102 STAT. 3398

PUBLIC LAW 100-647—NOV. 10, 1988

to qualified workouts) shall apply to such debt restruc-
turing."
26 USC 382 note.	(13) Subparagraph (D) of section 621(1X2) of the Reform Act is
amended—
 (A)	by striking out "or reorganization", and
 (B)	by adding at the end thereof the following new sen-
tence: "For purposes of the preceding sentence, in applying
section 382 (as so in effect), if a person has a warrant to
acquire stock, such stock shall be considered as owned by
such person/'
(14)	Section 621(fX3) of the Reform Act is amended by striking
out "after December 31,1986".
(15)	Paragraph (4) of section 621(0 of the Reform Act is
amended by striking out the last sentence and inserting in lieu
thereof the following:
"Any regulations prescribed under section 382 of the Internal
Revenue Code of 1986 (as added by subsection (a)) which have
the effect of treating a group of shareholders as a separate
5-percent shareholder by reason of a public offering shall not
apply to any public offering before January 1, 1989, for the
benefit of institutions described in section 591 of such Code.
Unless the corporation otherwise elects, an underwriter of any
offering of stock in a corporation before September 19, 1986
(January 1, 1989, in the case of an offering for the benefit of an
institution described in the preceding sentence), shall not be
treated as acquiring any stock of such corporation by reason of a
firm commitment underwriting to the extent the stock is dis-
posed of pursuant to the offering (but in no event later than 60
days after the initial offering)."
(16)	Subparagraph (A) of section 621(fX7) of the Reform Act is
amended by striking out "the parent corporation referred to in
section 203(dX13XB)" and inserting in lieu thereof "a parent
corporation incorporated in March 1980 under the laws of
Delaware".
(17XA) Subsection (e) of section 382 of the 1986 Code is
amended by adding at the end thereof the following new
paragraph:
"(3) treatment of foreign corporations.—Except as other-
wise provided in regulations, in determining the value of any
old loss corporation which is a foreign corporation, there shall
be taken into account only items treated as connected with the
conduct of a trade or business in the United States."
26 USC 382 note.	(B) The amendment made by Subparagraph (A) shall apply to
any ownership change after June 10, 1987. For purposes of the
preceding sentence, any equity structure shift pursuant to a
plan of reorganization adopted on or before June 10, 1987, shall
be treated as occurring when such plan was adopted.
(18) Subparagraph (C) of section 382(1X5) of the 1986 Code is
amended to read as follows:
"(C) reduction of tax attributes where discharge of
INDEBTEDNESS.—
"(i) in general.—In any case to which Subparagraph
(A) applies, 50 percent of the amount which, but for the
application of section 108(eX10XB), would have been
applied to reduce tax attributes under section 108(b)
shall be so applied.