Page:United States Statutes at Large Volume 100 Part 3.djvu/990

 100 STAT. 2798

PUBLIC LAW 99-514—OCT. 22, 1986, vf ' "(ii) Subparagraph (A)(i)(II) shall not apply to any %. sale or exchange pursuant to a written contract which ft'. was binding on June 8, 1984, and at all times thereafter before the sale or exchange." (4) CLERICAL AMENDMENT.—Clause (ii) of section 44(b)(6)(B) of the Tax Reform Act of 1984 (as added by section 2 of Public Law 98-612) is amended by striking out "greater than" and inserting , in lieu thereof "not greater than". (5) CLARIFICATION OF EFFECTIVE DATE FOR REPEAL OF CAPITAL

,, ASSET REQUIREMENT.—Subsection (g) of section 44 of the Tax

Reform Act of 1984 is amended by striking out "before December 31, 1984" and inserting in lieu thereof "on or before December 31, 1984". SEC. 1804. AMENDMENTS RELATED TO CORPORATE PROVISIONS. (a) AMENDMENT RELATED TO SECTION 51 OF THE ACT.—Subsection

(a) of section 246A (relating to dividends received deduction reduced where portfolio stock is debt financed) is amended— (1) by striking out "or 245" and inserting in lieu thereof "or 245(a)", and (2) by adding at the end thereof the following new sentence: "The preceding sentence shall be applied before any determination of a ratio under paragraph (1) or (2) of section 245(a)." (b) AMENDMENTS RELATED TO SECTION 53 AND SECTION 54 OF THE ACT.— (1) AMENDMENTS TO SECTION 246.—

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(A) Subparagraph (A) of section 246(c)(1) (relating to exclusion of certain dividends) is amended to read as follows: "(A) Which is held by the taxpayer for 45 days or less, or". (B) Paragraph (4) of section 246(c) (relating to holding period reduced for periods where risk of loss diminished) is amended by striking out "determined under paragraph (3)" and inserting in lieu thereof "determined for purposes of this subsection". (C) The amendments made by this paragraph shall apply to stock acquired after March 1, 1986. (2) EFFECTIVE DATE FOR RELATED PERSON PROVISIONS.—Para-

graph (3) of section 53(e) of the TEIX Reform Act of 1984 (relating to effective date for related person provisions) is amended to read as follows: ^r "(3) RELATED PERSON PROVISIONS.—

"(A) IN GENERAL.—Except as otherwise provided in ,. subparagraph (B), the amendment made by subsection (c) ^ shall take effect on July 18, 1984. f (B) SPECIAL RULE FOR PURPOSES OF SECTION 265(2).—The amendment made by subsection (c) insofar as it relates to, section 265(2) of the Internal Revenue Code of 1954 shall ^^ apply to— "(i) term loans made after July 18, 1984, and "(ii) demand loans outstanding after July 18, 1984 sise Y (other than any loan outstanding on July 18, 1984, and gj ' repaid before September 18, 1984). J "(C) TREATMENT OF RENEGOTIATIONS, ETC.—For purposes of this paragraph, any loan renegotiated, extended, or re-

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