I.R.C. § 243(a) General Rule —
In the case of a corporation, there shall be allowed as a deduction an amount equal
to the following percentages of the amount received as dividends from a domestic
corporation which is subject to taxation under this chapter:
I.R.C. § 243(a)(1) —
50 percent, in the case of dividends other than dividends described in paragraph
(2) or (3);
I.R.C. § 243(a)(2) —
100 percent, in the case of dividends received by a small business investment company
operating under the Small Business Investment Act of 1958 (15
U.S.C. 661 and following); and
I.R.C. § 243(a)(3) —
100 percent, in the case of qualifying dividends (as defined in subsection (b)(1)).
I.R.C. § 243(b) Qualifying Dividends
I.R.C. § 243(b)(1) In General —
For purposes of this section, the term “qualifying dividend” means any
dividend received by a corporation—
I.R.C. § 243(b)(1)(A) —
if at the close of the day on which such dividend is received, such corporation
is a member of the same affiliated group as the corporation distributing such dividend,
and
I.R.C. § 243(b)(1)(B) —
if such dividend is distributed out of the earnings and profits of a taxable year
of the distributing corporation which ends after December 31, 1963, and on each day
of which the distributing corporation and the corporation receiving the dividend were
members of such affiliated group.
I.R.C. § 243(b)(2) Affiliated Group —
For purposes of this subsection:
I.R.C. § 243(b)(2)(A) In General —
The term “affiliated group” has the meaning given such term by section
1504(a), except that for such purposes sections 1504(b)(2) and 1504(c) shall not apply.
I.R.C. § 243(b)(2)(B) Group Must Be Consistent In Foreign Tax Treatment —
The requirements of paragraph (1) (A) shall not be treated as being met with respect
to any dividend received by a corporation if, for any taxable year which includes
the day on which such dividend is received—
I.R.C. § 243(b)(2)(B)(i) —
1 or more members of the affiliated group referred to in paragraph (1)(A) choose
to any extent to take the benefits of section 901, and
I.R.C. § 243(b)(2)(B)(ii) —
1 or more other members of such group claim to any extent a deduction for taxes
otherwise creditable under section 901.
I.R.C. § 243(b)(3) Special Rule For Groups Which Include Life Insurance Companies
I.R.C. § 243(b)(3)(A) In General —
In the case of an affiliated group which includes 1 or more insurance companies
under section 801, no dividend by any member of such group shall be treated as a qualifying dividend
unless an election under this paragraph is in effect for the taxable year in which
the dividend is received. The preceding sentence shall not apply in the case of a
dividend described in paragraph (1)(B)(ii).
I.R.C. § 243(b)(3)(B) Effect Of Election —
If an election under this paragraph is in effect with respect to any affiliated
group—
I.R.C. § 243(b)(3)(B)(i) —
part II of subchapter B of chapter 6 (relating to certain controlled corporations)
shall be applied with respect to the members of such group without regard to sections
1563(a)(4) and 1563(b)(2)(D), and
I.R.C. § 243(b)(3)(B)(ii) —
for purposes of this subsection, a distribution by any member of such group which
is subject to tax under section 801 shall not be treated as a qualifying dividend if such distribution is out of earnings
and profits for a taxable year for which an election under this paragraph is not
effective and for which such distributing corporation was not a component member
of a controlled group of corporations within the meaning of section 1563 solely by reason of section 1563(b)(2)(D).
I.R.C. § 243(b)(3)(C) Election —
An election under this paragraph shall be made by the common parent of the affiliated
group and at such time and in such manner as the Secretary shall by regulations prescribe.
Any such election shall be binding on all members of such group and may be revoked
only with the consent of the Secretary.
I.R.C. § 243(c) Increased Percentage For Dividends From 20-Percent Owned Corporations
I.R.C. § 243(c)(1) In General —
In the case of any dividend received from a 20-percent owned corporation, subsection
(a)(1) shall be applied by substituting “65 percent” for “50 percent”.
