PUBLIC LAW 100-647—NOV. 10, 1988
102 STAT. 3433
"(D) the determination of whether any income is hightaxed income for purposes of section 904(d)(2) were made on the basis of the applicable rate specified in section 55(b)(l)(A) in lieu of the highest rate of tax specified in section 1 or 11 (whichever applies)." (4) Subsection (i) of section 59 of the 1986 (Dode is amended— (A) by striking out "of this subtitle" and inserting in lieu thereof "of this subtitle (other than this part)", and (B) by striking out "by this title" and inserting in lieu thereof "by this subtitle". (f) TRANSITIONAL PROVISIONS.—
(1) In the case of the taxable year of an estate or trust which 26 USC 55 note. begins before January 1, 1987, and ends on or after such date, the items of tax preference apportioned to any beneficiary of such estate or trust under section 58(c) of the Internal Revenue Code of 1954 (as in effect on the day before the date of the enactment of the Tax Reform Act of 1986) shall be taken into account for purposes of determining the amount of the tax imposed by section 55 of the Internal Revenue Code of 1986 (as amended by the Tax Reform Act of 1986) on such beneficiary for such beneficiary's taxable year in which such taxable year of the estate or trust ends. (2) The last sentence of subparagraph (B) of section 701(f)(6) of the Reform Act is amended to read as follows: "The aggregate 26 USC 55 note. amount of investment tax credits with respect to the unit in Mississippi allowed solely by reason of being described in this subparagraph shall not exceed $141,000,000." (3) Subsection (f) of section 701 of the Reform Act is amended by adding at the end thereof the following new paragraph: "(7) AGREEMENT VESSEL DEPRECIATION ADJUSTMENT.—
"(A) For purposes of part VI of subchapter A of chapter 1 of the Internal Revenue (Dode of 1986, in the case of a qualified taxpayer, alternative minimum taxable income for the taxable year shall be reduced by an amount equal to the agreement vessel depreciation adjustment. "(B) For purposes of this paragraph, the agreement vessel depreciation adjustment shall be an amount equal to the depreciation deduction that would have been allowable for such year under section 167 of such Code with respect to agreement vessels placed in service before January 1, 1987, if the basis of such vessels had not been reduced under section 607 of the Merchant Marine Act of 1936, as amended, and if depreciation with respect to such vessel had been computed using the 25-year straight-line method. The aggregate amount by which basis of a qualified taxpayer is treated as not reduced by reason of this subparagraph shall not exceed $100,000,000. "(C) For purposes of this paragraph, the term 'qualified taxpayer' means a parent corporation incorporated in the State of Delaware on December 1, 1972, and engaged in water transportation, and includes any other corporation which is a member of the affiliated group of which the parent corporation is the common parent. No taxpayer shall be treated as a qu£dified corporation for any taxable year beginning after December 31, 1991." (4)(A) If any property to which this paragraph applies is 26 USC 57 note. placed in service in a taxable year which begins before Janu-
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