S.Amdt. 1666

SA 1666. Mr. PERDUE submitted an amendment intended to be proposed to
amendment SA 1618 proposed by Mr. McConnell (for Mr. Hatch (for himself
and Ms. Murkowski)) 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:

In Section 14214 of the Act strike (b) and insert:
``(b) Limited Attribution Under Section 318(a)(3).
(1) In general. Notwithstanding subsection (a), a foreign
corporation shall not be considered a controlled foreign
corporation with respect to a United States shareholder if
the ownership requirements of subsection (a) would not be
satisfied with respect to such foreign corporation but for
the attribution under section 318(a)(3) (pursuant to section
958(b)) of ownership to a United States person that is not a
related person with respect to such United States
shareholder.
(2) Related person. For purposes of this subsection, the
term ``related person'' has the meaning given such term by
section 954(d)(3), except that such section shall be applied
by substituting ``United States Shareholder'' for
``controlled foreign corporation'' each place it appears.
(c) Effective Date.--The amendments made by this section
shall apply to--
(1) the last taxable year of foreign corporations beginning
before January 1, 2018, and each subsequent taxable year of
such foreign corporations, and
(2) taxable years of United States shareholders in which or
with which such taxable years of foreign corporations end.
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