Sec. 104. Special rules for transfers of intangible property relating to medical personal protective equipment to United States shareholders
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Subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: Except as otherwise provided by the Secretary, if a controlled foreign corporation holds qualified intangible property on the date of the enactment of this section and thereafter distributes such property to a domestic corporation which is a United States shareholder with respect to such controlled foreign corporation— for purposes of part I of subchapter C and any other provision of this title specified by the Secretary, the fair market value of such property on the date of such distribution shall be treated as not exceeding the adjusted basis of such property immediately before such distribution, and if any portion of such distribution is not a dividend— no gain shall be recognized by such United States shareholder with respect to such distribution, and the adjusted basis of such property in the hands of such United States shareholder immediately after such distribution shall be the adjusted basis of such property in the hands of such controlled foreign corporation immediately before such distribution reduced by the amount (if any) of gain not recognized by reason of subparagraph
(A)(determined after the application of paragraph (1)). For purposes of this section, the term qualified intangible property means any property described in section 367(d)(4)(A)— the principal purpose of which is use in connection with— any eligible property, as defined in section 48D(c)(2), or any item or product described in subclause
(I)or
(II)of section 48D(c)(1)(A)(i), or substantially all of the income from which is derived in connection with any eligible property (as defined in section 48D(c)(2)) or any item or product described in paragraph (1)(B). The Secretary shall prescribe such regulations or other guidance as may be necessary to carry out the purposes of this section, including to prevent abuse by taxpayers related to distributions of qualified intangible property. . Section 197(f)(2)(B)(i) of the Internal Revenue Code of 1986 is amended by inserting 966(a), after 731, . The table of sections for subpart F of part III of subchapter N of chapter 1 of such Code is amended by adding at the end the following new item: Sec. 966. Transfers of intangible property relating to medical personal protective equipment to United States shareholders. . The amendments made by this section shall apply to distributions made on or after the date of enactment of this Act.