Congressional intent. It is the intent of Congress (1) that the trans- fer of Freedmen’s Hospital to Xxxxxx University be effected as soon as practicable, (2) to assure the well-being of patients at Freedmen’s Hos- pital during the period of transition, and (3) that the transfer be effected with minimum disloca- tion of the present hospital staff and maximum consideration of their interests as employees.
Congressional intent. There seems little doubt that amending or supplementing the Medicare tax (i.e., the Medicare portions of F.I.C.A. and S.E.C.A.) was the Congressional intent for enact- ment of the N.I.I.T. That would place the N.I.I.T. within the literal language of most S.S.T.A.’s. The N.I.I.T. was brought into existence by the Health Care and Education Reconciliation Act of 2010 (H.C.E.R.A.). With the new health care law calling for 8 Chapters 2 and 21 contain S.E.C.A. and F.I.C.A., respectively. The N.I.I.T. is located in Chapter 2A. an expansion of Medicare, Congress presumably believed increased funding was required. One of the first mentions of the N.I.I.T. is a 2010 legislative proposal of the Obama Administration to institute a 2.9% tax on unearned income for individuals re- porting taxable income above certain thresholds. The proposed tax revenues were to fund Medicare. As if to further underscore the point, Chapter 2A of the Code is entitled “Unearned Income Medicare Contribution,” and Code §1411 is the only section that appears in Chapter 2A. This was an important distinction for the court in Toulouse, which looked to the location within the Code to conclude that the social security tax im- posed by the foreign country was not an income tax that could be claimed as a foreign tax credit against taxable income. The court stated the following: The Code is divided into subtitles, and subtitles are divided into chap- ters, which impose separate and distinct taxes. Section 1, which is in chapter 1, subtitle A, Income Taxes, of the Code, imposes a tax on the taxable income of individuals (regular tax). Compare ch. 1, sec. 26(b) (referring to tax imposed by section 1 as “regular tax liability”) with ch. 23, sec. 3301 (imposing a tax on employers on wages that they pay to their employees).
