A bill to amend the Internal Revenue Code of 1954 with respect to the treatment of gains in certain exchanges involving foreign corporations.

States that in determining the extent to which gain shall be recognized, under the Internal Revenue Code, in the case of exchanges among corporations, a foreign corporation shall not be considered a corporation, unless such an exchange is done to avoid income taxes.

Provides that such stipulation shall apply where there is an exchange incident to a complete liquidation of a foreign corporation into a second foreign corporation which is wholly owned by a United States corporation where both foreign corporations are incorporated under the laws of the same foreign country.