[Congressional Bills 110th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4839 Considered and Passed House (CPH)]
110th CONGRESS
1st Session
H. R. 4839
To amend the Internal Revenue Code of 1986 to make technical
corrections, and for other purposes.
_______________________________________________________________________
IN THE HOUSE OF REPRESENTATIVES
December 19, 2007
Mr. Rangel introduced the following bill; which was referred to the
Committee on Ways and Means
December 19, 2007
The Committee on Ways and Means discharged; considered and passed
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to make technical
corrections, and for other purposes.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE; AMENDMENT OF 1986 CODE; TABLE OF CONTENTS.
(a) Short Title.--This Act may be cited as the ``Tax Technical
Corrections Act of 2007''.
(b) Amendment of 1986 Code.--Except as otherwise expressly
provided, whenever in this Act an amendment or repeal is expressed in
terms of an amendment to, or repeal of, a section or other provision,
the reference shall be considered to be made to a section or other
provision of the Internal Revenue Code of 1986.
(c) Table of Contents.--The table of contents of this Act is as
follows:
Sec. 1. Short title; amendment of 1986 Code; table of contents.
Sec. 2. Amendment related to the Tax Relief and Health Care Act of
2006.
Sec. 3. Amendments related to title XII of the Pension Protection Act
of 2006.
Sec. 4. Amendments related to the Tax Increase Prevention and
Reconciliation Act of 2005.
Sec. 5. Amendments related to the Safe, Accountable, Flexible,
Efficient Transportation Equity Act: A
Legacy for Users.
Sec. 6. Amendments related to the Energy Policy Act of 2005.
Sec. 7. Amendments related to the American Jobs Creation Act of 2004.
Sec. 8. Amendments related to the Economic Growth and Tax Relief
Reconciliation Act of 2001.
Sec. 9. Amendments related to the Tax Relief Extension Act of 1999.
Sec. 10. Amendment related to the Internal Revenue Service
Restructuring and Reform Act of 1998.
Sec. 11. Clerical corrections.
SEC. 2. AMENDMENT RELATED TO THE TAX RELIEF AND HEALTH CARE ACT OF
2006.
(a) Amendment Related to Section 402 of Division A of the Act.--
Subparagraph (A) of section 53(e)(2) is amended to read as follows:
``(A) In general.--The term `AMT refundable credit
amount' means, with respect to any taxable year, the
amount (not in excess of the long-term unused minimum
tax credit for such taxable year) equal to the greater
of--
``(i) $5,000,
``(ii) 20 percent of the long-term unused
minimum tax credit for such taxable year, or
``(iii) the amount (if any) of the AMT
refundable credit amount determined under this
paragraph for the taxpayer's preceding taxable
year (as determined before any reduction under
subparagraph (B)).''.
(b) Effective Date.--The amendment made by this section shall take
effect as if included in the provision of the Tax Relief and Health
Care Act of 2006 to which it relates.
SEC. 3. AMENDMENTS RELATED TO TITLE XII OF THE PENSION PROTECTION ACT
OF 2006.
(a) Amendment Related to Section 1201 of the Act.--Subparagraph (D)
of section 408(d)(8) is amended by striking ``all amounts distributed
from all individual retirement plans were treated as 1 contract under
paragraph (2)(A) for purposes of determining the inclusion of such
distribution under section 72'' and inserting ``all amounts in all
individual retirement plans of the individual were distributed during
such taxable year and all such plans were treated as 1 contract for
purposes of determining under section 72 the aggregate amount which
would have been so includible''.
(b) Amendment Related to Section 1203 of the Act.--Subsection (d)
of section 1366 is amended by adding at the end the following new
paragraph:
``(4) Application of limitation on charitable
contributions.--In the case of any charitable contribution of
property to which the second sentence of section 1367(a)(2)
applies, paragraph (1) shall not apply to the extent of the
excess (if any) of--
``(A) the shareholder's pro rata share of such
contribution, over
``(B) the shareholder's pro rata share of the
adjusted basis of such property.''.
(c) Amendment Related to Section 1215 of the Act.--Subclause (I) of
section 170(e)(7)(D)(i) is amended by striking ``related'' and
inserting ``substantial and related''.
(d) Amendments Related to Section 1218 of the Act.--
(1) Section 2055 is amended by striking subsection (g) and
by redesignating subsection (h) as subsection (g).
(2) Subsection (e) of section 2522 is amended--
(A) by striking paragraphs (2) and (4),
(B) by redesignating paragraph (3) as paragraph
(2), and
(C) by adding at the end of paragraph (2), as so
redesignated, the following new subparagraph:
``(C) Initial fractional contribution.--For
purposes of this paragraph, the term `initial
fractional contribution' means, with respect to any
donor, the first gift of an undivided portion of the
donor's entire interest in any tangible personal
property for which a deduction is allowed under
subsection (a) or (b).''.
(e) Amendments Related to Section 1219 of the Act.--
(1) Paragraph (2) of section 6695A(a) is amended by
inserting ``a substantial estate or gift tax valuation
understatement (within the meaning of section 6662(g)),''
before ``or a gross valuation misstatement''.
(2) Paragraph (1) of section 6696(d) is amended by striking
``or under section 6695'' and inserting ``, section 6695, or
6695A''.
(f) Amendment Related to Section 1221 of the Act.--Subparagraph (A)
of section 4940(c)(4) is amended to read as follows:
``(A) There shall not be taken into account any
gain or loss from the sale or other disposition of
property to the extent that such gain or loss is taken
into account for purposes of computing the tax imposed
by section 511.''.
(g) Amendment Related to Section 1225 of the Act.--
(1) Subsection (b) of section 6104 is amended--
(A) by striking ``Information'' in the heading, and
(B) by adding at the end the following: ``Any
annual return which is filed under section 6011 by an
organization described in section 501(c)(3) and which
relates to any tax imposed by section 511 (relating to
imposition of tax on unrelated business income of
charitable, etc., organizations) shall be treated for
purposes of this subsection in the same manner as if
furnished under section 6033.''.
(2) Clause (ii) of section 6104(d)(1)(A) is amended to read
as follows:
``(ii) any annual return which is filed
under section 6011 by an organization described
in section 501(c)(3) and which relates to any
tax imposed by section 511 (relating to
imposition of tax on unrelated business income
of charitable, etc., organizations),''.
(3) Paragraph (2) of section 6104(d) is amended by striking
``section 6033'' and inserting ``section 6011 or 6033''.
(h) Amendment Related to Section 1231 of the Act.--Subsection (b)
of section 4962 is amended by striking ``or D'' and inserting ``D, or
G''.
(i) Amendment Related to Section 1242 of the Act.--
(1) Subclause (II) of section 4958(c)(3)(A)(i) is amended
by striking ``paragraph (1), (2), or (4) of section 509(a)''
and inserting ``subparagraph (C)(ii)''.
(2) Clause (ii) of section 4958(c)(3)(C) is amended to read
as follows:
``(ii) Exception.--Such term shall not
include--
``(I) any organization described in
paragraph (1), (2), or (4) of section
509(a), and
``(II) any organization which is
treated as described in such paragraph
(2) by reason of the last sentence of
section 509(a) and which is a supported
organization (as defined in section
509(f)(3)) of the organization to which
subparagraph (A) applies.''.
(j) Effective Date.--The amendments made by this section shall take
effect as if included in the provisions of the Pension Protection Act
of 2006 to which they relate.
SEC. 4. AMENDMENTS RELATED TO THE TAX INCREASE PREVENTION AND
RECONCILIATION ACT OF 2005.
(a) Amendments Related to Section 103 of the Act.--Paragraph (6) of
section 954(c) is amended by redesignating subparagraph (B) as
subparagraph (C) and inserting after subparagraph (A) the following new
subparagraph:
``(B) Exception.--Subparagraph (A) shall not apply
in the case of any interest, rent, or royalty to the
extent such interest, rent, or royalty creates (or
increases) a deficit which under section 952(c) may
reduce the subpart F income of the payor or another
controlled foreign corporation.''.
(b) Amendments Related to Section 202 of the Act.--
(1) Subparagraph (A) of section 355(b)(2) is amended to
read as follows:
``(A) it is engaged in the active conduct of a
trade or business,''.
(2) Paragraph (3) of section 355(b) is amended to read as
follows:
``(3) Special rules for determining active conduct in the
case of affiliated groups.--
``(A) In general.--For purposes of determining
whether a corporation meets the requirements of
paragraph (2)(A), all members of such corporation's
separate affiliated group shall be treated as one
corporation.
``(B) Separate affiliated group.--For purposes of
this paragraph, the term `separate affiliated group'
means, with respect to any corporation, the affiliated
group which would be determined under section 1504(a)
if such corporation were the common parent and section
1504(b) did not apply.
``(C) Treatment of trade or business conducted by
acquired member.--If a corporation became a member of a
separate affiliated group as a result of one or more
transactions in which gain or loss was recognized in
whole or in part, any trade or business conducted by
such corporation (at the time that such corporation
became such a member) shall be treated for purposes of
paragraph (2) as acquired in a transaction in which
gain or loss was recognized in whole or in part.
``(D) Regulations.--The Secretary shall prescribe
such regulations as are necessary or appropriate to
carry out the purposes of this paragraph, including
regulations which provide for the proper application of
subparagraphs (B), (C), and (D) of paragraph (2), and
modify the application of subsection (a)(3)(B), in
connection with the application of this paragraph.''.
(3) The Internal Revenue Code of 1986 shall be applied and
administered as if the amendments made by section 202 of the
Tax Increase Prevention and Reconciliation Act of 2005 and by
section 410 of division A of the Tax Relief and Health Care Act
of 2006 had never been enacted.
(c) Amendment Related to Section 515 of the Act.--Subsection (f) of
section 911 is amended to read as follows:
``(f) Determination of Tax Liability.--
``(1) In general.--If, for any taxable year, any amount is
excluded from gross income of a taxpayer under subsection (a),
then, notwithstanding sections 1 and 55--
``(A) if such taxpayer has taxable income for such
taxable year, the tax imposed by section 1 for such
taxable year shall be equal to the excess (if any) of--
``(i) the tax which would be imposed by
section 1 for such taxable year if the
taxpayer's taxable income were increased by the
amount excluded under subsection (a) for such
taxable year, over
``(ii) the tax which would be imposed by
section 1 for such taxable year if the
taxpayer's taxable income were equal to the
amount excluded under subsection (a) for such
taxable year, and
``(B) if such taxpayer has a taxable excess (as
defined in section 55(b)(1)(A)(ii)) for such taxable
year, the amount determined under the first sentence of
section 55(b)(1)(A)(i) for such taxable year shall be
equal to the excess (if any) of--
``(i) the amount which would be determined
under such sentence for such taxable year
(subject to the limitation of section 55(b)(3))
if the taxpayer's taxable excess (as so
defined) were increased by the amount excluded
under subsection (a) for such taxable year,
over
``(ii) the amount which would be determined
under such sentence for such taxable year if
the taxpayer's taxable excess (as so defined)
were equal to the amount excluded under
subsection (a) for such taxable year.
``(2) Special rules.--
``(A) Regular tax.--In applying section 1(h) for
purposes of determining the tax under paragraph
(1)(A)(i) for any taxable year in which, without regard
to this subsection, the taxpayer's net capital gain
exceeds taxable income (hereafter in this subparagraph
referred to as the capital gain excess)--
``(i) the taxpayer's net capital gain
(determined without regard to section 1(h)(11))
shall be reduced (but not below zero) by such
capital gain excess,
``(ii) the taxpayer's qualified dividend
income shall be reduced by so much of such
capital gain excess as exceeds the taxpayer's
net capital gain (determined without regard to
section 1(h)(11) and the reduction under clause
(i)), and
``(iii) adjusted net capital gain,
unrecaptured section 1250 gain, and 28-percent
rate gain shall each be determined after
increasing the amount described in section
1(h)(4)(B) by such capital gain excess.
``(B) Alternative minimum tax.--In applying section
55(b)(3) for purposes of determining the tax under
paragraph (1)(B)(i) for any taxable year in which,
without regard to this subsection, the taxpayer's net
capital gain exceeds the taxable excess (as defined in
section 55(b)(1)(A)(ii))--
``(i) the rules of subparagraph (A) shall
apply, except that such subparagraph shall be
applied by substituting `the taxable excess (as
defined in section 55(b)(1)(A)(ii))' for
`taxable income', and
``(ii) the reference in section 55(b)(3)(B)
to the excess described in section 1(h)(1)(B)
shall be treated as a reference to such excess
as determined under the rules of subparagraph
(A) for purposes of determining the tax under
paragraph (1)(A)(i).
``(C) Definitions.--Terms used in this paragraph
which are also used in section 1(h) shall have the
respective meanings given such terms by section 1(h),
except that in applying subparagraph (B) the
adjustments under part VI of subchapter A shall be
taken into account.''.
(d) Effective Date.--
(1) In general.--Except as otherwise provided in this
subsection, the amendments made by this section shall take
effect as if included in the provisions of the Tax Increase
Prevention and Reconciliation Act of 2005 to which they relate.
(2) Modification of active business definition under
section 355.--
(A) In general.--Except as otherwise provided in
this paragraph, the amendments made by subsection (b)
shall apply to distributions made after May 17, 2006.
(B) Transition rule.--The amendments made by
subsection (b) shall not apply to any distribution
pursuant to a transaction which is--
(i) made pursuant to an agreement which was
binding on May 17, 2006, and at all times
thereafter,
(ii) described in a ruling request
submitted to the Internal Revenue Service on or
before such date, or
(iii) described on or before such date in a
public announcement or in a filing with the
Securities and Exchange Commission.
(C) Election out of transition rule.--Subparagraph
(B) shall not apply if the distributing corporation
elects not to have such subparagraph apply to
distributions of such corporation. Any such election,
once made, shall be irrevocable.
(D) Special rule for certain pre-enactment
distributions.--For purposes of determining the
continued qualification under section 355(b)(2)(A) of
the Internal Revenue Code of 1986 of distributions made
on or before May 17, 2006, as a result of an
acquisition, disposition, or other restructuring after
such date, such distribution shall be treated as made
on the date of such acquisition, disposition, or
restructuring for purposes of applying subparagraphs
(A) through (C) of this paragraph. The preceding
sentence shall only apply with respect to the
corporation that undertakes such acquisition,
disposition, or other restructuring, and only if such
application results in continued qualification under
section 355(b)(2)(A) of such Code.
(3) Amendment related to section 515 of the act.--The
amendment made by subsection (c) shall apply to taxable years
beginning after December 31, 2006.
SEC. 5. AMENDMENTS RELATED TO THE SAFE, ACCOUNTABLE, FLEXIBLE,
EFFICIENT TRANSPORTATION EQUITY ACT: A LEGACY FOR USERS.
(a) Amendments Related to Section 11113 of the Act.--
(1) Paragraph (3) of section 6427(i) is amended--
(A) by inserting ``or under subsection (e)(2) by
any person with respect to an alternative fuel (as
defined in section 6426(d)(2))'' after ``section 6426''
in subparagraph (A),
(B) by inserting ``or (e)(2)'' after ``subsection
(e)(1)'' in subparagraphs (A)(i) and (B), and
(C) by striking ``alcohol fuel and biodiesel
mixture credit'' and inserting ``mixture credits and
the alternative fuel credit'' in the heading thereof.
(2) Subparagraph (F) of section 6426(d)(2) is amended by
striking ``hydrocarbons'' and inserting ``fuel''.
(3) Section 6426 is amended by adding at the end the
following new subsection:
``(h) Denial of Double Benefit.--No credit shall be determined
under subsection (d) or (e) with respect to any fuel with respect to
which credit may be determined under subsection (b) or (c) or under
section 40 or 40A.''.
(b) Effective Date.--The amendments made by this section shall take
effect as if included in the provisions of the SAFETEA-LU to which they
relate.
SEC. 6. AMENDMENTS RELATED TO THE ENERGY POLICY ACT OF 2005.
(a) Amendment Related to Section 1306 of the Act.--Paragraph (2) of
section 45J(b) is amended to read as follows:
``(2) Amount of national limitation.--The aggregate amount
of national megawatt capacity limitation allocated by the
Secretary under paragraph (3) shall not exceed 6,000
megawatts.''.
(b) Amendments Related to Section 1342 of the Act.--
(1) So much of subsection (b) of section 30C as precedes
paragraph (1) thereof is amended to read as follows:
``(b) Limitation.--The credit allowed under subsection (a) with
respect to all qualified alternative fuel vehicle refueling property
placed in service by the taxpayer during the taxable year at a location
shall not
exceed--''.
(2) Subsection (c) of section 30C is amended to read as
follows:
``(c) Qualified Alternative Fuel Vehicle Refueling Property.--For
purposes of this section, the term `qualified alternative fuel vehicle
refueling property' has the same meaning as the term `qualified clean-
fuel vehicle refueling property' would have under section 179A if--
``(1) paragraph (1) of section 179A(d) did not apply to
property installed on property which is used as the principal
residence (within the meaning of section 121) of the taxpayer,
and
``(2) only the following were treated as clean-burning
fuels for purposes of section 179A(d):
``(A) Any fuel at least 85 percent of the volume of
which consists of one or more of the following:
ethanol, natural gas, compressed natural gas, liquified
natural gas, liquefied petroleum gas, or hydrogen.
``(B) Any mixture--
``(i) which consists of two or more of the
following: biodiesel (as defined in section
40A(d)(1)), diesel fuel (as defined in section
4083(a)(3)), or kerosene, and
``(ii) at least 20 percent of the volume of
which consists of biodiesel (as so defined)
determined without regard to any kerosene in
such mixture.''.
(c) Amendments Related to Section 1351 of the Act.--
(1) Paragraph (3) of section 41(a) is amended by inserting
``for energy research'' before the period at the end.
(2) Paragraph (6) of section 41(f) is amended by adding at
the end the following new subparagraph:
``(E) Energy research.--The term `energy research'
does not include any research which is not qualified
research.''.
(d) Amendments Related to Section 1362 of the Act.--
(1)(A) Paragraph (1) of section 4041(d) is amended by
adding at the end the following new sentence: ``No tax shall be
imposed under the preceding sentence on the sale or use of any
liquid if tax was imposed with respect to such liquid under
section 4081 at the Leaking Underground Storage Tank Trust Fund
financing rate.''.
(B) Paragraph (3) of section 4042(b) is amended to read as
follows:
``(3) Exception for fuel on which leaking underground
storage tank trust fund financing rate separately imposed.--The
Leaking Underground Storage Tank Trust Fund financing rate
under paragraph (2)(B) shall not apply to the use of any fuel
if tax was imposed with respect to such fuel under section
4041(d) or 4081 at the Leaking Underground Storage Tank Trust
Fund financing rate.''.
(C) Notwithstanding section 6430 of the Internal Revenue
Code of 1986, a refund, credit, or payment may be made under
subchapter B of chapter 65 of such Code for taxes imposed with
respect to any liquid after September 30, 2005, and before the
date of the enactment of this Act under section 4041(d)(1) or
4042 of such Code at the Leaking Underground Storage Tank Trust
Fund financing rate to the extent that tax was imposed with
respect to such liquid under section 4081 at the Leaking
Underground Storage Tank Trust Fund financing rate.
(2)(A) Paragraph (5) of section 4041(d) is amended--
(i) by striking ``(other than with respect to any
sale for export under paragraph (3) thereof)'', and
(ii) by adding at the end the following new
sentence: ``The preceding sentence shall not apply with
respect to subsection (g)(3) and so much of subsection
(g)(1) as relates to vessels (within the meaning of
section 4221(d)(3)) employed in foreign trade or trade
between the United States and any of its
possessions.''.
(B) Section 4082 is amended--
(i) by striking ``(other than such tax at the
Leaking Underground Storage Tank Trust Fund financing
rate imposed in all cases other than for export)'' in
subsection (a), and
(ii) by redesignating subsections (f) and (g) as
subsections (g) and (h), respectively, and by inserting
after subsection (e) the following new subsection:
``(f) Exception for Leaking Underground Storage Tank Trust Fund
Financing Rate.--
``(1) In general.--Subsection (a) shall not apply to the
tax imposed under section 4081 at the Leaking Underground
Storage Tank Trust Fund financing rate.
``(2) Exception for export, etc.--Paragraph (1) shall not
apply with respect to any fuel if the Secretary determines that
such fuel is destined for export or for use by the purchaser as
supplies for vessels (within the meaning of section 4221(d)(3))
employed in foreign trade or trade between the United States
and any of its possessions.''.
(C) Subsection (e) of section 4082 is amended--
(i) by striking ``an aircraft, the rate of tax
under section 4081(a)(2)(A)(iii) shall be zero.'' and
inserting ``an aircraft--
``(1) the rate of tax under section 4081(a)(2)(A)(iii)
shall be zero, and
``(2) if such aircraft is employed in foreign trade or
trade between the United States and any of its possessions, the
increase in such rate under section 4081(a)(2)(B) shall be
zero.''; and
(ii) by moving the last sentence flush with the
margin of such subsection (following the paragraph (2)
added by clause (i)).
(D) Section 6430 is amended to read as follows:
``SEC. 6430. TREATMENT OF TAX IMPOSED AT LEAKING UNDERGROUND STORAGE
TANK TRUST FUND FINANCING RATE.
``No refunds, credits, or payments shall be made under this
subchapter for any tax imposed at the Leaking Underground Storage Tank
Trust Fund financing rate, except in the case of fuels--
``(1) which are exempt from tax under section 4081(a) by
reason of section 4082(f)(2),
``(2) which are exempt from tax under section 4041(d) by
reason of the last sentence of paragraph (5) thereof, or
``(3) with respect to which the rate increase under section
4081(a)(2)(B) is zero by reason of section 4082(e)(2).''.
(3) Paragraph (5) of section 4041(d) is amended by
inserting ``(b)(1)(A),'' after ``subsections''.
(e) Effective Date.--
(1) In general.--Except as otherwise provided in this
subsection, the amendments made by this section shall take
effect as if included in the provisions of the Energy Policy
Act of 2005 to which they relate.
(2) Nonapplication of exemption for off-highway business
use.--The amendment made by subsection (d)(3) shall apply to
fuel sold for use or used after the date of the enactment of
this Act.
(3) Amendment made by the safetea-lu.--The amendment made
by subsection (d)(2)(C)(ii) shall take effect as if included in
section 11161 of the SAFETEA-LU.
SEC. 7. AMENDMENTS RELATED TO THE AMERICAN JOBS CREATION ACT OF 2004.
(a) Amendments Related to Section 339 of the Act.--
(1)(A) Section 45H is amended by striking subsection (d)
and by redesignating subsections (e), (f), and (g) as
subsections (d), (e), and (f), respectively.
(B) Subsection (d) of section 280C is amended to read as
follows:
``(d) Credit for Low Sulfur Diesel Fuel Production.--The deductions
otherwise allowed under this chapter for the taxable year shall be
reduced by the amount of the credit determined for the taxable year
under section 45H(a).''.
(C) Subsection (a) of section 1016 is amended by striking
paragraph (31) and by redesignating paragraphs (32) through
(37) as paragraphs (31) through (36), respectively.
(2)(A) Section 45H, as amended by paragraph (1), is amended
by adding at the end the following new subsection:
``(g) Election To Not Take Credit.--No credit shall be determined
under subsection (a) for the taxable year if the taxpayer elects not to
have subsection (a) apply to such taxable year.''.
(B) Subsection (m) of section 6501 is amended by inserting
``45H(g),'' after ``45C(d)(4),''.
(3)(A) Subsections (b)(1)(A), (c)(2), (e)(1), and (e)(2) of
section 45H (as amended by paragraph (1)) and section 179B(a)
are each amended by striking ``qualified capital costs'' and
inserting ``qualified costs''.
(B) The heading of paragraph (2) of section 45H(c) is
amended by striking ``capital''.
(C) Subsection (a) of section 179B is amended by inserting
``and which are properly chargeable to capital account'' before
the period at the end.
(b) Amendments Related to Section 710 of the Act.--
(1) Clause (ii) of section 45(c)(3)(A) is amended by
striking ``which is segregated from other waste materials
and''.
(2) Subparagraph (B) of section 45(d)(2) is amended by
inserting ``and'' at the end of clause (i), by striking clause
(ii), and by redesignating clause (iii) as clause (ii).
(c) Amendments Related to Section 848 of the Act.--
(1) Paragraph (2) of section 470(c) is amended to read as
follows:
``(2) Tax-exempt use property.--
``(A) In general.--The term `tax-exempt use
property' has the meaning given to such term by section
168(h), except that such section shall be applied--
``(i) without regard to paragraphs (1)(C)
and (3) thereof, and
``(ii) as if section 197 intangible
property (as defined in section 197), and
property described in paragraph (1)(B) or (2)
of section 167(f), were tangible property.
``(B) Exception for partnerships.--Such term shall
not include any property which would (but for this
subparagraph) be tax-exempt use property solely by
reason of section 168(h)(6).
