PUBLIC LAW 97-248—SEPT. 3, 1982
96 STAT. 539
"(II) a stock life insurance company, 85 percent of the base amount. "(3) REDUCTION I N $1,000,000 AMOUNT FOR LARGE INSURERS.—If
the sum of the deductions under paragraphs (3), (5), and (6) of subsection (d) exceeds $4,000,000, then each of the $1,000,000 amounts in paragraphs (1) and (2) shall be reduced (but not below zero) by the amount which bears the same ratio to $1,000,000 as— "(A) the amount of such excess bears to, "(B) $4,000,000. "(4) BASE AMOUNT.—For purposes of paragraph (2)(B), the term 'base amount' means the excess of— "(A) the amount of the deductions under paragraphs (3) and (5) of subsection (d) for the taxable year, over "(B) the amount determined under paragraph (2)(A) for such taxable year. "(5) APPLICATION OF LIMITATION.—The limitation provided by paragraph (1) shall apply first to the amount of the deduction under subsection (d)(3), then to the amount of the deduction under subsection (d)(5), and finally to the amount of the deduction under subsection (d)(6)." (b) $1,000,000 LIMITATION TO BE APPORTIONED AMONG MEMBERS OF SAME CONTROLLED GROUP.—Section 1561(a) (relating to limitations
26 USC 1561.
on certain multiple tax benefits in the case of certain controlled corporations) is amended— (1) by striking out "and" at the end of paragraph (2), (2) by striking out the period at the end of paragraph (3) and inserting in lieu thereof a comma and "and", (3) by inserting after paragraph (3) the following new paragraph: "(4) one $1,000,000 amount (adjusted as provided in section 809(f)(3)) for purposes of computing the limitation under para- -^ra^^. P- 538. graph (1) or (2) of section 809(f).", and (4) by striking out "(2) and (3)" and inserting in lieu thereof "(2), (3), and (4)". (c) CONFORMING AMENDMENTS.—Section 1561(b) (relating to certain short taxable years) is amended— (1) by striking out "and" at the end of paragraph (2), (2) by striking out the comma at the end of paragraph (3) and inserting in lieu thereof a comma and "and", (3) by inserting after paragraph (3) the following new paragraph: "(4) the amount (adjusted as provided in section 809(f)(3)) to be used in computing the limitation under paragraph (1) or (2) of section 809(f),", and (4) by striking out "(2), or (3)" and inserting in lieu thereof "(2), (3), or (4)". SEC. 260. COMPUTATION OF AMOUNT OF LIFE INSURANCE RESERVES. (a) RESERVES ON CONTRACTS ON WHICH CERTAIN INTEREST Is GUAR-
ANTEED BEYOND THE END OF THE TAXABLE YEAR.—Section 818 (relat-
ing to accounting provisions), as amended by section 258(a), is amended by adding at the end thereof the following new subsection: "(h) METHOD OF COMPUTING RESERVES ON CONTRACT WHERE INTEREST Is GUARANTEED BEYOND END OF TAXABLE YEAR.—For purposes
of this part (other than section 801), interest payable under any contract which is computed at a rate which—
Ante, p. 538.
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