Page 115 - Tax Reform

PUBLIC LAW 115–97—DEC. 22, 2017 131 STAT. 2165

purposes of implementing the requirements of paragraph (2)(C)(i)(II)
of section 83(i) of the Internal Revenue Code of 1986 (as added
by this section), or the requirements of paragraph (6) of such
section, a corporation shall be treated as being in compliance with
such requirements (respectively) if such corporation complies with
a reasonable good faith interpretation of such requirements.
SEC. 13604. INCREASE IN EXCISE TAX RATE FOR STOCK COMPENSA-
TION OF INSIDERS IN EXPATRIATED CORPORATIONS.
(a) IN GENERAL.—Section 4985(a)(1) is amended by striking 26 USC 4985.
‘‘section 1(h)(1)(C)’’ and inserting ‘‘section 1(h)(1)(D)’’.
(b) EFFECTIVE DATE.—The amendment made by this section 26 USC 4985
shall apply to corporations first becoming expatriated corporations note.
(as defined in section 4985 of the Internal Revenue Code of 1986)
after the date of enactment of this Act.
Subpart B—Retirement Plans
SEC. 13611. REPEAL OF SPECIAL RULE PERMITTING RECHARACTER-
IZATION OF ROTH CONVERSIONS.
(a) IN GENERAL.—Section 408A(d)(6)(B) is amended by adding
at the end the following new clause:
‘‘(iii) CONVERSIONS.—Subparagraph (A) shall not
apply in the case of a qualified rollover contribution
to which subsection (d)(3) applies (including by reason
of subparagraph (C) thereof).’’.
(b) EFFECTIVE DATE.—The amendments made by this section 26 USC 408A
shall apply to taxable years beginning after December 31, 2017. note.
SEC. 13612. MODIFICATION OF RULES APPLICABLE TO LENGTH OF
SERVICE AWARD PLANS.
(a) MAXIMUM DEFERRAL AMOUNT.—Clause (ii) of section
457(e)(11)(B) is amended by striking ‘‘$3,000’’ and inserting
‘‘$6,000’’.
(b) COST OF LIVING ADJUSTMENT.—Subparagraph (B) of section
457(e)(11) is amended by adding at the end the following:
‘‘(iii) COST OF LIVING ADJUSTMENT.—In the case
of taxable years beginning after December 31, 2017,
the Secretary shall adjust the $6,000 amount under
clause (ii) at the same time and in the same manner
as under section 415(d), except that the base period
shall be the calendar quarter beginning July 1, 2016,
and any increase under this paragraph that is not
a multiple of $500 shall be rounded to the next lowest
multiple of $500.’’.
(c) APPLICATION OF LIMITATION ON ACCRUALS.—Subparagraph
(B) of section 457(e)(11), as amended by subsection (b), is amended
by adding at the end the following:
‘‘(iv) SPECIAL RULE FOR APPLICATION OF LIMITATION
ON ACCRUALS FOR CERTAIN PLANS.—In the case of a
plan described in subparagraph (A)(ii) which is a
defined benefit plan (as defined in section 414(j)), the
limitation under clause (ii) shall apply to the actuarial
present value of the aggregate amount of length of
service awards accruing with respect to any year of
service. Such actuarial present value with respect to
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any year shall be calculated using reasonable actuarial
assumptions and methods, assuming payment will be