PUBLIC LAW 100-647—NOV. 10, 1988
102 STAT. 3513
effect on the day before the date of the enactment of the Tax Reform Act of 1986)". QO AMENDMENT RELATED TO SECTION 1225 OP THE REFORM Acrr.— Subsection (c) of section 1225 of the Reform Act is amended by 26 USC 535 note. striking out "March 1, 1986" and inserting in lieu thereof "January 1, 1986". G) AMENDMENTS RELATED TO SECTION 1226 OF THE REFORM ACT.—
(1) Subsection (a) of section 246A of the 1986 Code is amended by striking out the last sentence. (2)(A) Paragraph (8) of section 245 of the 1986 Code is amended to read as follows: "(8) DISALLOWANCE OF FOREIGN TAX CREDIT.—No credit shall be allowed under section 901 for any taxes paid or accrued (or treated as paid or accrued) with respect to the United Statessource portion of any dividend received by a corporation from a qualified 10-percent-owned foreign corporation." (6) Subsection (a) of section 245 of the 1986 Code is amended by adding at the end thereof the following new paragraph: "(10) (COORDINATION WITH TREATIES.—If^
"(A) any portion of a dividend received by a corporation from a qualified 10-percent-owned foreign corporation would be treated as from sources in the United States under paragraph (9), "(B) under a treaty obligation of the United States (applied without r ^ a r d to this subsection), such portion would be treated as arising from sources outside the United States, and "((D) the taxpayer chooses the benefits of this paragraph, this subsection shall not apply to such dividend (but subsections (a), 0>), and (c) of section 904 and sections 902, 907, and 960 shall be apphed separately with respect to such portion of such dividend)." (3) Subsection (a) of section 245 of the 1986 Code is amended by adding at the end thereof the following new paragraph: "(11) COORDINATION WITH SECTION 1248.—For purposes of this subsection, the term 'dividend' does not include any amount treated as a dividend under section 1248." (m) AMENDMENTS RELATED TO SECTION 1228 OF THE REFORM ACT.—
(1) Subsection (a) of section 1228 of the Reform Act is amended 26 USC 897 note. by striking out "and" at the end of paragraph (3), and by striking out paragraph (4) and inserting in lieu thereof the following: "(4) the transfer, sale, exchange, or other disposition is part of a single i n t ^ r a t e d plan, whereby the stock of the corporation described in paragraph (1) becomes owned directly by the 2 corporations specifically referred to in subsection (b) or by such 2 corporations and by 1 or both of their jointly owned direct subsidiaries, "(5) within 20 days after each transfer, sale, exchange, or other disposition, the person making such transfer, sale, exchange, or other disposition notifies the Internal Revenue Service of the transaction, the date of the transad^ion, the b a a s of the stock involved, the holding period for such^stock, and^suc^ other mf<n*mation as the Internal Revenue Sendce^may reqpiire, and
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