8,400,000 464,035,000 Accepted $ 11,160,000 2,796,160,000 7,305.000 16,070,000 8,655,000 19,095,000 165,445,000 20,110,000 7,150,000 1.4/485,000 8,400,000 323,035,000 2,980,000 2,980,000 $5,702,340,000 $3,400,050,000d/ uriVS ^ 3 1 5 > 6 5 0 > 0 0 0 noncompetitive tenders from the public j. !fcs$191,025,000 noncompetitive tenders from the public a -^nt coupon-issue yield. FOR RELEASE AT 4:00 P.M. June 27, 1978 TREASURY'S WEEKLY BILL OFFERING The Department of the Treasury, by this public notice, invites tenders for two series of Treasury bills totaling approximately $5,700 million, to be issued July 6, 1978. This offering will not provide new cash for the Treasury as the maturing bills are outstanding in the amount of $5,707 million. The two series offered are as follows: 91-day bills (to maturity date) for approximately $2,300 million, representing an additional amount of bills dated an( t o April 6, 1978, * mature October 5, 1978 (CUSIP No. 912793 T6 3) t 'originally issued in the amount of $3,406 million, the additional and original bills to be freely interchangeable. 182-day bills for approximately $3,400 million to be dated July 6, 1978, and to mature January 4, 1979 (CUSIP No. 912793 W2 8) . Both series of bills will be issued for cash and in exchange for Treasury bills maturing July 6, 1978. Federal Reserve Banks, for themselves and as agents of foreign and international monetary authorities, presently hold $3,514 million of the maturing bills. These accounts may exchange bills they hold for the bills now being offered at the weighted average prices of accepted competitive tenders. The bills will be issued on a discount basis under competitive and noncompetitive bidding, and at maturity their par amount will be payable without interest. Except for definitive bills in the $100,000 denomination, which will be available only to investors who are able to show that they are required by law or regulation to hold securities in physical form, both series of bills will be issued entirely in book-entry form in a minimum amount of $10,000 and in any higher $5,000 multiple, on the records either of the Federal Reserve Banks and Branches, or of the Department of the Treasury. Tenders will be received at Federal Reserve Banks and Branches and at the Bureau of the Public Debt, Washington, D - C 20226, up to 1:30 p.m., Eastern Daylight Saving time, Monday, July 3, 1978. Form PD 4632-2 (for 26-week series) or Form PD 4632-3 (for 13-week series) should be used to submit tenders for bills to be maintained on the book-entry £-1006 records of the Department of the Treasury. -2Each tender must be for a minimum of $10,000. Tenders over $10,000 must be in multiples of $5,000. In the case of competitive tenders the price offered must be expressed on the basis of 100, with not more than three decimals, e.g., 99.925. Fractions may not be used. Banking institutions and dealers who make primary markets in Government securities and report daily to the Federal Reserve Bank of New York their positions in and borrowings on such securities may submit tenders for account of customers, if the names of the customers and the amount for each customer are furnished. Others are only permitted to submit tenders for their own account. Payment for the full par amount of the bills applied for must accompany all tenders submitted for bills to be maintained on the book-entry records of the Department of the Treasury. A cash adjustment will be made on all accepted tenders for the difference between the par payment submitted and the actual or issue price as determined in the auction. ii No deposit need accompany tenders from incorporated banks and trust companies and from responsible and recognized dealers in investment securities for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, or for bills issued in bearer form, where authorized. A deposit of 2 percent of the par amount of the bills applied for must accompany tenders for such bills from others, unless an express guaranty of payment by an incorporated bank or trust company accompanies the tenders. Public announcement will be made by the Department of the Treasury of the amount and price range of accepted bids. Competitive bidders will be advised of the acceptance or rejection of their tenders. The Secretary of the Treasury expressly reserves the right to accept or reject any or all tenders, in whole or in part, and the Secretary's action shall be final. Subject to these reservations, noncompetitive tenders for each issue for $500,000 or less without stated price from any one bidder will be accepted in full at the weighted average price (in three decimals) of accepted competitive bids for the respective issues. Settlement for accepted tenders for bills to be maintained on the book-entry records of Federal Reserve Banks and Branches, and bills issued in bearer form must be made or completed at the Federal Reserve Bank or Branch or at the Bureau of the Public Debt on July 6, 1978, in cash or other immediately available funds or in Treasury bills maturing July 6, 1978. Cash adjustments will be made for differences between the par value of the maturing bills accepted in exchange and the issue price of the new bills. -3Under Sections 454(b) and 1221(5) of the Internal Revenue Code of 1954 the amount of discount at which these bills are sold is considered to accrue when the bills are sold, redeemed or otherwise disposed of, and the bills are excluded from consideration as capital assets. Accordingly, the owner of these bills (other than life insurance companies) must include in his or her Federal income tax return, as ordinary gain or loss, the difference between the price paid for the bills, whether on original issue or on subsequent purchase, and the amount actually received either upon sale or redemption at maturity during the taxable year for which the return is made. Department of the Treasury Circulars, No. 418 (current revision), Public Debt Series - Nos. 26-76 and 27-76, and this notice, prescribe the terms of these Treasury bills and govern the conditions of their issue. Copies of the circulars and tender forms may be obtained from any Federal Reserve Bank or Branch, or from the Bureau of the Public Debt. FOR RELEASE UPON DELIVERY EXPECTED AT 9:00 A.M. THURSDAY, JUNE 29, 1978 STATEMENT OF THE HONORABLE DANIEL H. BRILL ASSISTANT SECRETARY OF THE TREASURY FOR ECONOMIC POLICY BEFORE THE SUBCOMMITTEE ON TAXATION AND DEBT MANAGEMENT OF THE SENATE FINANCE COMMITTEE Mr. Chairman and members of this distinguished Committee: The issue before us today is that of determining the most effective way of encouraging more investment. There is no disagreement among us as to the importance of this objective. It is clear, from many perspectives, that too much of our output of goods and services is devoted to current consumption, and too little to investment in new and more efficient tools of production—investment that will permit future growth in consumption. Even after three years of recovery, real business fixed investment remains below its prerecession peak. As a result, our capacity to produce is growing too slowly, at less than a 3 percent annual rate compared with over 4-1/2 percent in the first two postwar decades. Paralleling this sluggish growth in investment and capacity has been a deceleration in the rate of growth cf productivity, B-1007 -2the factor responsible for a major share of U.S. economic growth. This slowdown in productivity growth adversely affects our ability to achieve price stability and our ability to remain competitive with producers abroad. We are all dedicated, therefore, to the search for the most effective ways of promoting increased capital formation. There are before us specific proposals to encourage capital formation by reducing the tax on capital gains. Fundamentally, these proposals rest on the premise that reduction in the capital gains tax will have a very favorable effect on stock prices, and that the resulting enhancement of stock prices will, by increasing the wealth of investors and/or reducing the cost of raising equity capital, encourage a higher rate of investment. Admittedly, the argument appears intuitively plausible. One might indeed expect some favorable reaction in stock prices if the capital gains tax were reduced. And one might also expect that a reduction in the cost of equity capital— the result of rising stock prices—would encourage some additional investment, since the inability to obtain equity funds is generally recognized as one of the barriers to investment, particularly for smaller companies. The critical question is by how much. We have only a limited amount of resources to devote to tax preferences for -3investment. Is this use—a reduction in revenues from lower capital, gains taxes—a cost-effective way of promoting investment? Unfortunately, there is little direct historical evidence on which to base an analysis. There has been no reduction in capital gains tax rates in the past quartercentury, only increases. One must, therefore, argue the case for capital gains tax reduction by assertion or analogy, which is just what has been done in three major studies of the problem—the study sponsored by the Securities Industry Association (SIA), the study conducted by Merrill Lynch (ML) and the study conducted by Chase Econometric Services, Inc. (Chase). I would like to comment on the methodology employed in each of the surveys, particularly with respect to those variables critical to a determination of the effectiveness of capital gains tax changes in influencing investment. In the study sponsored by the Securities Industry Association, the argument is made by assertion. A specific and arbitrary assumption is made that complete elimination of the capital gains tax would result in a 20 percent increase in stock prices over the first five quarters after the tax change is implemented. This assertion, along with other -4assumptions about the extent to which higher prices will encourage shareholders to realize their gains, are inserted into the economic model constructed by Data Resources, Inc. (DRI), and the model is run to produce estimates of the resultant growth in GNP, in business investment, and in Federal revenues resulting from the higher GNP. The results are not surprising: higher stock prices, resulting in a greater amount of realization of capital gains, will increase incomes, investment and Federal revenues—all by substantial amounts. For example, two years after the elimination of the capital gains tax, real GNP in the SIA simulation would be about $47.5 billion (1978 $) higher, nonresidential fixed investment nearly $18 billion higher, the Federal budget deficit (NIA basis) about $10.5 billion lower, and the unemployment rate 0.7 percentage points lower. All delightful outcomes, devoutly to be wished. But all resting very heavily on an assumption that stock prices would increase by 20 percent in response to the postulated change in capital gains tax, and questionable econometric relationships implying that the higher level of stock prices would spur consumption and investment to such dramatically higher levels. -5Another study of the potential effect of capital gains tax reduction was undertaken by Merrill Lynch. In this study, it was assumed that the capital gains tax would be reduced in the third quarter of 1978, not to zero but to a new maximum rate of 25 percent. The result of such a tax change is assumed to reduce the cost of new equity capital by some 25 to 30 basis points. This assumption is traced through an econometric model to show the effect on overall stock prices, on investment and on gross national product. The results indicate a potential rise in stock prices of only 4 to 6 percent, an increase in 1980 GNP of only 0.3 percent, and increased Federal revenues sufficient to result in about a $2.5 billion smaller deficit despite an initial tax cut of about $2 billion. It is most important to emphasize again that this study, as did the SIA study, rests on assumptions about the effects of capital gains tax rate changes on stock prices, not on any empirical evidence of the effects. In the ML case, the effects assumed are those on the cost of new equity capital, which is translated into the prices of all equity issues. The ML assumptions about stock price response are more modest than those used in the SIA study, and the projected benefits to the economy and on the Federal deficit are correspondingly more modest. But they still rest on assumptions. -6The third study which we reference today is that undertaken by Chase Econometric Services, Inc. Here, the effect on stock prices of a reduction of capital gains taxation to a 25 percent maximum rate is stated to be a rise of nearly 40 percent in stock prices over the next two years which, in turn, increases gross national product, investment and Federal revenues. The Chase analysis does not rest on an assumption about the stock price response to capital gains tax reduction. Rather it is based on an equation "...empirically determined from multiple regression analysis and is not simply an assumption pulled out of thin air." It is worth examining this statement further, for any equation that can adequately explain stock price behavior is likely to be of interest to a wider audience than only those concerned with capital gains tax provisions. The Chase study states that fluctuations in stock prices can be explained by seven factors, or variables. These variables include interest rates, corporate profits, replacement cost adjustment to capital consumption allowances, dividend payments, disposable personal income and two variables relating to maximum tax rates: the maximum tax rate on capital gains, and a variable apparently intended to capture the effect of legislated changes in the maximum tax rate on earned income. The latter is set at zero -7from 1955 through 1968, and at 20 for the years after 1968. The results of the Chase equation purport to tell us that (a) changes in the capital gains tax rate explain about one-fourth of the fluctuation in stock prices over the period from 1955 to 1977 and (b) a reduction in the maximum capital gains tax rate to 25 percent would result in a 40 percent rise in stock prices within a two-year period. This is a far more dramatic effect on stock prices than is assumed in either the SIA or the Merrill Lynch study. Are there results derived from the Chase equation statistically valid? I*m afraid they must be regarded as suspect. The methodology used commits several grievous statistical sins. In the parlance of the statistical profession, the Chase equation is guilty of multicollinearity and serial correlation, as well as improper specification. I will not take up the Committee's time with methodological points; these are covered in a brief technical note attached to my statement. It is important to note, however, that the existence of such a defect as multicollinearity (technical jargon for the case where two of the factors used to explain -luctuations in a third are in themselves highly interrelated) means that the measure of the relative importance of the capital gains tax in explaining stock prices is subject -8to large statistical error. This is borne out by the fact that if one of the redundant variables is dropped from the equation, the results change dramatically; in this case, the rise in stock prices resulting from reduction in the capital gains tax falls to 9 percent, from the 40 percent claimed for the original equation. The existence of serial correlation—condition where differences between actual observations and the values estimated by an equation show a persistent pattern—also means that the equation is not statistically reliable. This can easily be confirmed by applying one of the standard techniques for correcting for serial correlation. When one applies this correction to the Chase equation, the importance of changes in the capital gains tax rate in explaining stock price behavior is reduced significantly. The major point to be made about the three studies relating to the effect of capital gains taxes is that in two of them, the results rest very heavily on assumptions about the critical factor of the response of stock prices, and in the third study, the attempt to use analytic techniques instead of assumptions suffers from such serious methodological flaws as to vitiate the results. On the stock price response factor, the studies differ widely: one study asserts that -9complete elimination of the capital gains tax would result in a 20 percent rise in stock prices, another that only partial elimination of the tax would yield a 40 percent rise, and the third that partial elimination would result in only a 4 to 6 percent stock price increase. The second point to be made about these studies is that they yield widely different results as to the economic benefits to be expected from a capital gains tax reduction and the ensuing rise in stock prices. The 20 percent rise in prices assumed for the SIA study would, in their calculation, produce a rise in total output—GNP—some 9 times as great as the initial tax reduction. The Merrill Lynch calculations yield a multiplier of only 2, and the Chase calculations a multiplier of about 3-1/2. It should also be noted that most of the projected increase in GNP in the SIA study develops in consumption, not investment; the Chase study has more of the benefits accruing to investment and the Merrill Lynch study splits its modest effects more evenly between consumption and investment. Thus, the studies are all over the map not only with respect to stock price impacts but also as to the purported benefits flowing from tax reduction. How reasonable are the assumptions about the effect of a capital gains tax reduction on stock prices? As noted -10earlier, there is little directly relevant historical experience, so the argument has to be made—if at all— by analogy. Thus, some proponents of capital gains tax reductions have simply cited the record of stock prices before and after the Tax Reform Act of 1969, which raised the maximum rates payable on realized capital gains. In the eight years after enactment of higher capital gains rates (from 1969 to the end of 1977), stock prices rose only 0.4 percent, compared with a 47.6 percent rise in the eight years preceding the imposition of higher taxes. Q.E.D.: raising capital gains taxes has tended to reduce stock price gains and, therefore, the converse must be true; lowering the capital gains tax rate would raise stock prices. But when one looks behind this glib, rather superficial analysis, a different and more puzzling story emerges. The Tax Reform Act of 1969 was signed on December 30, 1969, and most provisions became effective on January 1, 1970. Since it may have been anticipated that the capital gains tax rate would be increased, even before the change was formally enacted, one might have expected a rise in stock market volume and a decline in prices in 1969, as investors hurried to realize capital gains before the new higher tax rates were imposed. But stock prices started their decline a t the end of 1968—long before any expectation of higher tax -11rates—and both trading volume and the volume of realized gains declined in 1969. After the new tax rates became effective, stock prices rose from mid-70, until they reached a peak in January 1973. In the two and a half year period after higher tax rates were in effect, the stock price index rose by 46 percent. It is difficult to explain why prices and realizations, went u£ after the effective date, and it certainly raises doubts about the signficance of the maximum tax rate on investor decisions, at least in the 1969-73 period. Of course, since 1973, stock prices have behaved poorly. But it does strain credulity to attribute the behavior of stock prices to continued high capital gains taxation alone in a period marked by such events as an oil embargo, a quintupling of oil prices, a worldwide investment boom accompanied by double-digit inflation and double-digit interest rates, followed by the worst recession since 1930fs. To explain stock price behavior since 1973 exclusively in terms of a higher capital gains tax, in the midst of such sweeping economic trauma, requires some stretching. Where does this leave the analysis? I submit that the verdict any jury would deliver is "case not proven". Reductions in capital gains taxation might—and I emphasize -12might—influence stock prices by some indeterminate amount, and this change in stock prices might—and again I emphasize might—be conducive to some rise in investment. But none of the studies discussed today provides a sound basis—only assertion or imperfect statistical analysis— for determining what quantities would result from such tax policy changes. Tax preferences for specific forms of income must essentially be classed as subsidies, whatever euphemism is used to disguise the subsidy. It would appear to me, therefore, a rather risky venture to dispense public funds for subsidies to investment on the basis of such meager analytical evidence as has been submitted. And the risk is particularly great when this form of subsidy would result in a significant distortion in the equity of our tax structure. Equity in our tax system is no trivial matter, in a society where every citizen is expected to pay his fair share of the cost of public services. Moreover, it is an unnecessary risk, since other incentives to capital formation, such as extension of the investment tax credit and/or a reduction in corporate income tax rates have a more direct relationship to business investment decisions. I would urge the Committee, therefore, to devote its attention -13to the proposals for investment credits and tax rate reductions in the program submitted by the President, rather than to divert its attention to unproven and inequitable remedies. Appendix on Methodology This appendix considers certain technical details affecting the results of the analyses of the impact of a capital gains tax reduction prepared by the Securities Industry Association (SIA), Merrill Lynch (ML) and Chase Econometric Services, Inc. (Chase) . Securities Industrv Association Studv Method of Simulation The Data Resources Inc. (DRI) model used in the SIA study is not readily ameniable to answering questions concerning the impact of changes in capital gains taxation on economic activity. Tax rates on capital gains do not appear as explicit exogenous variables in the model. In using the DRI model, SIA simulated the impact of a complete elimination of capital gains taxation by decreasing personal and corporate income tax rates by an equivalent amount (initially $5.1 billion). The appropriateness of lowering the personal tax rate for all consumers is dubious, in that it is largely individuals in the upper income tax classes who would benefit from a capital qains reduction, rather than the publie-at-large. As a consequence, the net effect of the SIA procedure is probably to over-estimate the effect on consumption, and hence the induced effect on investment, of cuts in the maximum capital gains tax rate. The SIA study found that a complete elimination of capital gains taxes would result in a $47.7 increase in real GNP over about a two-year period. This result implies tax multipliers of about nine—four to five times as high as the empiricallyderived personal and corporate income tax multipliers traditionally used in assessing the likely impact of tax changes on GNP. Assumed Increase in Stock Prices The very large multiplier effect of the SIA study reflects not only the questionable manner in which the tax reduction is introduced into the simulation, but also the assumed 20 percent stock price increase which feeds back, via a household wealth equation, to consumption and investment. If smaller increases in stock market prices are assumed, much smaller GNP, consumption and investment multipliers result. -2It is interesting to note that stock prices are endogenous in the DRI model and need not be specified exogenously. When one leaves stock prices endogenous and simulates a capital gains tax reduction, or elimination, the DRI model shows only very modest stock price changes. Chase Study Stock Price Equation Stock prices are endogenous in the Chase model. The Chase stock market prediction equation treats stock prices as a function of seven explanatory variables: (1) the maximum capital gains tax rate (six quarter weighted average); (2) a dummy variable set at zero from 1955 through 1968, and set at 20 for the years after 1968 intended to capture the effect of the 20-point change in the maximum rate on earned income; (3) prime commercial bank loan rate (percent); (4) corporate profits, after tax, with adjustments^for capital consumption and inventory valuation (billions of current dollars); (5) corporate capital consumption adjustment (billions of current dollars); (6) dividend payout ratio; and, (7) disposable income less transfer payments to persons (billions of current dollars). The Chase equation has several serious methodological and specification flaws which cast doubts about the credibility of its predictions. Serial Correlation The Chase stock market equation suffers from "serial correlation." Serial correlation is a technical term to describe the situation in which differences between the actual and the estimated values derived from an equation show a^ persistent pattern. The presence of serial correlation in the Chase equation is indicated by the low Durbin-Watson ratio (0.6 -3a standard measure used by econometricians to test for this problem. There are statistical techniques for correcting for serial correlation, e.g., the Cochrane-Orcutt correction. When one applies this particular correction to the Chase equation, then the coefficients—the values attributed to each explanatory variable—change radically. In particular, the importance of the capital gains tax rate in explaining stock price behavior drops sharply. The presence of serial correlation means, to technical workers in the field, that results derived from an equation suffering from this malady are essentially "inefficient" and hence, particularly unreliable in forecasting. Multicollinearity The maximum tax rate variable and the dummy variable included in the Chase stock market equation are highly correlated—a 0.9 7 correlation out of a possible 1.00. Largely as a result, the equation suffers from "multicollinearity", an ailment that saps the strength of statistical results. Johnston points out that when multicollinearity is present in an equation, "The precision of estimation falls so that it becomes very difficult, if not impossible, to disentagle the relative influences of the various...variables. This loss of precision has three aspects: specific estimates may have very large errors; these errors may be highly correlated, one with another; and the sampling variances of the coefficients will be very large... Estimates of coefficients become very sensitive to particular sets of sample data, and the addition of a few more observations can sometimes produce dramatic shifts in some of the coefficients." (Econometric Methods, 2nd Edition, 19 72, p.160). A standard way of treating an equation for multicollinearity is to omit one of the collinear variables from the equation. When the dummy variable is dropped,.the coefficient of the capital gains tax rate drops substantially, implying a stock market rise of only 9 percent instead of the nearly 40 percent implied by the uncorrected Chase stock market prediction equation. In addition to the methodological flaws discussed above, the Chase equation has specification defects—such as the use of the maximum tax rate on capital gains instead of the much -4lower actual effective rates paid by most taxpayers. Merrill Lynch Study In the methodology used by ML to analyze the impact of the Steiger Amendment, calculations of pre-tax and after-tax rates of returns to investors were made outside of the ML macro-model. Assumptions regarding the extent that the firm's cost of equity financing would decrease were made based upon these calculations. These assumed cost decreases were then fed into the ML model and the impacts upon the general economy observed. A 4-6 percent increase in stock prices was predicted. When one uses the ML methodology to simulate the impact of a complete elimination of capital gains taxation, the results are a stock price increase of 9 to 12 percent. These results cast further doubt on the reasonableness, of the 20 percent rate assumed by SIA and the 40 percent rate derived from the Chase equation. FOR RELEASE UPON DELIVERY Statement of the Honorable W. Michael Blumenthal on Capital Gains Tax Bills Before the Subcommittee on Taxation and Debt Management Committee on Finance June 28, 1978 Mr. Chairman and members of this Subcommittee: I welcome the opportunity to appear before this Subcommittee to present the Administration's views on three bills before you: S.3065, S. 2428 and S. 2608. Each of these bills would reduce the tax on capital gains for selected groups of taxpayers. Each aims at objectives of capital formation and growth. These objectives are shared by the Administration. But each bill has fatal flaws and either would not achieve its stated objectives at all, or would do so in an inefficient and inequitable manner. Accordingly, the Administration strongly opposes all three bills. I will devote the bulk of my testimony to S. 3065, the "Investment Incentive Act of 1978". To say that this Bill and its House counterpart have received extensive publicity is to engage in understatement. Suddenly, like flowers that bloom in the spring, the notion of reducing capital gains taxation is appearing everywhere as an all-purpose solution to the country's economic problems. Manifold and sweeping claims are made for this idea: It is advertised as a technique of middle class tax relief, or a measure to help homeowners. It is said that reducing capital gains taxes will substantially increase stock values. It is claimed that the Treasury will gain revenues by cutting these taxes. We are told that this is the best way to accelerate capital accumulation in the United States. Some even claim that other economies outperform us because they avoid taxing of capital gains. This Administration shares the goals espoused by the supporters of a capital gains tax reduction. We too wish to see stock prices rise. We too are concerned about Treasury revenues? and we are certainly as concerned as anyone about reducing the federal deficit. We too are vitally interested in spurring capital accumulation and investment, and believe that tax B-1008 -2incentives are needed for this. We too are anxious to employ every reasonable device to improve our performance with respect to inflation, unemployment, and exports. Our opposition to S. 3065, therefore, is based not on disagreement with its goals. Rather we are persuaded that this bill would not advance us toward these goals or would do so only in ways that are inefficient, inadequate and unjust. The tax reduction legislation that the Administration has proposed this year would meet two broad objectives: First, relief for the average taxpayers of this country who are finding their incomes increasingly pinched by rising tax liabilities. Second, a broad and significant increase in the after-tax return on capital, which will increase business investments by making them more attractive. Mr. Chairman, a dispassionate and objective analysis of S. 3065 shows that this bill and others like it would achieve neither of these goals while wasting Treasury revenues urgently needed to achieve these critical objectives in an efficient and equitable fashion. The Facts About Capital Gains Taxation Under Current Law Under current law, the net capital gain of an individual taxpayer is taxed at a rate equal to one-half of the taxpayer's rate on ordinary forms of income, such as wages, salary, dividends, interest, and rent. Those persons in tax brackets above 50% need pay only the 25% alternative rate on the first $50,000 of their net capital gains. For corporations, net capital gains may be taxed at an "alternative" 30 percent rate instead of the maximum 48 percent rate on other income. In addition to these basic provisions, the Tax Reform Acts of 1969 and 1976 introduced two elaborations. First, the 1969 Act imposed a "minimum tax" on those with very large amounts of capital gains income or other income benefitting from preferential provisions. After changes in the 1976 Act, the minimum tax for individuals is 15 percent of preference income in excess of either $10,000 or one-half of -3regular tax liability (whichever is greater). One-half of capital gain is considered "preference income". Therefore, if a taxpayer's only preference item is capital gain, the minimum tax applies only if total gains exceed $20,000. Second, the 1969 Act reduced the maximum tax rate on earned income — wages and salaries — from 70 percent to 50 percent, providing massive relief to high-income individuals. For these persons, the amount of earned income eligible for this special "maximum tax" ceiling is offset by the amount of preference income, including the untaxed half of capital gains. Now, what are the consequences of this structure of captial gains taxation? Who pays what? In 1978, capital gains taxes will raise $10.3 billion in revenue, $7.8 billion from individuals and $2.5 billion from corporations. Let's look at the individual side of the equation, where public attention has been concentrated. The average effective tax rate on capital gains in 1976 was 15.9 percent. (See Table 1.) For most Americans with capital gains, the effective rate is quite low: for instance, 12.7 percent for those between $20,000 and $30,000 in adjusted gross income, 16.7 percent for those between $30,000 and $50,000. Up to $200,000 a year, the effective rate is below 25 percent. Even for those over $200,000 the average effective rate is only 27.4 percent. Typically, therefore, the great majority of taxpayers pays taxes on capital gains at modest levels, considerably below the rate on ordinary earned or unearned income, and the progressiveness of the capital gains tax is quite moderate. The rate generally rises above 25 percent only where the taxpayer's income or gains are extraordinarily large, and even in these instances, the taxes are not at all extreme. In the current debate, much has been made of the possibility — under the maximum and minimum tax provisions enacted in 1969 and 1976 — that individuals may be paying a 50 percent tax or even more on their capital gains. The facts are much less alarming than the rhetoric. Capital gain, at all income levels, is still very much a preference item in our tax system. -4More than 60 percent of all capital gains " t a x e d at 25 percent or less. Of all returns showing capital gains, only about 7 percent is taxed above 25 percent. Though in theory the tax rate could exceed 50 percent, this would require a very implausible composition of income, and in fact we have been unable to find even one case where this has happened. We have found fewer than 20 returns — out of 5.4 m i l l l o n ' e t " " « ^.lth capital gains -- taxed at more than 45 percent. The capital gains tax very rarely goes above 40 percent. Rates over 40 percent have appeared in less than five hundredths of one Percent of returns with capital gains, involving less than four-tenths of one percent of gains. In sum, the Tax Reform Acts of 1969 and 1976 increased capital gains taxes for very high income individuals with very large gains, but these measures did not introduce unreasonable marginal rates and they left capital gains in a clearly preferred status. The facts about S. 3065 This bill is not a general measure to reduce capital gains taxes for everyone. Rather, it aims to reduce the capital gains rate for the highest income individuals with the largest amount of gains. As I have just noted, the overwhelming majority of taxpayers, realizing the great bulk of capital gains each year, pays substantially less than 25 percent on capital gains. This bill is not designed for this vast majority. Its relief is focused almost entirely on the small minority who^ now pays more than 25 percent. The bill would do the following. It would remove all non-taxed capital gains income from the minimum tax, rather than exempting the first $10,000 of untaxed gain (or one-half of regular tax liability), as under present law. It would eliminate the present capital gains offset against wage and salary income eligible for the maximum tax. It would extend the 25 percent alternative tax to an unlimited amount of gain, as opposed to the $50,000 of gain eligible for this rate under present law. Finally, it would reduce the "alternative" rate on capital gains for corporations from 30 to 25 percent. For these changes in the law, very expansive claims have been made. We have examined those claims closely. Few of them stand up against such analysis. At best, it can be said that some of the claims can be neither proven nor disproven. For the most part, however, the claims run flat against the available evidence. -5- The proponents say that S. 3065 constitutes broad based tax reduction, in line with the so-called "middle class tax revolt". The facts are otherwise. About 20 percent of the bill's benefits would go to corporations. For individuals, the bill's benefits are skewed heavily to the highest income taxpayers. Four-fifths of the bill's benefits go the those with incomes over $100,000 a year. Mr. Chairman, this bill would provide lower taxes for less than one-half of one percent of the individual taxpayers in this country and would benefit only about 7 percent of the taxpayers that have capital gains. This is in truth a millionaire's relief bill, and I mean income millionaires, whose assets are usually many times greater than that. Of those million dollar earners benefitted by S. 3065, about 3,000 of them throughout the country, each would receive on average $214,000 in tax reduction. For all million dollar earners the average relief would be $145,000. By contrast, the average relief for those in the $20,000 to 30,000 class would one dollar. (See Table 2.) The bill's proponents assert that it would trigger a stock market boom. The studies said to show this result simply assume the fact, or rather they assume different facts. Bear in mind that the bill would reduce taxes on corporate stock gains by only $500 million. Yet, one study assumes the bill would raise stock values by 40 percent, a rise of more than $300 billion or 600 times the size of the tax cut; another study suggests only a 4 to 6 percent rise in stock values, which is still 60 times the size of the cut. A third study, which presumes total elimination of the capital gains tax, rather than the selective cuts in S. 3065, predicts a 20 percent rise in stock values. This is all the sheerest conjecture. The truth is that no one has any credible evidence or theory permitting a projection of the bill's impact on the stock market, and certainly there is no basis for the extreme assumptions that have dominated public discussion of the bill. If we look at recent stock market behavior, it is difficult to avoid the conclusion that the effects of capital gains tax changes, if any, are wholly swamped by other stock market influences. The bill's proponents often suggest that the 1969 Tax Reform Act lies behind the stock market's doldrums during the 1970's. However, the stock market fell sharply in 19/69, before the tax increases from the Reform Act took effect. Then the market rebounded sharply from 1970 through 1972 — the same -6period during which the reforms, were fully phased in. Then, as inflationary momentum accelerated in 1973, there was a huge fall in stock prices, though the tax law was not changed at all. (See Chart 1.) Analysis of stock market prices over the last ten years shows no relationship between the capital gains tax and the market's level. The record does not show that that the capital gains tax changes in the Reform Acts of 1969 and 1976 depressed stock prices. The assertion that repeal of those reforms would now raise stock prices is just that, an assertion, unsupported by evidence. Proponents of S. 3065 have noted that it would provide relief for homeowners forced to pay capital gains taxes upon sale of their residences, in those instances where the gain cannot be rolled over into purchase of a new residence. This aspect of the measure, we wholeheartedly support. The President's tax package provides nearly identical relief for homeowners. A further claim of the proponents is that this bill would greatly spur capital formation. Accelerating the rate of capital formation — particularly industrial and technological investment — is a priority objective of this Administration, but S. 3065 is not the way to go about it. Why is this so? The test of a tax cut for investment is how generally and directly it reduces the tax burden on income from productive capital. In applying this test, it is important to keep in mind two facts. First, productive capital is taxed in many ways — by the corporate income tax, the individual income tax, the capital gains tax, etc.. We don't have a single, unique tax on capital income; rather we have many taxes which together place a burden on capital. Capital gains tax is not the major tax on capital income. It accounts for only about 10 percent of the federal tax burden on capital. (See Table 3.) Second, the kind of capital we particularly need to accumulate is industrial and technological capital. Many types of assets — for instance jewelry, antiques, speculative real estate, and the like — are of much less importance to our economy's ability to adapt, grow, and compete in international markets. The President's tax proposal takes these two important facts into account. Through broad based reductions in corporate and individual income tax rates, and through a liberalization of the investment tax credit, the President's package would reduce -7the major taxes burdening capital income by about $7 billion and would directly increase the profitability and cash flow of all productive enterprises. It is a package ideally suited to increasing the rate of formation of productive capital. By contrast, S. 3065 is very poorly suited to this job. As I've noted, capital gains taxes constitute only about 10 percent of the federal tax burden on capital income. Reducing the capital gains tax would therefore deal with only a very small corner of the problem. Furthermore, it is in many respects the wrong corner. Only about one-quarter of realized capital gains come from corporate stock. The rest are scattered over a range of assets having little or no role to play in the kind of investment boom this country needs. For instance, another quarter of the realizations is on real estate sales, 3.4 percent on livestock, 2.5 percent on commodities, 9.7 percent on installment sales, etc. (See Table 4.) This bill would create windfalls on assets all over the landscape, but it would largely detour around the central objective, which is to reduce significantly and broadly the tax burden on income from productive investment. This bill takes a very inefficient approach to capital formation. This inefficiency is a fatal flaw for the simple reason that we do not have unlimited revenues available to stimulate capital formation. To keep the budget deficit in bounds, the Administration believes next year's total tax reduction should not exceed $20 billion. The bill before you would take up over $2 billion of that amount. This would have to come at the expense of wage and salary earners, which would be clearly inequitable, or at the expense of the corporate income tax reductions, which would render the bill a much less effective vehicle for capital formation. The only other choice is to increase the budget deficit, which would be an inflationary and irresponsible course. The proponents of S. 3065 try to avoid this dilemma by asserting that their bill, unlike the myriad other tax cuts promoted in the Congress, would in fact increase Treasury revenues. The reasoning behind this assertion has never been made clear. As is often the case with this subject, we are dealing here with conjecture, not facts. It is important, in assessing the revenue claims, to distinguish between three different time horizons: the very short term, the medium term, and the long term. -8- In the short term, the revenue impact of S. 3065 would turn on the so-called "unlocking" effect. With a cut in maximum capital gains rates, it is possible, at least in theory, that some taxpayers would sell assets that they had held for a very long time. Whether and how much this would occur, no one knows. If it did happen, two results would follow. First, the wave of selling might well depress asset prices, on the stock market and elsewhere. This would tend to reduce capital gains tax revenues. Second, the wave of selling would itself generate tax revenues. The net effect on revenues of these conflicting forces, no one can predict. But one thing is clear: It would be a temporary, one-shot effect. The wave of selling would not repeat itself year after year. In the medium term, any tax reduction will stimulate rggregate demand — investment and consumption — and therefore tend to increase GNP toward its potential level, creating a "feedback" of tax revenues to the Treasury. There is absolutely no reason to think that S. 3065 would create larger feedback effects than any other cut in capital income taxes. Indeed, such feedback effects are much less certain with capital gain taxes that with the corporate income tax cuts proposed by the President. Cutting corporate rates and liberalizing the investment tax credit would directly increase enterprise profits and cash flow, and thus real investment and tax revenues. The advocates of S. 3065 hold out the hope — no more — that a capital gains tax cut would substantially boost stock values and that this in turn would trigger a large amount of new investment, with a consequent rise in tax revenues. But, as I have indicated, there is no perceptible relationship between capital gains taxes and the level of the stock market, and a capital gains tax cut of this size is most unlikely to affect the stock market substantially. Unfortunately, it is equally difficult to trace a causal relationship between the level of the stock market and the rate of increase of investment or GNP. Both points in the argument are thus very shaky. For the medium term, the revenue feedback effect of a capital gains tax reduction is anyone's guess. In the long term — the most important perspective — tax revenues depend on the sustainable growth rate of the economy. In other words, the revenue feedback will be greater the more efficiently the tax cut boosts the long term trend of investment in productive assets and enterprises. It is precisely here that S. 3065 is most seriously defective. It scatters its benefits over a wide array of assets, many of little productivity, and it -9misses entirely 90 percent of the tax burden on capital income. It is a very poor tool for increasing the economy's long term rate of real growth, and its long term revenue feedback effects would be commensurately modest. Finally, I wish to say a word about the very loose international comparisons that have been made in the debate on this measure. Some proponents of S. 3065 have suggested that our economic performance — in areas of inflation, unemployment, and growth — has fallen short of that of Germany and Japan because we tax capital gains while they, assertedly, do not. This line of argument ignores certain important facts. First, the United States has over the past