102 STAT. 3450

PUBLIC LAW 100-647—NOV. 10, 1988

"(i) DEPOSIT MAY NOT BE FEDERALLY INSURED.—No
election may be made under subparagraph (A) with
respect to any loss on a deposit in a qualified financial
institution if part or all of such deposit is insured under
Federal law.

Banks and "(ii) DOLLAR LIMITATION.—With respect to each finan-

banking. ciai institution, the aggregate amount of losses attrib-

utable to deposits in such financial institution to which
an election under subparagraph (A) may be made by
the taxpayer for any taxable year shall not exceed
$20,000 ($10,000 in the case of a separate return by a
married individual). The limitation of the preceding
sentence shall be reduced by the amount of any insur-
ance proceeds under any State law which can reason-
ably be expected to be received with respect to losses on
deposits in such institution.

"(6) ELECTION.—Any election by the taxpayer under this
subsection for any taxable year—

"(A) shall apply to all losses for such taxable year of the
taxpayer on deposits in the institution with respect to
which such election was made, and

"(B) may be revoked only with the consent of the
Secretary.'

26 USC 451 note. (2) Paragraph (1) of section 905(c) of the Reform Act is

amended to read as follows:

"(1) IN GENERAL.—-The amendment made by subsection (a)
shall apply to taxable years beginning after December 31,1981,
and, except as provided in paragraph (2), the amendment made
by subsection (b) shall apply to taxable years beginning after
December 31,1982."

(3) The subsection (f) of section 451 of the 1986 Code which
was added by section 905(b) of the 1986 Reform Act is redesig-
nated as subsection (g).

26 USC 165 note. (4) If on the date of the enactment of this Act (or at any time

before the date 1 year after such date of enactment) credit or
refund of any overpayment of tax attributable to amendments
made by section 905 of the Reform Act or by this subsection (or
the assessment of any underpayment of tax so attributable) is
barred by any law or rule of law—

(A) credit or refund of any such overpayment may never-
theless be made if claim therefore is filed before the date 1
year after such date of enactment, and

(B) assessment of any such underpayment may neverthe-
less be made if made before the date 1 year after such date
of enactment.

SEC. 1010. AMENDMENTS RELATED TO TITLE X OF THE REFORM ACT.

(a) AMENDMENTS RELATED TO SECTION 1011 OF THE REFORM ACT.—
(1) Paragraph (1) of section 813(a) of the 1986 Code (relating to
foreign life insurance companies) is amended by striking out
"the special life insurance company deduction and".

26 USC 801 note. (2) Paragraph (1) of section 1011(d) of the Reform Act is

amended—

(A) by striking out "any bond*' and inserting in lieu
thereof "any market discount bond (as defined in section
1278 of the Internal Revenue Code of 1986)",