96 STAT. 670 26 USC 6046A.
PUBLIC LAW 97-248—SEPT. 3, 1982 "SEC. 6046A. RETURNS AS TO INTERESTS IN FOREIGN PARTNERSHIPS.
"(a) REQUIREMENT OF RETURN.—Any United States person, except to the extent otherwise provided by regulations— "(1) who acquires any interest in a foreign partnership, "(2) who disposes of any portion of his interest in a foreign partnership, or "(3) whose proportional interest in a foreign partnership changes substantially, shall file a return. "(b) FORM AND CONTENTS OF RETURN.—Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe. "(c) TIME FOR FILING RETURN.—Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return. "(d) CROSS REFERENCE.— "For provisions relating to penalties for violations of this section, see sections 6679 and 7203." (b) PENALTY.—
26 USC 6679.
Subsection (a) of section 6679 (relating to failure to file returns as to organization or reorganization of foreign corporations and acquisitions of their stock) is amended by striking out "section 6046" and inserting in lieu thereof "section 6046 or 6046A". (c) CLERICAL AMENDMENTS.—
(1) The table of sections for subpart B of part III of subchapter A of chapter 61 is amended by inserting after the item relating to section 6046 the following new item: "Sec. 6046A. Returns as to interests in foreign partnerships."
(2) The section heading of section 6679 is amended to read as follows: "SEC. 6679. FAILURE TO FILE RETURNS WITH RESPECT TO FOREIGN CORPORATIONS OR FOREIGN PARTNERSHIPS."
(3) The table of sections for subchapter B of chapter 68 is amended by striking out the item relating to section 6679 and inserting in lieu thereof the following: "Sec. 6679. Failure to file returns with respect to foreign corporations or foreign partnerships." 26 USC 6231 note.
SEC. 406. SPECIAL RULE FOR CERTAIN INTERNATIONAL SATELLITE PARTNERSHIPS.
Subchapter C of chapter 63 of the Internal Revenue Code of 1954 (relating to tax treatment of partnership items), section 6031 of such Code (relating to returns of partnership income), and section 6046A of such Code (relating to returns as to interest in foreign partnerships) shall not apply to the International Telecommunications Satellite Organization, the International Maritime Satellite Organization, and any organization which is a successor of either of such organizations. 26 USC 6221
SEC. 407. EFFECTIVE DATES.
(a)(1) Except as provided in paragraph (2), the amendments made by sections 402, 403, and 404 shall apply to partnership taxable years beginning after the date of the enactment of this Act.
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