Page:United States Statutes at Large Volume 100 Part 3.djvu/740

 100 STAT. 2548

PUBLIC LAW 99-514—OCT. 22, 1986

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(iii) which is a member of an affiliated group the average daily United States production of oil of which is less than 50,000 barrels and the average daily United States refining of which is less than 150,000 barrels. (4) SPECIAL RULES FOR SUBSIDIARY.—The amendments made by this section shall not apply to interest on up to the applicable dollar amount of indebtedness of a subsidiary incorporated on February 11, 1975, the indebtedness of which on May 6, 1986, included— (A) $100,000,000 face amount of 11% percent notes due in 1990, (B) $100,000,000 of 8% percent notes due in 1989, (C) 6% percent Japanese yen notes due in 1991, and (D) 5% percent Swiss franc bonds due in 1994. For purposes of this paragraph, the term "applicable dollar amount" means $600,000,000 in the case of taxable years beginning in 1987 through 1991, $500,000,000 in the case of the taxable year beginning in 1992, $400,000,000 in the case of the taxable year beginning in 1993, $300,000,000 in the case of the taxable year beginning in 1994, $200,000,000 in the case of the taxable year beginning in 1995, $100,000,000 in the case of the taxable year beginning in 1996, and zero in the case of taxable years beginning after 1996. (5) SPECIAL RULE FOR FINANCIAL CORPORATION.—For purposes of section 864(e)(5) of the Internal Revenue Code of 1986 (as added by this section), a corporation shall be treated as described in subparagraph (C) of such section for any taxable year if— (A) such corporation is a Delaware corporation incorporated on August 20, 1959, and (B) such corporation was primarily engaged in the financing of dealer inventory or consumer purchases on May 29, 1985, and at all times thereafter before the close of the taxable year.

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(6) S P E C I A L RULES FOR A L L O C A T I N G GENERAL A N D A D M I N I S T R A -

T IV E EXPENSES.—

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(A) IN GENERAL.—In the case of an affiliated group of domestic corporations the common parent of which has its principal office in New Brunswick, New Jersey, and has a certificate of organization which was filed with the Secretary of the State of New Jersey on November 10, 1887, the amendments made by this section shall not apply to the phase-in percentage of general and administrative expenses paid or incurred in its 1st 3 taxable years beginning after December 31, 1986. (B) PHASE-IN PERCENTAGE.—For purposes of subparagraph (A):

In the case of taxable f, years beginning in: ' * 1987 1988 1989

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The phase-in percentage is: 75 50 25.

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