eligible terminated S corporation

(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.


26 USC § 481(d)(2)

Scoping language

For purposes of this subsection
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