- 69 -
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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