Page:United States Statutes at Large Volume 102 Part 4.djvu/564

 102 STAT. 3534

PUBLIC LAW 100-647—NOV. 10, 1988 "(2) RELATED PERSON DIVIDEND OR INTEREST.—For purposes of

26 USC 551 note..

paragraph (1), the term 'related person dividend or interest' means any dividend or interest which— "(A) is described in subparagraph (A) of section 954(c)(3), and "(B) is received from a related person which is not a foreign personal holding company (determined without regard to this subsection). For purposes of the preceding sentence, the term 'related person' has the meaning given such term by section 954(d)(3) (determined by substituting 'foreign personal holding company' for 'controlled foreign corporation each place it appears)." (D) The amendments made by this paragraph shall apply to taxable years of foreign corporations beginning after December 31, 1986. (2) TREATMENT OF CERTAIN STATES.

PAYMENTS OUTSIDE THE UNITED

(A) Subparagraph (A) of section 3405(d)(13) of the 1986 Code is amended by striking out "the United States" and inserting in lieu thereof "the United States and any possession of the United States". (B) Clause (i) of section 3405(d)(13XB) of the 1986 Code is amended to read as follows: "(i) a United States citizen or a resident alien of the United States, or". (C) The heading of paragraph (13) of section 3405(d) of the 1986 Code is amended by striking out "UNITED STATES" and inserting in lieu thereof "UNITED STATES OR ITS POSSESSIONS".

26 USC 3405 note.

(D) The amendments made by this paragraph shall apply to distributions made after the date of the enactment of this Act. (3) CLARIFICATION MENTS.—

Effective date. 26 USC 6103 note.

OF DISCLOSURE UNDER

CERTAIN

AGREE-

(A) Paragraph (4) of section 6103(k) of the 1986 Code is amended— (i) by striking out "or other convention" and inserting in lieu thereof "or other convention or bilateral agreement", and (ii) by striking out "such convention" and inserting in lieu thereof "such convention or bilateral agreement". (B) Subparagraph (A) of section 6103(b)(5) of the 1986 Code is amended by striking out "the Commonwealth of the Northern Mariana Islands, the Republic of the Marshall Islands, the Federated States of Micronesia, and the Republic of Palau" and inserting in lieu thereof "and the Commonwealth of the Northern Mariana Islands". (C) The amendments made by this paragraph shall take effect on the date of the enactment of the Tax Reform Act of 1986. (4) COORDINATION OF TREATIES WITH SECTION 904 (g).—

(A) Subsection (g) of section 904 of the 1986 Code is amended by redesignating paragraph (10) as paragraph (11) and by inserting after paragraph (9) the following new paragraph: "(10) COORDINATION WITH TREATIES.—

