PUBLIC LAW 104-191—AUG. 21, 1996 110 STAT. 2103 Subtitle C—Repeal of Financial Institution Transition Rule to Interest Allocation Rules SEC. 521. REPEAL OF FINANCIAL INSTITUTION TRANSITION RULE TO INTEREST ALLOCATION RULES. (a) IN GENERAL. —Paragraph (5) of section 1215(c) of the Tax Reform Act of 1986 (Public Law 99-514, 100 Stat. 2548) is hereby 26 USC 864 note, repealed. (b) EFFECTIVE DATE.— 26 USC 864 note. (1) IN GENERAL.— The amendment made by this section shall apply to taxable years beginning after December 31, 1995. (2) SPECIAL RULE. —In the case of the first taxable year beginning after December 31, 1995, the pre-effective date portion of the interest expense of the corporation referred to in such paragraph (5) of such section 1215(c) for such taxable year shall be allocated and apportioned without regard to such amendment. For purposes of the preceding sentence, the preffective date portion is the amount which bears the same ratio to the interest expense for such taxable year as the number of days during such taxable year before the date of the enactment of this Act bears to 366. Approved August 21, 1996. LEGISLATIVE HISTORY—H.R. 3103 (S. 1028) (S. 1698): HOUSE REPORTS: Nos. 104-496, Pt. 1 (Comm. on Ways and Means) and 104-736 (Comm. of Conference). SENATE REPORTS: No. 104-156 accompanying S. 1028 (Comm. on Labor and Human Resources). CONGRESSIONAL RECORD, Vol. 142 (1996): Mar. 28, considered and passed House. Apr. 18, 23, considered and passed Senate, amended, in lieu of S. 1028. Aug. 1, House agreed to conference report. Aug. 2, Senate agreed to conference report. WEEKLY COMPILATION OF PRESIDENTIAL DOCUMENTS, Vol. 32 (1996): Aug. 21, Presidential remarks and statement.
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