For inflation adjustment of certain items in this section, see Revenue Procedures listed in a table under section 1 of this title.

The date of the enactment of the Taxpayer Relief Act of 1997, referred to in subsec. (a)(3)(D), is the date of enactment of Pub. L. 105–34, which was approved Aug. 5, 1997.

The date of the enactment of the Tax Reform Act of 1984, referred to in subsec. (a)(3)(E)(ii)(II), (III), is the date of enactment of division A of Pub. L. 98–369, which was approved July 18, 1984.

The date of the enactment of this subparagraph, referred to in subsec. (b)(13)(E)(iii)(I), is the date of enactment of Pub. L. 109–280, which was approved Aug. 17, 2006.

Sections 101(39), 107, 117(a), (b), and 121(d) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, referred to in subsec. (b)(19)(B)(ii)(I), (C)(i), (D)(i), (ii)(I), (V), are classified to sections 9601(39), 9607, 9617(a), (b), and 9621(d), respectively, of Title 42, The Public Health and Welfare.

The date of the enactment of this paragraph, referred to in subsec. (b)(19)(C)(i), (D)(i), (ii)(V), (E)(ii)(IV), is the date of enactment of Pub. L. 108–357, which was approved Oct. 22, 2004.

2019—Subsec. (a)(7). Pub. L. 116–94 struck out par. (7) which related to increases in unrelated business taxable income for certain fringe benefit expenses.

2018—Subsec. (a)(3). Pub. L. 115–141, § 401(b)(21)(G), substituted “or (17)” for “(17), or (20)” in heading.

Subsec. (a)(3)(A). Pub. L. 115–141, § 401(b)(21)(E), substituted “or (17)” for “(17), or (20)”.

Subsec. (a)(3)(B)(ii). Pub. L. 115–141, § 401(b)(21)(F), substituted “or (17)” for “, (17), or (20)”.

Subsec. (a)(3)(C), (D). Pub. L. 115–141, § 401(b)(21)(E), substituted “or (17)” for “(17), or (20)”.

Subsec. (a)(3)(E). Pub. L. 115–141, § 401(b)(21)(F), (H), substituted “or (17)” for “, (17), or (20)” in subpar. heading and text of cl. (i).

Subsec. (b)(19)(H)(iii). Pub. L. 115–141, § 401(a)(126), substituted “clause (i)” for “clause (i)(II)”.

2017—Subsec. (a)(6). Pub. L. 115–97, § 13702(a), added par. (6).

Subsec. (a)(7). Pub. L. 115–97, § 13703(a), added par. (7).

Subsec. (d)(2)(B). Pub. L. 115–97, § 11002(d)(1)(Y), substituted “for ‘calendar year 2016’ in subparagraph (A)(ii)” for “for ‘calendar year 1992’ in subparagraph (B)”.

2015—Subsec. (b)(13)(E)(iv). Pub. L. 114–113 struck out cl. (iv). Text read as follows: “This subparagraph shall not apply to payments received or accrued after December 31, 2014.”

2014—Subsec. (a)(3)(A). Pub. L. 113–295, § 221(a)(41)(G), struck out “, 244,” after “sections 243”.

Subsec. (b)(13)(E)(iv). Pub. L. 113–295, § 131(a), substituted “December 31, 2014” for “December 31, 2013”.

2013—Subsec. (b)(13)(E)(iv). Pub. L. 112–240 substituted “December 31, 2013” for “December 31, 2011”.

2010—Subsec. (b)(13)(E)(iv). Pub. L. 111–312 substituted “December 31, 2011” for “December 31, 2009”.

2008—Subsec. (b)(13)(E)(iv). Pub. L. 110–343 substituted “December 31, 2009” for “December 31, 2007”.

2006—Subsec. (b)(13)(E), (F). Pub. L. 109–280, which directed the amendment of section 512(b)(13) by adding subpar. (E) and redesignating former subpar. (E) as (F), without specifying the act to be amended, was executed by making the amendments to this section, which is section 512 of the Internal Revenue Code of 1986, to reflect the probable intent of Congress.

2005—Subsec. (b)(1). Pub. L. 109–135, § 412(dd), substituted “subsection (a)(5)” for “section 512(a)(5)”.

Subsec. (b)(18), (19). Pub. L. 109–135, § 412(ee)(1), redesignated par. (18), relating to treatment of gain or loss on sale or exchange of certain brownfield sites, as (19).

