Sec. 104. Repeal of check-the-box rules for certain foreign entities and CFC look-thru rules
127 words·~1 min read·
/bill/115/s/851/is/section-104A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Paragraph
(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 Stop Tax Haven Abuse Act . . The amendments made by subsection
(a)shall take effect on the date of the enactment of this Act. The amendment made by subsection
(b)shall apply to payments received after the date of the enactment of this Act.