Page:United States Statutes at Large Volume 104 Part 2.djvu/931

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PUBLIC LAW 101-508 —NOV. 5, 1990 104 STAT. 1388-523 (B) Paragraphs (1) and (2) of section 59(g) are each amended by striking "beginning after 1989". (C) Clause (iii) of section 56(g)(4)(C) is amended to read as follows: "(iii) TREATMENT OF TAXES ON DIVIDENDS FROM 936 CORPORATIONS. — "(I) IN GENERAL.—For purposes of determining the alternative minimum foreign tax credit, 75 percent of any withholding or income tax paid to a possession of the United States with respect to dividends received from a corporation eligible for the credit provided by section 936 shall be treated as a tax paid to a foreign country by the corporation receiving the dividend. " (II) LIMITATION. —I f the aggregate amount of the dividends referred to in subclause (I) for any taxable year exceeds the excess referred to in paragraph (1), the amount treated as tax paid to a foreign country under subclause (I) shall not exceed the amount which would be so treated without regard to this subclause multiplied by a fraction the numerator of which is the excess referred to in paragraph (1) and the denominator of which is the aggregate amount of such dividends. "(Ill) TREATMENT OF TAXES IMPOSED ON 936 COR- PORATION. —For purposes of this clause, taxes paid by any corporation eligible for the credit provided by section 936 to a possession of the United States shall be treated as a withholding tax paid with respect to any dividend paid by such corporation to the extent such taxes would be treated as paid by the corporation receiving the dividend under rules similar to the rules of section 902 (and the amount of any such dividend shall be increased by the amount so treated)." (D) Paragraph (1) of section 59(a) is amended by inserting "and" at the end of subparagraph (B), by striking subparagraph (C), and by redesignating subparagraph (D) as subparagraph (C). (E) Paragraph (2) of section 59A(b) is amended by striking "(and the last sentence of section 56(f)(2)(B))". (3) AMENDMENT RELATING TO REPEAL OF SECTION 124. —Subsection (f) of section 125 is amended by striking "section 117, 124," and inserting "section 117,". (4) AMENDMENT RELATING TO REPEAL OF SECTION 128. — Paragraph (2) of section 265(a) is amended by striking "subtitle" and all that follows down through the period at the end thereof and inserting "subtitle." (5) AMENDMENT RELATING TO REPEAL OF SECTION I70(i). — Section 170 is amended by redesignating subsections (j), (k), (1), (m), and (n) as subsections (i), (j), (k), (1), and (m), respectively. (6) AMENDMENTS RELATING TO REPEAL OF AMORTIZATION PROVI- SIONS.— (A) Subsection (a) of section 48 is amended by striking paragraph (8).