26 U.S.C. § 951B: Amounts included in gross income of foreign controlled United States shareholders

by substituting “foreign controlled United States shareholder” for “United States shareholder” each place it appears therein, and by substituting “foreign controlled foreign corporation” for “controlled foreign corporation” each place it appears therein, and by treating each reference to “United States shareholder” in such section as including a reference to such shareholder, and by treating each reference to “controlled foreign corporation” in such section as including a reference to such foreign controlled foreign corporation. section 951(b) were applied by substituting “more than 50 percent” for “10 percent or more”, and section 958(b) were applied without regard to paragraph (4) thereof. by substituting “foreign controlled United States shareholders” for “United States shareholders”, and by substituting “section 958(b) (other than paragraph (4) thereof)” for “section 958(b)”. to treat a foreign controlled United States shareholder or a foreign controlled foreign corporation as a United States shareholder or as a controlled foreign corporation, respectively, for purposes of provisions of this title other than this subpart (including any reporting requirement), and with respect to the treatment of foreign controlled foreign corporations that are passive foreign investment companies (as defined in section 1297). Except to the extent provided by the Secretary of the Treasury (or the Secretary’s delegate), the effective date of any amendment to the Internal Revenue Code of 1986 shall be applied by treating references to United States shareholders as including references to foreign controlled United States shareholders, and by treating references to controlled foreign corporations as including references to foreign controlled foreign corporations. Any term used in paragraph (1) which is used in subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code of 1986 (as amended by this section) shall have the meaning given such term in such subpart.”