Page:United States Statutes at Large Volume 98 Part 1.djvu/1046

 98 STAT. 998

PUBLIC LAW 98-369—JULY 18, 1984 "(A) the shareholder's DISC-related deferred tax liability for such year, and "(B) the base period T-bill rate. "(2) SHAREHOLDER'S DISC-RELATED DEFERRED TAX LIABILITY,—

For purposes of this subsection— "(A) IN GENERAL.—The term 'shareholder's DISC-related deferred tax liability' means, with respect to any taxable year of a shareholder of a DISC, the excess of— "(i) the amount which would be the tax liability of the shareholder for the taxable year if the deferred DISC income of such shareholder for such taxable year were included in gross income as ordinary income, over "(ii) the actual amount of the tax liability of such shareholder for such teixable year. Determinations under the preceding sentence shall be made without regard to carrybacks to such taxable year. "(B)

Ante, p. 826.

ADJUSTMENTS FOR

LOSSES,

CREDITS,

AND OTHER

ITEMS.—The Secretary shall prescribe regulations which provide such adjustments— "(i) to the accounts of the DISC, and "(ii) to the amount of any carryover or carryback of the shareholder, as may be necessary or appropriate in the case of net operating losses, credits, and carryovers, and carrybacks of losses and credits. "(C) TAX LIABILITY.—The term 'tax liability' means the amount of the tax imposed by this chapter for the taxable year reduced by credits allowable against such tax (other than Credits allowable under sections 31, 32, and 34). "(3) DEFERRED DISC INCOME.—For purposes of this subsection— "(A) IN GENERAL.—The term 'deferred DISC income' means, with respect to any taxable year of a shareholder, the excess of^ "(i) the shareholder's pro rata share of accumulated DISC income (for periods after 1984) of the DISC as of the close of the computation year, over "(ii) the amount of the distributions-in-excess-ofincome for the taxable year of the DISC following the computation year. "(B) COMPUTATION YEAR.—For purposes of applying subparagraph (A) with respect to any taxable year of a shareholder, the computation year is the taxable year of the DISC which ends with (or within) the taxable year of the shareholder which precedes the taxable year of the shareholder for which the amount of deferred DISC income is i being determined. "(C) D:STRIBUTIONS-IN-EXCESS-OF-INCOME.—For purposes of

subparagraph (A), the term 'distributions-in-excess-ofincome' means, with respect to any taxable year of a DISC, the excess (if any) of— "(i) the amount of actual distributions to the shareholder out of accumulated DISC income, over "(ii) the shareholder's pro rata share of the DISC income for such taxable year. il;, "(3) BASE PERIOD T-BILL RATE.—For purposes of this subsection, .„: the term 'base period T-bill rate' means the annual rate of
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