S.Amdt. 1757

SA 1757. Mr. CASSIDY (for himself and Mr. Roberts) 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 421, strike lines 15 through 21 and insert the
following:
``(o) Regulations.--The Secretary shall prescribe such
regulations or other guidance as may be necessary or
appropriate to carry out the provisions of this section or to
prevent the avoidance of the purposes of this section,
including through a reduction in earnings and profits through
changes in entity classification, changes in accounting
methods, or otherwise.
``(p) Inclusion of Deferred Foreign Income Under This
Section Not to Trigger Recapture of Overall Foreign Loss.--
For purposes of sections 904(f)(1) and 907(c)(4), in the case
of a United States shareholder of a deferred foreign income
corporation, such United States shareholder's taxable income
from sources without the United States and combined foreign
oil and gas income shall be determined without regard to this
section.''.
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