228
(4) Subsection (e) of section 443 is amended by
striking paragraph (3) and by redesignating para-
graphs (4) and (5) as paragraphs (3) and (4),
respectively.
(5) Clause (ii) of section 465(c)(7)(B) is
amended to read as follows:
‘‘(ii) a passive foreign corporation
with respect to which the stock ownership
requirements of section 1292(a)(2)(B) are
met, or’’.
(6) Subsection (b) of section 535 is amended by
striking paragraph (9).
(7) Subsection (d) of section 535 is hereby re-
pealed.
(8) Paragraph (1) of section 543(b) is amended
by inserting ‘‘and’’ at the end of subparagraph (A),
by striking ‘‘, and’’ at the end of subparagraph (B)
and inserting a period, and by striking subparagraph
(C).
(9) Section 545 is amended by striking sub-
sections (b)(7) and (c).
(10) Paragraph (1) of section 562(b) is amend-
ed by striking ‘‘or a foreign personal holding com-
pany described in section 552’’.
(11) Section 563 is amended—
229
(A) by striking subsection (c),
(B) by redesignating subsection (d) as sub-
section (c), and
(C) by striking ‘‘subsection (a), (b), or (c)’’
in subsection (c) (as so redesignated) and in-
serting ‘‘subsection (a) or (b)’’.
(12) Paragraph (2) of section 751(d) is amend-
ed by striking ‘‘subsection (a) of section 1246 (relat-
ing to gain on foreign investment company stock)’’
and inserting ‘‘section 1291 (relating to stock in
certain passive foreign corporations marked to
market)’’.
(13) Subsection (b) of section 851 is amended
by striking the sentence following paragraph (4)(B)
which contains a reference to section 1293(a).
(14) Clause (ii) of section 864(b)(2)(A) is
amended by striking ‘‘(other than’’ and all that fol-
lows down through ‘‘holding company)’’ and insert-
ing ‘‘(other than a corporation which would be a
personal holding company but for section 542(c)(5)
and which is not United States controlled (as de-
fined in section 1292(a)(2))’’.
(15) Subsection (d) of section 904 is amended
by striking paragraphs (2)(A)(ii), (2)(E)(iii), and
(3)(I).
230
(16)(A) Subparagraph (A) of section 904(g)(1)
is amended to read as follows:
‘‘(A) Any amount included in gross income
under section 951(a) (relating to amounts in-
cluded in gross income of United States share-
holders).’’
(B) The paragraph heading of paragraph (2) of
section 904(g) is amended by striking ‘‘AND FOR-
EIGN PERSONAL HOLDING OR PASSIVE FOREIGN IN-
VESTMENT COMPANY’’.
(17) Section 951 is amended by striking sub-
sections (c), (d), and (f), and by redesignating sub-
section (e) as subsection (c).
(18) Paragraph (3) of section 956A(c) is
amended—
(A) by striking ‘‘1297(d)’’ in subparagraph
(B) and inserting ‘‘1297(e)’’, and
(B) by striking ‘‘1297(e)’’ in subparagraph
(C) and inserting ‘‘1297(f)’’.
(19) Paragraph (1) of section 986(c) is amend-
ed by striking ‘‘or 1293(c)’’.
(20) Paragraph (3) of section 989(b) is amend-
ed by striking ‘‘, 551(a), or 1293(a)’’.
(21) Paragraph (5) of section 1014(b) is hereby
repealed.
231
(22) Subsection (a) of section 1016 is amended
by striking paragraph (13) and by redesignating the
following paragraphs accordingly.
(23) Paragraph (3) of section 1212(a) is
amended—
(A) by striking subparagraph (A),
(B) by redesignating subparagraphs (B)
and (C) as subparagraphs (A) and (B), respec-
tively, and
(C) by amending subparagraph (D) to read
as follows:
‘‘(C) for which it is a passive foreign cor-
poration.’’
(24) Section 1223 is amended by striking para-
graph (10) and by redesignating the following para-
graphs accordingly.
(25) Subsection (d) of section 1248 is amended
by striking paragraphs (5) and (7).
(26)(A) Subsection (a) of section 6035 is
amended by striking ‘‘foreign personal holding com-
pany (as defined in section 552)’’ and inserting
‘‘passive foreign corporation with respect to which
the 
stock 
ownership 
requirements 
of 
section
1292(a)(2)(B) are met’’.