1 So in original. Probably should be “10-percent”.
owned foreign corporation through a partnership.Statutory Notes and Related Subsidiaries
Effective Date
Puspan. L. 115–97, title I, § 14101(f), Dec. 22, 2017, 131 Stat. 2192, provided that:
“The amendments made by this section [enacting this section and amending sections 246, 904, 951, 957, and 1059 of this title] shall apply to distributions made after (and, in the case of the amendments made by subsection (d) [amending section 904 of this title], deductions with respect to taxable years ending after) December 31, 2017.”