MISCELLANEOUS PROVISIONS.

SEC. 1704. MISCELLANEOUS PROVISIONS. (a) Application of Amendments Made by Title XII of Omnibus Budget Reconciliation Act Of 1990.— Except as otherwise expressly provided, whenever in title XII of the Omnibus Budget Reconciliation Act of 1990 an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986. (b) Treatment of Certain Amounts Under Hedge Bond Rules.— (1) In general.— Clause (iii) of section 149(g)(3)(B) is amended to read as follows: “(iii) Amounts held pending reinvestment or redemption.— Amounts held for not more than 30 days pending reinvestment or bond redemption shall be treated as invested in bonds described in clause (i).”. (2) Effective date.— The amendment made by paragraph (1) shall take effect as if included in the amendments made by section 7651 of the Omnibus Budget Reconciliation Act of 1989. (c) Treatment of Certain Distributions Under Section 1445.— (1) In general.— Paragraph (3) of section 1445(e) is amended by adding at the end thereof the following new sentence: “Rules similar to the rules of the preceding provisions of this paragraph shall apply in the case of any distribution to which section 301 applies and which is not made out of the earnings and profits of such a domestic corporation.”. (2) Effective date.— The amendment made by paragraph (1) shall apply to distributions after the date of the enactment of this Act. (d) Treatment of Certain Credits Under Section 469.— (1) In general.— Subparagraph (B) of section 469(c)(3) is amended by adding at the end thereof the following new sentence: “If the preceding sentence applies to the net income from any property for any taxable year, any credits allowable under subpart B (other than section 27(a)) or D of part IV of subchapter A for such taxable year which are attributable to such property shall be treated as credits not from a passive activity to the extent the amount of such credits does not exceed the regular tax liability of the taxpayer for the taxable year which is allocable to such net income.”. (2) Effective date.— The amendment made by paragraph (1) shall apply to taxable years beginning after December 31, 1986. (e) Treatment of Dispositions Under Passive Loss Rules.— (1) In general.— Subparagraph (A) of section 469(g)(1) is amended to read as follows: “(A) In general.— If all gain or loss realized on such disposition is recognized, the excess of— 110 STAT. 1879 “(i) any loss from such activity for such taxable year (determined after the application of subsection (b)), over “(ii) any net income or gain for such taxable year from all other passive activities (determined after the application of subsection (b)), shall be treated as a loss which is not from a passive activity.”. (2) Effective date.— The amendment made by paragraph (1) shall apply to taxable years beginning after December 31, 1986. (f) Miscellaneous Amendments to Foreign Provisions.— (1) Coordination of unified estate tax credit with treaties.— Subparagraph (A) of section 2102(c)(3) is amended by adding at the end thereof the following new sentence: “For purposes of the preceding sentence, property shall not be treated as situated in the United States if such property is exempt from the tax imposed by this subchapter under any treaty obligation of the United States.”. (2) Treatment of certain interest paid to related person.— (A) Subparagraph (B) of section 163(j)(1) is amended by inserting before the period at the end thereof the following: “(and clause (ii) of paragraph (2)(A) shall not apply for purposes of applying this subsection to the amount so treated)”. (B) Subsection (j) of section 163 is amended by redesignating paragraph (7) as paragraph (8) and by inserting after paragraph (6) the following new paragraph: “(7) Coordination with passive loss rules, etc.— This subsection shall be applied before sections 465 and 469.”. (C) The amendments made by this paragraph shall apply as if included in the amendments made by section 7210(a) of the Revenue Reconciliation Act of 1989. (3) Treatment of interest allocable to effectively connected income.— (A) In general.— (i) Subparagraph (B) of section 884(f)(1) is amended by striking “to the extent” and all that follows down through “subparagraph (A)” and inserting “to the extent that the allocable interest exceeds the interest described in subparagraph (A)”. (ii) The second sentence of section 884(f)(1) is amended by striking “reasonably expected” and all that follows down through the period at the end thereof and inserting “reasonably expected to be allocable interest.”. (iii) Paragraph (2) of section 884(f) is amended to read as follows: “(2) Allocable interest.