90 STAT. 1616
PUBLIC LAW 94-455—OCT. 4, 1976 (a)(6) (relating to distributable net income in case of foreign trusts) is amended by striking out "foreign t r u s t created by a United States person" and inserting in lieu thereof "foreign trust". (2) TRAXSITIOXAL RULE FOR FOREIGN TRUSTS.—Section 643(a)
26 USC 643.
(6) is amended by adding a t the end thereof the following new subparagraph: " (D) Effective for distributions made in taxable years beginning after December 31, 1975, the undistributed n e t income of each foreign t r u s t for each taxable year beginning on or before December 31, 1975, remaining undistributed a t the close of the last taxable year beginning on or before December 31, 1975, shall be redetermined by taking into account the deduction allowed by section 1202." (d) RETURNS FOR FOREIGN TRUSTS HAVING O N E OR MORE UNITED STATES BENEFICIARIES.—
26 USC 6048.
(1) Section 6048 (relating to returns as to creation of or transfers to certain foreign trusts) is amended by redesignating subsection (c) as subsection (d) and by inserting after subsection (b) the following new subsection: " (c) A N N U A L RETURNS FOR FOREIGN TRUSTS H A VI N G O N E OR MORE UNITED STATES B E N E F I C I A R I E S. — E a c h tax p a y e r subject to tax under
26 USC 6677.
section 679 (relating to foreign trusts h a v i n g one or more United States beneficiaries) for his taxable year with respect to any trust shall make a return with respect to such trust for such year at such time and in such manner, and setting forth such information, as the Secretary may by regulations prescribe.". (2) Section 6677(a) (relating to failure to file information returns with respect to certain foreign trusts) is amended by striking out "to a t r u s t " and inserting in lieu thereof " to a trust (or, in the case of a failure with respect to section 6048(c), equal to 5 percent of the value of the corpus of the trust at the close of the taxable year) ". (e) CONFORMING AMENDMENTS. —
I 26 USC 643. 26 USC 6048.
(1) The table of sections for subpart. E of part I of subchapter J of chapter 1 is amended by adding at the end thereof the following new item: "Sec. 679. Foreign trusts having one or more United States beneficiaries." (2) Subsection (d) of section 643 is hereby repealed. (3) Subsection (d) of section 6048 (as redesignated by subsection (d)) is amended to read as follows: "(d)
26 USC 6041.
"For provisions relating to penalties for violation of this section, see sections 6677 and 7203." (4) The heading of section 6048 is amended to read as follows: "SEC. 6048. RETURNS AS TO CERTAIN FOREIGN TRUSTS.". (5) The table of sections for subpart B of part III of subchapter A of chapter 61 is amended by striking out the item relating to section 6048 and inserting in lieu thereof the following: "Sec. 6048. Returns as to certain foreign trusts." (f)
26 USC 679 ^°^-
CROSS R E F E R E N C E. —
EFFECTIVE D A T E S. —
(1) IN GENERAL.—The amendments made by this section (other than subsection (c)) shall apply to taxable years ending after December 31, 1975, b u t only in the case of—
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