PUBLIC LAW 98-369—JULY 18, 1984
98 STAT. 667
"(2) are received from a related person which is not a foreign personal holding company (determined without regard to this subsection)." (d) EFFECTIVE DATES.— 26 USC 551 note. (1) SUBSECTIONS (a) AND (b).—
(A) IN GENERAL.—Except as provided in subparagraph (B), the amendments made by subsections (a) and (b) shall apply to taxable years of foreign corporations beginning after December 31, 1983.
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(B) 1-YEAR EXTENSION FOR CERTAIN TRUSTS CREATED BEFORE JUNE 30, 1953.—
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(ii)
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(i) IN GENERAL.—The amendment made by subsection (b) shall apply to taxable years of a foreign corporation beginning after December 31, 1984, with respect to stock of such corporation which is held (directly or indirectly, within the meaning of section 554 of the Internal Revenue Code of 1954) by a trust created before June 30, 1953, if— (I) none of the beneficiaries of such trust was a citizen or resident of the United States at the time of its creation or within 5 years thereafter, and (II) such trust does not, after July 1, 1983, acquire (directly or indirectly) stock of any foreign personal holding company other than a company described in clause (ii). DESCRIPTION OF COMPANY.—A company is
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scribed in this clause if— (I) substantially all of the assets of such company are stock or assets previously held by such trust, or (II) such company ceases to be a foreign personal holding company before January 1, 1985.
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(2) SUBSECTION (C).—
(A) The amendment made by paragraph (1) of subsection 26 USC 951 note, (c) shall apply to taxable years of United States shareholders beginning after the date of the enactment of this Act. (B) The amendment made by paragraph (2) of subsection 26 USC 552 note, (c) shall apply to taxable years of foreign corporations beginning after March 15, 1984. SEC. 133. AMENDMENTS RELATED TO SECTION 1248. (a) SECTION 1248 To APPLY TO CERTAIN INDIRECT TRANSFERS OF STOCK IN A FOREIGN CORPORATION.—Section 1248 (relating to gain
26 USC 1248.
from certain sales or exchanges of stock in foreign corporations) is amended by adding at the end thereof the following new subsection: "(i) TREATMENT OF CERTAIN INDIRECT TRANSFERS.—
"(1) IN GENERAL.—If any shareholder of a 10-percent corporate shareholder of a foreign corporation exchanges stock of the 10-percent corporate shareholder for stock of the foreign corporation, for purposes of this section, the stock of the foreign corporation received in such exchange shall be treated as if it had been— "(A) issued to the 10-percent corporate shareholder, and "(B) then distributed by the 10-percent corporate shareholder to such shareholder in redemption of his stock. (2) 10-PERCENT CORPORATE SHAREHOLDER DEFINED.—For pur-
poses of this subsection, the term '10-percent corporate shareholder' means any domestic corporation which, as of the day
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