few years outperformed most other industrialized countries, including Germany and Japan, in terms of real growth and increases in employment. Our inflation record is less satisfactory, but is nonetheless superior to several countries (e.g. Italy) having no capital gains tax. Second, Japan does in fact tax captial gains. As for Germany, it instead uses an even more comprehensive tax on annual increases in wealth, whether or not realized; I doubt that the proponents of S. 3065 would prefer the German system to ours. What all this shows is that making simplistic international comparisions on a tax-by-tax basis is a very treacherous business. In sum, Mr. Chairman, the claims made for S. 3066 do not stand up to scrutiny: The bill would not provide general or middle income tax relief but would instead narrowly focus its benefits on the highest income classes and would provide an unprecedented boon to millionaires. The bill has no realistic potential for creating a substantial rise in stock prices. . The bill would not efficiently meet our urgent needs for more investment in productive enterprises. The bill would not gain us revenue but would instead use up revenue needed for far more efficient and equitable incentives for capital formation. There are of course many variations of S. 3065 qnder discussion in the other Chamber. I will not deal with them in detail. Some of the proposals escape certain problems I have noted here. However, those involving an effective repeal of the minimum tax so far as capital gains are concerned have the same -10defects as S. 3065: they are very expensive, and they focus their benefits on a narrow class of extremely high income individuals, with the result that many of those persons would pay very little tax. As the President has indicated, this is an unfair and ineffective response to the need of American workers and businesses for genuine tax reduction. Comments on S. 2428 I turn now to S. Preservation Act small businesses available on the 2428, the "Small Business and Farms Capital of 1978." This bill would extend to certain a tax-free rollover privilege similar to that sale of a principal residence. We believe such a rollover provision would be inequitable. Owners of businesses already enjoy enormous tax benefits. As a business grows and prospers, and its market value increases, the owners do not have to pay current tax on this appreciated value. A person receiving income in the form of wages, interest on a savings account, or stock dividends must first pay taxes before setting aside funds for future use. The business owner increases his wealth with before-tax dollars, while the wage earner increases his wealth with after-tax dollars. In addition, the owner of a business, when he sells, has the advantage of preferred capital gains rates. Further, any bunching of income resulting from the tax deferral can be alleviated by income averaging, made available for capital gains by the Tax Reform Act of 1969, and by the use of installment sales. S. 2428 would provide yet another valuable tax break to those who already benefit from a number of preferential provisions. This raises serious questions of fairness. Apart from considerations of equity, this proposal would raise considerable problems of compliance and administration. Some problems occur now with the tax-free rollover privilege afforded taxpayers on their personal residences. Individuals are asked for more information and computations than are generally required, and such data must be retained for very long periods of time. The complexity would be aggravated substantially by the rollover contained in S. 2428. Recordkeeping and computation burdens could be monumental where a taxpayer has several qualifying asset sales and purchases with overlapping one-year reinvestment periods. -11The Congress has allowed the extraordinary rollover privilege for principal residences because of the peculiar social value of home ownership. We think it would be a major error in tax policy to begin extending this privilege, piece by piece. Very soon, other types and classes of taxpayers would be demanding this preference, and a wholesale erosion of the tax base would result. Comments on S. 2608 This bill seeks correction for the appreciation of nominal asset values caused by inflation. It attempts this by excluding from taxable income a percentage of realized capital gains — a percentage that would increase with the length of time the asset had been held. The rationale is simple and understandable. It seems unfair to many that taxes should be paid on gains that are "paper gains" only, the product of inflation. Unfortunately, there is no easy way to solve this problem. While S. 2608 is concerned with "illusory income" in the case of capital gains, the same issue arises with all types of income from capital and with debt. A balanced program of indexing income for inflation would require at least four adjustments. Taxpayers would increase the basis of capital assets by the rate of inflation. Owners of savings accounts and other interest-bearing obligations would deduct the loss resulting from the inflation-induced decline in their assets' real value. Businesses would be allowed to increase their basis in computing depreciation deductions and inventory profits. Debtors would report income whenever inflation reduced the real value of their indebtedness. Obviously, an indexation system that included these four elements would be extremely complicated; but going only part way would create new inequities among taxpayers. For example, it is difficult to justify an inflation adjustment for owners of stock and real estate while ignoring the effect of inflation on the savings account depositor. Nor would a system be just that allowed the holder of debt-financed property to adjust the asset's basis for inflation while making no allowance for the f act that the debt was being repaid with cheaper dollars. -12There is, however, a more fundamental problem with the notion of indexation. It deals with the symptoms and not the disease itself. Indexation is a response to high inflation rates, but the proliferation of indexation schemes tends to make those rates an accepted fact of economic life. These schemes to ?nl?»M« tltUtl °l! al Jf e -he d e f e c t - ^ther than accommodating to inflation, we should, in my judgment, bend all efforts to eliminate it. f apital 9ains i^exing were desirable, S. 2608 would no. n^^i ^ not provide the proper means of implementing such a system ?hZ most appropriate inflation adjustment would be to inhale'the basis of capital assets by the rate of inflation rather than L exclude a fraction of the gain from income during a plrioS Cf proPorJJS; n f h n S b i i i i n S t e a d e x ^ ^ e s from tax a larger proportion of gain the longer the asset has been hPlrt \-ha mechanism should work in t L opposite Ly. Shi abSlite amount however tSraL2ai; d°SS ri5e aS the holding P«iod lengthens nowever, the absolute size of the real gain also rises A* A 0 be S h W n # r'ealto ^?* " " " ° «the«at!c«lly t£at SJ raJio of 9a aSSet W U 1 increas is Lid ^uS lL°l^t * the longer an asset SyStem f radu perverse. ° 9 ati°n would be Conclusion have exoffin^LT08!,"1686 three bills on the ^rits, as I nave explained at length. But we also object to them for » incol'taxluon in"686 ^^f aPPr°aCh «>« pSbiS-'oTcS ta*l federal taxes Sn 2«J<Ei " * a"d ad h ° C m a n n e r ' T h e v " i o ^ the corporate^ income tax ' S ^ " t h e C a p i * a l g a i n s Pulsions, income - 1 L 1 ™ i*l' ? t h f P e r s o n a l income tax on property Treas ry ^ " e n g a g e ^ T ? ^ ^ m r blemS Ur eC n my faces and will cSnt°Le to fLe ^ver thi°" S ° ° °° ' study my closes? personal attention V n f o ^ * ?" 2 ^ i n ? t M S ITt^t™^ &?V"^ ^ns^nV^xerlise. income taxation -- a J h l t i J i r K f o J ^ * t r U C t U ? e °f C a p i t a l nowhere. The whole L r u ^ n J i •?? u y ° U d ° "" w i l 1 9 e t U S inequitable? inefficient »«H Y i n K b e c o m e t h a t m u c h m o r e complex, will lose revenues « " H e r f l " I n th e process, we investment incentives TI ZJ t *?* m ? r e e f f i c i e " t tax, what is rlquirJI'is a S m , a E ^ P ? r l V l t h t h e C a p i t a l g a i n S to capital income a o gene?allj *"*c o m P r e h e n s i v e «PP"«ch -13- For that task, the Congress needs more than the few months remaining in this very busy legislative session. The proper agenda for this year is to take relatively simple and efficient steps to cut capital income taxes across the board, as the President has proposed. There is no question that this would best serve the needs of the economy and the long term interests of the American people. Thank you for this opportunity to present the Administration's views. Table 1 Income T a x on Capital Gains - 1976 Levels Adjusted gross income class ($000) Less than 5 Total capital gains (...$ millions...)'v (. $ Effective tax Tax •**" rate on r' " liability capital gains $ millions. .V.y^'O .;. percent...) 2,697 *1;3% $ 34 5 - 10 2,872 3.8 10 - 15 3,571 ^7 7$ 269 15 - 20 3,418 326 '9, 5 20 - 30 5,281 672 12'iJ 30 - 50 6,105 1,019 16,J 50 - 100 5,537 1,234* 22..3 100 - 200 3,613 898 24 .9 5,939 1,625 27 .4 $39,034 $$6,187 200 anc1 over Tot£ Office of the Secretary of t h e Treasury Office of T a x Analysis 110 15 .9% June 2 7 , 1978 Table 2 Distribution of Individual Tax Reductions Under S. 3065 (19 78 Income Levels) Average Percentage Distribution Expanded Income Class Tax Benefit of Tax Benefit Less than $15,000 12* 0.4 $15,000-20,000 25* 0.2 $20,000-30,000 $1 0.8 $30,000-50,000 11 4.0 $50,000-100,000 158 13.7 $100,000-200,000 783 14.2 $200,000-500,000 4,,000 15.7 $500,000-1,000,000 21,,540 11.3 $1,000,000 & over 145,r302 39.7 Total $ 19 100.0% Table 3 Tax Liability on Capital Gain Income Compared to Tax Liability on All Capital Income (1978 Levels) ($ billions) Tax liability on all capital income: Corporate tax liability Individual tax liability Total 63.8 36.8 100.6 Tax liability on capital gain income: Corporate Individual Total 2.5 7.8 10.3 Capital gain tax as a percent of total taxes on capital income 10.2% Office of the Secretary of the Treasury Office of Tax Analysis June 20, 1978 Note: Total capital income consists of corporate profits, dividends, interest, rents, royalties, the portion of partnership and sole proprietorship incane attributable to capita!, and capital gains. Table 4 Shares of Capital Gains and Losses by Asset Type - 1973 Asset Type Financial Assets (Stocks and bonds) Gains 0nl Y 28.8 % Losses Only 55.5 % : Gains and :Losses Combined 17.1 % Partnership, Fiduciaries, and Small Business Corporations Prior Year Installment Sales 8.5 7.2 9.7 * Liquidation Distributions 2.6 0.4 3.6 Residences 10.8 0.0 15.5 Nonbusiness Real Estate 8.1 1.3 11.1 Timber 0.5 9.0 14.0 * 0.7 Retirement Plan Distribution 1.8 Commodities, including future 2.5 8.2 * Involuntary Conversions 1.1 0.5 1.4 Trade or Business Assets 3.7 1.1 . 4.9 Business and Rental Building 3.8 0.0 5.5 Livestock 3.4 0.2 4.8 Farm Land and Property 0.7 0.3 0.8 14.0 25.1 9.1 Other Assets TOTAL Memorandum Corporate Stock Only 100 % 26.1 2.6 100 % 51.9 100.0 % 14.8 Office of the Secretary of the Treasury June 15, 1978 Office of Tax Analysis * Less than 0.05 percent Note: Details may not add to total due to rounding. Standard & Poor's 094 500 Stock Index and Capital Gains Tax Changes 1 1955-1978 1 60 62 64 66 68 70 72 74 76 78 r UmntofthelRtASURY LlN6T0Nt D.C. 20220 T E L E P H O N E 566-2041 June 28, 1978 FOR IMMEDIATE RELEASE RESULTS OF AUCTION OF 15-YEAR 1-MONTH TREASURY BONDS The Department of the Treasury has accepted $1,757 million of $4,131 million of tenders received from the public for the 15-year 1-month bonds auctioned today. The range of accepted competitive bids was as follows: Lowest yield Highest yield Average yield 8.62% 1/ 8.63% 8.63% The interest rate on the bonds will be 8-5/8% the above yields result in the following prices. Low-yield price 100.008 High-yield price Average-yield price At the 8-5/8% rate, 99.924 99.924 The $1,757 million of accepted tenders includes $377 million of noncompetitive tenders and $1,380 million of competitive tenders (including 96% of the amount of bonds bid for at the high yield) . 1/ Excepting 5 tenders totaling $67,000 B-1009 itfotmtntoftheJREASURY WASHINGTON. D.C. 20220 TELEPHONE MM041 ••••••••Hi FOR IMMEDIATE RELEASE June 29, 1978 Contact: George G. Ross 202/566-2356 TREASURY RELEASES FIRST REPORT ON U. S. CORPORATIONS IN PUERTO RICO The Treasury Department today released its First Annual Report on the Operation and Effect of the Possessions Corporations System of Taxation. A "possessions corporation" is a U. S.-chartered company operating in Puerto Rico, American Samoa, Guam, the Panama Canal Zone or certain other U. S. possessions. The body of the Report deals almost exclusively with Puerto Ricof which accounts for 98 percent of the combined book income of all possessions corporations. Possessions corporations since 1948 have been exempt from Puerto Rican income, property and certain other taxes. Recent revisions in the Puerto Rican tollgate tax on dividends paid to U. S. parent corporations, and in the Industrial Incentive Act, will substitute low rates of effective taxation for total tax exemption. Until 1976, possessions corporations were also exempt from Federal income taxes under Section 931 of the Internal Revenue Code. The Tax Reform Act of 1976 put the possessions corporations under a new Section 936, which continued the exemption from Federal taxes for income earned in Puerto Rice and the other possessions, but encouraged the repatriation to the United States of dividends which could not be profitably reinvested in the possession. Because the operation and effect of the possessions corporation tax system was not completely understood in 1976, the Congress asked the Treasury Department to begin reporting annually, not only on the systenfe effect on tax revenues, but also on its impact on investment and employment in Puerto Rico and the possessions. The first report covering calendar year 1976 was to be submitted to the Congress by June 30, 1978. The primary findings of the Report are; - The Federal tax expenditure in calendar year 1977 is estimated to be $698 million. This expenditure has grown from $255 million in 1973. In recent years, half of the tax savings have been realized by pharmaceutical companies. B-1010 (MORE) - 2 - - In the manufacturing industries, the Federal tax expenditure averaged $7,428 per Puerto Rican employee in 1975, which was slightly larger than the average total compensation of those employees. For pharmaceutical companies, the Federal tax saving represented $34,873 per Puerto Rican employee; for all manufacturers except pharmaceuticals, the Federal tax saving per employee averaged about $4,100. - The measured benefit Puerto Rico receives increases if account is also taken of possessions corporations1 local purchases of goods and services, and the subsequent "multiplier" effect on Puerto Rican gross national product. The benefit for Puerto Rico per dollar of Federal tax expenditure continues, however, to vary from one industry to another. - The impact of changing from Section 931 to 936 in 1976 is difficult to separate from contemporary and subsequent changes in Puerto Rican tax laws and other economic factors. Throughout 1977, new investment in Puerto Rico and repatriation of dividends to the United States was slow, but the pace of both has picked up in 1978. Portfolios of financial investments have also been restructured; investments in Eurodollar assets have been replaced by investments in Puerto Rican and U. S. assets. The increase in Puerto Rican investments has not, however, had an apparent impact on long-term interest rates or on credit conditions in Puerto Rico. An appendix to the Report summarizes the possessions corporation system of taxation as it relates to American Samoa, Guam and the Panama Canal Zone. In addition, an essentially similar system of taxation covered by Section 934 of the Code affecting U. S. corporations operating in the Virgin Islands is described. Copies of the Report are available for purchase from the Superintendent of Documents, U. S. Government Printing Office, Washington, D. C , 20401. When ordering, use Stock o 0 o Number 048-000-00315-0. The Operation and Effect of the Possessions Corporation System of Taxation First Annual Report Department of the Treasury June 1978 The Operation and Effect of the Possessions Corporation System of Taxation First Annual Report Department of the Treasury June 1978 For sale by the Superintendent of Documents. U. S. Government Printing Office Washington, D. C. 20402 Stock No. 048-000-00315-0 THE SECRETARY OF THE TREASURY WASHINGTON JUN 2 9 1978 Dear Chairman Ullman: The Report of the Committee on Ways and Means on H.R. 10612 (Public Law 94-455), The Tax Reform Act of 1976, provides that "the Treasury is to submit an annual report to the committee setting forth an analysis of the operation and effect of the possessions corporation system of taxation," and that the reports are to be submitted within 18 months following the close of the calendar year, with the first report covering calendar year 19 76. Pursuant to that provision, I hereby submit the first annual report entitled, "The Operation and Effect of the Possessions Corporation System of Taxation." I am sending a similar letter to Senator Russell B. Long Chairman of the Committee on Finance. Sincerely, W. Michael Blumenthal The Honorable Al Ullman, Chairman Committee on Ways and Means House of Representatives Washington, D.C. 20515 Enclosure THE SECRETARY OF THE TREASURY WASHINGTON JUN 2 9 1978 Dear Chairman Long: The Report of the Committee on Finance on H.R. 10612 (Public Law 94-455), The Tax Reform Act of 1976, provides that "the Treasury is to submit an annual report to the committee setting forth an analysis of the operation and effect of the possessions corporation system of taxation," and that the reports are to be submitted within 18 months following the close of the calendar year, with the first report covering calendar year 1976. Pursuant to that provision, I hereby submit the first annual report entitled, "The Operation and Effect of the Possessions Corporation System of Taxation." I am sending a similar letter to Representative Al Ullman, Chairman of the Committee on Ways and Means. Sincerely, W. Michael Blumenthal The Honorable Russell B. Long, Chairman Committee on Finance United States Senate Washington, D.C. 20510 Enclosure Table of Contents Page Chapter I. Chapter II Introduction and Summary Puerto Rican and Federal Income Tax Law — Past and Present A. Industrial Tax Exemption in Puerto Rico B. Section 931 of the U.S. Internal Revenue Code C. Section 936 of the U.S. Internal Revenue Code D. The Puerto Rican Tollgate Tax Act and the New ofIndustrial E. Allocation Income andIncentive Deductions 1 8 8 9 11 13 18 Chapter III. Economic Impact 24 A. Puerto Rican Economic Development B. Characteristics of Possessions Corporations C. Linkages and the Multiplier 1. Backward Linkages 2. The Multiplier 3. Direct, Indirect and Total Effects 4. Forward Linkages D. Impact of Changing from Section 931 to Section 936 and of Restructuring the Tollgate Tax 1. New Investment in Puerto Rico 2. Repatriation of Dividends 3. Financial Portfolios E. Possible Impact of the New Industrial Incentive Act Appendix A — Operation of the Possessions Corporations System of Taxation in American Samoa, Guam, the Panama Canal Zone and the Virgin Islands Appendix B — Sources and Limitations of the Data and Statistical Data for 1973 and 1974 Appendix C — Tax Forms from which Data Included in this* Report was Obtained 24 35 43 44 51 52 55 55 57 63 64 68 70 81 91 List of Figures and Tables Page Figure I: Total and Per Capita Gross National Product of Puerto Rico, 1948-1977 (Constant 1974 Dollars) 25 Figure II Total Government Expenditures plus Net Investment of Public Enterprises, Own Source Revenue Plus Federal Taxes Covered Over, Federal Grants-in-Aid, and Total Borrowing of Puerto Rico, 1960-1977 Figure III: Current Status of 149 Exemption Decrees Granted Between 1960 and 1962 and Utilized by Recipient Firms Table 1: Table 2: Table 3 Table 4: Table 5 Table 6 Table 7: 29 34 Federal Tax Expenditure Estimates and Projections, Possessions Corporation Provisions Federal Transfer Payments, Grants, "Covered Over" Taxes, and Tax Expenditure on Possessions Corporations in Puerto Rico, Fiscal Years 1968 and 1977 Total Manufacturing Employment in Puerto Rico, by Major Industry Group: Average for Calendar Years 19 73 to 1977 and April 1978 Major U.S. Manufacturing Corporations Claiming a Reduction in Income Taxes in Excess of 2.4 Percent of Book Income Because of Section 931 or 936 of the Internal Revenue Code Income and Estimated Tax Expenditure by Industry, 1975 28 33 36 38 Tax Expenditure, Employment and Compensation of Employees by Industry, 1975 * 41 Tax Expenditure, Employment and Compensation of Employees by Size of Tax Expenditure Per Employee, 19 75 42 Paae Table 8: Table 9: Table 10: Table 11: Table 12: Table 13: Table 14: Expenditures on Materials, Labor, Plant, and Equipment as a Percent of the Value of Production by Manufacturing Establishments in Puerto Rico, 1972 Tax Expenditures as a Percent of Compensation of Employees, of Direct Expenditure in Puerto Rico, and of Direct and Indirect Expenditure in Puerto Rico, for Manufacturing Industries Destination of Shipments by Puerto Rican Manufacturing Industries, 1972 56 Income and Estimated Tax Expenditure by Industry, 1976 58 Tax Expenditure, Employment and Compensation of Employees by Industry, 1976 60 Tax Expenditure, Employment and Compensation of Employees by Size of Tax Expenditure Per Employee, 19 76 61 Elections under Section 936 by Industry 62 Table 15: Estimated Composition of Financial Investments by 936 Corporations in Mid-1977 Table 16: 45 Sales of Bonds by the Government Development Bank for Puerto Rico, October 1976 - May 1978 54 65 66 Table A-l: Income and Estimated Tax Expenditure by Possession, 1975 73 Table A-2: Average Payroll and Employment for Tax Exempt Industries in the Virgin Islands, FY 1975 79 Table A-3: Virgin Islands' Tax Incentive Program Subsidy Claims, Fiscal Years 1975 and 1976 80 Paae Table B-l: Income and Estimated Tax Expenditure by Industry, 1974 85 Table B-2: Income and Estimated Tax Expenditure by Industry, 1973 86 Table B-3: Tax Expenditure, Employment and Compensation of Employees by Industry, 1974 87 Tax Expenditure, Employment and Compensation of Employees by Industry, 1973 88 Table B-4: Table B-5: Table B-6: Tax Expenditure, Employment and Compensation of Employees by Size of Tax Expenditure Per Employee, 1974 Tax Expenditure, Employment and Compensation of Employees by Size of Tax Expenditure Per Employee, 19 73 89 90 CHAPTER I. INTRODUCTION AND SUMMARY In 1975 and 1976, Congress considered a series of proposals to change Federal taxation of income from exporting and foreign investment. Having at first contemplated repeal of section 931, which exempted from Federal taxation the income of companies incorporated in the United States* but operating primarily in Puerto Rico, American Samoa, Guam, and the Panama Canal Zone, Congress instead passed a new section 936. The new section was intended to maintain tax incentives to invest in Puerto Rico and the possessions, but to encourage U.S. companies to bring money home to the United States if it could not be profitably reinvested in the local economy. Replacing section 931 with 936 was expected to reduce the Federal tax expenditure attributable to the possessions corporation system of taxation by $10 million in calendar year 1977, roughly 4 percent of the then estimated total tax expenditure of 5285 million.