Page:United States Statutes at Large Volume 101 Part 2.djvu/1187

 PUBLIC LAW 100-203—DEC. 22, 1987 ^...,. j..,.

(B) S P E C I A L RULES FOR OBLIGATIONS ARISING FROM DEALER DISPOSITIONS AFTER FEBRUARY 28, 1986, AND BEFORE JANUARY 1, 1988.—

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101 STAT. 1330-393

(i) IN GENERAL.—In the case of an applicable installment obligation arising from a disposition described in subclause (I) or (II) of section 453C(e)(l)(A)(i) of the Internal Revenue Code of 1986 (as in effect before the amendments made by this section) before January 1, 1988, the amendments made by subsections (a) and (b) shall apply to taxable years beginning after December 31, 1987. ^'' (ii) CHANGE IN METHOD OF ACCOUNTING.—In the case of any taxpayer who is required by clause (i) to change its method of accounting for any taxable year with respect to obligations described in clause (i)— (I) such change shall be treated as initiated by the taxpayer, (II) such change shall be treated as made with the consent of the Secretary of the Treasury or his delegate, and (III) the net amount of adjustments required by section 481 of the Internal Revenue Code of 1986 shall be taken into account over a period not longer than 4 taxable years.

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(3) SPECIAL RULE FOR NONDEALERS.—

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(A) ELECTION.—A taxpayer may elect, at such time and in such manner as the Secretary of the Treasury or his delegate may prescribe, to have the amendments made by subsections (a) and (c) apply to taxable years ending after December 31, 1986, with respect to dispositions and pledges occurring after August 16, 1986. (B) PLEDGING RULES.—Except as provided in subpara-

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graph (A)— (i) IN GENERAL.—Section 453A(d) of the Internal Revenue Code of 1986 shall apply to any installment obligation which is pledged to secure any secured ''••• indebtedness (within the meaning of section 453A(d)(4) of such Code) after December 17, 1987, in taxable years ending after such date. (ii) COORDINATION WITH SECTION 453C.—For purposes

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of section 453C of such Code (as in effect before its repeal), the face amount of any obligation to which section 453A(d) of such Code applies shall be reduced by the amount treated as payments on such obligation j^ under section 453A(d) of such Code and the amount of 9X. • Y" " any indebtedness secured by it shall not be taken into ^ account. " (4) MINIMUM TAX.—The amendment made by subsection (d) shall apply to dispositions in taxable years beginning after December 31, 1986. (5) COORDINATION WITH TAX REFORM ACT OF 1986.—The amend-

ments made by this section shall not apply to any installment obligation or to any taxpayer during any period to the extent the amendments made by section 811 of the Tax Reform Act of 1986 do not apply to such obligation or during such period.

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