Pub. L. 106–519, § 3(a)114 Stat. 2423Section, added , , , related to exclusion of extraterritorial income from gross income.
act Aug. 16, 1954, ch. 73668A Stat. 35Pub. L. 101–508, title XI, § 11801(a)(8)104 Stat. 1388–520A prior section 114, , , related to sports programs conducted for American National Red Cross, prior to repeal by , , .
Statutory Notes and Related Subsidiaries
Effective Date of Repeal
section 101(c) of Pub. L. 108–357section 56 of this titleRepeal applicable to transactions after , see , set out as an Effective Date of 2004 Amendments note under .
Transition Provisions
Pub. L. 108–357, title I, § 101(d)118 Stat. 1423Pub. L. 109–222, title V, § 513(b)120 Stat. 366Pub. L. 113–295, div. A, title II, § 219(a)128 Stat. 4035
Transitional Rule forand 2005 2006.—
In general .—
In the case of transactions during 2005 or 2006, the amount includible in gross income by reason of the amendments made by this section [amending sections 56, 275, 864, 903, and 999 of this title and repealing this section and sections 941 to 943 of this title] shall not exceed the applicable percentage of the amount which would have been so included but for this subsection.
Applicable percentage .—
For purposes of paragraph (1), the applicable percentage shall be as follows:
For 2005, the applicable percentage shall be 20 percent.
For 2006, the applicable percentage shall be 40 percent.
Coordination with section 199.—
This subsection shall be applied without regard to any deduction allowable under section 199 [probably means former section 199 of the Internal Revenue Code of 1986].
Revocation of Election To Be Treated as Domestic Corporation .—
If, during the 1-year period beginning on the date of the enactment of this Act [], a corporation for which an election is in effect under section 943(e) of the Internal Revenue Code of 1986 revokes such election, no gain or loss shall be recognized with respect to property treated as transferred under clause (ii) of section 943(e)(4)(B) of such Code to the extent such property—
was treated as transferred under clause (i) thereof, or
was acquired during a taxable year to which such election applies and before , in the ordinary course of its trade or business.
The Secretary of the Treasury (or such Secretary’s delegate) may prescribe such regulations as may be necessary to prevent the abuse of the purposes of this subsection.
Pub. L. 109–222, title V, § 513(b)120 Stat. 366 Repealed. , , .]”