** The operation and effect of the possessions corporation system of taxation were not completely understood. Thus, the staff of the Joint Committee on Taxation, adopting similar language to that used in the Reports of the House Committee on Ways and Means and the Senate Committee on Finance, stated in its General Explanation of the Tax Reform Act of 1976: *Although Puerto Rico and the possessions are included in some definitions of the United States, for convenience of exposition the term "United States" in this Report will mean only the fifty states and the District of Columbia. The Panama Canal Zone was never a U.S. possession, but has been treated as such under the U.S. Internal Revenue Code. **See Special Analysis F, "Tax Expenditure," in Special Analyses of the Budget of the United States Government for Fiscal Year 1977 (January, 1976), and "Estimates of Federal Tax Expenditures," Prepared for the Committee on Ways and Means and Committee on Finance by the staff of the Joint Committee on [Internal Revenue] Taxation, (March 15, 1976). 2 «8-508O-78-2 -2"It is the understanding of Congress that the Department of the Treasury is to review the operations of section 936 corporations in order to apprise Congress of the effects of the changes made by the Act. The Treasury is to submit an annual report to the Congress setting forth an analysis of the operation and effect of the possessions corporation system of taxation. Among other things, the report is to include an analysis of the revenue effects to the provision as well as the effects on investment and employment in the possessions. These reports, which are to begin with a report for calendar year 1976, are to be submitted to the Congress within 18 months following the close of each calendar year."* The body of this First Annual Report deals almost exclusively with Puerto Rico. Various Committee reports and other Congressional documents relating to the possessions corporation system of taxation reflect Congress1 primary concern with the impact on Puerto Rico, and as indicated in Table 1, Puerto Rico accounts for over 98 percent of the tax expenditure associated with section 931 or 936 of the Internal Revenue Code. Appendix A of this Report describes the system of taxation as it affects American Samoa, Guam, and the Panama Canal Zone. The tax exemption for U.S. corporations operating principally in the Virgin Islands is delimited by section 934, which was unaffected by the Tax Reform Act of 1976. Because the Virgin Islands is also a possession, and because section 934 has many features similar to those of section 931 or 936, the taxation of U.S. companies operating in the Virgin Islands is also described in Appendix A. In Puerto Rico, the possessions corporation system builds upon and reflects the complex interaction of the tax laws of the United States and those of the Commonwealth. This Report first reviews those tax laws and then undertakes an economic analysis of their impact. The review begins with Puerto Rico's Industrial Incentive Acts, which have provided *Pages 277-8. from exemptions income, property, and other taxes -3Table 1 Federal Tax Expenditure Estimates and Projections, Possessions Corporation Provisions 1/ (millions of dollars) Year 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 Reduction in Calendar Year Tax Liabilities : Conpanies Operating in: : :A11 Other U.S. Total :Puerto Rioo : Possessions 255 368 440 634 698 673 741 814 896 985 1,084 250 362 437 630 693 668 735 808 889 978 1,076 5 6 3 4 5 5 6 6 7 7 8 Fiscal Year Receipts Foregone 2/ Conpanies Operating in: :A11 Other U.S. Puerto Rico Possessions 239 3/ 289 390 498 663 687 703 774 850 936 1,029 234 3/ 284 385 495 659 682 698 768 844 929 1,022 5 3/ 5 5 3 4 5 5 6 6 7 7 Office of the Secretary of the Treasury Office of Tax Analysis 1/ The 1973 through 1975 figures are estimates based on income data taken primarily from election forms (Form 5712). The 1976 figures are estimates based on the 1975 to 1976 growth rate of income by broacl industry groups for those companies for which data for both years was availablfe. The 1977 figures are estimates based on the 1976 to 1977 increase in manufacturing employment in Puerto Rioo. Figures for 1978 and all subsequent years are projections based on an assumed 10 percent growth rate. All figures are based on the assumption that in the absence of the possessions corporation provisions, the income of possessions corporations would be subject to an effective Federal corporate tax rate of 40 percent. For conpanies operating in Puerto Rico, the calendar year 1973 through 1977 figures are net of estimated tax payments to Puerto Rico; the figures for 1978 and subsequent years are net of an assumed 5 percent effective Puerto Rican (corporate plus tollgate) tax rate. Note that the section 936 credit, which applies in 1976 and subsequent years, is based on tax liabilities computed without regard to such tax preferences as the investment tax credit, or with regard to Puerto Rican taxes, which are taken into account in computing the tax expenditure figures. Therefore, the actual section 936 credit claimed will exceed the tax expenditure figure for the corresponding year. 2/ Calculated on the basis of normal relationships between calendar year corporate tax liabilities and fiscal year receipts. Fiscal years through 1976 end on June 30 of the corresponding calendar year; thereafter on September 30. The transition quarter in 1976 is not shown separately. The receipts estimate for that quarter is $95 million. V Reflects in part reduced calendar year 1972 tax liabilities, which are estimated to have been 10 percent lower than the estimates shown for 1973. -4for corporations manufacturing in Puerto Rico, passes to section 931 of the United States Internal Revenue Code, and then describes section 936. The Report next describes Puerto Rico's tollgate tax on dividends paid to U.S. parent corporations, a tax which was changed in 1976 in anticipation of the enactment of section 936. The discussion then moves to the reform of the Industrial Incentive Act and the further modifications of the tollgate tax passed and signed into Puerto Rican law in June 1978. Finally, section 482 of the U.S. Internal Revenue Code, which guides the allocation of income and deductions between related entities is reviewed. Although section 482 has broader application than the possessions context, it is critical to the possessions corporation system of taxation. These Federal and Commonwealth tax provisions must be assessed against the backdrop of Puerto Rico's economic development. The economic growth of the Commonwealth from the late 1940's to the early 1970's has been termed an "economic miracle." Even after adjusting for price inflation, Puerto Rican income per capita grew at an average rate of 5 percent per annum. In the 1970's, however, real income per capita began to decline as the economy remained in a long recession, and many Puerto Ricans returned from the United States. The rate of unemployment, which had declined steadily through the 1960's to just over 10 percent of the measured labor force, went up to more than 20 percent in 1976 and 1977. And, were it not for the substantial increase in net Federal transfer payments to Puerto Rican individuals and Federal grants to Puerto Rican governments, the Puerto Rican recession of 1973-77 might have been much deeper. In late 1977 and the first half of 1978, the Puerto Rican economy has begun to recover; by April 1978 the unemployment rate had been reduced to 16.5 percent, its lowest rate since May 1975. The reasons for Puerto Rico's extended recession are many. The U.S. economy, to which Puerto Rican industry is closely linked, underwent a milder recession in 1973-74, and has not grown rapidly since. The Puerto Rican petrochemical industry suffered from the sharp increase in the price of foreign oil in 1973-74 and the consequent suspension of Federal oil import quotas. The construction industry has been hard hit by higher construction and interest costs and -5the sharp decline in demand for new condominiums. The traditional Puerto Rican industries, such as textiles, apparel and shoes, have had to compete with the sharp increase in U.S. imports of these goods from low-wage foreign countries. The increasing competitiveness of foreign exports to the United States has accelerated a change in the industrial composition of U.S. companies operating in Puerto Rico. At least prior to the recent effective dates of the Orderly Marketing Agreements limiting shoe exports from South Korea and Taiwan, and the Multifiber Arrangements limiting textile and apparel exports from eighteen developing countries, companies manufacturing such products in Puerto Rico were reluctant to keep existing plants open, much less to construct new ones. Because Congress in 19 76 emphasized its desire to continue assisting Puerto Rico in obtaining employmentproducing investments, the Treasury has matched income tax return information with employment and payroll information for individual possessions corporations. For all manufacturing industries, the Federal tax expenditure per Puerto Rican employee averaged $7,428 in 1975, which was slightly larger than the average compensation (wages or salary plus other benefits), $7,300, of possessions corporations' employees. Tax expenditure per employee or as a percentage of total employee compensation varies substantially from industry to industry. For pharmaceutical companies the tax expenditure represents almost $35,000 per employee, or approximately three and a half times the total compensation of the comparatively well paid pharmaceutical employees. At the low end of the spectrum were many of the traditional labor-intensive industries where the Federal tax expenditure usually averaged less than $3,000 per employee. For all manufacturers other than pharmaceuticals, the tax expenditure averaged about $4,100, which was 50-60 percent of those employees' average compensation. In addition to the employment and payroll directly attributable to possessions corporations, Puerto Rico receives indirect benefits from this system of taxation. Manufacturing requires raw materials, intermediate goods, and services, a portion of which are supplied by the local economy. New investment in plant and equipment creates jobs -6in the construction and capital equipment industries. Workers in all industries spend their salaries on goods and services, which has a "multiplier" effect on the Puerto Rican economy. Including the estimated value of these "backward linkages" and multiplier effects significantly increases (and arguably overstates) the measure of the total benefit Puerto Rico receives from the possessions corporation system of taxation. Because all industries exhibit backward linkages and have a multiplier impact on the local economy, the ratio of this broader measure of Puerto Rican benefits to Federal tax expenditure varies from industry to industry, much as the narrower measures do. The impact of changing from section 931 to 936 is difficult to separate from the effects of changes in the Puerto Rican tollgate tax, which became effective on the same date, and from other contemporary events. The rate of new investment and of dividend payments was very slow throughout 1977. In early 1978, the Puerto Rican government approved a number of new applications for tax exemption, many of which may have been either delayed during 1977 or accelerated by the anticipated announcement of the new Industrial Incentive Act. Dividend payments have also accelerated in 1978; as of early June, more than $1.4 billion in dividends have been declared, giving rise to $48 million in Puerto Rican tollgate taxes. Several changes in 1977 in the tollgate tax rules (especially the exemption for dividends paid out of non-^Puerto Rican income) reduced the effective rate from the statutory 10 percent to less than 5 percent. Because section 936 benefits are not available for income earned outside the possession where the corporation has a trade or business, but do apply to "qualified possessions source investment income," possessions corporations have had to restructure their substantial portfolios of financial assets. Eurodollar deposits have been replaced by substantial investments in Puerto Rican banks, Puerto Rican mortgages guaranteed by the Federal Government National Mortgage Association (GNMA), loans to other 936 companies, tax-exempt bonds (including Puerto Rican) and the preferred shares of U.S. corporations. To date, the special provision for "qualified possessions source investment income" does not appear to have had a material impact on long-term interest rates or credit conditions for the average Puerto Rican borrower. -7The June 1978 changes in the Puerto Rican Industrial Incentive Act and the tollgate tax are complex and will not become fully effective until 1979. Preliminary analysis suggests, however, that the combined efffective rate of income and tollgate taxation may be approximately 5 percent. If so, and if the level and composition of investment by possessions corporations and other aspects of their behavior are not materially affected by this tax increase, the Federal tax expenditure will be reduced in 1978 and the near future by one eighth (because the Federal taxes foregone will represent 35 percent, rather than the currently estimated 40 percent, of pretax income). -8CHAPTER II. PUERTO RICAN AND FEDERAL INCOME TAX LAW — PAST AND PRESENT A. Industrial Tax Exemption in Puerto Rico The modern history of industrial tax exemption in Puerto Rico begins in 1948. Prior to that year, Puerto Rican development strategy stressed government ownership and operation of key industries, such as cement, glass, paperboard, and shoes. When the financial requirements of such a program were recognized, Puerto Rico shifted the emphasis to private enterprise. Tax exemption became the keystone of an industrial incentive program that also included providing plants at low rent, cash grants to cover start-up costs, and low interest loans. The Industrial Incentive Act of 1948 offered qualified firms an exemption from income, property, and municipal taxes, while the excise tax act exempted raw materials, machinery, and equipment used in manufacturing for export or sold to other manufacturers in Puerto Rico. Originally, it was contemplated that the period of total exemption would end in 1959, with the exemption rate falling to 75 percent, 50 percent, and 25 percent in 1959, 1960, and 1961, respectively. All exemptions were to end in 1962. Tax exemption was restricted to items not produced on a commercial scale in Puerto Rico prior to 1948 and to certain other specified items, such as wearing apparel and processed food products. The 1948 legislation also provided for exemption from Puerto Rican taxes for a distribution of dividends to a parent outside Puerto Rico if the parent was unable to claim a foreign tax credit for the withholding tax. Finally, liquidation of an exempt company would be tax free, provided that the liquidating company was at least 80 percent owned by its parent. Many firms established plants in Puerto Rico in the early 1950's in response to these incentives. Textiles were the fastest growing industry, but shoes and other leather goods, and assembly of mechanical, electrical and electronic devices were also important. After a few years, however, a tax exemption with a 1959-1961 phaseout became less attractive, and, in 1954 the Industrial Incentive Act was amended. -9The 1954 Act provided for a ten-year exemption for new applicants. Because an established firm could lose its exemption, but a new applicant could qualify for a ten-year exemption, the 1954 Act sought to limit the ability of an old firm to obtain a new grant. If a firm received a new grant of exemption for a product produced under an old grant, the new grant would be terminated if the level of output in the predecessor operation was reduced. In addition, plant, equipment, and other property that had been used in the production of an exempted product could not be used by another enterprise to produce a similar exempt product. Both prohibitions were subsequently weakened, and the Governor had the power to waive them if ne deemed it to be in the public interest. As the 1950's drew to a close and some of the original grantees approached the end of their exemption periods, pressure for further revisions in the Industrial Incentive Act began building. An expanded Industrial Incentive Act was adopted in 1963, offering exemptions for periods of 10, 12, 15, 17, or 25 years, depending on the degree of economic development of the zone in which the plant was located. In addition, a partial exemption for up to twice the length of the original grant could be elected. A company could postpone the start of the exemption period for two years and 90 days after its first payroll, which permitted it to save the exemption for profitable years, rather than wasting it during the period of start-up losses. In the early 1970's, Puerto Rico redefined the tax-exemption zones and lengthened some exemption periods (exemptions of 10, 15, 25, or 30 years became available). An amendment was introduced classifying passive income from certain financial investments in Puerto Rico as "industrial development income," benefitting from the same tax exemption as trade or business income. This provision sought to encourage the possessions corporations to invest a larger portion of their earnings in Puerto Rico. B * Section 931 of the U.S. Internal Revenue Code The essential elements of section 931 of the Internal Revenue Code of 1954 became part of U.S. law as section 262 of the Revenue Act of 1921. Proponents of this legislation had sought exemption for any U.S. corporation deriving at 26 8-508O.78-3 -10least 80 percent of its income from foreign sources. They stressed the competitive disadvantage of American firms in comparison to their British rivals. English law deferred taxation on foreign income until it was remitted to England, while the United States taxed the foreign income of U.S. corporations as it was earned.* The proponents settled ultimately for an exemption for firms deriving income from U.S. possessions. The reduction in the coverage of this legislation, from the whole world to the U.S. possessions, is not as astonishing as it might seem. The demand for exemption came primarily from a group of U.S. firms then operating in the Philippines (a U.S. possession in 1921). They argued that tax exemption would encourage export trade to the Far East from the U.S. base in the Philippines, while at the same time reducing the incentive for the U.S. firms operating there to reincorporate outside the United States. Little attention was paid to the effect of this law on the Philippine economy; Puerto Rico was virtually ignored in the public debate. Under the terms of section 931 (as subsequently amended) a U.S. corporation deriving at least 80 percent of its gross income from sources within a U.S. possession (currently Puerto Rico, American Samoa, Guam, the Panama Canal Zone, and certain other areas) and at least 50 percent of its gross income from the active conduct of a trade or business therein could exclude from its gross income for Federal tax purposes all foreign-source income except that received within the United States. The corporation had to meet the 80 percent and 50 percent tests for the current and preceding two taxable years (or less if it was just initiating operations). Corporations that satisfied these requirements came to be called "possessions corporations," "931 corporations," or sometimes simply "931's". Such corporations were usually organized as subsidiaries of U.S. parent companies in order to assure that 80 percent of gross *At the had time, companies preferred not to income itsU.S. source in one or generally more possessions. incorporate subsidiaries under foreign laws; foreign operations were initially conducted through either a branch of the U.S. parent or a U.S.-chartered subsidiary. -11A 931 corporation would often operate at a loss for the first year or two. (Even an older corporation that had been profitable could suffer a loss from time to time.) In 1971, the Tax Court ruled that a company was not "receiving the benefits" of section 931 in a year in which it lost money, so it could join its parent and other affiliated corporations in filing a consolidated return for such a year. The owner of a 931 thus avoided taxes in profitable years but was able to offset any loss against other, taxable income in unprofitable years. A 931 corporation usually avoided earning or receiving any taxable income within the U.S. and, thus, was wholly exempt from federal taxation on its earnings. In the majority of cases the 931's were engaged in manufacturing activity that qualified them for exemption from Puerto Rican taxes as well. Thus, for the period of the Puerto Rican exemption (10 to 30 years) the 931 had a tax holiday. In the United States, however, the parent corporation could not claim a dividends-received deduction for dividends from a 931, so the dividend would be taxable upon receipt by the parent. To avoid payment of this tax, the typical 931 accumulated its earnings, investing them (tax free) in the Eurodollar market. (Because the income was not taxable as earned, the company was not subject to the Federal accumulated earnings tax.) After a number of years (usually at the end of its period of Puerto Rican tax exemption) the 931 would be liquidated into its parent. If it was at least 80 percent owned by a U.S. corporation (as was generally the case), the liquidation was free of any federal income tax. So, although the parent had to wait for the liquidation to receive the accumulated earnings, those earnings would be free of either Puerto Rican or Federal income taxes. C Section 936 of the U.S. Internal Revenue Code The Tax Reform Act of 1976 removed possessions corporations from section 931 and placed them in a newly created section 936. The primary differences between sections 931 and 936 are: -121. The method of effecting the exemption changed: instead of excluding income, section 936 provides i credit to offset any U.S. tax on income from the active conduct of a trade or business in a possession, or or "qualified possessions source investment income" (interest, dividends, and other types of passive income earned on funds invested for use in a possession ir which a trade or business is actively conducted). Because the section 936 credit offsets the U.S. tax liability on this income, a 936 corporation cannot alsc claim a foreign tax credit for taxes actually paid with respect to such income. A foreign tax credit offsets U.S. taxes only on income ineligible for the section 936 credit. 2. The dividends-received deduction can be claimed, so the parent pays no tax on dividends received from a wholly owned 936 subsidiary. This is true not only for dividends paid out of current earnings, but also for dividends from earnings presumably accumulated while the subsidiary qualified under section 931. Because the parent is entitled to the dividends-received deduction, it cannot claim a foreign tax credit for a withholding tax on the dividend. 3. The subsidiary must elect the benefits of: section 936, and that election is irrevocable for 10; years. During this period it cannot join with its;; parent in filing a consolidated return, although it can delay electing 936 status until profitable years begin. Although most observers in 1976 appeared to believe* that section 936 would make investing in Puerto Rico more, attractive than it had been under section 931, the change had negative, as well as positive, components. On the one hand, section 936 does not allow possessions corporations to avoid Federal taxes on Eurodollar and other foreign income, as section 931 had. On the other hand, a primary obstacle -13to paying dividends (and, thus, an inducement to accumulate earnings) was removed by allowing the parent a dividends received deduction.