Sec. 221. Repeal of exclusion of foreign oil and gas extraction income from the determination of tested income
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Section 951A(c)(2)(A)(i) of the Internal Revenue Code of 1986 is amended— by adding and at the end of subclause (III), by striking and at the end of subclause
(IV)and inserting over , and by striking subclause (V). The amendments made by this section shall apply to taxable years of foreign corporations beginning after the date of enactment of this Act, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.