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(2) 80-percent voting and value test.--The owner-
ship of stock of any corporation meets the requirements
of this paragraph if it--
(A) possesses at least 80 percent of the
total voting power of the stock of such corpora-
tion, and
(B) has a value equal to at least 80 percent
of the total value of the stock of such corpora-
tion.
As pertinent here, the principal difference between section
1504(a) and amended section 1504(a) is that the definition of the
term "affiliated group" in the latter provision imposes an 80-
percent value test in addition to the 80-percent voting power
test that is imposed by both provisions. Compare sec. 1504(a)
with amended sec. 1504(a).
Section 60(b)(2) of the 1984 Act, 98 Stat. 579, as amended
retroactively by section 1804(e)(2) of the Tax Reform Act of
1986, Pub. L. 99-514, 100 Stat. 2800, provides the following
special rule for the effective date of amended section 1504(a)
(special effective date rule):
(2) Special Rule for Corporations Affiliated on June
22, 1984--In the case of a corporation which on June 22,
1984, is a member of an affiliated group which files a
consolidated return for such corporation's taxable year
which includes June 22, 1984, for purposes of determining
whether such corporation continues to be a member of such
group for taxable years beginning before January 1, 1988,
the amendment made by subsection (a) [viz, amended section
1504(a)] shall not apply. The preceding sentence shall
cease to apply as of the first day after June 22, 1984, on
which such corporation does not qualify as a member of
such group under section 1504(a) the Internal Revenue Code
of 1954 (as in effect on the day before the enactment of
this [1984] Act).
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