S.Amdt. 1820

SA 1820. Mr. HATCH 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:

At the end of subpart D of part VII of subtitle C of title
I, add the following:

[[Page S7724]]

SEC. 13543. MODIFICATION OF TREATMENT OF S CORPORATION
CONVERSIONS TO C CORPORATIONS.

(a) In General.--Section 1371 is amended by adding at the
end the following new subsection:
``(f) Cash Distributions Following Post-termination
Transition Period.--
``(1) In general.--In the case of a distribution of money
by an eligible terminated S corporation after the post-
termination transition period, the accumulated adjustments
account shall be allocated to such distribution, and the
distribution shall be chargeable to accumulated earnings and
profits, in the same ratio as the amount of such accumulated
adjustments account bears to the amount of such accumulated
earnings and profits.
``(2) Eligible terminated s corporation.--For purposes of
this subsection, the term `eligible terminated S corporation'
means any C corporation--
``(A) which--
``(i) was an S corporation on the day before the date of
the enactment of the Tax Cuts and Jobs Act, and
``(ii) during the 2-year period beginning on the date of
such enactment makes a revocation of its election under
section 1362(a), and
``(B) the owners of the stock of which, determined on the
date such revocation is made, are the same owners (and in
identical proportions) as on the date of such enactment.''.
(b) Effective Date.--The amendments made by this sectin
shall apply to distributions after the date of the enactment
of this Act.
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