Page:United States Statutes at Large Volume 90 Part 2.djvu/171

 PUBLIC LAW 94-455—OCT. 4, 1976

90 STAT. 1639

"(D) in the case of a person seeking a declaratory judgment under section 7477, the le^al residence of such person if Ante, p. 1637. such person is not a corporation, or the principal place of business or principal office or agency of such person if such person is a corporation,". (B) Section 7482(b)(1) is further amended— 26 USC 7482. (i) by striking out "subparagraph (A), (B), and (C) do not apply" in the second sentence and inserting in lieu thereof "no subparagraph of the preceding sentence applies"; and (ii) by striking out "section 7476" in the last sentence and inserting in lieu thereof "section 7476 or 7477". (C) The heading for section 7476 is amended to read as follows:

"SEC. 7476. DECLARATORY JUDGMENTS RELATING TO QUALIFICATION OF CERTAIN RETIREMENT PLANS."

(D) The table of sections for part IV of subchapter C of chapter 76 is amended to read as follows: "Sec. 7476. Declaratory judgments relating to qualification of certain retirement plans. "Sec. 7477. Declaratory judgments relating to transfers of property from United States." (E) The heading of part IV of subchapter C of chapter 76 is amended to read as follows: "PART IV—DECLARATORY JUDGMENTS**. (F) The table of parts for subchapter C of chapter 76 is amended by striking out the item relating to part IV and inserting in lieu thereof the following: "Part IV. Declaratory judgments." (e) EFFECTIVE DATES.—

26 USC 367

(1) The amendments made by this section (other than by sub- note, section (d)) shall apply to transfers beginning after October 9, 1975, and to sales, exchanges, and distributions taking place after such date. The amendments made by subsection (d) shall apply with respect to pleadings filed with the Tax Court after the date of the enactment of this Act but only with respect to transfers beginning after October 9, 1975. (2) In the case of any exchange described in section 367 of the Internal Revenue Code of 1954 (as in effect on December 31, 1974) in any taxable year beginning after December 31, 1962, and before the date of the enactment of this Act, which does not involve the transfer of property to or from a United States person, a taxpayer shall have for purposes of such section until 183 days after the date of the enactment of this Act to file a request with the Secretary of the Treasury or his delegate seeking to establish to the satisfaction of the Secretary of the Treasury or his delegate that such exchange was not in pursuance of a plan having as one of its principal purposes the avoidance of Federal income taxes and that for purposes of such section a foreign corporation is to be treated as a foreign corporation. SEC. 1043. CONTIGUOUS COUNTRY BRANCHES OF DOMESTIC LIFE INSURANCE COMPANIES. (a) AMENDMENT OF SUBCHAPTER L.—Subpart E of part I of sub-

chapter L of chapter 1 (relating to life insurance companies) is amended by inserting after section 819 the following new section:

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