718
PUBLIC LAW_91-172-:DEC. 30, 1969
[83 STAT.
" (B) the basis of the assets of such trust which are treated under subparagraph (A) as being owned by a holder of an interest in such trust shall be the same as the basis of his interest in such trust; and " (C) in determining the period for which the holder of an interest in such trust has held the assets of the trust which are treated under subparagraph (A) as being owned by him, there shall be included the period for which such holder has held his interest in such trust. This subsection shall not apply in the case of a unit investment trust which is a segregated asset account under the insurance laws or regulations of a State." (b) EFFECTIVE DATE.—The amendment made by subsection (a) shall apply to taxable years of unit investment trusts ending after December ol, 15)()8, and to taxable years of holders of interests ni such trusts ending with or within such taxable years of such trusts. The enactment of this section shall not be construed to result in the realization of gain or loss by any unit investment trust or by any holder of an interest in a unit investment trust. SEC. 909. FOREIGN CORPORATIONS NOT AVAILED OF TO REDUCE TAXES. (a)
26 USC 954°^'
EXCLUSION FROM FOREICXX BASE COMPANY INCOME.—Section
954(b)(4) (relating to exception for foreign corporations not availed of to reduce taxes) is amended to read as follows: "(4)
68A Stat. 302; 26 USC 10311038.
EXCEPTION FOR FOI{EIGN CORPOIJATIONS NOT AVAILED OF TO
REDUCE TAXES.—For purposes of subsection (a), foreign base company income does not include any item of income receiA'ed by a controlled foreign corporation if it is established to the satisfaction of the Secretary or his delegate that neither— " (A) the creation or organization of such controlled foreign corporation under the laws of the foreign country in which it is incorporated (or, in the case of a controlled foreign corporation which is an acquired corporation, the acquisition of such corporation created or organized under the laws of the foreign country in which it is incorporated), nor " (B) the effecting of the transaction giving rise to such income through the controlled foreign corporation, has as one of its significant purposes a substantial reduction of income, war profits, or excess profits or similar taxes." (b) EFFECTIVE DATE.—The amendment made by subsection (a) shall apply to taxable years ending after October 9,19(59. SEC. 910. SALES OF CERTAIN LOW-INCOME HOUSING PROJECTS. (a) NoNRECO(}NITION OF (xAIN IN CASE OF APPROVED DISPOSITIONS.— Part III of Subchapter O of chapter 1 (relating to common nontax'ible exchanges) is amended by adding at the end thereof the following new section: "SEC. 1039. CERTAIN SALES OF LOW-INCOME HOUSING PROJECTS. " (a) NoNRECO(JNrnoN OF GAIN.—If^— "(1) a qualified housing project is sold or disposed of by the taxpayer in an approved disposition, and "(2) within the reinvestment period the taxpayer constructs, reconstructs, or accjuires another qualified housing project, then, at the election of the taxpayer, gain from such approved disposition shall be recognized only to the extent that the net amount realized on such approved disposition exceeds the cost of such other qualified housing project. An election under this subsection shall be made at such time and in such manner as the Secretary or his delegate prescribes by regulations.
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