98 STAT. 496
PUBLIC LAW 98-369—JULY 18, 1984 Sec. 93. Amortization of construction period interest and taxes for residential real property held by corporations. Sec. 94. Capitalization of start-up expenditures. Sec. 95. LIFO conformity rules applied on controlled group basis. Subtitle H—Provisions Relating to Tax Straddles Sec. 101. Repeal of exception from straddle rules for stock options and certain stock. Sec. 102. Section 1256 extended to certain options. Sec. 103. Regulations under section 1092(b). Sec. 104. Limitation on losses from hedging transactions. Sec. 105. Clarification that section 1234 applies to options on regulated futures contracts and cash settlement options. Sec. 106. Wash sale rules to apply to losses on certain short sales. Sec. 107. Time for identification by taxpayer of certain transactions. Sec. 108. Treatment of certain losses on straddles entered into before effective date of Economic Recovery Tax Act of 1981. Sec. Sec. Sec. Sec.
111. 112. 113. 114.
Subtitle I—Depreciation Recovery period for certain real property extended to 18 years. Recapture in case of installment sales. Provisions relating to sound recordings and films. Definition of section 38 property in sale-leaseback transactions. Subtitle J—Foreign Provisions PART I—CHANGES IN SOURCE AND CHARACTER RULES
Sec. 121. Certain amounts treated as derived from United States sources for purposes of limitation on foreign tax credit. Sec. 122. Certain amounts treated as interest for purposes of the limitation on the foreign tax credit. Sec. 123. Treatment of related person factoring income. Sec. 124. Treatment of certain transportation income. Sec. 125. Treatment of certain distributions received by United States-owned foreign corporations. Sec. 126. Allocation under section 861 of research and experimental expenditures. PART II—WITHHOLDING PROVISIONS
Sec. 127. Repeal of 30 percent tax on interest received by foreign persons on certain portfolio investments. Sec. 128. Treatment of United States source original issue discount in case of foreign persons. Sec. 129. Withholding of tax on dispositions of United States real property interests. Sec. 130. Treatment of payments to Guam and Virgin Islands corporations. PART III—TAXATION OF CERTAIN TRANSFERS OF PROPERTY OUTSIDE THE UNITED STATES
Sec. 131. Taxation of certain transfers of property outside the United States. PART IV—MISCELLANEOUS FOREIGN CORPORATE PROVISIONS
Sec. Sec. Sec. Sec. Sec. Sec.
132. 133. 134. 135. 136. 137.
Amendments related to foreign personal holding companies. Amendments related to section 1248. Definition of foreign investment company. Application of collapsible corporation rules to foreign corporations. Stapled stock; stapled entities. Services relating to insurance policies are treated as performed in country of risk. PART V—TREATMENT OF A U E N INDIVIDUALS
Sec. 138. Definition of resident alien and nonresident alien. Sec. 139. Treatment of community income. Subtitle K—Reporting, Penalty, and Other Provisions PART I—PROVISIONS RELATING TO TAX SHELTERS
Sec. 141. Registration of tax shelters. Sec. 142. Organizers and sellers of potentially abusive tax shelters must keep lists of investors.
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