``(C) Cross reference.--For treatment of
partnerships as leases to which section 168(h) applies,
see section 7701(e).''.
(2) Subparagraph (A) of section 470(d)(1) is amended by
striking ``(at any time during the lease term)'' and inserting
``(at all times during the lease term)''.
(d) Amendments Related to Section 888 of the Act.--
(1) Subparagraph (A) of section 1092(a)(2) is amended by
striking ``and'' at the end of clause (ii), by redesignating
clause (iii) as clause (iv), and by inserting after clause (ii)
the following new clause:
``(iii) if the application of clause (ii)
does not result in an increase in the basis of
any offsetting position in the identified
straddle, the basis of each of the offsetting
positions in the identified straddle shall be
increased in a manner which--
``(I) is reasonable, consistent
with the purposes of this paragraph,
and consistently applied by the
taxpayer, and
``(II) results in an aggregate
increase in the basis of such
offsetting positions which is equal to
the loss described in clause (ii),
and''.
(2)(A) Subparagraph (B) of section 1092(a)(2) is amended by
adding at the end the following flush sentence:
``A straddle shall be treated as clearly identified for
purposes of clause (i) only if such identification
includes an identification of the positions in the
straddle which are offsetting with respect other
positions in the straddle.''.
(B) Subparagraph (A) of section 1092(a)(2) is amended--
(i) by striking ``identified positions'' in clause
(i) and inserting ``positions'',
(ii) by striking ``identified position'' in clause
(ii) and inserting ``position'', and
(iii) by striking ``identified offsetting
positions'' in clause (ii) and inserting ``offsetting
positions''.
(C) Subparagraph (B) of section 1092(a)(3) is amended by
striking ``identified offsetting position'' and inserting
``offsetting position''.
(3) Paragraph (2) of section 1092(a) is amended by
redesignating subparagraph (C) as subparagraph (D) and
inserting after subparagraph (B) the following new
subparagraph:
``(C) Application to liabilities and obligations.--
Except as otherwise provided by the Secretary, rules
similar to the rules of clauses (ii) and (iii) of
subparagraph (A) shall apply for purposes of this
paragraph with respect to any position which is, or has
been, a liability or obligation.''.
(4) Subparagraph (D) of section 1092(a)(2), as redesignated
by paragraph (3), is amended by inserting ``the rules for the
application of this section to a position which is or has been
a liability or obligation, methods of loss allocation which
satisfy the requirements of subparagraph (A)(iii),'' before
``and the ordering rules''.
(e) Effective Date.--
(1) In general.--Except as otherwise provided in this
subsection, the amendments made by this section shall take
effect as if included in the provisions of the American Jobs
Creation Act of 2004 to which they relate.
(2) Identification requirement of amendment related to
section 888 of the american jobs creation act of 2004.--The
amendment made by subsection (d)(2)(A) shall apply to straddles
acquired after the date of the enactment of this Act.
SEC. 8. AMENDMENTS RELATED TO THE ECONOMIC GROWTH AND TAX RELIEF
RECONCILIATION ACT OF 2001.
(a) Amendments Related to Section 617 of the Act.--
(1) Subclause (II) of section 402(g)(7)(A)(ii) is amended
by striking ``for prior taxable years'' and inserting
``permitted for prior taxable years by reason of this
paragraph''.
(2) Subparagraph (A) of section 3121(v)(1) is amended by
inserting ``or consisting of designated Roth contributions (as
defined in section 402A(c))'' before the comma at the end.
(b) Effective Date.--The amendments made by this section shall take
effect as if included in the provisions of the Economic Growth and Tax
Relief Reconciliation Act of 2001 to which they relate.
SEC. 9. AMENDMENTS RELATED TO THE TAX RELIEF EXTENSION ACT OF 1999.
(a) Amendment Related to Section 507 of the Act.--Clause (i) of
section 45(e)(7)(A) is amended by striking ``placed in service by the
taxpayer'' and inserting ``originally placed in service''.
(b) Amendment Related to Section 542 of the Act.--Clause (ii) of
section 856(d)(9)(D) is amended to read as follows:
``(ii) Lodging facility.--The term `lodging
facility' means a--
``(I) hotel,
``(II) motel, or
``(III) other establishment more
than one-half of the dwelling units in
which are used on a transient basis.''.
(c) Effective Date.--The amendments made by this section shall take
effect as if included in the provisions of the Tax Relief Extension Act
of 1999 to which they relate.
SEC. 10. AMENDMENT RELATED TO THE INTERNAL REVENUE SERVICE
RESTRUCTURING AND REFORM ACT OF 1998.
(a) Amendment Related to Section 3509 of the Act.--Paragraph (3) of
section 6110(i) is amended by inserting ``and related background file
documents'' after ``Chief Counsel advice'' in the matter preceding
subparagraph (A).
(b) Effective Date.--The amendment made by this section shall take
effect as if included in the provision of the Internal Revenue Service
Restructuring and Reform Act of 1998 to which it relates.
SEC. 11. CLERICAL CORRECTIONS.
(a) In General.--
(1) Paragraph (5) of section 21(e) is amended by striking
``section 152(e)(3)(A)'' in the flush matter after subparagraph
(B) and inserting ``section 152(e)(4)(A)''.
(2) Paragraph (3) of section 25C(c) is amended by striking
``section 3280'' and inserting ``part 3280''.
(3) Paragraph (2) of section 26(b) is amended by
redesignating subparagraphs (S) and (T) as subparagraphs (U)
and (V), respectively, and by inserting after subparagraph (R)
the following new subparagraphs:
``(S) sections 106(e)(3)(A)(ii),
223(b)(8)(B)(i)(II), and 408(d)(9)(D)(i)(II) (relating
to certain failures to maintain high deductible health
plan coverage),
``(T) section 170(o)(3)(B) (relating to recapture
of certain deductions for fractional gifts),''.
(4) Subsection (a) of section 34 is amended--
(A) in paragraph (1), by striking ``with respect to
gasoline used during the taxable year on a farm for
farming purposes'',
(B) in paragraph (2), by striking ``with respect to
gasoline used during the taxable year (A) otherwise
than as a fuel in a highway vehicle or (B) in vehicles
while engaged in furnishing certain public passenger
land transportation service'', and
(C) in paragraph (3), by striking ``with respect to
fuels used for nontaxable purposes or resold during the
taxable year''.
