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TITLE 26-INTERNAL REVENUE CODE8 treated, as having made an election with re- spect to such aircraft or vessel. (Aug. 16, 1954, ch. 736, 68A Stat. 275; Sept. 14, 1960, Pub, L. 86-779, § 3(b), 74 Stat. 998; Oct. 16, 1962, Pub. L. 87-834, § 9(c), 76 Stat, 1001; Nov. 13, 1963, Pub. L. 89-809, title I, § 102(a)(1)-(3), (b), (c), 80 Stat. 1541-1543; Dec. 30, 1969, Pub. L. 91-172, title IV, § 435(a), 83 Stat. 625; Apr. 1, 1971, Pub. L. 92-9, § 3(a)(2), 85 Stat. 15; Dec. 10, 1971, Pub. L. 92-178, title III, § 314(a), title V, § 503, 85 Stat. 528, 550; Jan. 3, 1975, Pub. L. 93- 625, §§ 8, 9(a), 88 Stat. 2116; Oct. 4, 1976, Pub. L. 94-455, title X, §§ 1036(a), 1041, 1051(h)(3), title XIX, §§ 1901(b)(26)(A), (B), (c)(7), 1904(b)(10)(B), 1906(b)(13)(A), 90 Stat. 1633, 1634, 1647, 1798, 1803, 1817, 1834.) AMENDMENTS 1976-Subsec. (a)(1). Pub. L. 94-455, §§ 1901(c)(7), 1904(b)(10)(B), struck out ", any Territory, any politi- cal subdivision of a Territory," following "United States" in the provisions preceding subpar. (A) and, in subpar. (G), substituted "subsection (c) of section 4912 (as in effect before July 1, 1974)" for "section 4912(c)" and "subsection (c)(2) of such section" for "section 4912(c)(2)". Subsec. (a)(2)(A), Pub, L. 94-455, §§ 1051(h)(3), 1906(b)(13)(A), substituted "other than a corporation ,,hich has an election in effect under section 936" for "other than a corporation entitled to the benefits of section 931" and struck out "or his delegate" following "Secretary". Subsec. (a)(2)(D). Pub. L. 94-455, § 1906(b)(13)(A), struck out "or his delegate" following "Secretary". Subsec. (a)(5), (6). Pub. L. 94-455, § 1901(b)(26)(A), substituted "sale or exchange" for "sale" in headings and text. Subsec. (a)(7). Pub. L. 94-455, § 1036(a), added subsec. (a)(7). Subsec. (c)(3). Pub. L. 94-455, § 1041, struck out pro- vision that subsec. (a)(1)(A) and (c) would cease to apply effective with respect to amounts paid or cred- ited after Dec. 31, 1976. Subsec. (e)(l). Pub. L. 94-455, § 1901(b)(26)(B), sub- stituted "sale, exchange, or other disposition" for "sale or other disposition". Subsecs. (e)(2), (3). Pub, L. 94-455, § 1906(b)(13)(A), struck out or his delegate" following "Secretary". 1975-Subsec. (a)(1)(H). Pub. L. 93-625, § 9(a), added subpar. (H). Subsec. (c)(3). Pub. L. 93-625, § 8, substituted "1976" for "1975". 1971-Subsec. (a)(1)(G). Pub. L. 92-9 added subpar. (G). Subsec. (a)(2)(D). Pub. L. 92-178s § 503, added subpar. (D). Subsec. (el. Pub. L. 92-178, § 314(a), added subsec. (e). 1969-Subset, (a)(1). Pub. L. 91-172, §435(a)(1), struck out "after December 31, 1972," following "inter- est paid or credited" in parenthetical material follow- ing "interest received from a foreign corporation" in subpars. (C) and (D). Subsec. (c)(3). Pub. L. 91-172, § 435(a)(2), substituted "1975" for "1972". 1966-Subsec. (a)(1)(A). Pub. L. 89-809, § 102(a)(1)(A), substituted "interest on amounts de- scribed in subsection (c) received by a nonresident alien individual or a foreign corporation, if such inter- est is not effectively connected with the conduct of a trade or business within the United States" for "inter- est on deposits with persons carrying on the banking business paid to persons not engaged in business within the United States". Subsec. (a)(1)(B). Pub. L. 89-809, § 102(a)(2), elimi- nated interest received from a resident foreign corpo- ration, and substituted "gross income from all sources of such individual or such corporation" for "gross income of such resident payor or domestic corpora- tion", and "taxable year of such individual or such corporation" for "taxable year of such payor". Subsec. (a)(1)(C). Pub. L. 89-809, § 102(a)(2), added subsec. (a)(1)(C), and redesignated former subsec. (a)(1)(C) as (a)(1)(E). Subsec. (a)(1)(D). Pub. L. 89-809, § 102(a)(2), added subsec. (a)(1)(D). Subsec. (a)(1)(E). Pub. L. 89-809, § 102(a)(2), redesig- nated former subsec. (a)(1)(C) as (a)(1)(E). Subsec. (a)(1)(F). Pub. L. 89-809, § 102(a)(2), added subsec. (a)(1)(F). Subsec. (a)(2)(B). Pub. L. 89-809, § 102(b), substitut- ed "50 percent of the gross income from all sources" * for "50 percent of the gross income", "effectively con- nected with the conduct of a trade or business within the United States" for "derived from sources within the United States as determined from the provisions of this part", and "ratio to such dividends as the gross income of the corporation for such period which was effectively connected with the conduct of a trade or business within the United States bears to its gross income from all sources" for "ratio to such dividends as the gross income of the corporation for such period derived from sources within the United States bears to its gross income from all sources" and inserted "(other than dividends for which a deduction is allowable under section 245(b))" after "dividends" and "(and only to the extent)" after "extent". Subsec. (a)(3)(C)(Hi). Pub. L. 89-809, § 102(c), inserted "an individual who is a citizen or resident of the United States, a domestic partnership, or" before "a domestic corporation" and "individual, partnership, or" after "United States by such". Subsec. (c). Pub. L. 89-809, § 102(a)(1)(B), added subsec. (c). Subsec. (d). Pub. L. 89-809, § 102(a)(3), added subsec. (d). 1962-Subsec. (a)(2)(B). Pub. L. 87-834 substituted "to the extent exceeding the amount which is 100/ 85ths of the amount of the deduction allowable under section 245 in respect of such dividends" for "to the extent exceeding the amount of the deduction allowa- ble under section 245 in respect of such dividends." 1960-Subsec. (a)(2)(C). Pub. L. 86-779 added subpar. (C). EFFECTIVE DATE OF 1976 AMENDMENT Section 1036(c) of Pub. L. 94-455 provided that: "The amendments made by this section [enacting subsec. (a)(7) of this section and section 862(a)(7) of this title] shall apply to taxable years beginning after December 31, 1976." For effective date of amendment of subsec. (a)(2)(A) by section 1051(h)(3) of Pub. L. 94-455, see section 1051(0)(1) of Pub. L. 94-455, set out as an Effective Date of 1976 Amendment note under section 33 of this title. Amendment of subsecs. (a)(1), (5). (6), (e)(1) by sec- tion 1901(b)(26)(A), (B), (c)(7) of Pub. L. 94-455 effec- tive for taxable years beginning after Dec. 31, 1976, see section 1901(d) of Pub. L. 94-455, set out as an Effec- tive Date of 1976 Amendment note under section 2 of this title. Amendment of subsec. (a)(1) by section 1904(b)(10)(B) of Pub. L. 94-455 effective on the first day of the first month which begins more than 90 days after the date of the enactment of this Act [Oct. 4, 19761, see section 1904(d) of Pub. L. 94-455, set out as an Effective Date of 1976 Amendment note under section 4041 of this title. EFFECTIVE DATE OF 1975 AMENDMENT Section 9(c) of Pub. L. 93-625 provided that: "The amendment made by subsection (a) [to this section] applies to interest paid after the date of enactment of this Act [Jan. 3, 19751, and the amendment made by subsection (b) [to section 2104(c) of this title] applies with respect to estates of decedents dying after such date." Page 557 § 861