Page:United States Statutes at Large Volume 102 Part 4.djvu/589

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PUBLIC LAW 100-647—NOV. 10, 1988

102 STAT. 3559

of section 146(f)(2)(A) of the 1986 Code shall be treated as met if such project is identified with reasonable specificity. The preceding sentence shall not apply so as to permit a carryforward with respect to any qualified small issue bond." (i) APPLICATION TO 501 (c)(3) BONDS.—In accordance with section 26 USC 501 note. 1302 of the Reform Act, each amendment and other provision of this Act which applies to private activity bonds shall, unless otherwise expressly provided, apply to qualified 501(c)(3) bonds. SEC. 1014. AMENDMENTS RELATED TO TITLE XIV OF THE REFORM ACT. (a) AMENDMENTS RELATED TO SECTION 1401 OF THE REFORM ACT.—

(1) Subsection (e) of section 672 of the 1986 Code is amended to read as follows: "(e) GRANTOR TREATED AS HOLDING ANY POWER OR INTEREST OF GRANTOR'S SPOUSE.—

"(1) IN GENERAL.—For purposes of this subpart, a grantor shall be treated as holding any power or interest held by— "(A) any individual who was the spouse of the grantor at the time of the creation of such power or interest, or "(B) any individual who became the spouse of the grantor after the creation of such power or interest, but only with respect to periods after such individual became the spouse of the grantor. "(2) MARITAL STATUS.—For purposes of paragraph (I)(A), an individual legally separated from his spouse under a decree of divorce or of separate maintenance shall not be considered as married." (2) Paragraph (3) of section 675 of the 1986 (Dode is amended by adding at the end thereof the following new sentence: "For periods during which an individual is the spouse of the grantor (within the meaning of section 672(e)(2)), any reference in this paragraph to the grantor shall be treated as including a reference to such individual." (3) Subsection (c) of section 674 of the 1986 (Dode is amended by adding at the end thereof the following new sentence: "For periods during which an individual is the spouse of the grantor (within the meaning of section 672(e)(2)), any reference in this subsection to the grantor shall be treated as including a reference to such individual." (b) AMENDMENT RELATED TO SECTION 1402 OF THE REFORM ACT.—

Section 673 of the 1986 Code is amended by adding at the end thereof the following new subsections: "(c)

SPECIAL RULE FOR DETERMINING VALUE OF REVERSIONARY

INTEREST.—For purposes of subsection (a), the value of the grantor's reversionary interest shall be determined by assuming the maximum exercise of discretion in favor of the grantor. "(d) POSTPONEMENT OF DATE SPECIFIED FOR REACQUISITION.—Any

postponement of the date specified for the reacquisition of possession or enjoyment of the reversionary interest shall be treated as a new transfer in trust commencing with the date on which the postponement is effective and terminating with the date prescribed by the postponement. However, income for any period shall not be included in the income of the grantor by reason of the preceding sentence if such income would not be so includible in the absence of such postponement." (c) AMENDMENTS RELATED TO SECTION 1403 OF THE REFORM ACT.— 26 USC 645 note.

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