Page:United States Statutes at Large Volume 104 Part 2.djvu/924

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104 STAT. 1388-516 PUBLIC LAW 101-508—NOV. 5, 1990 "(A) requires that at least 1 trustee of the trust be an individual citizen of the United States or a domestic corporation, and "(B) provides that no distribution (other than a distribution of income) may be made from the trust unless a trustee who is an individual citizen of the United States or a domestic corporation has the right to withhold from such distribution the tax imposed by this section on such distribution,". (B) Subsection (b) of section 2056A is amended by adding at the end thereof the following new paragraphs: " (14) COORDINATION WITH TERMINABLE INTEREST RULES. — Any interest in a qualified domestic trust shall not be treated as failing to meet the requirements of paragraph (5) or (7) of section 2056(b) merely by reason of any provision of the trust instrument permitting the withholding from any distribution of an amount to pay the tax imposed by paragraph (1) on such distribution. "(15) No TAX ON CERTAIN DISTRIBUTIONS. —No tax shall be imposed by paragraph (1) on any distribution to the surviving spouse to the extent such distribution is to reimburse such surviving spouse for any tax imposed by subtitle A on any item of income of the trust to which such surviving spouse is not entitled under the terms of the trust." (3)(A) Subsection (d) of section 2056A is amended by adding at the end thereof the following new sentence: "No election may be made under this section on any return if such return is filed more than one year after the time prescribed by law (including extensions) for filing such return." 26 USC 2056A (B) The amendment made by subparagraph (A) shall not ^°^- apply to any election made before the date 6 months after the date of the enactment of this Act. (4) Subparagraph (A) of section 2056A(b)(10) is amended by striking 'Wtion 2032" and inserting "section 2011, 2014, 2032" (5) Paragraph (3) of section 2056(d) is amended by striking "s e ction 2056A(b)(6)" and inserting "section 2056A(b)(7)". (h) AMENDMENTS RELATED TO SECTION 6009. — (1) Subparagraph (B) of section 135(b)(2) is amended by striking "each dollar amount" and inserting "the $40,000 and $60,000 amounts". (2) Subparagraph (C) of section 135(b)(2) is amended by striking "(A) or". (i) AMENDMENTS RELATED TO SECTION 6282.—Subsection (e) of section 216 is amended— (1) by striking "ASSOCIATIONS" in the subsection heading and inserting "CORPORATIONS", and (2) by striking "association" and inserting "corporation". 26 USC 59 note. (j) EFFECTIVE DATE.—Any amendment made by this section shall take effect as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988 to which such amendment relates. SEC. 11703. MISCELLANEOUS AMENDMENTS. (a) SALES TO COMPLY WITH CONFLICT-OF-INTEREST REQUIRE- MENTS. — (1) IN GENERAL.—Subsection (a) of section 1043 is amended by striking "reduced by any basis adjustment under subsection (c)