An Act to amend section 278 of the Internal Revenue Code of 1954 to extend its application from citrus groves to almond groves
PL 91-680 (H.R.19242), enacted 01/12/1971

2064 
PUBLIC LAW 91^80-JAN. 12, 1971 
[84 
STAT. 
68A Stat. 3. 
26 use 1 
et 
seq, 
53 Stat. 4. 
SEC. 3. The amendments made by the first two sections of this Act 
shall apply to all taxable years to which the Internal Revenue Code 
of 1954 applies. Corresponding provisions shall be deemed to be 
included in the Internal Revenue Code of 1939 and shall apply to all 
taxable years to which such Code applies. 
Approved January 12, 1971. 
January 12, 1971 
[H. R. 19242] 
Public Law 91-680 
AN ACT 
To auieiid .section 278 of the Internal Revenue Code of 1954: to extend its 
application from citrus groves to almond groves. 
Taxes. 
Almond groves, 
capital expendi-
tures. 
83 Stat. 57 4. 
26 u s e 278. 
Be it enacted by the Senate and House of Refresentatwes 
of the 
United States of America in Congress assemhled^ That (a) the text 
of section 278 of the Internal Revenue Code of 1954 (relating to capi-
tal expenditures incurred in planting and developing citrus groves) is 
amended by striking out "citrus grove" each place it appears and 
inserting in lieu thereof "citrus or almond grove". 
(b) The heading for section 278 of such Code is amended to read 
as follows: 
Effective date. 
Airline 
tickets, total 
cost requirement. 
i4n(e, p. 239. 
"SEC. 278. CAPITAL 
EXPENDITURES 
INCURRED 
IN 
PLANTING AND DEVELOPING CITRUS AND 
ALMOND GROVES." 
(c) The table of sections for part I X of subchapter B of chapter 1 
of such Code is amended by striking out the item relating to section 278 
and inserting in lieu thereof the following: 
"Sec. 278. Capital expenditures incurred in planting and de-
veloping citrus and almond groves." 
(d) Subsection (b) (2) of such section 278 is amended to read as 
follows: 
"(2) planted or replanted before— 
"(A) December 30, 1969, in the case of a citrus grove, or 
"(B) December 30, 1970, in the case of an almond grove." 
SEC. 2. The amendments made by the first section of this Act shall 
apply to taxable years beginning after the date of the enactment of this 
Act. 
SEC. 3. (a) Subsection (a) of section 7275 of the Internal Revenue 
Code of 1954 (relating to requirements of showing total cost on airline 
tickets) is amended by— 
(1) inserting "and" at the end of paragraph (1) thereof, 
(2) striking out paragraph (2) thereof, and 
(3) renumbering paragraph (3) as paragraph (2) and striking 
out in such paragraph "paragraphs (1) and (2)" and inserting 
in lieu thereof "paragraph (1)". 
(b) Subsection (b) of such section (relating to requirements of 
showing total cost on airline advertising) is amended by striking out 
the word "only" in paragraph (1) and by amending paragraph (2) 
to read as follows: 
84 STAT. ] 
PUBLIC LAW 91-681-JAN. 12, 1971 
20(55 
"(2) if any such advertising states separately the amount to 
be paid for such transportation or the amount of such taxes, shall 
state such total at least as prominently as the more prominently 
stated of the amount to be paid for such transportation or the 
amount of such taxes and shall describe such taxes substantially 
as: 'user taxes to pay for airport construction and airway safety 
and operations'.". 
SEC. 4. The amendments made by the third s
e
> tion of this Act shall 
apply to transportation beginning after June 30, 1970. 
Approved January 12, 1971. 
Public Law 91-681 
AN ACT 
January 12, 1971 
To aineiul sei-tion 307 of the Internal Revenue Code of 1954. 
[H. R. 19686] 
Effective date,, 
Taxes. 
Foreign 
Be it enacted hy the Senate and House of Representatives 
of the 
United States of America in Congress assembled^ That (a) section 367 
of the Internal Revenue Code of 1954 (relating to foreign corpora- co^orau^ns. 
tions) is amended to read as follows: 
^^A stat. 119. 
' 
26 u s e 367. 
"SEC. 367. FOREIGN CORPORATIONS. 
"(a) GENERAL RULE.—In determining the extent to which gain 
shall be recognized in the case of any of the exchanges described in 
section 332, 351, 354, 355, 356, or 361, a foreign corporation shall not 8o^ltlt!l577.°^' 
be considered as a corporation unless— 
" (1) before such exchange, or 
"(2) in the case of an exchange described in subsection (b), 
either before or after such exchange, 
it has been established to the satisfaction of the Secretary or his dele-
gate that such exchange is not in pursuance of a plan having as one 
of its principal purposes the avoidance of Federal income taxes. 
"(b) APPLICATION or SUBSECTION (a)(2).—Subsection (a)(2) shall 
apply in the case of a mere change in fonn in Avhich there is an 
exchange by a foreign corporation of— 
" (1) stock in one foreign corporation for, 
" (2) stock in another foreign corporation, 
if the corporations referred to in paragraphs (1) and (2) differ only 
in their form of organization, and if the ownership of the corporation 
referred to in paragraph (1) immediately before such exchange is 
identical to the ownership of the corporation referred to in paragraph 
(2) immediately after such exchange. 
"(c) 
SECTION 355 
DISTRIBUTIONS TREATED AS EXCHANGES.—For 
purposes of this section, any distribution described in section 355 (or 
so much of section 356 as relates to section 355) shall be treated as an 
exchange whether or not it is an exchange. 
" ( d ) 
CONTRIBUTIONS OF CAPITAL TO CONTROLLED CORPORATIONS.— 
For purposes of this chapter, any transfer of property to a foreign 
corporation as a contribution to the capital of such corporation by 
one or more persons who, immediately after the transfer, own (within 
the meaning of section 318) stock possessing at least 80 percent of the 
^^^A stat. 99; 
total combined voting power of all classes of stock of such corporation 
^
*
^
*
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entitled to vote shall be treated as an exchange of such property for 
stock of the foreign corporation equal in value to the fair market 
value of the property transferred unless, before such transfer, it has 
been established to the satisfaction of the Secretary or his delegate 
that such transfer is not in pursuance of a plan having as one of its 
principal purposes the avoidance of Federal income taxes."