Source
(Added Pub. L. 99–514, title XII, § 1235(a), Oct. 22, 1986, 100 Stat. 2569; amended Pub. L. 100–647, title I, § 1012(p)(15), (18), (23), (32), Nov. 10, 1988, 102 Stat. 3518, 3519, 3521; Pub. L. 103–66, title XIII, § 13231(c)(3), Aug. 10, 1993, 107 Stat. 498; Pub. L. 105–34, title XI, § 1122(d)(3), Aug. 5, 1997, 111 Stat. 977.)
Amendments
1997—Subsecs. (a)(1), (d).
Pub. L. 105–34 substituted “section
1298
(a)” for “section
1297
(a)”.
1993—Subsec. (c).
Pub. L. 103–66 inserted at end “If the passive foreign investment company is a controlled foreign corporation (as defined in section
957
(a)), the preceding sentence shall not apply to any United States shareholder (as defined in section
951
(b)) in such corporation, and, in applying section
959 to any such shareholder, any inclusion under this section shall be treated as an inclusion under section
951
(a)(1)(A).”
1988—Subsec. (b).
Pub. L. 100–647, § 1012(p)(15), inserted at end “To the extent provided in regulations, if the fund establishes to the satisfaction of the Secretary that it uses a shorter period than the taxable year to determine shareholders’ interests in the earnings of such fund, pro rata shares may be determined by using such shorter period.”
Subsec. (c).
Pub. L. 100–647, § 1012(p)(23), inserted “, for purposes of this chapter,” after “shall be treated”, and “; except that such distribution shall immediately reduce earnings and profits” after “is not a dividend”.
Subsec. (e)(3).
Pub. L. 100–647, § 1012(p)(18), added par. (3).
Subsec. (g).
Pub. L. 100–647, § 1012(p)(32), added subsec. (g).
Effective Date of 1997 Amendment
Amendment by
Pub. L. 105–34 applicable to taxable years of United States persons beginning after Dec. 31, 1997, and to taxable years of foreign corporations ending with or within such taxable years of United States persons, see section 1124 of
Pub. L. 105–34, set out as a note under section
532 of this title.
Effective Date of 1993 Amendment
Amendment by
Pub. L. 103–66 applicable to taxable years of foreign corporations beginning after Sept. 30, 1993, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end, see section 13231(e) of
Pub. L. 103–66, set out as a note under section
951 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 of foreign corporations beginning after Dec. 31, 1986, see section 1235(h) of
Pub. L. 99–514, set out as a note under section
1291 of this title.