current and accumulated foreign earnings (1) In general Section 965(b)(1) of such Code is amended to read as follows: (1) In general The amount of dividends taken into account under subsection (a) shall not exceed the sum of the current and accumulated earnings and profits described in section 959(c)(3) for the year a deduction is claimed under subsection (a), without diminution by reason of any distributions made during the election year, for all controlled foreign corporations of the United States shareholder. . (2) Conforming amendments (A) Section 965(b) of such Code is amended by striking paragraph (2) and by redesignating paragraphs (3) and (4) as paragraphs (2) and (3), respectively. (B) Section 965(c) of such Code is amended by striking paragraphs (1) and (2) and by redesignating paragraphs (3), (4), and (5) as paragraphs (1), (2), and (3), respectively. (C) Section 965(c)(3) of such Code, as redesignated by subparagraph (B), is amended to read as follows: (3) Controlled groups All United States shareholders which are members of an affiliated group filing a consolidated return under section 1501 shall be treated as one United States shareholder. . (d) Clerical amendments (1) The heading for section 965 of such Code is amended by striking temporary . (2) The table of sections for subpart F of part III of subchapter N of chapter 1 of such Code is amended by striking Temporary dividends and inserting Dividends . (e) Effective date The amendments made by this section shall apply to taxable years ending after the date of the enactment of this Act. V Bonus depreciation increased to 100 percent and made permanent 501. Bonus depreciation increased to 100 percent and made permanent (a) Increase Section 168(k)(1)(A) of the Internal Revenue Code of 1986 is amended by striking 50 percent and inserting 100 percent . (b) Made permanent Section 168(k)(2) of the Internal Revenue Code of 1986 is amended to read as follows: (2) Qualified property For purposes of this subsection— (A) In general The term qualified property