MODIFICATION OF TREATMENT OF S CORPORATION CONVERSIONS TO C CORPORATIONS.

SEC. 13543. MODIFICATION OF TREATMENT OF S CORPORATION CONVERSIONS TO C CORPORATIONS.(a) Adjustments Attributable to Conversion From S Corporation to C Corporation.—Section 481 is amended by adding at the end the following new subsection:“(d) Adjustments Attributable to Conversion From S Corporation to C Corporation.—“(1) In general.—In the case of an eligible terminated S corporation, any adjustment required by subsection (a)(2) which is attributable to such corporation’s revocation described in paragraph (2)(A)(ii) shall be taken into account ratably during the 6-taxable year period beginning with the year of change.“(2) Eligible terminated s corporation.—For purposes of this subsection, the term ‘eligible terminated S corporation’ means any C corporation—“(A) which—“(i) was an S corporation on the day before the date of the enactment of the Tax Cuts and Jobs Act, and“(ii) during the 2-year period beginning on the date of such enactment makes a revocation of its election under section 1362(a), and“(B) the owners of the stock of which, determined on the date such revocation is made, are the same owners (and in identical proportions) as on the date of such enactment.”.(b) Cash Distributions Following Post-termination Transition Period From S Corporation Status.—Section 1371 is amended by adding at the end the following new subsection:“(f) Cash Distributions Following Post-termination Transition Period.—In the case of a distribution of money by an eligible terminated S corporation (as defined in section 481(d)) after the post-termination transition period, the accumulated adjustments account shall be allocated to such distribution, and the distribution shall be chargeable to accumulated earnings and profits, in the same ratio as the amount of such accumulated adjustments account bears to the amount of such accumulated earnings and profits.”.