2004—Subsec. (b)(18). Pub. L. 108–357, § 702(a), added par. (18) relating to treatment of gain or loss on sale or exchange of certain brownfield sites.

Pub. L. 108–357, § 319(c), added par. (18) relating to treatment of mutual or cooperative electric companies.

Subsec. (e)(1). Pub. L. 108–357, § 233(d), inserted “1361(c)(2)(A)(vi) or” before “1361(c)(6)” in introductory provisions.

1998—Subsec. (b)(13)(A). Pub. L. 105–206, § 6010(j)(1), inserted “or accrues” after “receives” in first sentence.

Subsec. (b)(13)(B)(i)(I). Pub. L. 105–206, § 6010(j)(2), struck out “(as defined in section 513A(a)(5)(A))” after “exempt purposes”.

Subsec. (b)(17)(B)(ii)(II). Pub. L. 105–206, § 6023(8), substituted “rule” for “Rule” in subcl. heading.

1997—Subsec. (a)(3)(D). Pub. L. 105–34, § 312(d)(5), inserted “(as in effect on the day before the date of the enactment of the Taxpayer Relief Act of 1997)” after “1034”.

Subsec. (b)(13). Pub. L. 105–34, § 1041(a), amended par. (13) generally. Prior to amendment, par. (13) related to inclusion in gross income of controlling organization of amounts of interest, annuities, royalties, and rents derived from a controlled organization.

Subsec. (e)(1). Pub. L. 105–34, § 1601(c)(4)(D), substituted “section 1361(c)(6)” for “section 1361(c)(7)”.

Subsec. (e)(2). Pub. L. 105–34, § 1601(c)(4)(A), substituted “as defined in section 1361(e)(1)(C)” for “within the meaning of section 1012”.

Subsec. (e)(3). Pub. L. 105–34, § 1523(a), added par. (3).

1996—Subsec. (b)(17). Pub. L. 104–188, § 1603(a), added par. (17).

Subsec. (d). Pub. L. 104–188, § 1115(a), added subsec. (d).

Subsec. (e). Pub. L. 104–188, § 1316(c), added subsec. (e).

1993—Subsec. (b)(1). Pub. L. 103–66, § 13148(a), inserted “amounts received or accrued as consideration for entering into agreements to make loans,” before “and annuities”.

Subsec. (b)(5). Pub. L. 103–66, § 13148(b), in second sentence, substituted “all gains or losses recognized, in connection with the organization’s investment activities, from” for “all gains on”, struck out “, written by the organization in connection with its investment activities,” after “termination of options”, and inserted before period at end “or real property and all gains or losses from the forfeiture of good-faith deposits (that are consistent with established business practice) for the purchase, sale, or lease of real property in connection with the organization’s investment activities”.

Subsec. (b)(16). Pub. L. 103–66, § 13147(a), added par. (16).

Subsec. (c)(2), (3). Pub. L. 103–66, § 13145(a), redesignated par. (3) as (2), substituted “paragraph (1)” for “paragraph (1) or (2)”, and struck out heading and text of former par. (2). Text read as follows: “Notwithstanding any other provision of this section—

“(A) any organization’s share (whether or not distributed) of the gross income of a publicly traded partnership (as defined in section 469(k)(2)) shall be treated as gross income derived from an unrelated trade or business, and

“(B) such organization’s share of the partnership deductions shall be allowed in computing unrelated business taxable income.”

1990—Subsec. (b)(14). Pub. L. 101–508 struck out par. (14) which read as follows: “Except as provided in paragraph (4), in the case of a church, or convention or association of churches, for taxable years beginning before January 1, 1976, there shall be excluded all gross income derived from a trade or business and all deductions directly connected with the carrying on of such trade or business if such trade or business was carried on by such organization or its predecessor before May 27, 1969.”

1988—Subsec. (a)(3)(E)(ii)(II). Pub. L. 100–647 substituted “subclause (I)” for “subclause (II)” and a period for comma at end.