— For purposes of this subsection, the term ‘allocable interest’ means any interest which is allocable to income which is effectively connected (or treated as effectively connected) with the conduct of a trade or business in the United States.”. (B) Effective date.— The amendments made by subparagraph (A) shall take effect as if included in the110 STAT. 1880 amendments made by section 1241(a) of the Tax Reform Act of 1986. (4) Clarification of source rule.— (A) In general.— Paragraph (2) of section 865(b) is amended by striking “863(b)” and inserting “863”. (B) Effective date.— The amendment made by subparagraph (A) shall take effect as if included in the amendments made by section 1211 of the Tax Reform Act of 1986. (5) Repeal of obsolete provisions.— (A) Paragraph (1) of section 6038(a) is amended by striking “, and” at the end of subparagraph (E) and inserting a period, and by striking subparagraph (F). (B) Subsection (b) of section 6038A is amended by adding “and” at the end of paragraph (2), by striking “, and” at the end of paragraph (3) and inserting a period, and by striking paragraph (4). (g) Clarification of Treatment of Medicare Entitlement Under Cobra Provisions.— (1) In general.— (A) Subclause (V) of section 4980B(f)(2)(B)(i) is amended to read as follows: “(V) Medicare entitlement followed by qualifying event.— In the case of a qualifying event described in paragraph (3)(B) that occurs less than 18 months after the date the covered employee became entitled to benefits under title XVIII of the Social Security Act, the period of coverage for qualified beneficiaries other than the covered employee shall not terminate under this clause before the close of the 36-month period beginning on the date the covered employee became so entitled.”. (B) Clause (v) of section 602(2)(A) of the Employee Retirement Income Security Act of 1974 is amended to read as follows: “(v) Medicare entitlement followed by qualifying event.— In the case of a qualifying event described in section 603(2) that occurs less than 18 months after the date the covered employee became entitled to benefits under title XVIII of the Social Security Act, the period of coverage for qualified beneficiaries other than the covered employee shall not terminate under this subparagraph before the close of the 36-month period beginning on the date the covered employee became so entitled.”. (C) Clause (iv) of section 2202(2)(A) of the Public Health Service Act is amended to read as follows: “(iv) Medicare entitlement followed by qualifying event.— In the case of a qualifying event described in section 2203(2) that occurs less than 18 months after the date the covered employee became entitled to benefits under title XVIII of the Social Security Act, the period of coverage for qualified beneficiaries other than the covered employee shall not terminate under this subparagraph before the close110 STAT. 1881 of the 36-month period beginning on the date the covered employee became so entitled.”. (2) Effective date.— The amendments made by this subsection shall apply to plan years beginning after December 31, 1989. (h) Treatment of Certain Remic Inclusions.— (1) In general.— Subsection (a) of section 860E is amended by adding at the end thereof the following new paragraph: “(6) Coordination with minimum tax.— For purposes of part VI of subchapter A of this chapter— “(A) the reference in section 55(b)(2) to taxable income shall be treated as a reference to taxable income determined without regard to this subsection, “(B) the alternative minimum taxable income of any holder of a residual interest in a REMIC for any taxable year shall in no event be less than the excess inclusion for such taxable year, and “(C) any excess inclusion shall be disregarded for purposes of computing the alternative tax net operating loss deduction. The preceding sentence shall not apply to any organization to which section 593 applies, except to the extent provided in regulations prescribed by the Secretary under paragraph (2).”. (2) Effective date.— The amendment made by paragraph (1) take effect as if included in the amendments made by section 671 of the Tax Reform Act of 1986 unless the taxpayer elects to apply such amendment only to taxable years beginning after the date of the enactment of this Act. (i) Exemption From Harbor Maintenance Tax for Certain Passengers.— (1) In general.— Subparagraph (D) of section 4462(b)(1) (relating to special rule for Alaska, Hawaii, and possessions) is amended by inserting before the period the following: “, or passengers transported on United States flag vessels operating solely within the State waters of Alaska or Hawaii and adjacent international waters”. (2) Effective date.— The amendment made by paragraph (1) shall take effect as if included in the amendments made by section 1402(a) of the Harbor Maintenance Revenue Act of 1986. (j) Amendments Related to Revenue Provisions of Energy Policy Act of 1992.— (1) Effective with respect to taxable years beginning after December 31, 1990, subclause (II) of section 53(d)(1)(B)(iv) is amended to read as follows: “(II) the adjusted net minimum tax for any taxable year is the amount of the net minimum tax for such year increased in the manner provided in clause (iii).”. (2) Subsection (g) of section 179A is redesignated as subsection (f). (3) Subparagraph (E) of section 6724(d)(3) is amended by striking “section 6109(f)” and inserting “section 6109(h)”. (4) (A) Subsection (d) of section 30 is amended— 110 STAT. 1882 (i) by inserting “(determined without regard to subsection (b)(3))” before the period at the end of paragraph (1) thereof, and (ii) by adding at the end thereof the following new paragraph: “(4) Election to not take credit.— No credit shall be allowed under subsection (a) for any vehicle if the taxpayer elects to not have this section apply to such vehicle.”. (B) Subsection (m) of section 6501 (as redesignated by section 1602) is amended by striking “section 40(f)” and inserting “sections 30(d)(4), 40(f)”. (5) Subclause (III) of section 501(c)(21)(D)(ii) is amended by striking “section 101(6)” and inserting “section 101(7)” and by striking “1752(6)” and inserting “1752(7)”. (6) Paragraph (1) of section 1917(b) of the Energy Policy Act of 1992 shall be applied as if “at a rate” appeared instead of “at the rate” in the material proposed to be stricken. (7) Paragraph (2) of section 1921(b) of the Energy Policy Act of 1992 shall be applied as if a comma appeared after “(2)” in the material proposed to be stricken. (8) Subsection (a) of section 1937 of the Energy Policy Act of 1992 shall be applied as if “Subpart B” appeared instead of “Subpart C”. (k) Treatment of Qualified Football Coaches Plan.— (1) In general.— For purposes of the Internal Revenue Code of 1986, a qualified football coaches plan— (A) shall be treated as a multiemployer collectively bargained plan, and (B) notwithstanding section 401(k)(4)(B) of such Code, may include a qualified cash and deferred arrangement under section 401(k) of such Code. (2) Qualified football coaches plan.— For purposes of this subsection, the term “qualified football coaches plan” means any defined contribution plan which is established and maintained by an organization— (A) which is described in section 501(c) of such Code, (B) the membership of which consists entirely of individuals who primarily coach football as full-time employees of 4-year colleges or universities described in section 170(b)(1)(A)(ii) of such Code, and (C) which was in existence on September 18, 1986. (3) Effective date.— This subsection shall apply to years beginning after December 22, 1987. (l) Determination of Unrecovered Investment in Annuity Contract.— (1) In general.— Subparagraph (A) of section 72(b)(4) is amended by inserting “(determined without regard to subsection (c)(2))” after “contract”. (2) Effective date.— The amendment made by paragraph (1) shall take effect as if included in the amendments made by section 1122(c) of the Tax Reform Act of 1986. (m) Modifications to Election to Include Child’s Income on Parent’s Return.— (1) Eligibility for election.— Clause (ii) of section 1(g)(7)(A) (relating to election to include certain unearned income of child on parent’s return) is amended to read as follows: 110 STAT. 1883 “(ii) such gross income is more than the amount described in paragraph (4)(A)(ii)(I) and less than 10 times the amount so described,”. (2) Computation of tax.— Subparagraph (B) of section 1(g)(7) (relating to income included on parent’s return) is amended— (A) by striking “$1 000” in clause (i) and inserting “twice the amount described in paragraph (4)(A)(ii)(I)”, and (B) by amending subclause (II) of clause (ii) to read as follows: “(II) for each such child, 15 percent of the lesser of the amount described in paragraph (4)(A)(ii)(I) or the excess of the gross income of such child over the amount so described, and”. (3) Minimum tax.— Subparagraph (B) of section 59(j)(1) is amended by striking “$1,000” and inserting “twice the amount in effect for the taxable year under section 63(c)(5)(A)”. (4) Effective date.— The amendments made by this subsection shall apply to taxable years beginning after December 31, 1995. (n) Treatment of Certain Veterans’ Reemployment Rights.— (1) In general.— Section 414 is amended by adding at the end the following new subsection: “(u) Special Rules Relating to Veterans’ Reemployment Rights Under USERRA.— “(1) Treatment of certain contributions made pursuant to veterans’ reemployment rights.