I.R.C. § 243(c)(2) 20-Percent Owned Corporation —
For purposes of this section, the term “20-percent owned corporation”
means any corporation if 20 percent or more of the stock of such corporation (by
vote and value) is owned by the taxpayer. For purposes of the preceding sentence,
stock described in section 1504(a)(4) shall not be taken into account.
I.R.C. § 243(d) Special Rules For Certain Distributions —
For purposes of subsection (a)—
I.R.C. § 243(d)(1) —
Any amount allowed as a deduction under section 591 (relating to deduction for dividends paid by mutual savings banks, etc.) shall not
be treated as a dividend.
I.R.C. § 243(d)(2) —
A dividend received from a regulated investment company shall be subject to the
limitations prescribed in section 854.
I.R.C. § 243(d)(3) —
Any dividend received from a real estate investment trust which, for the taxable
year of the trust in which the dividend is paid, qualifies under part II of subchapter
M (section 856 and following) shall not be treated as a dividend.
I.R.C. § 243(e) Certain Dividends From Foreign Corporations —
For purposes of subsection (a) and for purposes of section 245, any dividend from a foreign corporation from earnings and profits accumulated by
a domestic corporation during a period with respect to which such domestic corporation
was subject to taxation under this chapter (or corresponding provisions of prior
law) shall be treated as a dividend from a domestic corporation which is subject
to taxation under this chapter.
(Aug. 16, 1954, ch. 736, 68A Stat. 73; Sept. 2, 1958,
Pub. L. 85-866, title I, Sec. 57(b), 72 Stat. 1645;
Sept. 14, 1960, Pub. L. 86-779, Sec. 3(a), 10(g), 74 Stat. 998, 1009; Feb. 26, 1964, Pub. L. 88-272, title II, Sec. 214(a), 78 Stat. 52; June 28, 1968, Pub. L. 90-364, title I, Sec. 103(e)(2), 82 Stat. 264; Dec. 30, 1969, Pub. L. 91-172, title V, Sec. 504(c)(1), 83 Stat. 633; Mar. 29, 1975, Pub. L. 94-12, title III, Sec. 304(b), 89 Stat. 45; Oct. 4, 1976, Pub. L. 94-455, title X, Sec. 1031(b)(2), 1051(f)(1), (2), title XIX, Sec. 1901(a)(34), (b)(1)(J)(ii),
(21)(A)(i), 1906(b)(3)(C)(ii), (13)(A), 90 Stat. 1622, 1646, 1769, 1791, 1797, 1833, 1834; Aug. 13, 1981, Pub. L. 97-34, title II, Sec. 232(b)(2),
95 Stat. 250; July 18, 1984, Pub. L. 98-369, div. A, title II, Sec. 211(b)(3), 98 Stat. 754;
Oct. 22, 1986, Pub. L. 99-514, title IV, Sec. 411(b)(2)(C)(iv), title VI, Sec. 611(a)(1), 100 Stat. 2227, 2249; Dec. 22, 1987, Pub. L. 100-203, title X, Sec. 10221(a)(1),
(b), 101 Stat. 1330-408; Nov. 10, 1988, Pub. L. 100-647, title I, Sec. 1010(f)(4), 102 Stat. 3454;
Nov. 5, 1990, Pub. L. 101-508, title XI, Sec. 11814(a), 104 Stat. 1388-556;
Aug. 20, 1996, Pub. L. 104-188, title I, Sec. 1702(h)(4), (8), 110 Stat. 1755; Pub. L. 113-295, Div. A, title II, Sec. 221(a)(41), Dec. 19, 2014, 128 Stat. 4010; Pub. L. 115-97, Sec. 13002, Dec. 22, 2017, 131 Stat. 2054; Pub. L. 115-141, Div. U, title IV, Sec. 401(d)(1)(D)(v), (xvii)(II), Mar. 23, 2018, 132 Stat. 348.)
