75TH CONGRESS, 1s'r SESSION-CH . 815-AUGUST 26, 1937 SEC. 202. EFFECTIVE DATE . Supplement P of Title I of the Revenue Act of 1936, added to such Act by section 201 of this Act, shall not apply to a taxable year (either of a shareholder or of a foreign corporation) ending on or before the date of the enactment of this Act ; and in no case shall the stock ownership requirement provided in section 331 (a) (2) of such Supplement be satisfied unless a United States group (as therein defined) existed with respect to the corporation after the date of the enactment of this Act . If under section 338 or 339 of such Supple- ment the date on which a return is required to be filed occurs prior to November 1, 1937, the return shall be considered as filed on time if filed prior to December 1, 1937 . SEC. 203. ADJUSTED BASIS OF STOCK OF FOREIGN PERSONAL HOLD- ING COMPANY . Section 113 (b) (1) of the Revenue Act of 1936 is amended by striking out the period at the end thereof and inserting in lieu thereof a semicolon and the following "and "(E) to the extent provided in section 337 (f) in the case of the stock of United States shareholders in a foreign personal holding company ." SEC. 204 . BA SIS OF STO CK IN FOR EIG N PERSONAL HO LDIN G COM - PAN Y ACQUIRED FR OM DECEDENT . Section 113 (a) (5) of the Revenue Act of 1936 is amended by adding at the en thereof a new sentence to read as follows "If the property was acquired by bequest devise, or inheri- tance, or by the decedent's estate from the decedent, and if the decedent died after the date of the enactment of the Revenue Act of 1937, and if the property consists of stock or securities of a foreign corporation, which with respect to its taxable year next preceding the date of the decedent's death was a foreign personal holding company, then the basis shall be the fair market value of such property at the time of such acquisition or the basis in the hands of the decedent, whichever is lower ." SEC. 205 . LIQUIDATION OF FOR EI GN PERSONAL HO LDI NG COMPANIES . Section 115 (c) of the Revenue Act of 1936 is amended by adding at the end thereof a new sentence to read as follows "If any distribution in complete liquidation (including any one of a series of distributions made by the corporation in complete can cella tion or red empti on of all i ts st ock) is made by a foreign corporation which with respect to any taxable year beginning on or before, and ending after, the date of the enactment of the Revenue Act of 1937, w as a fore ign person al holding company, and with respect to which a United States group (as defined in section 331 (a) (2)) existed after the date of the enactment of the Revenue Act of 1937 and before January 1, 1938, then, despite the foregoin provi- sions of this subsection 100 per centum of the gain recognize result- ing from such distribution shall be taken into account in computing net income- " (1 ) Unless such liquidation is completed b efore January 1,1938;or "( 2) Unless (if it is established to the satisfaction of the Co mmissioner by evide nce submit ted before January 1, 1938, that due to the laws of the foreign country in which such cor- p oratio n is incorp orate d, or for o ther reason , it is or will be impossible to complete the liquidation of such company before such date) the liquidation is completed on or before such date as the Commissioner may find reasonable, but not later than June 30 . 1938 ." 825 Effective date. Provisions relating to foreign personal holding companies . Ante, p . 818. Adjusted basis of stock of foreign per- sonal holding com- pany. General rule . 49 Stat . 1685. Basis of stock in foreign personal hold- ing company acquired from decedent . 49 Stat. 1682 . Liquidation of for- eign personal holding companies . 49 Stat . 1687. Distribution .
