(a)
Source rules— Section 937(b)(2) of the Internal Revenue Code of 1986 is amended by striking the period at the end and inserting the following: “to the extent such income is attributable to an office or fixed place of business within the United States (determined under the rules of section 864(c)(5)).”.
(b)
Source rules for personal property sales— Section 865(j)(3) of such Code is amended by adding “932,” after “931,” and before “933.”.
(c)
Effective date— The amendments made by this section shall apply to taxable years beginning after December 31, 2017.