89 STAT. 6 4 26 USC 954.
Ante, p. 61.
PUBLIC LAW 9 4 - 1 2 — M A R. 29, 1975 in section 9 5 4 (d)(3)) with respect to the corporation actually making or withdrawing the investment. " (3) SPECIAL RULE.—For purposes of this subpart, a United States shareholder of a controlled foreign corporation may, under regulations prescribed by the Secretary or his delegate, elect to make the determinations under subsection (a)(2) of this section and under subsection (g) of section 954 as of the close of the years following the years referred to in such subsections, or as of the close of such longer period of time as such regulations may permit, in lieu of on the last d a y of such years. Any election under this paragraph made with respect to any taxable year shall apply to such year and to all succeeding taxable years unless the Secretary or his delegate consents to the revocation of such election. " (4) A M O U N T ATTRIBUTABLE TO PROPERTY.—The a m o u n t t a k e n
into account under this subpart with respect to any property described in paragraph (1) shall be its adjusted basis, reduced by any liability to which such property is subject, " (5) INCOME EXCLUDED UNDER PRIOR LAW.—Amounts invested
26 USC 955.
Ante, p. 58.
in less developed country corporations described in section 955 (c)(2) (as in effect before the enactment of the T a x Reduction Act of 1975) shall be treated as qualified investments i n foreign base company shipping operations and shall not be treated as investments in less developed countries for purposes of section 951 (a)(1)(A) ( i i). " (B) The table of sections of subpart F of part III of subchapter N of chapter 1 is amended by inserting after the item relating to section 954 the following new item: "Sec. 955. Withdrawal of previously excluded subpart F income from qualified investment." (e) EXCLUSION F R O M FOREIGN B A S E COMPANY I N C O M E WHEREFOREIGN BASE COINIPANY I N C O M E I s L E S S T H A N 10 I'ERCENT o r GROSS
I N C O M E. — Paragraph (3) of section 954(b) is amended by striking out "30 percent" each place it appears and inserting in lieu thereof "10 percent". 26use955 note. (f) EFFECTIVE D A T E. — The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 1975, and to taxable years of United States shareholders (within the meaning of 951(b) of the I n t e r n a l Revenue Code of 1954) within which or with which such taxable years of such foreign corporations end.
26 USC 993.
26 USC 611.
50 USC app. 2402.
SEC. 603. DENIAL OF DISC BENEFITS WITH RESPECT TO ENERGY RESOURCES AND OTHER PRODUCTS. (a) AMENDMENT OF SECTION 993 (c)(2).—Section 993(c)(2) (relati n g to property excluded from export property) is amended by striking out " o r " a t the end of subparagraph (A), by striking out the period a t the end of subparagraph (B) and inserting i n lieu thereof ", or", and by a d d i n g a t the end thereof the following: " (C) products of a character with respect to which a deduction for depletion is allowable (including oil, g a s, coal, o r uranium products) under section 611, or " (D) products the export of which is prohibited o r curtailed under section 4(b) of the E x p o r t Administration Act of 1969 (50 U.S.C. A p p. 2403(b)) to effectuate the policy set forth i n paragraph (2)(A) of section 3 of such Act (relating to the protection of the dbmestic economy). Subparagraph (C) shall not apply to any commodity or product a t least 50 percent of the fair market value of which is attributable to manufacturing or processing, except that subparagraph (C) shall
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