90 STAT. 1652
PUBLIC LAW 94-455—OCT. 4, 1976 " (B) SEPARATE AND IDENTIFIABLE OPERATIONS.—A taxpayer may show that different operations within the same country, or operations in different countries, are clearly separate and identifiable operations. " (3) DEFINITION OF BOYCOTT PARTICIPATION AND COOPERATION.— For purposes of this section, a person participates in or cooperates with an international boycott if he agrees— " (A) as a condition of doing business directly or indirectly within a country or with the government, a company, or a national of a country— •'(i) to refrain from doing business with or in a country which is the object of the boycott or with the government, companies, or nationals of that country; " ( i i) to refrain from doing business with any United States person engaged in trade in a country which is the object of the boycott or with the government, companies, or nationals of that country; " ( i i i) to refrain from doing business with any company whose ownership or management is made u p, all or in part, of individuals of a particular nationality, race, or religion, or to remove (or refrain from selecting) corporate directors who are individuals of a particular nationality, race, or religion; or " ( i v) to refrain from employing individuals of a particular nationality, race, or religion; or " (B) as a condition of the sale of a product to the government, a company, or a national of a country, to refrain from shipping or insuring that product on a carrier owned, leased, or operated by a person who does not participate in or cooperate with an international boycott (within the meaning of subparagraph (A)). " (4) COMPLIANCE W I T H CERTAIN LAWS.—This section shall not
apply to any agreement by a person (or such member) — " (A) to meet requirements imposed by a foreign country with respect to an international boycott if United States law or regulations, or an Executive Order, sanctions participation in, or cooperation with, that international boycott, " (B) to comply with a prohibition on the importation of goods produced in whole or in part in any country which is the object of an international boycott, or " (C) to comply with a prohibition imposed by a country on the exportation of products obtained in such country to any country which is the object of an international boycott. " (c) INTERNATIONAL BOYCOTT FACTOR.— " (1) INTERNATIONAL BOYCOTT FACTOR.—For purposes of sec-
Ante, pp. 1649, 1650. Post, p. 1655. 26 USC 993.
tions 9 0 8 (a), 9 5 2 (a)(3), and 9 9 5 (b)(3), the international boycott factor is a fraction, determined under regulations prescribed by the Secretary, the numerator of which reflects the world-wide operations of a person (or, in the case of a controlled g r o u p (within the meaning of section 993(a)(3)) which includes that person, of the group) which are operations in or related to a group of countries associated in carrying out an international boycott in or with which that person or a member of that controlled group has participated or cooperated in the taxable year, and the denominator of which reflects the world-wide operations of that person or group.
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