Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647)
NOV. 10, 1988
Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647)
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Joint Committee Report JCX-20-88
(for S. 2238)
ADDITIONAL TECHNICAL CORRECTIONS
TO S. 2238
ADOPTED BY FINANCE COMMITTEE*
A. Foreign
Liquidation of Possession Corporation
The amendment would treat as foreign source, and subject to a separate foreign tax credit limitation, gain derived from the liquidation of a corporation organized in a U.S. possession and which derives more than 50 percent (based on the prior three taxable years) of its gross income from the active conduct of a trade or business in that possession.
B. Capital Cost Recovery
Passage of Time Problem for 1986 Act Transitional Exception
The amendment would modify a 1986 transitional exception for the Frankford Arsenal to ameliorate problems caused by the delay in passage of the technical corrections bill.
C. Amortizable Bond Premium
Effective Date
The amendment would provide that the provision of the bill (sec. 106(j)(1)) relating to the treatment of bond premium as a reduction of interest income on the bond applies to bonds acquired after December 31, 1987, unless the taxpayer elects to have the amendment apply to bonds acquired after October 22, 1986.
FOOTNOTE
* At Finance Committee markup on July 26, 1988. These provisions are in addition to the additional technicals listed in JCX-18-88.
END OF FOOTNOTE
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