Page:United States Statutes at Large Volume 92 Part 3.djvu/190

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PUBLIC LAW 95-000—MMMM. DD, 1978

92 STAT. 2822

PUBLIC LAW 95-600—NOV. 6, 1978 "(B) CAP WHERE INCOME IS LESS THAN $6,000.—The tax imposed by subparagraph (A) shall not exceed 34 percent of the amount by which the taxable investment income exceeds $3,000."

26 USC 826.

Ante, p. 2820.

(10) ELECTION BY MUTUAL INSURANCE COMPANY WHICH IS A

RECIPROCAL.—Paragraph (1) of section 826(c) (relating to exception) is amended to read as follows: "(1) is subject to the tax imposed by section 11;". (11) REGULATED INVESTMENT COMPANIES.—Paragraph (1)

26 USC 852.

of

section 852(b) (relating to method of taxation of companies and shareholders) is amended to read as follows: "(1) IMPOSITION OF TAX ON REGULATED INVESTMENT COMPA-

NIES.—There is hereby imposed for each taxable year upon the investment company taxable income of every regulated investment company a tax computed as provided in section 11, as though the investment company taxable income were the taxable income referred to in section 11." (12) REAL ESTATE INVESTMENT TRUSTS.—Paragraph (1) of section

26 USC 857.

857(b) (relating to imposition of normal tax and surtax on real estate investment trusts) is amended to read as follows: "(1) IMPOSITION OF TAX ON REAL ESTATE INVESTMENT TRUSTS.—

There is hereby imposed for each taxable year on the real estate investment trust taxable income of every real estate investment trust a tax computed as provided in section 11, as though the real estate investment trust taxable income were the taxable income referred to in section 11." (13) TAX ON INCOME OF FOREIGN CORPORATIONS CONNECTED WITH

26 USC 882.

26 USC 907. 26 USC 901.

UNITED STATES BUSINESS.—The heading of subsection (a) of section 882 (relating to tax on income of foreign corporations connected with United States business) and the heading of paragraph (1) of such subsection are amended to read as follows: "(a) IMPOSITION OF TAX.— "(1) IN GENERAL.—". (14) FOREIGN TAX CREDIT.—Paragraph (2) of section 907(a)

(relating to reduction in amount allowed as foreign tax under section 901) is amended to read as follows: "(2) the percentage which is equal to the highest rate of tax specified in section 11(b)." (15) SPECIAL DEDUCTION FOR WESTERN HEMISPHERE TRADE CORPO-

26 USC 922.

RATION.—Subparagraph (B) of section 922(a)(2) (relating to general rule) is amended by striking out "the sum of the normal tax rate and the surtax rate for the taxable year prescribed by section 11" and inserting in lieu thereof "the highest rate of tax specified in section 11(b)." (16) ELECTION BY INDIVIDUALS TO BE SUBJECT TO TAX AT CORPO-

26 USC 962.

RATE RATES.—Subsection (c) of section 962 (relating to surtax exemption with respect to individuals subject to tax at corporate rates) is amended to read as follows: "(c) PRO RATION OF EACH SECTION 11 BRACKET AMOUNT.—For

26 USC 951.

purposes of applying subsection (a)(1), the amount in each taxable income bracket in the tax table in section 11(b) shall not exceed an amount which bears the same ratio to such bracket amount as the amount included in the gross income of the United States shareholder under section 951(a) for the taxable year bears to such shareholder's pro rata share of the earnings and profits for the taxable year of all controlled foreign corporations with respect to