1987—Subsec. (c). Pub. L. 100–203 substituted “for partnerships” for “applicable to partnerships” in heading and amended text generally. Prior to amendment, text read as follows: “If a trade or business regularly carried on by a partnership of which an organization is a member is an unrelated trade or business with respect to such organization, such organization in computing its unrelated business taxable income shall, subject to the exceptions, additions, and limitations contained in subsection (b), include its share (whether or not distributed) of the gross income of the partnership from such unrelated trade or business and its share of the partnership deductions directly connected with such gross income. If the taxable year of the organization is different from that of the partnership, the amounts to be so included or deducted in computing the unrelated business taxable income shall be based upon the income and deductions of the partnership for any taxable year of the partnership ending within or with the taxable year of the organization.”

1986—Subsec. (a)(3)(E)(i). Pub. L. 99–514, § 1851(a)(10)(A), substituted “determined under section 419A (without regard to subsection (f)(6) thereof)” for “determined under section 419A(c)”.

Subsec. (a)(3)(E)(ii). Pub. L. 99–514, § 1851(a)(10)(B), (C), redesignated cl. (iii) as (ii), in subcl. I substituted “an existing reserve” for “a existing reserve”, and substituted new subcl. (II) for former subcl. (II) which read as follows: “For purposes of subclause (I), the term ‘existing reserve or post-retirement medical or life insurance benefit’ means the amount of assets set aside as of the close of the last plan year ending before the date of the enactment of the Tax Reform Act of 1984 for purposes of post-retirement medical benefits or life insurance benefits to be provided to covered employees.” Former cl. (ii), which provided that no set aside for assets used in the provision of benefits described in cl. (ii) of subpar. (B), could be taken into account, was struck out.

Subsec. (a)(3)(E)(iii), (iv). Pub. L. 99–514, § 1851(a)(10)(B), (D), redesignated former cl. (iv) as (iii) and substituted “subparagraph shall not” for “paragraph shall not”. Former cl. (iii) redesignated (ii).

1984—Subsec. (a)(3). Pub. L. 98–369, § 511(b)(1)(A), substituted “paragraph (7), (9), (17), or (20) of section 501(c)” for “section 501(c)(7) or (9)” wherever appearing in heading and in text.

Subsec. (a)(3)(B)(ii). Pub. L. 98–369, § 511(b)(1)(B), substituted “paragraph (9), (17), or (20) of section 501(c)” for “section 501(c)(9)”.

Subsec. (a)(3)(C), (D). Pub. L. 98–369, § 511(b)(1)(A), substituted in subpars. (C) and (D) “paragraph (7), (9), (17), or (20) of section 501(c)” for “section 501(c)(7) or (9)” wherever appearing.

Subsec. (a)(3)(E). Pub. L. 98–369, § 511(b)(2), added subpar. (E).

1983—Subsec. (b)(10). Pub. L. 97–448 substituted “10 percent” for “5 percent”.

1978—Subsec. (a)(5). Pub. L. 95–345, § 2(b), added par. (5).

Subsec. (b)(1). Pub. L. 95–345, § 2(a)(2), inserted provision relating to payments with respect to securities loans.

1976—Subsec. (a)(3)(A). Pub. L. 94–568 provided that for purposes of the general rule, the deductions provided by sections 243, 244, and 245 (relating to dividends received by corporations) shall be treated as not directly connected with the production of gross income.

Subsec. (b). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”.

Subsec. (b)(5). Pub. L. 94–396 inserted provision relating to exclusion of gains on the lapse or termination of options to buy or sell securities.

Subsec. (b)(13), (14). Pub. L. 94–455, § 1951(b)(8)(A), redesignated pars. (15) and (16) as (13) and (14), respectively. Former pars. (13) and (14), relating to exceptions, additions, and limitations applicable in determining unrelated business taxable income, were struck out.

Subsec. (b)(15). Pub. L. 94–455, §§ 1901(b)(8)(F), 1906(b)(13)(A), 1951(b)(8)(A), redesignated par. (17) as (15) and substituted in subpar. (B) “educational organization described in section 170(b)(1)(A)(ii)” for “educational institution (as defined in section 151(e)(4))” after “order or by an”, and struck out “or his delegate” after “Secretary”. Former par. (15) redesignated (13).

Subsec. (b)(16), (17). Pub. L. 94–455, § 1951(b)(8)(A), redesignated pars. (16) and (17) as (14) and (15), respectively.

1972—Subsec. (a)(4). Pub. L. 92–418 added par. (4).

