Page:United States Statutes at Large Volume 98 Part 1.djvu/600

 98 STAT. 552 ,,.,,. -,

Ante, p. 532.

Ante, p. 540.

Ante, p. 536.

Ante, p. 533.

26 USC 1287.

PUBLIC LAW 98-369—JULY 18, 1984 "(1) is purchased after August 16, 1954, and before January 1, 1958, and the purchaser does not receive all the coupons which first become payable more than 12 months after the date of the purchase, or "(2) is purchased after December 31, 1957, and before July 2, 1982, and the purchaser does not receive all the coupons which first become payable after the date of the purchase, then the gain on the sale or other disposition of such bond by such purchaser (or by a person whose basis is determined by reference to the basis in the hands of such purchaser) shall be considered as ordinary income to the extent that the fair market value (determined as of the time of the purchase) of the bond with coupons attached exceeds the purchase price. If this subsection and section 1271(a)(2)(A) apply with respect to gain realized on the sale or exchange of any evidence of indebtedness, then section 1271(a)(2)(A) shall apply with respect to that part of the gain to which this subsection does not apply. "(d) SPECIAL RULES FOR TAX-EXEMPT OBLIGATIONS.—In the case of any tax-exempt obligation (as defined in section 1275(a)(3))— "(1) subsections (a) and (b)(1) shall not apply, "(2) the rules of subsection (b)(4) shall apply for purposes of subsection (c), and "(3) subsection (c) shall be applied without regard to the requirement that the bond be purchased before July 2, 1982. "(e) DEFINITIONS AND SPECIAL RULES.—For purposes of this section— "(1) BOND.—The term 'bond' means a bond, debenture, note, or certificate or other evidence of indebtedness. "(2) STRIPPED BOND.—The term 'stripped bond' means a bond issued at any time with interest coupons where there is a separation in ownership between the bond and any coupon which has not yet become payable. "(3) STRIPPED COUPON.—The term 'stripped coupon' means any coupon relating to a stripped bond. "(4) STATED REDEMPTION PRICE AT MATURITY.—The term 'stated redemption price at maturity' has the meaning given such term by section 1273(a)(2). "(5) COUPON.—The term 'coupon' includes any right to receive interest on a bond (whether or not evidenced by a coupon). This paragraph shall apply for purposes of subsection (c) only in the case of purchases after July 1, 1982. "(6) PURCHASE.—The term 'purchase' has the meaning given such term by section 1272(d)(1). "(f) REGULATION AUTHORITY.—The Secretary may prescribe regulations providing that where, by reason of varying rates of interest, put or call options, or other circumstances, the tax treatment under this section does not accurately reflect the income of the holder of a stripped coupon or stripped bond, or of the person disposing of such bond or coupon, as the case may be, for any period, such treatment shall be modified to require that the proper amount of income be included for such period. "SEC. 1287. DENIAL OF CAPITAL GAIN TREATMENT FOR GAINS ON CERTAIN OBLIGATIONS NOT IN REGISTERED FORM.

"(a) IN GENERAL.—If any registration-required obligation is not in registered form, any gain on the sale or other disposition of such

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