* In explaining its motives, Congress cited its desire to leave undisturbed the tax exemption of earnings from a trade or business in Puerto Rico or from investments made with those earnings for use in Puerto Rico. At the same time, Congress desired to end the exemption for passive income from funds invested in foreign capital markets and to hasten their repatriation. Congress stated that it wanted to "assist the U.S. possessions in obtaining employmentproducing investments by U.S. corporations, while at the same time encouraging those corporations to bring back to the United States the earnings from these investments to the extent they cannot be reinvested productively in the possession."** D. The Puerto Rican Tollgate Tax and the New Industrial Incentive Act Prior to October 1, 19 76, the Puerto Rican government imposed a 15 percent tollgate tax on dividends paid out of Puerto Rican income from hotels, manufacturing and shipping to any corporation without significant business of its own in Puerto Rico, but only if that nonresident parent corporation could claim a foreign tax credit for the tollgate tax. In the United States a foreign tax credit was available until 1976, but because dividends were rarely paid, the tollgate tax was rarely applicable, and the foreign tax credit little used. Anticipating the passage of section 936 and the other Federal provisions relating to *The dividends-received deduction eliminates the need to liquidate a possessions corporation to repatriate earnings free of Federal taxes; in the past liquidation was often accompanied by an actual cessation of operations and discharge of workers. The provisions of Puerto Rican law which lead to this regretable practice were ameliorated, but not wholly eliminated, in the recent (June 1978) reforms of the Industrial Incentive Act. **Report of the Committee on Ways and Means, U.S. House of Representatives, on H.R. 10612, Report No. 94-658, November 12, 19 75, pg. 255; and Report of the Committee on Finance, United States Senate, on H.R. 10612, Report No. 94-938, June 10, 1976, pg. 279. -14possessions corporations, the Puerto Ricans in 1976 modified their tollgate tax in two important ways. The rate was reduced from 15 to 10 percent, and the tax became applicable to U.S. shareholders, even though they were denied a foreign tax credit. The two changes taken together had the effect of subjecting dividends paid to nonresident U.S. parent corporations to a 10 percent Puerto Rican tax.* Although the tax rate seemed low, the potential source of dividends included not only new income earned under section 936, but also earnings accumulated under section 931. Although the 10 percent tollgate rate instituted in 1976 remains, the effective rate has been subsequently reduced by a series of amendments and rulings. In summary: 1. Dividends paid out of accumulated "931" industrial development income (i.e., income earned prior to October 1, 1976) are subject to a tollgate tax of 7 percent, rather than 10 percent, if no more than 25 percent of the balance at the beginning of the year is paid out and a matching 25 percent is invested in designated Puerto Rican assets in that year. Designated Puerto Rican assets include working capital, deposits in Puerto Rican banks, Puerto Rican government bonds, mortgages insured by the Puerto Rican Housing Bank and Finance Agency, and loans or other *The 10 percent tollgate tax does not apply to a resident parent corporation (e.g., a U.S. manufacturer which wholesales and retails its products in Puerto Rico). Dividend payments to such a corporation would, however, initially be subject to the regular Puerto Rican income tax, which has a maximum statutory rate of 45 percent. The 85 percent dividends-received deduction in Puerto Rico would, however, reduce the effective rate on dividends from a possessions corporation to such a resident parent corporation to no more than 6.75 percent (45 percent of 15 percent). Thus, a U.S. parent corporation resident in Puerto Rico is taxable in Puerto Rico on its dividend income from a possessions corporation, but the effective rate of taxation is less than the 10 percent tollgate tax applicable to dividends paid to nonresident U.S. parent corporations. -15guaranteed mortgage bonds executed by any government pension or retirement plan. Thus, part of the accumulated earnings may be brought home subject to a reduced tollgate tax rate if a matching amount from such earnings is invested in designated assets. 2. Dividends paid out of accumulated "936" industrial development income (i.e., earned subsequent to October 1, 1976) are subject to a tollgate tax of 7 percent, rather than 10 percent, if no more than 75 percent of such income is paid out and if at least 25 percent of such income is reinvested in the designated Puerto Rican assets for a period of at least 8 years. 3. Dividends paid out of income from interest on the designated Puerto Rican assets are exempt from the tollgate tax. 4. A credit equal to 3 percent of new investment (made subsequent to the later of March 31, 1977 or the second year of tax exemption) in buildings and other structures used in manufacturing is allowed against the tollgate tax. In December 1977, the Puerto Rican Treasury issued regulations clarifying the exemption paid out of non-Puerto Rican income earned outside Puerto Rico (e.g., Eurodollar investments). As long as a company has both undistributed earnings from Puerto Rico and earnings from foreign sources, a dividend is deemed to consist of 50 percent exempt foreign-source income. That is to say, the tollgate tax in these instances equals 5 percent of the total dividend. In March 1978, Governor Romero Barcelo made his long awaited proposals for restructuring the Industrial Incentive Act; after debate and minor revisions, the Puerto Rican legislature enacted the Governor's program on June 2, 1978. The primary features of the new legislation are: 1. New grants will exempt from taxation only a declining fraction of income; that fraction is 90 percent in the first five years, 75 percent in the sixth through tenth years, 65 percent in the eleventh to fifteenth years, and 55 percent the sixteenth to the -16twentieth years. The first $100,000 of real property will be exempt from property tax, and the remainder will be exempt in the same proportion as income is. When the original grant expires, the company may apply for a ten year extension. If the extension is granted, 50 percent of income may be excluded for the first five years; for the second five years, between 35 percent and 50 percent may be excluded, the exact percentage depending on the location of the investment in Puerto Rico. 2. Companies earning less than $500,000 may also exclude the first $100,000 of income from taxation; companies earning more than $500,000 have no such exemption (the exemption applies to the entire controlled corporate group). Corporations ineligible for, or not claiming, the $100,000 exemption may, however, deduct an amount equal to 5 percent of production-worker payroll costs. This extra payroll deduction cannot exceed 50 percent of otherwise taxable income. 3. The regular tollgate tax will be reduced to 5 percent for funds reinvested in designated Puerto Rican assets and withdrawn according to the following schedule: 10 percent may be withdrawn annually for five years, and the remaining 50 percent may be withdrawn at the end of the five years. The list of designated assets was expanded to include investment of earnings in the company's own business or in paying off its own debt. 4. Upon liquidation, a 4 percent tollgate tax will apply to accumulated Puerto Rican income. In the past, accumulated Puerto Rican income was exempt from the tollgate tax if distributed upon liquidation of the company. 5. Export-oriented service industries (architectectural, insurance, engineering, management consulting firms, etc.), which had been fully taxable under prior law, will be able to exempt 50 percent of their export-service income, providing that 80 percent of their employees are residents of Puerto Rico and 80 -17percent of the cost of the Puerto Rico. services was incurred in The new law also contains provisions permitting currently tax-exempt corporations to elect to move to a partially exempt status. The election, which may apply to either the current or the coming fiscal year, must be made when the corporation files its Puerto Rican income tax return for the fiscal year which includes December 31, 1978. Thus a possessions corporation whose fiscal year corresponds to the calendar year could elect in April 1979 (the usual filing date) to become partially taxable for either 1978 or 1979. If 1979 is elected, then the first return indicating taxes actually due would be filed in April 1980. The election is subject to the following provisions: 1. During the years remaining until the end of the existing grant, the following percentages of income will be exempt from tax: Years Left on Original Grant 0-4 years 5-8 years 9-12 years 13-16 years 17-20 years More than 20 years :Maximum Effective Exemption : Tax Rate Percentages: (percent) 73.3 77.7 85.5 90.0 91.0 93.3 12,,0 10.,0 6,,5 4.,5 4.,0 3.,0 After the period of original exemption has expired, the companies electing this option are automatically entitled to operate partially exempt from taxation for ten more years. During the first five of those ten years, 50 percent of income will be exempt; during the second five years, between 35 percent and 50 percent (depending on the location of the investment) of total income will be exempt. 2. Companies with six or more years remaining on their current tax exemption may make an alternative -18election. They may exclude 90 percent of their income from taxation and credit two thirds of their net income taxes paid against the post-conversion tollgate tax imposed on dividends paid from current earnings. Companies electing this second option may apply for a ten-year extension when the current grant expires, but the extension is not automatic. 3. For all companies, 50 percent of all tollgate taxes paid on distributions of income earned before converting to partial exemption are creditable against the post-conversion income tax liability. Dividends will also benefit from special reductions in the tollgate tax. Accumulated earnings will be subject to a 4 percent tollgate providing that pre-1973 earnings are paid out over a two-year interval, and that 1973-1977 earnings are paid out over a five-year interval (no more than 10 percent can be paid out in each of the five years, and the balance at the end). Income earned in 1978 or thereafter will be subject to a reduced 5 percent tollgate, providing each year's income is paid out according to the five-year schedule just described. All earnings whose distribution is deferred to benefit from a reduced tollgate tax rate must be invested in designated Puerto Rican assets, in plant and equipment to be used in Puerto Rican industrial development, or in retiring the principal of the company's debt. 4. Finally, textile, apparel and shoe producers whose exemption grants expire within the next five years are automatically entitled to a 90 percent tax exemption for an additional five years. The probable effects of these changes are analyzed below. E. Allocation of Income and Deductions Under section 482 of the Internal Revenue Code, the Internal Revenue Service may reallocate income, deductions or credits among two or more corporations under common ownership so as to prevent evasion of taxes. Nowhere has the application of section 482 been more controversial than to transactions between a U.S. parent and its possessions corporation. -19Section 482 cases involving possessions corporations first surfaced in the 1950's. In determining what percentage of a subsidiary's income came from a possession rather than the United States, the Internal Revenue Service had initially ruled that exports from the subsidiary to the parent could be priced so as to attribute to the parent only the profit margin normally earned by an independent distributor. In some, but not all, cases, the Service subsequently clarified its initial ruling to indicate that it applied only to the 50 percent and 80 percent tests of eligibility for section 931 benefits. Some other income allocation rule would be used under section 482 to determine the tax liability of the parent. In August, 1959, Governor Munoz Marin of Puerto Rico formally protested to the Secretary of the U.S. Treasury that Puerto Rico was not a tax haven, but that the Internal Revenue Service's 482 position was hurting Puerto Rico's ability to attract U.S. investment. Furthermore, because a few 931 subsidiaries of U.S. parents never had a Puerto Rican tax exemption, and because many exemptions would expire in the future, section 482 cases might diminish Puerto Rican tax collections. Although the Federal government never accepted the Governor's proposal that a Federal-Commonwealth unit (analogous to the competent authority procedures incorporated into many bilateral tax treaties) be established for resolving transfer-pricing disputes, pending section 482 cases were suspended from 1961 to 1963 while the Internal Revenue Service reviewed its transfer pricing standards. In the early 1960's the Treasury and Internal Revenue Service were increasingly aware of transfer-pricing problems in taxing foreign income, and Puerto Rico presented an acute case of a more general problem. Although the new rules set forth by the Service in early 1963 were applicable only to transactions between possessions corporations and their U.S. parent, the 1963 rules became the foundation for the generally applicable section 482 regulations issued five years later. The 1963 guidelines noted four situations where an improper shifting of profits might occur and a section 482 adjustment would be appropriate. -201. When the parent for exports. 931 subsidiary overcharged its 2. When the 931 subsidiary sold to an independent third party, but derived a benefit from some intangible asset belonging to the parent (e.g., a patent or trademark) without paying an appropriate fee or royalty to its parent. 3. When the parent undercharged its subsidiary for raw materials or component parts furnished by the parent. 4. When the parent incurred a direct expense on behalf of its subsidiary without charging it back to the subsidiary. In determining appropriate transfer prices, the general standard was always to be the arm's-length price, that which would have applied to a comparable transaction between unrelated parties. In any given instance, the specific methods for applying the general standard were ranked as follows: 1. Directly Applicable Independent Prices. In some instances, the subsidiary or the parent may sell the same product to, or buy the same product from, independent parties. If so, the price used in these transactions should also be used for the inter-affiliate transactions. 2. Independent Prices for Similar Products. Even though the parent and the subsidiary deal exclusively with one another, the same or similar product may be bought and sold by others at an identifiable price. This price should be used only if the first method cannot be applied. 3. Other Methods. If the two prior methods availed nothing, then the parent should establish how much the product would have cost if purchased from an independent U.S. manufacturer. This price would include all relevant U.S. costs of production plus a reasonable profit margin. -21Under this last method, if a product could be manufactured in Puerto Rico and shipped to the United States more cheaply than it could be manufactured in the United States (for example, because Puerto Rican labor is usually cheaper than mainland labor), the additional profit from manufacturing in Puerto Rico would be allocable to the subsidiary. If the opposite were the case (for example, because transport costs were higher), the Puerto Rican subsidiary would earn less than a U.S. manufacturer would. The most difficult and contentious cases, the 1963 ruling noted, typically involve intangible property: patents, trademarks, brand names, access to established marketing and distribution channels, and goodwill with customers. For example, in the pharmaceutical industry, manufacturing and distribution costs are a small fraction of the selling price. The large profit margins reflect a return on valuable intangibles, such as a patent on the product. The value of a patent may, in turn, reflect substantial outlays for past research and development. If R&D is to be economical, the ultimate profits must cover not only the cost of the projects yielding commercial products but the "losers" as well. Regardless of whether current profits represent a low, reasonable or high return on past R&D, the tax saving of assigning those profits to a tax-exempt subsidiary can be substantial. Because the total profit margin (i.e., that on manufacturing and distribution) often includes an implicit return on patents, trademarks, goodwill, etc., appropriate transfer prices can be established only by first determining whether the mainland parent or the 931 affiliate owns the intangibles. In some instances, an intangible asset could not possibly be owned by the affiliate (for example, goodwill with customers based on the parent's own marketing and distribution effort). In others, the intangible could have been transferred (for example, exclusive patent rights), but for one reason or another was not, so the parent, not the subsidiary, was still entitled to the return on it. Only if the intangible property truly belongs to the subsidiary could the transfer price appropriately allocate the return on the intangible to the subsidiary. These 1963 guidelines did not fully satisfy the companies and the Puerto Rican government. The companies -22had not engaged in careful tax planning in the past and had not taken care to transfer ownership of relevant intangibles to the subsidiaries. The Internal Revenue Service's guidelines would have resulted, in many cases, in substantial reallocations of income to the parent. An Internal Revenue Service Manual Supplement implementing the 1963 guidelines was held in abeyance from 1965 to 1968, and section 482 cases involving possessions corporations were again suspended. Finally, in 1968, comprehensive regulations implementing, section 482 were issued, as was a revenue procedure allowing companies to follow the 1963 revenue procedure instead of the 1968 regulations (with respect to Puerto Rican transactions only) if the results were more favorable. Although at least one major case dating back to the 1950's remains unresolved twenty years later, the logjam of unresolved cases was really broken in 1968. Section 482 has, however, remained a problem. The 1963 revenue procedure did not necessarily preclude parents from allocating substantial income to their possessions corporations, but did force the companies to lay a careful legal foundation for those allocations. After 1963, the creation of the subsidiary was usually accompanied by the execution of legal documents irrevocably assigning exclusive patent and other rights to the newborn company. Seeing that the 1963 revenue procedure and the 1968 regulations did not materially reduce profit shifting, the Internal Revenue Service has brought a case against Eli Lilly involving a possessions corporation established to manufacture Darvon. Because Eli Lilly executed the legal documents purporting to effect the transfer of intangibles, the argument that the Service has traditionally used in such cases, that the parent and not the subsidiary is entitled to the return on the intangible, will be much more difficult to make. The Service must either argue that the original transfer of the patent was a sham and can be disregarded or find a new legal basis for denying the company the tax benefits it has claimed. Concerned by the transfer-pricing disputes, the current Governor of Puerto Rico, Carlos Romero Barcelo, has recently written the Secretary of the U.S. Treasury to protest that the Internal Revenue Service's practices are inhibiting Puerto Rico's ability to attract new investments through its -23tax exemption program. Furthermore, because some companies do not have a complete exemption, and because all are subject to the tollgate tax, the Governor maintains that the Internal Revenue Service's position could erode the Puerto Rican tax base. The Governor urges that the Treasury review the Service's practices and reaffirm its 1963 guidelines. In summary, then, the allocation of income between a U.S. parent and its tax-exempt possessions corporation has been a source of contention for the last twenty years. Because the income in question has usually been exempt from Puerto Rican taxation, the threat of double taxation has until recently been remote. Successive Puerto Rican Administrations have argued, however, that the Service's proposed reallocations would seriously jeopardize the Puerto Rican industrial development program. With the recent changes in the Industrial Incentive Act and the tollgate tax, the potential for double taxation will become more immediate. -24CHAPTER III. ECONOMIC IMPACT A. Puerto Rican Economic Development Although a full review of Puerto Rican economic development since 1947, the year of the initial Industrial Incentive Act, is beyond the scope of this study, a summary is useful in placing the possessions corporation system of taxation in perspective. Puerto Rico's economic growth after 1947 has often been called an "economic miracle." Figure I traces the growth in Puerto Rican gross national product in dollar and per capita terms (adjusted for price inflation) from 1947 to 1977.* The population statistics used in determining national product per capita reflect not only birth and death rates, but also net migration from Puerto Rico (in recent years, more Puerto Ricans have returned to Puerto Rico than have moved to the mainland). Between 1947 and 1972, Puerto Rican total and per capita GNP grew at average annual growth rates of better than 6 percent and just under 5 percent, respectively. By any historical or international yardstick, this was a remarkable performance.