120 STAT. 346
PUBLIC LAW 109–222—MAY 17, 2006
Sec. 505. Treatment of distributions attributable to FIRPTA gains. Sec. 506. Prevention of avoidance of tax on investments of foreign persons in United States real property through wash sale transactions. Sec. 507. Section 355 not to apply to distributions involving disqualified investment companies. Sec. 508. Loan and redemption requirements on pooled financing requirements. Sec. 509. Partial payments required with submission of offers-in-compromise. Sec. 510. Increase in age of minor children whose unearned income is taxed as if parent’s income. Sec. 511. Imposition of withholding on certain payments made by government entities. Sec. 512. Conversions to Roth IRAs. Sec. 513. Repeal of FSC/ETI binding contract relief. Sec. 514. Only wages attributable to domestic production taken into account in determining deduction for domestic production. Sec. 515. Modification of exclusion for citizens living abroad. Sec. 516. Tax involvement of accommodation parties in tax shelter transactions.
TITLE I—EXTENSION AND MODIFICATION OF CERTAIN PROVISIONS SEC. 101. INCREASED EXPENSING FOR SMALL BUSINESS.
Subsections (b)(1), (b)(2), (b)(5), (c)(2), and (d)(1)(A)(ii) of section 179 (relating to election to expense certain depreciable business assets) are each amended by striking ‘‘2008’’ and inserting ‘‘2010’’.
26 USC 179.
SEC. 102. CAPITAL GAINS AND DIVIDENDS RATES. 26 USC 1 note.
Section 303 of the Jobs and Growth Tax Relief Reconciliation Act of 2003 is amended by striking ‘‘December 31, 2008’’ and inserting ‘‘December 31, 2010’’. SEC. 103. CONTROLLED FOREIGN CORPORATIONS.
(a) SUBPART F EXCEPTION FOR ACTIVE FINANCING.— (1) EXEMPT INSURANCE INCOME.—Paragraph (10) of section 953(e) (relating to application) is amended— (A) by striking ‘‘January 1, 2007’’ and inserting ‘‘January 1, 2009’’, and (B) by striking ‘‘December 31, 2006’’ and inserting ‘‘December 31, 2008’’. (2) EXCEPTION TO TREATMENT AS FOREIGN PERSONAL HOLDING COMPANY INCOME.—Paragraph (9) of section 954(h) (relating to application) is amended by striking ‘‘January 1, 2007’’ and inserting ‘‘January 1, 2009’’. (b) LOOK-THROUGH TREATMENT OF PAYMENTS BETWEEN RELATED CONTROLLED FOREIGN CORPORATIONS UNDER THE FOREIGN PERSONAL HOLDING COMPANY RULES.— (1) IN GENERAL.—Subsection (c) of section 954 (relating to foreign personal holding company income) is amended by adding at the end the following new paragraph: ‘‘(6) LOOK-THRU RULE FOR RELATED CONTROLLED FOREIGN CORPORATIONS.— ‘‘(A) IN GENERAL.—For purposes of this subsection, dividends, interest, rents, and royalties received or accrued from a controlled foreign corporation which is a related person shall not be treated as foreign personal holding company income to the extent attributable or properly allocable (determined under rules similar to the rules of subparagraphs (C) and (D) of section 904(d)(3)) to income of the related person which is not subpart F income. For
VerDate 14-DEC-2004
10:20 Jul 12, 2007
Jkt 059194
PO 00001
Frm 00344
Fmt 6580
Sfmt 6581
E:\PUBLAW\PUBL001.109
APPS06
PsN: PUBL001
�
