333
‘‘(E) REGULATIONS.—The Secretary shall
prescribe such regulations as may be necessary
or appropriate to carry out the purposes of this
paragraph, including regulations for the appli-
cation of this paragraph in the case of income
paid through 1 or more entities or between 2 or
more chains of entities.’’
(b) EFFECTIVE DATE.—The amendments made by
this section shall apply to—
(1) dividends paid out of earnings and profits
of foreign corporations for taxable years beginning
after December 31, 1993, and
(2) amounts included in gross income under
section 951(a)(1)(A) of the Internal Revenue Code
of 1986 in respect of any such taxable year.
SEC. 902. SPECIAL RULES FOR RENTAL USE OF DWELLING
FOR LESS THAN 15 DAYS PER YEAR.
(a) IN GENERAL.—Section 280A is amended by
striking subsection (g) and inserting:
‘‘(g) SPECIAL RULE FOR CERTAIN RENTAL USE.—
Notwithstanding any other provision of this section or sec-
tion 183, if the principal residence of the taxpayer is actu-
ally rented for less than 15 days during the taxable year
for the purpose of providing accommodations to visitors
to an event for which commercial rental accommodations
334
in the community holding the event are not sufficient to
reasonably provide more than one-half of the accommoda-
tions necessary (and the rental income received by the tax-
payer for any visitor is not greater than a reasonable rent-
al rate charged per individual guest by commercial rental
accommodations), then—
‘‘(1) no deduction otherwise allowable under
this chapter because of the rental use of such dwell-
ing unit shall be allowed, and
‘‘(2) the income derived from such use for the
taxable year shall not be included in the gross in-
come of such taxpayer under section 61.
‘‘(h) REGULATIONS.—The Secretary shall prescribe
such regulations as may be appropriate to carry out the
purposes of this section, including regulations providing
such de minimis rules as the Secretary may deem appro-
priate.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to taxable years beginning after
December 31, 1993.
SEC. 903. LOSS CARRYOVERS AND CARRYBACKS NOT EX-
CLUDED IN APPLYING TAXABLE INCOME LIM-
ITATION ON CERTAIN RESERVE DEDUCTIONS.
(a) GENERAL RULE.—Subparagraph (D) of section
593(b)(2) (relating to computation of taxable income) is
335
amended by adding at the end thereof the following new
sentence:
‘‘Except as providing in the preceding sentence,
for purposes of this paragraph, taxable income
shall be computed as provided in this chapter,
including the application of any carryover or
carryback.’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to losses incurred in taxable
years ending after December 31, 1993.
SEC. 904. EXTENSION OF WITHHOLDING TO CERTAIN GAM-
BLING WINNINGS.
(a) REPEAL
OF
EXEMPTION
FOR
BINGO
AND
KENO.—Paragraph (5) of section 3402(q) is amended to
read as follows:
‘‘(5) EXEMPTION FOR SLOT MACHINES.—The
tax imposed by paragraph (1) shall not apply to
winnings from a slot machine.’’
(b) THRESHOLD AMOUNT.—Paragraph (3) of section
3402(q) is amended—
(1) by striking ‘‘(B) and (C)’’ in subparagraph
(A) and inserting ‘‘(B), (C), and (D)’’, and
(2) by adding at the end thereof the following
new subparagraph:
336
‘‘(D) BINGO
AND
KENO.—Proceeds of
more than $10,000 from a wager placed in a
bingo or keno game.’’
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect on January 1, 1994.
TITLE X—TECHNICAL
CORRECTIONS
Subtitle A—Revenue Provisions
SEC. 1001. AMENDMENTS RELATED TO REVENUE REC-
ONCILIATION ACT OF 1990.
(a) AMENDMENTS RELATED TO SUBTITLE A.—
(1) Subparagraph (B) of section 59(j)(3) is
amended by striking ‘‘section 1(i)(3)(B)’’ and insert-
ing ‘‘section 1(g)(3)(B)’’.
(2) Clause (i) of section 151(d)(3)(C) is amend-
ed by striking ‘‘joint of a return’’ and inserting
‘‘joint return’’.
(3) Subsection (b) of section 1 (as in effect on
the day before the date of the enactment of the Rev-
enue Reconciliation Act of 1993) is amended by
striking ‘‘$26,500’’ in the table contained therein
and inserting ‘‘$26,050’’.
(b) AMENDMENTS RELATED TO SUBTITLE B.—
(1) Paragraph (1) of section 11212(e) of the
Revenue Reconciliation Act of 1990 is amended by
337
striking ‘‘Paragraph (1) of section 6724(d)’’ and in-
serting ‘‘Subparagraph (B) of section 6724(d)(1)’’.
