
From the U.S. Code Online via GPO Access
[wais.access.gpo.gov]
[Laws in effect as of January 2, 2001]
[Document not affected by Public Laws enacted between
  January 2, 2001 and January 28, 2002]
[CITE: 26USC59]

 
                     TITLE 26--INTERNAL REVENUE CODE
 
                        Subtitle A--Income Taxes
 
                  CHAPTER 1--NORMAL TAXES AND SURTAXES
 
              Subchapter A--Determination of Tax Liability
 
                    PART VI--ALTERNATIVE MINIMUM TAX
 
Sec. 59. Other definitions and special rules


(a) Alternative minimum tax foreign tax credit

    For purposes of this part--

                           (1) In general

        The alternative minimum tax foreign tax credit for any taxable 
    year shall be the credit which would be determined under section 
    27(a) for such taxable year if--
            (A) the pre-credit tentative minimum tax were the tax 
        against which such credit was taken for purposes of section 904 
        for the taxable year and all prior taxable years beginning after 
        December 31, 1986,
            (B) section 904 were applied on the basis of alternative 
        minimum taxable income instead of taxable income, and
            (C) the determination of whether any income is high-taxed 
        income for purposes of section 904(d)(2) were made on the basis 
        of the applicable rate specified in subparagraph (A)(i) or 
        (B)(i) of section 55(b)(1) (whichever applies) in lieu of the 
        highest rate of tax specified in section 1 or 11 (whichever 
        applies).

                 (2) Limitation to 90 percent of tax

        (A) In general

            The alternative minimum tax foreign tax credit for any 
        taxable year shall not exceed the excess (if any) of--
                (i) the pre-credit tentative minimum tax for the taxable 
            year, over
                (ii) 10 percent of the amount which would be the pre-
            credit tentative minimum tax without regard to the 
            alternative tax net operating loss deduction and section 
            57(a)(2)(E).

        (B) Carryback and carryforward

            If the alternative minimum tax foreign tax credit exceeds 
        the amount determined under subparagraph (A), such excess shall, 
        for purposes of this part, be treated as an amount to which 
        section 904(c) applies.

                (3) Pre-credit tentative minimum tax

        For purposes of this subsection, the term ``pre-credit tentative 
    minimum tax'' means--
            (A) in the case of a taxpayer other than a corporation, the 
        amount determined under the first sentence of section 
        55(b)(1)(A)(i), or
            (B) in the case of a corporation, the amount determined 
        under section 55(b)(1)(B)(i).

        (4) Election to use simplified section 904 limitation

        (A) In general

            In determining the alternative minimum tax foreign tax 
        credit for any taxable year to which an election under this 
        paragraph applies--
                (i) subparagraph (B) of paragraph (1) shall not apply, 
            and
                (ii) the limitation of section 904 shall be based on the 
            proportion which--
                    (I) the taxpayer's taxable income (as determined for 
                purposes of the regular tax) from sources without the 
                United States (but not in excess of the taxpayer's 
                entire alternative minimum taxable income), bears to
                    (II) the taxpayer's entire alternative minimum 
                taxable income for the taxable year.

        (B) Election

            (i) In general

                An election under this paragraph may be made only for 
            the taxpayer's first taxable year which begins after 
            December 31, 1997, and for which the taxpayer claims an 
            alternative minimum tax foreign tax credit.
            (ii) Election revocable only with consent

                An election under this paragraph, once made, shall apply 
            to the taxable year for which made and all subsequent 
            taxable years unless revoked with the consent of the 
            Secretary.

(b) Minimum tax not to apply to income eligible for credits under 
        section 30A or 936

    In the case of any corporation for which a credit is allowable for 
the taxable year under section 30A or 936, alternative minimum taxable 
income shall not include any income with respect to which a credit is 
determined under section 30A or 936.

(c) Treatment of estates and trusts

    In the case of any estate or trust, the alternative minimum taxable 
income of such estate or trust and any beneficiary thereof shall be 
determined by applying part I of subchapter J with the adjustments 
provided in this part.

(d) Apportionment of differently treated items in case of certain 
        entities

                           (1) In general

        The differently treated items for the taxable year shall be 
    apportioned (in accordance with regulations prescribed by the 
    Secretary)--

        (A) Regulated investment companies and real estate investment 
                trusts

            In the case of a regulated investment company to which part 
        I of subchapter M applies or a real estate investment company to 
        which part II of subchapter M applies, between such company or 
        trust and shareholders and holders of beneficial interest in 
        such company or trust.

