102 STAT. 3426 PUBLIC LAW 100-647—NOV. 10,1988

graph (B)) for any taxable year beginning before January 1,
1989.

(17) Subparagraph (B) of section 860E(cX2) of the 1986 Code is
amended—

(A) by inserting "(adjusted for contributions)" after
"residual interest" the second place it appears, and

(B) by striking "decreased by" in clause (ii) and inserting
in lieu thereof "decreased (but not below zero) by".

(18XA) Subsection (e) of section 860F of the 1986 Code is
amended by adding at the end thereof the following new sen-
tences: "Such return shall be filed by the REMIC. The deter-
mination of who may sign such return shall be made without
regard to the first sentence of this subsection."

26 USC 860F (B) Unless the EEMIC otherwise elects, the amendment made

note. by subparagraph (A) shall not apply to any REMIC where the

start-up day (as defined in section 860G(a)(9) of the 1986 Code as

in effect on the day before the date of the enactment of this Act)

is before the date of the enactment of this Act.

(19) Subsection (a) of section 860D of the 1986 Code is amended
by adding at the end thereof the following new sentence:

"In the case of a qualified liquidation (as defined in section
860F(aX4XA)), paragraph (4) shall not apply during the liquidation
period (as defined in section 860F(aX4XB).

(20) Subsection (a) of section 860A of the 1986 Code is
amended by striking out "this chapter" each place it appears
and inserting in lieu thereof "this subtitle".

(21) Paragraph (1) of section 860C(b) of the 1986 Code is
amended by striking out "and in the same manner" and insert-
ing in lieu thereof "and, except as provided in regulations, in
the same manner".

(22) The following sections of the 1986 Code are each amended
by striking out "real estate mortgage pool" and inserting in lieu
thereof "REMIC":

(A) Section 382(lX4XBXii).

(B) Section 860F(aX2XAXiii).

(C) Section 860F(aX2XC).

(D) Section 860F(bXlXCXii).

(E) Section 860F(bXlXDXii).

(23) Subsection (d) of section 860E of the 1986 Code is amended
by adding at the end thereof the following new sentence:

"Rules similar to the rules of the preceding sentence shall apply also
in the case of regulated investment companies, common trust funds,
and organizations to which part I of subchapter T applies."

(24) Subparagraph (C) of section 6049(dX7) of the 1986 Code is
amended by striking out "the issue price" and inserting in lieu
thereof "the adjusted issue price".

(25XA) Paragraph (19) of section 7701(a) of the 1986 Code is
amended by adding at the end thereof the following new sen-
tence: "For purposes of determining whether any interest in a
REMIC qualifies under clause (xi), any regular interest in an-
other REMIC held by such REMIC shall be treated as a loan
described in a preceding clause under principles similar to the
principles of clause (xi); except that, if such REMIC's are part of
a tiered structure, they shall be treated as 1 REMIC for pur-
poses of clause (xi)."

(B) Paragraph (4) of section 593(d) of the 1986 Code is amended
by adding at the end thereof the following new sentence: "For