104
PUBLIC LAW 89-384-APR. 8, 1966
notice and demand from the Secretary or his delegate. I n applying section 6601(j) (relating to the application of the 4-percent rate of interest in the case of recoveries of foreign expropriation losses to which this section applies) in the case of a deficiency, the entire amount which is prorated to installments under this section shall be treated as an amount of tax the payment of which is extended under this section.
Infra.
"(f)
Ante,
[80 STAT.
p. 99.
Loss.—For purposes of this section, the tax attributable to a recovery of a foreign expropriation loss is the sum of— "(1) the additional tax imposed by section 1351(d)(1) on such recovery, and "(2) the amount by which the tax imposed under subtitle A is increased by reason of the gain on such recovery which under section 1351(e) is f^'^nsidered as gain on the involuntary conversion of property. " (g) FAILURE TO P A Y INSTALLMENT.—If any installment under this section is not paid on or before the date fixed for its payment by this section (including any extension of time for the payment of such installment), the unpaid portion of the tax payable in installments shall' be paid upon notice and demand from the Secretary or his delegate. "(h)
70 Stat. 1075.
TAX ATTRIBUTABLE TO RECOVERY or FOREIGN EXPROPRIATION
CROSS-REFERENCES.—
"(1) Interest.—For provisions requiring the payment of interest at the rate of 4 percent per annum for the period of an extension, see section 6601(j). "(2) Security.—For authority of the Secretary or his delegate to require security in the case of an extension under this section, see section 6165. "(3) Period of limitation.—For extension of the period of limitation in the case of an extension under this section, see section 6503(f)." (e) Section 6503 of the Internal Revenue Code of 1954 (relating to suspension of running of period of limitation) is amended by redesignating subsection (f) as (g), and by inserting after subsection (e) the following new subsection: "(f) EXTENSIONS OF T I M E FOR PAYMENT OF TAX ATTRIBUTABLE TO RECOVERIES OF FOREIGN EXPROPRIATION LOSSES.—The running of the
^"P'°-
period of limitations for collection of the tax attributable to a recovery of a foreign expropriation loss (within the meaning of section 6167 (f)) shall be suspended for the period of any extension of time for payment under subsection (a) or (b) of section 6167." (f) Section 6601 of the Internal Revenue Code of 1954 (relating to interest on underpayments) is amended by redesignating subsection (j) as (k), and by inserting after subsection (i) the following new subsection: "(j) EXTONSIONS OF T I M E FOR PAYMENT or TAX ATTRIBUTABLE TO RECOVERIES OF FOREIGN EXPROPRIATION IJOSSES.—If the time for pay-
ment of an amount of the tax attributable to a recovery of a foreign expropriation loss (within the meaning of section 6167(f)) is extended as provided in subsection (a) or (b) of section 6167, interest shall be paid at the rate of 4 percent, in lieu of 6 percent as provided in subsection (a). " (g)(1) The table of parts for subchapter Q of chapter 1 of the Internal Revenue Code of 1954 is amended by adding at the end thereof the following: "Part VII. Recoveries of foreign expropriation losses."
(2) The table of sections for subchapter B of chapter 62 of such Code is amended by adding at the end thereof the following: "See. 6167. Extension of time for payment of tax attributable to recovery of foreign expropriation losses."
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