[Congressional Record Volume 163, Number 196 (Friday, December 1, 2017)]
[Senate]
[Pages S7723-S7724]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  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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