Page:United States Statutes at Large Volume 98 Part 1.djvu/1048

 98 STAT. 1000

26 USC 441.

PUBLIC LAW 98-369—JULY 18, 1984

SEC. 803. TAXABLE YEAR OF DISC AND FSC REQUIRED TO CONFORM TO TAXABLE YEAR OF MAJORITY SHAREHOLDER. (a) IN GENERAL.—Subsection (b) of section 441 (relating to period for computation of taxable income) is amended— (1) by striking out "or" at the end of paragraph (2), (2) by striking out the period at the end of paragraph (3) and inserting in lieu thereof "; or", and (3) by adding at the end thereof the following new paragraph: "(4) in the case of a FSC or DISC filing a return for a period of at least 12 months, the period determined under subsection (h).". (b) DETERMINATION OF TAXABLE YEAR.—Section 441 is amended by

adding at the end thereof the following new subsection: "(h) TAXABLE YEAR OF F S C ' S AND DISC'S.—

"(1) IN GENERAL.—For purposes of this subtitle, the taxable year of any FSC or DISC shall be the taxable year of that shareholder (or group of shareholders with the same 12-month taxable year) who has the highest percentage of voting power. "(2) SPECIAL RULE WHERE MORE THAN ONE SHAREHOLDER (OR

GROUP) HAS HIGHEST PERCENTAGE.—If 2 or more shareholders (or groups) have the highest percentage of voting power under paragraph (1), the taxable year of the FSC or DISC shall be the same 12-month period as that of any such shareholder (or group). "(3) SUBSEQUENT CHANGES OF OWNERSHIP.—The Secretary

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shall prescribe regulations under which paragraphs (1) and (2) shall apply to a change of ownership of a corporation after the taxable year of the corporation has been determined under paragraph (1) or (2) only if such change is a substantial change of ownership. "(4) VOTING POWER DETERMINED.—For purposes of this subsection, voting power shall be determined on the basis of total combined voting power of all classes of stock of the corporation entitled to vote..

SEC. 804. REPORTING REQUIREMENTS. 26 USC 921 note. (a) IN GENERAL.—The Secretary of the Treasury shall, for calendar year 1985 and each second calendar year thereafter, submit a report to the Congress within 27 ¥2 months following the close of such calendar yea> setting forth an analysis of the operation and effect of the provisions of this title, (b) REPEAL OF DISC REPORTING REQUIREMENTS.— 26 USC 991 note. (1) IN GENERAL.—Section 806 of the Revenue Act of 1971 (relating to submission of annual reports to Congress) is hereby repealed. 26 USC 991 note. (2) EFFECTIVE DATE.—The amendment made by paragraph (1) shall apply to reports for calendar years after 1984. SEC. 805. EFFECTIVE DATE; TRANSITION RULES. 26 USC 921 note.

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Ante, p. 987.

(a) EFFECTIVE D A T E S. —

(1) IN GENERAL.—Except as provided in this subsection, the amendments made by this title shall apply to transactions after December 31, 1984, in taxable years ending after such date. (2) SPECIAL RULE FOR CERTAIN CONTRACTS.—To the extent provided in regulations prescribed by the Secretary, subsections (c) and (d) of section 924 of the Internal Revenue Code of 1954 (as added by this title) shall not apply to—

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