Page:United States Statutes at Large Volume 98 Part 1.djvu/863

 PUBLIC LAW 98-369—JULY 18, 1984

98 STAT.

"(ii) INTEREST AS SHAREHOLDER WITH RESPECT TO

AMOUNTS BORROWED BY CORPORATION.—In the case of amounts borrowed by a corporation from a shareholder, subparagraph (A) shall not apply to an interest as a shareholder. "(C) RELATED PERSON DEFINED.—For purposes of subpara-

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graph (A), the term 'related person' has the meaning given such term by section 168(e)(4)." (d) EFFECTIVE DATE.—The amendments made by this section shall 26 USC 465 note. apply to taxable years beginning after December 31, 1983; except that any loss from an activity described in section 465(c)(7)(A) of the Internal Revenue Code of 1954 (as amended by this section) which Ante, p. 811. (but for the amendments made by this section) would have been treated as a deduction for the taxpayer's first taxable year beginning after December 31, 1983, under section 465(a)(2) of such Code shall be allowed as a deduction for such first taxable year notwithstanding such amendments.

Subtitle D—Miscellaneous Treasury Administrative Provisions

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PART I—PROVISIONS NOT RELATING TO DISTILLED SPIRITS TAX

SEC. 441. SIMPLIFICATION OF CERTAIN REPORTING REQUIREMENTS.

26 USC 936 note.

(a) REPORT ON POSSESSIONS CORPORATIONS.—The Secretary of the

Treasury shall, for the calendar year 1981 and each second calendar year thereafter, submit a report to the Congress within 24 months following the close of such calendar year setting forth an analysis of the operation and effect of sections 936 and 934(b) of the Internal Revenue Code of 1954.

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(b) HIGH INCOME TAXPAYER REPORT.—

(1) Section 2123 of the Tax Reform Act of 1976 is amended to 26 USC 56 note. read as follows: "SEC. 2123. HIGH INCOME TAXPAYER REPORT. "The Secretary of the Treasury shall publish annually information on the amount of tax paid by individual taxpayers with high total incomes. Total income for this purpose is to be calculated and set forth by adding to adjusted gross income any items of tax preference excluded from, or deducted in arriving at, adjusted gross income, and by subtracting any investment expenses incurred in the production of such income to the extent of the investment income. These data are to include the number of such individuals with total income over $200,000 who owe no Federal income tax (after credits) and the deductions, exclusions, or credits used by them to avoid tax." (2) The amendment made by paragraph (1) shall apply to 26 USC 56 note. information published after the date of the enactment of this Act. (c) INTERNATIONAL BOYCOTT REPORTS.—

(1) Section 1067 of the Tax Reform Act of 1976 is amended to 26 USC 999 note. read as follows:

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