senate bailout 100108

Page 446

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S.L.C.

446 1

‘‘(2) COMPREHENSIVE

FOREIGN INCOME TAX.—

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The term ‘comprehensive foreign income tax’ means,

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with respect to any foreign person, the income tax

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of a foreign country if—

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‘‘(A) such person is eligible for the benefits

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of a comprehensive income tax treaty between

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such foreign country and the United States, or

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‘‘(B) such person demonstrates to the sat-

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isfaction of the Secretary that such foreign

10

country has a comprehensive income tax.

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‘‘(3) NONQUALIFIED

12

TION PLAN.—

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‘‘(A)

IN

DEFERRED

GENERAL.—The

COMPENSA-

term

‘non-

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qualified deferred compensation plan’ has the

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meaning

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409A(d), except that such term shall include

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any plan that provides a right to compensation

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based on the appreciation in value of a specified

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number of equity units of the service recipient.

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‘‘(B)

given

such

term

under

EXCEPTION.—Compensation

section

shall

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not be treated as deferred for purposes of this

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section if the service provider receives payment

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of such compensation not later than 12 months

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after the end of the taxable year of the service

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recipient during which the right to the payment


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