Ill STAT. 792 PUBLIC LAW 105-34—AUG. 5, 1997 Subtitle F—Foreign Provisions Sec. 1051. Definition of foreign personal holding company income. Sec. 1052. Personal property used predominantly in the United States treated as not property of a like kind with respect to property used predominantly outside the United States. Sec. 1053. Holding period requirement for certain foreign taxes. Sec. 1054. Denial of treaty benefits for certain payments through hybrid entities. Sec. 1055. Interest on underpayments not reduced by foreign tax credit carrybacks. Sec. 1056. Clarification of period of limitations on claim for credit or refund attributable to foreign tax credit carryforward. Sec. 1057. Repeal of exception to alternative minimum foreign tax credit limit. Subtitle G—Partnership Provisions Sec. 1061. Allocation of basis among properties distributed by partnership. Sec. 1062. Repeal of requirement that inventory be substantially appreciated with respect to sale or exchange of partnership interest. Sec. 1063. Extension of time for taxing precontribution gain. Subtitle H—Pension Provisions Sec. 1071. Pension accrued benefit distributable without consent increased to $5,000. Sec. 1072. Election to receive taxable cash compensation in lieu of nontaxable parking benefits. Sec. 1073. Repeal of excess distribution and excess retirement accumulation tax. Sec. 1074. Increase in tax on prohibited transactions. Sec. 1075. Basis recovery rules for annuities over more than one life. Subtitle I—Other Revenue Provisions Sec. 1081. Termination of suspense accounts for family corporations required to use accrual method of accounting. Sec. 1082. Modification of taxable years to which net operating losses may be carried. Sec. 1083. Modifications to taxable years to which unused credits may be carried. Sec. 1084. Expansion of denial of deduction for certain amounts paid in connection with insurance. Sec. 1085. Improved enforcement of the application of the earned income credit. Sec. 1086. Limitation on property for which income forecast method may be used. Sec. 1087. Expansion of requirement that involuntarily converted property be replaced with property acquired from an unrelated person. Sec. 1088. Treatment of exception from installment sales rules for sales of property by a manufacturer to a dealer. Sec. 1089. Limitations on charitable remainder trust eligibility for certain trusts. Sec. 1090. Expanded SSA records for tax enforcement. Sec. 1091. Modification of estimated tax safe harbors. TITLE XI—SIMPLIFICATION AND OTHER FOREIGN-RELATED PROVISIONS Subtitle A—General Provisions Sec. 1101. Certain individuals exempt from foreign tax credit limitation. Sec. 1102. Exchange rate used in translating foreign taxes. Sec. 1103. Election to use simplified section 904 limitation for alternative minimum tax. Sec. 1104. Treatment of personal transactions by individuals under foreign currency rules. Sec. 1105. Foreign teix credit treatment of dividends from noncontroUed section 902 corporations. Subtitle B—Treatment of Controlled Foreign Corporations Sec. 1111. Gain on certain stock sales by controlled foreign corporations treated as dividends. Sec. 1112. Miscellaneous modifications to subpart F. Sec. 1113. Indirect foreign tax credit allowed tor certain lower tier companies. Subtitle C—Treatment of Passive Foreign Investment Companies Sec. 1121. United States shareholders of controlled foreign corporations not subject to PFIC inclusion. Sec. 1122. Election of mark to market for marketable stock in passive foreign investment company. Sec. 1123. Valuation of assets for passive foreign investment company determination.
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