DELAY IN APPLICATION OF WORLDWIDE ALLOCATION OF INTEREST.

SEC. 3093. DELAY IN APPLICATION OF WORLDWIDE ALLOCATION OF INTEREST.(a) In General.—Paragraphs (5)(D) and (6) of section 864(f) are each amended by striking “December 31, 2008” and inserting “December 31, 2010”.(b) Transitional Rule.—Subsection (f) of section 864 is amended by adding at the end the following new paragraph:“(7) Transition.—In the case of the first taxable year to which this subsection applies, the increase (if any) in the amount of the interest expense allocable to sources within the United States by reason of the application of this subsection shall be 30 percent of the amount of such increase determined without regard to this paragraph.”.(c) Effective Date.—The amendments made by this section shall apply to taxable years beginning after December 31, 2008.