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131 STAT. 2224 PUBLIC LAW 115–97—DEC. 22, 2017 (25) Section 907(c)(3)(A) is amended— (A) by striking subparagraph (A) and inserting the following: ‘‘(A) interest, to the extent the category of income of such interest is determined under section 904(d)(3),’’, and (B) by striking ‘‘section 960(a)’’ in subparagraph (B) and inserting ‘‘section 960’’. (26) Section 907(c)(5) is amended by striking ‘‘902 or’’. (27) Section 907(f)(2)(B)(i) is amended by striking ‘‘902 or’’. (28) Section 908(a) is amended by striking ‘‘902 or’’. (29) Section 909(b) is amended— (A) by striking ‘‘section 902 corporation’’ in the matter preceding paragraph (1) and inserting ‘‘specified 10-percent owned foreign corporation (as defined in section 245A(b) without regard to paragraph (2) thereof)’’, (B) by striking ‘‘902 or’’ in paragraph (1), (C) by striking ‘‘by such section 902 corporation’’ and all that follows in the matter following paragraph (2) and inserting ‘‘by such specified 10-percent owned foreign cor- poration or a domestic corporation which is a United States shareholder with respect to such specified 10-percent owned foreign corporation.’’, and (D) by striking ‘‘SECTION 902 CORPORATIONS’’ in the heading thereof and inserting ‘‘SPECIFIED 10-PERCENT OWNED FOREIGN CORPORATIONS’’. (30) Section 909(d) is amended by striking paragraph (5). (31) Section 958(a)(1) is amended by striking ‘‘960(a)(1)’’ and inserting ‘‘960’’. (32) Section 959(d) is amended by striking ‘‘Except as pro- vided in section 960(a)(3), any’’ and inserting ‘‘Any’’. (33) Section 959(e) is amended by striking ‘‘section 960(b)’’ and inserting ‘‘section 960(c)’’. (34) Section 1291(g)(2)(A) is amended by striking ‘‘any dis- tribution—’’ and all that follows through ‘‘but only if’’ and inserting ‘‘any distribution, any withholding tax imposed with respect to such distribution, but only if’’. (35) Section 1293(f) is amended by striking ‘‘and’’ at the end of paragraph (1), by striking the period at the end of paragraph (2) and inserting ‘‘, and’’, and by adding at the end the following new paragraph: ‘‘(3) a domestic corporation which owns (or is treated under section 1298(a) as owning) stock of a qualified electing fund shall be treated in the same manner as a United States share- holder of a controlled foreign corporation (and such qualified electing fund shall be treated in the same manner as such controlled foreign corporation) if such domestic corporation meets the stock ownership requirements of subsection (a) or (b) of section 902 (as in effect before its repeal) with respect to such qualified electing fund.’’. (36) Section 6038(c)(1)(B) is amended by striking ‘‘sections 902 (relating to foreign tax credit for corporate stockholder in foreign corporation) and 960 (relating to special rules for foreign tax credit)’’ and inserting ‘‘section 960’’. (37) Section 6038(c)(4) is amended by striking subpara- graph (C). 26 USC 907. VerDate Sep 11 2014 10:09 Oct 18, 2018 Jkt 079139 PO 00097 Frm 00172 Fmt 6580 Sfmt 6581 E:\PUBLAW\PUBL097.115 PUBL097 dkrause on DSKBC28HB2PROD with PUBLAWS