(2)(A) Subparagraph (B) of section 4093(c)(2),
as in effect before the amendments made by the
Revenue Reconciliation Act of 1993, is amended is
amended by inserting before the period ‘‘unless such
fuel is sold for exclusive use by a State or any politi-
cal subdivision thereof’’.
(B) Paragraph (4) of section 6427(l), as in ef-
fect before the amendments made by the Revenue
Reconciliation Act of 1993, is amended by inserting
before the period ‘‘unless such fuel was used by a
State or any political subdivision thereof’’.
(3) Paragraph (1) of section 6416(b) is amend-
ed by striking ‘‘chapter 32 or by section 4051’’ and
inserting ‘‘chapter 31 or 32’’.
(4) Section 7012 is amended—
(A) by striking ‘‘production or importation
of gasoline’’ in paragraph (3) and inserting
‘‘taxes on gasoline and diesel fuel’’, and
(B) by striking paragraph (4) and redesig-
nating paragraphs (5) and (6) as paragraphs
(4) and (5), respectively.
338
(5) Subsection (c) of section 5041 is amended
by striking paragraph (6) and by inserting the fol-
lowing new paragraphs:
‘‘(6) CREDIT FOR TRANSFEREE IN BOND.—If—
‘‘(A) wine produced by any person would
be eligible for any credit under paragraph (1)
if removed by such person during the calendar
year,
‘‘(B) wine produced by such person is re-
moved during such calendar year by any other
person (hereafter in this paragraph referred to
as the ‘transferee’) to whom such wine was
transferred in bond and who is liable for the tax
imposed by this section with respect to such
wine, and
‘‘(C) such producer holds title to such wine
at the time of its removal and provides to the
transferee such information as is necessary to
properly determine the transferee’s credit under
this paragraph,
then, the transferee (and not the producer) shall be
allowed the credit under paragraph (1) which would
be allowed to the producer if the wine removed by
the transferee had been removed by the producer on
that date.
339
‘‘(7) REGULATIONS.—The Secretary may pre-
scribe such regulations as may be necessary to carry
out the purposes of this subsection, including regula-
tions—
‘‘(A) to prevent the credit provided in this
subsection from benefiting any person who pro-
duces more than 250,000 wine gallons during a
calendar year, and
‘‘(B) to assure proper reduction of such
credit for persons producing more than 150,000
wine gallons of wine during a calendar year.’’
(6) Paragraph (3) of section 5061(b) is amend-
ed to read as follows:
‘‘(3) section 5041(f),’’.
(7) Section 5354 is amended by inserting ‘‘(tak-
ing into account the appropriate amount of credit
with respect to such wine under section 5041(c))’’
after ‘‘any one time’’.
(8) Effective on the date of the enactment of
this Act, paragraph (7) of section 11202(i) of the
Revenue Reconciliation Act of 1990 is amended by
adding at the end thereof the following: ‘‘The Sec-
retary may treat any person who bore the ultimate
burden of the tax imposed by this subsection as the
340
person to whom a credit or refund under such provi-
sions may be allowed or made.’’.
(c) AMENDMENTS RELATED TO SUBTITLE C.—
(1) Paragraph (4) of section 56(g) is amended
by redesignating subparagraphs (I) and (J) as sub-
paragraphs (H) and (I), respectively.
(2) Subparagraph (B) of section 6724(d)(1) is
amended—
(A) by striking ‘‘or’’ at the end of clause
(xii), and
(B) by striking the period at the end of
clause (xiii) and inserting ‘‘, or’’.
(3) Subsection (g) of section 6302 is amended
by inserting ‘‘, 22,’’ after ‘‘chapters 21’’.
(4) The earnings and profits of any insurance
company to which section 11305(c)(3) of the Reve-
nue Reconciliation Act of 1990 applies shall be de-
termined without regard to any deduction allowed
under such section; except that, for purposes of ap-
plying sections 56 and 902, and subpart F of part
III of subchapter N of chapter 1 of the Internal
Revenue Code of 1986, such deduction shall be
taken into account.
(5) Subparagraph (D) of section 6038A(e)(4) is
amended—
341
(A) by striking ‘‘any transaction to which
the summons relates’’ and inserting ‘‘any af-
fected taxable year’’, and
(B) by adding at the end thereof the fol-
lowing new sentence: ‘‘For purposes of this sub-
paragraph, the term ‘affected taxable year’
means any taxable year if the determination of
the amount of tax imposed for such taxable
year is affected by the treatment of the trans-
action to which the summons relates.’’.
(6) Subparagraph (A) of section 6621(c)(2) is
amended by adding at the end thereof the following
new sentence: ‘‘The preceding sentence shall be ap-
plied without regard to any such letter or notice
which is withdrawn by the Secretary.’’.
