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107 STAT. 488 PUBLIC LAW 103-66—AUG. 10, 1993 (A) IN GENERAL.—^Except aa otherwise provided in this paragraph, the amendments made by this subsection shall apply to stock transferred after December 31, 1994, in satisfaction of any indebtedness. (B) EXCEPTION FOR TITLE ii CASES.—The amendments made by this subsection shall not apply to stock transferred in satisfaction of any indebtedness if such transfer is in a title 11 or similar case (as defined in section 368(aX3XA) of the Internal Revenue Code of 1986) which was filed on or before December 31,1993. (b) TAX ATTRIBUTES SUBJECT TO REDUCTION.— 26USC108. (1) MINIMUM TAX CREDIT.—Section 108(bX2) (relating to tax attributes affected; order of reduction) is amended by redesignating subparagraphs (C), (D), and (E) as subparagraphs (D), (E), and (F) and by adding after subparagraph (B) the following new subparagraph: "(C) MINIMUM TAX CREDIT.—The amount of the mini- mum tax credit available under section 53(b) as of the beginning of the taxable year immediately following the taxable year of the discharge." (2) PASSIVE ACTIYITY LOSSES AND CREDITS.—Section 108(b)(2), as amended by paragraph (1), is amended by redesignating subparagraph (F) as subparagraph (G) and by adding after subparagraph (E) the following new subparagraph: "(F) PASSIVE ACTIVITY LOSS AND CREDIT CARRYOVERS.— Any passive activity loss or credit carryover of the taxpayer under section 469<b) from the teixable year of the dis- charge." (3) CONFORMING AMENDMENTS.— (A) Subparagraph (B) of section 108(bX3) is amended to read as follows: "(B) CREDIT CARRYOVER REDUCTION.—The reductions described in subparagraphs (B), (C), and (G) shall be 33 Vs cents for each dollar excluded by subsection (a). The reduc- tion described in subparagraph (F) in any passive activity credit carryover shall be 33 Vs cents for each dollar excluded by subsection (a)." (B) Subparagraph (B) of section 108(bX4) is amended by striking "(C)" in the text and heading thereof and insert- ing "(D)". (C) Subparagraph (C) of section 108(bX4) is amended by striking "(E)" in the text and heading thereof and insert- ing "(G)". (D) Subparagraph (B) of section 108(gX3) is amended— (i) by striking "subparagraphs (A), (B), (C), and (E)" and inserting "subparagraphs (A), (B), (C), (D), (F),and(G)'', (ii) by striking "subparagraphs (B) and (E)" and inserting "subparagraphs (B), (C), and (G)", and (iii) by inserting before the period at the end the following: "and the attribute described in subparagraph (F) of subsection (bX2) to the extent attributable to £uiy passive activitycredit carryover". 26 use 108 note. (4) EFFECTIVE DATE.—The amendments made by this sub- section shall apply to discharges of indebtedness in taxable years beginning after December 31,1993.