** *In interpreting these and other statistics on Puerto Rico, the reader should be aware of the distinction between gross national product and gross domestic product. Gross domestic product equals gross national product plus Puerto Rican income earned by foreign residents, such as possessions corporations, less income earned by Puerto Rican residents from foreign sources (the primary example being wages paid to Puerto Rican employees of the Federal Government). Gross domestic product is a measure of the total value of all goods and services produced in Puerto Rico in a particular year, whereas gross national product is a measure of the value of the production and income earned by residents of Puerto Rico. Largely because of the growth of high-profit possessions corporations, the ratio of gross national product to gross domestic product has declined from 99 percent in 1960 to 90 percent in 1972 and to 81 percent in 1977. **Over this same quarter century, real GNP in the United States grew at an annual rate of 3.7 percent, and GNP per capita at a rate of 2.2 percent. -25- FIGURE I Total and Per Capita Gross National Product of Puerto Rico, 1947-1977 (Constant 1974 Dollars) Total (left scale) 6,000 5,000 Dollars T 2,400 2,200 Per Capita 2,000 (right scale) 1,800 1,600 H 1,400 1,200 2,000 1,000 800 600 1,000 iq. ' ^ 1 1 1 •w/ 48 '50 '52 '54 _J '56 1 1 1 1 1 1 1 1 1 '58 '60 '62 '64 '66 '68 70 '72 74 Source: Puerto Rico Planning Board 268 5 - °8 0 - 7 8 - 5 1—|— 76 77 -26Explanations for this success are many. In the late 1940"s and 1950's, Puerto Rican labor was very cheap by U.S. standards: per capita incomes were low, unemployment and underemployment were high, and federal minimum wage standards did not fully apply. U.S. manufacturers found Puerto Rico attractive compared to low-wage foreign countries. Puerto Rico was inside the U.S. tariff wall and offered a more stable political and economic climate than countries in Latin America or the Far East. Puerto Rico's tax exemption was important not only in boosting U.S. investors' profits, but also in symbolizing the less tangible, but equally important, differences between Puerto Rico and developing countries. Several studies have concluded that tax exemption has been crucial in inducing firms to locate one or more of their operations in Puerto Rico during the past 30 years. Company surveys conclude repeatedly that the attraction of "100 percent tax exemption" was the leading factor in most firms' decision to locate in Puerto Rico. Such findings can be overstated, for some firms now operating under an exemption probably would have been operating even without one. Nevertheless, while it would be difficult to determine how much manufacturing investment would have gone into Puerto Rico had a tax exemption not been available, the level and composition of Puerto Rican manufacturing investment surely reflects three decades of tax exemption. Puerto Rico's remarkable economic growth decelerated sharply in the 1970's. As one can see in Figure I, real GNP slowed its growth in 1974, declined in 1975, remained more or less stagnant in 1976, before increasing in 1977. Because of the influx of native Puerto Ricans returning from the United States, Puerto Rican GNP per capita declined steadily from 1973 to 1977. The traditionally high rate of unemployment in Puerto Rico, which had been gradually reduced to just over 10 percent in the late 1960's, started edging up in the early 1970's, and went to 21.5 percent in April 1977. As explained more fully below, the Puerto Rican economy began a recovery in late 19 77 and early 19 78, and in April 1978, the unemployment rate was back down to 16.5 percent. -27The prolonged recession in the Puerto Rican economy would have been deeper had it not been for offsetting expenditures by the Federal and Commonwealth governments. Total Federal transfers to Puerto Rico increased almost tenfold beween 1968 and 1977 — see Table 2. By 1977, net Federal transfers directly to individuals (the bonus value of food stamps, net social security and medicare payments, veterans benefits, etc.) of $1.2 billion represented 15 percent of personal income, which was two and a half times the 6 percent average for the United States. Net Federal transfers to individuals plus grants to Puerto Rican governments represented 25 percent of Puerto Rican GNP in 1977, also two and a half times the 10 percent U.S. average. The efforts of the Commonwealth government to cushion the recession on the Puerto Rican economy are reflected in Figure II. Total spending by the Puerto Rican government plus investment by public enterprises went from $1.5 billion in 1970 to $2.8 billion in 1974, a 90 percent increase in four years. (In recent years the Puerto Rican government has taken over the telephone company, the sugar industry, and other private enterprises, and investment spending by public enterprise has become an instrument of public finance.) Until 1968, total public sector borrowing never exceeded $100 million per year; by 1975, new public sector borrowing exceeded $600 million. Higher interest costs forced the former and the current Administrations to cut back on their rate of net new borrowing. By 1977, new borrowing was down to $300 million, and the premium Puerto Rico has paid to market its bonds has been pared. The reasons for the prolonged recession of the Puerto Rican economy are many. First and most obviously, the Puerto Rican economy is closely tied to the U.S. economy. Roughly 45 percent of Puerto Rican gross domestic product is exported to the United States, so recessions in the U.S. economy, such as those in 1969-1971 and 1974-75, are transmitted to Puerto Rico. Puerto Rico's ability to offset economic fluctuations through its own monetary or fiscal policy is limited. With the dollar as its currency and a free flow of capital between San Juan and New York, Puerto Rico has no real control over local interest rates or the -28Table 2 Federal Transfer Payments, Grants, "Covered Over" Taxes and Tax Expenditure on Possessions Corporations in Puerto Rioo, ' Fiscal Years 1968 and 1977 1/ (Millions of dollars) FY 1968 Net Federal transfer payments to individuals, total 2/ Food stamps Old age, survivors, and disability insurance Veterans benefits Unemployment compensation All other Federal grants to Puerto Rican Commonwealth and municipal governments, total Child nutrition and special milk programs Human development 3/ Office of Education programs Public assistance Community development block grants Low rent public housing Employment and training programs All other Federal taxes "covered over" to Puerto Rican treasury, total Customs duties Alcoholic beverage and tobacco excises Federal tax expenditure on possessions corporations TOTAL _68 — 1 59 1 7 : FY 1977 1/235 610 295 185 87 58 31 15 11 7 54 716 81 48 67 59 49 48 150 214 93 27 66 223 60 163 99 659 389 2,833 129 5 6 — Office of the Secretary of the Treasury Office of Tax Analysis Sources: U.S. Department of the Treasury, Federal Aid to States: Fiscal Year 1977, and the Statistical A p p W H v *-r> <-h^figrrehary'sAnnual Report for 1968; Office of the Governor, Commonwealth of Puerto Rico, Economic Report of the Governor (various years); and U.S. Department of the Treasury estimates. 1/ In 1968 both the Federal and Puerto Rican fiscal years ended on June 30, and therefore all data for FY 1968 is based on the same time period. In 1977, however, the Federal fiscal year was changed, beginning on October 1, 1976 and ending on September 30, while the Puerto Rican fiscal year again ended on June 30. With the exception of certain Federal transfer payments, all data for 1977 is based on the Federal fiscal year. 2/ All transfer payments are net of associated payments by or on behalf of current or future recipients, such as employer, employee, and self-employment contributions for QASDI. 3/ Formerly, "child" development. -29- FIGURE II Total Government Expenditures Plus Net Investment of Public Enterprises, O w n Source Revenue Plus Federal Taxes Covered Over, Federal Grants-in-Aid, and Total Borrowing of Puerto Rico, 1960-1977 $ Millions 4.000 r 1960 '61 '62 '63 '64 '65 '66 '67 '68 '69 7 0 Source: Puerto Rico Planning Board '71 '72 '73 '74 '75 '76 '77 -30availability of credit. Government and public enterprise spending was increased to mitigate the recession, but the impact was dissipated by the high propensity to import. in recent years, more than 75 percent of Puerto Rican gross national product has been spent on imports, primarily from the United States. Even if all government spending is limited to Puerto Rican-produced goods and services, a dollar of government spending probably results in no more than a $1.33 increase in Puerto Rican GNP. (The Puerto Rican multiplier is discussed more fully below.) With a multiplier of only 1.33, Puerto Rico's pursuit of a countercyclical fiscal policy has been frustrating. The roots of Puerto Rico's economic problems go, however, deeper than recent U.S. recessions. Two important industries, petrochemicals and construction, have been depressed. In the late 1960's the Puerto Rican government viewed petroleum refining as a centerpiece for a growing petrochemical and plastics complex, and a foundation on which the island's future prosperity could be based. Puerto Rico's advantage was due, however, to its large allocation of U.S. oil import quotas (which allowed imports of foreign oil, which before 1973 was cheaper than domestic oil) rather than to low wages, locational advantages, or other real factors. The OPEC increase in the price of foreign oil and the consequent termination of the Federal quota scheme eliminated Puerto Rico's previous advantage. In March 1978 the Commonwealth Oil Refining Company (CORCO), the principal oil refiner and the largest private corporation in Puerto Rico, filed for protection under Federal bankruptcy laws. The Puerto Rican construction industry has also been hit by events of the last four years. From 1969 to 1973, construction spending, especially on apartment houses and condominiums, boomed. But in 19 73, interest rates increased as the Federal Reserve tightened the money supply to fight inflation. High borrowing and construction costs and the general economic downturn choked off new condominium demand and left a large stock of unsold units. Between 1974 and 1977, employment of highly paid construction workers dropped by 50 percent to 40,000 jobs. Although the backlog of unsold units is being worked off and other sectors of the construction industry show some new signs of life, full recovery for the construction industry is still a long way off. -31Puerto Rico has also been hurt by the growing competitiveness of foreign imports in U.S. markets. Its traditional advantages, cheap labor and no tariffs on exports to the U.S. market, have been undermined by a series of changes. Throughout the 1950's and 1960's (but not the 1970's) Puerto Rican wage rates rose not only in dollar terms but also relative to wages paid in the United States and foreign countries. To some extent, Puerto Rico was the victim of its own economic success: as per capita incomes rose, so did the wage at which labor would work. Higher Puerto Rican wages are also the product of Commonwealth and Federal government policies. By the end of 1977, almost two-thirds of non-government employees were subject to the U.S. minimum wage, $2.30 per hour, and over 90 percent were subject to a minimum wage of at least $2.00 per hour. Furthermore, 37 percent of Puerto Rican employees work for the Federal or Commonwealth governments (the U.S. figure is 18 percent), both of which pay higher than average salaries. Food stamp, unemployment insurance, and other income support programs have discouraged many Puerto Ricans from taking unpleasant jobs paying a low wage. The competitiveness of Puerto Rican production has been further undercut by structural changes in the world economy. After the Kennedy round of tariff negotiations in the 1960's, U.S. tariff rates were cut by 40-50 percent on average. As Japanese and other competitors utilizing low-wage foreign labor penetrated the U.S. market, U.S. companies lost their inhibitions about manufacturing in low-wage countries and exporting back to the United States. The difference in labor costs between these countries and Puerto Rico is striking. For example, in the Dominican Republic and Haiti, two countries sharing an island closer to the United States than Puerto Rico, unskilled labor earns roughly 33 cents per hour, a seventh of the minimum wage in Puerto Rico. Such countries' exports are subject to U.S. tariffs and non-tariff trade barriers, but they can be transported in ships flying foreign flags and using cheaper foreign labor, which Puerto Rican exports cannot. The increasing competitiveness of foreign imports is clearly reflected in the level and composition of Puerto Rican employment. Between 1973 and 1977, total Puerto Rican -32manufacturing employment dropped from 152,100 to 145,400, or 4.4 percent — see Table 3.* This drop, which was much sharper in Puerto Rico than in the United States, was due to a decline in the traditional labor-intensive industries (tobacco, textiles, apparel, and leather products (including footwear)), and the petrochemical sector. By contrast, employment grew in the chemical (including pharmaceutical), non-electrical machinery, and professional and scientific industries. Because these industries taken together employ a fourth of manufacturing workers, their gain offered a partial offset to the others' loss. An unfortunate side effect of the possessions corporation system of taxation in the past has been tax-induced plant closings. Until 1976,,a U.S. parent was subject to Federal tax on dividends received from a possessions corporation, but not on the distribution upon the liquidation of that corporation. Accordingly, liquidation of the subsidiary into the parent was the final step in realizing the full tax benefit of the possession corporation system of taxation- Although Puerto Rican operations could be continued after corporate liquidation as an unincorporated branch of the U.S. parent, high Puerto Rican and Federal taxes applicable to non-exempt income discouraged companies from continuing operations as taxable establishments. Although the available evidence is rather meager, a recent study by Fomento, the Puerto Rican agency charged with promoting new investment in Puerto Rico, provides information on this point (see Figure III for source). The Fomento study examined 149 cases in which companies were granted tax exemption between 1960 and 1962 and actually established operations. Because the grants apply to specific products, not to all the operations of the company obtaining the grant, the current status of operations in 46 of the 149 cases could not be determined. Of the 103 cases remaining, 62 operations apparently discontinued, *The statistics in Table had 3 for April 1978 been represent a sharp increase in manufacturing employment over the March level. Table 3 Total Manufacturing Employment in Puerto Rico, by Major Industry Group: Average for Calendar Years 1973 to 1977 and April 1978 1977 Total Employment (000) Average for Calendar Year: 7976 : T975 ': 1974 145.4 142. 5 135.2 150.9 152.1 98.3 97. 7 93.5 103.9 105.3 Industry Group April 1978 ; All Manufacturing Industries Nondurable goods 102.1 151.5 1973 Percentage Change 1973-1977 -4.4 -6.6 -1.3 24.0 24.1 23.8 24. 1 23.7 Food and kindred products 26.3 5.5 -3U.9 4. 9 5.4 5.1 3.8 Tobacco products 3.2 7.6 -42.1 4. 6 7.4 5.1 4.4 Textile mill products 4.7 40.3 -9.9 37. 5 38.1 34.6 36.3 Apparel 36.7 + 2.3 4.3 4.2 4.0 4. 1 Paper and allied products; Printing 4.4 10.6 + 33.U 11 .4 11.6 10.4 and publishing 4.4 14.1 6.7 -6.0 5 9 6.6 5.5 Chemicals 15.1 6.3 6.4 -18.8 5 2 6.2 5.0 Petroleum refining; Rubber products 6.1 5.2 Leather and leather products 5.6 46.9 +0.6 41.7 46.8 47.1 44.9 Durable goods 49.3 Lumber and wood products; 4.9 -28.6 3.9 4.4 3.7 3.5 Furniture and fixtures 3.7 7.3 -28.8 6.1 7.3 5.6 5.2 Stone, clay and glass products 5.4 6.8 -23.5 5.8 5.6 5.4 5.2 Primary metal products; Fabricated metal products 5.7 +163.2 2.3 1.9 4.4 3.5 5.0 Machinery, except electrical; 14.0 -0.7 13.9 11.8 9.6 13.9 Transportation equipment 5.3 8.6 + 34.9 9.3 10.9 10.1 11.6 Electrical and electronic equipment 13.9 3.2 -15.6 3.0 3.0 2.8 2.7 Scientific instruments 12.1 Miscellaneous manufacturing 3.2 Office of the Secretary of the industries Treasury Office of Tax Analysis Sources : Economic Development Administration, Commonwealth of Puerto Rico; Office of the Governor, Commonwealth of Puerto Rico, tudy of Puerto Rico, Part Two - Problems Affecting Development of Puerto Rican Society, An Agenda for a Socio-Economic Study June 1977, Table III-A-4, p. 166; and U.S. Department of Commerce. i Ui Ui I -34- FIGURE III Current Status of 149 Exemption Decrees Granted Between 1960 and 1962 and Utilized by Recipient Firms 6 Exemptions held 4 Exemptions held by taxable firms by taxable firms reporting profits reporting losses i )urce: Government of Puerto Rico, Economic Development Administration, Economic Analysis the Industrial Incentive Program of Puerto Rico, February 1978. -35and 31 were still operating under an extension or a modification of the original tax exempt grant. Ten operations were continuing in a taxable status; six were paying taxes, and four were reporting losses. As noted below, the Tax Reform Act of 1976 eliminated the Federal tax incentive to liquidate operations, recent changes in the Puerto Rican Industrial Incentive ease the transition from exempt to taxable status. and Act B. Characteristics of Possessions Corporations The characteristics of the possessions corporations reflect the unique features of Puerto Rican and Federal tax laws. Because most of the statistical analysis below is based on tax returns, the identities and characteristics of individual taxpayers are confidential. Companies must, however, file 10-K returns with the U.S. Securities and Exchange Commission, and these returns, which are available to the public, provide information on the importance of section 936 to individual companies. To explain why corporate income tax payments are often less than 48 percent (the maximum statutory tax rate in the United States) of book income, the S.E.C. requires corporations to indicate which provisions of the Internal Revenue Code reduced their tax liability by more than 2.4 percent of pre-tax book income. A survey of recent 10-K forms, most of which cover fiscal years ending in 1976 or the first half of 1977, provides the information shown in Table 4. In interpreting these data, two caveats should be kept clearly in mind. First, because specific procedures for estimating the dollar value of various tax preferences have never been set forth by the S.E.C, the statistics presented in Table 4 should be regarded as only rough estimates of the importance to the companies of the possessions corporation system of taxation- Second, companies for whom the tax savings may be large in dollar terms, but less than 2.4 percent of book income before taxes, need not and generally do not report this item separately. Third, even when tax savings exceed 2.4 percent of book income, companies may combine the tax savings attributable to possessions corporations with lesser items (e.g., deferral or sometimes DISC). Companies following this practice were excluded from Table 4. Table 4 Major U.S. Manufacturing Corporations Claiming a Reduction in Income Taxes in Excess of 2.4 Percent of Book Income Because of Section 931 or 936 of the Internal Revenue Code Corporation Esmark H.J. Heinz Pepsico Blue Bell Hanes Corporation Rohm & Haas Abbott Laboratories Baxter Travenol Merck Pfizer Richardson-Merrell Schering-Plough G.D. Searle Smith-Kline American Hospital Supply Johnson & Johnson Eli Lilly Squibb Upjohn Becton Dickinson Chesebrough-Pond's Digital Equipment Motorola Gould Perkins-Elmer Insilco : : Industry :Estimated Tax Saving : Estimated Tax Saving : (millions of dollars): (Percent of Book Income Before Taxes) Food products Food products Beverages Textile & Apparel Textile & Apparel Chemicals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Pharmaceuticals Toiletries Office Equipment Electronics Automotive Equipment Instruments Miscellaneous Manufactures Sub-total - 14 pharmaceuticals Total 26 manufacturers Office of the Secretary of the Treasury Office of Tax Analysis $ 5.6 4.9% 7.2 7.0 3.6 3.1 0.6 4.6 2.8 3.4 10.6 3.0 16.2 12.1 22.9 35.6 11.8 14.3 5.5 15.1 5.8 5.3 37.0 32.5 24.5 15.1 38.5 22.9 7.2 6.7 3.6 4.2 12.7 13.9 21.9 10.0 14.6 8.0 5.1 3.3 6.3 2.9 3.5 11.1 6.2 1.1 1.7 2.3 8. 2 1.1 4.5 10.8 255.2 308.2 ~"~ ~~ —~ Source: Summary of 10-K Reports filed.with U.S. Securities and Exchange Commission in Tax Analysts and Advocates, Tax Notes, recent issues. • -37To gain as complete a picture of possessions corporations' operations as possible, information from Federal and Puerto Rican income tax returns was matched with payroll and employment data from companies' Federal unemployment insurance tax returns. This section summarizes the results based on information for 1975*, the most recent year for which relatively complete data are available. Section D below summarizes the less complete, but essentially similar information for 1976, and Appendix B sets forth comparable information for 1973 and 1974. Table 5 indicates that 595 companies were apparently eligible for the section 931 exclusion in 1975**, the book income (net of losses) of these subsidiaries was $1.1 billion, and their estimated tax saving was $447 million. This total tax saving is estimated by multiplying book income (before deducting losses) by 40 percent and then subtracting any income taxes paid to the Puerto Rican and foreign governments.*** The tax-saving calculation ignores companies with losses because in 1975, under section 931, •Tables 5, 6 and 7 are based on the returns for corporations whose fiscal years ended between July 1, 1975 and June 30, 1976. Because most possessions corporations have calendar year accounting periods, the data correspond closely to calendar year 1975 operations. See Appendix B for details. **That is to say, the companies excluded income under section 931 in 1973, 1974 or 1975 and reported a profit or a loss in 1975. Included in these 595 companies are those which may not in fact have excluded income under section 931 in 1975 because they reported a loss or failed to qualify in 1975 for the section 931 exclusion. ***The conventional practice of measuring tax savings or expenditures by calculating the tax consequences of changing the Internal Revenue Code, but assuming that corporations and individuals behave as they did before, may need explanation. The reason for the current practice is that the tax expenditure defined in this way may be estimated using available information on existing law and behavior. Estimating the behavioral change requires additional economic analysis of what would happen if tax policy were changed, and knowledgeable observers may differ in their assessment of what would indeed happen. -38Table 5 Income and Estimated Tax Expenditure by Industry, 1975 1/ Industry Group :: Number of Corporations : : :: Book Income :: : ($000) : Estimated Tax Expenditure ($000) All Industries 595 1,109,567 447,059 Manufacturing industries 394 1,055,462 425,369 22 7 8 88 69 47 22 14 14 7 26 7 76 5 27 24 71,747 26,805 -3,051 43,557 616,191 547,060 69,131 1,444 7,289 8,419 24,714 1,882 195,593 1,074 33,688 26,110 28,652 10,744 265 17,669 246,470 218,210 28,260 572 2,910 3,384 10,114 759 79,164 430 13,627 10,609 Nonmanufacturing 201 54,104 21,689 Transportation, communications, and utilities Wholesale trade Retail trade Apparel Finance, insurance, real estate Savings and loans Services Miscellaneous and not available 9 12 101 83 26 9 16 37 30,006 3,144 12,541 2,082 1,284 808 -107 7,236 10,062 1,258 5,250 1,123 588 307 1,623 2,908 Food and kindred products •tobacco products Textile mill products Apparel Chemicals, total Pharmaceuticals All other chemicals Rubber products Leather and leather products Stone, clay, and glass products Fabricated metal products Machinery, except electrical Electrical and electronic equipment Transportation equipment Scientific instruments All other manufacturing Office of the Secretary of the Treasury Office of Tax Analysis 1/ Includes data for possessions corporations operating in American Samoa, Guam, and the Panama Canal Zone. These non-Puerto Rican operations account for less than 2 percent of total tax expenditure in any year (see Table 1). -39they could join affiliated U.S. companies in filing a consolidated Federal return. The 40 percent represents the Treasury's necessarily rough estimate of what the effective rate of taxation would have been in the absence of a tax provision such as this.