(7) Clause (i) of section 6621(c)(2)(B) is
amended by striking ‘‘this subtitle’’ and inserting
‘‘this title’’.
(d) AMENDMENTS RELATED TO SUBTITLE D.—
(1) Notwithstanding section 11402(c) of the
Revenue Reconciliation Act of 1990, the amendment
made by section 11402(b)(1) of such Act shall apply
to taxable years ending after December 31, 1989.
(2) Clause (ii) of section 143(m)(4)(C) is
amended—
342
(A) by striking ‘‘any month of the 10-year
period’’ and inserting ‘‘any year of the 4-year
period’’,
(B) by striking ‘‘succeeding months’’ and
inserting ‘‘succeeding years’’, and
(C) by striking ‘‘over the remainder of
such period (or, if lesser, 5 years)’’ and insert-
ing ‘‘to zero over the succeeding 5 years’’.
(e) AMENDMENTS RELATED TO SUBTITLE E.—
(1)(A) Clause (ii) of section 56(d)(1)(B) is
amended to read as follows:
‘‘(ii) appropriate adjustments in the
application of section 172(b)(2) shall be
made to take into account the limitation of
subparagraph (A).’’
(B) For purposes of applying sections 56(g)(1)
and 56(g)(3) of the Internal Revenue Code of 1986
with respect to taxable years beginning in 1991 and
1992, the reference in such sections to the alter-
native tax net operating loss deduction shall be
treated as including a reference to the deduction
under section 56(h) of such Code as in effect before
the amendments made by section 1915 of the En-
ergy Policy Act of 1992.
343
(2) Clause (i) of section 613A(c)(3)(A) is
amended by striking ‘‘the table contained in’’.
(3) Section 6501 is amended—
(A) by striking subsection (m) (relating to
deficiency attributable to election under section
44B) and by redesignating subsections (n) and
(o) as subsections (m) and (n), respectively, and
(B) by striking ‘‘section 40(f) or 51(j)’’ in
subsection (m) (as redesignated by subpara-
graph (A)) and inserting ‘‘section 40(f), 43, or
51(j)’’.
(4) Subparagraph (C) of section 38(c)(2) (as in
effect on the day before the date of the enactment
of the Revenue Reconciliation Act of 1990) is
amended by inserting before the period at the end
of the first sentence the following: ‘‘and without re-
gard to the deduction under section 56(h)’’.
(5) 
The 
amendment 
made 
by 
section
1913(b)(2)(C)(i) of the Energy Policy Act of 1992
shall apply to taxable years beginning after Decem-
ber 31, 1990.
(f) AMENDMENTS RELATED TO SUBTITLE F.—
(1)(A) Section 2701(a)(3) is amended by add-
ing at the end thereof the following new subpara-
graph:
344
‘‘(C) VALUATION OF QUALIFIED PAYMENTS
WHERE NO LIQUIDATION, ETC. RIGHTS.—In the
case of an applicable retained interest which is
described in subparagraph (B)(i) but not sub-
paragraph (B)(ii), the value of the distribution
right shall be determined without regard to this
section.’’
(B) Section 2701(a)(3)(B) is amended by in-
serting ‘‘CERTAIN’’ before ‘‘QUALIFIED’’ in the head-
ing thereof.
(C) Sections 2701 (d)(1) and (d)(4) are each
amended by striking ‘‘subsection (a)(3)(B)’’ and in-
serting ‘‘subsection (a)(3) (B) or (C)’’.
(2) Clause (i) of section 2701(a)(4)(B) is
amended by inserting ‘‘(or, to the extent provided in
regulations, the rights as to either income or cap-
ital)’’ after ‘‘income and capital’’.
(3)(A) Section 2701(b)(2) is amended by add-
ing at the end thereof the following new subpara-
graph:
‘‘(C) APPLICABLE FAMILY MEMBER.—For
purposes of this subsection, the term ‘applicable
family member’ includes any lineal descendant
of any parent of the transferor or the transfer-
or’s spouse.’’
345
(B) Section 2701(e)(3) is amended—
(i) by striking subparagraph (B), and
(ii) by striking so much of paragraph (3)
as precedes ‘‘shall be treated as holding’’ and
inserting:
‘‘(3) ATTRIBUTION
OF
INDIRECT
HOLDINGS
AND TRANSFERS.—An individual’’.
(C) Section 2704(c)(3) is amended by striking
‘‘section 2701(e)(3)(A)’’ and inserting ‘‘section
2701(e)(3)’’.
(4) Clause (i) of section 2701(c)(1)(B) is
amended to read as follows:
‘‘(i) a right to distributions with re-
spect to any interest which is junior to the
rights of the transferred interest,’’.