BACKGROUND NOTES
Section 1562, referred to in subsec. (b)(1)(B)(i), was repealed by Pub. L. 91-172, title IV, Sec. 401(a)(2), Dec. 30, 1969, 83 Stat. 600.
AMENDMENTS
2018 -
Subsec. (b)(1)(B). Pub. L. 115-141, Div. U, Sec. 401(d)(1)(D)(v), amended subpar. (B). Before being amended, subpar.
(B) read as follows:
“(B) if —
“(i) such dividend is distributed out of the earnings and profits of a taxable
year of the distributing corporation which ends after December 31, 1963, for which
an election under section 1562 was not in effect, and on each day of which the distributing
corporation and the corporation receiving the dividend were members of such affiliated
group, or
“(ii) such dividend is paid by a corporation with respect to which an election
under section 936 is in effect for the taxable year in which such dividend is paid.”
Subsec. (b)(2). Pub. L. 115-141, Div. U, Sec. 401(d)(1)(D)(xvii)(II), amended par. (2) by striking “, 1504(b)(4),”.
2017 -
Subsec. (a)(1). Pub. L. 115-97, Sec. 13002(a)(1), amended par. (1) by substituting ‘‘50 percent’’ for ‘‘70
percent’’.
Subsec. (c)(1). Pub. L. 115-97, Sec. 13002(a)(2), amended par. (1) by substituting
‘‘65 percent’’ for ‘‘80 percent’’,
and by substituting “50 percent” for ‘‘70 percent’’.
Subsec. (c). Pub. L. 115-97, Sec. 13002(a)(3), amended the heading for subsec.
(c) by substituting ‘‘INCREASED PERCENTAGE’’
for ‘‘RETENTION OF 80-PERCENT DIVIDEND RECEIVED DEDUCTION’’.
2014 - Subsec. (c)(1). Pub. L. 113-295, Div. A, Sec. 221(a)(41)(C), amended par. (1). Before amendment, it read as follows:
“(1) In General.— In the case of any dividend received from a 20-percent
owned corporation—
“(A) subsection (a)(1) of this section, and
“(B) subsections (a)(3) and (b)(2) of section 244, shall be applied by substituting
“80 percent” for “70 percent”.”
Subsec. (d)(4). Pub. L. 113-295, Div. A, Sec. 221(a)(41)(D), amended subsec.
(d) by striking par. (4). Before being struck, it read as follows:
“(4) Any dividend received which is described in section 244 (relating to dividends
received on preferred stock of a public utility) shall not be treated as a dividend.”
1996 - Subsec. (b)(2). Pub. L. 104-188, Sec. 1702(h)(8), amended paragraph (2). Prior to the amendment, paragraph (2) read as follows:
“(2) AFFILIATED GROUP. -- For purposes of this subsection, the term ‘affiliated
group’ has the meaning given such term by section 1504(a), except that for such
purposes sections 1504(b)(2), 1504(b)(4), and 1504(c) shall not apply.”
Subsec. (b)(3)(A). Pub. L. 104-188, Sec. 1702(h)(4), amended subsection (b)(3)(A) by inserting “of” after ‘’In
the case”.
1990 - Subsec. (b). Pub. L. 101-508 amended subsec. (b) generally, substituting present provisions for provisions defining
‘qualifying dividends’, providing for an election by or for an affiliated
group, the effect of an election, and the termination of an election, defining an
‘affiliated group’, and providing special rules for insurance companies.
1988 - Subsec. (b)(6). Pub. L. 100-647 substituted ‘section 801’ for ‘section 801 or 821’.
1987 - Subsec. (a)(1). Pub. L. 100-203, Sec. 10221(a)(1), substituted ‘70 percent’ for ‘80 percent’.
Subsecs. (c) to (e). Pub. L. 100-203, Sec. 10221(b), added subsec. (c) and redesignated former subsecs. (c) and (d) as
(d) and (e), respectively.
