(1) thereof) shall take effect on the date of the en-
actment of this Act.
SEC. 306. REGULATORY AUTHORITY TO EXCLUDE CERTAIN
PRELIMINARY AGREEMENTS FROM DEFINI-
TION OF INTANGIBLE PROPERTY.
(a) IN GENERAL.—Section 936(h)(3)(B) (defining
intangible property) is amended by adding at the end the
following new sentence: ‘‘The Secretary shall by regulation
provide that such term shall not include any preliminary
agreement which is not legally enforceable.’’
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to agreements entered into after
the date of the enactment of this Act.
SEC. 307. AIRLINE MILEAGE AWARDS TO CERTAIN FOREIGN
PERSONS.
(a) IN GENERAL.—The last sentence of section
4261(e)(3)(C) (relating to regulations) is amended by in-
serting ‘‘and mileage awards which are issued to individ-
uals whose mailing addresses on record with the person
providing the right to air transportation are outside the
United States’’ before the period at the end thereof.
(b) EFFECTIVE DATE.—The amendment made by
this section shall apply to amounts paid, and benefits pro-
vided, after December 31, 1997.
SEC. 308. REPEAL OF REDUCTION OF SUBPART F INCOME
OF EXPORT TRADE CORPORATIONS.
(a) IN GENERAL.—Subpart G of part III of sub-
chapter N of chapter 1 (relating to export trade corpora-
tions) is repealed.
(b) TREATMENT
OF CERTAIN ACTUAL DISTRIBU-
TIONS.—
(1) IN
GENERAL.—For purposes of applying
sections 959 and 960(b) of the Internal Revenue
Code of 1986, in the case of any actual distribution
of export trade income made after December 31,
1986, by an export trade corporation (or former ex-
port trade corporation that was an export trade cor-
poration on December 31, 1986), notwithstanding
any other provision of chapter 1 of such Code, the
earnings and profits attributable to amounts which
have been included in the gross income of a United
States shareholder under section 951(a) of such
Code shall be treated as including an amount equal
to the amount of export trade income that was in-
cluded in gross income as a dividend. If a distribu-
tion is excluded from gross income by application of
this subsection, the amount of such distribution shall
be treated as an amount described in section
951(a)(2)(B) of such Code that reduces the amount
described in section 951(a)(2)(A) of such Code for
the taxable year.
(2) 
DEFINITIONS.—For 
purposes 
of 
this
subsection—
(A) EXPORT TRADE CORPORATION.—The
term ‘‘export trade corporation’’ has the mean-
ing given such term by section 971(a) of the In-
ternal Revenue Code of 1986 (as in effect be-
fore the amendment made by subsection (a)).
(B) EXPORT TRADE INCOME.—The term
‘‘export trade income’’ has the meaning given
such term by section 971(b) of the Internal
Revenue Code of 1986 (as so in effect).
(c) CONFORMING AMENDMENTS.—
(1) Section 865(e)(2)(A) is amended by striking
the last sentence.
(2) Section 1297(b)(2)(D) is amended by strik-
ing ‘‘or export trade income of an export trade cor-
poration (as defined in section 971)’’.
(3) The table of parts for part III of subchapter
N of chapter 1 is amended by striking the item re-
lating to subpart G.
(d) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years beginning after
December 31, 1999.
SEC. 309. STUDY OF INTEREST ALLOCATION.
(a) STUDY.—The Secretary of the Treasury or the
Secretary’s delegate shall conduct a study of the rules
under section 864(e) of the Internal Revenue Code of
1986 for allocating interest expense of members of an af-
filiated group. Such study shall include an analysis of the
effect of such rules, including the effects such rules have
on different industries.
(b) REPORT.—Not later than 6 months after the date
of the enactment of this Act, the Secretary of the Treasury
shall report to the Committee on Ways and Means of the
House of Representatives and the Committee on Finance
of the Senate the results of the study conducted under
subsection (a), including recommendations (if any) for leg-
islation.
SEC. 310. INTEREST PAYMENTS DEDUCTIBLE WHERE DIS-
QUALIFIED GUARANTEE HAS ECONOMIC EF-
FECT.
(a) IN GENERAL.—Section 163(j)(6)(D)(ii) (relating
to exceptions to disqualified guarantee) 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 inserting after subclause (II) the following new
subclause:
‘‘(III) if, in the case of a guar-
antee by a foreign person, the tax-
payer establishes to the satisfaction of
the Secretary that the loan giving rise
to the indebtedness would have been
made by the unrelated person without
regard to the guarantee and that the
guarantee resulted in a reduction in
the interest payable on the loan.’’
(b) EFFECTIVE DATE.—The amendments made by
this section shall apply to guarantees issued on and after
the date of the enactment of this Act.
SEC. 311. MODIFICATIONS OF REPORTING REQUIREMENTS
FOR CERTAIN FOREIGN OWNED CORPORA-
TIONS.
(a) DE MINIMIS EXCEPTION.—Section 6038A(b) (re-
lating to required information) is amended by adding at
the end the following new flush sentence:
‘‘The Secretary shall not require the reporting corporation
to report any information with respect to any foreign per-
son which is a related person if the aggregate value of
the transactions between the corporation and the related
person (and any person related to such person) during the
taxable year does not exceed $5,000,000.’’
(b) TIME FOR PROVIDING TRANSLATIONS OF SPE-
CIFIC DOCUMENTS.—Notwithstanding Internal Revenue
Service Regulation § 1.6038A–3(f)(2), a taxpayer shall