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131 STAT. 2192 PUBLIC LAW 115–97—DEC. 22, 2017 Any term which is used in section 245A and in this paragraph shall have the same meaning for purposes of this paragraph as when used in such section.’’. (e) CONFORMING AMENDMENTS.— (1) Subsection (b) of section 951 is amended by striking ‘‘subpart’’ and inserting ‘‘title’’. (2) Subsection (a) of section 957 is amended by striking ‘‘subpart’’ in the matter preceding paragraph (1) and inserting ‘‘title’’. (3) The table of sections for part VIII of subchapter B of chapter 1 is amended by inserting after the item relating to section 245 the following new item: ‘‘Sec. 245A. Deduction for foreign source-portion of dividends received by domestic corporations from certain 10-percent owned foreign corporations.’’. (f) EFFECTIVE DATE.—The amendments made by this section shall apply to distributions made after (and, in the case of the amendments made by subsection (d), deductions with respect to taxable years ending after) December 31, 2017. SEC. 14102. SPECIAL RULES RELATING TO SALES OR TRANSFERS INVOLVING SPECIFIED 10-PERCENT OWNED FOREIGN CORPORATIONS. (a) SALES BY UNITED STATES PERSONS OF STOCK.— (1) IN GENERAL.—Section 1248 is amended by redesignating subsection (j) as subsection (k) and by inserting after subsection (i) the following new subsection: ‘‘(j) COORDINATION WITH DIVIDENDS RECEIVED DEDUCTION.— In the case of the sale or exchange by a domestic corporation of stock in a foreign corporation held for 1 year or more, any amount received by the domestic corporation which is treated as a dividend by reason of this section shall be treated as a dividend for purposes of applying section 245A.’’. (2) EFFECTIVE DATE.—The amendments made by this sub- section shall apply to sales or exchanges after December 31, 2017. (b) BASIS IN SPECIFIED 10-PERCENT OWNED FOREIGN CORPORA- TION REDUCED BY NONTAXED PORTION OF DIVIDEND FOR PURPOSES OF DETERMINING LOSS.— (1) IN GENERAL.—Section 961 is amended by adding at the end the following new subsection: ‘‘(d) BASIS IN SPECIFIED 10-PERCENT OWNED FOREIGN CORPORA- TION REDUCED BY NONTAXED PORTION OF DIVIDEND FOR PURPOSES OF DETERMINING LOSS.—If a domestic corporation received a divi- dend from a specified 10-percent owned foreign corporation (as defined in section 245A) in any taxable year, solely for purposes of determining loss on any disposition of stock of such foreign corporation in such taxable year or any subsequent taxable year, the basis of such domestic corporation in such stock shall be reduced (but not below zero) by the amount of any deduction allowable to such domestic corporation under section 245A with respect to such stock except to the extent such basis was reduced under section 1059 by reason of a dividend for which such a deduction was allowable.’’. (2) EFFECTIVE DATE.—The amendments made by this sub- section shall apply to distributions made after December 31, 2017. (c) SALE BY A CFC OF A LOWER TIER CFC.— 26 USC 961 note. 26 USC 1248 note. 26 USC 245A note. 26 USC 241 prec. 26 USC 951. VerDate Sep 11 2014 10:09 Oct 18, 2018 Jkt 079139 PO 00097 Frm 00140 Fmt 6580 Sfmt 6581 E:\PUBLAW\PUBL097.115 PUBL097 dkrause on DSKBC28HB2PROD with PUBLAWS