Page:United States Statutes at Large Volume 96 Part 1.djvu/583

 PUBLIC LAW 97-248—SEPT. 3, 1982

96 STAT. 541

"(A) IN GENERAL.—The a m o u n t of the consolidated life insurance company taxable income under paragraph s (1) and (2) of section 802(b) shall be determined by taking into 26 USC 802. account the life insurance company taxable income (including any case where deductions exceed income) of each life insurance company which is a member of the group (as computed separately under such paragraphs). "(B) CERTAIN AMOUNTS COMPUTED SEPARATELY.—For pur-

poses of subparagraph (A), the determination of a life insurance company's taxable investment income and gain or loss from operations (after applying the limitation provided by section 809(f)) shall be made without regard to the taxable investment income or gain or loss from operations of any other such company. "(3) CONSOLIDATED N E T CAPITAL G A I N. — I f the r e is a consoli-

dated n e t capital gain, the n the partial tax referred to in section 802(a)(2)(A) shall be computed on— "(A) the consolidated life insurance company taxable income, reduced (but not below the s u m of the a m o u n t s determined under section 802(b)(3)) by "(B) the a m o u n t of such consolidated n e t capital gain." SEC. 263. EFFECTIVE DATES; SPECIAL RULES APPLICABLE TO TRANSACTIONS BEFORE EFFECTIVE DATE. (a) EFFECTIVE D A T E S. —

26 USC 805 note.

(1) IN GENERAL.—Except a s provided in this subsection, the amendments made by this part shall apply to taxable years beginning after December 31, 1981, and before January 1, 1984. (2) G R O U P PENSION CONTRACTS.—The amendments

m a d e by

section 260(b) shall apply to taxable years beginning December 31, 1982, and before January 1, 1984.

after

(3) RESERVES O N CONTRACTS WHERE INTEREST GUARANTEED FOR EXTENDED PERIODS.—

(A) IN GENERAL.—The amendment made by section 260(a) shall apply to reserves computed for taxable years beginning after December 31, 1981, and before January 1, 1984, with respect to g u a r a n t e e s made after July 1, 1982, and before January 1, 1984. (B) SPECIAL RULE RELATING TO RESERVES.—If, for any tax-

able year beginning before January 1, 1982— (i) a tax p a y e r increased reserves pursuant to section 810(c)(4) of the I n t e r n a l Revenue Code of 1954 to reflect interest g u a r a n t e e d beyond the end of such taxable year, and (ii) the Federal income tax liability of such tax p a y e r for all taxable years would be the s a m e if such liability was computed with or without regard to such reserves, the n such reserves shall, a s of the beginning of the first taxable year of the taxpayer beginning after December 31, 1981, be recomputed as if section 818(h) of such Code (as Ante,p.5S9. added by this Act) applied to such reserves. If this subparagraph applies to any taxpayer, subparagraph (A) shall be applied with respect to such tax p a y e r by striking out "after July 1, 1982, and". (b) SPECIAL RULES FOR CERTAIN TRANSACTIONS IN TAXABLE YEARS B E G I N N I N G BEFORE J A N U A R Y 1, 1982.— (1) CERTAIN INTEREST AND P R E M I U M S. —

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