112 STAT. 2681-907 PUBLIC LAW 105-277—OCT. 21, 1998 statute of limitation not having expired with regard to either a tax underpayment or a tax overpayment, the amendments". 26 USC 7443A. (e) AMENDMENT RELATED TO SECTION 3401 OF 1998 ACT.— Section 3401(c) of the 1998 Act is amended— (1) in paragraph (1), by striking "7443(b)" and inserting "7443A(b)"; and (2) in paragraph (2), by striking "7443(c)" and inserting "7443A(c)". (f) AMENDMENT RELATED TO SECTION 3433 OF 1998 ACT. — Section 7421(a) of the 1986 Code is amended by inserting "633 l(i)," after "6246(b),". (g) AMENDMENT RELATED TO SECTION 3467 OF 1998 ACT.— The subsection (d) of section 6159 of the 1986 Code relating to cross reference is redesignated as subsection (e). (h) AMENDMENT RELATED TO SECTION 3708 OF 1998 ACT.— Subparagraph (A) of section 6103(p)(3) of the 1986 Code is amended by inserting "(f)(5)," after "(c), (e),". (i) AMENDMENTS RELATED TO SECTION 5001 OF 1998 ACT. — (1) Subparagraph (B) of section l(h)(13) of the 1986 Code is amended by striking "paragraph (7)(A)" and inserting "paragraph (7)(A)(i)". 26 USC 1 note. (2)(A) Subparagraphs (A)(i)(II), (A)(ii)(II), and (B)(ii) of section l(h)(13) of the 1986 Code shall not apply to any distribution after December 31, 1997, by a regulated investment company or a real estate investment trust with respect to— (i) gains and losses recognized directly by such company or trust, and (ii) amounts properly taken into account by such company or trust by reason of holding (directly or indirectly) an interest in another such company or trust to the extent that such subparagraphs did not apply to such other company or trust with respect to such amounts. (B) Subparagraph (A) shall not apply to any distribution ' which is treated under section 852(b)(7) or 857(b)(8) of the 1986 Code as received on December 31, 1997. (C) For purposes of subparagraph (A), any amount which is includible in gross income of its shareholders under section 852(b)(3)(D) or 857(b)(3)(D) of the 1986 Code after December 31, 1997, shall be treated as distributed after such date. (D)(i) For purposes of subparagraph (A), in the case of a qualified partnership with respect to which a regulated invest- - ment company meets the holding requirement of clause (iii)— (I) the subparagraphs referred to in subparagraph (A) , shall not apply to gains and losses recognized directly by such partnership for purposes of determining such compan5r's distributive share of such gains and losses, and
(II) such company's distributive share of such gains and losses (as so determined) shall be treated as recognized directly by such company. Applicability. The preceding sentence shall apply only if the qualified partnership provides the company with written documentation of such distributive share as so determined. (ii) For purposes of clause (i), the term "qualified partnership" means, with respect to a regulated investment company, any partnership if— (I) the partnership is an investment company registered under the Investment Company Act of 1940,
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