(5)(A) Clause (i) of section 2701(c)(3)(C) is
amended to read as follows:
‘‘(i) IN
GENERAL.—Payments under
any interest held by a transferor which
(without regard to this subparagraph) are
qualified payments shall be treated as
qualified payments unless the transferor
elects not to treat such payments as quali-
fied payments. Payments described in the
preceding sentence which are held by an
346
applicable family member shall be treated
as qualified payments only if such member
elects to treat such payments as qualified
payments.’’
(B) 
The 
first 
sentence 
of 
section
2701(c)(3)(C)(ii) is amended to read as follows: ‘‘A
transferor or applicable family member holding any
distribution right which (without regard to this sub-
paragraph) is not a qualified payment may elect to
treat such right as a qualified payment, to be paid
in the amounts and at the times specified in such
election.’’.
(C) The time for making an election under the
second sentence of section 2701(c)(3)(C)(i) of the
Internal Revenue Code of 1986 (as amended by sub-
paragraph (A)) shall not expire before the due date
(including extensions) for filing the transferor’s re-
turn of the tax imposed by section 2501 of such
Code for the first calendar year ending after the
date of enactment.
(6) Section 2701(d)(3)(A)(iii) is amended by
striking ‘‘the period ending on the date of’’.
(7) Subclause (I) of section 2701(d)(3)(B)(ii) is
amended by inserting ‘‘or the exclusion under sec-
tion 2503(b),’’ after ‘‘section 2523,’’.
347
(8) Section 2701(e)(5) is amended—
(A) by striking ‘‘such contribution to cap-
ital or such redemption, recapitalization, or
other change’’ in subparagraph (A) and insert-
ing ‘‘such transaction’’, and
(B) by striking ‘‘the transfer’’ in subpara-
graph (B) and inserting ‘‘such transaction’’.
(9) Section 2701(d)(4) is amended by adding at
the end thereof the following new subparagraph:
‘‘(C) TRANSFER
TO
TRANSFERORS.—In
the case of a taxable event described in para-
graph (3)(A)(ii) involving a transfer of an ap-
plicable retained interest from an applicable
family member to a transferor, this subsection
shall continue to apply to the transferor during
any period the transferor holds such interest.’’
(10) Section 2701(e)(6) is amended by insert-
ing ‘‘or to reflect the application of subsection (d)’’
before the period at the end thereof.
(11)(A) Section 2702(a)(3)(A) is amended—
(i) by striking ‘‘to the extent’’ and insert-
ing ‘‘if’’ in clause (i),
(ii) by striking ‘‘or’’ at the end of clause
(i),
348
(iii) by striking the period at the end of
clause (ii) and inserting ‘‘, or’’, and
(iv) by adding at the end thereof the fol-
lowing new clause:
‘‘(iii) to the extent that regulations
provide that such transfer is not inconsist-
ent with the purposes of this section.’’
(B)(i) Section 2702(a)(3) is amended by strik-
ing ‘‘incomplete transfer’’ each place it appears and
inserting ‘‘incomplete gift’’.
(ii) The heading for section 2702(a)(3)(B) is
amended by striking ‘‘INCOMPLETE TRANSFER’’ and
inserting ‘‘INCOMPLETE GIFT’’.
(g) AMENDMENTS RELATED TO SUBTITLE G.—
(1)(A) Subsection (a) of section 1248 is amend-
ed—
(i) by striking ‘‘, or if a United States per-
son receives a distribution from a foreign cor-
poration which, under section 302 or 331, is
treated as an exchange of stock’’ in paragraph
(1), and
(ii) by adding at the end thereof the follow-
ing new sentence: ‘‘For purposes of this section,
a United States person shall be treated as hav-
ing sold or exchanged any stock if, under any
349
provision of this subtitle, such person is treated
as realizing gain from the sale or exchange of
such stock.’’.
(B) Paragraph (1) of section 1248(e) is amend-
ed by striking ‘‘, or receives a distribution from a
domestic corporation which, under section 302 or
331, is treated as an exchange of stock’’.
(C) Subparagraph (B) of section 1248(f)(1) is
amended by striking ‘‘or 361(c)(1)’’ and inserting
‘‘355(c)(1), or 361(c)(1)’’.
(D) Paragraph (1) of section 1248(i) is amend-
ed to read as follows:
‘‘(1) IN GENERAL.—If any shareholder of a 10-
percent corporate shareholder of a foreign corpora-
tion exchanges stock of the 10-percent corporate
shareholder for stock of the foreign corporation,
such 10-percent corporate shareholder shall recog-
nize gain in the same manner as if the stock of the
foreign corporation received in such exchange had
been—
‘‘(A) issued to the 10-percent corporate
shareholder, and
‘‘(B) then distributed by the 10-percent
corporate shareholder to such shareholder in re-
350
demption or liquidation (whichever is appro-
priate).
