Page:United States Statutes at Large Volume 102 Part 4.djvu/750

 102 STAT. 3720

PUBLIC LAW 100-647—NOV. 10, 1988 (3) TRANSITIONAL RULES.—

(A) The requirements of subclause (IV) of section 988(c)(l)(E)(iii) of the 1986 Code (as added by subsection (b)) shall not apply to periods before the date of the enactment of this Act. (B) In the case of any partner in an existing partnership, the 20-percent ownership requirements of subclause (I) of such section 988(c)(l)(E)(iii) shall be treated as met during any period during which such partner does not own a percentage interest in the capital or profits of such partnership greater than 33^3 percent (or, if lower, the lowest such percentage interest of such partner during any prior period after October 21, 1988, during which such partnership is in existence). For purposes of the preceding sentence, the term "existing partnership" means any partnership if— (i) such partnership was in existence on October 21, 1988, and principally engaged on such date in buying and selling options, futures, or forwards with respect to commodities, or (ii) a r^istration statement was filed with respect to such partnership with the Securities and Exchange Commission on or before such date and such r^istration statement indicated that the principal activity of such partnership will consist of buying and selling instruments referred to in clause (i). SEC 6131. TREATMENT OF INSURANCE COMPANIES UNDER CHAIN DEFICIT RULE.

26 USC 952 note.

(a) IN GENERAL.—Subparagraph (B) of section 952(c)(l) of the 1986 Code is amended by adding at the end thereof the following new clause: "(vii) SPECIAL RULES FOR INSURANCE INCOME.— "(1) IN GENERAL.—An election may be made under this clause to have section 953(a) applied for purposes of this title without r^ard to the same country exception under paragraph (I)(A) thereof. Such election, once made, may be revoked only with the consent of the Secretary. "(ID SPECIAL RULES FOR AFFILIATED GROUPS.—In the case of an affiliated group of corporations (within the meaning of section 1504 but without r^ard to section 1504(b)(3) and by substituting 'more than 50 percent' for 'at least 80 percent' each place it appears), no election may be made under subclause (1) for any controlled foreign corporation unless such election is made for all other controlled foreign corporations who are members of such group and who were created or organized under the laws of the same country as such controlled foreign corporation. For purposes of clause (v), in determining whether any controlled corporation described in the preceding sentence is a qualified insurance company, all such corporations shall be treated as 1 corporation." (b) EFFBCTIVE DATE.—The amendment made by this section shall take effect as if included in the amendments made by section 1221(f) of the Reform Act.

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