— if any contribution is made by an employer or an employee under an individual account plan with respect to an employee, or by an employee to a defined benefit plan that provides for employee contributions, and such contribution is required by reason of such employee’s rights under chapter 43 of title 38, United States Code, resulting from qualified military service, then— “(A) such contribution shall not be subject to any otherwise applicable limitation contained in section 402(g), 402(h), 403(b), 404(a), 404(h), 408, 415, or 457, and shall not be taken into account in applying such limitations to other contributions or benefits under such plan or any other plan, with respect to the year in which the contribution is made, “(B) such contribution shall be subject to the limitations referred to in subparagraph (A) with respect to the year to which the contribution relates (in accordance with rules prescribed by the Secretary), and “(C) such plan shall not be treated as failing to meet the requirements of section 401(a)(4), 401(a)(26), 401(k)(3), 401(k)(11), 401(k.)(12), 401(m), 403(b)(12), 408(k)(3), 408(k)(6), 408(p), 410(b), or 416 by reason of the making of (or the right to make) such contribution. For purposes of the preceding sentence, any elective deferral or employee contribution made under paragraph (2) shall be treated as required by reason of the employee’s rights under such chapter 43. “(2) Reemployment rights under userra with respect to elective deferrals.— 110 STAT. 1884 “(A) In general.— For purposes of this subchapter and section 457, if an employee is entitled to the benefits of chapter 43 of title 38, United States Code, with respect to any plan which provides for elective deferrals, the employer sponsoring the plan shall be treated as meeting the requirements of such chapter 43 with respect to such elective deferrals only if such employer— “(i) permits such employee to make additional elective deferrals under such plan (in the amount determined under subparagraph (B) or such lesser amount as is elected by the employee) during the period which begins on the date of the reemployment of such employee with such employer and has the same length as the lesser of— “(I) the product of 3 and the period of qualified military service which resulted in such rights, and “(II) 5 years, and “(ii) makes a matching contribution with respect to any additional elective deferral made pursuant to clause (i) which would have been required had such deferral actually been made during the period of such qualified military service. “(B) Amount of makeup required.— The amount determined under this subparagraph with respect to any plan is the maximum amount of the elective deferrals that the individual would have been permitted to make under the plan in accordance with the limitations referred to in paragraph (1)(A) during the period of qualified military service if the individual had continued to be employed by the employer during such period and received compensation as determined under paragraph (7). Proper adjustment shall be made to the amount determined under the preceding sentence for any elective deferrals actually made during the period of such qualified military service. “(C) Elective deferral.— For purposes of this paragraph, the term ‘elective deferral’ has the meaning given such term by section 402(g)(3); except that such term shall include any deferral of compensation under an eligible deferred compensation plan (as defined in section 457(b)). “(D) After-tax employee contributions.— References in subparagraphs (A) and (B) to elective deferrals shall be treated as including references to employee contributions. “(3) Certain retroactive adjustments not required.— For purposes of this subchapter and subchapter E, no provision of chapter 43 of title 38, United States Code, shall be construed as requiring— “(A) any crediting of earnings to an employee with respect to any contribution before such contribution is actually made, or “(B) any allocation of any forfeiture with respect to the period of qualified military service. “(4) Loan repayment suspensions permitted.— If any plan suspends the obligation to repay any loan made to an employee from such plan for any part of any period during which such employee is performing service in the uniformed services (as defined in chapter 43 of title 38, United States110 STAT. 1885 Code), whether or not qualified military service, such suspension shall not be taken into account for purposes of section 72(p), 401(a). or 4975(d)(1). “(5) Qualified military service.— For purposes of this subsection, the term ‘qualified military service’ means any service in the uniformed services (as defined in chapter 43 of title 38, United States Code) by any individual if such individual is entitled to reemployment rights under such chapter with respect to such service. “(6) Individual account plan.