Page:United States Statutes at Large Volume 90 Part 2.djvu/182

 90 STAT. 1650

PUBLIC LAW 94-455—OCT. 4, 1976 (b) (YKHICAL AMKNDMKXT.—Tho table of s('<'tioiis for sncli subpart is amended by addhifr at the end thereof the following new itejn: "Sec. 908. Rfductioo of credit for participation in or cooperation witl) an international boycott." SEC. 1062. D E N I A L OF D E F E R R A L O F INTERNATIONAL BOYCOTT AMOUNTS.

26 USC 952.

\

Infra.

(a) D E X I A L OF DEFERUAr..—Section 1)52(a) (relating to general definition of subpart F income) is amended— (1) by striking out ''and'" at the end of paragraph (1). (2) by striking out the period a t the end of paragraph (2) and inserting in lieu thereof a comma, and the word "and", and (3) by adding at the end thereof the following new paragraph: •'(?>) an amount ecjual to the product of— " (A) the income of such corporation other than income which— " (i) is attributable to earnings and profits of the foreign co]'poration included in the gross income of a United States person undei- section 951 (other than by reason of this paragraph), or " ( i i) is described in subsection (b), multiplied by " (B) the international boycott factor (as determined under section 999)." SEC. 1063. DENIAL OF DISC BENEFITS. (a)

26 USC 995.

INTERXATIONAE BOYCOTT ACT IV I T Y. — Subparagraph

(D)

of

section 9 9 5 (b)(1) (relating to distributions in qualified years) is amended to read as follows: " (D) the sum of— " (i) one-half of the excess of the taxable income of the DISC; for the taxable year, before reduction for any distributions during the year, over the sum of the amounts deemed distributed for the taxable year under subparagraph s (A), (B), and (C). an d " ( i i) an amount equal to the amount determined under clause (i) multiplied by the international boycott factor determined under section 999, and'-. SEC. 1064. DETERMINATIONS AS TO PARTICIPATION IN OR COOPERATION WITH AN INTERNATIONAL BOYCOTT. (a) I N GENERVL.—Subchapter X of chapter 1 (relating to tax based on income fiom sources within oi- without the United States) is amended by adding at the end thereof the following new part: "PART V — INTERNATIONAL BOYCOTT DETERMINATIONS •'Sec. 95]S). Reports by taxpayers: determinations.

26 USC 999.

"SEC. 999. REPORTS BY TAXPAYERS; DETERMINATIONS. " (a) INTERNATIONAL BOYCOTT EFFORTS BY TAXPAYERS.— " (1) REPORT REQUIRED.—If any person, or a member of a con-

trolled group (within the meaning of section 993(a)(3)) which includes that person, has operations in, or related to— " (A) a country (or with the government, a company, or a national of a country) which is on the list maintained by the Secretary under paragraph (3), or

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