1969—Subsec. (a). Pub. L. 91–172, § 121(b)(1), designated existing provisions as pars. (1) and (2)(B) and added pars. (2)(A) and (3).

Subsec. (b). Pub. L. 91–172, § 121(b)(2)(D), substituted “Modifications” for “Exceptions, additions, and limitations”, in heading, and, in text preceding par. (1) substituted “The modifications referred to in subsection (a)” for “The exceptions, additions, and limitations applicable in determining unrelated business taxable income”.

Subsec. (b)(3)(A). Pub. L. 91–172, § 121(b)(2)(A), inserted reference to exceptions set out in subsec. (b)(3)(B) in text preceding cl. (i), substituted “property described in section 1245(a)(3)(C)” for “personal property leased with the real property” in parenthetical of cl. (i), and added cl. (ii).

Subsec. (b)(3)(B). Pub. L. 91–172, § 121(b)(2)(A), added subpar. (B).

Subsec. (b)(3)(C). Pub. L. 91–172, § 121(b)(2)(A), substituted “rents excluded under subparagraph (A)” for “such rents”.

Subsec. (b)(4). Pub. L. 91–172, § 121(b)(2)(A), inserted reference to pars. (1), (3) and (5) of this subsec., and substituted “debt financed property” for “a business lease”.

Subsec. (b)(12). Pub. L. 91–172, § 121(b)(2)(B), made the allowance of the specific $1,000 deduction inapplicable for the purposes of computing the net operating loss under section 172 of this title and par. (6) of this subsec., and provided for the allowance of specific deductions equal to the lower of $1,000 or the gross income derived from any unrelated trade or business carried on by a parish, individual church, district, or other local unit.

Subsec. (b)(15) to (17). Pub. L. 91–172, § 121(b)(2)(C), added pars. (15) to (17).

1966—Subsec. (a). Pub. L. 89–809 substituted “, the unrelated business taxable income shall be its unrelated business taxable income which is effectively connected with the conduct of a trade or business within the United States” for “, the unrelated business taxable income shall be its unrelated business taxable income derived from sources within the United States determined under subchapter N (sec. 861 and following), relating to tax based on income from sources within or without the United States”.

1964—Subsec. (b)(14). Pub. L. 88–380 added par. (14).

1958—Subsec. (b)(13). Pub. L. 85–367 added par. (13).

Pub. L. 116–94, div. Q, title III, § 302(b), Dec. 20, 2019, 133 Stat. 3248, provided that: “The amendment made by this section [amending this section] shall take effect as if included in the amendments made by section 13703 of Public Law 115–97.”

Amendment by section 11002(d)(1)(Y) of Pub. L. 115–97 applicable to taxable years beginning after Dec. 31, 2017, see section 11002(e) of Pub. L. 115–97, set out as a note under section 1 of this title.

Pub. L. 115–97, title I, § 13702(b), Dec. 22, 2017, 131 Stat. 2168, provided that:

Pub. L. 115–97, title I, § 13703(b), Dec. 22, 2017, 131 Stat. 2169, provided that: “The amendment made by this section [amending this section] shall apply to amounts paid or incurred after December 31, 2017.”

Pub. L. 114–113, div. Q, title I, § 114(b), Dec. 18, 2015, 129 Stat. 3049, provided that: “The amendment made by this section [amending this section] shall apply to payments received or accrued after December 31, 2014.”

Pub. L. 113–295, div. A, title I, § 131(b), Dec. 19, 2014, 128 Stat. 4018, provided that: “The amendment made by this section [amending this section] shall apply to payments received or accrued after December 31, 2013.”

Amendment by section 221(a)(41)(G) of Pub. L. 113–295 not applicable to preferred stock issued before Oct. 1, 1942 (determined in the same manner as under section 247 of this title as in effect before its repeal by Pub. L. 113–295), see section 221(a)(41)(K) of Pub. L. 113–295, set out as a note under section 172 of this title.

Except as otherwise provided in section 221(a) of Pub. L. 113–295, amendment by section 221(a)(41)(G) of Pub. L. 113–295 effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 113–295, set out as a note under section 1 of this title.

Pub. L. 112–240, title III, § 319(b), Jan. 2, 2013, 126 Stat. 2332, provided that: “The amendment made by this section [amending this section] shall apply to payments received or accrued after December 31, 2011.”

