§13232

13232(a), 107 Stat. at 501. As in effect before 1993, former section 956(a)(2) determined the U.S. - 50 - shareholder's section 951(a) inclusion by reference to "the increase" ofa CFC's earnings invested in U.S. property. For the tax years at issue here, section 956(a) determined that inclusion, as noted above, by reference to the amount ofU.

13232(a) (1) and (2), 107 Stat. 501 (the 1993 legislation). The legislative 5(...continued) dividends for reasons apart from the operation of secs. 951 and 956. In any event, Gulf Oil was decided under the pre-1993 version of sec. 956(a), which, as discussed infra, differed materially from the versionjof sec. 956( ) in effect for the years at