— For purposes of this subsection, the term ‘individual account plan’ means any defined contribution plan (including any tax-sheltered annuity plan under section 403(b), any simplified employee pension under section 408(k), any qualified salary reduction arrangement under section 408(p), and any eligible deferred compensation plan (as defined in section 457(b)). “(7) Compensation.— For purposes of sections 403(b)(3), 415(c)(3), and 457(e)(5), an employee who is in qualified military service shall be treated as receiving compensation from the employer during such period of qualified military service equal to— “(A) the compensation the employee would have received during such period if the employee were not in qualified military service, determined based on the rate of pay the employee would have received from the employer but for absence during the period of qualified military service, or “(B) if the compensation the employee would have received during such period was not reasonably certain, the employee’s average compensation from the employer during the 12-month period immediately preceding the qualified military service (or, if shorter, the period of employment immediately preceding the qualified military service). “(8) USERRA requirements for qualified retirement plans.— For purposes of this subchapter and section 457, an employer sponsoring a retirement plan shall be treated as meeting the requirements of chapter 43 of title 38, United States Code, only if each of the following requirements is met: “(A) An individual reemployed under such chapter is treated with respect to such plan as not having incurred a break in service with the employer maintaining the plan by reason of such individual’s period of qualified military service. “(B) Each period of qualified military service served by an individual is, upon reemployment under such chapter, deemed with respect to such plan to constitute service with the employer maintaining the plan for the purpose of determining the nonforfeitability of the individual’s accrued benefits under such plan and for the purpose of determining the accrual of benefits under such plan. “(C) An individual reemployed under such chapter is entitled to accrued benefits that are contingent on the making of, or derived from, employee contributions or elective deferrals only to the extent the individual makes payment to the plan with respect to such contributions or deferrals. No such payment may exceed the amount the110 STAT. 1886 individual would have been permitted or required to contribute had the individual remained continuously employed by the employer throughout the period of qualified military service. Any payment to such plan shall be made during the period beginning with the date of reemployment and whose duration is 3 times the period of the qualified military service (but not greater than 5 years). “(9) Plans not subject to title 38.— This subsection shall not apply to any retirement plan to which chapter 43 of title 38, United States Code, does not apply. “(10) References.— For purposes of this section, any reference to chapter 43 of title 38, United States Code, shall be treated as a reference to such chapter as in effect on December 12, 1994 (without regard to any subsequent amendment).”. (2) Amendment to erisa.— Section 408(b)(1) of the Employee Retirement Income Security Act of 1974 (29 U.S.C. 1148(b)) is amended by adding at the end the following new sentence: “A loan made by a plan shall not fail to meet the requirements of the preceding sentence by reason of a loan repayment suspension described under section 414(u)(4) of the Internal Revenue Code of 1986.”. (3) Effective date.— The amendments made by this subsection shall be effective as of December 12, 1994. (o) Reporting of Real Estate Transactions.— (1) In general.— Paragraph (3) of section 6045(e) (relating to prohibition of separate charge for filing return) is amended by adding at the end the following new sentence: “Nothing in this paragraph shall be construed to prohibit the real estate reporting person from taking into account its cost of complying with such requirement in establishing its charge (other than a separate charge for complying with such requirement) to any customer for performing services in the case of a real estate transaction.”. (2) Effective date.— The amendment made by paragraph (1) shall take effect as if included in section 1015(e)(2)(A) of the Technical and Miscellaneous Revenue Act of 1988. (p) Clarification of Denial of Deduction for Stock Redemption Expenses. (1) In general.