Sec. 4103. Passive category income expanded to include other mobile income
545 words·~2 min read·
/bill/113/hr/1/ih/section-4103A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Clause
(i)of section 904(d)(2)(A) is amended by striking and specified passive category income and inserting specified passive category income, foreign base company sales income (as defined in section 954(d)), and foreign base company intangible income (as defined in section 954(f)) . Paragraph
(2)of section 904(d) is amended by striking subparagraphs
(C)and
(D)and by redesignating subparagraphs
(E)through
(K)as subparagraphs
(C)through (I), respectively. Section 904(d)(1)(A) is amended by striking passive category income and inserting mobile category income . Section 904(d)(2)(A)(i), as amended by subsection (a), is amended— by striking in the heading thereof and inserting Passive category income , Mobile category income by striking passive category income and inserting mobile category income , by striking passive income and inserting mobile income , and by striking specified passive category income and inserting specified mobile category income . Section 904(d)(2)(A)(ii) is amended by striking passive category income and inserting mobile category income . Section 904(d)(2)(B) is amended— by striking in the heading thereof and inserting Passive income , Mobile income by striking passive income in clauses (i), (ii), and
(iii)and inserting mobile income , by striking in the heading of clause
(iv)and inserting Specified passive category income , and Specified mobile category income by striking specified passive category income in clause
(iv)and inserting specified mobile category income . Section 904(d)(2)(D), as redesignated by subsection (b), is amended by striking passive income and inserting mobile income . Section 904(d)(3)(A) is amended by striking passive category income and inserting mobile category income . Section 904(d)(3)(B) is amended by striking passive category income both places it appears and inserting mobile category income . Section 904(d)(3)(C) is amended by striking passive category income both places it appears and inserting mobile category income . Section 904(d)(3)(D) is amended by striking passive category income both places it appears and inserting mobile category income . Section 904(d)(3)(E) is amended— by striking passive category income both places it appears and inserting mobile category income , and by striking passive income and inserting mobile income . Section 904(d)(3)(F) is amended by striking passive category income both places it appears and inserting mobile category income . Subparagraph
(B)of section 864(f)(5) is amended by inserting (as in effect before its repeal) after section 904(d)(2)(D)(ii) . Subparagraph
(B)of section 954(c)(2) is amended by striking section 904(d)(2)(G) and inserting section 904(d)(2)(E) . The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2014, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. For purposes of section 904 of the Internal Revenue Code of 1986— the amendments made by this section shall apply to any taxes carried from any taxable year beginning before January 1, 2015, to any taxable year beginning on or after such date, and the Secretary of the Treasury, or his designee, may by regulations provide for the allocation of any carryback of taxes with respect to income from a taxable year beginning on or after January 1, 2015, to a taxable year beginning before such date for purposes of allocating such income among the separate categories in effect under section 904(d) for the taxable year to which carried.