This provision in Code Sec. 1411 and the proposed regulations thereunder has catalyzed an abundance of reaction by taxpayers and tax professionals who claim this additional requirement is creates an unnecessary burden for real estate professionals.

FORBES: Not so Fast: an Additional Obstacle for Real Estate Professional in the 3.8% Medicare Surtax

In other words, after universities like Harvard and Stanford had gone to the trouble setting up reciprocal or unilateral exchange programs and had reserved thereunder a number of positions for students from Japan, the Japanese university was failing to produce the students.

FORBES: Fewer Japanese Students Studying Abroad

Section 604 of the 1974 Act authorizes the President to embody in the HTS the substance of relevant provisions of chapter V of that Act, and of other Acts affecting import treatment, and of actions taken thereunder, including the removal, modification, continuance, or imposition of any rate of duty or other import restriction.

WHITEHOUSE: The White House

Section 604 of the 1974 Act (19 U.S.C. 2483) authorizes the President to embody in the HTS the substance of the relevant provisions of that Act, and of other acts affecting import treatment, and actions taken thereunder, including the removal, modification, continuance, or imposition of any rate of duty or other import restriction.

WHITEHOUSE: The White House