Source
(Added Pub. L. 99–514, title XII, § 1212(b)(1), Oct. 22, 1986, 100 Stat. 2537; amended Pub. L. 100–647, title I, § 1012(e)(6), Nov. 10, 1988, 102 Stat. 3500; Pub. L. 101–239, title VII, § 7811(i)(8)(A), (B), (9), Dec. 19, 1989, 103 Stat. 2410, 2411.)
Amendments
1989—Subsec. (b)(1).
Pub. L. 101–239, § 7811(i)(8)(B), substituted “paragraphs (2) and (3)” for “paragraph (2)”.
Subsec. (b)(3).
Pub. L. 101–239, § 7811(i)(8)(A), added par. (3). Former par. (3) redesignated (4).
Subsec. (b)(4).
Pub. L. 101–239, § 7811(i)(8)(A), (9), redesignated former par. (3) as (4) and substituted “United States source gross transportation income” for “transportation income” in introductory provisions and in subpar. (A).
1988—Subsec. (b)(1).
Pub. L. 100–647 substituted “under section
863
(c)(2)” for “under section
863
(c)” and inserted at end “To the extent provided in regulations, such term does not include any income of a kind to which an exemption under paragraph (1) or (2) of section
883
(a) would not apply.”
Effective Date of 1989 Amendment
Amendment by
Pub. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988,
Pub. L. 100–647, to which such amendment relates, see section 7817 of
Pub. L. 101–239, set out as a note under section
1 of this title.
Effective Date of 1988 Amendment
Amendment by
Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986,
Pub. L. 99–514, to which such amendment relates, see section 1019(a) of
Pub. L. 100–647, set out as a note under section
1 of this title.
Effective Date
Section applicable to taxable years beginning after Dec. 31, 1986, see section 1212(f) of
Pub. L. 99–514, set out as an Effective Date of 1986 Amendment note under section
863 of this title.
Applicability of Certain Amendments by Pub. L. 99–514 in Relation to Treaty Obligations of United States
For nonapplication of amendment by section 1212(b)(1) of
Pub. L. 99–514 (enacting this section) to the extent application of such amendment would be contrary to any treaty obligation of the United States in effect on Oct. 22, 1986, with provision that for such purposes any amendment by title I of
Pub. L. 100–647 be treated as if it had been included in the provision of
Pub. L. 99–514 to which such amendment relates, see section 1012(aa)(3), (4) of
Pub. L. 100–647, set out as a note under section
861 of this title.