PUBLIC LAW 100-647—NOV. 10, 1988

102 STAT. 3703

"(8) AIR CARGO.—For purposes of subsection (b), the transpor-
tation of cargo by air and the transportation of passengers by
air shall be treated as the same service."

(b) EFFECTIVE DATE.—The amendment made by subsection (a) 26 USC132 note.
shall apply to transportation furnished after December 31, 1987, in
taxable years ending after such date.

SEC. 6067. SPECIAL RULE FOR APPLYING SPIN-OFF RULES TO BRIDGE

BANKS.

(a) IN GENERAL.—Section 414(1X2) of the 1986 Code is amended by
adding at the end thereof the following new subparagraph:

"(G) SPECIAL RULES FOR BRIDGE BANKS.—For purposes of this
paragraph, in the case of a bridge bank established under
section ll(i) of the Federal Deposit Insurance Act (12 U.S.C.
18210))—

"(i) such bank shall be treated as a member of any
controlled group which includes any insured bank (as
defined in section 3(h) of such Act (12 U.S.C. 1813(h)))—
"(I) which maintains a defined benefit plan,
"(II) which is closed by the appropriate bank regu-
latory authorities, and

"(III) any asset and liabilities of which are received
by the bridge bank, and

"(ii) the requirements of this paragraph shall not be
treated as met with respect to such plan unless during the
180-day period beginning on the date such insured bank is
closed—

"(I) the bridge bank has the right to require the plan
to transfer (subject to the provisions of this paragraph)
not more than 50 percent of the excess assets (as
defined in subparagraph (Q) to a defined benefit plan
maintained by the bridge bank with respect to partici-
pants or former participants (including retirees and
beneficiaries) in the original plan employed by the
bridge bank or formerly employed by the closed -bank,
and

"(II) no other merger, spin-off, termination, or simi-
lar transaction involving the portion of the excess
assets described in subclause (I) may occur without the
prior written consent of the bridge bank."

(b) STUDY.—The Secretary of the Treasury or his delegate, in 26 USC 414 note.
consultation with the Federal Deposit Insurance Corporation, shall

conduct a study with respect to the proper method of allocating

assets in the case of a transaction to which the amendment made by

this subsection applies. The Secretary of the Treasury shall not later Reports.

than January 1, 1990, report the results of such study to the

Committee on Ways and Means of the House of Representatives and

to the Committee on Finance of the Senate.

(c) EFFECTIVE DATE.—The amendment made by this section shall 26 USC 414 note.
take effect as if included in the amendments made by section 205(c)

of this Act.

SEC. 6068. INCOME AVERAGING ALLOWED TO LUMP-SUM DISTRIBUTIONS
OF ALTERNATE PAYEES.

(a) IN GENERAL.—Section 402(eX4) of the 1986 Code is amended by
adding at the end thereof the following new subparagraph: