Page:United States Statutes at Large Volume 90 Part 2.djvu/73

 PUBLIC LAW 94-455—OCT. 4, 1976

90 STAT. 1541

(B) The table of sections for such subpart A is amended by adding at the end thereof the following: "Sec. 447. Method of accounting for corporations engaged in farming." (2) EFFECTIVE DATE.—The amendments made by paragraph (1) 26 USC 447 shall apply to taxable years beginning after December 31, 1976. "o*^(3) ELECTION TO CHANGE FROM STATIC VALUE METHOD TO ACCRUAL METHOD O F ACCOUNTING. —

26 USC 447 note.

(A) I x GEXERAL. If— (i) a corporation has computed its taxable income on an annual accrual method of accounting together with a static value method of accounting for deferred costs of growing crops for the 10 taxable years ending with its first taxable year beginning after December 31, 1975, (ii) such corporation raises crops which are harvested not less than 12 months after planting, and (iii) such corporation elects, within one year after the date of the enactment of this Act and in such manner as the Secretary of the Treasury or his delegate prescribes, to change to the annual accrual method of accounting (within the meaning of section 4 4 7 (g)(2) of the Internal Revenue Code of 1954) for taxable years Ante, p. 1538. beginning after December 31, 1976, such change shall be treated as having been made with the consent of the Secretary of the Treasury, and, under regulations prescribed by the Secretary of the Treasury or his delegate, the net amount of the adjustments required by section 481(a) of the I n t e r n a l Revenue Code of 1954 to be taken into account by the taxpayer in computing taxable income shall (except as otherwise provided in such regulations) be taken into account in each of the 10 taxable years beginning with the year of change. (B) CooRDiXATiox WITH SECTiox' 44 7 OF THE CODE.—A Corporation which elects under subparagraph (A) to change to the annual accrual method of accounting shall, for purposes of section 447(g) of the Internal Revenue Code of 1954, be deemed to be a corporation which has computed its taxable income on an annual accrual method of accounting for its 10 taxable years ending with its first taxable year beginning after December 31, 1975. (C) CERTAIN CORPORATE REORGANIZATIONS.—For purposes

of this paragraph, if a corj^oration acquired substantially all the assets of a farming trade or business from another corporation in a transaction in which no gain or loss was recognized to the transferor or transferee corporation, the transferee corporation shall be deemed to have computed its taxable income on an annual accrual method of accounting together with a static value method of accounting for deferred costs of growing crops during the period for which the transferor corporation computed its taxable income from such trade or business on such accrual and static value method. SEC. 208. TREATMENT OF PREPAID INTEREST. (a) GENERAL RULE.—Section 461 (relating to general rule for tax - 26 USC 461. able year of deduction) is amended by a d d i n g at the end thereof the f ollowinc: new subsection r

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