— Paragraph (1) of section 162(k) is amended by striking “the redemption of its stock” and inserting “the reacquisition of its stock or of the stock of any related person (as defined in section 465(b)(3)(C))”. (2) Certain deductions permitted.— Subparagraph (A) of section 162(k)(2) is amended by striking “or” at the end of clause (i), by redesignating clause (ii) as clause (iii), and by inserting after clause (i) the following new clause: “(ii) deduction for amounts which are properly allocable to indebtedness and amortized over the term of such indebtedness, or”. (3) Clerical amendment.— The subsection heading for subsection (k) of section 162 is amended by striking “REDEMPTION” and inserting “REACQUISITION”. (4) Effective date.— (A) In general.— Except as provided in subparagraph (B), the amendments made by this subsection shall apply110 STAT. 1887 to amounts paid or incurred after September 13, 1995, in taxable years ending after such date. (B) Paragraph (2).— The amendment made by paragraph (2) shall take effect as if included in the amendment made by section 613 of the Tax Reform Act of 1986. (q) Clerical Amendment to Section 404.— (1) In general.— Paragraph (1) of section 404(j) is amended by striking “(10)” and inserting “(9)”. (2) Effective date.— The amendment made by paragraph (1) shall take effect as if included in the amendments made by section 713(d)(4)(A) of the Deficit Reduction Act of 1984. (r) Passive Income Not To Include FSC Income, Etc.— (1) In general.— Paragraph (2) of section 1296(b) is amended by striking “or” at the end of subparagraph (B), by striking the period at the end of subparagraph (C) and inserting “, or”, and by inserting after subparagraph (C) the following new subparagraph: “(D) which is foreign trade income of an FSC or export trade income of an export trade corporation (as defined in section 971).”. (2) Effective date.— The amendments made by paragraph (1) shall take effect as if included in the amendments made by section 1235 of the Tax Reform Act of 1986. (s) Technical Correction of Intermediate Sanctions Provisions.— (1) Subparagraph (C) of section 6652(c)(1) is amended by striking “$10” and inserting “$20”, and by striking “$5,000” and inserting “$10,000”. (2) Subparagraph (D) of section 6652(c)(1) is amended by striking “$10” and inserting “$20”. (t) Miscellaneous Clerical Amendments.— (1) Subclause (II) of section 56(g)(4)(C)(ii) is amended by striking “of the subclause” and inserting “of subclause”. (2) Paragraph (2) of section 72(m) is amended by inserting “and” at the end of subparagraph (A), by striking subparagraph (B), and by redesignating subparagraph (C) as subparagraph (B). (3) Paragraph (2) of section 86(b) is amended by striking “adusted” and inserting “adjusted”. (4) (A) The heading for section 112 is amended by striking “combat pay” and inserting “combat zone compensation”. (B) The item relating to section 112 in the table of sections for part III of subchapter B of chapter 1 is amended by striking “combat pay” and inserting “combat zone compensation”. (C) Paragraph (1) of section 3401(a) is amended by striking “combat pay” and inserting “combat zone compensation”. (5) Clause (i) of section 172(h)(3)(B) is amended by striking the comma at the end thereof and inserting a period. (6) Clause (ii) of section 543(a)(2)(B) is amended by striking “section 563(c)” and inserting “section 563(d)”. (7) Paragraph (1) of section 958(a) is amended by striking “sections 955(b)(1)(A) and (B), 955(c)(2)(A)(ii), and 960(a)(1)” and inserting “section 960(a)(1)”. (8) Subsection (g) of section 642 is amended by striking “under 2621(a)(2)” and inserting “under section 2621(a)(2)”. (9) Section 1463 is amended by striking “this subsection” and inserting “this section”. 110 STAT. 1888 (10) Subsection (k) of section 3306 is amended by inserting a period at the end thereof. (11) The item relating to section 4472 in the table of sections for subchapter B of chapter 36 is amended by striking “and special rules”. (12) Paragraph (3) of section 5134(c) is amended by striking “section 6662(a)” and inserting “section 6665(a)”. (13) Paragraph (2) of section 5206(f) is amended by striking “section 5(e)” and inserting “section 105(e)”. (14) Paragraph (1) of section 6050B(c) is amended by striking “section 85(c)” and inserting “section 85(b)”. (15) Subsection (k) of section 6166 is amended by striking paragraph (6). (16) Subsection (e) of section 6214 is amended to read as follows: “(e) Cross Reference.— “For provision giving Tax Court jurisdiction to order a refund of an overpayment and to award sanctions, see section 6512(b)(2).”