98 STAT. 842
PUBLIC LAW 98-369—JULY 18, 1984 us lol "m;
(i) by striking out "with respect to any unused investment credit" and all that follows and inserting in lieu 1o 3 1' thereof the following: "with respect to any unused <>j sfi jpi: business credit of the corporation which can otherwise Ante, p. 828. be Carried forward under section 39, to any unused credit of the corporation which could otherwise be Ante, p. 826. Carried forward under section 30(g)(2), to any excess ^*^' foreign taxes of the corporation which could otherwise be carried forward under section 904(c), and to any net
- ,; J a.,-;. capital loss of the corporation which can otherwise be
carried forward under section 1212.", and (ii) by striking out the section heading and inserting 0(;^>S;feU «; -f- J" • in lieu thereof the following: "SEC. 383. SPECIAL LIMITATIONS ON UNUSED BUSINESS CREDITS, RESEARCH CREDITS, FOREIGN TAXES, AND CAPITAL LOSSES." 26 USC 383. ^ (|5j_^^ (B) Section 383 (as amended by the Tax Reform Act of 1976) is amended— .:..(i) by striking out "with respect to any unused investment credit" and all that follows and inserting in lieu thereof the following: "with respect to any unused business credit of the corporation under section 39, to any unused credit of the corporation under section ^p;, . ' * ' 30(g)(2), to any excess foreign taxes of the corporation ' ^ '* " under section 904(c), and to any net capital loss of the corporation under section 1212.', and (ii) by striking out the section heading and inserting in lieu thereof the following: "SEC. 383. SPECIAL LIMITATIONS ON UNUSED BUSINESS CREDITS, RESEARCH CREDITS, FOREIGN TAXES, AND CAPITAL LOSSES." SI 'bf ' (C) The table of sections for part V of subchapter C of chapter 1 is amended by striking out the item relating to section 383 and inserting in lieu thereof the following: B^
26 USC 401. 1^ 26 USC 404.
"Sec. 383. Special limitations on unused business credits, research credits, foreign taxes, and capital losses."
(13) Paragraph (21) of section 401(a) is amended by striking out "allowable—" and all that follows and inserting in lieu thereof "allowable under section 41 if the employer made the transfer described in section 41(c)(1)(B)." (14) SECTION 404.—Subsection (i) of section 404 (relating to deductibility of unused portions of employee stock ownership credit) is amended to read as follows:
"(i) DEDUCTIBILITY OF UNUSED PORTIONS OF EMPLOYEE STOCK OWNERSHIP CREDIT.— "(1) UNUSED CREDIT CARRYOVERS.—If any portion of the em-
Ante, p. 826. Ante, p. 827. Tr „ „ „t ^Q . Ante, p. 828.
^gi. 5
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ployee stock ownership credit determined under section 41 for any taxable year has not, after the application of section 38(c), A^ been allowed under section 38 for any taxable year, such portion
shall be allowed as a deduction (without regard to any limitations provided under this section) for the last taxable year to which such portion could have been allowed as a credit under section 39. "(2) REDUCTIONS IN CREDIT.—There shall be allowed as a deduction (subject to the limitations provided under this section) an amount equal to any reduction of the credit allowed under section 41 resulting from a final determination of such credit to
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