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PUBLIC LAW 103-66—AUG. 10, 1993 107 STAT. 467 **(B) SECTION 305(e).—^This subsection shall not apply to the holder of the dividend rights which were separatea from any stripped preferred stock to which section 305(e)(1) applies. (3) EFFECTIVE DATE.—The amendments made by this sub- 26 use i67 note. section shall take effect on April 30,1993. (d) TREATMENT OF CAPITAL GAIN UNDER LIMITATION ON INVEST- MENT INTEREST.— (1) IN GENERAL.—Subparagraph (B) of section 163(dX4) 26 use 163. (defining investment income) is amended to read as follows: "(B) INVESTMENT INCOME.—The term 'investment income' means the siun of— "(i) gross income from property held for investment (other than any gain taken into account under clause (iiXD), **(ii) the excess (if any) of— "(1) the net gain attributable to the disposition of property held for investment, over "(II) the net capital gain determined by only taking into account gains and losses from disposi- tions of property held for investment, plus "(iii) so much of the net capital gain referred to in clause (iiXH) (or, if lesser, the net gain referred to in clause (iiXI)) as the taxpayer elects to take into accoimt under this clause." (2) COORDINATION WITH SPECIAL CAPITAL GAINS RATE.— Subsection (h) of section 1 is amended by adding at the end the following new sentence: "For purposes of the preceding sentence, the net capital gain for any taxable year shall be reduced (but not below zero) by the amount which the taxpayer elects to take into accoimt as investment income for the taxable year under section 163(dX4XBXiii).'' (3) EFFECTIVE DATE.—The amendments made by this sub- 26 use 1 note. section shall apply to taxable years beginning after December 31.1992. (e) TREATMENT OF CERTAIN APPRECIATED INVENTORY.— (1) IN GENERAL.—Paragraph (1) of section 751(d) is amended to read as follows: "(1) SUBSTANTIAL APPRECIATION.— "(A) IN GENERAL.—Inventory items of the partnership shall be considered to have appreciated substantially in value if their fair market value exceeds 120 percent of the adjusted basis to the partnership of such property. "(B) CERTAIN PROPERTY EXCLUDED.—For purposes of subparagraph (A), there shall be excluded any inventory property if a principal purpose for acquiring such property was to avoid the provisions of this section relating to inven- tory items." (2) EFFECTIVE DATE.—^The amendment made by paragraph 26 use 751 note. (1) shall apply to sales, exchanges, and distributions after April 30.1993. Subpart B—Other Provisions SEC. 13207. REPEAL OF LIMITATION ON AMOUNT OF WAGES SUBJECT TO HEALTH INSURANCE EMPLOYMENT TAX. (a) HOSPITAL INSURANCE TAX.—