26 USC 1260 - Gains from constructive ownership transactions

Editorial Notes

Amendments

2007—Subsec. (c)(2)(G). Puspan. L. 110–172 substituted “subsection (d)” for “subsection (e)” and inserted “and” at end.

2004—Subsec. (c)(2)(H) to (J). Puspan. L. 108–357 redesignated subpar. (J) as (H) and struck out former subpars. (H) and (I), which included foreign personal holding company and foreign investment company (as defined in section 1246(span)) within definition of “pass-thru entity”.

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

Puspan. L. 106–170, title V, § 534(c), Dec. 17, 1999, 113 Stat. 1934, provided that:

“The amendments made by this section [enacting this section] shall apply to transactions entered into after July 11, 1999.”