80 STAT.] "(c)
PUBLIC LAW 89-809-NOV. 13, 1966
1551
CROSS EEFERENCES.—
"(1) For disallowance of standard deduction, see section 142(b)(1). "(2) For rule that certain foreign taxes are not to be taken into account in determining deduction or credit, see section 906(b)(1)." (2) Section 154(3) (relating to cross references in respect of deductions for personal exemptions) is amended to read as follows: "(3) For exemptions of nonresident aliens, see section 873(b)(3)." (d)
ALLOWANCE OF DEDUCTIONS AND CREDITS.—Subsection (a)
of
section 874 (relating to filing of returns) is amended to read as follows: " (a) RETURN PREREQUISITE TO ALLOWANCE.—A nonresident alien individual shall receive the benefit of the deductions and credits allowed to him in this subtitle only by filing or causing to be filed with the Secretary or his delegate a true and accurate return, in the manner prescribed in subtitle F (sec. 6001 and following, relating to procedure and administration), including therein all the information which the Secretary or his delegate may deem necessary for the calculation of such deductions and credits. This subsection shall not be construed to deny the credits provided by sections 31 and 32 for tax withheld at source or the credit provided by section 39 for certain uses of gasoline and lubricating oil." (e)
68A Stat. 45.
BENEFICIARIES OF ESTATES AND TRUSTS.—
(1) Section 875 (relating to partnerships) is amended to read as follows: "SEC. 875. PARTNERSHIPS; BENEFICIARIES OF ESTATES AND TRUSTS. "For purposes of this subtitle— "(1) a nonresident alien individual or foreign corporation shall be considered as being engaged in a trade or business within the United States if the partnership of which such individual or corporation is a member is so engaged, and "(2) a nonresident alien individual or foreign corporation which is a beneficiary of an estate or trust which is engaged in any trade or business within the United States shall be treated as being engaged in such trade or business within the United States." (2) The table of sections for subpart A of part II of subchapter N of chapter 1 is amended by striking out the item relating to section 875 and inserting in lieu thereof the following:
79 Stat. 167.
68A Stat. 281.
"Sec. 875. Partnerships; beneficiaries of estates and trusts." (f)
EXPATRIATION To AVOID T A X. —
(1) Subpart A of part II of subchapter N of chapter 1 (relating to nonresident alien individuals) is amended by redesignating section 877 as section 878, and by inserting after section 876 the following new section: "SEC. 877. EXPATRIATION TO AVOID TAX. " (a) IN GENERAL.—Every nonresident alien individual who at any time after March 8, 1965, and within the 10-year period immediately preceding the close of the taxable year lost United States citizenship, unless such loss did not have for one of its principal purposes the avoidance of taxes under this subtitle or subtitle B, shall be taxable for such taxable year in the manner provided in subsection (b) if the tax imposed pursuant to such subsection exceeds the tax which, without regard to this section, is imposed pursuant to section 871. " (b) ALTERNATIVE TAX.—A nonresident alien individual described in subsection (a) shall be taxable for the taxable year as provided in section 1 or section 1201(b), except that—
26 USC 1-2524.
Ante, p. 1547.
^"'^' P ^^^O.
�
