Page:United States Statutes at Large Volume 98 Part 1.djvu/759

 ^PUBLIC LAW 98-369—JULY 18, 1984

98 STAT. 711

headings) and inserting in lieu thereof "mortgage disposition loss", and (B) by striking out "FNMA MORTGAGE DISPOSITION Loss" in the subsection heading and inserting in lieu thereof •

"MORTGAGE DISPOSITION LOSS OF THE FEDERAL NATIONAL MORTGAGE ASSOCIATION OR THE FEDERAL HOME LOAN MORTGAGE CORPORATION". (d) EFFECTIVE DATES.—

26 USC 172 note.

(1) IN GENERAL.—The amendments made by this section shall take effect on January 1, 1985. (2) ADJUSTED BASIS OF ASSETS.—

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(A) IN GENERAL.—Except as otherwise provided in subparagraph (B), the adjusted basis of any asset of the Federal Home Loan Mortgage Corporation held on January 1, 1985, shall— (i) for purposes of determining any loss, be equal to the lesser of the adjusted basis of such asset or the fair market value of such asset as of such date, and (ii) for purposes of determining any gain, be equal to the higher of the adjusted basis of such asset or the fair market value of such asset as of such date.

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(B) SPECIAL RULE FOR TANGIBLE DEPRECIABLE PROPERTY.—

In the case of any tangible property which— ^' -* • > (i) is of a character subject to the allowance for B' depreciation provided by section 167 of the Internal Revenue Code of 1954, and (ii) is held by the Federal Home Loan Mortgage !iu f: * Corporation on January 1, 1985, the adjusted basis of such property shall be equal to the I lesser of the basis of such property or the fair market value of such property as of such date. diiw (3) TREATMENT OF PARTICIPATION CERTIFICATES.— (A) IN GENERAL.—Paragraph (2) shall not apply to any right to receive income with respect to any mortgage pool participation certificate or other similar interest in any mortgage (not including any mortgage).

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(B) TREATMENT OF CERTAIN SALES AFTER MARCH 15, 1984, AND BEFORE JANUARY 1, 1985.—If any gain is realized on the

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sale or exchange of any right described in subparagraph (A) after March 15, 1984, and before January 1, 1985, the gain shall not be recognized when realized but shall be recognized on January 1, 1985. (4) N O ACCUMULATED EARNINGS AND PROFITS ON JANUARY i,

1985.—For purposes of the Internal Revenue Code of 1954, the 26 USC i et seq. accumulated profits of the Federal Home Loan Mortgage Corporation as of January 1, 1985, shall be treated as zero. (5) ADJUSTED BASIS.—For purposes of this subsection, the adjusted basis of any asset shall be determined under part II of subchapter O of the Internal Revenue Code of 1954. , » >^ j,« (6) No CARRYBACKS FOR YEARS BEFORE 1985.—No net Operating loss, capital loss, or excess credit of the Federal Home Loan Mortgage Corporation for any taxable year beginning after December 31, 1984, shall be allowed as a carryback to any taxable year beginning before January 1, 1985. (7) N o DEDUCTION ALLOWED FOR INTEREST ON REPLACEMENT OBLIGATIONS.—

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