Page:United States Statutes at Large Volume 78.djvu/857

 78 STAT. ]

PUBLIC LAW 88-563-SEPT. 2, 1964

815

" (7) LOANS TO ASSURE RAW MATERIALS SOURCES.—Of debt obligations by United States persons in connection with loans made to foreign corporations to assure raw materials sources, to the extent provided in subsection (d). "(8)

ACQUISITIONS BY INSURANCE COMPANIES DOING BUSINESS IN

FOREIGN COUNTRIES.—Of stock OT debt obligations by insurance companies doin^ business in foreign countries, to the extent provided in subsection (e). "(9) ACQUISITIONS BY CERTAIN TAX-EXEMPT LABOR, FRATERNAL, AND SIMILAR ORGANIZATIONS HAVING FOREIGN BRANCHES OR CHAP-

TERS.—Of stock or debt obligations by certain tax-exempt United States persons operating in foreign countries through local organizations, to the extent provided in subsection (f). " (10) ACQUISITIONS OF DEBT OBLIGATIONS ON SALE OR LIQUIDATION

OF WHOLLY OWNED FOREIGN SUBSIDIARIES.—Of debt obligations acquired in connection with the sales or liquidation of a wholly owned foreign corporation, to the extent provided in subsection (g). "(11) ACQUISITIONS OF DEBT OBLIGATIONS ARISING OUT OF PURCHASE OF REAL PROPERTY LOCATED IN THE UNITED STATES. Of debt

obligations secured by real property located in the United States and arising out of the purchase of such property from United States persons, to the extent provided in subsection (h). " (12) ACQUISITIONS BY UNITED STATES PERSONS RESIDING IN FOR-

EIGN COUNTRIES OF STOCK OF CERTAIN FOREIGN ISSUERS INVESTING EXCLUSIVELY IN THE UNITED STATES.

O f StOck o f foreign isSUCTS

investing exclusively in the United States by United States persons residing in foreign countries, to the extent provided in subsection "(c)

EXPORT CREDIT, ETC.. TRANSACTIONS.—

"(1) IN GENERAL.—The tax imposed by section 4911 shall not apply to the acquisition from a foreign obligor of a debt obligation arising out of the sale of tangible personal property or services (or both) to such obligor by any United States person, if— " (A) payment of such debt obligation (or of any related debt obligation arising out of such sale) is guaranteed or insured, in whole or in part, by an agency or wholly owned instrumentality of the United States; or " (B) the United States person acquiring such debt obligation makes the sale in the ordinary course of his trade or business and not less than 85 percent of the purchase price is attributable to the sale of property manufactured, produced, grown, or extracted in the United States, or to the performance of services by such United States person (or by one or more includible corporations in an affiliated group, as defined in section 1504, of which such person is a member), or to both. The term 'services', as used in this paragraph and paragraph (2), shall not be construed to include functions performed as an underwriter. "(2)

ALTERNATE RULE FOR PRODUCING EXPORTERS.—The tax

im-

posed by section 4911 shall not apply to the acquisition by a United States person from a foreign issuer or obligor of its stock in payment for, or of a debt obligation arising out of, the sale of tangible personal property or services (or both) to such issuer or obligor, if (A) at least 30 percent of the purchase price, or 60 percent of the actual value of the stock or debt obligation acquired, is attributable to the sale of property manufactured, pro-

^e use 1504,

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