102 STAT. 3426
26 USC 860F note.
Loans,
PUBLIC LAW 100-647—NOV. 10, 1988
graph (B)) for any taxable year beginning before January 1, 1989 (17) Subparagraph (B) of section 860E(c)(2) of the 1986 Code is amended— (A) by inserting "(adjusted for contributions)" after "residual interest" the second place it appears, and (B) by striking "decreased by" in clause (ii) and inserting in lieu thereof "decreased (but not below zero) by". (18XA) Subsection (e) of section 860F of the 1986 Code is amended by adding at the end thereof the following new sentences: "Such return shall be filed by the REMIC. The determination of who may sign such return shall be made without regard to the first sentence of this subsection." (B) Unless the REMIC otherwise elects, the amendment made by subparagraph (A) shall not apply to any REMIC where the start-up day (as defined in section 860(jr(a)(9) of the 1986 C!ode as in effect on the day before the date of the enactment of this Act) is before the date of the enactment of this Act. (19) Subsection (a) of section 860D of the 1986 (Dode is amended by adding at the end thereof the following new sentence: "In the case of a qualified liquidation (as defined in section 860F(a)(4)(A)), paragraph (4) shall not apply during the liquidation period (as defined in section 860F(a)(4)(B).'^ (20) Subsection (a) of section 860A of the 1986 Code is amended by striking out "this chapter" each place it appears and inserting in lieu thereof "this subtitle". (21) Paragraph (1) of section 860C(b) of the 1986 Code is amended by striking out "and in the same manner" and inserting in lieu thereof "and, except as provided in regulations, in the same manner". (22) The following sections of the 1986 Code are each amended by striking out "real estate mortgage pool" and inserting in lieu thereof "REMIC": (A) Section 382(l)(4)(B)(ii). (B) Section 860F(a)(2)(A)(iii). (C) Section 860F(a)(2)(C). (D) Section 860F(b)(l)(C)(ii). (E) Section 860F(b)(l)(D)(ii). (23) Subsection (d) of section 860E of the 1986 Code is amended by adding at the end thereof the following new sentence: "Rules similar to the rules of the preceding sentence shall apply also in the case of regulated investment companies, common trust funds, and organizations to which part I of subchapter T applies." (24) Subparagraph (C) of section 6049(d)(7) of the 1986 Code is amended by striking out "the issue price" and inserting in lieu thereof "the adjusted issue price". (25XA) Paragraph (19) of section 7701(a) of the 1986 Code is amended by adding at the end thereof the following new sentence: "For purposes of determining whether any interest in a REMIC qualifies under clause (xi), any regular interest in another REMIC held by such REMIC shall be treated as a loan described in a preceding clause under principles similar to the principles of clause (xi); except that, if such REMIC's are part of a tiered structure, they shall be treated as 1 REMIC for purposes of clause (xi)." (B) Paragraph (4) of section 593(d) of the 1986 Ckxie is amended by adding at the end thereof the following new sentence: "For
�
