Page:United States Statutes at Large Volume 107 Part 1.djvu/528

 107 STAT. 502 PUBLIC LAW 103-66 —AUG. 10, 1993 including regulations to prevent the avoidance of the provisons of this section through reorganizations or otherwise." (c) CONFORMING AMENDMENTS.— 26 USC 951. (1) Subparagraph (B) of section 951(a)(l) is amended to read as follows: "(B) the amount determined under section 956 with respect to such shareholder for such year 0>ut only to the extent not excluded from gross income under section 959(a)(2)); and" (2) Subsection (a) of section 951 is amended by striking paragraph (4). 26 USC 951 note. (d) EFFECTIVE DATE.— The amendments made by this section shall apply to taxable years of controlled foreign corporations beginning after September 30, 1993, and to taxable years of United States shareholders in which or with which such taxable years of controlled foreign corporations end. SEC. 13233. OTHER MODIFICATIONS TO SUBPART F. (a) SAME COUNTRY EXCEPTION NOT TO APPLY TO CERTAIN DIVI- DENDS. — (1) IN GENERAL.— Paragraph (3) of section 954(c) (relating to certain income received from redated persons) is amended by adding at the end thereof the following new subparagraph: "(C) EXCEPTION FOR CERTAIN DIVIDENDS.— Subparagraph (A)(i) shall not apply to any dividend with respect to any stock which is attributable to earnings and profits of the distributing corporation accumulated during any period during which the person receiving such dividend did not hold such stock either directly, or indirectly through a chain of one or more subsidiaries each of which meets the requirements of subparagraph (A)(i)." 26 USC 954 note. (2) EFFECTIVE DATE.— The amendment made by paragraph (1) shall apply to taxable years of controlled foreign corporations beginning after September 30, 1993, and to taxable years of United States shareholders in which or with which such taxable years of controlled foreign corporations end. (b) AMENDMENTS TO SECTION 960(b).— (1) IN GENERAL.— Subsection (b) of section 960 is amended— (A) by redesignating paragraphs (3) and (4) as paragraphs (4) and (5), respectively, and (B) by striking paragraphs (1) and (2) cmd inserting the following new paragraphs: "(1) INCREASE IN SECTION 904 LIMITATION. —In the case of any taxpayer who— "(A) either (i) chose to have the benefits of subpart A of this part for a taxable year beginning after September 30, 1993, in which he was required under section 951(a) to include any amount in his gross income, or (ii) did not pay or accrue for such taxable year any income, war profits, or excess profits taxes to any foreign country or to any possession of the United States, "(B) chooses to have the benefits of subpart A of this part for any taxable year in which he receives 1 or more distributions or amounts which are excludable from gross income under section 959(a) and which are attributable

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