PUBLIC LAW 98-369—JULY 18, 1984
98 STAT. 707
"(B) such loss shall be deferred until the property is transferred outside such controlled group and there would be recognition of loss under consolidated return principles or until such other time as may be prescribed in regulations. "(3) Loss DEFERRAL RULES NOT TO APPLY IN CERTAIN CASES.— "(A) TRANSFER TO DISC.—For purposes of applying subsec-
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tion (a)(1), the term 'controlled group' shall not include a DISC. "(B) CERTAIN SALES OF INVENTORY.—Except to the extent provided in regulations prescribed by the Secretary, subsection (a)(1) shall not apply to the sale or exchange of property between members of the same controlled group if^ "(i) such property in the hands of the transferor is property described in section 1221(1), "(ii) such sale or exchange is in the ordinary course of the transferor's trade or business, "(iii) such property in the hands of the transferee is property described in section 1221(1), and "(iv) the transferee or the transferor is a foreign corporation. "(C) CERTAIN FOREIGN CURRENCY LOSSES.—To the extent provided in regulations, subsection (a)(1) shall not apply to any loss sustained by a member of a controlled group on the repayment of a loan made to another member of such group if such loan is payable in a foreign currency or is denominated in such a currency and such loss is attributable to a reduction in value of such foreign currency." (3) CORPORATION AND PARTNERSHIP OWNED BY SAME PERSONS.—
Paragraph (10) of section 2670t)) is amended— (A) by striking out "An S corporation" and inserting in lieu thereof "A corporation", and (B) by striking out "the S corporation" and inserting in lieu thereof "the corporation".
26 USC 267.
(4) S CORPORATION AND CORPORATION OWNED BY SAME PER-
SONS.—Paragraph (12) of section 2670?) is amending by striking out "the same individual" and inserting in lieu thereof "the same persons".
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(5)'TECHNICAL AMENDMENTS.—
(A) Paragraph (3) of section 170(a) is amended by striking 26 USC 170. out "section 267(b)" and inserting in lieu thereof "section 267(b) or 707(b)". (B) Clause (iii) of section 514(c)(9)(B) is amended by strik- Post, p. 1039. .«a ing out "section 2670t))" and inserting in lieu thereof "sec;; tion 267(b) or 707(b)". j^^,, (C) Subsection (d) of section 1235 is amended— 26 USC 1235. (i) by striking out "section 267(b)" in the matter preceding paragraph (1) and inserting in lieu thereof K-,;^ jr "section 267(b) or persons described in section 70703)", (ii) by striking out "section 267(b) and (c)" and ., inserting in lieu thereof "section 267(b) and (c) and section 707(b)", and (iii) by striking out "section 2670t))" in paragraph (1) and inserting in lieu thereof "section 267(b) or 7070t))". (D) Subparagraph (F) of section 368(a)(2) is amended by 26 USC 368. striking out clause (viii). (c) EFFECTIVE DATES.— 26 USC 267 note.
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