83 STAT. ]
PUBLIC LAW 91-172-DEC. 30, 1969
mineral income from sources within such country or possession which would (but for this paragraph) be allowed under such subsection shall be reduced by the amount (if any) by which " (A) the amount of such taxes (or, if smaller, the amount of the tax which would be computed under this chapter with respect to such income determined without the deduction allowed under section 613), exceeds " (B) the amount of the tax computed under this chapter with respect to such income. "(2)
FOREIGN MINERAL INCOME DEFINED.—For p u r p O S e S
Ante, p. 629.
paragraph (1), the term 'foreign mineral income' means income derived from the extraction of minerals from mines, wells, or other natural deposits, the processing of such minerals into their primary products, and the transportation, distribution, or sale of such minerals or primary products. Such term includes, but is n.., ».' not limited to-y jr- i.;u^ " (A) dividends received from a foreign corporation in respect of which taxes are deemed paid by the taxpayer under section 902, to the extent such dividends are attributable to ^^ Stat. 999. foreign mineral income, and ^^ ^^^ ^°^" " (B) that portion of the taxpayer's distributive share of the income of partnerships attributable to foreign mineral income" (b) ELECTION OF OVERALL LIMITATION.—Section 904(b) (relating '^'* ^*^*- lo^oto election of overall limitation) is amended— (1) by striking out "with the consent of the Secretary or his delegate with respect to any taxable year" in paragraph (1) and inserting in lieu thereof " (A) with the consent of the Secretary or his delegate with respect to any taxable year or (B) for the taxpayer's first taxable year beginning after December 31, 1969", and (2) by striking o u t ' ' I f a taxpayer" in paragraph (2) and insert- , ing in lieu thereof "Except in a case to which paragraph (1)(B) applies, if the taxpayer". (c) EFFECTIVE DATE.—The amendments made by this section shall apply with respect to taxable years beginning after December 31, 1969.
Subtitle B—Capital Gains and Losses
SEC. 511. INCREASE IN ALTERNATIVE CAPITAL GAINS TAX. (a) DEFINITION OF N E T SECTION 1201 GAIN.—Section 1222 (relating
^^^ ^'^'- ^^'^^
to definition of terms applicable to capital gains and losses) is amended by adding at the end thereof the following new paragraph: " (11) N E T SECTION 1201 GAIN.—The term 'net section 1201 gain' means the excess of the net long-term capital gain for the taxable year over the net short-term capital loss for such year." (b) INCREASE I N ALTERNATIVE TAX EATES.—Section 1201 (relating
to alternative tax) is amended to read as follows: "SEC. 1201. ALTERNATIVE TAX. '
"(a) CORPORATIONS.—If for any taxable year a corporation has a net section 1201 gain, then, in lieu of the tax imposed by sections 11,511, 821 (a) or (c), and 831 (a), there is hereby imposed a tax (if such tax is less than the tax imposed by such sections) which shall consist of the sum of a tax computed on the taxable income reduced by the amount of the net section 1201 gain, at the rates and in the manner as if this subsection had not been enacted, plus—
26 USC 1201.
7/ltat^ 997; ' Ante. pp. 536, 585. ""^