REPEAL OF CERTAIN EXCEPTIONS FOR WORKING CAPITAL

SEC. 13235. REPEAL OF CERTAIN EXCEPTIONS FOR WORKING CAPITAL (a) Provisions Relating to Oil and Gas Income.— (1) Amendments to section 907.— (A) Paragraph (1) of section 907(c) is amended by adding at the end thereof the following new flush sentence: “Such term does not include any dividend or interest income which is passive income (as defined in section 904(d)(2)(A)).”. (B) Paragraph (2) of section 907(c) is amended by adding at the end thereof the following new flush sentence: “Such term does not include any dividend or interest income which is passive income (as defined in section 904(d)(2)(A)).”. (2) Separate application of foreign tax credit.— Clause (iii) of section 904(d)(2)(A) is amended by inserting “and” at the end of subclause (II), by striking “, and” at the end of subclause (III) and inserting a period, and by striking subclause (IV). (3) Treatment under subpart f.— (A) Paragraph (1) of section 954(g) is amended by adding at the end thereof the following new flush sentence: “Such term shall not include any foreign personal holding company income (as defined in subsection (c)).”. 107 STAT. 505 (B) Paragraph (8) of section 954(b) is amended by striking “(1),”. (b) Treatment of Shipping Income.— Subsection (f) of section 954 is amended by adding at the end thereof the following new sentence: “Except as provided in paragraph (1), such term shall not include any dividend or interest income which is foreign personal holding company income (as defined in subsection (c)).”. (c) Effective Date.— The amendments made by this section shall apply to taxable years beginning after December 31, 1992.