PUBLIC LAW 100-647—NOV. 10, 1988

102 STAT. 3575

"(ID as deductions allowable in computing unre-
lated business taxable income, such holder's pro
rata share of the items of deduction described in
clause (iiXID of such organization.
Such amounts shall be taken into account for the
taxable year of the holder in which (or with which) the
taxable year of such organization ends.

"(ii) DESCRIPTION OF AMOUNTS.—For purposes of
clause (i)—

"(I) gross income is described in this clause to the
extent such income would (but for this paragraph)
be treated under subsection (a) as derived from an
unrelated trade or business, and

"(II) any deduction is described in this clause to
the extent it would (but for this paragraph) be
allowable under subsection (aX2) in computing un-
related business taxable income,
"(iii) DISQUALIFIED HOLDER.—For purposes of this
subparagraph, the term 'disqualified holder' means any
shareholder (or beneficiary) which is not described in
clause (i) or (ii) of subparagraph (C)."

(B) The amendment made by subparagraph (A) shall apply 26 USC 514 note,
with respect to interests in the organization acquired after June
10, 1987, except that such amendment shall not apply to any
such interest acquired after June 10, 1987, pursuant to a bind-
ing written contract in effect on June 10,1987, and at all times
thereafter before such acquisition.

(6) The last sentence of section 514(cX9XB) of the 1986 Code is
amended by striking out "clause (vi)" and inserting in lieu
thereof "this paragraph".

(b) REPEAL OF SECTION 1608 OF THE REFORM ACT.—Section 1608 of
the Reform Act is hereby repealed. 26 USC 170 note.

SEC. 1017. AMENDMENTS RELATED TO TITLE XVII OF THE REFORM ACT.

(a) AMENDMENTS RELATED TO SECTION 1701 OF THE REFORM ACT.—
Clause (i) of section 51(dX12XB) of the 1986 Code is amended by
striking out "subsection (aXl)" and inserting in lieu thereof "subsec-
tion (af.

(b) AMENDMENT RELATED TO SECTION 1702 OF THE REFORM ACT.—
Subsection (j) of section 6652 of the 1986 Code, as added by section
1702(b) of the Reform Act and as in effect before its repeal by the
Revenue Act of 1987, is amended by inserting "(and the correspond-
ing provision of section 4041(dXD)" after "section 4041(aXD".

(c) AMENDMENTS RELATED TO SECTION 1703 OF THE REFORM ACT.—

(1XA) Subsection (a) of section 4081 of the 1986 Code, as
amended by section 1703 of the Reform Act, is amended by
redesignating paragraph (2) as paragraph (3) and by striking out
paragraph (1) and inserting in lieu thereof the following new
paragraphs:

"(1) IN GENERAL.—There is hereby imposed a tax at the rate
specified in paragraph (2) on the earlier of—
"(A) the removal, or
"(B) the sale,

of gasoline by the refiner or importer thereof or the terminal
operator.

"(2) RATES OF TAX.—