1986 - Subsec. (a)(1). Pub. L. 99-514, Sec. 611(a)(1), substituted ‘80 percent’ for ‘85 percent’.
Subsec. (b)(3)(C). Pub. L. 99-514, Sec. 411(b)(2)(C)(iv), inserted ‘and’ at end of cl. (i), redesignated cl. (iii) as (ii), and
struck out former cl. (ii) which read as follows: ‘$400,000 limitation for certain
exploration expenditures under section 617(h)(1), and’.
1984 - Subsec. (b)(3)(C). Pub. L. 98-369, Sec. 211(b)(3)(A), inserted ‘and’ at end of cl. (ii), struck out cl. (iii) which provided
for a $25,000 limitation on small business deduction of life insurance companies under
sections 804(a)(3) and 809(d)(10), and redesignated cl. (iv) as (iii).
Subsec. (b)(6). Pub. L. 98-369, Sec. 211(b)(3)(B), substituted ‘section 801’ for ‘section 802’.
1981 - Subsec. (b)(3)(C)(i). Pub. L. 97-34 struck out ‘$150,000’
before ‘minimum accumulated earnings credit’.
1976 - Subsec. (a)(2). Pub. L. 94-455, Sec. 1901(a)(34)(A), inserted ‘(15 U.S.C. 661 and following)' after ‘Small Business Investment Act of 1958’.
Subsec. (b)(1). Pub. L. 94-455, Sec. 1051(f)(1), inserted ‘either’ at end of subpar. (A), substituted a comma for a period
and inserted ‘or’ at end of subpar. (B), and added subpar.
(C).
Subsec. (b)(2), (3), (4). Pub. L. 94-455, title XIX, Sec. 1906(b)(13)(A), struck out ‘or his delegate’ after ‘Secretary’.
Subsec. (b)(2)(A). Pub. L. 94-455, Sec. 1901(a)(34)(B), struck out ‘(except that in the case of a taxable year of a member beginning
in 1963 and ending in 1964, if the election is effective for the taxable year of the
common parent corporation which includes the last day of such taxable year of such
member, such election shall be effective for such taxable year of such member, if
such member consents to such election with respect to such taxable year)’ after
‘with respect to which the election is made’.
Subsec. (b)(3)(B). Pub. L. 94-455, Sec. 1031(b)(2), substituted ‘election under section 901(a) (relating to allowance of foreign
tax credit)’ for ‘elections under section 901(a) (relating to allowance
of foreign tax credit) and section 904(b)(1) (relating to election of overall limitation)’.
Subsec. (b)(3)(C). Pub. L. 94-455, Sec. 1901(b)(1)(J)(ii),
(21)(A)(i), 1906(b)(3)(C)(ii), struck out cl. (ii) which set a $100,000 limitation
for exploration expenditures under section 615 (a) and
(b), redesignated former cls. (iii), (iv), and (v) as cls. (ii), (iii), and (iv),
respectively, and substituted ‘certain exploration expenditures under section
617(h)(1)’ for ‘exploration expenditures under sections 615(c)(1) and
617(h)(1)’ in cl. (ii) as so redesignated, ‘804(a)(3)’
for ‘804(a)(4)’ in cl. (iii) as so redesignated, and ‘section 6154(c)(2)
and section 6655(e)(2)’ for ‘sections 6154(c)(2) and (3) and sections
6655(e)(2) and (3)’ in cl. (iv) as so redesignated.
Subsec. (b)(5). Pub. L. 94-455, Sec. 1051(f)(2), inserted ‘, 1504(b)(4),’ after ‘sections 1504(b)(2)’.
1975 - Subsec. (b)(3)(C)(i). Pub. L. 94-12 substituted ‘$150,000’
for ‘$100,000’.
1969 - Subsec. (b)(3)(C)(iii). Pub. L. 91-172 substituted ‘sections 615(c)(1) and 617(h)(1)’ for ‘section 615(c)(1)’.
