Page 174 - Tax Reform

131 STAT. 2224 PUBLIC LAW 115–97—DEC. 22, 2017

26 USC 907. (25) Section 907(c)(3)(A) is amended—
(A) by striking subparagraph (A) and inserting the
following:
‘‘(A) interest, to the extent the category of income of
such interest is determined under section 904(d)(3),’’, and
(B) by striking ‘‘section 960(a)’’ in subparagraph (B)
and inserting ‘‘section 960’’.
(26) Section 907(c)(5) is amended by striking ‘‘902 or’’.
(27) Section 907(f)(2)(B)(i) is amended by striking ‘‘902
or’’.
(28) Section 908(a) is amended by striking ‘‘902 or’’.
(29) Section 909(b) is amended—
(A) by striking ‘‘section 902 corporation’’ in the matter
preceding paragraph (1) and inserting ‘‘specified 10-percent
owned foreign corporation (as defined in section 245A(b)
without regard to paragraph (2) thereof)’’,
(B) by striking ‘‘902 or’’ in paragraph (1),
(C) by striking ‘‘by such section 902 corporation’’ and
all that follows in the matter following paragraph (2) and
inserting ‘‘by such specified 10-percent owned foreign cor-
poration or a domestic corporation which is a United States
shareholder with respect to such specified 10-percent owned
foreign corporation.’’, and
(D) by striking ‘‘SECTION 902 CORPORATIONS’’ in the
heading thereof and inserting ‘‘SPECIFIED 10-PERCENT
OWNED FOREIGN CORPORATIONS’’.
(30) Section 909(d) is amended by striking paragraph (5).
(31) Section 958(a)(1) is amended by striking ‘‘960(a)(1)’’
and inserting ‘‘960’’.
(32) Section 959(d) is amended by striking ‘‘Except as pro-
vided in section 960(a)(3), any’’ and inserting ‘‘Any’’.
(33) Section 959(e) is amended by striking ‘‘section 960(b)’’
and inserting ‘‘section 960(c)’’.
(34) Section 1291(g)(2)(A) is amended by striking ‘‘any dis-
tribution—’’ and all that follows through ‘‘but only if’’ and
inserting ‘‘any distribution, any withholding tax imposed with
respect to such distribution, but only if’’.
(35) Section 1293(f) is amended by striking ‘‘and’’ at the
end of paragraph (1), by striking the period at the end of
paragraph (2) and inserting ‘‘, and’’, and by adding at the
end the following new paragraph:
‘‘(3) a domestic corporation which owns (or is treated under
section 1298(a) as owning) stock of a qualified electing fund
shall be treated in the same manner as a United States share-
holder of a controlled foreign corporation (and such qualified
electing fund shall be treated in the same manner as such
controlled foreign corporation) if such domestic corporation
meets the stock ownership requirements of subsection (a) or
(b) of section 902 (as in effect before its repeal) with respect
to such qualified electing fund.’’.
(36) Section 6038(c)(1)(B) is amended by striking ‘‘sections
902 (relating to foreign tax credit for corporate stockholder
in foreign corporation) and 960 (relating to special rules for
foreign tax credit)’’ and inserting ‘‘section 960’’.
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(37) Section 6038(c)(4) is amended by striking subpara-
graph (C).