10 “(ii) the credit (if any) allowable by this section to each such trade or business with respect to any qualified teaching employee or qualified vocational edication instructor shall be in proportion to such trade or business' share of the wages paid for the taxable year to such qualified teaching employee or qualified vocational education instructor with respect to whom the credit is allowable. The regulations prescribed under this subparagraph shall be based on principles similar to the principles which apply in the case of subparagraph (A). "(C) PASSTHROUGH IN THE CASE OF SUBCHAPTER 8 CORPORATIONS, ETC.-Under regulations prescribed by the Secretary, rules similar to the rules of subsections (d) and (e) of section 52 shall apply. "(D) ALLOCATION IN THE CASE OF PARTNERSHIPS.—In the case of partnerships, the credit shall be allocated among partners under regulations prescribed by the Secretary. "(6) CONTROLLED GROUP OF CORPORATIONS. The term 'controlled group of corporations' has the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2220 11 same meaning given to such term by section 1563(a), "(A) 'more that 50 percent' shall be substituted for 'at least 80 percent' each place it ap pears in section 1563(a)(1), and "(B) the determination shall be made without regard to subsections (a)(4) and (e)(3)(C) of section 1563.". "(7) DOUBLE BENEFIT.-Any credit allowable under this section for the taxable year with respect to any employee of the taxpayer shall be in addition to any deduction under this chapter which is allowable to the taxpayer for such taxable year with respect to compensation paid to such employee.". (b) CONFORMING AMENDMENTS. (1) The table of sections for subpart A of part IV of subchapter A of chapter 1 of such Code is amended by inserting after the item relating to section 44G the following new item: "Sec. 44H. Vocational education instruction credit.". (2) Section 6096(b) of such Code (relating to des 21 ignation of income tax payments to Presidential Elec 22 23 tion Campaign Fund) is amended by striking out "and 44G" and inserting in lieu thereof "44G, and 44H”. 1 SEC. 3. EFFECTIVE DATE. 2 12 The amendments made by this Act shall apply to tax 3 able years beginning after December 31, 1982. To amend the Tax Reform Act of 1969 with respect to the application of the excess business holding provisions to private foundations. IN THE SENATE OF THE UNITED STATES JUNE 14 (legislative day, JUNE 13), 1983 Mr. ARMSTRONG (for himself and Mr. HART) introduced the following bill; which was read twice and referred to the Committee on Finance A BILL To amend the Tax Reform Act of 1969 with respect to the application of the excess business holding provisions to private foundations. 1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 3 That section 101(1)(4) of the Tax Reform Act of 1969 is 4 amended by adding at the end thereof the following new sub5 paragraph: 7 8 9 10 "(D)(i) The divestiture requirements of section 4943 of the Internal Revenue Code of 1954 shall not apply to the stock of a corporation held by any private foundation if the foundation and the corporation meet the following conditions: 2 "(I) On May 26, 1969, the private foundation owned 100 percent of the voting stock in the corporation and substantially all of the operating assets of the corporation were used in operating a hotel business enterprise. "(II) The stock described in subclause (I) was acquired by the foundation solely by gift, devise, or bequest before December 31, 1966. "(III) Neither the donor of such stock nor any member of his family (within the meaning of section 4946(d) of such Code) is a manager of such foundation (as defined in section 4946(b) of such Code) on or after December 31, 1956. "(IV) On May 26, 1969, and at all times thereafter "(aa) the hotel business enterprise described in subclause (I) is of substantially the same character as the enterprise which was conducted by the cor poration on the date of the last gift, devise, or bequest of such stock of such |