1968 - Subsec. (b)(3)(C)(v). Pub. L. 90-364 substituted ‘surtax exemption, and one amount under section 6154(c)(2) and
(3) and sections 6655(e)(2) and (3), for purposes of estimated tax payment requirements
under section 6154’ for ‘$100,000 exemption for purposes of estimated
tax filing requirements under section 6016’.
1964 - Subsec. (a). Pub. L. 88-272 substituted provisions permitting a deduction for 85 percent of dividends received
except that it shall be 100 percent when received by a small business investment company
operating under the Small Business Investment Act of 1958, and 100 percent in case
of qualifying dividends, for provisions permitting an 85 percent deduction for corporations
other than one operating under the Small Business Investment Act of 1958, and for
other than dividends described in section 244(1) of this title.
Subsec. (b). Pub. L. 88-272 added subsec. (b) and omitted a prior subsec.
(b) which allowed a 100 percent deduction of dividends received by a small business
investment company operating under the Small Business Investment Act of 1958, other
than dividends described in section 244(1) of this title.
Subsec. (c). Pub. L. 88-272 substituted ‘subsection (a)’ for ‘subsections
(a) and (b)’ and added par. (4).
Subsec. (d). Pub. L. 88-272 substituted ‘subsection (a)’ for ‘subsections
(a) and (b)’.
1960 - Subsec. (c)(3). Pub. L. 86-779, Sec. 10(g), added par. (3).
Subsec. (d). Pub. L. 86-779, Sec. 3(a), added subsec. (d).
1958 - Subsec. (a). Pub. L. 85-866, Sec. 57(b)(1), inserted ‘(other than a small business investment company operating under
the Small Business Investment Act of 1958)’.
Subsecs. (b), (c). Pub. L. 85-866, Sec. 57(b)(2),
(3), added subsec. (b), redesignated former subsec. (b) as (c), and substituted ‘subsections
(a) and (b)’ for ‘subsection (a)’.
EFFECTIVE DATE OF 2018 AMENDMENTS
Amendments by Pub. L. 115-141, Div. U, Sec. 401(d)(1)(D)(v), (xvii)(II), effective March 23, 2018.
Sec. 401(e) of Pub. L. 115-141, Div. U, provided the following Savings Provision:
“(e) General Savings Provision With Respect To Deadwood Provisions.—If—
“(1) any provision amended or repealed by the amendments made by subsection
(b) or (d)
applied to—
“(A) any transaction occurring before the date of the enactment of this Act,
“(B) any property acquired before such date of enactment, or
“(C) any item of income, loss, deduction, or credit taken into account before
such date of enactment, and
“(2) the treatment of such transaction, property, or item under such provision
would
(without regard to the amendments or repeals made by such subsection)
affect the liability for tax for periods ending after such date of enactment,
“nothing in the amendments or repeals made by this section shall be construed
to affect the treatment of such transaction, property, or item for purposes of determining
liability for tax for periods ending after such date of enactment.”
EFFECTIVE DATE OF 2017 AMENDMENTS
Amendments by Pub. L. 115-97, Sec. 13002(a), effective for taxable years beginning after December 31, 2017.
EFFECTIVE DATE OF 2014 AMENDMENTS
Amendments by Pub. L. 113-295, Div. A, Sec. 221(a)(41), effective on the date of the enactment of this Act [Enacted:
Dec. 19, 2014]. Pub. L. 113-295, Div. A, Sec. 221(a)(41)(K), provided that:
“(K) The amendments made by this paragraph shall not apply to preferred stock
issued before October 1, 1942 (determined in the same manner as under section 247
of the Internal Revenue Code of 1986 as in effect before its repeal by such amendments).”
