To amend the Internal Revenue Code of 1986 to reduce tax benefits for foreign corporations, and for other purposes.
Removes the deferral, for purposes of taxation of controlled foreign corporations, of tax on extraction income or income from consumption in the foreign country.
Provides that the Secretary of the Treasury's authority, in allocating income, deductions, credits, and allowances among taxpayers owned or controlled by the same interests, shall not be limited by any restriction on the ability of the entities to transfer or receive money or property.
Revises provisions concerning the exclusion of foreign earned income by U.S. citizens living abroad.
Treats the gain or loss of a nonresident alien individual or foreign corporation that is a ten-percent shareholder in a domestic corporation upon disposition of such a corporation's stock as if the taxpayer were engaged during the taxable year in a trade or business within the United States and such gain or loss attributable to a permanent U.S. trade or business establishment. Imposes a 26-percent minimum tax on nonresident alien individuals. Provides for the withholding of tax on such dispositions, except in the case of stock which is not regularly traded. Excepts such gain from the branch profits tax imposed on foreign corporations. Requires notice to the Secretary upon distributions by a U.S. person to a foreign person in redemption of stock or complete liquidation of a subsidiary.
Removes the exemption of ten-percent shareholders from the tax on interest of nonresident alien individuals received from portfolio debt investments. Redefines portfolio interest as only interest paid on obligations issued by governmental entities.
Provides special rules for determining the source of income from the sale of inventory property.
Introduced in House
Introduced in House
Referred to the House Committee on Ways and Means.
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