PUBLIC LAW 98-369—JULY 18, 1984 reinsurance contracts) is amended by striking out "conventional coinsurance contract" and inserting in lieu thereof "reinsurance contract". (h) AMENDMENT RELATED TO SECTION 281A.—Paragraph (2) of section 281AG3) of the Tax Equity and Fiscal Responsibility Act of 1982 is amended by striking out "subsection (a)" and inserting in lieu thereof "paragraph (1)". (c) AMENDMENT RELATED TO SECTION 292.—Paragraph (2) of section 7430(a) (relating to awarding of court costs and certain fees) is amended by striking out "including the Tax Court" and inserting in lieu thereof "including the Tax Court and the United States Claims Court". (d) AMENDMENT RELATED TO SECTION 309.—Paragraph (2) of section 6042(b) (relating to exceptions from dividend reporting requirements) is amended to read as follows: "(2) EXCEPTIONS.—For purposes of this section, the term 'dividend' does not include any distribution or payment— "(A) to the extent provided in regulations prescribed by the Secretary— "(i) by a foreign corporation, or "(ii) to a foreign corporation, a nonresident alien, or a , partnership not engaged in a trade or business in the bii£ ^u United States and composed in whole or in part of , ^^, nonresident aliens, or Diifc u^g^ except to the extent otherwise provided in regulations prescribed by the Secretary, to any person described in section 6049(b)(4)." (e) AMENDMENTS RELATED TO SECTION 311.— (1) IN GENERAL.—Section 6045(c) (relating to returns of brokers) is amended by adding at the end thereof the following new paragraph: "(4) PERSON.—The term 'person' includes any governmental unit and any agency or instrumentality thereof." (2) N o PENALTY FOR PAYMENTS BEFORE JANUARY 1, 1985.—No
penalty shall be imposed under the Internal Revenue Code of 1954 with respect to any peison required (by reason of the amendment made by paragraph (1)) to file a return under section 6045 of such Code with respect to any payment before January 1, 1985, (f) AMENDMENT RELATED TO SECTION 314.—Subparagraph (E) of section 6678(a)(3) is amended by striking out "section 6053(c)" and inserting in lieu thereof "section 6053". (g) AMENDMENTS RELATED TO SECTION 320.— (1) PERMITTING THE JOINDER OF REFUND AND INJUNCTIVE ACTIONS WITH RESPECT TO CERTAIN PENALTIES.—Section 7422 (relat-
98 STAT. 961
A,
26 USC 7275 "ote. 26 USC 7430.
26 USC 6042. -( Hi
*~
^..^,, '"""' ^ ^'
., 97 Stat. 370. 26 USC 6049. 26 USC 6045. K
-, a
26 USC 6045
"°*® 26 USC l et seq.
97 Stat. 381. 26 USC 6678. 26 USC 7422.
ing to civil actions for refund) is amended by redesignating subsection (i) as subsection (j) and by inserting after subsection (h) the following new subsection: "(i) SPECIAL RULE FOR ACTIONS WITH RESPECT TO TAX SHELTER PROMOTER AND UNDERSTATEMENT PENALTIES.—No action or proceed-
ing may be brought in the United States Claims Court for any refund or credit of a penalty imposed by section 6700 (relating to penalty for promoting abusive tax shelters, etc.) or section 6701 (relating to penalties for aiding and abetting understatement of tax liability)."
,,
- f
�
