[Congressional Record Volume 163, Number 195 (Thursday, November 30, 2017)]
[Senate]
[Page S7573]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  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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