(5) Paragraph (2) of section 35(d) is amended--
(A) by striking ``paragraph (2) or (4) of'', and
(B) by striking ``(within the meaning of section
152(e)(1))'' and inserting ``(as defined in section
152(e)(4)(A))''.
(6) Subsection (b) of section 38 is amended--
(A) by striking ``and'' each place it appears at
the end of any paragraph,
(B) by striking ``plus'' each place it appears at
the end of any paragraph, and
(C) by inserting ``plus'' at the end of paragraph
(30).
(7) Paragraphs (2) and (3) of section 45L(c) are each
amended by striking ``section 3280'' and inserting ``part
3280''.
(8) Subsection (c) of section 48 is amended by striking
``subsection'' in the text preceding paragraph (1) and
inserting ``section''.
(9) Paragraphs (1)(B) and (2)(B) of section 48(c) are each
amended by striking ``paragraph (1)'' and inserting
``subsection (a)''.
(10) Clause (ii) of section 48A(d)(4)(B) is amended by
striking ``subsection'' both places it appears.
(11)(A) Paragraph (9) of section 121(d) is amended by
adding at the end the following new subparagraph:
``(E) Termination with respect to employees of
intelligence community.--Clause (iii) of subparagraph
(A) shall not apply with respect to any sale or
exchange after December 31, 2010.''.
(B) Subsection (e) of section 417 of division A of the Tax
Relief and Health Care Act of 2006 is amended by striking ``and
before January 1, 2011''.
(12) The last sentence of section 125(b)(2) is amended by
striking ``last sentence'' and inserting ``second sentence''.
(13) Subclause (II) of section 167(g)(8)(C)(ii) is amended
by striking ``section 263A(j)(2)'' and inserting ``section
263A(i)(2)''.
(14)(A) Clause (vii) of section 170(b)(1)(A) is amended by
striking ``subparagraph (E)'' and inserting ``subparagraph
(F)''.
(B) Clause (ii) of section 170(e)(1)(B) is amended by
striking ``subsection (b)(1)(E)'' and inserting ``subsection
(b)(1)(F)''.
(C) Clause (i) of section 1400S(a)(2)(A) is amended by
striking ``subparagraph (F)'' and inserting ``subparagraph
(G)''.
(D) Subparagraph (A) of section 4942(i)(1) is amended by
striking ``section 170(b)(1)(E)(ii)'' and inserting ``section
170(b)(1)(F)(ii)''.
(15) Subclause (II) of section 170(e)(1)(B)(i) is amended
by inserting ``, but without regard to clause (ii) thereof''
after ``paragraph (7)(C)''.
(16)(A) Subparagraph (A) of section 170(o)(1) and
subparagraph (A) of section 2522(e)(1) are each amended by
striking ``all interest in the property is'' and inserting
``all interests in the property are''.
(B) Section 170(o)(3)(A)(i), and section 2522(e)(2)(A)(i)
(as redesignated by section 3(d)(2)), are each amended--
(i) by striking ``interest'' and inserting
``interests'', and
(ii) by striking ``before'' and inserting ``on or
before''.
(17)(A) Subparagraph (C) of section 852(b)(4) is amended to
read as follows:
``(C) Determination of holding periods.--For
purposes of this paragraph, in determining the period
for which the taxpayer has held any share of stock--
``(i) the rules of paragraphs (3) and (4)
of section 246(c) shall apply, and
``(ii) there shall not be taken into
account any day which is more than 6 months
after the date on which such share becomes ex-
dividend.''.
(B) Subparagraph (B) of section 857(b)(8) is amended to
read as follows:
``(B) Determination of holding periods.--For
purposes of this paragraph, in determining the period
for which the taxpayer has held any share of stock or
beneficial interest--
``(i) the rules of paragraphs (3) and (4)
of section 246(c) shall apply, and
``(ii) there shall not be taken into
account any day which is more than 6 months
after the date on which such share or interest
becomes ex-dividend.''.
(18) Paragraph (2) of section 856(l) is amended by striking
the last sentence and inserting the following: ``For purposes
of subparagraph (B), securities described in subsection
(m)(2)(A) shall not be taken into account.''.
(19) Subparagraph (F) of section 954(c)(1) is amended to
read as follows:
``(F) Income from notional principal contracts.--
``(i) In general.--Net income from notional
principal contracts.
``(ii) Coordination with other categories
of foreign personal holding company income.--
Any item of income, gain, deduction, or loss
from a notional principal contract entered into
for purposes of hedging any item described in
any preceding subparagraph shall not be taken
into account for purposes of this subparagraph
but shall be taken into account under such
other subparagraph.''.
(20) Paragraph (1) of section 954(c) is amended by
redesignating subparagraph (I) as subparagraph (H).
(21) Paragraph (33) of section 1016(a), as redesignated by
section 7(a)(1)(C), is amended by striking ``section 25C(e)''
and inserting ``section 25C(f)''.
(22) Paragraph (36) of section 1016(a), as redesignated by
section 7(a)(1)(C), is amended by striking ``section 30C(f)''
and inserting ``section 30C(e)(1)''.
(23) Subparagraph (G) of section 1260(c)(2) is amended by
adding ``and'' at the end.
(24)(A) Section 1297 is amended by striking subsection (d)
and by redesignating subsections (e) and (f) as subsections (d)
and (e), respectively.
(B) Subparagraph (G) of section 1260(c)(2) is amended by
striking ``subsection (e)'' and inserting ``subsection (d)''.
(C) Subparagraph (B) of section 1298(a)(2) is amended by
striking ``Section 1297(e)'' and inserting ``Section 1297(d)''.
(25) Paragraph (1) of section 1362(f) is amended--
(A) by striking ``, section 1361(b)(3)(B)(ii), or
section 1361(c)(1)(A)(ii)'' and inserting ``or section
1361(b)(3)(B)(ii)'', and
(B) by striking ``, section 1361(b)(3)(C), or
section 1361(c)(1)(D)(iii)'' in subparagraph (B) and
inserting ``or section 1361(b)(3)(C)''.
(26) Paragraph (2) of section 1400O is amended by striking
``under of'' and inserting ``under''.
(27) The table of sections for part II of subchapter Y of
chapter 1 is amended by adding at the end the following new
item:
``Sec. 1400T. Special rules for mortgage revenue bonds.''.
