§14301

2054, 2221 (2017). 8 chain, and (iii) such other corporation is not below the sixth tier in such chain. § 902(b)(2). Relatedly, section 951(b) defines United States shareholder to mean, “with respect to any foreign corporation, a United States person (as defined in section 957(c)) who owns . . . 10 percent or more of the total c

Congress could have included in TCJA § 14101 a similar, modest amendment to section 78 with an effective date matching that of section 245A, while leaving the more substantive amendments for TCJA § 14301 with an effective date that matched the repeal of section 902 and the amendments to section 960, but it followed a different path.