Paragraph 55 Minor amendments

In section 170 (adjustments for ultimate parent that is a flow-through entity), in subsection (9)(b), for the words from “the ultimate parent’s“ to the end substitute

“—

(i)

the entity is regarded as tax transparent in the territory in which the ultimate parent is located, and

(ii)

the ultimate parent’s interest in that entity is held directly or through one or more entities all of which are regarded as tax transparent in that territory.”