Page:United States Statutes at Large Volume 98 Part 1.djvu/1033

 PUBLIC LAW 98-369—JULY 18, 1984 thereof "under section 4071 with respect to tires of the types used on aircraft". (16) Sections 1366(f)(1) and 6401(b) are each amended by striking out ", special fuels, and lubricating oil" and inserting in lieu thereof "and special fuels". SEC. 736. EFFECTIVE DATE.

Except as otherwise provided in this subtitle, any amendment made by this subtitle shall take effect as if included in the provisions of the Highway Revenue Act of 1982 to which such amendment relates.

98 STAT. 985

26 USC 1366. ^"^«. P- 846. 26 USC 4051

26 USC i note,

TITLE VIII—FOREIGN SALES CORPORATIONS SEC. 801. FOREIGN SALES CORPORATIONS.

(a) IN GENERAL.—Part III of subchapter N of chapter 1 (relating to income from sources outside the United States) is amended by inserting after subpart B the following new subpart: "Subpart C—Taxation of Foreign Sales Corporations '

"Sec. 921. Exempt foreign trade income excluded from gross income. "Sec. 922. FSe defined. "Sec. 923. Exempt foreign trade income. "Sec. 924. Foreign trading gross receipts. "Sec. 925. Transfer pricing rules. "Sec. 926. Distributions to shareholders. "Sec. 927. Other definitions and special rules. "SEC. 921. EXEMPT FOREIGN TRADE INCOME EXCLUDED FROM GROSS INCOME.

26 USC 921.

"(a) EXCLUSION.—Exempt foreign trade income of a FSC shall be treated as foreign source income which is not effectively connected with the conduct of a trade or business within the United States. "(b) PROPORTIONATE ALLOCATION OF DEDUCTIONS TO EXEMPT FOREIGN TRADE INCOME.—Any deductions of the FSC properly appor-

tioned and allocated to the foreign trade income derived by a FSC from any transaction shall be allocated between— "(1) the exempt foreign trade income derived from such transaction, and "(2) the foreign trade income (other than exempt foreign trade income) derived from such transaction, on a proportionate basis. "(c) DENIAL OF CREDITS.—Notwithstanding any other provision of this chapter, no credit (other than a credit allowable under section 27(a), 33, or 34) shall be allowed under this chapter to any FSC. Ante, pp. 826, "(d) FOREIGN TRADE INCOME, INVESTMENT INCOME, AND CARRYING CHARGES TREATED AS EFFECTIVELY CONNECTED WITH UNITED STATES

BUSINESS.—For purposes of this chapter— "(1) all foreign trade income of a FSC other than— "(A) exempt foreign trade income, and "(B) section 923(a)(2) non-exempt income, "(2) all interest, dividends, royalties, and other investment income received or accrued by a FSC, and "(3) all carrying charges received or accrued by a FSC, shall be treated as income effectively connected with a trade or business conducted through a permanent establishment of such

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Post, p. 986.

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