Sec. 14302. Separate foreign tax credit limitation basket for foreign branch income

167 words·~1 min read·/bill/115/hr/1/eas/section-14302

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Section 904(d)(1), as amended by section 14201, is amended by redesignating subparagraphs

(B)and

(C)as subparagraphs

(C)and (D), respectively, and by inserting after subparagraph

(A)the following new subparagraph: foreign branch income, . Section 904(d)(2) is amended by inserting after subparagraph

(I)the following new subparagraph: The term foreign branch income means the business profits of such United States person which are attributable to 1 or more qualified business units (as defined in section 989(a)) in 1 or more foreign countries. For purposes of the preceding sentence, the amount of business profits attributable to a qualified business unit shall be determined under rules established by the Secretary. Such term shall not include any income which is passive category income. . Section 904(d)(2)(A)(ii), as amended by section 14201, is amended by striking income described in paragraph (1)(A) and and inserting income described in paragraph (1)(A), foreign branch income, and . The amendments made by this section shall apply to taxable years beginning after December 31, 2017.