PUBLIC LAW 99-514—OCT. 22, 1986 eluded in the gross income of a United States shareholder for any taxable year both under subsection (a)(l)(A)(i) and under section 1293 (relating to current taxation of income from certain passive foreign investment companies), such amount shall be included in the gross income of such shareholder only under subsection (a)(1)(A)." (d) EXTENSION OF STATUTE OF LIMITATION.—Section 6503 (relating to suspension of running of period of limitation) is amended by redesignating subsection (j) as subsection (k) and by inserting after subsection (i) the following new subsection: "(j) EXTENSION OF TIME FOR PAYMENT OF UNDISTRIBUTED P F I C EARNINGS TAX LIABILITY.—The running of any period of limitations
for collection of any amount of undistributed PFIC earnings tax liability (as defined in section 1294(b)) shall be suspended for the period of any extension of time under section 1294 for payment of such amount." (e) COORDINATION WITH FOREIGN PERSONAL HOLDING COMPANY
PROVISIONS.—Section 551 is amended by redesignating subsection (g) as subsection (h) and by inserting after subsection (f) the following new subsection: "(g) COORDINATION WITH PASSIVE FOREIGN INVESTMENT COMPANY
PROVISIONS.—If, but for this subsection, an amount would be included in the gross income of any person under subsection (a) and under section 1293 (relating to current taxation of income from certain passive foreign investment companies), such amount shall be included in the gross income of such person only under subsection (a)." (f) OTHER TECHNICAL AMENDMENTS.—
(1) Subsection (b) of section 532 (relating to exceptions from accumulated earnings tax) is amended by striking out "or" at the end of paragraph (2), by striking out the period at the end of paragraph (3) and inserting in lieu thereof ", or", and by adding at the end thereof the following new paragraph: "(4) a passive foreign investment company (as defined in section 1296)." (2) Subsection (c) of section 542 (relating to exceptions from personal holding company provisions) is amended by striking out "and" at the end of paragraph (8), by striking out the period at the end of paragraph (9) and inserting in lieu thereof "; and", and by adding at the end thereof the following new paragraph: "(10) a passive foreign investment company (as defined in section 1296)." (3) The second sentence of section 851(b) is amended— (A) by striking out "section 951(a)(l)(A)(i)" and inserting in lieu thereof "section 951(a)(l)(A)(i) or 1293(a)", and (B) by striking out "section 959(a)(1)" and inserting in lieu thereof "section 959(a)(1) or 1293(c) (as the case may be)". (4)(A) Subparagraph (A) of section 904(g)(1) is amended by striking out "or" at the end of clause (i), by striking out the period at the end of clause (ii) and inserting in lieu thereof ", or", and by adding at the end thereof the following new clause: "(iii) section 1293 (relating to current taxation of income from qualified funds)." (B) The paragraph heading of section 904(g)(2) is amended by striking out "HOLDING COMPANY" and inserting in lieu thereof "HOLDING OR PASSIVE FOREIGN INVESTMENT COMPANY".
100 STAT. 2575
�
