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obligation of the United States in effect on the date of
enactment of the 1954 Code. See S. Rept. 100-445, at 316-
328 (1988). More recently, Congress had specifically
provided from time to time that it intended certain
amendments of the Internal Revenue Code to prevail over
treaties in case of a conflict. Id.
In TAMRA, Congress amended section 7852(d) to provide
that neither a provision of a treaty nor a law of the
United States affecting revenue shall have preferential
status by reason of its being a treaty or a law. TAMRA
sec. 1012(aa)(1), 102 Stat. 3531. Congress intended this
change to place treaties and revenue statutes on the same
footing, so that conflicts in their provisions would be
resolved under the rule that the provision adopted later
in time controls. S. Rept. 100-445, supra at 321-322.
Congress also intended this change to codify the approach
of the courts under which the same canons of construction
applied to the interaction of two statutes enacted at
different times would be applied to the interaction of
revenue statutes and treaties enacted and entered into at
different times. Id. at 321.
In addition to amending section 7852(d), Congress
enacted the following provision as section 1012(aa)(2)
of TAMRA:
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