. (17) The section heading for section 6043 is amended by striking the semicolon and inserting a comma. (18) The item relating to section 6043 in the table of sections for subpart B of part III of subchapter A of chapter 61 is amended by striking the semicolon and inserting a comma. (19) The table of sections for part I of subchapter A of chapter 68 is amended by striking the item relating to section 6662. (20) (A) Section 7232 is amended— (i) by striking “lubricating oil,” in the heading, and (ii) by striking “lubricating oil,” in the text. (B) The table of sections for part II of subchapter A of chapter 75 is amended by striking “lubricating oil,” in the item relating to section 7232. (21) Paragraph (1) of section 6701(a) of the Omnibus Budget Reconciliation Act of 1989 is amended by striking “subclause (IV)” and inserting “subclause (V)”. (22) Clause (ii) of section 7304(a)(2)(D) of such Act is amended by striking “subsection (c)(2)” and inserting “subsection (c)”. (23) Paragraph (1) of section 7646(b) of such Act is amended by striking “section 6050H(b)(1)” and inserting “section 6050H(b)(2)”. (24) Paragraph (10) of section 7721(c) of such Act is amended by striking “section 6662(b)(2)(C)(ii)” and inserting “section 6661(b)(2)(C)(ii)”. (25) Subparagraph (A) of section 7811(i)(3) of such Act is amended by inserting “the first place it appears” before “in clause (i)”. (26) Paragraph (10) of section 7841(d) of such Act is amended by striking “section 381(a)” and inserting “section 381(c)”. (27) Paragraph (2) of section 7861(c) of such Act is amended by inserting “the second place it appears” before “and inserting”. (28) Paragraph (1) of section 460(b) is amended by striking “the look-back method of paragraph (3)” and inserting “the look-back method of paragraph (2)”. 110 STAT. 1889 (29) Subparagraph (C) of section 50(a)(2) is amended by striking “subsection (c)(4)” and inserting “subsection (d)(5)”. (30) Subparagraph (B) of section 172(h)(4) is amended by striking the material following the heading and preceding clause (i) and inserting “For purposes of subsection (b)(2)—”. (31) Subparagraph (A) of section 355(d)(7) is amended by inserting “section” before “267(b)”. (32) Subparagraph (C) of section 420(e)(1) is amended by striking “mean” and inserting “means”. (33) Paragraph (4) of section 537(b) is amended by striking “section 172(i)” and inserting “section 172(f)”. (34) Subparagraph (B) of section 613(e)(1) is amended by striking the comma at the end thereof and inserting a period. (35) Paragraph (4) of section 856(a) is amended by striking “section 582(c)(5)” and inserting “section 582(c)(2)”. (36) Sections 904(f)(2)(B)(i) and 907(c)(4)(B)(iii) are each amended by inserting “(as in effect on the day before the date of the enactment of the Revenue Reconciliation Act of 1990)” after “section 172(h)”. (37) Subsection (b) of section 936 is amended by striking “subparagraphs (D)(ii)(I)” and inserting “subparagraphs (D)(ii)”. (38) Subsection (c) of section 2104 is amended by striking “subparagraph (A), (C), or (D) of section 861(a)(1)” and inserting “section 861(a)(1)(A)”. (39) Subparagraph (A) of section 280A(c)(1) is amended to read as follows: “(A) as the principal place of business for any trade or business of the taxpayer,”. (40) Section 6038 is amended by redesignating the subsection relating to cross references as subsection (f). (41) Clause (iv) of section 6103(e)(1)(A) is amended by striking all that follows “provisions of” and inserting “section 1(g) or 59(j);”. (42) The subsection (f) of section 6109 of the Internal Revenue Code of 1986 which was added by section 2201(d) of Public Law 101–624 is redesignated as subsection (g). (43) Subsection (b) of section 7454 is amended by striking “section 4955(e)(2)” and inserting “section 4955(f)(2)”. (44) Subsection (d) of section 11231 of the Revenue Reconciliation Act of 1990 shall be applied as if “comma” appeared instead of “period” and as if the paragraph (9)proposed to be added ended with a comma. (45) Paragraph (1) of section 11303(b) of the Revenue Reconciliation Act of 1990 shall be applied as if “paragraph” appeared instead of “subparagraph” in the material proposed to be stricken. (46) Subsection (f) of section 11701 of the Revenue Reconciliation Act of 1990 is amended by inserting “(relating to definitions)” after “section 6038(e)”. (47) Subsection (i) of section 11701 of the Revenue Reconciliation Act of 1990 shall be applied as if “subsection” appeared instead of “section” in the material proposed to be stricken. (48) Subparagraph (B) of section 11801(c)(2) of the Revenue Reconciliation Act of 1990 shall be applied as if “section 56(g)” appeared instead of “section 59(g)”. 