115 STAT. 144 PUBLIC LAW 107-16^JUNE 7, 2001 of this subsection and subsection (k), including regulations permitting appropriate aggregation of plans and contributions.". Applicability. (b) EFFECTIVE DATE. —The amendment made by this section 26 USC 401 note, shall apply to years beginning after December 31, 2001. Subtitle G—Miscellaneous Provisions SEC. 671. TAX TREATMENT AND INFORMATION REQUIREMENTS OF ALASKA NATIVE SETTLEMENT TRUSTS. (a) TREATMENT OF ALASKA NATIVE SETTLEMENT TRUSTS.— Subpart A of part I of subchapter J of chapter 1 (relating to general rules for taxation of trusts and estates) is amended by adding at the end the following new section: "SEC. 646. TAX TREATMENT OF ELECTING ALASKA NATIVE SETTLE- MENT TRUSTS. "(a) IN GENERAL.—I f an election under this section is in effect with respect to any Settlement Trust, the provisions of this section shall apply in determining the income tax treatment of the Settlement Trust and its beneficiaries with respect to the Settlement Trust. "(b) TAXATION OF INCOME OF TRUST. —Except as provided in subsection (f)(l)(B)(ii)— f "(1) IN GENERAL.— T here is hereby imposed on the taxable income of an electing Settlement Trust, other than its net capital gain, a tax at the lowest rate specified in section 1(c). "(2) CAPITAL GAIN.— In the case of an electing Settlement Trust with a net capital gain for the taxable year, a tax is hereby imposed on such gain at the rate of tax which would apply to such gain if the taxpayer were subject to a tax on its other taxable income at only the lowest rate specified in section 1(c). Any such tax shall be in lieu of the income tax otherwise imposed by this chapter on such income or gain. "(c) ONE-TIME ELECTION.— "(1) IN GENERAL.—^A Settlement Trust may elect to have the provisions of this section apply to the trust and its beneficiaries. "(2) TIME AND METHOD OF ELECTION.An election under paragraph (1) shall be made by the trustee of such trust— "(A) on or before the due date (including extensions) for filing the Settlement Trust's return of tax for the first taxable year of such trust ending after the date of the enactment of this section, and "(B) by attaching to such return of tax a statement specifically providing for such election. " (3) PERIOD ELECTION IN EFFECT. —Except as provided in subsection (f), an election under this subsection— "(A) shall apply to the first taxable year described in paragraph (2)(A) and all subsequent taxable years, and "(B) may not be revoked once it is made. " (d) CONTRIBUTIONS TO TRUST. — "(1) BENEFICLA.RIES OF ELECTING TRUST NOT TAXED ON CON- TRIBUTIONS.— In the case of an electing Settlement Trust, no amount shall be includible in the gross income of a beneficiary of such trust by reason of a contribution to such trust.
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