        (B) Common trust funds

            In the case of a common trust fund (as defined in section 
        584(a)), pro rata among the participants of such fund.

                    (2) Differently treated items

        For purposes of this section, the term ``differently treated 
    item'' means any item of tax preference or any other item which is 
    treated differently for purposes of this part than for purposes of 
    computing the regular tax.

(e) Optional 10-year writeoff of certain tax preferences

                           (1) In general

        For purposes of this title, any qualified expenditure to which 
    an election under this paragraph applies shall be allowed as a 
    deduction ratably over the 10-year period (3-year period in the case 
    of circulation expenditures described in section 173) beginning with 
    the taxable year in which such expenditure was made (or, in the case 
    of a qualified expenditure described in paragraph (2)(C), over the 
    60-month period beginning with the month in which such expenditure 
    was paid or incurred).

                      (2) Qualified expenditure

        For purposes of this subsection, the term ``qualified 
    expenditure'' means any amount which, but for an election under this 
    subsection, would have been allowable as a deduction (determined 
    without regard to section 291) for the taxable year in which paid or 
    incurred under--
            (A) section 173 (relating to circulation expenditures),
            (B) section 174(a) (relating to research and experimental 
        expenditures),
            (C) section 263(c) (relating to intangible drilling and 
        development expenditures),
            (D) section 616(a) (relating to development expenditures), 
        or
            (E) section 617(a) (relating to mining exploration 
        expenditures).

                  (3) Other sections not applicable

        Except as provided in this subsection, no deduction shall be 
    allowed under any other section for any qualified expenditure to 
    which an election under this subsection applies.

                            (4) Election

        (A) In general

            An election may be made under paragraph (1) with respect to 
        any portion of any qualified expenditure.

        (B) Revocable only with consent

            Any election under this subsection may be revoked only with 
        the consent of the Secretary.

        (C) Partners and shareholders of S corporations

            In the case of a partnership, any election under paragraph 
        (1) shall be made separately by each partner with respect to the 
        partner's allocable share of any qualified expenditure. A 
        similar rule shall apply in the case of an S corporation and its 
        shareholders.

                          (5) Dispositions

        (A) Application of section 1254

            In the case of any disposition of property to which section 
        1254 applies (determined without regard to this section), any 
        deduction under paragraph (1) with respect to amounts which are 
        allocable to such property shall, for purposes of section 1254, 
        be treated as a deduction allowable under section 263(c), 
        616(a), or 617(a), whichever is appropriate.

        (B) Application of section 617(d)

            In the case of any disposition of mining property to which 
        section 617(d) applies (determined without regard to this 
        subsection), any deduction under paragraph (1) with respect to 
        amounts which are allocable to such property shall, for purposes 
        of section 617(d), be treated as a deduction allowable under 
        section 617(a).

       (6) Amounts to which election apply not treated as tax 
                                 preference

        Any portion of any qualified expenditure to which an election 
    under paragraph (1) applies shall not be treated as an item of tax 
    preference under section 57(a) and section 56 shall not apply to 
    such expenditure.

(f) Coordination with section 291

    Except as otherwise provided in this part, section 291 (relating to 
cutback of corporate preferences) shall apply before the application of 
this part.

(g) Tax benefit rule

    The Secretary may prescribe regulations under which differently 
treated items shall be properly adjusted where the tax treatment giving 
rise to such items will not result in the reduction of the taxpayer's 
regular tax for the taxable year for which the item is taken into 
account or for any other taxable year.

(h) Coordination with certain limitations

    The limitations of sections 704(d), 465, and 1366(d) (and such other 
provisions as may be specified in regulations) shall be applied for 
purposes of computing the alternative minimum taxable income of the 
taxpayer for the taxable year with the adjustments of sections 56, 57, 
and 58.

(i) Special rule for amounts treated as tax preference

    For purposes of this subtitle (other than this part), any amount 
shall not fail to be treated as wholly exempt from tax imposed by this 
subtitle solely by reason of being included in alternative minimum 
taxable income.

(j) Treatment of unearned income of minor children

                           (1) In general

        In the case of a child to whom section 1(g) applies, the 
    exemption amount for purposes of section 55 shall not exceed the sum 
    of--
            (A) such child's earned income (as defined in section 
        911(d)(2)) for the taxable year, plus
            (B) $5,000.

                      (2) Inflation adjustment

        In the case of any taxable year beginning in a calendar year 
    after 1998, the dollar amount in paragraph (1)(B) shall be increased 
    by an amount equal to the product of--
            (A) such dollar amount, and
            (B) the cost-of-living adjustment determined under section 
        1(f)(3) for the calendar year in which the taxable year begins, 
        determined by substituting ``1997'' for ``1992'' in subparagraph 
        (B) thereof.

    If any increase determined under the preceding sentence is not a 
    multiple of $50, such increase shall be rounded to the nearest 
    multiple of $50.

(Added Pub. L. 99-514, title VII, Sec. 701(a), Oct. 22, 1986, 100 Stat. 
2336; amended Pub. L. 100-647, title I, Secs. 1007(e), 1014(e)(5)(A), 
Nov. 10, 1988, 102 Stat. 3432, 3561; Pub. L. 101-239, title VII, 
Secs. 7611(f)(5)(B), (6), 7612(e)(1), 7811(d)(1)(A), (j)(7), Dec. 19, 
1989, 103 Stat. 2373, 2374, 2408, 2412; Pub. L. 101-508, title XI, 
Secs. 11101(d)(3), 11531(b)(2), 11702(d), 11801(c)(2)(D), Nov. 5, 1990, 
104 Stat. 1388-405, 1388-490, 1388-514, 1388-523; Pub. L. 102-486, title 
XIX, Sec. 1915(c)(3), Oct. 24, 1992, 106 Stat. 3024; Pub. L. 104-188, 
title I, Secs. 1601(b)(2)(D), 1702(a)(1), 1703(e), 1704(m)(3), Aug. 20, 
1996, 110 Stat. 1833, 1868, 1875, 1883; Pub. L. 105-34, title X, 
Sec. 1057(a), title XI, Sec. 1103(a), title XII, Sec. 1201(b)(1), Aug. 
5, 1997, 111 Stat. 945, 966, 994; Pub. L. 105-206, title VI, 
Secs. 6011(a), 6023(2), July 22, 1998, 112 Stat. 817, 824.)

  Adjustment of Alternative Minimum Tax Exemption Amount for Tax Years 
                            Beginning in 2001

        For adjustment of alternative minimum tax exemption amount under 
    subsec. (j) of this section in the case of a child to whom the 
    ``kiddie tax'' applies for tax years beginning in 2001, see section 
    3.04 of Revenue Procedure 2001-13, set out as a note under section 1 
    of this title.


                               Amendments

    1998--Subsec. (a)(3), (4). Pub. L. 105-206, Sec. 6011(a), 
redesignated par. (3), relating to election to use simplified section 
904 limitation, as (4).
    Subsec. (b). Pub. L. 105-206, Sec. 6023(2), substituted ``credits 
under section 30A or 936'' for ``section 936 credit'' in heading.
    1997--Subsec. (a)(2)(C). Pub. L. 105-34, Sec. 1057(a), struck out 
subpar. (C) which read as follows:
    ``(C) Exception.--Subparagraph (A) shall not apply to any domestic 
corporation if--
        ``(i) more than 50 percent of the stock of such domestic 
    corporation (by vote and value) is owned by United States persons 
    who are not members of an affiliated group (as defined in section 
    1504 of such Code) which includes such corporation,
        ``(ii) all of the activities of such corporation are conducted 
    in 1 foreign country with which the United States has an income tax 
    treaty in effect and such treaty provides for the exchange of 
    information between such foreign country and the United States,
        ``(iii) all of the current earnings and profits of such 
    corporation are distributed at least annually (other than current 
    earnings and profits retained for normal maintenance or capital 
    replacements or improvements of an existing business), and
        ``(iv) all of such distributions by such corporation to United 
    States persons are used by such persons in a trade or business 
    conducted in the United States.''
    Subsec. (a)(3). Pub. L. 105-34, Sec. 1103(a), added par. (3) 
relating to election to use simplified section 904 limitation.
    Subsec. (j). Pub. L. 105-34, Sec. 1201(b)(1), amended subsec. (j) 
generally, restating limitation on exemption amount, adding provisions 
for inflation adjustment of such amount, and deleting provisions 
relating to limitation based on parental minimum tax and unused parental 
minimum tax exemption.
    1996--Subsec. (a)(1)(A). Pub. L. 104-188, Sec. 1703(e)(1), 
substituted ``the pre-credit tentative minimum tax'' for ``the amount 
determined under section 55(b)(1)(A)''.
    Subsec. (a)(1)(C). Pub. L. 104-188, Sec. 1703(e)(2), substituted 
``specified in subparagraph (A)(i) or (B)(i) of section 55(b)(1) 
(whichever applies)'' for ``specified in section 55(b)(1)(A)''.
    Subsec. (a)(2)(A)(i). Pub. L. 104-188, Sec. 1703(e)(1), substituted 
``the pre-credit tentative minimum tax'' for ``the amount determined 
under section 55(b)(1)(A)''.
    Subsec. (a)(2)(A)(ii). Pub. L. 104-188, Sec. 1703(e)(3), substituted 
``which would be the pre-credit tentative minimum tax'' for ``which 
would be determined under section 55(b)(1)(A)''.
    Subsec. (a)(3). Pub. L. 104-188, Sec. 1703(e)(4), added par. (3).
    Subsec. (b). Pub. L. 104-188, Sec. 1601(b)(2)(D), substituted 
``section 30A or 936, alternative minimum taxable income shall not 
include any income with respect to which a credit is determined under 
section 30A or 936.'' for ``section 936, alternative minimum taxable 
income shall not include any amount with respect to which the 
requirements of subparagraph (A) or (B) of section 936(a)(1) are met.''
    Subsec. (j)(1)(B). Pub. L. 104-188, Sec. 1704(m)(3), substituted 
``twice the amount in effect for the taxable year under section 
63(c)(5)(A)'' for ``$1,000''.
    Subsec. (j)(3)(B). Pub. L. 104-188, Sec. 1702(a)(1), substituted 
``section 1(g)(3)(B)'' for ``section 1(i)(3)(B)''.
    1992--Subsec. (a)(2)(A)(ii). Pub. L. 102-486 substituted ``and 
section 57(a)(2)(E)'' for ``and the alternative tax energy preference 
deduction under section 56(h)''.
    1990--Subsec. (a)(1)(B) to (D). Pub. L. 101-508, 
Sec. 11801(c)(2)(D), inserted ``and'' at end of subpar. (B), 
redesignated subpar. (D) as (C), and struck out former subpar. (C) which 
read as follows: ``for purposes of section 904, any increase in 
alternative minimum taxable income by reason of section 56(c)(1)(A) 
(relating to adjustment for book income) shall have the same 
proportionate source (and character) as alternative minimum taxable 
income determined without regard to such increase, and''.
    Subsec. (a)(2)(A)(ii). Pub. L. 101-508, Sec. 11531(b)(2), inserted 
before period at end ``and the alternative tax energy preference 
deduction under section 56(h)''.
    Subsec. (j). Pub. L. 101-508, Sec. 11101(d)(3)(A), substituted 
``section 1(g)'' for ``section 1(i)'' in pars. (1), (2)(A), (B)(i)(I), 
(II), (D), and (3).
    Subsec. (j)(1)(B). Pub. L. 101-508, Sec. 11702(d)(1), inserted 
``(or, if greater, the child's share of the unused parental minimum tax 
exemption)'' before period at end.
    Subsec. (j)(2)(C). Pub. L. 101-508, Sec. 11101(d)(3)(B), substituted 
``section 1(g)(3)(B)'' for ``section 1(i)(3)(B)''.
    Subsec. (j)(2)(D). Pub. L. 101-508, Sec. 11702(d)(3), substituted 
``paragraphs (3)(D), (5), and (6)'' for ``paragraphs (5) and (6)''.
    Subsec. (j)(3). Pub. L. 101-508, Sec. 11702(d)(2), added par. (3).
    1989--Subsec. (a)(2)(C). Pub. L. 101-239, Sec. 7612(e)(1), added 
subpar. (C).
    Subsec. (e)(1). Pub. L. 101-239, Sec. 7611(f)(5)(B), inserted before 
period at end ``(or, in the case of a qualified expenditure described in 
paragraph (2)(C), over the 60-month period beginning with the month in 
which such expenditure was paid or incurred)''.
    Subsec. (g). Pub. L. 101-239, Sec. 7811(d)(1)(A), substituted ``for 
the taxable year for which the item is taken into account or for any 
other taxable year'' for ``for any taxable year''.
    Subsec. (i). Pub. L. 101-239, Sec. 7611(f)(6), substituted 
``amounts'' for ``interest'' in heading and ``any amount shall'' for 
``interest shall'' in text.
    Subsec. (j)(2)(D). Pub. L. 101-239, Sec. 7811(j)(7), substituted 
``Other rules'' for ``Others rules'' in heading.
    1988--Subsec. (a)(1)(D). Pub. L. 100-647, Sec. 1007(e)(3), added 
subpar. (D).
    Subsec. (e)(2). Pub. L. 100-647, Sec. 1007(e)(1), inserted 
``(determined without regard to section 291)'' after ``as a deduction''.
    Subsec. (h). Pub. L. 100-647, Sec. 1007(e)(2), substituted ``taxable 
year with the adjustments of sections 56, 57, and 58'' for ``taxable 
year--
        ``(1) with the adjustments of section 56, and
        ``(2) by not taking into account any deduction to the extent 
    such deduction is an item of tax preference under section 57(a)''.
    Subsec. (i). Pub. L. 100-647, Sec. 1007(e)(4), inserted ``(other 
than this part)'' after ``of this subtitle'' and substituted 
``subtitle'' for ``title'' before ``solely''.
    Subsec. (j). Pub. L. 100-647, Sec. 1014(e)(5)(A), added subsec. (j).


                    Effective Date of 1998 Amendment

    Amendment by section 6023(2) of Pub. L. 105-206 effective July 22, 
1998, see section 6023(32) of Pub. L. 105-206, set out as a note under 
section 34 of this title.
    Amendment by section 6011(a) of Pub. L. 105-206 effective, except as 
otherwise provided, as if included in the provisions of the Taxpayer 
Relief Act of 1997, Pub. L. 105-34, to which such amendment relates, see 
section 6024 of Pub. L. 105-206, set out as a note under section 1 of 
this title.


                    Effective Date of 1997 Amendment

    Section 1057(b) of Pub. L. 105-34 provided that: ``The amendment 
made by this section [amending this section] shall apply to taxable 
years beginning after the date of the enactment of this Act [Aug. 5, 
1997].''
    Section 1103(b) of Pub. L. 105-34 provided that: ``The amendment 
made by this section [amending this section] shall apply to taxable 
years beginning after December 31, 1997.''
    Section 1201(c) of Pub. L. 105-34 provided that: ``The amendments 
made by this section [amending this section and sections 63 and 6103 of 
this title] shall apply to taxable years beginning after December 31, 
1997.''


                    Effective Date of 1996 Amendment

    Amendment by section 1601(b)(2)(D) of Pub. L. 104-188 applicable to 
taxable years beginning after Dec. 31, 1995, except as otherwise 
provided, see section 1601(c) of Pub. L. 104-188, set out as an 
Effective Date note under section 30A of this title.
    Amendment by section 1702(a)(1) of Pub. L. 104-188 effective, except 
as otherwise expressly provided, as if included in the provision of the 
Revenue Reconciliation Act of 1990, Pub. L. 101-508, title XI, to which 
such amendment relates, see section 1702(i) of Pub. L. 104-188, set out 
as a note under section 38 of this title.
    Amendment by section 1703(e) of Pub. L. 104-188 effective as if 
included in the provision of the Revenue Reconciliation Act of 1993, 
Pub. L. 103-66, Secs. 13001-13444, to which such amendment relates, see 
section 1703(o) of Pub. L. 104-188, set out as a note under section 39 
of this title.
    Amendment by section 1704(m)(3) of Pub. L. 104-188 applicable to 
taxable years beginning after Dec. 31, 1995, see section 1704(m)(4) of 
Pub. L. 104-188, set out as a note under section 1 of this title.


                    Effective Date of 1992 Amendment

    Amendment by Pub. L. 102-486 applicable to taxable years beginning 
after Dec. 31, 1992, see section 1915(d) of Pub. L. 102-486, set out as 
a note under section 56 of this title.


                    Effective Date of 1990 Amendment

    Amendment by section 11101(d)(3) of Pub. L. 101-508 applicable to 
taxable years beginning after Dec. 31, 1990, see section 11101(e) of 
Pub. L. 101-508, set out as a note under section 1 of this title.
    Amendment by section 11531(b)(2) of Pub. L. 101-508 applicable to 
taxable years beginning after Dec. 31, 1990, see section 11531(c) of 
Pub. L. 101-508, set out as a note under section 56 of this title.
    Section 11702(j) of Pub. L. 101-508 provided that: ``Any amendment 
made by this section [amending this section and sections 135, 216, 355, 
367, 447, 453B, 468B, 2056, 2056A, 2523, 4980B, and 6114 of this title] 
shall take effect as if included in the provision of the Technical and 
Miscellaneous Revenue Act of 1988 [Pub. L. 100-647] to which such 
amendment relates.''


                    Effective Date of 1989 Amendment

    Amendment by section 7611(f)(6) of Pub. L. 101-239 applicable to 
taxable years beginning after Dec. 31, 1989, see section 7611(g)(1) of 
Pub. L. 101-239, set out as a note under section 56 of this title.
    Amendment by section 7611(f)(5)(B) of Pub. L. 101-239 applicable to 
costs paid or incurred in taxable years beginning after Dec. 31, 1989, 
see section 7611(g)(2) of Pub. L. 101-239, set out as a note under 
section 56 of this title.
    Section 7612(e)(2) of Pub. L. 101-239 provided that:
    ``(A) In general.--The amendment made by paragraph (1) [amending 
this section] shall apply to taxable years beginning after March 31, 
1990.
    ``(B) Special rule for year which includes march 31, 1990.--In the 
case of any taxable year (of a corporation described in subparagraph (C) 
of section 59(a)(2) of the Internal Revenue Code of 1986 (as added by 
paragraph (1))) which begins after December 31, 1989, and includes March 
31, 1990, the amount determined under clause (ii) of section 59(a)(2)(A) 
of such Code shall be an amount which bears the same ratio to the amount 
which would have been determined under such clause without regard to 
this subparagraph as the number of days in such taxable year on or 
before March 31, 1990, bears to the total number of days in such taxable 
year.''
    Amendment by section 7811(d)(1)(A), (j)(7) of Pub. L. 101-239 
effective, except as otherwise provided, as if included in the provision 
of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 
to which such amendment relates, see section 7817 of Pub. L. 101-239, 
set out as a note under section 1 of this title.


                    Effective Date of 1988 Amendment

    Amendment by section 1007(e) of Pub. L. 100-647 effective, except as 
otherwise provided, as if included in the provision of the Tax Reform 
Act of 1986, Pub. L. 99-514, to which such amendment relates, see 
section 1019(a) of Pub. L. 100-647, set out as a note under section 1 of 
this title.
    Section 1014(e)(5)(B) of Pub. L. 100-647 provided that: ``The 
amendment made by subparagraph (A) [amending this section] shall apply 
to taxable years beginning after December 31, 1988.''


                             Effective Date

    Section applicable to taxable years beginning after Dec. 31, 1986, 
with certain exceptions and qualifications, see section 701(f) of Pub. 
L. 99-514, set out as a note under section 55 of this title.


                            Savings Provision

    For provisions that nothing in amendment by section 11801 of Pub. L. 
101-508 be construed to affect treatment of certain transactions 
occurring, property acquired, or items of income, loss, deduction, or 
credit taken into account prior to Nov. 5, 1990, for purposes of 
determining liability for tax for periods ending after Nov. 5, 1990, see 
section 11821(b) of Pub. L. 101-508, set out as a note under section 29 
of this title.


Consideration of Certain Taxes Treated as Paid or Accrued Under Section 
  904(c) in Determination of Alternative Minimum Tax Foreign Tax Credit

    Section 1007(f)(5) of Pub. L. 100-647 provided that: ``In 
determining the amount of the alternative minimum tax foreign tax credit 
under section 59 of the 1986 Code, there shall not be taken into account 
any taxes paid or accrued in a taxable year beginning after December 31, 
1986, which are treated under section 904(c) of the 1986 Code as paid or 
accrued in a taxable year beginning on or before December 31, 1986.''


  Applicability of Certain Amendments by Pub. L. 99-514 in Relation to 
                   Treaty Obligations of United States

    For applicability of amendment by section 701(a) of Pub. L. 99-514 
[enacting this section] notwithstanding any treaty obligation of the 
United States in effect on Oct. 22, 1986, with provision that for such 
purposes any amendment by title I of Pub. L. 100-647 be treated as if it 
had been included in the provision of Pub. L. 99-514 to which such 
amendment relates, see section 1012(aa)(2), (4) of Pub. L. 100-647, set 
out as a note under section 861 of this title.

                  Section Referred to in Other Sections

    This section is referred to in sections 53, 173, 174, 263, 263A, 
616, 617, 904, 1016 of this title.
