Pub. L. 88-272, tit. I, pt. II, sec. 123
RELATED AMENDMENTS.
SEC. 123. RELATED AMENDMENTS. (a) Tax on Mutual Insurance Companies (Other Than Life, Etc.)— (1) Subsection (a) of section 821 (relating to imposition of tax) is amended to read as follows: “(a) Imposition of Tax.—A tax is hereby imposed for each taxable year beginning after December 31, 1963, on the mutual insurance company taxable income of every mutual insurance company (other than a life insurance company and other than a fire, flood, or marine insurance company subject to the tax imposed by section 831). Such tax shall consist of— “(1) Normal tax.—A normal tax of 22 percent of the mutual insurance company taxable income, or 44 percent of the amount by which such taxable income exceeds $6,000, whichever is the lesser; plus “(2) Surtax.—A surtax on the mutual insurance company taxable income computed as provided in section 11(c) as though the mutual insurance company taxable income were the taxable income referred to in section 11(c).” (2) Paragraph (1) of section 821(c) (relating to alternative tax for certain small companies) is amended to read as follows: “(1) Imposition of tax.—In the case of taxable years beginning after December 31, 1963, there is hereby imposed for each taxable year on the income of each mutual insurance company to which this subsection applies a tax (which shall be in lieu of the tax imposed by subsection (a)) computed as follows: “(A) Normal tax.—A normal tax of 22 percent of the taxable investment income, or 44 percent of the amount by which such taxable income exceeds $3,000, whichever is the lesser; plus “(B) Surtax.—A surtax on the taxable investment income computed as provided in section 11(c) as though the taxable investment income were the taxable income referred to in section 11(c).” (b) Receipt of Minimum Distributions by Domestic Corporations.—Subsection (b) of section 963 (relating to receipt of minimum distributions by domestic corporations) is amended to read as follows: “(b) Minimum Distribution.—For purposes of this section, a minimum distribution with respect to the earnings and profits for the taxable year of any controlled foreign corporation or corporations shall, in the case of any United States shareholder, be its 78 Stat. 30pro rata share of an amount determined in accordance with whichever of the following tables applies to the taxable year: “(1) Taxable years beginning in 1963.— “If the effective foreign tax rate is (percentage)— The required minimum distribution of earnings and profits is (percentage)— Under 10 90 10 or over but less than 20 86 20 or over but less than 28 82 28 or over but less than 34 75 34 or over but less than 39 68 39 or over but less than 42 55 42 or over but less than 44 40 44 or over but less than 46 27 46 or over but less than 47 14 47 or over 0 “(2) Taxable years beginning in 1964.— “If the effective foreign tax rate is (percentage)— The required minimum distribution of earnings and profits is (percentage)— Under 10 87 10 or over but less than 19 83 19 or over but less than 27 79 27 or over but less than 33 72 33 or over but less than 37 65 37 or over but less than 40 53 40 or over but less than 42 38 42 or over but less than 44 26 44 or over but less than 45 13 45 or over 0 “(3) Taxable years beginning after december 31, 1964.— “If the effective foreign tax rate is (percentage)— The required minimum distribution of earnings and profits is (percentage)— Under 9 83 9 or over but less than 18 79 18 or over but less than 26 76 26 or over but less than 32 69 32 or over but less than 36 63 36 or over but less than 39 51 39 or over but less than 41 37 41 or over but less than 42 25 42 or over but less than 43 13 43 or over 0” (c) Amendment of Section 242.—Section 242(a) (relating to deduction for partially tax-exempt interest.) is amended by adding at the end thereof the following new sentence: “No deduction shall be allowed under this section for purposes of any surtax imposed by this subtitle.”