Electronic Arts, Inc. and Subsidiaries - Page 69




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          C.B. 600, 617; see also Staff of Joint Comm. on Taxation, General           
          Explanation of the Revenue Provisions of the Tax Equity And                 
          Fiscal Responsibility Act of 1982, 79 n.* (J. Comm. Print 1982)             
          (hereinafter sometimes referred to as JCT Staff General                     
          Explanation).  The bill as reported by the Senate Finance                   
          Committee and as passed by the Senate included subsection (h), as           
          proposed to be enacted by section 218(a)(2) of the bill, but did            
          not have a provision corresponding to paragraph (5)--the                    
          election-out provision.  See text of H.R. 4691 reported by the              
          Senate Finance Committee, 258-266; text of the Senate-passed                
          amendments, 263-271.  The election-out provision was added in               
          conference, and was described in pertinent part as follows in the           
          Joint Statement of Managers portion of the conference committee             
          report (H. Conf. Rept. 97-760, 505, 510, 1982-2 C.B. at 617-618,            
          620; see also JCT Staff General Explanation 85, 87, 92):                    
               Intangible income                                                      
                    An election may be made to treat income                           
               attributable to certain intangible property as income                  
               of the section 936 corporation eligible for the credit                 
               (and certain domestic corporations operating in the                    
               Virgin Islands) under two options--(1) a cost sharing                  
               rule and (2) a 50/50 profit split.  The two exceptions                 
               with respect to certain types of intangible property                   
               found in the Senate amendment are deleted.  In                         
               addition, an exception to the Senate bill is made for                  
               intangible property which has been licensed since prior                
               to 1948 to a U.S. corporation operating in a possession                
               and is in use by such corporation on the date of                       
               enactment.                                                             
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