Table of Contents-Public Law 94-455-Continued

TITLE V-TAX SIMPLIFICATION IN THE

INDIVIDUAL INCOME TAX

Sec. 501. Revision of tax tables for individuals

Sec. 502. Deduction for alimony allowed in determining adjusted gross

income

Sec. 503. Revision of retirement income credit

Sec. 504. Credit for child care expenses

Sec. 505. Changes in exclusions for sick pay and certain military, etc.,

disability pensions; certain disability income

Sec. 506. Moving expenses

Sec. 507. Tax revision study

Sec. 508. Effective date

TITLE VI-BUSINESS RELATED INDIVIDUAL

INCOME TAX PROVISIONS

Sec. 601. Deductions for expenses attributable to business use of

homes, rental of vacation homes, etc.

Sec. 602. Deductions for attending foreign conventions

Sec. 603. Change in tax treatment of qualified stock options

Sec. 604. State legislators' travel expenses away from home

Sec. 605. Deduction for guarantees of business bad debts to guaran-

tors not involved in business

TITLE VII-ACCUMULATION TRUSTS

Sec. 701. Accumulation trusts

TITLE VIII-CAPITAL FORMATION

Sec. 801. Extension of $100,000 limitation on used property for 4

years

Sec. 802. Extension of 10 percent credit for 4 years and first-in-first-

out treatment of investment credit amounts

Sec. 803 Employee stock ownership plans; study of expanded stock

ownership

Sec. 804. Investment credit in the case of movie and television films

Sec. 805. Investment credit in the case of certain ships

Sec. 806. Additional net operating loss carryover years; limitations

on net operating loss carryovers

Sec. 807. Small fishing vessel construction reserves

TITLE IX-SMALL BUSINESS PROVISIONS

Sec. 901. Extension of certain corporation income tax reductions

Sec. 902. Changes in subchapter S rules

TITLE X-CHANGES IN THE TREATMENT OF FOREIGN INCOM

PART I-FOREIGN TAX PROVISIONS AFFECTING INDIVIDUALS ABROAD

Sec. 1011. Income earned abroad by United States citizens living or

residing abroad

Sec. 1012. Income tax treatment of nonresident alien individuals who

are married to citizens or residents of the United States-

Sec. 1013. Foreign trusts having one or more United States benefici-

aries to be taxed currently to grantor

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TITLE X-CHANGES IN THE TREATMENT OF

FOREIGN INCOME-Continued

Sec. 1014. Interest charge on accumulation distributions from foreign

trusts

Sec. 1015. Excise tax on transfers of property to foreign persons to

avoid Federal income tax

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93

PART II—AMENDMENTS AFFECTING Tax Treatment of ConTROLLED FOREIGN

CORPORATIONS AND THEIR SHAREHOLDERS

Sec. 1021. Amendment of provision relating to investment in United

States property by controlled foreign corporations

Sec. 1022. Repeal of exclusion for earnings of less developed country

corporations for purposes of section 1248

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95

Sec. 1023. Exclusion from subpart F of certain earnings of insurance

companies

96

Sec. 1024. Shipping profits of foreign corporations

96

PART III-AMENDMENTS AFFECTING TREATMENT OF FOREIGN TAXES

Sec. 1031. Requirement that foreign tax credit be determined on over-

all basis

96

Sec. 1032. Recapture of foreign losses

100

Sec. 1033. Dividends from less developed country corporations to be

grossed up for purposes of determining United States in-

come and foreign tax credit against that income

Sec. 1034. Treatment of capital gains for purposes of foreign tax

credit

Sec. 1037. Third tier foreign tax credit when section 951 applies

109

PART IV-MONEY OR OTHER PROPERTY MOVING OUT OF OR

INTO THE UNITED STATES

Sec. 1041. Portfolio debt investments in United States of nonresident

aliens and foreign corporations

110

Sec. 1042. Changes in ruling requirements under section 367; certain

changes in section 1248

110

Sec. 1043. Contiguous country branches of domestic life insurance

companies

115

Sec. 1044. Transitional rule for bond, etc., losses of foreign banks

118

PART V-SPECIAL CATEGORIES OF FOREIGN TAX TREATMENT

Sec. 1051. Tax treatment of corporations conducting trade or business

in Puerto Rico and possessions of the United States

119

Sec. 1052. Western Hemisphere trade corporations

Sec. 1053. Repeal of provisions relating to China Trade Act corpora-

123

tions

124

PART VI-DENIAL OF CERTAIN TAX BENEFITS FOR COOPERATION WITH OR PAR-

TICIPATION IN INTERNATIONAL BOYCOTTS AND IN CONNECTION

WITH THE PAYMENT OF CERTAIN BRIBES

Sec. 1061. Denial of foreign tax credit

125

Sec. 1062. Denial of deferral of international boycott amounts

Sec. 1063. Denial of DISC benefits

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Table of Contents-Public Law 94-455-Continued

TITLE X-CHANGES IN THE TREATMENT OF

FOREIGN INCOME-Continued

Sec. 1064. Determinations as to participation in or cooperation with

an international boycott

Sec. 1065. Foreign bribes

Sec. 1066. Effective dates

Sec. 1067. Reports by Secretary

TITLE XI-AMENDMENTS AFFECTING DISC

Sec. 1101. Amendments affecting DISC

TITLE XII-ADMINISTRATIVE PROVISIONS

Sec. 1201. Public inspection of written determinations by Internal

Revenue Service

Sec. 1202. Confidentiality and disclosure of returns and return infor-

mation

Sec. 1203. Income tax return preparers

Sec. 1204. Jeopardy and termination assessments

Sec. 1205. Administrative summons

Sec. 1206. Assessments in case of mathematical or clerical errors

Sec. 1207. Withholding

Sec. 1208. State-conducted lotteries

Sec. 1209. Minimum exemption from levy for wages, salary, and

other income

Sec. 1210. Joint committee refund cases

Sec. 1211. Social security account numbers

Sec. 1212. Abatement of interest on errors when return is prepared

for taxpayer by the Internal Revenue Service

TITLE XIII-TAX EXEMPT ORGANIZATIONS

Sec. 1301. Disposition of private foundation property under transition

rules of Tax Reform Act of 1969

Sec. 1302. New private foundation set-asides

Sec. 1303. Minimum distribution amount for private foundations
Sec. 1304. Extension of time to amend charitable remainder trust gov-

erning instrument

Sec. 1305. Unrelated trade or business income of trade shows, State

fairs, etc.

Sec. 1306. Declaratory judgments with respect to section 501(c)(3)

status and classification

Sec. 1307. Lobbying by public charities

Sec. 1308. Tax liens, etc., not to constitute acquisition indebtedness...

Sec. 1309. Extension of self-dealing transition rules for private foun-

dations

Sec. 1310. Imputed interest

Sec. 1311. Certain hospital services

Sec. 1312. Clinical services of cooperative hospitals

Sec. 1313. Exemption of certain amateur athletic organizations from

tax

TITLE XIV-CAPITAL GAINS

Sec. 1401. Increase in amount of ordinary income against which cap-

ital loss may be offset

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TITLE XIV-CAPITAL GAINS-Continued

Sec. 1402. Increase in holding period required for capital gain or loss

to be long term

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209

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Sec. 1403. Allowance of 8-year capital loss carryover in case of regu-

lated investment companies

Sec. 1404. Sale of residence by elderly

TITLE XV-PENSION AND INSURANCE TAXATION
Sec. 1501. Retirement savings for certain married individuals
Sec. 1502. Limitation on contributions to certain pension, etc., plans.
Sec. 1503. Participation by members of reserves or National Guard in
individual retirement accounts; participation by volun-
teer firefighters in individual retirement accounts, etc.__

Sec. 1504. Certain investments by annuity plans

Sec. 1505. Segregated asset accounts

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Sec. 1506. Study of salary reduction pension plans

