PUBLIC LAW 100-647—NOV. 10, 1988
102 STAT. 3427
purposes of determining whether any interest in a REMIC qualifies under the preceding sentence, any interest in another REMIC held by such REMIC shall be treated as a qualifying real property loan under principles similar to the principles of the preceding sentence, except that if such REMIC's are part of a tiered structure, they shall be treated as 1 REMIC for purposes of this paragraph." (26) Section 860E of the 1986 Code is amended by adding at the end thereof the following new subsection: "(f) TREATMENT OF VARIABLE INSURANCE CONTRACTS.—Except as
provided in r^ulations, with respect to any variable contract (as defined in section 817), there shall be no adjustment in the reserve to the extent of any excess inclusion." (27) Subsection (a) of section 860E of the 1986 Ckxle is amended by adding at the end thereof the following new paragraph: "(5) (COORDINATION WITH SECTION 172.—Any excess inclusion for any taxable year shall not be taken into account— "(A) in determining under section 172 the amount of any net operating loss for such taxable year, and "(B) in determining taxable income for such taxable year for purposes of the 2nd sentence of section 172(b)(2)." (u) AMENDlifENTS RELATED TO SECTION 672 OP THE REFORM ACT.—
(1) Subparagraph (B) of section 163(e)(2) of the 1986 Code is amended by striking out "paragraph (6)" and inserting in lieu thereof "paragraph (7)". (2) Subparagraph (B) of section 1278(a)(4) of the 1986 Code is amended by striking out "section 1272(a)(6)" and inserting in lieu thereof "section 1272(a)(7)". (3) Section 1288(a) of the 1986 Code is amended by striking out "paragraph (6)" each place it appears and inserting in lieu thereof "paragraph (7)". (4) Sections 1271(a)(2)(A)(ii) and 1275(a)(4)(B)(iiXD of the 1986 Code are each amended by striking out "subsection (a)(6)" and inserting in lieu thereof "subsection (a)(7)". (v) AMENDMENT RELATED TO SECTION 674 OF THE REFORM ACT.—
Subparagraph (A) of section 6049(d)(7) of the 1986 Code is amended by inserting "(and such amounts shall be treated as paid when includible in gross income under section 860B(b))" before the period at the end thereof. (w) AMENDMENTS RELATED TO SECTION 675 OF THE REFORM ACT.—
(1) Subsection (a) of section 675 of the Reform Act is amended 26 USC 860A note. to read as follows: "(a) GENERAL RULE.—Except as otherwise provided in this section, Effective date. the amendments made by this subtitle shall take effect on January 1, 1987." (2) Section 675 of the Reform Act is amended by adding at the end thereof the following new subsection: "(d) STUDY.—The Secretary of the Treasury or his delegate shall Banks and conduct a study of the operation of the amendments made by this banking. part and their competitive impact on savings and loan institutions 26 USC 860A note. and similar financial institutions. Not later than January 1, 1990, Reports. the Secretary shall submit a report of such study to the (jommittee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate (t<^ether with such recommendations as he may deem advisable)."
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