1. Reduced recognition period for built-in gains made permanent
by striking subparagraphs (A), (B), (C), and (D),
by redesignating subparagraph (E) as subparagraph (B), and
by inserting before subparagraph (B) (as so redesignated) the following new subparagraph:
“(A) In general—The term recognition period means the 5-year period beginning with the 1st day of the 1st taxable year for which the corporation was an S corporation. For purposes of applying this section to any amount includible in income by reason of distributions to shareholders pursuant to section 593(e), the preceding sentence shall be applied without regard to the phrase “5-year”.”
Effective date— The amendment made by this section shall apply to taxable years beginning after December 31, 2013.