Page:United States Statutes at Large Volume 102 Part 4.djvu/591

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PUBLIC LAW 100-647—NOV. 10, 1988

102 STAT. 3561

date 1 month before the due date for the installment' for 'ending before the due date for the installment'." (3) Subsection (g) of section 643 of the 1986 Code is amended— (A) by striking out the last sentence of paragraph (1), and (B) by amending paragraph (2) to read as follows: "(2) TIME FOR MAKING ELECTION.—An election under paragraph (1) shall be made on or before the 65th day after the close of the taxable year of the trust and in such manner as the Secretary may prescribe." (4) Subsection (g) of section 643 of the 1986 Code is amended by adding at the end thereof the following new paragraph: "(3) EXTENSION TO LAST YEAR OF ESTATE.—In the case of a taxable year reasonably expected to be the last taxable year of an estate— "(A) any reference in this subsection to a trust shall be treated as including a reference to an estate, and "(B) the fiduciary of the estate shall be treated as the trustee." (e) AMENDMENTS RELATED TO SECTION 1411 OF THE REFORM ACT.—

(1) Paragraph (3) of section l(i) of the 1986 Code is amended by adding at the end thereof the following new subparagraph: "(C) COORDINATION WITH SECTION 644.—If tax is imposed

under section 644(a)(l) with respect to the sale or exchange of any property of which the parent was the transferor, for purposes of applying subparagraph (A) to the taxable year of the parent in which such sale or exchange occurs— "(i) taxable income of the parent shall be increased by the amount treated as included in gross income under section 644(a)(2)(A)(i), and "(ii) the amount described in subparagraph (A)(ii) shall be increased by the amount of the excess referred to in section 644(a)(2)(A)." (2) The last sentence of subparagraph (A) of section l(i)(3) of the 1986 Code is amended by striking out "any deduction or credit" and inserting in lieu thereof "any exclusion, deduction, or credit". (3) Subparagraph (A) of section l(i)(4) of the 1986 Code is amended— (A) by striking out "gross income for the taxable year which is not earned income" in clause (i) and inserting in lieu thereof "adjusted gross income for the taxable year which is not attributable to earned income", (B) by striking out "his deduction" in clause (iiXH) and inserting in lieu thereof "his deductions", (C) by striking out "the deductions allowed" in clause (ii)(II) and inserting in lieu thereof "the itemized deductions allowed", and (D) by striking out "gross income" in clause (iiXII) and inserting in lieu thereof "adjusted gross income". (4) Clause (iv) of section 6103(e)(l)(A) of the 1986 Code is amended by striking out "section l(j)" and inserting in lieu thereof "section l(i) or 590')". (5)(A) Section 59 of the 1986 Code is amended by adding at the end thereof the following new subsection: "(j) TREATMENT OF UNEARNED INCOME OF MINOR CHILDREN.—

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