118 STAT. 1562 PUBLIC LAW 108–357—OCT. 22, 2004 SEC. 714. CERTAIN STEAM GENERATORS, AND CERTAIN REACTOR VESSEL HEADS AND PRESSURIZERS, USED IN NUCLEAR FACILITIES. (a) CERTAIN STEAM GENERATORS.—Heading 9902.84.02 of the Harmonized Tariff Schedule of the United States is amended by striking ‘‘12/31/2006’’ and inserting ‘‘12/31/2008’’. (b) CERTAIN REACTOR VESSEL HEADS AND PRESSURIZERS.—Sub chapter II of chapter 99 of the Harmonized Tariff Schedule of the United States is amended by inserting in numerical sequence the following new heading: ‘‘ 9902.84.03 Reactor vessel heads and pressur izers for nuclear reactors (provided for in subheading 8401.40.00) ........ Free No change No change On or before 12/31/2008 ’’. (c) EFFECTIVE DATE.— (1) SUBSECTION (a).—The amendment made by subsection (a) shall take effect on the date of the enactment of this Act. (2) SUBSECTION (b).—The amendment made subsection (b) shall apply to goods entered, or withdrawn from warehouse, for consumption on or after the 15th day after the date of the enactment of this Act. TITLE VIII—REVENUE PROVISIONS Subtitle A—Provisions to Reduce Tax Avoidance Through Individual and Cor porate Expatriation SEC. 801. TAX TREATMENT OF EXPATRIATED ENTITIES AND THEIR FOREIGN PARENTS. (a) IN GENERAL.—Subchapter C of chapter 80 (relating to provi sions affecting more than one subtitle) is amended by adding at the end the following new section: ‘‘SEC. 7874. RULES RELATING TO EXPATRIATED ENTITIES AND THEIR FOREIGN PARENTS. ‘‘(a) TAX ON INVERSION GAIN OF EXPATRIATED ENTITIES.— ‘‘(1) IN GENERAL.—The taxable income of an expatriated entity for any taxable year which includes any portion of the applicable period shall in no event be less than the inversion gain of the entity for the taxable year. ‘‘(2) EXPATRIATED ENTITY.—For purposes of this subsection— ‘‘(A) IN GENERAL.—The term ‘expatriated entity’ means— ‘‘(i) the domestic corporation or partnership referred to in subparagraph (B)(i) with respect to which a foreign corporation is a surrogate foreign corporation, and ‘‘(ii) any United States person who is related (within the meaning of section 267(b) or 707(b)(1)) to a domestic corporation or partnership described in clause (i).
�
