98 STAT. 526
PUBLIC LAW 98-369—JULY 18, 1984 ^itupH
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requires the foreign person or entity to be the lessee of such property. (D) CERTAIN AIRCRAFT.—The amendments made by this section shall not apply with respect to any wide-body, fourengine, commercial aircraft used by a foreign person or entity if— (i) on or before November 1, 1983, the foreign person or entity entered into a written binding contract to > acquire such aircraft, and (ii) such aircraft is placed in service before January 1, 1986. (E) U S E AFTER
1983.—Qualified
container
equipment
placed in service before January 1, 1984, which is used before such date by a foreign person shall not, for purposes of section 47 of the Internal Revenue Code of 1954, be treated as ceasing to be section 38 property by reason of the use of such equipment before January 1, 1985, by a foreign person or entity. For purposes of this subparagraph, the term "qualified container equipment" means any container, container chassis, or container trailer of a United States person with a present class life of not more than 6 years.
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(16) ORGANIZATIONS E L E C T I N G E X E M P T I O N F R O M RULES R E L A T -
I N G TO PREVIOUSLY TAX-EXEMPT ORGANIZATIONS MUST ELECT TAXATION OF EXEMPT ARBITRAGE PROFITS.—
Ante, p. 509.
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(A) IN GENERAL.—An organization may make the election under section 168(j)(4)(E)(ii) of the Internal Revenue Code of 1954 (relating to election not to have rules relating to previously tax-exempt organizations apply) only if such organization elects the tax treatment of exempt arbitrage profits described in subparagraph (B). (B) TAXATION OF EXEMPT ARBITRAGE PROFITS.—
(i) IN GENERAL.—In the case of an organization which elects the application of this subparagraph, there is hereby imposed a tax on the exempt arbitrage profits of such organization. (ii) RATE OF TAX, ETC.—The tax imposed by clause
(i)(I) shall be the amount of tax which would be imposed by section 11 of such Code if the exempt arbitrage profits were taxable income (and there were no other taxable income), and (II) shall be imposed for the first taxable year of the tax-exempt use period (as defined in section 168(j)(4)(E)(ii) of such Code). (C) EXEMPT ARBITRAGE PROFITS.—
Post, p. 922. '::
(i) IN GENERAL.—For purposes of this paragraph, the term exempt arbitrage profits means the aggregate amount described in clauses (i) and (ii) of subparagraph (D) of section 103(c)(6) of such Code for all taxable years for which the organization was exempt from tax under section 501(a) of such Code with respect to obligations— (I) associated with property described in section 168(j)(4)(E)(i)(I), and (II) issued before January 1, 1985. (ii) APPLICATION OF SECTION IO3 (B)(6).—For purposes
of this paragraph, section 103(b)(6) of such Code shall
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