S.Amdt. 1603

SA 1603. Mr. INHOFE submitted an amendment intended to be proposed by
him to the bill H.R. 1, to provide for reconciliation pursuant to
titles II and V of the concurrent resolution on the budget for fiscal
year 2018; which was ordered to lie on the table; as follows:

On page __, strike line __, and insert the following:
``(9) Safe harbor for domestic members of worldwide
affiliated group.--
``(A) In general.--In the case of a taxpayer which is a
domestic corporation which is a member of a worldwide
affiliated group, this subsection shall not apply to such
taxpayer if the ratio of debt to equity of all domestic
corporations which are members of such group does not exceed
such ratio of all corporations which are members of such
group.
``(B) Ratio of debt to equity.--For purposes of this
paragraph, the ratio of debt to equity means the ratio which
total indebtedness bears to total equity, determined in the
same manner as subsection (n).
``(C) Definition and special rule.--For purposes of this
paragraph--
``(i) Worldwide affiliated group.--The term `worldwide
affiliated group' has the same meaning given such term by
subsection (n)(4)(A).
``(ii) Domestic members of affiliated group treated as 1
taxpayer.--The rule of subsection (n)(5) shall apply.
``(10) Cross references.--
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