The amount of gain recognized by such 10-percent
corporate shareholder under the preceding sentence
shall not exceed the amount treated as a dividend
under this section.’’
(2) Section 897 is amended by striking sub-
section (f).
(3) Paragraph (13) of section 4975(d) is
amended by striking ‘‘section 408(b)’’ and inserting
‘‘section 408(b)(12)’’.
(4) Clause (iii) of section 56(g)(4)(D) is amend-
ed by inserting ‘‘, but only with respect to taxable
years beginning after December 31, 1989’’ before
the period at the end thereof.
(5)(A) Paragraph (11) of section 11701(a) of
the Revenue Reconciliation Act of 1990 (and the
amendment made by such paragraph) are hereby re-
pealed, and section 7108(r)(2) of the Revenue Rec-
onciliation Act of 1989 shall be applied as if such
paragraph (and amendment) had never been en-
acted.
(B) Subparagraph (A) shall not apply to any
building if the owner of such building establishes to
the satisfaction of the Secretary of the Treasury or
351
his delegate that such owner reasonably relied on the
amendment made by such paragraph (11).
(h) AMENDMENTS RELATED TO SUBTITLE H.—
(1)(A) Clause (vi) of section 168(e)(3)(B) is
amended by striking ‘‘or’’ at the end of subclause
(I), by striking the period at the end of subclause
(II) and inserting ‘‘, or’’, and by adding at the end
thereof the following new subclause:
‘‘(III) 
is 
described 
in 
section
48(l)(3)(A)(ix) (as in effect on the day be-
fore the date of the enactment of the Reve-
nue Reconciliation Act of 1990).’’
(B) Subparagraph (K) of section 168(g)(4) is
amended by striking ‘‘section 48(a)(3)(A)(iii)’’ and
inserting ‘‘section 48(l)(3)(A)(ix) (as in effect on the
day before the date of the enactment of the Revenue
Reconciliation Act of 1990)’’.
(2) Clause (ii) of section 172(b)(1)(E) is
amended by striking ‘‘subsection (m)’’ and inserting
‘‘subsection (h)’’.
(3) Sections 805(a)(4)(E), 832(b)(5)(C)(ii)(II),
and 832(b)(5)(D)(ii)(II) are each amended by strik-
ing ‘‘243(b)(5)’’ and inserting ‘‘243(b)(2)’’.
(4) Subparagraph (A) of section 243(b)(3) is
amended by inserting ‘‘of’’ after ‘‘In the case’’.
352
(5) The subsection heading for subsection (a) of
section 280F is amended by striking ‘‘INVESTMENT
TAX CREDIT AND’’.
(6) Clause (i) of section 1504(c)(2)(B) is
amended by inserting ‘‘section’’ before ‘‘243(b)(2)’’.
(7) Paragraph (3) of section 341(f) is amended
by striking ‘‘351, 361, 371(a), or 374(a)’’ and in-
serting ‘‘351, or 361’’.
(8) Paragraph (2) of section 243(b) is amended
to read as follows:
‘‘(2) AFFILIATED GROUP.—For purposes of this
subsection:
‘‘(A) IN
GENERAL.—The term ‘affiliated
group’ has the meaning given such term by sec-
tion 1504(b), except that for such purposes sec-
tions 1504(b)(2), 1504(b)(4), and 1504(c) shall
not apply.
‘‘(B) GROUP
MUST
BE
CONSISTENT
IN
FOREIGN TAX TREATMENT.—The requirements
of paragraph (1)(A) shall not be treated as
being met with respect to any dividend received
by a corporation if, for any taxable year which
includes the day on which such dividend is re-
ceived—
353
‘‘(i) 1 or more members of the affili-
ated group referred to in paragraph (1)(A)
choose to any extent to take the benefits of
section 901, and
‘‘(ii) 1 or more other members of such
group claim to any extent a deduction for
taxes otherwise creditable under section
901.’’
(9) 
The 
amendment 
made 
by 
section
11813(b)(17) of the Revenue Reconciliation Act of
1990 shall be applied as if the material stricken by
such amendment included the closing parenthesis
after ‘‘section 48(a)(5)’’.
(10) Paragraph (1) of section 179(d) is amend-
ed—
(A) by striking ‘‘in a trade or business’’
and inserting ‘‘a trade or business’’, and
(B) by adding at the end thereof the fol-
lowing new sentence: ‘‘Such term shall not in-
clude any property described in section 50(b)
and shall not include air conditioning or heating
units and horses’’.
