Page:United States Statutes at Large Volume 100 Part 3.djvu/705

 PUBLIC LAW 99-514—OCT. 22, 1986

100 STAT. 2513

(c) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years beginning after December 31, 1986.

Subtitle C—Changes Relating to Employee Stock Ownership Plans SEC. 1171. REPEAL OF EMPLOYEE STOCK OWNERSHIP CREDIT. (a) IN GENERAL.—Section 41 (relating to employee stock ownership credit) is hereby repealed. (b) TECHNICAL AND CONFORMING AMENDMENTS.—

(1) Subsection (b) of section 38 is amended by striking out paragraph (4), by striking out ", plus" at the end of paragraph (3) and inserting in lieu thereof a period, and by inserting "plus" at the end of paragraph (2). (2) Subsection (d) of section 38 is amended— (A) by striking out "196(a), and 404(i)" and inserting in lieu thereof "and 196(a)", and (B) by striking out "41(a),". (3) Subsection (c) of section 56 is amended by striking out the last sentence. (4) Subparagraph (B) of section 108(b)(2) is amended by striking out the last sentence. (5) Paragraph (21) of section 401(a) is hereby repealed. (6) Subsection (i) of section 404 (relating to deductibility of unused portions of employee stock ownership credit) is hereby repealed. (7)(A) Section 6699 (relating to assessable penalties relating to tax credit employee stock ownership plan) is hereby repealed. (B) The table of sections for subchapter B of chapter 68 is amended by striking out the item relating to section 6699. (c) EFFECTIVE DATE.—

(1) IN GENERAL.—Except as provided in paragraph (2), the amendments made by this section shall apply to compensation paid or accrued after December 31, 1986, in taxable years ending after such date. (2) SECTIONS 404(i) AND 6699 TO CONTINUE TO APPLY TO PRE-1987 CREDITS.—The provisions of sections 404(i) and 6699 of the Internal Revenue Code of 1986 shall continue to apply with respect to credits under section 41 of such Code attributable to compensation paid or accrued before January 1, 1987 (or under section 38 of such Code with respect to qualified investment before January 1, 1983). SEC. 1172. ESTATE TAX DEDUCTION FOR PROCEEDS FROM SALES OF EMPLOYER SECURITIES. (a) IN GENERAL.—Part IV of subchapter A of chapter 11 (relating to taxable estate) is amended by adding at the end thereof the following new section: "SEC. 2057. SALES OF EMPLOYER SECURITIES TO EMPLOYEE STOCK OWNERSHIP PLANS OR WORKER-OWNED COOPERATIVES. "(a) GENERAL RULE.—For purposes of the tax imposed by section

2001, the value of the taxable estate shall be determined by deduct-

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