98 STAT. 652
Ante, p. 648.
PUBLIC LAW 98-369—JULY 18, 1984
income from sources without the United States were such interest received by the decedent at the time of his death, "(2) deposits with a foreign branch of a domestic corporation or domestic partnership, if such branch is engaged in the commercial banking business, and "(3) debt obligations, if, without regard to whether a statement meeting the requirements of section 871(h)(4) has been received, any interest thereon would be eligible for the exemption from tax under section 871(h)(1) were such interest received by the decedent at the time of his death, shall not be deemed property within the United States.". (e) WITHHOLDING.—
26 USC 1441.
(1) NONRESIDENT ALIENS.—Subsection (c) of section 1441 (relating to withholding of tax on nonresident aliens) is amended by adding at the end thereof the following new paragraph: "(9) INTEREST INCOME FROM CERTAIN PORTFOLIO DEBT INVEST-
Ante, p. 648.
26 USC 1442.
26 USC 163.
26 USC 871 note.
MENTS.—In the case of portfolio interest (within the meaning of 871(h)(2)), no tax shall be required to be deducted and withheld from such interest unless the person required to deduct and withhold tax from such interest knows, or has reason to know, that such interest is not portfolio interest by reason of section 871(h)(3).". (2) FOREIGN CORPORATIONS.—The last sentence of section 1442(a) is amended— (A) by striking out "and" after "section 881(a)(4)," and (B) by inserting before the period at the end thereof the following: ", and the references in section 1449(c)(9) to sections 871(h)(2) and 871(h)(3) shall be treated as referring to sections 881(c)(2) and 881(c)(3)". (f) REGISTERED OBLIGATIONS.—Subparagraph (C)(i) of section 163(f)(2) (relating to authority to include other obligations) is amended to read as follows: "(i) in the case of— "(I) subparagraph (A), such obligation is of a type which the Secretary has determined by regulations to be used frequently in avoiding Federal taxes, or "(II) subparagraph (B), such obligation is of a type specified by the Secretary in regulations, and". (g) EFFECTIVE D A T E S. —
(1) IN GENERAL.—Except as otherwise provided in this subsection, the amendments made by this section shall apply to interest received after the date of the enactment of this Act with respect to obligations issued after such date, in taxable years ending after such date. (2) SUBSECTION (d).—The amendment made by subsection (d) shall apply to obligations issued after the date of the enactment of this Act with respect to the estates of decedents dying after such date. (3) SPECIAL RULE FOR CERTAIN UNITED STATES AFFILIATE OBLIGATIONS.—
26 USC 1 et seq.
(A) IN GENERAL.—For purposes of the Internal Revenue Code of 1954, payments of interest on a United States affiliate obligation to an applicable CFC in existence on or before June 22, 1984, shall be treated as payments to a resident of the country in which the applicable CFC is incorporated. „, -: - s.*:«5,;.:.>-ij ^t--* DIJ-OV;' i!i.-:i«nT
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