Page:United States Statutes at Large Volume 87.djvu/46

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PUBLIC LAW 93-000—MMMM. DD, 1973

14

PUBLIC LAW 93-17-APR. 10, 1973

26 USC ili^e 83^statr602! '

"Foreign issuer or obligor."

[87 STAT.

mitment letter, memorandum of terms, draft purchase contract, or other documents setting forth, or referring to a document sent by the foreign issuer or obligor from whoni the acquisition was made which set forth, the principal terms of such acquisition, or (ii) had received from the foreign issuer or obligor from whom the acquisition was made a memorandum of terms, draft purchase contract, or other document setting forth, or referring to a document sent by the acquiring United States person (or persons) which set forth, the principal terms of such acquisitions; (C) of stock or a debt obligation issued in connection with the purchase or lease of a vessel the construction of which was begun before January 30, 1973, if— (i) the acquisition meets the requirements of subparagraph (B) (except that for purposes of this clause, the term "January 29, 1973" appearing in such subparagraph shall be read as "April 30, 1973"), and (ii) the contract for the construction of the vessel was entered into by the United States person, or by a less developed country corporation described in section 4916 (^) (^) ( ^) ^^ *^^ Internal Revenue Code of 1954 which is a member of the same controlled group (within the meaning of section 1563(a) of such Code) as that person, which purchased or leased such vessel; or (D) of stock or a debt obligation issued in connection with a purchase or lease of a vessel the construction of which was begun before January 30, 1973 if— (i) a request for a ruling had been filed with the Internal Revenue Service within 60 days prior to January 30, 1973, with respect to the transaction, (ii) before such date the United States person financing the transaction (or if two or more such persons are participating in financing the transaction, a majority in interest of such persons) had approved the transaction, or given a commitment to participate in the transaction (orally or in writing), subject to customary closing conditions, and (iii) the vessel to be acquired in the transaction was delivered on or before March 1, 1973. For purposes of this paragraph— (I) FoREiGN ISSUER O OBLIGOR.—The term "foreign issuer or R obligor" shall iuclude any person which, on the date of such acquisition, owned at least 80 percent of each class of stock of the foreign issuer or obligor, as determined under section 958(a) of