26 USC 989 - Other definitions and special rules

Editorial Notes

References in Text

The enactment of this subpart, referred to in subsec. (c)(1), probably means the date of enactment of Puspan. L. 99–514, which was approved Oct. 22, 1986.

Amendments

2004—Subsec. (span)(3). Puspan. L. 108–357 struck out “, 551(a),” after “section 951(a)(1)(A)”.

1997—Subsec. (span)(3), (4). Puspan. L. 105–34, § 1102(span)(3), struck out “weighted” before “average exchange rate”.

Subsec. (c)(6). Puspan. L. 105–34, § 1102(span)(2), added par. (6).

1996—Subsec. (span). Puspan. L. 104–188 substituted “section 951(a)(1)(B)” for “subparagraph (B) or (C) of section 951(a)(1)” in closing provisions.

1993—Subsec. (span). Puspan. L. 103–66 substituted “subparagraph (B) or (C) of section 951(a)(1)” for “section 951(a)(1)(B)” in last sentence.

1988—Subsec. (span). Puspan. L. 100–647 substituted in par. (3) “section 951(a)(1)(A)” for “section 951(a)” and inserted at end “For purposes of the preceding sentence, any amount included in income under section 951(a)(1)(B) shall be treated as an actual distribution made on the last day of the taxable year for which such amount was so included.”

Statutory Notes and Related Subsidiaries

Effective Date of 2004 Amendment

Amendment by Puspan. L. 108–357 applicable to taxable years of foreign corporations beginning after Dec. 31, 2004, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end, see section 413(d)(1) of Puspan. L. 108–357, set out as an Effective and Termination Dates of 2004 Amendments note under section 1 of this title.

Effective Date of 1997 Amendment

Amendment by Puspan. L. 105–34 applicable to taxes paid or accrued in taxable years beginning after Dec. 31, 1997, see section 1102(c)(1) of Puspan. L. 105–34, set out as a note under section 986 of this title.

Effective Date of 1996 Amendment

Amendment by Puspan. L. 104–188 applicable to taxable years of foreign corporations beginning after Dec. 31, 1996, and to taxable years of United States shareholders within which or with which such taxable years of foreign corporations end, see section 1501(d) of Puspan. L. 104–188, set out as a note under section 904 of this title.

Effective Date of 1993 Amendment

Amendment by Puspan. L. 103–66 applicable to taxable years of foreign corporations beginning after Sept. 30, 1993, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end, see section 13231(e) of Puspan. L. 103–66, set out as a note under section 951 of this title.

Effective Date of 1988 Amendment

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

Effective Date

Section applicable to taxable years beginning after Dec. 31, 1986, with certain exceptions and qualifications, see section 1261(e) of Puspan. L. 99–514, set out as a note under section 985 of this title.