100 STAT. 2910
PUBLIC LAW 99-514—OCT. 22, 1986 tions (within the meaning of section 1563(a)) shall be treated as one issuer." (2) EFFECTIVE DATE.—The amendment made by this subsection shall apply as if included in section 2131 of the Tax Reform Act of 1976. (m)
AMENDMENTS RELATING TO SUBCHAPTER S CORPORATIONS.— (1) IN GENERAL.—
(A) Section 1361(d)(3) (relating to qualified subchapter S trusts) is amended by adding at the end thereof the following new sentence: "A substantially separate and independent share of a trust treated as a separate trust under section 663(c) shall be treated as a separate trust for purposes of this subsection and subsection (c)." (B) Section 1368(e)(l) (relating to definitions and special rules) is amended by striking out the period at the end of subparagraph (A) and inserting in lieu thereof "and no adjustment shall be made for Federal taxes attributable to any taxable year in which the corporation was a C corporation." (2) EFFECTIVE DATE.—The amendments made by this subsection shall apply to taxable years beginning after December 31, 1982. (n) AMENDMENT RELATING TO SECTION 2523.— (1) IN GENERAL.—Subparagraph (A) of section 2523(fK4) (relating to election with respect to life estate for donee spouse) is amended to read as follows: "(A) TIME AND MANNER.—An election under this subsection with respect to any property shall be made on or before the date prescribed by section 6075(b) for filing a gift tsix return with respect to the transfer (determined without regard to section 6019(2)) and shall be made in such manner as the Secretary shall by regulations prescribe." (2) EFFECTIVE DATE.—The amendment made by paragraph (1) shall apply to transfers made after December 31, 1985. (3) SPECIAL RULE FOR CERTAIN TRANSFERS I N OCTOBER 1984.—
An election under section 2523(f) of the Internal Revenue (Dode of 1954 with respect to an interest in property which— (A) was transferred during October 1984, and (B) was transferred pursuant to a trust instrument stating that the grantor's intention was that the property of the trust would constitute qualified terminable interest property as to which a Federal gift tax marital deduction would be allowed upon the grantor's election, shall be made on the return of tax imposed by section 2501 of such Code for the calendar year 1984 which is filed on or before the due date of such return or, if a timely return is not filed, on the first such return filed after the due date of such return and before December 31, 1986. (o) AMENDMENTS RELATING TO SECTION 4994.— (1) For purposes of section 49910t)), a "qualified charitable interest" shall include an economic interest in crude oil held by the Episcopal Royalty Company, an entity created in 1961 as a subsidiary of the Protestant Episcopal Church Foundation of the Diocese of Oklahoma. (2) The amendment made by this subsection shall apply to oil removed after February 29, 1980.
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