Section 221(b)(2) of Pub. L. 113-295, Div. A, provided the following Savings Provision:
“(2)
SAVINGS PROVISION.—If—
“(A)
any provision amended or repealed by the amendments made by this section applied to—
“(i)
any transaction occurring before the date of the enactment of this Act [Enacted: Dec.
19, 2014],
“(ii)
any property acquired before such date of enactment, or
“(iii)
any item of income, loss, deduction, or credit taken into account before such date
of enactment, and
“(B)
the treatment of such transaction, property, or item under such provision would (without
regard to the amendments or repeals made by this section)
affect the liability for tax for periods ending after date of enactment, nothing in
the amendments or repeals made by this section shall be construed to affect the treatment
of such transaction, property, or item for purposes of determining liability for tax
for periods ending after such date of enactment.”
EFFECTIVE DATE OF 1996 AMENDMENTS
Amendment by Pub. L. 104-188 effective, except as otherwise provided, as if included in the provision of the Revenue
Reconciliation Act of 1990 to which such amendment relates.
EFFECTIVE DATE OF 1990 AMENDMENTS
Section 11814(c) of Pub. L. 101-508 provided that:
‘(1) In general. - The amendments made by this section (amending this section
and section 1504 of this title) shall apply to taxable years beginning after December
31, 1990.
‘(2) Treatment of old elections. - For purposes of section 243(b)(3) of the
Internal Revenue Code of 1986 (as amended by subsection (a)), any reference to an election under such section
shall be treated as including a reference to an election under section 243(b) of such
Code (as in effect on the day before the date of the enactment of this Act (Nov. 5,
1990)).’
EFFECTIVE DATE OF 1988 AMENDMENTS
Amendment by Pub. L. 100-647 effective, except as otherwise provided, as if included in the provision of the Tax
Reform Act of 1986, Pub. L. 99-514, to which such amendment relates, see section 1019(a) of Pub. L. 100-647, set out as a note under section 1 of this title.
EFFECTIVE DATE OF 1987 AMENDMENTS
Section 10221(e) of Pub. L. 100-203, as amended by Pub. L. 100-647, title II, Sec. 2004(i)(1), Nov. 10, 1988, 102 Stat. 3603, provided that:
‘(1) In general. - Except as provided in paragraph
(2), the amendments made by this section (amending this section and sections 244 to
246A, 805, 854, and 861 of this title) shall apply to dividends received or accrued
after December 31, 1987, in taxable years ending after such date.
‘(2) Amendments relating to limitations. - The amendments made by subsection
(c) (amending sections 246 and 805 of this title) shall apply to taxable years beginning
after December 31, 1987.’
EFFECTIVE DATE OF 1986 AMENDMENTS
Amendment by section 411(b)(2)(C)(iv) of Pub. L. 99-514 applicable, except as otherwise provided, to costs paid or incurred after Dec. 31,
1986, in taxable years ending after such date, see section 411(c) of Pub. L. 99-514 set out as a note under section 263 of this title.
Amendment by section 611(a)(1) of Pub. L. 99-514 applicable to dividends received or accrued after Dec. 31, 1986, in taxable years
ending after such date, see section 611(b) of Pub. L. 99-514, set out as a note under section 246 of this title.
EFFECTIVE DATE OF 1984 AMENDMENTS
Amendment by Pub. L. 98-369 applicable to taxable years beginning after Dec. 31, 1983, see section 215 of Pub. L. 98-369, set out as an Effective Date note under section 801 of this title.
EFFECTIVE DATE OF 1981 AMENDMENT
Amendment by Pub. L. 97-34 applicable to taxable years beginning after Dec. 31, 1981, see section 232(c) of
Pub. L. 97-34, set out as a note under section 535 of this title.
EFFECTIVE DATE OF 1976 AMENDMENT
For effective date of amendment by section 1031(b)(2)
of Pub. L. 94-455, see section 1031(c) of Pub. L. 94-455, set out as a note set out under section 904 of this title.
