A bill to amend the Internal Revenue Code of 1954 to terminate the operation of those provisions permitting the deferral of income tax with respect to foreign source income.

Amends the Internal Revenue Code to impose immediate taxation on United States' taxpayers pro rata shares of controlled foreign corporations' net post-1976 profits which can legally be distributed, whether they are or not. Allows domestic corporations to take the foreign tax credit for their pro rata share of the taxes paid by foreign corporations of which they own, directly or indirectly, specified portions of the voting stock. Allows individuals an election to be taxed at corporate rates under these provisions.