(11) Subparagraph (E) of section 50(a)(2) is
amended by striking ‘‘section 48(a)(5)(A)’’ and in-
serting ‘‘section 48(a)(5)’’.
354
(12) 
The 
amendment 
made 
by 
section
11801(c)(9)(G)(ii) of the Revenue Reconciliation Act
of 1990 shall be applied as if it struck ‘‘Section
422A(c)(2)’’ and inserted ‘‘Section 422(c)(2)’’.
(13) Subparagraph (B) of section 424(c)(3) is
amended by striking ‘‘a qualified stock option, an in-
centive stock option, an option granted under an em-
ployee stock purchase plan, or a restricted stock op-
tion’’ and inserting ‘‘an incentive stock option or an
option granted under an employee stock purchase
plan’’.
(14) Subparagraph (E) of section 1367(a)(2) is
amended by striking ‘‘section 613A(c)(13)(B)’’ and
inserting ‘‘section 613A(c)(11)(B)’’.
(15) Subparagraph (B) of section 460(e)(6) is
amended by striking ‘‘section 167(k)’’ and inserting
‘‘section 168(e)(2)(A)(ii)’’.
(16) Subparagraph (C) of section 172(h)(4) is
amended by striking ‘‘subsection (b)(1)(M)’’ and in-
serting ‘‘subsection (b)(1)(E)’’.
(17) Section 6503 is amended—
(A) by redesignating the subsection relat-
ing to extension in case of certain summonses
as subsection (j), and
355
(B) by redesignating the subsection relat-
ing to cross references as subsection (k).
(18) Paragraph (4) of section 1250(e) is hereby
repealed.
(19) Subsection (c) of section 2104 is amended
by striking ‘‘subparagraph (A), (C), or (D)’’ and in-
serting ‘‘subparagraph (A)’’.
(i) EFFECTIVE DATE.—Except as otherwise expressly
provided—
(1) the amendments made by this section shall
be treated as amendments to the Internal Revenue
Code of 1986 as amended by the Revenue Reconcili-
ation Act of 1993; and
(2) any amendment made by this section shall
apply to periods before the date of the enactment of
this section in the same manner as if it had been in-
cluded in the provision of the Revenue Reconciliation
Act of 1990 to which such amendment relates.
SEC. 1002. AMENDMENTS RELATED TO REVENUE REC-
ONCILIATION ACT OF 1993.
(a) AMENDMENT RELATED TO SECTION 13114.—
Paragraph (2) of section 1044(c) is amended to read as
follows:
‘‘(2) PURCHASE.—The taxpayer shall be consid-
ered to have purchased any property if, but for sub-
361
‘‘(B) for any period before January 1,
2001, during which the rates of tax under sec-
tion 4081(a)(2)(A) are 4.3 cents per gallon.’’
(l) AMENDMENT RELATED TO SECTION 13261.—
Clause (iii) of section 13261(g)(2)(A) of the Revenue Rec-
onciliation Act of 1993 is amended by striking ‘‘by the
taxpayer’’ and inserting ‘‘by the taxpayer or a related per-
son’’.
(m) AMENDMENT RELATED TO SECTION 13301.—
Subparagraph (B) of section 1397B(d)(5) is amended by
striking ‘‘preceding’’.
(n) CLERICAL AMENDMENTS.—
(1) Subsection (d) of section 39 is amended—
(A) by striking ‘‘45’’ in the heading of
paragraph (5) and inserting ‘‘45A’’, and
(B) by striking ‘‘45’’ in the heading of
paragraph (6) and inserting ‘‘45B’’.
(2) Subparagraph (A) of section 108(d)(9) is
amended by striking ‘‘paragraph (3)(B)’’ and insert-
ing ‘‘paragraph (3)(C)’’.
(3) Subparagraph (C) of section 143(d)(2) is
amended by striking the period at the end thereof
and inserting a comma.
(4) Clause (ii) of section 163(j)(6)(E) is amend-
ed by striking ‘‘which is a’’ and inserting ‘‘which is’’.
362
(5) Subparagraph (A) of section 1017(b)(4) is
amended by striking ‘‘subsection (b)(2)(D)’’ and in-
serting ‘‘subsection (b)(2)(E)’’.
(6) So much of section 1245(a)(3) as precedes
subparagraph (A) thereof is amended to read as fol-
lows:
‘‘(3) SECTION 1245 PROPERTY.—For purposes
of this section, the term ‘section 1245 property’
means any property which is or has been property
of a character subject to the allowance for deprecia-
tion provided in section 167 and is either—’’.