For effective date of amendment by section 1051(f)(1),
(2) of Pub. L. 94-455, see section 1051(i) of Pub. L. 94-455, set out as a note under section 27 of this title.
Amendment by section 1901(a)(34), (b)(1), (21)
of Pub. L. 94-455 effective for taxable years beginning after Dec. 31, 1976, see section 1901(d)
of Pub. L. 94-455, set out as a note under section 2 of this title.
For effective date of amendment by section 1906(b)(3)(C)(ii)
of Pub. L. 94-455, see section 1906(d) of Pub. L. 94-455, set out as a note under section 6013 of this title.
EFFECTIVE DATE OF 1975 AMENDMENTS
Amendment by Pub. L. 94-12 applicable to taxable years beginning after Dec. 31, 1974, see section 305(c) of
Pub. L. 94-12, set out as a note under section 535 of this title.
EFFECTIVE DATE OF 1969 AMENDMENTS
Section 504(d) of Pub. L. 91-172, as amended by Pub. L. 99-514, Sec. 2, Oct. 22, 1986, 100 Stat. 2095, provided that:
‘(1) In general. - The amendments made by this section (amending this section
and sections 381, 615, 617, 703, and 1016 of this title) shall apply with respect
to exploration expenditures paid or incurred after December 31, 1969.
‘(2) Presumption of election under section 617.
- For purposes of section 617 of the Internal Revenue Code of 1986
(formerly I.R.C. 1954), an election under section 615(e) of such Code, which is effective with respect
to exploration expenditures paid or incurred before January 1, 1970, shall be treated
as an election under section 617(a) of such Code with respect to exploration expenditures
paid or incurred after December 31, 1969. The preceding sentence shall not apply to
any taxpayer who notifies the Secretary of the Treasury or his delegate (at such time
and in such manner as the Secretary or his delegate prescribes by regulations) that
he does not desire his election under section 615(e) to be so treated.'
EFFECTIVE DATE OF 1968 AMENDMENTS
Section 103(f) of Pub. L. 90-364 provided that: ‘Except as provided by section 104 (formerly set out as notes
under sections 51 and 6154 of this title), the amendments made by this section (enacting
section 6425, amending this section and sections 6020, 6154, 6651, 6655, 7203, and
7701, and repealing sections 6016 and 6074 of this title) shall apply with respect
to taxable years beginning after December 31, 1967.’
EFFECTIVE DATE OF 1964 AMENDMENTS
Section 214(c) of Pub. L. 88-272 provided that: ‘The amendments made by subsections (a) (amending this section)
and (b) (amending sections 244, 246, 804, and 809 of this title) shall apply with
respect to dividends received in taxable years ending after December 31, 1963.’
EFFECTIVE DATE OF 1960 AMENDMENTS
Section 3(c) of Pub. L. 86-779 provided that: ‘The amendments made by subsections (a) and (b) (amending this
section and section 861 of this title) shall apply to dividends received after December
31, 1959, in taxable years ending after such date.’
Amendment by section 10(g) of Pub. L. 86-779 applicable with respect to taxable years of real estate investment trusts beginning
after Dec. 31, 1960, see section 10(k) of Pub. L. 86-779, set out as an Effective Date note under section 856 of this title.
EFFECTIVE DATE OF 1958 AMENDMENTS
Section 57(d) of Pub. L. 85-866 provided that: ‘The amendments made by this section (enacting sections 1242
and 1243 and amending this section and sections 165 and 246 of this title) shall apply
with respect to taxable years beginning after the date of the enactment of this Act
(Sept. 2, 1958).’
SAVINGS PROVISION
For provisions that nothing in amendment by Pub. L. 101-508 be construed to affect treatment of certain transactions occurring, property acquired,
or items of income, loss, deduction, or credit taken into account prior to Nov. 5,
1990, for purposes of determining liability for tax for periods ending after Nov.
5, 1990, see section 11821(b) of Pub. L. 101-508, set out as a note under section 29 of this title.
