Page:United States Statutes at Large Volume 96 Part 1.djvu/541

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PUBLIC LAW 97-000—MMMM. DD, 1982

PUBLIC LAW 97-248—SEPT. 3, 1982

96 STAT. 499

thereof and without regard to the second sentence of section 1232(b)(1))." (c) CONFORMING AMENDMENTS. —

(1) Subparagraph (A) of section 1232(a)(2) is amended— (A) by striking out "by a corporation after May 27, 1969" and inserting in lieu thereof "by a corporation after May 27, 1969, or by a government or political subdivision thereof after July 1, 1982", (B) by striking out " a s provided in paragraph (3)(B)" and inserting in lieu thereof "without regard to subsection (a)(6) or (b)(4) of section 1232A (or the corresponding provisions of prior law)", and (C) by striking out the subparagraph heading and inserting in lieu thereof the following:

26 USC 1232.

"(A) CORPORATE BONDS ISSUED AFTER MAY 27, 1969, A N D GOVERNMENT BONDS ISSUED AFTER JULY 1, 1982.—".

(2) Subparagraph (B) of section 1232(a)(2) is amended— (A) by striking out "by a government or political subdivision thereof after December 31, 1954" and inserting in lieu thereof "by a government or political subdivision thereof after December 31, 1954, and on or before July 1, 1982,", and (B) by striking out " G O V E R N M E N T BONDS" in the s u b p a r a -

g r a p h heading and inserting in lieu thereof "GOVERNMENT BONDS ISSUED ON OR BEFORE JULY 1, 1982 ".

(3) Subparagraph (D) of section 1232(a)(2) is amended by striking out "This section" and inserting in lieu thereof "This section and sections 1232A and 1232B". (4) Subsection (a) of section 1232 is amended by striking o u t paragraph (3) and by redesignating paragraph (4) a s paragraph (3). (d) CLERICAL AMENDMENT. — The table of sections for such part IV is amended by inserting after the item relating to section 1232 the following: "Sec. 1232A. Original issue discount."

(e) TRANSITIONAL RULE. — For purposes of the amendments made 26 USC 1232A by this section, any evidence of indebtedness issued pursuant to a "°*'^' written c o m m i t m e n t which was binding on July 1, 1982, and a t all times thereafter shall be t r e a t e d as issued on July 1, 1982. SEC. 232. TAX TREATMENT OF STRIPPED BONDS.

(a) IN GENERAL. — Part IV of subchapter P of chapter 1 (relating to special rules for determining capital gains and losses) is amended by inserting after section 1232A the following new section: "SEC. 1232B. TAX TREATMENT OF STRIPPED BONDS,

26 USC 1232B.

"(a) INCLUSION IN INCOME AS IF B O N D AND C O U P O N S W E R E O R I G I NAL ISSUE DISCOUNT BONDS.—If any person purchase s after July 1,

1982, a stripped bond or a stripped coupon, the n such bond or coupon while held by such purchase r (or by any other person whose basis is determined by reference to the basis in the h and s of such purchaser) shall be treated for purposes of section 1232A(a) as a bond originally issued by a corporation on the purchase date and having a n original issue discount equal to the excess (if any) of— "(1) the stated redemption price a t m a t u r i t y (or, in the case of a coupon, the a m o u n t payable on the due date of such coupon), over

•^"^«. P- 496.