PUBLIC LAW 105-34—AUG. 5, 1997 111 STAT. 1095 (1) Paragraph (4) of section 264(a) is amended by striking subparagraph (A) and all that follows through "by the taxpayer," and inserting the following: "(A) is or was an officer or employee, or "(B) is or was financially interested in, any trade or business carried on (currently or formerly) by the taxpayer.". (2) The last 2 sentences of section 264(d)(2)(B)(ii) are amended to read as follows: "For purposes of subclause (II), the term 'applicable period' means the 12-month period beginning on the date the policy is issued (and each successive 12-month period thereafter) unless the taxpayer elects a number of months (not greater than 12) other than such 12- month period to be its applicable period. Such an elec- Applicability. tion shall be made not later than the 90th day after the date of the enactment of this sentence and, if made, shall apply to the taxpayer's first taxable year ending on or after October 13, 1995, and all subsequent taxable years unless revoked with the consent of the Secretary.". (3) Subparagraph (B) of section 264(d)(4) is amended by striking "the employer" and inserting "the taxpayer". (4) Subsection (c) of section 501 of the Health Insurance Portability and Accountability Act of 1996 is amended by strik- 26 USC 264 note. ing paragraph (3). (5) Paragraph (2) of section 501(d) of such Act is amended by striking "no additional premiums" and all that follows and inserting the following: "a lapse occurring after October 13, 1995, by reason of no additional premiums being received under the contract.". (g) AMENDMENTS RELATED TO SECTION 511.— (1) Subparagraph (B) of section 877(d)(2) is amended by striking "the 10-year period described in subsection (a)" and inserting "the 10-year period beginning on the date the individual loses United States citizenship". (2) Subparagraph (D) of section 877(d)(2) is amended by adding at the end the following new sentence: "In the case of any exchange occurring during such 5 years, any gain recognized under this subparagraph shall be recognized immediately after such loss of citizenship.". (3) Paragraph (3) of section 877(d) is amended by inserting "and the period applicable under paragraph (2)" after "subsection (a)". (4) Subparagraph (A) of section 877(d)(4) is amended— (A) by inserting "during the 10-year period beginning on the date the individual loses United States citizenship after "contributes property" in clause (i), (B) by inserting "immediately before such contribution" after "from such property", and (C) by striking "during the 10-year period referred to in subsection (a),". (5) Subparagraph (C) of section 2501(a)(3) is amended by striking "decedent" and inserting "donor". (6)(A) Clause (i) of section 2107(c)(2)(B) is amended by striking "such foreign country in respect of property included in the gross estate as the value of the property" and inserting
�
