PUBLIC LAW 99-514—OCT. 22, 1986
100 STAT. 2817
(A) Subparagraph (A) of section 467(b)(4) is amended by striking out "statutory recover period" and inserting in lieu thereof "statutory recovery period". (B) Paragraph (4) of section 467(c) is amended by striking out "subsection (b)(3)(A)" and inserting in lieu thereof "subsection (b)(4)(A)". (C) The last sentence of section 467(d)(2) is amended by striking out "section 1274(c)(2)(C)" and inserting in lieu thereof "section 1274(c)(4)(C)". (D) Paragraph (5) of section 467(e) is amended by striking out "section 168((1)(4)(D)" and inserting in lieu thereof "section 168(e)(4)(D)". (c) TRANSITION RULE.—A taxpayer shall be allowed to use the cash receipts and disbursements method of accounting for taxable years ending after January 1, 1982, if such taxpayer— (1) is a partnership which was founded in 1936, (2) has over 1,000 professional employees, (3) used a long-term contract method of accounting for a substantial part of its income from the performance of architectural and engineering services, and (4) is headquartered in Chicago, Illinois. SEC. 1808. AMENDMENTS RELATED TO TAX STRADDLE PROVISIONS. (a) TREATMENT OF SUBCHAPTER S CORPORATIONS.—
(1) Section 102 of the Tax Reform Act of 1984 (relating to section 1256 extended to certain options) is amended by adding at the end thereof the following new subsection: "0") COORDINATION OF ELECTION UNDER SUBSECTION (d)(3) WITH ELECTIONS UNDER SUBSECTIONS (g) AND (h).—The Secretary of the Tresisury or his delegate shall prescribe such regulations as may be necessary to coordinate the election provided by subsection (d)(3) with the elections provided by subsections (g) and (h)." (2) Paragraph (3) of section 102(d) of the Tax Reform Act of 1984 (relating to subchapter S election) is amended by striking out "(as so defined)" and inserting in lieu thereof "(as so defined) or such other day as may be permitted under regulations". (b) TREATMENT OF AMOUNTS RECEIVED FOR LOANING SECURITIES.—
Subparagraph (B) of section 263(g)(2) (defining interest and carrying charges) is amended by striking out "and" at the end of clause (ii), by striking out the period at the end of clause (iii) and inserting in lieu thereof ", and", and by inserting after clause (iii) the following new clause: "(iv) any amount which is a payment with respect to ' a security loan (within the meaning of section 512(a)(5)) includible in gross income with respect to such property for the taxable year." (c) TREATMENT OF OPTION STRADDLES.—Subparagraph (A) of section 1092(d)(3) (relating to special rules for stocks) is amended by adding at the end thereof the following new sentence: "The preceding sentence shall not apply to any interest in stock." (d) SECTION 108.—Section 108 of the Tax Reform Act of 1984 is amended— (1) by striking out "if such position is part of a transaction entered into for profit" and inserting in lieu thereof "if such loss is incurred in a trade or business, or if such loss is incurred
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