103 STAT. 2410 PUBLIC LAW 101-239—DEC. 19, 1989 Ck>rporation8. •< "To the extent provided in r^ulations, payments made by a partnership with 1 or more corporate partners shall be
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treated as made by such corporate partners in proportion to their respective interests in the partnership." (4) Paragraph (5) of section 1297(b) is amended— (A) by inserting "STOCK" after "WHERE" in the paragraph heading, (B) by striking "any disposition of in subparagraph (A)(ii) and inserting "any distribution of, and (C) by striking treated as a disposition to" in subpara- graph (A) and inserting "treated as a disposition by, or distribution to". 26 USC 884 note. (5) Subparagraph (B) of section 1012(q)(l) of the 1988 Act is amended^^ (A) by striking "1021(e)(2)(C)" and inserting "1021(c)(2)(O", and (B) by striking "823(b)(4)(C)" and inserting "832(b)(4)(O". ^
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(6)(A) Subparagraph (B) of section 1446(b)(2) is amended by striking "section 11(b)" and inserting "section ll(b)(l)". (B) Paragraph (2) of section 1446(d) is amended to read as follows: "(2) CREDIT TREATED AS DISTRIBUTED TO PARTNER.— Except as provided in regulations, a foreign partner's share of any withholding tax paid by the partnership under this section shall be treated as distributed to such partner by such partnership on the earlier of— "(A) the day on which such tax was paid by the partner- ship, or '(B) the last day of the partnership's taxable year for which such tax was paid." (C) Subsection (f) of section 1446 is amended to read as follows: "(f) REGULATIONS.— The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this section, including— "(1) regulations providing for the application of this section in the case of publicly traded partnerships, and "(2) regulations providing— "(A) that, for purposes of section 6655, the withholding tax imposed under this section shall be treated as a tax
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imposed by section 11 and any partnership required to pay such tax shall be treated as a corporation, and "(B) appropriate adjustments in applying section 6655 with respect to such withholding tax." (7) Subsection (a) of section 988 is amended by inserting after the subsection heading the following: "Notwithstanding any other provision of this chapter—". (8)(A) Subsection (b) of section 887 is amended by redesignat- ing paragraph (3) as paragraph (4) and by inserting after para- graph (2) the following new paragraph: "(3) EXCEPTION FOR CERTAIN INCOME TAXABLE IN POSSES- SIONS.— The term 'United States source gross transportation income' does not include any income taxable in a possession of the United States under the provisions of this title as made applicable in such possession." (B) Paragraph (1) of section 887(b) is amended by striking "paragraph (2) and inserting "paragraphs (2) and (3)'.
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