* (Another way of interpreting this 40 percent is that it is the effective rate which would apply if Puerto Rico were treated the same way as the fifty States and the District of Columbia.) The effective rate is less than 48 percent, the maximum statutory rate, because other provisions of the Internal Revenue Code (e.g., the investment tax credit and accelerated depreciation) would have reduced the tax burden by an estimated 8 percentage points. Puerto Rican and foreign taxes, which amounted to $6.2 million overall, would also have been creditable against the Federal income tax liability and, thus, further reduce the net saving of U.S. taxes. Several important conclusions can be drawn from the tables in the text and Appendix B and from the underlying statistics: — The Federal tax expenditure in 1975 was $447 million, compared to $258 million in 1973. — If all the possessions corporations of each U.S. parent are consolidated, the benefits of the possessions corporation system of taxation were concentrated among all U.S. parent corporations as follows in 1975: : Percent of Total Number of : Tax Benefits of All Parent Corporations :: Corporations Top 5 Top 10 Top 20 Top 30 — 27.3% 46.2 70.0 80.2 Just under 50 percent of the total tax saving from 1973-1975 was realized by pharmaceutical subsidiaries. The concentration of tax benefits for parent corporations indicated above is largely attributable to its concentration in the pharmaceutical sector. *See Department of the Treasury, Effective Income Tax Paid by United States Corporations in 1972, May Rates 1978. -40Tables 6 and 7 are based on 280 possessions corporations for which 19 75 employment and payroll data could be obtained from the Federal unemployment tax returns. While the coverage represents less than half the number of companies included in Table 5, the combined book income of the sample, $860 million, represents four fifths of the book income of all possessions corporations. For no apparent reason, information for companies in the high-profit industries was more frequently available than that for companies in the labor-intensive industries. The first three columns of Table 6 present information comparable to that in Table 5. Columns 5 and 7 indicate the number of employees and the total employee compensation, respectively, in each industry in 1975. Finally, the last three columns indicate the tax expenditure per employee, the tax expenditure as a percent of total compensation, and average compensation. Table 6 highlights the relationship between Federal tax expenditures and Puerto Rican employment. For the manufacturing companies covered, the tax expenditure per employee averaged $7,428, which was slightly larger than the average compensation per worker, $7,300. Table 6 also indicates that the tax expenditure per employee varied from one industry to another. In the pharmaceutical industry the Federal tax expenditure represented almost $35,000 per employee, or approximately three and a half times the total compensation of the comparatively well paid Puerto Rican pharmaceutical employee. By contrast, in the rubber industry, the tax expenditure per employee was $760, or 11 percent of the average wage. The tax expenditure per employee in all manufacturing corporations except pharmaceuticals was $4,061. Table 7 is based on the same 280 possessions corporations shown in Table 6, but ranked according to the Federal tax expenditure per employee. At the top of the ranking was a company for which the Federal tax expenditure represented more than $500,000 per Puerto Rican employee; at the low end were the companies which incurred losses and, thus, derived no immediate tax benefit from section 931. According to Table 7, the top five possessions corporations had tax savings per employee in excess $100,000; together they accounted for 8.4 percent of the total tax savings and 0.5 percent of the total employment, of the 280 companies for which employment information was available. The top 58 possessions corporations, those for which tax savings per employee exceeded $10,000 in 1975, collectively accounted Table 6 Tax Expenditure, Employment and Compensation of Employees by Industry, 1975 Industry Group : Tax Expenditure ; Employees : Compensation of :Tax Expendi-:Tax Expenditure : : : : : Employees 1/ : ture Per :as Percent of Number of Book Income: Amount :Percent : :Percent : Amount :Percent : Employee :Compensation of Corporations ($000) ; ($000) ;of Total: Number ;of Total: ($000) :of Total: ($) :Employees dl industries 280 858,961 342,212 100.0 43,174 100.0 345,234 100.0 Manufacturing industries 237 824,816 328,863 96.1 31,812 73.7 250,149 72.5 14 5 3 46 49 35 14 8 9 4 18 3 46 3 21 8 37,173 5,487 13,138 2,271 3.8 .7 .1 1.7 5,321 12.3 2.0 .2 38,920 4,600 11.3 861 83 4,658 7,838 5,794 2,044 10.8 18.2 13.4 Food and kindred products Tobacco products Textile mill products Apparel Chemicals, total Pharmaceuticals All other chemicals Rubber products Leather and leather products Stone, clay and glass products Fabricated metal products Machinery, except electrical Electrical and electronic equipment Transportation equipment Scientific instruments All other manufacturing Nonmanufacturing Transportation, communications and utilities Wholesale trade Retail trade Finance, insurance, real estate Savings and loans Services Miscellaneous and not available 281 143 14,007 562,306 507,126 55,108 1,173 6,011 4,530 21,156 5,847 224,734 202,054 22,680 65.7 59.0 527 25,508 84,390 58,127 25,075 3,959 8,381 2,775 10,412 1.3 .2 7.4 24.4 16.8 963 392 6.6 .1 .7 .5 2.5 .1 71 4.7 1.3 3.4 1.0 2.9 .2 457 7.3 1.1 2.4 .8 3.0 .1 128,423 51,651 15.1 6,958 16.1 51,580 14.9 109 898 11,235 7,696 .3 3.3 2.2 438 2,404 1,835 8,578 576 1,477 414 1,248 734 293 26,085 16,487 10,479 6,660 .1 3.1 1.9 1,627 571 .3 3.8 1.3 43 34,145 13,349 3.9 11,362 26.3 95,084 27.5 4 5 3 12 8 8 11 27,975 1,756 2,346 9,249 2.7 .2 .3 .1 .1 .4 .2 4,430 10.3 .8 5.6 2.0 1.9 4.8 2.9 37,792 3,283 21,944 7,509 6,913 15,031 9,525 10.9 340 950 785 -991 2,108 702 876 390 298 1,331 801 2,400 861 799 2,061 1,270 1.0 6.4 2.2 2.0 4.4 2.8 y 7,428 y 5,229 2,469 2,638 1,723 1,255 28,672 34,873 11,096 760 1,628 4,432 6,873 5,521 7,423 2,688 6,441 11,664 768 2/ 33.8 49.4 27.1 22.9 266.3 347.6 90.4 11.1 28.7 66.1 82.4 85.8 100.1 32.6 93.3 86.5 8.9 2/ 2,088 2,064 24.5 21.4 365 452 373 646 631 4.0 5.2 4.3 8.9 8.4 Office of the Secretary of the Treasury Office of Tax Analysis 1/ Compensation of employees was computed by multiplying 1.189 times payroll. The additional 18.9 percent reflects the employer-paid portion of social security, unemployment insurance, and other non-payroll labor costs. The 18.9 percent is the average for all U.S. manufacturing industries in 1975; see the U.S. Department of Commerce, Survey of Current Business, July 1977, Tables 6.5 and 6.6. 2/ Compensation of employees and number of employees used to compute these amounts were weighted by industry using the ratio of ~~ tax expenditure in Table 5 and tax expenditure in this Table. — 1/ 101.7 y 61.1 Average Employee Compensation ($) 7,729 2/ 7,300 2/ 7,314 5,342 6,346 5,475 10,766 10,032 12,300 6,872 5,674 6,702 8,342 6,431 7,412 8,239 6,905 13,478 8,597 2/ 8,530 9,656 9,143 8,720 8,651 7,292 7,500 I Table 7 Tax Expenditure, Employment and Compensation of Employees by Size of Tax Expenditure Per Employee, 1975 Size of Tax Expenditure per Employee Book Income Number of ($000) Corporations Tax Expenditure Amount :Percent ($000) :of Total : Compensation of :Tax ExpendiEmployees : Employees 1/ : ture Per :Percent : Amount :Percent : Employee Number :of Total: ($000) :of Total: ($) All Corporations 280 858,961 342,212 100.0 43,174 100.0 345,234 100.0 $100,000 50,000 10,000 5,000 1,000 500 100 1 5 11 42 39 91 28 26 6 72,950 266,912 274,257 128,198 114,456 6,695 5,615 438 29,180 106,760 108,529 51,266 41,535 2,636 2,246 59 8.4 30.9 31.7 15.0 12.4 .8 .7 227 1,511 4,851 6,810 15,972 3,640 6,607 896 .5 3.5 11.2 15.8 37.0 8.4 15.3 2.1 2,442 16,289 44,863 67,322 117,558 24,145 49,392 5,574 .6 4.3 11.8 17.7 30.9 6.3 13.0 1.5 32 -10,561 2,660 6.2 17,650 14.0 or more under $100,000 50,000 under 10,000 under 5,000 under 1,000 under 500 under 100 under Loss Corporations 5,229 2/ 128,546 70,655 22,373 7,528 2,600 724 340 66 :Tax Expenditure : as Percent of :Compensation of : Employees Average Employee Compensation ($) 67.7 2/ 7,729 2/ 1,194.9 655.4 241.9 76.2 35.3 10.9 4.5 1.1 Office of the Secretary of the Treasury Office of Tax Analysis 10,757 10,779 9,248 9,885 7,360 6,632 7,475 6,2206,635 i I 1/ Compensation of employees was computed by multiplying 1.189 times payroll. The additional 18.9 percent reflects the " employer-paid portion of social security, unemployment insurance, and other non-payroll labor costs. The 18.9 percent is the average f w all U.S. manufacturing industries in 1975; see the U.S. Department of Commerce, Survey of Current Business, July 1977, Tables 6.5 and 6.6. 2/ Compensation of employees and number of employees used to compute these amounts were weighted by industry using the ratio of ~~ tax expenditure in Table 5 and tax expenditure in Table 6. -43for 71 percent of the total tax expenditure and 15.2 percent of total employment. Because the coverage of employment and payroll statistics is not complete, possessions corporations with tax savings exceeding $10,000 per employee may in fact have realized a somewhat smaller percentage of the total tax savings and a significantly smaller percentage of the total employees of all possessions corporations than was the case for the 280 companies represented in Table 7.* Both Tables 6 and 7 indicate a direct relationship between the company's tax saving per employee and its total compensation per employee. This reflects a tendency of the high-profit industries to employ more highly skilled workers and/or a willingness to pay those workers more than they would have been paid by other Puerto Rican employers. Finally, the industries in which tax savings per employee were the highest (pharmaceuticals, electrical and electronic equipment, scientific instruments, non-electrical machinery) tended to be the same industries in which total employment has been growing since 1973; conversely, industries in which tax savings per employee were the lowest (tobacco products, textiles, apparel, leather products) tended to be those whose employment was declining — see Table 3 above. While taxation is not the only factor shaping the development of Puerto Rican industry — the growth in U.S. demand for the products, international trade considerations and other factors play an important role -- the evidence does suggest that tax incentives may bring investment to Puerto Rico. C. Linkages and the Multiplier The preceding Section related the tax cost of the possessions corporation system of taxation to the employment and payroll of those companies. In addition to creating jobs directly, this system of taxation may bring indirect benefits to Puerto Rico. Manufacturing requires raw materials, intermediate goods, and services, a portion of which are supplied by the local economy. Investment in Plant and equipment creates jobs in the construction and capital equipment industries. Workers in all industries spend salaries goods on and the services, whichthat hastax a *Thesetheir inferences areon based assumption savings per employee for companies missing from the sample equal the average tax savings per employee for companies in ^e same industry — see Table 6. Because the Pharmaceutical companies tend to be over represented in the sample, the biases indicated in the text may have occurred. -44"multiplier" effect on the Puerto Rican economy.* in addition to these "backward linkages", the development of one industry may encourage the growth of downstream customers, a phenomenon called "forward linkage." For example, the building of a petroleum refinery facilitates the growth of the petrochemical manufacturers. This Section summarizes the evidence currently available on the importance of these indirect benefits. 1. Backward Linkages The usual method of evaluating backward linkages begins by examining industries' expenditures on various inputs. In order to compare linkages in one industry to those in another, each industry's expenditures on labor, capital, locally purchased materials and on imports are expressed as a percentage of the total value of its production. The sum of the shares of all expenditures measured in this way, plus the rate of return on invested capital, is 100 percent. The costs of materials, labor and other inputs as a percentage of the total value of production by Puerto Rican manufacturing industries in 1972 are depicted in Table 8. The primary statistical source on which Table 8 is based does not differentiate between possessions corporations and locally owned companies or between imported and locally produced materials. Because the operations of a possessions corporation are often integrated with those of its U.S. parent, the linkage of possessions corporations with the local economy may be somewhat weaker than the linkage for all Puerto Rican manufacturers, as measured in Table 8. To estimate how much possessions corporations purchase from the local economy, one must first determine how total purchases are apportioned between Puerto Rican and imported inputs. Unfortunately, neither the 1972 Census of Manufactures nor any other recent study provides up to date information on this point. Rather than assuming that every industry's propensity to import was the same as that of the Puerto Rican economy as a whole, each industry's 1972 expenditure was apportioned using data from a recently *As a general practice, the Treasury does not estimate the linkage and multiplier impacts of specific tax provisions. This is because tax changes are usually taken in the context of an overall Federal budget. The purpose of undertaking the analysis here is to assess the impact of section 931/936, both in total and by industry, on Puerto Rico alone, not on the U.S. and Puerto Rico taken together. ^= ^ r>« as a P e r c e n t Table 8 * x.u E t x P f n d i t u r e s on M a t e r i a l s , L a b o r , P l a n t , and E q u i p m e n t o f the V a l u e o f P r o d u c t i o n by M a n u f a c t u r i n g E s t a b l i s h m e n t s in P u e r t o All Manufacturing : Food and : Industries ; Kindred Products ; Cost of Materials from All Sources 1/ Cost of Materials from Puerto Rico 2/ 54.3 64.7 26.8 49.8 Value Added 1/ 45.7 35.3 Return on Capital and Overhead Costs 4/ 59.3 60.8 46.1 56.3 19.0 39.2 18.9 •1 .1 Expenditures on New Equipment 1/ 2.2 3.2 • 18.0 43.7 30.8 30.0 22.7 12.8 .1 .2 i 2.2 .9 .8 1.0 .3 Total Expenditures on Materials, Labor, Plant, and Equipment in Puerto Rico 5/ 45.9 66.2 Ratio of Labor Costs to Total Expenditures in Puerto Rico .370 .219 Office of the Secretary of the Treasury ~~~ — — — . Office of Tax Analysis 14.8 53.9 20.0 1.1 * 16.4 24.1 2.1 *Less than 0.05 percent. Apparel : Lumber and : Wood Products 20.6 Expenditures on New Plant 1/ Expenditures on Used Equipment 1/ : Textile : :Mill Products; 16.3 28.4 1972 Tobacco Products 40.7 Labor Costs 3/ 17.0 14.5 Rico, en I .5 * .4 * 36.3 35.6 .449 46.3 .531 48.4 .665 .620 Table 8-continued Furniture and Fixtures Cost of Materials from All Sources i Paper and ; Allied Products .7 46 1/ Cost of Materials 24 9 20.9 from Puerto Rico 2/ Value Added 1/ „ ,_ 0/ Labor Costs 3/ Return on Capital and .g Overhead Costs 4/ Expenditures on . 3 3 3,0 New Plant 1/ 7 Printing and : Publishing 34.2 8 -3 ^<*»3 si 7 53 7 27 5 z/ 3 ' 42.2 65.8 22.4 30.3 5 35#1 25.7 3 Expenditures on 8<1 3.9 New Equipment 1,/ '7 ±,z Expenditures on 2 Used Equipment 1/ Total Expenditures on Materials, Labor, Plant, and Equipment from Puerto Rico 5/ Ratio of Labor Costs to Total Expenditures in Puerto Rico * 4 Office ot the Secretary ot the Treasury Office of Tax Analysis *Less than 0.05 percent. 54.4 51 7 D0 496 ^433 #5 Table 8-continued Rubber Products Cost of Materials from All Sources 1/ Cost of Materials from Puerto Rico 2/ Leather and :Stone, Clay and Leather Products :Glass Products Value Added 1/ 46.5 48.8 Labor Costs 3/ 27.5 29.3 Return on Capital and Overhead Costs A/ 16.0 10.9 65,.9 49,.9 21.9 26.1 29.0 23.5 27.7 39.4 1.6 1.1 1.4 .2 i I .2 Expenditures on Used Equipment 1/ 2.2 .607 4.2 5.4 2.4 1.6 .2 __ .1 • 66.2 39.1 45.3 Office of the Secretary the Treasury Office of Tax Analysis *Less than 0.05 percent. 31.5 17.8 25.3 .2 Expenditures on New Equipment 1/ Total Expenditures on Materials, Labor, Plant, and Equipment from Puerto Rico 5/ Ratio of Labor Costs to Total Expenditures in Puerto Rico 34.1 50.1 41 .6 54.7 19.0 18.6 Expenditures on New Plant 1/ 38.5 9.7 17.1 : Fabricated : Machinery ;Metal Products:Except Electrical 58.4 45.3 51.2 53.5 Primary Metals .749 39.2 51.2 .382 .348 37.5 .558 .696 Table 8-continued Electrical and Electronic Equipment Cost of Materials from All Sources Transportation Equipment Miscellaneous Manufacturing Industries Scientific Instruments 42.5 46.6 36.2 54.6 13.6 14.9 11.6 17.5 Value Added 1/ 57.5 53.4 63.8 45.4 Labor Costs 3/ 19.8 28.9 25.5 21.0 Return on Capital and Overhead Costs 4/ 37.4 24.1 37.9 24.1 Expenditures on New Plant 1/ 2.7 .5 1.2 1/ Cost of Materials from Puerto Rico 2/ Expenditures on New Equipment 1/ Expenditures on Used Equipment 1/ Total Expenditures on Materials, Labor, Plant, and Equipment from Puerto Rico 5/ Ratio of Labor Costs to Total Expenditures in Puerto Rico .9 1.8 .6 .2 .1 .1 .1 38.0 44.3 36.1 Office of the Secretary of the Treasury Office of Tax Analysis *Less than 0.05 percent. 1.3 .548 .655 39.8 .671 .530 Table 8-continued Notes: 1/ Based on U.S. Department of Commerce, 1972 Economic Census of Outlying Areas, Manufacturing, Puerto Rico, October 1974, " Chapter 2, Table 2. All statistics are expressed as a percentage of value added plus cost ot materials. 2/ Percentage of cost of materials from Puerto Rico is estimated by multiplying the cost of materials from ^^^^n^yE^rd ~ share of intermediate imports in total intermediate inputs. This latter share was estimated by Richard Weisskoff and Edward Wolff, "Development and Trade Dependence: The Case of Puerto Rico, 1948-1963," Review of Economics and Statistics, November 1975, Table 2, p. 474. These import shares are based on 1963 data; more recent information is unavailable. Whether the degree of dependence on imported inputs for individual industries decreased between 1963 and 1972 is impossible to determine, but the ratio of Puerto Rican imports of capital goods, raw materials and other intermediate goods to the value of shipments for all industries decreased only slightly over this interval. 3/ Labor costs are estimated by multiplying total payroll, as reported by the U.S. Department of Commerce, op. cit., by 1.16. " The additional 16 percent reflects the employer-paid portion of social security, unemployment insurance and other non-payroll labor costs. The 16 percent is the average for all U.S. manufacturing industries in 1972; see the u - b Department of Commerce, The National Income and Product Accounts of the United States 1929-74: Statistical Tables, iy/b, Tables 6.5 and 6.6. 4/ Value shown equals the differential between value added and labor costs. The return on capital includes not only profits, ~ but also interest expenses, depreciation, expenditures on accounting and legal services, and any other overhead costs. ( 5/ Value shown equals the sum of the cost of materials from Puerto Rico, labor costs, 80 percent of expenditures on new plant, « " 21 percent of expenditures on new equipment and total expenditures on used equipment. The 80 percent of expenditures on new plant corresponds to the estimated ratio of expenditures on Puerto Rican inputs to total expenditures by the construction industry, as reported in Weisskoff and Wolff, op. cit. The 21 percent of expenditures on new equipment corresponds to the ratio of the value of shipments of machinery except electrical with a Puerto Rican destination to total expenditures for new equipment by all manufacturers. -50published study based on 1963 data (see footnote 2 to Table 8). Because Puerto Rico"s total imports of capital equipment, raw materials and intermediate products as a percentage of either aggregate manufacturing shipments or gross domestic output decreased only slightly between 1963 and 1972, applying the 1963 apportionment ratios to the 1972 data may produce reasonable results. Between 1972 and 1977, however, the ratio of imported capital equipment, raw materials and intermediate products increased substantially, so the statistics in Table 8 may overstate possessions corporations dependence on the local economy.* With these caveats in mind, Table 8 indicates that for all manufacturers the cost of materials represented 54.3 percent of the value of production. Just under half of these materials (26.8 percent of the value of production) were estimated to have been obtained in Puerto Rico, and the rest were imported, primarily from the United States. Labor costs, which include the employer-paid Social Security contribution and the cost of other non-wage benefits, constituted 17.0 percent of the value of production. The return on capital plus overhead costs (interest, depreciation of existing capital, accounting and legal costs, etc.) accounted for the remaining 28.4 percent of the value of production. Although the source on which Table 8 is based does not estimate the cost of existing capital used in production, it does report new investment in plant and equipment, be it for replacement or expansion. New investment represented 4.3 percent of the value of manufacturing production, roughly a seventh of the current return on capital plus overhead costs. The last two rows in Table 8 show estimated expenditures on all Puerto Rican inputs (labor plus locally purchased materials, plant and equipment) as a percent of the value of production, and labor costs as a percentage of estimated expenditures on all Puerto Rican inputs, respec*A group of pharmaceutical indicated an tively. The 12 former statistic iscompanies useful in comparingin one April 19, 1978 submission to the Treasury that their own recent annual purchases in Puerto Rico of materials and services totaled $89.9 million, which was 11 percent larger than their own total payroll in Puerto Rico. By comparison, Table 8 estimates the cost of materials from Puerto Rico for all pharmaceutical manufacterers was 7 percent larger than the cost of labor in 1972. in this one industry, at least, the use of 1963 data has produced a result close to that based on more recent and presumably more accurate data. -51industry's use of Puerto Rican inputs to another's, while the latter will be used below to translate the Federal tax expenditure as a percent of compensation of employees into tax expenditure as a percent of Puerto Rican income associated directly or indirectly with possessions corporations. The second to last row in Table 8 indicates that some Puerto Rican manufacturers depend much more than others on locally produced inputs. For example, food, furniture, paper, printing, stone, clay and glass, and primary metal manufacturers' expenditures on Puerto Rican inputs represent more than half of the total value of their own production. At the opposite extreme, the pharmaceutical manufacturers spent less than a fifth of the value of production on Puerto Rican inputs. The low pharmaceutical percentage reflects a high return on capital plus overhead costs, not a heavier than average dependence on imported versus locally purchased materials. (The pharmaceutical companies are estimated to import approximately 55 percent of their total inputs, which is slightly higher than the 51 percent average for all manufacturers.) Finally, Table 8 also indicates that the pharmaceutical companies reinvested 7.6 percent of the value of their current production in additions to plant and equipment, more than the 4.3 percent for all manufacturers. As Table 3 above indicated, the chemical sector, which includes pharmaceuticals, has expanded rapidly since 1972. 