Page:United States Statutes at Large Volume 98 Part 1.djvu/690

 98 STAT. 642

PUBLIC LAW 98-369—JULY 18, 1984 (i) the requirements of clause (i) of section 163(f)(2)(B) of the Internal Revenue Code of 1954 are met with respect to such obligation, and (ii) in the case of an obligation issued after December 31, 1982, the requirements of clause (ii) of such section 163(f)(2)(B) are met with respect to such obligation. (H) TREATMENT OF OBLIGATIONS WITH ORIGINAL ISSUE DIS-

Ante, p. 547.

Ante, p. 638.

COUNT.—For purposes of this paragraph, in the case of any obligation with original issue discount, the principal amount of such obligation as of any day shall be treated as equal to the revised issue price as of such day (as defined in section 1278(a)(4) of the Internal Revenue Code of 1954). (I) APPLICABLE LIMIT.—For purposes of subparagraph (B)(ii)(I), the term "applicable limit" means the sum of— (i) the equity of the applicable CFC on March 31, 1984, and (ii) the aggregate principal amount of CFC obligations outstanding on March 31, 1984, which were issued by an applicable CFC— (I) before March 8, 1984, or (II) after March 7, 1984, pursuant to a binding commitment in effect on March 7, 1984. (3) EXCEPTION FOR CERTAIN TERM OBLIGATIONS.—The amendments made by subsection (a) shall not apply to interest on any term obligations held by a foreign corporation on March 7, 1984. The preceding sentence shall not apply to any United States affiliate obligation (as defined in paragraph (2)(F)) held by an applicable CFC (as defined in paragraph (2)(D)). (4) DEFINITIONS.—Any term used in this subsection which is also used in section 904(g) of the Internal Revenue Code of 1954 (as added by subsection (a)) shall have the meaning given such term by such section 904(g). (5) SEPARATE APPLICATION OF SECTION 904 IN CASE OF INCOME COVERED BY TRANSITIONAL RULES.—Subsections (a), (b), and (c) of

section 904 of the Internal Revenue Code of 1954 shall be applied separately to any amount not treated as income derived from sources within the United States but which (but for the provisions of paragraph (2) or (3) of this subsection) would be so treated under the amendments made by subsection (a). Any such separate application shall be made before any separate application required under section 904(d) of such Code. (6) APPLICATION OF PARAGRAPH

(5)

DELAYED IN CERTAIN

CASES.—In the case of a foreign corporation— (A) which is a subsidiary of a domestic corporation which has been engaged in manufacturing for more than 50 years, and (B) which issued certificates with respect to obligations on— (i) September 24, 1979, denominated in French francs, (ii) September 10, 1981, denominated in Swiss francs, (iii) July 14, 1982, denominated in Swiss francs, and (iv) December 1, 1982, denominated in United States dollars, with a total principal amount of less than 200,000,000 United States dollars.

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