214

Sec. 1510. Taxable status of pension benefits guaranty corporation

Sec. 1511. Level premium plans covering owner-employees

Sec. 1512. Lump-sum distributions from qualified pension, etc., plans-

Sec. 1509. Study of expanded participation in individual retirement

accounts

Sec. 1508. Treatment of certain life insurance contracts guaranteed

renewable

Sec. 1507. Consolidated returns for life and other insurance com-

panies

215

215

217

217

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217

218

187

TITLE XVI-REAL ESTATE INVESTMENT TRUSTS

Sec. 1601. Deficiency dividend procedure

Sec. 1603. Treatment of property held for sale to customers

Sec. 1604. Other changes in limitations and requirements

Sec. 1605. Excise tax

Sec. 1606. Allowance of net operating loss carryover

Sec. 1607. Alternative tax in case of capital gains

Sec. 1608. Effective date for title

Sec. 1602. Trust not disqualified in certain cases where income tests

were not met

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230

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TITLE XVII-RAILROAD AND AIRLINE PROVISIONS

192

Sec. 1701. Certain provisions relating to railroads

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196

205

Sec. 1703. Certain provisions relating to airlines

Sec. 1702. Amortization over 50-year period of railroad grading and

tunnel bores placed in service before 1969

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TITLE XVIII-INTERNATIONAL TRADE AMENDMENTS

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205

Sec. 1801. United States International Trade Commission

Sec. 1802. Trade Act of 1974 amendments

238

TITLE XIX-REPEAL AND REVISION OF OBSOLETE, RARELY

USED, ETC., PROVISIONS OF INTERNAL REVENUE CODE OF 1954

SUBTITLE A-AMENDMENTS OF INTERNAL REVENUE CODE GENERALLY

Sec. 1901. Amendments of subtitle A; income taxes

Sec. 1902. Amendments of subtitle B; estate and gift taxes

TITLE XIX-REPEAL AND REVISION OF OBSOLETE, RARELY

USED, ETC., PROVISIONS OF INTERNAL REVENUE

CODE OF 1954-Continued

Sec. 1903. Amendments of subtitle C; employment taxes

Sec. 1904. Amendments of subtitle D; misecllaneous excise taxes

Sec. 1905. Amendments of subtitle E; alcohol, tobacco, and certain

other excise taxes

282

286

294

300

Sec. 1906. Amendments of subtitle F; procedure and administration_

Sec. 1907. Amendments of subtitle G; the Joint Committee on Inter-

nal Revenue Taxation

Sec. 1908. Effective date of certain definitions and designations

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312

SUBTITLE B-AMENDMENTS OF CODE PROVISIONS WITH LIMITED CURRENT

APPLICATION: REPEALS AND SAVINGS PROVISIONS

Sec. 1951. Provisions of subtitle A; income taxes

Sec. 1952. Provisions of subchapter D of chapter 39; cotton futures

312

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TITLE XX-ESTATE AND GIFT TAXES

Sec. 2001. Unified rate schedule for estate and gift taxes; unified

credit in lieu of specific exemptions

Sec. 2002. Increase in limitations on marital deductions; fractional

interests of spouse

322

330

Sec. 2003. Valuation for purposes of the Federal estate tax of certain

real property devoted to farming or closely held busi-

nesses

332

Sec. 2004. Extension of time for payment of estate tax

Sec. 2101. Tax treatment of certain housing associations

Sec. 2102. Treatment of certain disaster payments

Sec. 2103. Tax treatment of certain 1972 disaster losses

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376

Sec. 2104. Tax treatment of certain debts owed by political parties,

etc., to accrual basis taxpayers

377

Sec. 2105. Tax-exempt bonds for student loans

378

Sec. 2106. Personal holding company income amendments

Sec. 2107. Work incentive program expenses

378

379

Sec. 2108. Repeal of excise tax on light-duty truck parts

380

Sec. 2109. Exclusion from excise tax on certain articles resold after

modification

380

Sec. 2110. Franchise transfers

381

Sec. 2111. Employer's duties in connection with the recording and re-

porting of tips

381

Sec. 2112. Treatment of certain pollution control facilities

381

Sec. 2113. Clarification of status of certain fishermen's organizations

Sec. 2114. Application of section 6013(e) of the Internal Revenue

383

Code of 1954

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