(28) Subsection (b) of section 4082 is amended to read as
follows:
``(b) Nontaxable Use.--For purposes of this section, the term
`nontaxable use' means--
``(1) any use which is exempt from the tax imposed by
section 4041(a)(1) other than by reason of a prior imposition
of tax,
``(2) any use in a train, and
``(3) any use described in section 4041(a)(1)(C)(iii)(II).
The term `nontaxable use' does not include the use of kerosene in an
aircraft and such term shall not include any use described in section
6421(e)(2)(C).''.
(29) Paragraph (4) of section 4101(a) (relating to
registration in event of change of ownership) is redesignated
as paragraph (5).
(30) Paragraph (6) of section 4965(c) is amended by
striking ``section 4457(e)(1)(A)'' and inserting ``section
457(e)(1)(A)''.
(31) Subpart C of part II of subchapter A of chapter 51 is
amended by redesignating section 5432 (relating to
recordkeeping by wholesale dealers) as section 5121.
(32) Paragraph (2) of section 5732(c), as redesignated by
section 11125(b)(20)(A) of the SAFETEA-LU, is amended by
striking ``this subpart'' and inserting ``this subchapter''.
(33) Subsection (b) of section 6046 is amended--
(A) by striking ``subsection (a)(1)'' and inserting
``subsection (a)(1)(A)'', and
(B) by striking ``paragraph (2) or (3) of
subsection (a)'' and inserting ``subparagraph (B) or
(C) of subsection (a)(1)''.
(34)(A) Subparagraph (A) of section 6103(b)(5) is amended
by striking ``the Canal Zone,''.
(B) Section 7651 is amended by striking paragraph (4) and
by redesignating paragraph (5) as paragraph (4).
(35) Subparagraph (A) of section 6211(b)(4) is amended by
striking ``and 34'' and inserting ``34, and 35''.
(36) Subparagraphs (A) and (B) of section 6230(a)(3) are
each amended by striking ``section 6013(e)'' and inserting
``section 6015''.
(37) Paragraph (3) of section 6427(e) (relating to
termination), as added by section 11113 of the SAFETEA-LU, is
redesignated as paragraph (5) and moved after paragraph (4).
(38) Clause (ii) of section 6427(l)(4)(A) is amended by
striking ``section 4081(a)(2)(iii)'' and inserting ``section
4081(a)(2)(A)(iii)''.
(39)(A) Section 6427, as amended by section 1343(b)(1) of
the Energy Policy Act of 2005, is amended by striking
subsection (p) (relating to gasohol used in noncommercial
aviation) and redesignating subsection (q) as subsection (p).
(B) The Internal Revenue Code of 1986 shall be applied and
administered as if the amendments made by paragraph (2) of
section 11151(a) of the SAFETEA-LU had never been enacted.
(40) Subsection (a) of section 6695A is amended by striking
``then such person'' in paragraph (2) and inserting the
following:
``then such person''.
(41) Subparagraph (C) of section 6707A(e)(2) is amended by
striking ``section 6662A(e)(2)(C)'' and inserting ``section
6662A(e)(2)(B)''.
(42)(A) Paragraph (3) of section 9002 is amended by
striking ``section 309(a)(1)'' and inserting ``section
306(a)(1)''.
(B) Paragraph (1) of section 9004(a) is amended by striking
``section 320(b)(1)(B)'' and inserting ``section
315(b)(1)(B)''.
(C) Paragraph (3) of section 9032 is amended by striking
``section 309(a)(1)'' and inserting ``section 306(a)(1)''.
(D) Subsection (b) of section 9034 is amended by striking
``section 320(b)(1)(A)'' and inserting ``section
315(b)(1)(A)''.
(43) Section 9006 is amended by striking ``Comptroller
General'' each place it appears and inserting ``Commission''.
(44) Subsection (c) of section 9503 is amended by
redesignating paragraph (7) (relating to transfers from the
trust fund for certain aviation fuels taxes) as paragraph (6).
(45) Paragraph (1) of section 1301(g) of the Energy Policy
Act of 2005 is amended by striking ``shall take effect of the
date of the enactment'' and inserting ``shall take effect on
the date of the enactment''.
(46) The Internal Revenue Code of 1986 shall be applied and
administered as if the amendments made by section 1(a) of
Public Law 109-433 had never been enacted.
(b) Clerical Amendments Related to the Tax Relief and Health Care
Act of 2006.--
(1) Amendment related to section 209 of division a of the
act.--Paragraph (3) of section 168(l) is amended by striking
``enzymatic''.
(2) Amendments related to section 419 of division a of the
act.--
(A) Clause (iv) of section 6724(d)(1)(B) is amended
by inserting ``or (h)(1)'' after ``section 6050H(a)''.
(B) Subparagraph (K) of section 6724(d)(2) is
amended by inserting ``or (h)(2)'' after ``section
6050H(d)''.
(3) Effective date.--The amendments made by this subsection
shall take effect as if included in the provision of the Tax
Relief and Health Care Act of 2006 to which they relate.
(c) Clerical Amendments Related to the Gulf Opportunity Zone Act of
2005.--
(1) Amendments related to section 402 of the act.--
Subparagraph (B) of section 24(d)(1) is amended--
(A) by striking ``the excess (if any) of'' in the
matter preceding clause (i) and inserting ``the greater
of'', and
(B) by striking ``section'' in clause (ii)(II) and
inserting ``section 32''.
(2) Effective date.--The amendments made by this subsection
shall take effect as if included in the provisions of the Gulf
Opportunity Zone Act of 2005 to which they relate.
(d) Clerical Amendments Related to the Safe, Accountable, Flexible,
Efficient Transportation Equity Act: A Legacy for Users.--
(1) Amendments related to section 11163 of the act.--
Subparagraph (C) of section 6416(a)(4) is amended--
(A) by striking ``ultimate vendor'' and all that
follows through ``has certified'' and inserting
``ultimate vendor or credit card issuer has
certified'', and
(B) by striking ``all ultimate purchasers of the
vendor'' and all that follows through ``are certified''
and inserting ``all ultimate purchasers of the vendor
or credit card issuer are certified''.
(2) Effective date.--The amendments made by this subsection
shall take effect as if included in the provisions of the Safe,
Accountable, Flexible, Efficient Transportation Equity Act: A
Legacy for Users to which they relate.
(e) Clerical Amendments Related to the Energy Policy Act of 2005.--
(1) Amendment related to section 1344 of the act.--
Subparagraph (B) of section 6427(e)(5), as redesignated by
subsection (a)(37), is amended by striking ``2006'' and
inserting ``2008''.
