Page 173 - Tax Reform

PUBLIC LAW 115–97—DEC. 22, 2017 131 STAT. 2223

(12) Section 901(k)(2) is amended by striking ‘‘, 902,’’. 26 USC 901.
(13) Section 901(k)(6) is amended by striking ‘‘902 or’’.
(14) Section 901(m)(1)(B) is amended to read as follows:
‘‘(B) in the case of a foreign income tax paid by a
foreign corporation, shall not be taken into account for
purposes of section 960.’’.
(15) Section 904(d)(2)(E) is amended—
(A) by amending clause (i) to read as follows:
‘‘(i) NONCONTROLLED 10-PERCENT OWNED FOREIGN
CORPORATION.—The term ‘noncontrolled 10-percent
owned foreign corporation’ means any foreign corpora-
tion which is—
‘‘(I) a specified 10-percent owned foreign cor-
poration (as defined in section 245A(b)), or
‘‘(II) a passive foreign investment company (as
defined in section 1297(a)) with respect to which
the taxpayer meets the stock ownership require-
ments of section 902(a) (or, for purposes of applying
paragraphs (3) and (4), the requirements of section
902(b)).
A controlled foreign corporation shall not be treated
as a noncontrolled 10-percent owned foreign corpora-
tion with respect to any distribution out of its earnings
and profits for periods during which it was a controlled
foreign corporation. Any reference to section 902 in
this clause shall be treated as a reference to such
section as in effect before its repeal.’’, and
(B) by striking ‘‘non-controlled section 902 corporation’’
in clause (ii) and inserting ‘‘noncontrolled 10-percent owned
foreign corporation’’.
(16) Section 904(d)(4) is amended—
(A) by striking ‘‘noncontrolled section 902 corporation’’
each place it appears and inserting ‘‘noncontrolled 10-per-
cent owned foreign corporation’’,
(B) by striking ‘‘NONCONTROLLED SECTION 902 CORPORA-
TIONS’’ in the heading thereof and inserting ‘‘NONCON-
TROLLED 10-PERCENT OWNED FOREIGN CORPORATIONS’’.
(17) Section 904(d)(6)(A) is amended by striking ‘‘902, 907,’’
and inserting ‘‘907’’.
(18) Section 904(h)(10)(A) is amended by striking ‘‘sections
902, 907, and 960’’ and inserting ‘‘sections 907 and 960’’.
(19) Section 904(k) is amended to read as follows:
‘‘(k) CROSS REFERENCES.—For increase of limitation under sub-
section (a) for taxes paid with respect to amounts received which
were included in the gross income of the taxpayer for a prior
taxable year as a United States shareholder with respect to a
controlled foreign corporation, see section 960(c).’’.
(20) Section 905(c)(1) is amended by striking the last sen-
tence.
(21) Section 905(c)(2)(B)(i) is amended to read as follows:
‘‘(i) shall be taken into account for the taxable
year to which such taxes relate, and’’.
(22) Section 906(a) is amended by striking ‘‘(or deemed,
under section 902, paid or accrued during the taxable year)’’.
(23) Section 906(b) is amended by striking paragraphs (4)
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and (5).
(24) Section 907(b)(2)(B) is amended by striking ‘‘902 or’’.