PUBLIC LAW 94-455—OCT. 4, 1976 (h)
90 STAT. 164'
CoNFOK.ALlNC A.MKND.MKN TS.
(1) Section 48(a) (-2)(B) ( v i i) (ivlating to definition of section 38 property) is amended by sti-iking out " ( other tlian a corporation entitled to the benefits of section 031 or 0 3 4 (b)) ' ' and insertin<i- in lieu thereof the f'oll()\vin<r: " ( other than a corporation which has an election in effect under section 03() or which is entitled to the benefits of section 0 3 4 (b)) ". (2) Paragraph (2) of subsection IK)(t>) (relatinf,^ to certain dividends excluded from partial exclusion of dividends ivceived by indivi(bials) is amended to read as follows: " (2) a corporation which, for the taxable year of the corporation in which the distribution is made, oi' for the next precedin,ii' taxable year of the corporation, is a corporation exempt from tax under section 501 (relating to certain char-itable, etc., organizations) or section r)21 (relating to farmers' cooperative associations); or". (3) Section 8f)l(a)(2)(A) (relating to income from sources within the Tinted States) is amended by striking out "othei- tlum a corporation entitled to the benefits of section 031," and inserting in lieu thereof the following: "other than a corporation which has an election in effect under section 03(5,". (4) Section 0001(b)(2)(H) (ii) (relating to place of filing foi' corporations) is amended by striking out "section 031 (relating to income from sources within possessions of the United States), " and inserting in lieu fhereof the following: "section 036 (relating to possession tax credit),", (i)
P]FFE(TIVE D A T E. —
26 USC 48.
26 USC 116. •'
a: 26 USC 861.
Post, p. 1648. - v 26 USC 33 note.
(1) Except as provided by paragraph (2), the amendments made by this section shall apply to taxable years beginning after .,. Decembv'r 31, 107;"), except that "(jualified possession source investment income" as defined in section 03()(d)(2) of the Internal Revenue Code of 1054 shall include income from any source out- ^"^^' P- 1643. side the United States if the taxpayer establishes to the satisfaction of the Secretary of the Treasury or his delegate that the income from such sources was earned before October 1, 1076. (2) The amendment made by subsection (d)(2) shall not apply to any tax imposed by a possession of the United States with respect to the complete liquidation occurring before fJanuary 1. • >' 1070, of a corporation to the extent that such tax is attributable to earnings and profits accmnulated by such corporation during periods ending before January 1, 1076. SEC. 1052. WESTERN HEIVIISPHERE TRADE CORPORATIONS. (a) PiiASEouT OF SPECIAL DEDUCTION FOR W E S T E R X H E M I S P H E R E TRADE CORPORATIONS.—Section 022 (special deduction for Western
Hemisphere trade corporations) is amended by adding at the end thereof the following new subsection: " (b) PiiASEOUT OF DEDUCTION.—In the case of a taxable year beginning after December 31, 1075. and before January 1, 1080," the percent specified in subsection (a)(2)(A) shall be (in lieu of 14 percent) the percent specified in the following t a b l e: "For a taxable year The percentage beginning in— shall be— 1976 n 1977 1978 1979
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S o 2".
26 USC 922.
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