Page:United States Statutes at Large Volume 111 Part 1.djvu/1011

 PUBLIC LAW 105-34—AUG. 5, 1997 111 STAT. 987 of the Internal Revenue Code of 1986 (without regard to paragraph (2) thereof) with respect to such regulations. Subtitle G—Other Simplification Provisions SEC. 1161. TRANSITION RULE FOR CERTAIN TRUSTS. (a) IN GENERAL. —Paragraph (3) of section 1907(a) of the Small Business Job Protection Act of 1996 is amended by adding at 26 USC 7701 the end the following flush sentence: "^ote. "To the extent prescribed in regulations by the Secretary of the Treasury or his delegate, a trust which was in existence on August 20, 1996 (other than a trust treated as owned by the grantor under subpart E of part I of subchapter J of chapter 1 of the Internal Revenue Code of 1986), and which was treated as a United States person on the day before the date of the enactment of this Act may elect to continue to be treated as a United States person notwithstanding section 7701(a)(30)(E) of such Code. ". (b) EFFECTIVE DATE. —The amendment made by subsection (a) 26 USC 7701 shall take effect as if included in the amendments made by section note. 1907(a) of the Small Business Job Protection Act of 1996. SEC. 1162. REPEAL OF STOCK AND SECURITIES SAFE HARBOR REQUIREMENT THAT PRINCIPAL OFFICE BE OUTSIDE THE UNITED STATES. (a) IN GENERAL. —The last sentence of clause (ii) of section 864(b)(2)(A) (relating to stock or securities) is amended by striking ", or in the case of a corporation" and all that follows and inserting a period. (b) EFFECTIVE DATE. —The amendment made by subsection (a) 26 USC 864 note. shall apply to taxable years beginning after December 31, 1997. SEC. 1163. MISCELLANEOUS CLARIFICATIONS. (a) ATTRIBUTION OF DEEMED PAID FOREIGN TAXES TO PRIOR DISTRIBUTIONS. —Subparagraph (B) of section 902(c)(2) is amended by striking "deemed paid with respect to" and inserting "attributable to". (b) FINANCIAL SERVICES INCOME DETERMINED WITHOUT REGARD TO HIGH-TAXED INCOME.— Subclause (II) of section 904(d)(2)(C)(i) is amended by striking "subclause (I)" and inserting "subclauses (I) and (III)". (c) EFFECTIVE DATE. —The amendments made by this section 26 USC 902 note. shall take effect on the date of the enactment of this Act. Subtitle H—Other Provisions SEC. 1171. TREATMENT OF COMPUTER SOFTWARE AS FSC EXPORT PROPERTY. (a) IN GENERAL. —Subparagraph (B) of section 927(a)(2) (relating to property excluded from eligibility as FSC export property) is amended by inserting ", and other than computer software (whether or not patented)" before ", for commercial or home use".

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