Page:United States Statutes at Large Volume 102 Part 4.djvu/753

 PUBLIC LAW 100-647—NOV. 10, 1988

102 STAT. 3723

"(iv) SPECIFIED PROVISIONS.—The provisions specified in this clause are: "(I) Section 1248 (relating to gain from certain sales or exchanges of stock in certain foreign corporations). "(11) Subpart F of part III of subchapter N to the extent such subpart relates to earnings invested in United States property or amounts referred to in clause (ii) or (iii) of section 951(a)(l)(A). "(Ill) Section 884 to the extent the foreign corporation reinvested 1987 earnings and profits in United States assets. "(5) EFFECT OF TERMINATION.—For purposes of section 367,

if— "(A) an election is made by a corporation under paragraph (1) for any taxable year, and "(B) such election ceases to apply for any subsequent taxable year, such corporation shall be treated as a domestic corporation transferring (as of the 1st day of such subsequent taxable year) all of its property to a foreign corporation in connection with gin exchange to which section 354 applies. "(6) ADDITIONAL TAX ON CORPORATION MAKING ELECTION.—

"(A) IN GENERAL.—If a corporation makes an election under paragraph (1), the amount of tax imposed by this chapter for the 1st taxable year to which such election applies shall be increased by the amount determined under subparagraph (B). "(B) AMOUNT OF TAX.—The amount of tax determined under this paragraph shall be equal to the lesser of— "(i) % of 1 percent of the aggregate amount of capital and accumulated surplus of the corporation as of December 31, 1987, or "(ii) $1,500,000." (b) EFFECTIVE DATE.—The amendment made by subsection (a) 26 USC 953 note. shall apply to taxable years beginning after December 31, 1987. SEC. 6136. TAX EXEMPTION FOR ENJEBI COMMUNITY TRUST FUND.

48 USC 1681

(a) IN GENERAL.—Any earnings on, and distributions from, the "° ® Enjebi Community Trust Fund created under section 103 of the Compact of Free Association Act of 1985 shall be exempt from all Federal, State, or local taxation. (b) EFFECTIVE DATE.—The provisions of subsection (a) shall apply to all taxable years whether beginning before, on, or after the date of the enactment of this Act. SEC. 6137. APPLICATION OF SECTION 912 TO JUDICIAL EMPLOYEES.

(a) IN GENERAL.—Section 912(2) of the 1986 Code is amended by inserting "(or in the case of judicial officers or employees of the United States, in accordance with rules similar to such regulations)" after "President". 0)) EFFECTIVE DATE.—The amendment made by subsection (a) 26 USC 912 note. shall apply to allowances received after October 12, 1987, in taxable years ending after such date.

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