Page:United States Statutes at Large Volume 90 Part 2.djvu/174

 90 STAT. 1642

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PUBLIC LAW 94-455—OCT. 4, 1976 inado not later tlian tlu> time, proscribed by law for filina" the re(iirii for the taxable year (inchidino- extensions thereof) ^vith respect" to AYliicli sncli election is made, and snch election and any approve(l I'evocation thereof shall be made in the manner pro\ided by the Secretary. "(h)

Ante, pp. 1634, 1617.

Srix'iAiv IviLK FOK I)O:MKSTI(^ STOCK L I F K I x s r i i A x n: Co:\r-

pAxiKs.^—At the election of a domestic stock life insurance company which has a contiguous country life insurance l)ranch descrilx'd in subsection (b) (M-ithout reo-ard to the mutual re(}uirement in subsection (b)(3)). the assets of such branch may be transferred to a forei<:'u corporation or<iani/ed under the laws of the contiguous counti'V "without the application of section ^\Vu or 14pl. Subsection (a) shall aj^ply to the stock of such foreiiiii corporation as if such donu'stic company Avere a mutual company and as if the stock were an item described in subsection (c). Subsection (e)("2) shall apply to amounts transferi'cd or ci'edited to such domestic company as if s\ich domestic company and such forei-i'(>o;)te fair market value of the in\ested assets and tan<>-il)le property which are separately accomited foi- by the domestic life insurance company in the bi-anch account exceeds th{> <'iaii) which ecpials the prportion which the a<i;ar(\iiate fair market value of snch assets which aiv. transferred pursuant to this subsection is of the aa'jireaate fair market value of all such assets." (b) C'LKincAr A^MKNUMKNT.—The table of sections for such subpart E is amended by iiiserting after the item I'elatinii' to section 810 the following new item: "Soc. 81!)A. Coiiti.iriioiis country lirnnches of domestic life iiisurnnco couipiliiics."

26 USC 819A note.

26 USC 582.

(c) KFFKcrn K DATK.—The amendment made by this section shall fPpl.v ^^o taxable years beginning after I)eceiiibei' o l. ^!)7.^. SEC. 1044. TRANSITIONAL lUTLE FOR BOND, ETC., LOSSES OF FOREIGN BANKS. (a) GF.XKI^M. IJn.K.—Section r)82(c) (relating to bond. etc.. losses and gains of financial institutions) is amended by adding at the end thereof the following new paragraph: " (4) TiiAXsrrioxAi. VA \A: FOU I?AXKS.—In the case of a corporation which would be a bank except foi' tlu> fact that it is a foivign cor]ioration, the net gain, if any. for the taxabl(> year on sales and exchanges described in paragraph (1) shall be considered as gain from the sale or exchange of a capital asset to the (>xti'nt such net gain does not exceed the portion of any capital loss canwover to such taxable year which is attributable to capital lossc's on sales oiexchanges described in paragraph (1) for a taxable^ year beginning b(>fore duly 12, 19i). For purposes of the prece([ing sentence, the portion of a net capital loss for a taxable yearwliicli is attributable to capital losses on sales or exchanges dcscrilied in paragra))li (1) is the amount of the net cajiital loss on such sal(>s or exchanges

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