S.Amdt. 1726

SA 1726. Mr. RISCH (for himself and Mr. Crapo) 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:

On page 402, strike lines 12 through 24 and insert the
following:
``(2) Accumulated post-1986 deferred foreign income.--The
term `accumulated post-1986 deferred foreign income' means
post-1986 earnings and profits--
``(A) except to the extent such earnings--
``(i) are attributable to income of the specified foreign
corporation which is effectively connected with the conduct
of a trade or business within the United States and subject
to tax under this chapter, or
``(ii) in the case of a controlled foreign corporation, if
distributed, would be excluded from the gross income of a
United States shareholder under section 959, and
``(B) reduced by the amount of deductions recognized by a
specified foreign corporation in taxable years beginning
after December 31, 2017, with respect to income recognized by
a United States shareholder in taxable years beginning before
December 31, 2017.

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