78 STAT. ]
PUBLIC LAW 88-272-FEB. 26, 1964
47
of the distributor or transferor corporation beginning on or before the date of distribution or transfer shall be treated as a prior taxable year with reference to the acquiring corporation's taxable years beginning after such date." (e) FUTURE INTERESTS I N TANGIBLE PERSONAL PROPERTY.—Sec-
tion 170 (relating to charitable, etc., contributions and gifts) is ^J^^ ^*r*43!°^^' amended by redesignating subsections (f) and (g) as subsections (h) 26 USC no. and (i), respectively, and by inserting after subsection (e) the following new subsection: "(f)
FUTURE INTERESTS I N TANGIBLE PER«K)NAL PROPERTY,—For
purposes of this section, payment of a charitable contribution which consists of a future interest in tangible personal property shall be treated as made only when all intervening interests in, and rights to the actual possession or enjoyment of, the property have expired or are held by persons other than the taxpayer or those standing in a relationship to the taxpayer described in section 267(b). For pur- 26 USC 267. poses of the preceding sentence, a fixture which is intended to be severed from the real property shall be treated as tangible personal property." (f) EFFECTIVE DATES.—
(1) The amendments made by subsections (a), (b), and (c), shall apply with respect to contributions which are paid' in taxable years beginning after December 31, 1963. (2) The amendments made by subsection (d) shall apply to taxable years beginning after December 31, 1963, with respect to contributions which are paid (or treated as paid under section 170(a)(2) of the Internal Revenue Code of 1954) in taxable years beginning after December 31, 1961. (3) The amendments made by subsection (e) shall apply to transfers of future interests made after December 31, 1963, in taxable years ending after such date, except that such amendments shall not apply to any transfer of a future interest made before July 1, 1964, where— (A) the sole intervenuig interest or right is a nontransferable life interest reserved by the donor, or (B) in the case of a joint gift by husband and wife, the sole intervening interest or right is a nontransferable life interest, reserved by the donors which expires not later than the death of whichever of such donors dies later. For purposes of the exception contained in the preceding sentence, a right to make a transfer of the reserved life interest to the donee of the future interest shall not be treated as making a life interest transferable. SEC. 210. LOSSES ARISING FROM EXPROPRIATION OF PROPERTY BY GOVERNMENTS OF FOREIGN COUNTRIES. (a) N E T OPERATING LOSS CARRYOVER.—Section 172 (relating to
26 USC f?^
net operating loss deduction) is amended— (1) by striking out "Except as provided in clause ( i i) " in subsection (b)(l)(A)(i) and inserting in lieu thereof "Except as provided in clause (ii) and in subparagraph (D) "
(3) by adding at the end of subsection (b)(1) the followhig new subparagraph: " (D) I n the case of a taxpayer which has a foreign expropriation loss (as defined in subsection (k)) for any taxable ^°^*' P' '*^year ending after December 31, 1958, the portion of the net operating loss for such year attributable to such foreign ex-
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