Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 6

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                    (A) the Federal short-term rate determined under                  
                    subsection (b), plus                                              
                    (B) 3 percentage points (2 percentage points in the               
                    case of a corporation).                                           
               To the extent that an overpayment of tax by a                          
               corporation for any taxable period * * * exceeds                       
               $10,000, subparagraph (B) shall be applied by                          
               substituting “0.5 percentage point” for “2 percentage                  
               points”.[3]                                                            

               The flush language of section 6621(a)(1), reflecting the               
          reduced overpayment interest rate for large corporate                       
          overpayments for periods after December 31, 1994, was added to              
          the Code in 1994 as part of the Uruguay Round Agreements Act                
          (GATT), Pub. L. 103-465, sec. 713(a), 108 Stat. 5001-5002 (1994).           
          In accordance with the terminology used in Gen. Elec. Co. v.                
          United States, 384 F.3d at 1309, we refer to the amendment of               
          section 6621(a)(1) as the GATT amendment.                                   
               The effective date of the GATT amendment was provided in               
          section 713(b), as follows:                                                 

                    (b)  Effective Date.–-The amendment made by this                  
               section shall apply for purposes of determining interest for           
               periods after December 31, 1994.                                       


               3  The version of the statute quoted in the text is the                
          current version, reflecting changes not relevant herein made by             
          the Taxpayer Relief Act of 1997 (TRA 1997), Pub. L. 105-34, sec.            
          1463(a), 111 Stat. 1057; TRA 1997, sec. 1604(b)(1), 111 Stat.               
          1097; Internal Revenue Service Restructuring and Reform Act of              
          1998, Pub. L. 105-206, sec. 3302(a), 112 Stat. 741.                         






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