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NOTES:


Source

(Added Pub. L. 94–12, title VI, § 602(d)(3)(A), Mar. 29, 1975, 89 Stat. 62; amended Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834; Pub. L. 99–514, title XII, § 1221(c)(3)(B), (C), Oct. 22, 1986, 100 Stat. 2553; Pub. L. 100–647, title I, § 1012(i)(11), Nov. 10, 1988, 102 Stat. 3509.)

References in Text

Section 955 (c)(2) (as in effect before the enactment of the Tax Reduction Act of 1975), referred to in subsecs. (a)(2) and (b)(5), refers to section 955 (c)(2) as added by Pub. L. 87–834, § 12(a), Oct. 16, 1962, 76 Stat. 1013, and as in effect from 1962 until the repeal of that section and the enactment of this section by Pub. L. 94–12.
The Tax Reduction Act of 1975, referred to in subsecs. (a)(2) and (b)(5), is Pub. L. 94–12, Mar. 29, 1975, 89 Stat. 26, as amended, which was enacted Mar. 29, 1975. For complete classification of this Act to the Code, see Short Title of 1975 Amendment note set out under section 1 of this title and Tables.

Prior Provisions

A prior section 955, added Pub. L. 87–834, § 12(a), Oct. 16, 1962, 76 Stat. 1013, related to investments in less developed countries and dealing with less developed country corporations, prior to repeal by Pub. L. 94–12, title VI, § 602(c)(5), Mar. 29, 1975, 89 Stat. 59.

Amendments

1988—Subsec. (a)(2)(A). Pub. L. 100–647 inserted “(to the extent such amount exceeds the sum of the decreases in qualified investments determined under this paragraph for prior taxable years beginning after 1986)” after “beginning before 1987”.
1986—Subsec. (a)(1)(A). Pub. L. 99–514, § 1221(c)(3)(B), inserted “beginning before 1987” after “all prior taxable years”.
Subsec. (a)(2)(A). Pub. L. 99–514, § 1221(c)(3)(C), substituted “as of the close of the last taxable year beginning before 1987” for “at the close of the preceding taxable year”.
1976—Subsec. (b)(2), (3). Pub. L. 94–455 struck out “or his delegate” after “Secretary” wherever appearing.

Effective Date of 1988 Amendment

Amendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.

Effective Date of 1986 Amendment

Amendment by Pub. L. 99–514 applicable to taxable years of foreign corporations beginning after Dec. 31, 1986, except as otherwise provided, see section 1221(g) of Pub. L. 99–514, set out as a note under section 954 of this title.

Effective Date

Section 602(f) of Pub. L. 94–12, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “The amendments made by this section [enacting this section, amending sections 851, 902, 951, and 954 of this title, and repealing section 963 and former section 955 of this title] shall apply to taxable years of foreign corporations beginning after December 31, 1975, and to taxable years of United States shareholders (within the meaning of 951(b) of the Internal Revenue Code of 1986 [formerly I.R.C. 1954]) within which or with which such taxable years of such foreign corporations end.”


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