Pub. L. 111–312, title VII, § 747(b), Dec. 17, 2010, 124 Stat. 3320, provided that: “The amendment made by this section [amending this section] shall apply to payments received or accrued after December 31, 2009.”

Pub. L. 110–343, div. C, title III, § 306(b), Oct. 3, 2008, 122 Stat. 3868, provided that: “The amendment made by this section [amending this section] shall apply to payments received or accrued after December 31, 2007.”

Pub. L. 109–280, title XII, § 1205(c)(1), Aug. 17, 2006, 120 Stat. 1067, provided that: “The amendments made by subsection (a) [amending this section] shall apply to payments received or accrued after December 31, 2005.”

Pub. L. 108–357, title II, § 233(e), Oct. 22, 2004, 118 Stat. 1435, provided that: “The amendments made by this section [amending this section and sections 1361 and 4975 of this title] shall take effect on the date of the enactment of this Act [Oct. 22, 2004].”

Amendment by section 319(c) of Pub. L. 108–357 applicable to taxable years beginning after Oct. 22, 2004, see section 319(e) of Pub. L. 108–357, set out as a note under section 501 of this title.

Pub. L. 108–357, title VII, § 702(d), Oct. 22, 2004, 118 Stat. 1546, provided that: “The amendments made by this section [amending this section and section 514 of this title] shall apply to any gain or loss on the sale, exchange, or other disposition of any property acquired by the taxpayer after December 31, 2004.”

Amendment by section 6023(8) 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 6010(j)(1), (2) 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.

Amendment by section 312(d)(5) of Pub. L. 105–34 applicable to sales and exchanges after May 6, 1997, with certain exceptions, see section 312(d)[(e)] of Pub. L. 105–34, set out as a note under section 121 of this title.

Pub. L. 105–34, title X, § 1041(b), Aug. 5, 1997, 111 Stat. 939, as amended by Pub. L. 105–206, title VI, § 6010(j)(3), July 22, 1998, 112 Stat. 815, provided that:

Pub. L. 105–34, title XV, § 1523(b), Aug. 5, 1997, 111 Stat. 1071, provided that: “The amendments made by this section [amending this section] shall apply to taxable years beginning after December 31, 1997.”

Amendment by section 1601(c)(4)(A), (D) of Pub. L. 105–34 effective as if included in the provisions of the Small Business Job Protection Act of 1996, Pub. L. 104–188, to which it relates, see section 1601(j) of Pub. L. 105–34, set out as a note under section 23 of this title.

Pub. L. 104–188, title I, § 1115(b), Aug. 20, 1996, 110 Stat. 1761, provided that:

Amendment by section 1316(c) of Pub. L. 104–188 applicable to taxable years beginning after Dec. 31, 1997, see section 1316(f) of Pub. L. 104–188, set out as a note under section 170 of this title.

Pub. L. 104–188, title I, § 1603(b), Aug. 20, 1996, 110 Stat. 1836, provided that: “The amendment made by this section [amending this section] shall apply to amounts included in gross income in any taxable year beginning after December 31, 1995.”

Pub. L. 103–66, title XIII, § 13145(b), Aug. 10, 1993, 107 Stat. 443, provided that: “The amendments made by subsection (a) [amending this section] shall apply to partnership years beginning on or after January 1, 1994.”

Pub. L. 103–66, title XIII, § 13147(b), Aug. 10, 1993, 107 Stat. 444, provided that: “The amendment made by subsection (a) [amending this section] shall apply to property acquired on or after January 1, 1994.”

Pub. L. 103–66, title XIII, § 13148(c), Aug. 10, 1993, 107 Stat. 444, provided that: “The amendments made by this section [amending this section] shall apply to amounts received on or after January 1, 1994.”

Amendment by 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.

Pub. L. 100–203, title X, § 10213(b), Dec. 22, 1987, 101 Stat. 1330–407, provided that: “The amendment made by subsection (a) [amending this section] shall apply to partnership interests acquired after December 17, 1987.”

Amendment by Pub. L. 99–514 effective, except as otherwise provided, as if included in the provisions of the Tax Reform Act of 1984, Pub. L. 98–369, div. A, to which such amendment relates, see section 1881 of Pub. L. 99–514, set out as a note under section 48 of this title.

