Paragraph 8

Section 434 (elections under section 433) is amended as follows.

In subsection (1)(a), for “the beginning” substitute “ the end ”.

In subsection (5), after paragraph (a) (but before the “and” at the end of it) insert—

“(ab)

the time of the transfer falls in a period of account of a worldwide group of which both the transferor and transferee are members,”.