110 STAT. 1890 (49) Subparagraph (C) of section 11801(c)(8) of the Revenue Reconciliation Act of 1990 shall be applied as if “reorganizations” appeared instead of “reorganization” in the material proposed to be stricken. (50) Subparagraph (H) of section 11801(c)(9) of the Revenue Reconciliation Act of 1990 shall be applied as if “section 1042(c)(1)(B)” appeared instead of “section 1042(c)(2)(B)”. (51) Subparagraph (F) of section 11801(c)(12) of the Revenue Reconciliation Act of 1990 shall be applied as if “and (3)” appeared instead of “and (E)”. (52) Subparagraph (A) of section 11801(c)(22) of the Revenue Reconciliation Act of 1990 shall be applied as if “chapters 21” appeared instead of “chapter 21” in the material proposed to be stricken. (53) Paragraph (3) of section 11812(b) of the Revenue Reconciliation Act of 1990 shall be applied by not executing the amendment therein to the heading of section 42(d)(5)(B). (54) Clause (i) of section 11813(b)(9)(A) of the Revenue Reconciliation Act of 1990 shall be applied as if a comma appeared after “(3)(A)(ix)” in the material proposed to be stricken. (55) Subparagraph (F) of section 11813(b)(l3) of the Revenue Reconciliation Act of 1990 shall be applied as if “tax” appeared after “investment” in the material proposed to be stricken. (56) Paragraph (19) of section 11813(b) of the Revenue Reconciliation Act of 1990 shall be applied as if “Paragraph (20) of section 1016(a), as redesign.ated by section. 11801,” appeared instead of “Paragraph (21) of section 1016(a)”. (57) Paragraph (5) section 8002(a) of the Surface Transportation Revenue Act of 1991 shall be applied as if “4481(e)” appeared instead of “4481(c)”. (58) Section 7872 is amended— (A) by striking “foregone” each place it appears in subsections (a) and (e)(2) and inserting “forgone”, and (B) by striking “FOREGONE” in the heading for subsection (e) and the heading for paragraph (2) of subsection (e) and inserting “FORGONE”. (59) Paragraph (7) of section 76l1(h) is amended by striking “approporiate” and inserting “appropriate”. (60) The heading of paragraph (3) of section 419A(c) is amended by striking “severence” and inserting “severance”. (61) Clause (ii) of section 807(d)(3)(B) is amended by striking “Commissoners’” and inserting “Commissioners’”. (62) Subparagraph (B) of section 1274A(c)(1) is amended by striking “instument” and inserting “instrument”. (63) Subparagraph (B) of section 724(d)(3) by striking “Subparagaph” and inserting “Subparagraph”. (64) The last sentence of paragraph (2) of section 42(c) is amended by striking “of 1988”. (65) Paragraph(1) of section 9707(d) is amended by striking “diligence,” and inserting “diligence”. (66) Subsection (c) of section 4977 is amended by striking “section 132(i)(2)” and inserting “section 132(h)”. (67) The last sentence of section 401(a)(20) is amended by striking “section 211” and inserting “section 521”. 110 STAT. 1891 (68) Subparagraph (A) of section 402(g)(3) is amended by striking “subsection (a)(8)” and inserting “subsection (e)(3)”. (69) The last sentence of section 403(b)(10) is amended by striking “an direct” and inserting “a direct”. (70) Subparagraph (A) of section 4973(b)(1) is amended by striking “sections 402(c)” and inserting “section 402(c)”. (71) Paragraph (12) of section 3405(e) is amended by striking “(b)(3)” and inserting “(b)(2)”. (72) Paragraph (41) of section 521(b) of the Unemployment Compensation Amendments of 1992 shall be applied as if “section” appeared instead of “sections” in the material proposed to be stricken. (73) Paragraph (27) of section 521(b) of the Unemployment Compensation Amendments of 1992 shall be applied as if “Section 691(c)(5)” appeared instead of “Section 691(c)”. (74) Paragraph (5) of section 860F(a) is amended by striking “paragraph (1)” and inserting “paragraph (2)”. (75) Paragraph (1) of section 415(k) is amended by adding “or” at the end of subparagraph (C), by striking subparagraphs (D) and (E), andby redesignating subparagraph (F) as subparagraph (D). (76) Paragraph (2) of section 404(a) is amended by striking “(18),”. (77) Clause (ii) of section 72(p)(4)(A) is amended to read as follows: (ii) Special rule.— The term ‘qualified employer plan’ shall include any plan which was (or was determined to be) a qualified employer plan or a government plan.”. (78) Sections 461(i)(3)(C) and 1274(b)(3)(B)(i) are each amended by striking “section 6662(d)(2)(C)(ii)” and inserting “section 6662(d)(2)(C)(iii)”. (79) Subsection (a) of section 164 is amended by striking the paragraphs relating to the generation-skipping tax and the environmental tax imposed by section 59A and by inserting after paragraph (3) the following new paragraphs: “(4) The GST tax imposed on income distributions. “(5) The environmental tax imposed by section 59A.”. (80) Subclause (I) of section 936(a)(4)(A)(ii) is amended by striking “deprecation” and inserting “depreciation”.