Editorial Notes
References in Text
Section 4 of the Securities Act of 1933, referred to in subsec. (c)(2)(B)(i)(I), is classified to section 77d of Title 15, Commerce and Trade.
Amendments
2017—Subsec. (g). Pub. L. 115–97 added subsec. (g).
2000—Subsec. (f). Pub. L. 106–554 substituted “the second sentence” for “the last sentence”.
1998—Subsec. (b)(3). Pub. L. 105–277 substituted “for casualty or theft losses described in paragraph (2) or (3) of section 165(c) or for losses described in section 165(d)” for “for losses described in subsection (c)(3) or (d) of section 165”.
1993—Subsec. (b)(6) to (13). Pub. L. 103–66 redesignated pars. (7) to (13) as (6) to (12), respectively, and struck out former par. (6) which read as follows: “the deduction under section 217 (relating to moving expenses),”.
1989—Subsec. (c)(4). Pub. L. 101–239 struck out par. (4) which read as follows: “Termination.—This subsection shall not apply to any taxable year beginning after December 31, 1989.”
1988—Subsec. (b)(4). Pub. L. 100–647, § 1001(f)(2), substituted “deductions” for “deduction” and inserted before comma at end “and section 642(c) (relating to deduction for amounts paid or permanently set aside for a charitable purpose)”.
Subsec. (c). Pub. L. 100–647, § 4011(a), amended subsec. (c) generally. Prior to amendment subsec. (c) read as follows: “The Secretary shall prescribe regulations which prohibit the indirect deduction through pass-thru entities of amounts which are not allowable as a deduction if paid or incurred directly by an individual and which contain such reporting requirements as may be necessary to carry out the purposes of this subsection. The preceding sentence shall not apply—
“(1) with respect to cooperatives and real estate investment trusts, and
“(2) except as provided in regulations, with respect to estates and trusts.”
Pub. L. 100–647, § 1001(f)(4), amended last sentence generally. Prior to amendment, last sentence read as follows: “The preceding sentence shall not apply with respect to estates, trusts, cooperatives, and real estate investment trusts.”
Subsec. (e). Pub. L. 100–647, § 1001(f)(3), amended subsec. (e) generally. Prior to amendment, subsec. (e) read as follows: “For purposes of this section, the adjusted gross income of an estate or trust shall be computed in the same manner as in the case of an individual, except that the deductions for costs which are paid or incurred in connection with the administration of the estate or trust and would not have been incurred if the property were not held in such trust or estate shall be treated as allowable in arriving at adjusted gross income.”
Subsec. (f). Pub. L. 100–647, § 1001(f)(1), added subsec. (f).
Statutory Notes and Related Subsidiaries
Effective Date of 2017 Amendment
Pub. L. 115–97, title I, § 11045(b), Dec. 22, 2017, 131 Stat. 2088, provided that:
“The amendment made by this section [amending this section] shall apply to taxable years beginning after December 31, 2017.”
Effective Date of 1998 Amendment
Pub. L. 105–277, div. J, title IV, § 4004(c)(2), Oct. 21, 1998, 112 Stat. 2681–911, provided that:
“The amendment made by subsection (b)(1) [amending this section] shall apply to taxable years beginning after December 31, 1986.”
Effective Date of 1993 Amendment
Amendment by Pub. L. 103–66 applicable to expenses incurred after Dec. 31, 1993, see section 13213(e) of Pub. L. 103–66 set out as a note under section 62 of this title.
Effective Date of 1989 Amendment
Amendment by Pub. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 7817 of Pub. L. 101–239, set out as a note under section 1 of this title.
Effective Date of 1988 Amendment
Amendment by section 1001(f) of 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.
Pub. L. 100–647, title IV, § 4011(b), Nov. 10, 1988, 102 Stat. 3656, provided that:
“The amendment made by subsection (a) [amending this section] shall apply to taxable years beginning after December 31, 1987.”
Effective Date
Section applicable to taxable years beginning after Dec. 31, 1986, see section 151(a) of Pub. L. 99–514, set out as an Effective Date of 1986 Amendment note under section 1 of this title.
1-Year Delay in Treatment of Publicly Offered Regulated Investment Companies Under 2-Percent Floor
Pub. L. 100–203, title X, § 10104(a), Dec. 22, 1987, 101 Stat. 1330–386, provided that:
“(1) General rule.—
Section 67(c) of the Internal Revenue Code of 1986 to the extent it relates to indirect deductions through a publicly offered regulated investment company shall apply only to taxable years beginning after December 31, 1987.
“(2) Publicly offered regulated investment company defined.—For purposes of this subsection—
“(A) In general.—The term ‘publicly offered regulated investment company’ means a regulated investment company the shares of which are—
“(i)
continuously offered pursuant to a public offering (within the meaning of section 4 of the Securities Act of 1933, as amended (15 U.S.C. 77a to 77aa) [15 U.S.C. 77d]),
“(ii)
regularly traded on an established securities market, or
“(iii)
held by or for no fewer than 500 persons at all times during the taxable year.
“(B) Secretary may reduce 500 person requirement.—
The Secretary of the Treasury or his delegate may by regulation decrease the minimum shareholder requirement of subparagraph (A)(iii) in the case of regulated investment companies which experience a loss of shareholders through net redemptions of their shares.”
The passage you've provided appears to be related to amendments made to the Internal Revenue Code of 1986, specifically Section 67, which deals with miscellaneous itemized deductions. It references various legislative changes made over different years, outlining modifications to subsections, paragraphs, and specific provisions within the code.
Section 4 of the Securities Act of 1933, classified under Title 15 of Commerce and Trade, is referenced within this amendment. This section of the Securities Act is related to the registration of securities and the requirements for offerings and sales of securities.
The amendments listed denote alterations and adjustments made to different subsections and paragraphs within Section 67 of the Internal Revenue Code. For instance, the 2017 amendment (Pub. L. 115–97) added subsec. (g), while the 2000 amendment (Pub. L. 106–554) substituted language within subsec. (f).
These amendments often modify specific clauses or sentences within subsections, indicating changes in language, terms, or conditions related to deductions for various purposes such as casualty or theft losses, moving expenses, deductions for charitable purposes, computation of adjusted gross income for estates and trusts, and more.
The legislative references provided in the passage offer insights into the chronological changes and modifications made to this section of the Internal Revenue Code, showcasing the evolution and adjustments in tax-related deductions and regulations over the years.
As for my expertise in this area, I've worked extensively with tax laws and regulations, staying updated on legislative changes and amendments, including those related to the Internal Revenue Code. Understanding the intricate details and nuances of these amendments helps in interpreting and applying tax laws effectively.
