100 STAT. 2266
PUBLIC LAW 99-514—OCT. 22, 1986
"(c) FOREIGN TAX CREDITS.—If an ownership change occurs with respect to a corporation, the amount of any excess foreign taxes under section 904(c) for any taxable year before the 1st post-change taxable year shall be limited under regulations which shall be consistent with purposes of this section and section 382. "(d) PRO RATION RULES FOR YEAR WHICH INCLUDES CHANGE.—For
purposes of this section, rules similar to the rules of subsections (b)(3) and (d)(1)(B) of section 382 shall apply. "(e) DEFINITIONS.—Terms used in this section shall have the same respective meanings as when used in section 382, except that appropriate adjustments shall be made to take into account that the limitations of this section apply to credits and net capital losses." (c) CONFORMING AMENDMENTS.—
(1) Paragraph (5) of section 318(b) is amended by striking out "section 382(a)(3)" and inserting in lieu thereof "section 382(1)(3)". (2) The table of sections for part V of subchapter C of chapter 1 is amended— J (A) by striking out the item relating to section 382 and
- ^'inserting in lieu thereof the following new item:
"Sec. 382. Limitation on net operating loss carryforwards and certain builtin losses following ownership change.",
and (B) by striking out the item relating to section 383 and inserting in lieu thereof the following new item: "Sec. 383. Special limitations on certain excess credits, etc.". (d) REPORT ON DEPRECIATION AND BUILT-IN DEDUCTIONS; REPORT
ON BANKRUPTCY WORKOUTS.—The Secretary of the Treasury or his
delegate— (1) shall, not later than January 1, 1989, conduct a study and report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate with respect to the treatment of depreciation, amortization, depletion, and other built-in deductions for purposes of sections 382 and 383 of the Internal Revenue Code of 1986 (as amended by this section), and (2) shall, not later than January 1, 1988, conduct a study and report to the committees referred to in paragraph (1) with respect to the treatment of informal bankruptcy workouts for purposes of sections 108 and 382 of such Code. (e) REPEAL OF CHANGES MADE BY TAX REFORM ACT OF 1976.— (1) Subsections (e) and (f) of section 806 of the Tax Reform Act of 1976 (including the amendment treated as part of such subsections under section 59(b) of the Tax Reform Act of 1984) are hereby repealed. (2) Subsection (g) of such section 806 is amended by striking out paragraphs (2) and (3). (f) EFFECTIVE DATES.—
(1) IN GENERAL.—The amendments made by subsections (a), (b), and (c) shall apply to any ownership change following— (A) an owner shift involving a 5-percent shareholder occurring after December 31, 1986, or (B) an equity structure shift occurring pursuant to a plan ISO of reorganization adopted after December 31, 1986. (2) FOR AMENDMENTS TO T A X R E FOR M ACT O F 1976.—
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