Page:United States Statutes at Large Volume 92 Part 3.djvu/272

 92 STAT. 2904

PUBLIC LAW 95-600—NOV. 6, 1978 "(E) INDIVIDUALS RESIDING IN FOREIGN COUNTRIES.—For

26 USC 274. 26 USC 274 note.

purposes of this subsection, in the case of an individual citizen of the United States who establishes to the satisfaction of the Secretary that he was a bona fide resident of a foreign country at the time that he attended a convention in such foreign country, such individual's attendance at such convention shall not be considered as attendance at a foreign convention.". (3) TECHNICAL AMENDMENT.—The first sentence of section 274(h)(3) is amended by striking out "more than, one-half and inserting in lieu thereof "at least one-half. (4) EFFECTIVE DATE.—The amendments made by this subsection shall apply to conventions beginning after December 31, 1976. (h) RENTAL OF FORMER PRINCIPAL RESIDENCE.—

26 USC 280A.

(1) IN GENERAL.—Subsection (d) of section 280A (relating to use of residence for personal purposes) is amended by adding at the end thereof the following new paragraph: "(3) RENTAL OF PRINCIPAL RESIDENCE.—

26 USC 1034.

26 USC 267.

26 USC 280A note. 26 USC 280A. 26 USC 601. 26 USC 337.

"(A) IN GENERAL.—For purposes of applying subsection (c)(5) to deductions allocable to a qualified rental period, a taxpayer shall not be considered to have used a dwelling unit for personal purposes for any day during the taxable year which occurs before or after a qualified rental period described in subparagraph (B)(i), or before a qualified rental period described in subparagraph (B)(ii), if with respect to such day such unit constitutes the principal residence (within the meaning of section 1034) of the taxpayer. "(B) QUALIFIED RENTAL PERIOD.—For purposes of subparagraph (A), the term 'qualified rental period' means a consecutive period of— "(i) 12 or more months which begins or ends in such taxable year, or "(ii) less than 12 months which begins in such taxable year and at the end of which such dwelling unit is sold or exchanged, and for which such unit is rented to a person other than a member of the family (as defined in section 267(c)(4)) of the taxpayer, or is held for rental, at a fair rental." (2) EFFECTIVE DATE.—The amendment made by paragraph (1) shall take effect as if included in section 280A of the Internal Revenue Code of 1954, as such provision was added to such Code by section 601(a) of the Tax Reform Act of 1976. (i) CLARIFICATION OF LAST SENTENCE OF SECTION 337(c)(2).— (1) IN GENERAL.—Subsection (c) of section 337 (relating to limitations on application of section 337) is amended by striking out the last sentence of paragraph (2) and by adding at the end of such subsection the following new paragraph: "(3) SPECIAL RULE FOR AFFILIATED GROUP.—

"(A) IN GENERAL.—Paragraph (2) shall not apply to a sale or exchange by a corporation (hereinafter in this paragraph referred to as the 'selling corporation') if— "(i) within the 12-month period beginning on the date of the adoption of a plan of complete liquidation by the selling corporation, the selling corporation and each distributee corporation is completely liquidated, and

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