- 12 - 1221(f), 100 Stat. 2554. The repeal was based generally on Congress' belief that the chain deficit rule in section 952(d) allowed U.S. taxpayers to shelter through CFC's excessive amounts of tax haven income from current U.S. tax. See H. Conf. Rept. 99-841, at 621-626 (1986), 1986-3 C.B. (Vol. 4) 473, 621-626. In 1988, a new and revised chain deficit rule was enacted, retroactive to any year ending after 1986. Sec. 952(c)(1)(C); Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 1012(i)(25)(A), 102 Stat. 3512. The TAMRA version of the chain deficit rule is the rule that governs in this case for 1990. The chain deficit rule, as enacted in 1988, provided new restrictions on the use of deficits in earnings and profits of CFC's to reduce subpart F income of profitable CFC's owned by U.S. shareholders. In particular, under TAMRA, the new chain deficit rule provides that, in order to reduce subpart F income of profitable CFC's by deficits in earnings and profits of unprofitable CFC's, the profitable and unprofitable CFC's must satisfy a new "qualified chain member" rule and subpart F income of the profitable CFC's must be attributable to the same qualified activity to which deficits in earnings and profits of the unprofitable CFC's are attributable. Sec. 952(c)(1)(B) and (C). CFC's constitute qualified chain members under section 952(c)(1)(C) only where the CFC's are related to each other directly or indirectly through a single, straight-line chain ofPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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