(7) Paragraph (2) of section 1394(e) is amend-
ed—
(A) by striking ‘‘(i)’’ and inserting ‘‘(A)’’,
and
(B) by striking ‘‘(ii)’’ and inserting ‘‘(B)’’.
(8) Subsection (m) of section 6501 (as redesig-
nated by section 1001) is amended by striking ‘‘or
51(j)’’ and inserting ‘‘45B, or 51(j)’’.
(9)(A) The section 6714 added by section
13242(b)(1) of the Revenue Reconciliation Act of
1993 is hereby redesignated as section 6715.
(B) The table of sections for part I of sub-
chapter B of chapter 68 is amended by striking
363
‘‘6714’’ in the item added by such section
13242(b)(2) of such Act and inserting ‘‘6715’’.
(10) Paragraph (2) of section 9502(b) is
amended by inserting ‘‘and before’’ after ‘‘1982,’’.
(11) Subsections (a)(2) and (a)(3) of section
13206 of the Revenue Reconciliation Act of 1993
are each amended by striking ‘‘this section’’ and in-
serting ‘‘this subsection’’.
(12) Paragraph (1) of section 13215(c) of the
Revenue Reconciliation Act of 1993 is amended by
striking ‘‘Public Law 92–21’’ and inserting ‘‘Public
Law 98–21’’.
(13) Paragraph (2) of section 13311(e) of the
Revenue Reconciliation Act of 1993 is amended by
striking ‘‘section 1393(a)(3)’’ and inserting ‘‘section
1393(a)(2)’’.
(14) Subparagraph (B) of section 117(d)(2) is
amended by striking ‘‘section 132(f)’’ and inserting
‘‘section 132(h)’’.
(o) EFFECTIVE DATE.—Any amendment made by
this section shall take effect as if included in the provision
of the Revenue Reconciliation Act of 1993 to which such
amendment relates.
364
SEC. 1003. MISCELLANEOUS PROVISIONS.
(a) APPLICATION OF AMENDMENTS MADE BY TITLE
XII OF OMNIBUS BUDGET RECONCILIATION ACT
OF
1990.—Except as otherwise expressly provided, whenever
in title XII of the Omnibus Budget Reconciliation Act of
1990 an amendment or repeal is expressed in terms of
an amendment to, or repeal of, a section or other provi-
sion, the reference shall be considered to be made to a
section or other provision of the Internal Revenue Code
of 1986.
(b) TREATMENT
OF CERTAIN AMOUNTS UNDER
HEDGE BOND RULES.—
(1) Clause (iii) of section 149(g)(3)(B) is
amended to read as follows:
‘‘(iii) AMOUNTS HELD PENDING REIN-
VESTMENT
OR
REDEMPTION.—Amounts
held for not more than 30 days pending re-
investment or bond redemption shall be
treated as invested in bonds described in
clause (i).’’
(2) The amendment made by paragraph (1)
shall take effect as if included in the amendments
made by section 7651 of the Omnibus Budget Rec-
onciliation Act of 1989.
(c) 
TREATMENT
OF
CERTAIN
DISTRIBUTIONS
UNDER SECTION 1445.—
365
(1) IN
GENERAL.—Paragraph (3) of section
1445(e) is amended by adding at the end thereof
the following new sentence: ‘‘Rules similar to the
rules of the preceding provisions of this paragraph
shall apply in the case of any distribution to which
section 301 applies and which is not made out of the
earnings and profits of such a domestic corpora-
tion.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall apply to distributions after
the date of the enactment of this Act.
(d) TREATMENT OF CERTAIN CREDITS UNDER SEC-
TION 469.—
(1) IN GENERAL.—Subparagraph (B) of section
469(c)(3) is amended by adding at the end thereof
the following new sentence: ‘‘If the preceding sen-
tence applies to the net income from any property
for any taxable year, any credits allowable under
subpart B (other than section 27(a)) or D of part
IV of subchapter A for such taxable year which are
attributable to such property shall be treated as
credits not from a passive activity to the extent the
amount of such credits does not exceed the regular
tax liability of the taxpayer for the taxable year
which is allocable to such net income.’’
366
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall apply to taxable years begin-
ning after December 31, 1986.
(e) TREATMENT OF DISPOSITIONS UNDER PASSIVE
LOSS RULES.—
(1) IN GENERAL.—Subparagraph (A) of section
469(g)(1) is amended to read as follows:
‘‘(A) IN GENERAL.—If all gain or loss real-
ized on such disposition is recognized, the ex-
cess of—
‘‘(i) any loss from such activity for
such taxable year (determined after the ap-
plication of subsection (b)), over
‘‘(ii) any net income or gain for such
taxable year from all other passive activi-
ties (determined after the application of
subsection (b)),
shall be treated as a loss which is not from a
passive activity.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall apply to taxable years begin-
ning after December 31, 1986.
