software (as defined in section 197(e)(3)(B)), or (4) any similar item, which has substantial value independent of the services of any individual. . (b) Conforming amendments (1) Section 197(f)(2)(B)(i) of such Code is amended by inserting 966(a), after 731, . (2) The table of sections for subpart F of part III of subchapter N of chapter 1 of such Code is amended by adding at the end the following new item: Sec. 966. Transfers of intangible property to United States shareholders. . (c) Effective date The amendments made by this section shall apply to distributions made in taxable years of foreign corporations beginning after December 31, 2020, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.