Sec. 8045. Repeal of Puerto Rico and possession tax credit
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Subpart D of part III of subchapter N of chapter 1 is amended by striking section 936 (and by striking the item relating to such section in the table of sections of such subpart). Section 27 is amended to read as follows: The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax imposed by this chapter to the extent provided in section 901. . The item relating to section 27 in the table of sections for subpart B of part IV of subchapter A of chapter 1 is amended to read as follows:
Sec. 27. Taxes of foreign countries and possessions of the United States. . Section 243(b)(1)(B) is amended to read as follows: if such dividend is distributed out of the earnings and profits of a taxable year of the distributing corporation which ends after December 31, 1963, and on each day of which the distributing corporation and the corporation receiving the dividend were members of such affiliated group. . Section 246 is amended by striking subsection (e). Section 338(h)(6)(B)(i) is amended by striking , a DISC, or a corporation to which an election under section 936 applies and inserting or a DISC .
Section 861(a)(2) is amended— by striking subparagraph
(A)and by redesignating subparagraphs (B), (C), and
(D)as subparagraphs (A), (B), and (C), respectively, and by striking subparagraph
(B)each place it appears and inserting subparagraph
(A). Section 864(d)(5) is amended to read as follows: The following provisions shall not apply to any amount treated as interest under paragraph
(1)or (6): Section 904(d)(2)(B)(iii)(I) (relating to exceptions for export financing interest). Subparagraph
(A)of section 954(b)(3) (relating to exception where foreign base company income is less than 5 percent or $1,000,000). Subparagraph
(B)of section 954(c)(2) (relating to certain export financing). Clause
(i)of section 954(c)(3)(A) (relating to certain income received from related persons). . Section 865(j)(3) is amended by striking , 933, and 936 and inserting and 933 . Section 901(g)(2) is amended by inserting (as in effect before its repeal) after 936 . Section 904(b) is amended by striking paragraph (4). Section 1202(e)(4) is amended by striking subparagraph
(B)and by redesignating subparagraphs
(C)and
(D)as subparagraphs
(B)and (C), respectively. Section 1361(b)(2) is amended by adding or at the end of subparagraph (B), by striking subparagraph (C), and by redesignating subparagraph
(D)as subparagraph (C). Section 1504(b) is amended by striking paragraph (4). Section 6091(b)(2)(B) is amended by striking clause
(ii)and by redesignating clauses
(iii)and
(iv)as clauses
(ii)and (iii), respectively. Section 6654(d)(2)(D) is amended— by striking 936(h) or in clause (i), and by striking “ and section ” in the heading. 936 Section 6655(e)(4) is amended— by striking 936(h) or in subparagraph (A), and by striking “ and section ” in the heading. 936 Section 367(d) is amended by adding at the end the following new paragraph: For purposes of this subsection, the term intangible property means any— patent, invention, formula, process, design, pattern, or know-how, copyright, literary, musical, or artistic composition, trademark, trade name, or brand name, franchise, license, or contract, method, program, system, procedure, campaign, survey, study, forecast, estimate, customer list, or technical data, or any similar item, which has substantial value independent of the services of any individual. . Section 367(a)(3)(B)(iv) is amended by striking section 936(h)(3)(B) and inserting subsection (d)(4) . Sections 482 and 1298(e)(2)(A) are each amended by striking section 936(h)(4)(B) and inserting section 367(d)(4) .