Page:United States Statutes at Large Volume 96 Part 1.djvu/508

 96 STAT. 466 26 USC 934. 48 USC 1642.

Ante, p. 452.

26 USC 936 note.

PUBLIC LAW 97-248—SEPT. 3, 1982 "(ii) which is described in subsection (b) of section 934 and which is an inhabitant of the Virgin Islands (within the meaning of section 28(a) of the Revised Organic Act of the Virgin Islands). "(B) FORMER POSSESSION CORPORATION.—A corporation shall be treated as a possession corporation with respect to any transfer if such corporation was a possession corporation (within the meaning of subparagraph (A)) at any time during the 5-year period ending on the date of such transfer. "(3) TRANSFER BY UNITED STATES AFFILIATES.—A rule similar to the rule of paragraph (1) shall apply in the case of a direct or indirect transfer by a United States affiliate to a foreign person of intangible property which, after August 14, 1982, was being used (or held for use) by a possession corporation under an arrangement with a United States affiliate. For purposes of the preceding sentence, the term "United States affiliate" means any United States person who is a member of an affiliated group (within the meaning of section 936(h)(5)(C)(i)(I)(b)) which includes the possession corporation. "(4) WAIVER AUTHORITY.—Subject to such terms and conditions as the Secretary may provide, paragraph (1) or (3) shall not apply to any case where the Secretary is satisfied that the transfer will not result in the reduction of current or future Federal income taxes." (e) EFFECTIVE D A T E S. —

(1) IN GENERAL.—Except as provided in paragraphs (2) and (3), the amendments made by this section shall apply to taxable years beginning after December 31, 1982. (2) CERTAIN SALES MADE AFTER JULY i, 1982.—Paragraph (6) of

Ante, p. 463.

section 936(h) of the Internal Revenue Code of 1954, and so much of section 934 to which such paragraph applies by reason of section 934(e)(4) of such Code, shall apply to taxable years ending after July 1, 1982. (3) CERTAIN TRANSFERS OF INTANGIBLES MADE AFTER AUGUST

14, 1982.—Subsection (d) shall apply to taxable years ending after August 14, 1982. PART IV—TAX-EXEMPT OBLIGATIONS SEC. 214. MODIFICATION OF EXEMPTION FOR SMALL ISSUES.

26 USC 103.

(a) COMPOSITE ISSUES.—Paragraph (6) of section 103(b) (relating to exemption for certain small issues) is amended by adding at the end thereof the following new subparagraphs: "(K) LIMITATIONS ON TREATMENT OF OBLIGATIONS AS PART OF THE SAME ISSUE.—For purposes of this paragraph, sepa-

rate lots of obligations which (but for this subparagraph) would be treated as part of the same issue shall be treated as separate issues unless the proceeds of such lots are to be used with respect to 2 or more facilities— "(i) which are located in more than 1 State, or "(ii) which have, or will have, as the same principal user the same person or related persons. "(L) FRANCHISES.—For purposes of subparagraph (K), a person (other than a governmental unit) shall be considered

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