Sec. 125. Repeal of check-the-box rules for certain foreign entities and CFC look-thru rules
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(3)of section 7701(a) is amended— by striking and , and by inserting after insurance companies the following: , and any foreign business entity that— has a single owner that does not have limited liability, or has one or more members all of which have limited liability . Subparagraph
(C)of section 954(c)(6) is amended to read as follows: Subparagraph
(A)shall not apply to dividends, interest, rents, and royalties received or accrued after the date of the enactment of the CUT Loopholes Act. .