Page 167 - Tax Reform

PUBLIC LAW 115–97—DEC. 22, 2017 131 STAT. 2217

(1) Section 952(c)(1)(B)(iii) is amended by striking subclause 26 USC 952.
(I) and redesignating subclauses (II) through (V) as subclauses
(I) through (IV), respectively.
(2) Section 954(b) is amended—
(A) by striking the second sentence of paragraph (4),
(B) by striking ‘‘the foreign base company services
income, and the foreign base company oil related income’’
in paragraph (5) and inserting ‘‘and the foreign base com-
pany services income’’, and
(C) by striking paragraph (6).
(3) Section 954 is amended by striking subsection (g).
(c) EFFECTIVE DATE.—The amendments made by this section 26 USC 952 note.
shall apply to taxable years of foreign corporations beginning after
December 31, 2017, and to taxable years of United States share-
holders with or within which such taxable years of foreign corpora-
tions end.
SEC. 14212. REPEAL OF INCLUSION BASED ON WITHDRAWAL OF PRE-
VIOUSLY EXCLUDED SUBPART F INCOME FROM QUALI-
FIED INVESTMENT.
(a) IN GENERAL.—Subpart F of part III of subchapter N of
chapter 1 is amended by striking section 955.
(b) CONFORMING AMENDMENTS.—
(1)(A) Section 951(a)(1)(A) is amended to read as follows:
‘‘(A) his pro rata share (determined under paragraph
(2)) of the corporation’s subpart F income for such year,
and’’.
(B) Section 851(b) is amended by striking ‘‘section
951(a)(1)(A)(i)’’ in the flush language at the end and inserting
‘‘section 951(a)(1)(A)’’.
(C) Section 952(c)(1)(B)(i) is amended by striking ‘‘section
951(a)(1)(A)(i)’’ and inserting ‘‘section 951(a)(1)(A)’’.
(D) Section 953(c)(1)(C) is amended by striking ‘‘section
951(a)(1)(A)(i)’’ and inserting ‘‘section 951(a)(1)(A)’’.
(2) Section 951(a) is amended by striking paragraph (3).
(3) Section 953(d)(4)(B)(iv)(II) is amended by striking ‘‘or
amounts referred to in clause (ii) or (iii) of section 951(a)(1)(A)’’.
(4) Section 964(b) is amended by striking ‘‘, 955,’’.
(5) Section 970 is amended by striking subsection (b).
(6) The table of sections for subpart F of part III of sub-
chapter N of chapter 1 is amended by striking the item relating 26 USC 951 prec.
to section 955.
(c) EFFECTIVE DATE.—The amendments made by this section 26 USC 851 note.
shall apply to taxable years of foreign corporations beginning after
December 31, 2017, and to taxable years of United States share-
holders in which or with which such taxable years of foreign corpora-
tions end.
SEC. 14213. MODIFICATION OF STOCK ATTRIBUTION RULES FOR
DETERMINING STATUS AS A CONTROLLED FOREIGN
CORPORATION.
(a) IN GENERAL.—Section 958(b) is amended—
(1) by striking paragraph (4), and
(2) by striking ‘‘Paragraphs (1) and (4)’’ in the last sentence
and inserting ‘‘Paragraph (1)’’.
dkrause on DSKBC28HB2PROD with PUBLAWS VerDate Sep 11 2014 10:09 Oct 18, 2018 Jkt 079139 PO 00097 Frm 00165 Fmt 6580 Sfmt 6581 E:\PUBLAW\PUBL097.115 PUBL097
(b) EFFECTIVE DATE.—The amendments made by this section 26 USC 958 note.
shall apply to—