Page:United States Statutes at Large Volume 124.djvu/3574

 124 STAT. 3548 PUBLIC LAW 111–325—DEC. 22, 2010 ‘‘(ii) COORDINATION WITH TREATMENT OF NET CAP- ITAL LOSSES.—Clause (i) shall not apply to a net capital loss to which subparagraph (A) applies.’’. (b) CONFORMING AMENDMENTS.— (1) Subsection (c) of section 852 is amended by adding at the end the following new paragraph: ‘‘(4) REGULATED INVESTMENT COMPANY.—For purposes of this subsection, the term ‘regulated investment company’ includes a domestic corporation which is a regulated investment company determined without regard to the requirements of subsection (a).’’. (2) Paragraphs (1)(A) and (2)(A) of section 871(k) are each amended by inserting ‘‘which meets the requirements of section 852(a) for the taxable year with respect to which the dividend is paid’’ before the period at the end. (c) EFFECTIVE DATE.—The amendments made by this section shall apply to taxable years beginning after the date of the enact- ment of this Act. SEC. 303. PASS-THRU OF EXEMPT-INTEREST DIVIDENDS AND FOREIGN TAX CREDITS IN FUND OF FUNDS STRUCTURE. (a) IN GENERAL.—Section 852 is amended by adding at the end the following new subsection: ‘‘(g) SPECIAL RULES FOR FUND OF FUNDS.— ‘‘(1) IN GENERAL.—In the case of a qualified fund of funds— ‘‘(A) such fund shall be qualified to pay exempt-interest dividends to its shareholders without regard to whether such fund satisfies the requirements of the first sentence of subsection (b)(5), and ‘‘(B) such fund may elect the application of section 853 (relating to foreign tax credit allowed to shareholders) without regard to the requirement of subsection (a)(1) thereof. ‘‘(2) QUALIFIED FUND OF FUNDS.—For purposes of this sub- section, the term ‘qualified fund of funds’ means a regulated investment company if (at the close of each quarter of the taxable year) at least 50 percent of the value of its total assets is represented by interests in other regulated investment companies.’’. (b) EFFECTIVE DATE.—The amendment made by this section shall apply to taxable years beginning after the date of the enact- ment of this Act. SEC. 304. MODIFICATION OF RULES FOR SPILLOVER DIVIDENDS OF REGULATED INVESTMENT COMPANIES. (a) DEADLINE FOR DECLARATION OF DIVIDEND.—Paragraph (1) of section 855(a) is amended to read as follows: ‘‘(1) declares a dividend before the later of— ‘‘(A) the 15th day of the 9th month following the close of the taxable year, or ‘‘(B) in the case of an extension of time for filing the company’s return for the taxable year, the due date for filing such return taking into account such extension, and’’. (b) DEADLINE FOR DISTRIBUTION OF DIVIDEND.—Paragraph (2) of section 855(a) is amended by striking ‘‘the first regular dividend payment’’ and inserting ‘‘the first dividend payment of the same type of dividend’’. 26 USC 852 note. 26 USC 852 note. 26 USC 852.