Amendment by Pub. L. 98–369 applicable to taxable years ending after Dec. 31, 1985, with such amendments treated as a change in the rate of tax imposed by chapter 1 of this title for purposes of section 15 of this title, see section 511(e)(6) of Pub. L. 98–369, set out as an Effective Date note under section 419 of this title.

Amendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.

Amendment by Pub. L. 95–345 applicable with respect to amounts received after Dec. 31, 1976, as payments with respect to securities loans (as defined in subsec. (a)(5) of this section), and transfers of securities, under agreements described in section 1058 of this title, occurring after such date, see section 2(e) of Pub. L. 95–345, set out as a note under section 509 of this title.

Amendment by Pub. L. 94–568 applicable to taxable years beginning after Oct. 20, 1976, see section 1(d) of Pub. L. 94–568, set out as a note under section 501 of this title.

Amendment by section 1901(b)(8)(F) of Pub. L. 94–455 applicable with respect to taxable years beginning after Dec. 31, 1976, see section 1901(d) of Pub. L. 94–455, set out as a note under section 2 of this title.

Amendment by section 1951(b)(8)(A) of Pub. L. 94–455 applicable with respect to taxable years beginning after Dec. 31, 1976, see section 1951(d) of Pub. L. 94–455, set out as a note under section 72 of this title.

Pub. L. 94–396, § 1(b), Sept. 3, 1976, 90 Stat. 1201, provided that: “The amendment made by subsection (a) [amending this section] shall apply to gain from options which lapse or terminate on or after January 1, 1976, in taxable years ending on or after such date.”

Amendment by Pub. L. 92–418 applicable to taxable years beginning after Dec. 31, 1969, see section 1(c) of Pub. L. 92–418, set out as a note under section 501 of this title.

Amendment by Pub. L. 91–172 applicable to taxable years beginning after Dec. 31, 1969, see section 121(g) of Pub. L. 91–172, set out as a note under section 511 of this title.

Amendment by Pub. L. 89–809 applicable with respect to taxable years beginning after Dec. 31, 1966, see section 104(n) of Pub. L. 89–809, set out as a note under section 11 of this title.

Pub. L. 88–380, § 2, July 17, 1964, 78 Stat. 333, provided that: “The amendment made by the first section of this Act [amending this section] shall apply with respect to taxable years beginning after December 31, 1963.”

Pub. L. 85–367, § 1(b), Apr. 7, 1958, 72 Stat. 80, provided that: “The amendment made by subsection (a) [amending this section] shall apply to taxable years of trusts beginning after December 31, 1955.”

For provisions that nothing in amendment by section 401(b)(21)(E)–(H) of Pub. L. 115–141 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Mar. 23, 2018, for purposes of determining liability for tax for periods ending after Mar. 23, 2018, see section 401(e) of Pub. L. 115–141, set out as a note under section 23 of this title.

Pub. L. 108–357, title VII, § 702(c), Oct. 22, 2004, 118 Stat. 1546, provided that: “Nothing in the amendments made by this section [amending this section and section 514 of this title] shall affect any duty, liability, or other requirement imposed under any other Federal or State law. Notwithstanding section 128(b) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 [42 U.S.C. 9628(b)], a certification provided by the Environmental Protection Agency or an appropriate State agency (within the meaning of section 198(c)(4) of the Internal Revenue Code of 1986) shall not affect the liability of any person under section 107(a) of such Act [42 U.S.C. 9607(a)].”

For provisions that nothing in amendment by 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 45K of this title.

Pub. L. 94–455, title XIX, § 1951(b)(8)(B), Oct. 4, 1976, 90 Stat. 1839, provided that: “Notwithstanding subparagraph (A) [amending this section], income received in a taxable year beginning after December 31, 1975, shall be excluded from gross income in determining unrelated business taxable income, if such income would have been excluded by paragraph (13) or (14) of section 512(b) if received in a taxable year beginning before such date. Any deductions directly connected with income excluded under the preceding sentence in determining unrelated business taxable income shall also be excluded for such purpose.”

For provisions directing that if any amendments made by subtitle A or subtitle C of title XI [§§ 1101–1147 and 1171–1177] or title XVIII [§§ 1800–1899A] of Pub. L. 99–514 require an amendment to any plan, such plan amendment shall not be required to be made before the first plan year beginning on or after Jan. 1, 1989, see section 1140 of Pub. L. 99–514, as amended, set out as a note under section 401 of this title.