is amended— (1) by striking paragraph (4), and (2) by striking Paragraphs (1) and (4) in the last sentence and inserting Paragraph (1) . (b) Application of certain reporting requirements Section 6038(e)(2) is amended by striking except that— and all that follows through in applying subparagraph (C) and inserting except that in applying subparagraph (C) . (c) Effective date The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end. 4206. Elimination of requirement that corporation must be controlled for 30 days before subpart F inclusions apply (a) In general Section 951(a)(1) is amended by striking for an uninterrupted period of 30 days or more and inserting at any time . (b) Effective date The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2017, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end. D Prevention of base erosion 4301. Current year inclusion by United States shareholders with foreign high returns (a) In general Subpart F of part III of subchapter N of chapter 1 is amended by inserting after section 951 the following new section: 951A. Foreign high return amount included in gross income of United States shareholders (a) In general Each person who is a United States shareholder of any controlled foreign corporation for any taxable year of such United States shareholder shall include in gross income for such taxable year 50 percent of such shareholder’s foreign high return amount for such taxable year. (b) Foreign high return amount For purposes of this section— (1) In general The term foreign high return amount means, with respect to any United States shareholder for any taxable year of such United States shareholder, the excess (if any) of— (A) such shareholder’s net CFC tested income