American Jobs Promotion Act of 1991 - Title I: Treatment of Junk Bonds and Hostile Takeovers - Amends the Internal Revenue Code to disallow a deduction for interest on junk bonds incurred to acquire stock or assets in hostile takeovers.
Requires that a hostile stock purchase in a corporate takeover attempt be treated as an asset acquisition by the purchasing corporation.
Disallows an income tax deduction for interest on any indebtedness incurred or continued by a purchasing shareholder to purchase or carry corporate stock or assets acquired through a hostile purchase.
Lowers the minimum maturity date requirement of an applicable high yield discount obligation from five years to two years (thus restricting the tax deduction for interest on certain high yield original issue discount obligations). Amends the definition of "disqualified yield" as it relates to the disqualified portion of original issue discount on any applicable high yield discount obligation to remove the additional percentage point added to the excess of the yield to maturity over a specified sum.
Title II: Termination of Deferral of Tax on Income of Controlled Foreign Corporations Attributable to Property Imported Into United States - Amends the Internal Revenue Code to include imported property income of a controlled foreign corporation or related person as foreign base company income. Defines imported property income as that from: (1) manufacturing, producing, growing, or extracting imported property; (2) the sale, exchange, or other disposition of imported property; or (3) the lease, rental, or licensing of imported property.
Requires the separate application of the limitation on the foreign tax credit on imported property income. Applies the look-thru rules in the case of controlled foreign corporations to such income.
Title III: Termination of Puerto Rico and Possessions Tax Credit - Terminates the Puerto Rico and possession tax credit.
Introduced in House
Introduced in House
Referred to the House Committee on Ways and Means.
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