506
PUBLIC LAW 183—OCT. 20, 1951
[65 STAT.
shall be the excess, if any, of the amount of such net operating loss over the sum of the net income for each of the intervening years computed— "(i) with the exceptions, additions, and limitations provided in subsection (d)(1), (2), (4), and (6), and "(ii) by determining the net operating loss deduction • for each intervening taxable year without regard to such net operating loss or to the net operating loss for any succeeding taxable year and without regard to any §u"s (3^§ 122 (c) reduction specified in subsection (c). For the purpose of the preceding sentence, the net operating loss for any taxable year beginning after December 31, 1946, shall be reauced by the sum of the net income for each of the two preceding taxable years computed— "(iii) with the exceptions, additions, and limitations provided in subsection (d)(1), (2), (4), and (6), and " (iv) by determining the net operating loss deduction without regard to such net operating loss or to the net operating loss for the succeeding taxable year, and without regard to any reduction specified in subsection (c). " (c) EFFECTIVE DATE.—The amendments made by this section shall be applicable in computing the net operating loss deduction for taxable years beginning after December 31, 1948. SEC. 331. STOCK OPTIONS. 26^u**s^'. § 1 0 3A (a-) OPTION SUBJECT TO STOCKHOLDER APPROVAL.—Section 130A (d) (d). (relating to definition of restricted stock option) is hereby amended by striking out "As used in" and inserting "For the purposes of" and by adding at the end thereof the following: "(5) STOCKHOLDER APPROVAL.—If the grant of an option is subject to approval by stockholders, the date of grant of the option shall be determined as if the option had not been subject to such approval." (b) EFFECTIVE DATE.—rThe amendment made by subsection (a) shall be effective as if it had been enacted as part of section 218 of the l e W c. 5 1 0 Revenue Act of 1950. 3A and note. ^ ^ ^ ^^^ CREDIT FOR TAXES OF FOREIGN CORPORATIONS. (a)
56 sta|. 857. ^^ (1).
FOREIGN SUBSIDIARY OF A DOMESTICORPORATION.—Effective
with respect to dividends received by a domestic corporation from a foreign corporation during taxable years beginning after December 31, 1950, the first sentence of section 131(f)(1) is hereby amended by striking out "a majority" and inserting in lieu thereof "at least 10 per centum. (b) FOREIGN SUBSIDIARY OF A FOREIGN CORPORATION.—Effective with respect to dividends received by a foreign corporation from another foreign corporation in taxable years beginning after December 31, 1950, section 131(f)(2) is hereby amended by striking out "all the voting stock (except qualifying shares)" and inserting in lieu thereof "50 per centum or more of the voting stock". (c) CLERICAL AMENDMENT.—So much of section 131(f)(1) as precedes the first sentence thereof is hereby amended to read as follows: "(f)
TAXES OF FOREIGN CORPORATION.— " (1) TREATMENT OF TAXES PAID BY FOREIGN CORPORATION.—".
SEC. 333. INFORMATION AT SOURCE ON PAYMENTS OF INTEREST. Section 147(a) is hereby amended by striking out "interest," in the 26 u*s c! 1147. first sentence. Section 147(b) is hereby amended to read as follows: «(b) RETURNS REGARDLESS OF AMOUNT OF PAYMENT.—Such returns
may be required, regardless of amounts, (1) in the case of payments of
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