Page:United States Statutes at Large Volume 96 Part 1.djvu/535

 PUBLIC LAW 97-248—SEPT. 3, 1982

96 STAT. 493

SEC. 228. WAIVER OF FA.MILY ATTRIBUTION BY ENTITIES.

(a) GENERAL RULE. — Paragraph (2) of section 302(c) (relating to constructive ownership of stock) is amended by adding at the end thereof the following new subparagraph:

26 USC 302.

"(C) SPECIAL RULE FOR WAIVERS BY ENTITIES.—

"(i) IN GENERAL.—Subparagraph (A) shall not apply to a distribution to any entity unless— "(I) such entity and each related person meet the requirements of clauses (i), (ii), and (iii) of subparagraph (A), and "(II) each related person agrees to be jointly and severally liable for any deficiency (including interest and additions to tax) resulting from an acquisition described in clause (ii) of subparagraph (A). In any case to which the preceding sentence applies, the second sentence of subparagraph (A) and subparagraph (B)(ii) shall be applied by substituting 'distributee or any related person' for 'distributee' each place it appears. "(ii) DEFINITIONS.—For purposes of this subparagraph— "(I) the term 'entity' means a partnership, estate, trust, or corporation; and "(II) the term 'related person' means any person to whom ownership of stock in the corporation is (at the time of the distribution) a t t r i b u t a b l e under section 318(a)(1) if such stock is further a t t r i b u t a ble to the entity under section 318(a)(3).". (b) EFFECTIVE D A T E. — The amendment m a d e by subsection (a) shall apply with respect to distributions after August 31, 1982, in taxable years ending after such date.

26 USC 302 note,

PART VI—METHODS OF ACCOUNTING SEC.

229.

MODIFICATION OF REGULATIONS ON CONTRACT METHOD OF ACCOUNTING.

THE

COMPLETED

(a) IN GENERAL. — The Secretary of the Treasury shall modify the income tax regulations relating to accounting for long-term contracts to— (1) clarify the time at which a contract is to be considered completed, (2) clarify when— (A) one a g r e e m e n t will be t r e a t e d as more than one contract, and (B) two or more a g r e e m e n t s will be t r e a t e d as one contract, and (3) properly allocate all costs which directly benefit, or a r e incurred by reason of, the extended period long-term contract activities of the taxpayer. (b) EXTENDED PERIOD L O N G - T E R M CONTRACTS D E F I N E D. — For pur-

poses of this section— (1) IN GENERAL.—The term "extended period long-term contract " means any long-term contract which the tax p a y e r estim a t e s (at the time such contract is entered into) will not be completed within the 2-year period beginning on the contract c o m m e n c e m e n t date of such contract.

26 USC 451 note.

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