SEC. 521. REPEAL OF FINANCIAL INSTITUTION TRANSITION RULE TO INTEREST ALLOCATION
RULES.
Title[ Title V\Subtitle C Contents
Subtitle C--Repeal of Financial Institution Transition Rule to Interest
Allocation Rules
(a) In General.--Paragraph (5) of section 1215(c) of the Tax Reform
Act of 1986 (Public Law 99-514, 100 Stat. 2548) <<NOTE: 26 USC 864
note.>> is hereby repealed.
(b) Effective <<NOTE: 26 USC 864 note.>> Date.--
(1) In general.--The amendment made by this section shall
apply to taxable years beginning after December 31, 1995.
(2) Special rule.--In the case of the first taxable year
beginning after December 31, 1995, the pre-effective date
portion of the interest expense of the corporation referred to
in such paragraph (5) of such section 1215(c) for such taxable
year shall be allocated and apportioned without regard to such
amendment. For purposes of the preceding sentence, the pre-
effective date portion is the amount which bears the same ratio
to the interest expense for such taxable year as the number of
days during such taxable year before the date of the enactment
of this Act bears to 366.
Approved August 21, 1996.
LEGISLATIVE HISTORY--H.R. 3103 (S. 1028) (S. 1698):
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HOUSE REPORTS: Nos. 104-496, Pt. 1 (Comm. on Ways and Means) and 104-736
(Comm. of Conference).
SENATE REPORTS: No. 104-156 accompanying S. 1028 (Comm. on Labor and
Human Resources).
CONGRESSIONAL RECORD, Vol. 142 (1996):
Mar. 28, considered and passed House.
Apr. 18, 23, considered and passed Senate, amended, in lieu
of S. 1028.
Aug. 1, House agreed to conference report.
Aug. 2, Senate agreed to conference report.
WEEKLY COMPILATION OF PRESIDENTIAL DOCUMENTS, Vol. 32 (1996):
Aug. 21, Presidential remarks and statement.
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