Page:United States Statutes at Large Volume 89.djvu/118

 89 STAT. 58

PUBLIC LAW 94-12—MAR. 29, 1975

26 use907 note.

(d) EFFECTIVE DATES.—The amendments made by this section shall apply to taxable years ending after December 31, 1974; except that— (1) the second sentence of section 907(b) shall apply to taxable years ending after December 31, 1975, and (2) the provisions of section 907(f) shall apply to losses sustained in taxable years ending after December 31, 1975. SEC. 602. TAXATION OF EARNINGS AND PROFITS OF CONTROLLED FOREIGN CORPORATIONS AND THEIR SHAREHOLDERS.

Ante, p. 54:.

26 USC 963.

(a) REPEAL OF MINIMUM DISTRIBUTION EXCEPTION TO REQUIREMENT or CURRENT TAXATION OF SUBPART F I N C O M E. — (1) REPEAL, OF MINIMUM DISTRIBUTION PROVISIONS.—Section 963

(relating to receipt of minimum distributions by domestic corporations) is hereby repealed. (2) CERTAIN DISTRIBUTIONS BY CONTROLLED FOREIGN CORPORATIONS TO REGULATED INVESTMENT COMPANIES TREATED AS DIVIDENDS.

26 USC 851.

26 USC 951. 26 USC 959.

Subsection (b) of section 851 (relating to limitations on definition of regulated investment company) is amended by a d d i n g at the end thereof the following new sentence: " For purposes of paragraph (2), there shall be treated as dividends amounts included in gross income under section 951(a)(1)(A)(i) for the taxable year to the extent that, under section 959(a)(1), there is a distribution out of the earnings and profits of the taxable year which are attributable to the amounts so included." (3) CONFORMING AMENDMENTS.—

(A) The table of sections for subpart F of part III of subchapter N of chapter 1 is amended by striking out the item relating to section 963. (B) Subparagraph (A)(i) of section 951(a)(1) (relating to general rule for amounts included in gross income of United States shareholders) is amended by striking out "except as provided in section 963.". (b) LIMITATION ON DEFINITION OF FOREIGN B A S E COMPANY SALES

26 USC 954.

I N C O M E. — Paragraph (1) of section 954(d) (relating to definition of foreign base company sales income) is amended by a d d i n g a t the end thereof the following new sentence: " For purposes of this subsection, personal property does not include agricultural commodities which are not grown in the United States in commercially marketable quantities." (c) REPEAL OF EXCEPTION TO REQUIREMENT OF CURRENT TAXATION OF SUBPART F INCOME FOR REINVESTMENT I N L E S S DEVELOPED C O U N TRIES.— (1) REPEAL OF SECTION 954(b)(1). — Paragraph (1) of subsec-

tion (b) of section 954 (relating to exclusions and special rules r e g a r d i n g foreign base company income) is hereby repealed. (2) REPEAL OF SECTION 954(f).—Subsection (f) of section 954

(relating to increase in qualified investments in less developed countries) is hereby repealed. (3) AMENDMENT OF SECTION 951(a)(1)(A) ( i i). — C l a u s e

26 USC 955.

(ii)

of section 9 5 1 (a)(1)(A) is amended by striking out " ( determined under section 9 5 5 (a)(3)) " and inserting m lieu thereof " (determined under section 955(a)(3) as in effect before the enactment of the T a x Reduction Act of 1975)". (4) R E P E A L OF SECTION 9 5 1 (a)(3). — Paragraph (3) of section

951(a) (relating to limitation on p r o r a t a share of previously excluded subpart F income withdrawn from investment) is hereby repealed.

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