Sec. 4202. Foreign base company sales income

181 words·~1 min read·/bill/113/hr/1/ih/section-4202

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Subparagraph

(B)of section 954(a)(1), as amended by the preceding provisions of this Act, is amended by inserting 50 percent of before the foreign base company sales income . Section 960, as amended by this Act, is amended by redesignating subsection

(c)as subsection

(d)and by inserting after subsection

(b)the following new subsection: Solely for purposes of subsection (a), section 954(a)(1)(B) shall be applied by substituting 100 percent for 50 percent in determining amounts included under section 951(a)(1). . Section 954(d) is amended by adding at the end the following new paragraph: No portion of the gross income of a controlled foreign corporation shall be treated as foreign base company sales income if such controlled foreign corporation is eligible as a qualified resident for all of the benefits provided under a comprehensive income tax treaty with the United States. . 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.