826 P eriod of limitat ion upon assessment and collection . 49 Stat . 1726. Sha reholders of for - eign personal holding companies . Time prescribed for flung . 49 Stat. 1726 . Subsection relet- tered . Mi nor am endmen ts toTitleIof1936Act. 49 Stat . 1653. 49 Stat . 1657. Fo reign person al holding companies. Ante, p . 820. 49 Stat. 1671 . Foreign personal holding companies . I nform ation re- turns . Ante, pp . 823, 824 . 49 Stat . 1706. For eign p ersona l holding companies . Information re- tur ns. Ante, pp. 823, 824 . Pe nalti es . 49 Stat . 1703; Inf ormat ion re- turns, failure to file . 75TH CONGRESS, 1ST SESSION-CH . 815-AUGUST 26, 1937 SEC. 206 . PERIOD OF LIMITATION UPON ASSESSMENT AND C OLLEC - TION. (a) Section 275 of the Revenue Act of 1936 is amended by insert- ing after subsection (c) thereof a new subsection to read as follows
"(d) SHAREHOLDERS OF FOREIGN PERSONAL HOLDING COlYIPANIES .- If the taxpayer omits from gross income an amount properly includ- ible therein under sectio n 337 (b) (relating to the in clusion in the gross income of United States shareholders of their distributive shares of the undistributed Supplement P net income of a foreign personal holding company) the tax may be assessed, or a proceed- ing in court for the collection of such'tax may be begun without assessment, at any time within seven ' years after the return was filed ." (b) Subsection (d) of such section 275, before its amendment by subsection (a) of this section, is amended to read as follows : "(e) For the purpo ses of subsec tions (a), (b), (c), and (d), a return filed before the last day prescribed by law for the filing thereof shall be considered as filed on such last day ." (c) Subsection (e) of such section 275, before its amendment by subsections (a) and (b) of this section, is amended by striking out "(e)" and inserting in lieu thereof "(f)". SEC. 207 . MINOR AMENDMENTS TO TITLE I OF 1936 ACT . (a) Section 4 of the Revenue Act of 1936 is amended by adding at the end thereof a new subsection to read as follows "( i) Foreig n personal ho lding compani es and their shareholders - Supplem ent P ." (b) Sectio n 22 of such Act is amended b y adding at the end thereof a new subsection to read as f ollows "(g) FOREIGN PERSONAL HOLDING COMPANIES .-For provisions relat- ing to gross income of foreign personal holding companies and of their shareholders, see section 334 ." (c) Sectio n 54 of such Act is amended b y adding at the end thereof a new subsection to read as follows : " (e) FOREIGN PERSONAL HOLDING COMPANIES .-For information retu rns by o ffic ers, dir ecto rs, and larg e sh areh olde rs, with res pect to foreign personal holding companies, see sections 338, 339, and 341 . For information returns by attorneys, accountants, and so forth, as to formation, and so forth, of foreign corporations, see sections 340 and 341 ." (d) Such Act i s amended by adding after sec tion 150 a new section to read as follows "SEC. 151 . FOREIGN PERSONAL HOLD ING C OMPA NIES . "For information returns by officers, directors, and large share- holders, with respect to foreign personal holding companies, see sec- tions 338, 339, and 341 . For information returns by attorneys, accountants, and so forth, as to formation, and so forth, of foreign car orations, see sections 340 and 341 ." (e) Section 145 of such Act is amended by adding at the end thereof a new subsection to read as follows "(d) For penalties for failure to file information returns with respect to foreign personal holding companies and foreign corpora- tions, see section 341 ."