(f) MISCELLANEOUS AMENDMENTS
TO FOREIGN
PROVISIONS.—
367
(1) COORDINATION OF UNIFIED ESTATE TAX
CREDIT WITH TREATIES.—Subparagraph (A) of sec-
tion 2102(c)(3) is amended by adding at the end
thereof the following new sentence: ‘‘For purposes
of the preceding sentence, property shall not be
treated as situated in the United States if such
property is exempt from the tax imposed by this
subchapter under any treaty obligation of the United
States.’’
(2) TREATMENT OF CERTAIN INTEREST PAID
TO RELATED PERSON.—
(A) IN
GENERAL.—Subparagraph (B) of
section 163(j)(1) is amended by inserting before
the period at the end thereof the following:
‘‘(and clause (ii) of paragraph (2)(A) shall not
apply for purposes of applying this subsection
to the amount so treated)’’.
(B) EFFECTIVE
DATE.—The amendment
made by subparagraph (A) shall apply as if in-
cluded in the amendments made by section
7210(a) of the Revenue Reconciliation Act of
1989.
(3) TREATMENT OF INTEREST ALLOCABLE TO
EFFECTIVELY CONNECTED INCOME.—
(A) IN GENERAL.—
368
(i) Subparagraph (B) of section
884(f)(1) is amended by striking ‘‘to the
extent’’ and all that follows down through
‘‘subparagraph (A)’’ and inserting ‘‘to the
extent that the allocable interest exceeds
the interest described in subparagraph
(A)’’.
(ii) The second sentence of section
884(f)(1) is amended by striking ‘‘reason-
ably expected’’ and all that follows down
through the period at the end thereof and
inserting ‘‘reasonably expected to be alloca-
ble interest.’’
(iii) Paragraph (2) of section 884(f) is
amended to read as follows:
‘‘(2) ALLOCABLE INTEREST.—For purposes of
this subsection, the term ‘allocable interest’ means
any interest which is allocable to income which is ef-
fectively connected (or treated as effectively con-
nected) with the conduct of a trade or business in
the United States.’’
(B) EFFECTIVE DATE.—The amendments
made by subparagraph (A) shall take effect as
if included in the amendments made by section
1241(a) of the Tax Reform Act of 1986.
369
(4) CLARIFICATION OF SOURCE RULE.—
(A) IN GENERAL.—Paragraph (2) of sec-
tion 865(b) is amended by striking ‘‘863(b)’’
and inserting ‘‘863’’.
(B) EFFECTIVE
DATE.—The amendment
made by subparagraph (A) shall take effect as
if included in the amendments made by section
1211 of the Tax Reform Act of 1986.
(5) REPEAL OF OBSOLETE PROVISIONS.—
(A) Paragraph (1) of section 6038(a) is
amended by striking ‘‘, and’’ at the end of sub-
paragraph (E) and inserting a period, and by
striking subparagraph (F).
(B) Subsection (b) of section 6038A is
amended by adding ‘‘and’’ at the end of para-
graph (2), by striking ‘‘, and’’ at the end of
paragraph (3) and inserting a period, and by
striking paragraph (4).
(g) TREATMENT OF ASSIGNMENT OF INTEREST IN
CERTAIN BOND-FINANCED FACILITIES.—
(1) IN GENERAL.—Subparagraph (A) of section
1317(3) of the Tax Reform Act of 1986 is amended
by adding at the end thereof the following new sen-
tence: ‘‘A facility shall not fail to be treated as de-
scribed in this subparagraph by reason of an assign-
370
ment (or an agreement to an assignment) by the
governmental unit on whose behalf the bonds are is-
sued of any part of its interest in the property fi-
nanced by such bonds to another governmental
unit.’’
(2) EFFECTIVE DATE.—The amendment made
by paragraph (1) shall take effect as if included in
such section 1317 on the date of the enactment of
the Tax Reform Act of 1986.
(h) CLARIFICATION OF TREATMENT OF MEDICARE
ENTITLEMENT UNDER COBRA PROVISIONS.—
(1) IN GENERAL.—
(A) 
Subclause 
(V) 
of 
section
4980B(f)(2)(B)(i) is amended to read as fol-
lows:
‘‘(V) MEDICARE
ENTITLEMENT
FOLLOWED BY QUALIFYING EVENT.—
In the case of a qualifying event de-
scribed in paragraph (3)(B) that oc-
curs less than 18 months after the
date the covered employee became en-
titled to benefits under title XVIII of
the Social Security Act, the period of
coverage for qualified beneficiaries
other than the covered employee shall