Page:United States Statutes at Large Volume 98 Part 1.djvu/631

 PUBLIC LAW 98-369—JULY 18, 1984

98 STAT. 583

shall apply to contracts entered into after September 30, 1984, in taxable years ending after such date. (2) SUBSECTION (b).—The amendments made by subsection (b) shall apply to property placed in service in taxable years beginning after September 30, 1984. (3) SUBSECTION ( O.—The amendments made by subsection (c) shall apply with respect to distributions declared after March 15, 1984, in taxable years ending after such date. (4) SUBSECTION (d).—The amendment made by subsection (d) 26 USC 30i note, shall apply to distributions after the date of the enactment of this Act in taxable years ending after such date. SEC. 62. 2-YEAR DELAY IN APPLICATION OF THE NET OPERATING LOSS RULES ADDED BY THE TAX REFORM ACT OF 1976. (a) IN GENERAL.—Subsection (g) of section 806 of the Tax Reform Act of 1976 (26 U.S.C. 382 note) (relating to effective dates for the amendments to sections 382 and 383 of the Internal Revenue Code of 1954) is amended— (1) by striking out "June 30, 1984" in paragraph (2) and inserting in lieu thereof "December 31, 1985"; (2) by striking out "January 1, 1984" in paragraph (2)(B) and inserting in lieu thereof "January 1, 1986"; and (3) by striking out "January 1, 1984" in paragraph (3) and inserting in lieu thereof "January 1, 1986".

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26 USC 382, 383. v jv

(b) TECHNICAL AMENDMENT.—

(1) Paragraph (1) of section 382(b) (as amended by the Tax 26 USC 382. Reform Act of 1976) is amended by striking out "section 368(a)(1)(A), (B), (C), (D) (but only if the requirements of section 354(b)(1) are met), or (F)" and inserting in lieu thereof "subparagraph (A), (B), (C), or (F) of section 368(a)(1) or subparagraph (D) or (G) of section 368(a)(1) (but only if the requirements of section 354(b)(1) are met)". (2) The amendment made by paragraph (1) shall take effect as 26 USC 382 note. if included in the amendments made by section 4 of the Bankruptcy Tax Act of 1980. 94 Stat. 3401. i SEC. 63. TARGET CORPORATION MUST DISTRIBUTE ASSETS AFTER REORGANIZATION DESCRIBED IN SECTION 368(a)(1)(C). (a) IN GENERAL.—Paragraph (2) of section 368(a) (relating to spe- 26 USC 368. cial rules for paragraph (1)) is amended by adding at the end thereof cS the following new subparagraph: "(G)

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DISTRIBUTION

REQUIREMENT

FOR

PARAGRAPH

(1)(C).— "(i) IN GENERAL.—A transaction shall fail to meet the requirements of paragraph (1)(C) unless the acquired corporation distributes the stock, securities, and other properties it receives, as well as its other properties, in pursuance of the plan of reorganization. "(ii) EXCEPTION.—The Secretary may waive the application of clause (i) to any transaction subject to any conditions the Secretary may prescribe." (b) ALLOCATION IN CERTAIN CORPORATE SEPARATIONS AND REORGA-

NIZATIONS.—Subsection (h) of section 312 (relating to allocation in certain corporate separations) is amended to read as follows: "(h) ALLOCATION IN CERTAIN CORPORATE SEPARATIONS AND REORGANIZATIONS.—

26 USC 312. ^

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