2. The Multiplier In addition to the income generated by payroll and purchases of locally produced materials, expenditures by possessions corporations have a multiplier impact on the local economy. The original increase in spending generates income, part of which is used to purchase locally produced goods and services, thereby inducing a secondary increase in spending and income. Lacking any econometric model of the Puerto Rican economy, one must resort to less exact methods to estimate the size of the Puerto Rican multiplier. According to standard textbook macroeconomic analysis, the size of the multiplier for an increase in spending (assuming, as seems reasonable in the case of Puerto Rico, that the government cannot change the rate of interest or credit conditions) is: 1 s+m The symbols s and m represent the fraction of an increase in GNP which is saved or is spent on imports, respectively. -52Saving and importing represent "leakages" — the opposite of "linkages" — from the spending-income cycle; the greater these leakages are, the more quickly the impact of increased spending is dissipated, and the smaller the multipler is. In Puerto Rico, the propensity to save appears to be small, and the propensity to import high. In 1976, imports equaled 72 percent of gross national product; between 1974 and 1976 the increase in the dollar value of imports equaled 79 percent of the increase in the dollar value of gross national product. If the marginal propensity to save, s, is assumed to be zero and the marginal propensity to import, m, to be .75, then the formula given above indicates a multiplier of 1.33. That is to say, if spending increases by $1.00, an additional $.33 in local spending will be subsequently generated, so the total increase in income is $1.33.* -*• Direct, Indirect and Total Effects Information on total employee compensation of possessions corporations was presented in Section B above. A broader measure of Puerto Rican benefits can be obtained by adding to employee compensation estimates of the companies' purchases of Puerto Rican materials, new plant and equipment, and then incrementing that total spending on Puerto Rican inputs by the multiplier. The final result would be a measure of the total Puerto Rican income associated directly and indirectly with possessions corporations. An assumption implicit in this new, broader measure is that all Puerto Rican resources used by the possessions corporation in their production have no alternative economic use — they would be unemployed but for the possessions corporations. Although this may be a resonable assumption for the Puerto Rican labor used, other Puerto Rican factors may be scarce. Capital must be diverted from other productive uses. Water and land are scarce in Puerto Rico; their use by possessions corporations precludes their use in other sectors, such as agriculture. Some purchased inputs, such as gas, oil, sugar, wood, or alcohol, are standard commodities which must be bought or could be sold overseas. *This estimate ignores government taxation and spending. If part of an additional dollar of income is paid in taxes and the Puerto Rican government does not increase its spending by a matching amount, the "leakage" will be greater, and the multiplier will be smaller, than this simple analysis indicates. -53Sewage treatment, solid-waste collection and disposal and other government services may also have economic costs. If employee compensation by possessions corporations is too narrow a measure of the benefits they bring Puerto Rico, the total income associated directly or indirectly with those corporations is probably too broad a measure. Table 9 below shows for various manufacturing industries Federal tax expenditures as a percentage of direct labor costs, of total direct expenditures on Puerto Rican inputs, and of Puerto Rican income directly or indirectly associated with those expenditures. The first percentage is identical to that in Table 6 above, the second is obtained by multiplying the first by the percentage in the last row of Table 8, and the third by dividing the second by the multiplier. Finally, the fourth column is simply the inverse of the third column — Puerto Rican expenditures directly or indirectly generated by possessions corporations per dollar of Federal tax expenditure. Table 9 indicates that Federal tax expenditure in some industries is associated directly or indirectly with more Puerto Rican expenditures or income than in other industries. The average for all manufacturing is 3.5. In some industries (e.g., food products, rubber products), the ratio is between 15 and 20, reflecting a low level of tax-exempt income and/or substantial purchases of goods and services from the Puerto Rican economy. In other industries, the ratio is quite low, usually because the tax-exempt income is high and local purchases are only average. In summary, taking account of the backward linkages and the multiplier effect significantly expands — and probably overstates — the total benefit to Puerto Rico associated with the possessions corporation system of taxation. And while the measured cost-benefit ratios are reduced, they continue to vary widely from one industry to another.* *Note that a benefit-cost ratio of 1.0 does not mark the boundary between a "good" program and a "bad" one. For the reasons indicated above, the total income associated directly or indirectly with possessions corporations may overstate the benefits to Puerto Rico. More importantly, the benefit-cost ratio of one program should be compared not to some fixed benchmark, but rather to the ratio for alternative programs. For example (and only for example), a public-works program funded by the Federal government would, because of the multiplier effect, have a benefit-cost ratio of 1.3. The alternative program could, of course, be a restructured tax incentive. Table 9 Tax Expenditures as a Percent of Compensation of Employees, of Direct Expenditure in Puerto Rico, and of Direct and Indirect Expenditure in Puerto Rico, for Manufacturing Industries Tax Expenditure:Tax Expenditure :Tax Expenditure as Percent:Total Direct and as a Percent :as Percent of :of Total Direct and :Indirect Expenditures of Compensation:Direct Expenditures:Indirect Expenditures in :in Puerto Rico Divided of Employees l/:in Puerto Rico 2/ : Puerto Rico 3/ : by Tax Expenditure 4/ Manufacturing industries 101.7 37.6 28.2 3.5 33.8 7.4 Food and kindred products 5.6 17.9 49.4 22.2 Tobacco products 16.7 6.0 27.1 14.4 Textile mill products 10.8 9.3 22.9 15.2 Apparel 11.4 266.3 73.0 8.8 Chemicals, total 347.6 132.4 54.8 1.8 11.1 6.7 Pharmaceuticals 99.3 1.0 28.7 21.5 Rubber products 5.0 20.0 66.1 25.3 Leather and leather products 16.1 6.2 82.4 46.0 Stone, clay, and glass products 85.8 59.7 19.0 5.3 Fabricated metal products 100.1 54.9 34.5 2.9 32.6 21.4 Machinery, except electrical 44.8 2.2 93.3 62.6 Electrical and electronic equipment 41.2 2.4 Transportation equipment 16.1 6.2 Office of the Secretary of the Treasury Scientific instruments 47.0 2.1 Office of Tax Analysis 1/ 2/ 1/ 4/ From Table Column (1) Column (2) Inverse of 6, column (10). times Table 8, line (10). divided by 1.33. column (3). I -554. Forward Linkages Forward linkages are usually evaluated by examining the percentage of total sales to various types of customers. Table 10 shows the percentages of manufacturing industries' shipments in 1972 to Puerto Rico, to the United States and to foreign countries, respectively. For manufacturing as a whole, 41.2 percent went to individual and industrial consumers in Puerto Rico, 54.2 percent to buyers (including parent companies) in the United States, and 4.5 percent to foreign purchasers. If indirect exports (i.e., goods sold to other Puerto Rican manufacturers who, in turn, were exporting to the United States or foreign countries) could be estimated separately, Puerto Rico's dependence on export markets would appear larger than what Table 10 indicates. Table 10 indicates that some industries' forward linkages with other sectors of the Puerto Rican economy are stronger than others'. The lumber and wood industry sells its limited output to Puerto Rican users, and its primary customers — the furniture and paper industries -- also sell almost exclusively to the local market. By contrast, the pharmaceutical industry derived 1 percent of its total sales from the Puerto Rican market. Sales to United States buyers, many of whom may be parent corporations, accounted for 76 percent of total sales. The remaining 23 percent of pharmaceuticals' sales were to foreign purchasers (many of whom may have been affiliated foreign subsidiaries), a larger percentage than the corresponding figure for any other industry. The machinery industry, which exported 15 percent of its total shipments to foreign buyers, was second in terms of non-U.S. exports. Because possessions corporations sell mostly outside Puerto Rico, their operations were not depressed by the 1973-77 recession in the local economy. D. Impact of Changing from Section 931 to Section 936 and of Restructuring the Tollgate Tax This Section reviews the available evidence on the impact of the Federal Tax Reform Act of 1976 and of the Commonwealth's restructuring of its tollgate tax on dividends paid by possessions corporations. Because the tollgate tax changes became effective on the same date (October 1, 1976) as section 936, and because the entire Puerto Rican Industrial Incentive Act has been under close scrutiny and its reform anticipated, the impact of shifting from section 931 to section 936 cannot be completely disentangled from the impact of the tollgate tax or the uncertainty about the future of the tax exemption program. Table 10 Destination of Shipments by Puerto Rican Manufacturing Industries, 1972 (Percentage of Total) Industry Group All manufacturing industries : Puerto Rico : United States 1/ : Foreign Countries 41.2 54.2 4.5 Food and kindred products 59.2 37.2 3.7 • 15.5 84.5 Tobacco products • 28.7 71.3 Textile mill products * 21.8 78.0 Apparel — 100.0 * Lumber and wood products 97.9 2.1 87.5 5.0 7.5 Furniture and fixtures 78.2 18.2 3.6 Paper and allied products 18.9 66.5 14.6 Printing and publishing 1.0 76.0 23.0 Chemicals 64.2 32.7 3.3 * Pharmaceuticals 47.8 52.2 * 15.6 83.1 Petroleum refining * s 91.7 8.3 Rubber products 47.8 52.2 * 87.1 9.7 3.2 Leather and leather products 15.6 83.1 * 77.1 22.2 1.4 Stone, clay and glass products "" "* " " 35.2 50.0 14.8 lpme nt 10.7 87.9 Primary metal products .2 72.7 9.1 9.1 Fabricated metal products 3.9 94.6 2.3 Machinery except electrical Electrical and electronic equipment Transportation equipment Office of the instruments Secretary of the Treasury ~"~ Scientific Office of Tax Analysis Miscellaneous manufacturing industries 12.3 87.7 Source: U.S. Department of Commerce, 1972 Economic Censuses of Outlying Areas, Manufactures, Puerto Rico, October 1974, Chapter 2, Table 3. 1/ Includes shipments to the Virgin Islands. * Less than 0.05 percent. ^ <* ' -571. New Investment in Puerto Rico The Puerto Rican economy remained sluggish throughout 1977, but has been picking up speed in 1978. To a large extent these recent gains represent a welcome, if long overdue, recovery from the recession which began in 1973-74. In addition, Puerto Rico is a primary beneficiary of recent changes in the international economy. The recent depreciation of the dollar against many foreign currencies has helped Puerto Rican goods and services compete with foreign producers for U.S. markets. The Orderly Marketing Agreements limiting Korean and Taiwanese exports of shoes to the U.S., and the Multifiber Arrangements limiting eighteen developing countries' exports of textiles and apparel to the U.S., have lessened the competitive pressure on Puerto Rican manufacturers in these industries. The winter of 1977-78 was apparently the best ever for Puerto Rico's tourist industry. As the dollar depreciated and foreign vacations became more expensive, Puerto Rico seemed more attractive. In addition, the Tax Reform Act of 1976 imposed record-keeping and other requirements on Americans attending foreign conventions, but exempted those attending conventions in Puerto Rico and the possessions from those limitations. The combined Federal and Commonwealth tax changes enacted in 1976 apparently made investing in Puerto Rico somewhat less attractive for most U.S. companies. The Federal tax change added new incentives and disincentives to investing in Puerto Rico. Those companies anxious to bring money home from Puerto Rico as soon as possible benefitted from the dividends-received deduction made available in 1976; those who felt no pressing need for domestic use of accumulated Puerto Rican income might have preferred to keep section 931 because of the exemption for Eurodollar interest income. But when the Puerto Rican tollgate tax rules and rates were also changed to make the dividends taxable, the gains U.S. investors expected from the Tax Reform Act of 1976 were diminished and, perhaps, reversed. Table 11 below is based on 394 corporations claiming section 936 benefits for fiscal years ending before July 1, 1977 (most of which were for the calendar year 1976). The 394 corporations included in Table 11 accounted for approximately 80 percent of the income excludable under section 931 in 1975 (as shown in Table 5 above). For corporations included in both the 1975 statistics of Table 5 and the 1976 statistics of Table 11, total book income and total Federal tax savings increased by 43 percent and 44 percent, respectively. Accordingly, the estimated tax expenditure for sections 931 and 936 inover calendar year 1976 for is $634 1975. million, a 44 percent increase the $440 million -58Table 11 Income and Estimated Tax Expenditure by Industry, 1976 1/ Industry Group : : Estimated Tax Number of :Book Income: Expenditure Corporations: ($000) : ($000) All industries 394 1,325,963 532,996 Manufacturing industries 301 1,217,482 489,579 Food and kindred products Tobacco products Textile mill products Apparel Chemicals, total Pharmaceuticals All other chemicals Rubber products Leather and leather products Stone, clay and glass products Fabricated metal products Machinery, except electrical Electrical and electronic equipment Transportation equipment Scientific instruments All other manufacturing Nonmanufacturing 18 6 6 67 52 36 16 7 6 3 15 7 67 79,205 15,989 -272 47,462 758,401 654,540 103,861 1,560 5,818 9,242 15,475 2,012 224,057 31,882 6,396 192 19,072 303,360 261,816 41,544 626 2,327 3,697 6,199 808 89,772 21 26 44,174 14,359 17,670 7,578 93 108,482 43,417 Transportation, communications and utilities Wholesale trade Retail trade Finance, insurance, real estate Services Miscellaneous and not available 9 11 39 9 10 15 97,948 1,881 2,056 1,065 743 4,787 39,179 753 840 434 297 1,915 Office of the Secretary of the Treasury Office of Tax Analysis 1/ Preliminary statistics. See text. Includes data for possessions ^F°ra^.0nS ° P e r a t i n g i n American Samoa, Guam, and the Panama Canal 4one. These non-Puerto Rican operations account for less than 2 percent ot total tax expenditure in any year (see Table 1 ) . -59Tables 12 and 13 present information for the 209 possessions corporations included in Table 11 for which 1976 employment and payroll-data are available. Comparing Table 12 to Table 6 above suggests that between 1975 and 1976 the Federal tax expenditure increased not only in dollar terms, but also relative to Puerto Rican employment and payroll. This increase appears to be attributable as much to higher tax expenditure per employee or per dollar of employee compensation in the high-profit industries as to an increase in the relative importance of these industries. For the 143 manufacturing corporations included in both Table 6 and Table 12, tax expenditure as a percentage of total employee compensation increased from 138 percent in 1975 to 149 percent in 19 76. (As noted above, employment and payroll data were, for no apparent reason, more often available for high-profit companies.) Because Tables 11, 12, and 13 are based largely on operations for calendar year 1976, they do not capture the effect of the Puerto Rican tollgate tax, which was passed and signed into law in the second half of 1976, much less the uncertainty of 1977 about the future investment climate in Puerto Rico. A better indicator of the impact of those developments may be the number of new tax exemptions applied for or granted over the last few years. Throughout 1977, each was low by historical standards, but this may have been due more to broader political and economic factors than to the technical changes in Federal and Commonwealth tax laws. As the outlines of the Puerto Rican Administration's proposals for reforming the Industrial Incentive Act became apparent, investors realized that the days of total tax exemption were about to end. The large number of exemptions granted just before the new program was announced presumably included both a backlog of those that might have applied earlier and a rush of those that would have applied later. As of May 1978, 711 corporations had filed a section 936 election form — see Table 14. Taken together, these 711 companies accounted for 99.5 percent of the income excludable under section 931 in 1975. Of these, 635 were included in one or more of the tables for 1973 to 1976 in this Report. The remaining 76 corporations are "new" 936 corporations; that is to say, they excluded no income under section 931 between 1973 and 1975, nor did they claim a section 936 credit for a fiscal year ending before July 1, 1977. Thirty-five of these 76 new companies were incorporated in 1977 or 1978, while the remaining 41 were incorporated prior to 1977. This last group includes Table 12 Tax Expenditure, Employment and Compensation of Employees by Industry, 1976 1/ Industry Group Employees Tax Expenditure :Percent of Amount : Percent of Total Number ($000) ; Total Book Income Number of ($000) Corporations 100.0 32,912 192 811,909 327,271 99.6 31,697 96.3 Food and kindred products Tobacco products Textile mill products Apparel Chemicals, total Pharmaceuticals All other chemicals Rubber products Leather and leather products Fabricated metal products Electrical and electronic equipment Scientific instruments All other manufacturing 4/ 10 38,557 15,621 5 12,158 4 -454 42 30,099 35 549,315 25 478,329 10 70,986 5 1,069 5 5,550 12 11,141 38 110,042 18 38,466 18 15,966 4.8 1.5 Nonmanufacturing 17 3,396 1,357 All industries 209 Manufacturing industries 815,305 328,627 4,863 119 12,066 219,722 191,329 28,393 430 2,219 4,465 44,160 15,386 8,220 100.0 Compensation of Employees 2/ Amount :Percent of ($000) ; Total Tax Expenditure Per Employee ($) :Tax Expenditure:Average :as Percent of : Employee :Compensation of:Compensation {Employees : ($) 266,223 00.0 5,127 3/ 71.1 3/ 7,208 3/ 255,590 96.0 7,522 3/ 119.7 3/ 6,287 3/ 11.3 3,685 2,584 51.7 36.6 8.2 26.0 286.4 392.9 101.3 30.6 34.9 105.5 92.1 112.1 59.1 7,124 7,054 6,834 5,844 12,332 10,996 15,634 7,816 6,393 8,107 7,797 7,656 8,862 12.8 8,751 3.7 66.9 58.2 8.6 .1 .7 1.4 13.4 4.7 2.5 4,239 1,882 212 7,938 6,220 4,428 1,792 180 995 522 6,147 1,792 1,570 12.9 5.7 .6 24.1 18.9 13.5 5.4 .5 3.0 1.6 18.7 5.4 4.8 30,199 13,276 1,449 46,390 76,707 48,691 28,016 1,407 6,362 4,232 47,934 13,721 13,913 .4 1,215 3.7 10,633 5.0 .5 562 5.2 5.2 1,520 35,325 43,209 15,844 2,386 2,230 8,553 7,184 8,586 5,236 4.0 1,118 17.4 28.8 18.3 10.5 .5 2.4 1.6 18.0 Office of the Secretary of the Treasury Office of Tax Analysis ~ ^^?f^^X&^^ r^U^De^eST&ce, *,rvey of Current Business, Ouly 3/ cl£en£Son tfe^oyees and number of employees used to oo^te these amounts were wei9hted by Industry using the ratio of t-av extjenditure in Table 11 and tax expenditure in this Table. 4/ i n t l S S ^ u f a c t S r S g industries wherfdata were available for less than 3 corporations. i o I Table 13 Tax Expenditure, Employment and Compensation of Employees by Size of Tax Expenditure Per Employee, 1976 1/ Size of Tax Expenditure per Employee All Corporations 50,000 under $100,000 10,000 under $ 50,000 5,000 under $ 10,000 1,000 under $ 5,000 500 under $ 1,000 500 100 under $ 100 1 under $ Loss Corporations Compensation of Employees 2/_ Employees : Tax Expenditure ; :Percent : Amount : Percent Book Income: Amount :Percent Number of ($000) : ($000) :of Total Number :of Total; ($000) ; of Total Corporations 209 815,305 328,627 100.0 32,912 100.0 266,223 100.0 9 339,728 314,304 64,402 95,374 6,314 1,460 33 135,889 125,719 25,761 38,136 2,522 584 13 41.4 38.3 7.8 11.6 .8 .2 1,721 6,291 3,780 14,567 3,588 1,780 224 5.2 19.1 11.5 44.3 10.9 5.4 .7 20,121 72,339 29,038 100,039 22,364 11,691 1,242 7.6 27.2 10.9 37.6 8.4 4.4 .5 961 2.9 9,389 3.5 50 28 64 29 16 3 10 -6,309 Tax Expenditure Per Employee ($) ;Tax Expenditure Average :as Percent of Employee : Compensation of Compensation : Employees ($) 71.1 3/ 5,127 3/ 78,959 19,984 6,815 2,618 703 328 58 675.4 173.8 88.7 38.1 11.3 5.0 1.0 Office of the Secretary of the Treasury Office of Tax Analysis 1/ Preliminary statistics. See text. 1/ Compensation of employees was computed by multiplying 1.195 times payroll. The additional 19.5 percent reflects the employer-paid portion of social security, unemployment insurance, and other non-payroll labor costs. The 19.5 percent is the average fo^all U.S. manufacturing industries in 1976; see the U.S. Department of Commerce, Survey of Current Business, July 1977, Tables 6.5 and 6.6. . . 3/ Compensation of employees and number of employees used to compute these amounts were weighted by industry using the ratio of "" tax expenditure in Table 11 and tax expenditure in Table 12. 7,208 3/ 11,691 11,498 7,682 6,867 6,232 6,568 5,545 9,770 i CTk Industry Table 14 Elections under Section 936 by Industry : Total : Included; New E : as of : in : ; Date of ;May 1978; Report : Total ;1977 or All industries 711 635 76 35 Manufacturing industries 546 491 55 27 Food and kindred products Apparel Chemicals, total Pharmaceuticals All other chemicals Fabricated metal products Electrical and electronic equip: Scientific instruments All other manufacturing Nonmanufacturing Wholesale and retail trade Finance, insurance, real estate All other nonmanufacturing Office of the Secretary of the Treasury Office of Tax Analysis 32 126 95 65 30 35 106 36 116 28 114 87 61 26 31 97 32 102 4 12 8 4 4 4 9 4 14 1 6 4 2 2 2 5 1 8 165 144 21 8 70 29 66 65 23 56 5 6 10 2 1 5 -63several companies incorporated in the last five years, but which presumably had start-up losses making an earlier section 936 election disadvantageous. Table 14 does not include companies who recently obtained a tax exemption from Puerto Rico, but have delayed their 936 election until they are past their start-up losses. Table 14 indicates that the new 936 corporations have very much the same industrial composition as the old ones do. 2. Repatriation of Dividends In denying a tax exemption for income earned outside the possession in which the corporation had a trade or business, and in making a dividends-received deduction available to the parent, Congress hoped to speed the repatriation of dividends. Because of the Puerto Rican tollgate tax, however, dividend payments were slow throughout 1977. With the entire 936 community seeking repeal or substantial modification of the tax, most companies waited to see what would happen. Because the tollgate tax does not apply to a liquidating distribution, the incentive to wait until the income tax exemption expired and then liquidate the subsidiary into the parent remained, albeit with diminished force and for Commonwealth, rather than for Federal, tax reasons. Finally, some companies initially wondered whether they could pay any tollgate tax without being required by their accountants to establish a reserve to provide for future tollgate taxes on all accumulated earnings. Creating such a reserve could depress income in financial statements in the quarter in which the reserve was established. Accounting firms have, however, taken the position that a reserve for taxes on accumulated earnings need not be established, providing the company commits itself to repatriating only current earnings. In the first six months of 1978, the rate of dividend payments increased appreciably. As of early June, companies have committed th