Page:United States Statutes at Large Volume 119.djvu/2646

 119 STAT. 2628

26 USC 965.

Applicability.

26 USC 460 note.

VerDate 14-DEC-2004

07:21 Oct 30, 2006

PUBLIC LAW 109–135—DEC. 21, 2005

‘‘(4) COORDINATION WITH SECTION 78.—Section 78 shall not apply to any tax which is not allowable as a credit under section 901 by reason of this subsection.’’. (7) The last sentence of section 965(e)(1) is amended by inserting ‘‘which are imposed by foreign countries and possessions of the United States and are’’ after ‘‘taxes’’. (8) Subsection (f) of section 965 is amended by inserting ‘‘on or’’ before ‘‘before the due date’’. (r) AMENDMENTS RELATED TO SECTION 501 OF THE ACT.— (1) Subparagraph (A) of section 164(b)(5) is amended to read as follows: ‘‘(A) ELECTION TO DEDUCT STATE AND LOCAL SALES TAXES IN LIEU OF STATE AND LOCAL INCOME TAXES.—At the election of the taxpayer for the taxable year, subsection (a) shall be applied— ‘‘(i) without regard to the reference to State and local income taxes, and ‘‘(ii) as if State and local general sales taxes were referred to in a paragraph thereof.’’. (2) Clause (ii) of section 56(b)(1)(A) is amended by inserting ‘‘or clause (ii) of section 164(b)(5)(A)’’ before the period at the end. (s) AMENDMENTS RELATED TO SECTION 708 OF THE ACT.—Section 708 of the American Jobs Creation Act of 2004 is amended— (1) in subsection (a), by striking ‘‘contract commencement date’’ and inserting ‘‘construction commencement date’’, and (2) by redesignating subsection (d) as subsection (e) and inserting after subsection (c) the following new subsection: ‘‘(d) CERTAIN ADJUSTMENTS NOT TO APPLY.—Section 481 of the Internal Revenue Code of 1986 shall not apply with respect to any change in the method of accounting which is required by this section.’’. (t) AMENDMENT RELATED TO SECTION 710 OF THE ACT.—Clause (i) of section 45(c)(7)(A) is amended by striking ‘‘synthetic’’. (u) AMENDMENT RELATED TO SECTION 801 OF THE ACT.—Paragraph (3) of section 7874(a) is amended to read as follows: ‘‘(3) COORDINATION WITH SUBSECTION (b).—A corporation which is treated as a domestic corporation under subsection (b) shall not be treated as a surrogate foreign corporation for purposes of paragraph (2)(A).’’. (v) AMENDMENTS RELATED TO SECTION 804 OF THE ACT.— (1) Subparagraph (C) of section 877(g)(2) is amended by striking ‘‘section 7701(b)(3)(D)(ii)’’ and inserting ‘‘section 7701(b)(3)(D)’’. (2) Subsection (n) of section 7701 is amended to read as follows: ‘‘(n) SPECIAL RULES FOR DETERMINING WHEN AN INDIVIDUAL IS NO LONGER A UNITED STATES CITIZEN OR LONG-TERM RESIDENT.—For purposes of this chapter— ‘‘(1) UNITED STATES CITIZENS.—An individual who would (but for this paragraph) cease to be treated as a citizen of the United States shall continue to be treated as a citizen of the United States until such individual— ‘‘(A) gives notice of an expatriating act (with the requisite intent to relinquish citizenship) to the Secretary of State, and

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