(2) Amendments related to section 1351 of the act.--
Subparagraphs (A)(ii) and (B)(ii) of section 41(f)(1) are each
amended by striking ``qualified research expenses and basic
research payments'' and inserting ``qualified research
expenses, basic research payments, and amounts paid or incurred
to energy research consortiums,''.
(3) Effective date.--The amendments made by this subsection
shall take effect as if included in the provisions of the
Energy Policy Act of 2005 to which they relate.
(f) Clerical Amendments Related to the American Jobs Creation Act
of 2004.--
(1) Amendment related to section 301 of the act.--Section
9502 is amended by striking subsection (e) and redesignating
subsection (f) as subsection (e).
(2) Amendment related to section 413 of the act.--
Subsection (b) of section 1298 is amended by striking paragraph
(7) and by redesignating paragraphs (8) and (9) as paragraphs
(7) and (8), respectively.
(3) Amendment related to section 895 of the act.--Clause
(iv) of section 904(f)(3)(D) is amended by striking ``a
controlled group'' and inserting ``an affiliated group''.
(4) Effective date.--The amendments made by this subsection
shall take effect as if included in the provisions of the
American Jobs Creation Act of 2004 to which they relate.
(g) Clerical Amendments Related to the FSC Repeal and
Extraterritorial Income Exclusion Act of 2000.--
(1) Subclause (I) of section 56(g)(4)(C)(ii) is amended by
striking ``921'' and inserting ``921 (as in effect before its
repeal by the FSC Repeal and Extraterritorial Income Exclusion
Act of 2000)''.
(2) Clause (iv) of section 54(g)(4)(C) is amended by
striking ``a cooperative described in section 927(a)(4)'' and
inserting ``an organization to which part I of subchapter T
(relating to tax treatment of cooperatives) applies which is
engaged in the marketing of agricultural or horticultural
products''.
(3) Paragraph (4) of section 245(c) is amended by adding at
the end the following new subparagraph:
``(C) FSC.--The term `FSC' has the meaning given
such term by section 922.''.
(4) Subsection (c) of section 245 is amended by inserting
at the end the following new paragraph:
``(5) References to prior law.--Any reference in this
subsection to section 922, 923, or 927 shall be treated as a
reference to such section as in effect before its repeal by the
FSC Repeal and Extraterritorial Income Exclusion Act of
2000.''.
(5) Paragraph (4) of section 275(a) is amended by striking
``if'' and all that follows and inserting ``if the taxpayer
chooses to take to any extent the benefits of section 901.''.
(6)(A) Subsection (a) of section 291 is amended by striking
paragraph (4) and by redesignating paragraph (5) as paragraph
(4).
(B) Paragraph (1) of section 291(c) is amended by striking
``subsection (a)(5)'' and inserting ``subsection (a)(4)''.
(7)(A) Paragraph (4) of section 441(b) is amended by
striking ``FSC or''.
(B) Subsection (h) of section 441 is amended--
(i) by striking ``FSC or'' each place it appears,
and
(ii) by striking ``FSC's and'' in the heading
thereof.
(8) Subparagraph (B) of section 884(d)(2) is amended by
inserting before the comma ``(as in effect before their repeal
by the FSC Repeal and Extraterritorial Income Exclusion Act of
2000)''.
(9) Section 901 is amended by striking subsection (h).
(10) Clause (v) of section 904(d)(2)(B) is amended--
(A) by inserting ``and'' at the end of subclause
(I), by striking subclause (II), and by redesignating
subclause (III) as subclause (II),
(B) by striking ``a FSC (or a former FSC)'' in
subclause (II) (as so redesignated) and inserting ``a
former FSC (as defined in section 922)'', and
(C) by adding at the end the following:
``Any reference in subclause (II) to section
922, 923, or 927 shall be treated as a
reference to such section as in effect before
its repeal by the FSC Repeal and
Extraterritorial Income Exclusion Act of
2000.''.
(11) Subsection (b) of section 906 is amended by striking
paragraph (5) and redesignating paragraphs (6) and (7) as
paragraphs (5) and (6), respectively.
(12) Subparagraph (B) of section 936(f)(2) is amended by
striking ``FSC or''.
(13) Section 951 is amended by striking subsection (c) and
by redesignating subsection (d) as subsection (c).
(14) Subsection (b) of section 952 is amended by striking
the second sentence.
(15)(A) Paragraph (2) of section 956(c) is amended--
(i) by striking subparagraph (I) and by
redesignating subparagraphs (J) through (M) as
subparagraphs (I) through (L), respectively, and
(ii) by striking ``subparagraphs (J), (K), and
(L)'' in the flush sentence at the end and inserting
``subparagraphs (I), (J), and (K)''.
(B) Clause (ii) of section 954(c)(2)(C) is amended by
striking ``section 956(c)(2)(J)'' and inserting ``section
956(c)(2)(I)''.
(16) Paragraph (1) of section 992(a) is amended by striking
subparagraph (E), by inserting ``and'' at the end of
subparagraph (C), and by striking ``, and'' at the end of
subparagraph (D) and inserting a period.
(17) Paragraph (5) of section 1248(d) is amended--
(A) by inserting ``(as defined in section 922)''
after ``a FSC'', and
(B) by adding at the end the following new
sentence: ``Any reference in this paragraph to section
922, 923, or 927 shall be treated as a reference to
such section as in effect before its repeal by the FSC
Repeal and Extraterritorial Income Exclusion Act of
2000.''.
(18) Subparagraph (D) of section 1297(b)(2) is amended by
striking ``foreign trade income of a FSC or''.
(19)(A) Paragraph (1) of section 6011(c) is amended by
striking ``or former DISC or a FSC or former FSC'' and
inserting ``, former DISC, or former FSC (as defined in section
922 as in effect before its repeal by the FSC Repeal and
Extraterritorial Income Exclusion Act of 2000)''.
(B) Subsection (c) of section 6011 is amended by striking
``and FSC's'' in the heading thereof.
(20) Subsection (c) of section 6072 is amended by striking
``a FSC or former FSC'' and inserting ``a former FSC (as
defined in section 922 as in effect before its repeal by the
FSC Repeal and Extraterritorial Income Exclusion Act of
2000)''.
(21) Section 6686 is amended by inserting ``FORMER'' before
``FSC'' in the heading thereof.
<all>