TREATMENT OF CERTAIN UNITED STATES AFFILIATE OBLIGATIONS.

SEC. 6128. TREATMENT OF CERTAIN UNITED STATES AFFILIATE OBLIGATIONS. (a) General Rule.—Subparagraph (B) of section 127(g)(3) of the Tax Reform Act of 1984 is amended by inserting before the period at the end thereof the following: “as such principles are applied in Revenue Ruling 86–6, except that the maximum debt-to-equity ratio described in such Revenue Rulings shall be increased from 5–to–1 to 25–to–1”. (b) Effective Date.—The amendment made by subsection (a) shall apply to taxable years ending after the date of the enactment of this Act.