Page:United States Statutes at Large Volume 98 Part 1.djvu/1050

 98 STAT. 1002

PUBLIC LAW 98-369—JULY 18, 1984 revocation which under regulations prescribed by the Secretary results solely from the provisions of this title. (3) INSTALLMENT TREATMENT OF CERTAIN DEEMED DISTRIBUTIONS OF SHAREHOLDERS.—

(A) IN GENERAL.—Notwithstanding section 995(b) of such Code, if a shareholder of a DISC elects the application of this paragraph, any qualified distribution shall be treated, for purposes of such Code, as received by such shareholder in 10 equal installments on the last day of each of the 10 taxable years of such shareholder which begins after the first taxable year of such shareholder beginning in 1984. The preceding sentence shall apply without regard to whether the DISC exists after December 31, 1984. (B) QUALIFIED DISTRIBUTION.—The term 'qualified distribution' means any distribution which a shareholder is deemed to have received by reason of section 99503) of such Code with respect to income derived by the DISC in the first taxable year of the DISC beginning— (i) in 1984, and (ii) after the date in 1984 on which the taxable year of such shareholder begins. (C) SHORTER PERIOD FOR INSTALLMENTS.—The Secretary of

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the Treasury or his delegate may by regulations provide for the election by any shareholder to be treated as receiving a qualified distribution over such shorter period as the taxpayer may elect. (D) ELECTIONS.—Any election under this paragraph shall be made at such time and in such manner as the Secretary of the Treasury or his delegate may prescribe. (4) TREATMENT OP TRANSFERS FROM DISC TO FSC—Except to the

extent provided in regulations, section 367 of such Code shall not apply to transfers made before January 1, 1986 (or, if later, the date 1 year after the date on which the corporation ceases to be a DISC), to a FSC of qualified export assets (as defined in section 9930)) of such Code) held on August 4, 1983, by a DISC in a transaction described in section 351 or 368(a)(1) of such Code. (5) DEEMED TERMINATION OF A DISC—Under regulations prescribed by the Secretary, if any controlled group of corporations of which a DISC is a member establishes a FSC, then any DISC which is a member of such group shall be treated as having terminated its DISC status. (6) DEFINITIONS.—For purposes of this subsection, the terms "DISC" and "former DISC" have the respective meanings given to such terms by section 992 of such Code. 26 USC 991 note.

Ante, p. 991.

(c) SPECIAL RULE FOR ExPORT TRADE CORPORATIONS.—

(1) IN GENERAL.—If, before January 1, 1985, any export trade corporation— (A) makes an election under section 927(f)(1) of the Internal Revenue Code of 1954 to be treated as a FSC, or (B) elects not to be treated as an export trade corporation with respect to taxable years beginning after December 31, 1984, rules similar to the rules of paragraphs (2) and (4) of subsection (b) shall apply to such export trade corporation. (2) TREATMENT OF TRANSFERS TO FSC.—In the case of any export trade corporation which— (A) makes an election described in paragraph (1), and

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