3.0.0 5793 2023-01-11T13:21:55Z 2023-01-11T13:21:55Z House H HR 2010-07-20 111 hswm00 Ways and Means Committee House Standing Referred to 2010-07-20T14:36:09Z 111 5893 HR 2010-07-29 POSTPONED PROCEEDINGS - Pursuant to clause 2c of rule 19, the Chair postponed further proccedings on H.R. 5893 until a time to be announced. 17:39:11 Related bill CRS 111 5982 HR 2010-07-30 On motion to suspend the rules and pass the bill Failed by the Yeas and Nays: (2/3 required): 241 - 154 (Roll no. 514). 18:30:35 Related bill CRS 2010-07-20 Referred to the House Committee on Ways and Means. IntroReferral H11100 2 House floor actions hswm00 Ways and Means Committee 2010-07-20 Introduced in House IntroReferral Intro-H 9 Library of Congress 2010-07-20 Introduced in House IntroReferral 1000 9 Library of Congress G000559 Rep. Garamendi, John [D-CA-10] John Garamendi D CA 10 N M000404 Rep. McDermott, Jim [D-WA-7] JIM MCDERMOTT D WA 7 2010-07-20 True N000179 Rep. Napolitano, Grace F. [D-CA-38] GRACE NAPOLITANO D CA F. 38 2010-07-20 True D000191 Rep. DeFazio, Peter A. [D-OR-4] PETER DEFAZIO D OR A. 4 2010-07-20 True H001040 Rep. Hare, Phil [D-IL-17] Phil Hare D IL 17 2010-07-20 True S001174 Rep. Sutton, Betty [D-OH-13] Betty Sutton D OH 13 2010-07-20 True S001178 Rep. Schauer, Mark H. [D-MI-7] Mark Schauer D MI H. 7 2010-07-20 True H000627 Rep. Hinchey, Maurice D. [D-NY-22] MAURICE HINCHEY D NY D. 22 2010-07-20 True K000009 Rep. Kaptur, Marcy [D-OH-9] MARCY KAPTUR D OH 9 2010-07-20 True K000365 Rep. Kagen, Steve [D-WI-8] Steve Kagen D WI 8 2010-07-20 True P000593 Rep. Perlmutter, Ed [D-CO-7] Ed Perlmutter D CO 7 2010-07-20 True K000180 Rep. Kilpatrick, Carolyn C. [D-MI-13] CAROLYN KILPATRICK D MI CHEEKS 13 2010-07-21 False D000355 Rep. Dingell, John D. [D-MI-15] JOHN DINGELL D MI D. 15 2010-07-21 False P000099 Rep. Pastor, Ed [D-AZ-4] ED PASTOR D AZ 4 2010-07-21 False F000043 Rep. Fattah, Chaka [D-PA-2] CHAKA FATTAH D PA 2 2010-07-22 False P000034 Rep. Pallone, Frank, Jr. [D-NJ-6] FRANK PALLONE D NJ 6 2010-07-26 False H001046 Rep. Heinrich, Martin [D-NM-1] Martin Heinrich D NM T. 1 2010-07-30 False S000810 Rep. Stark, Fortney Pete [D-CA-13] PETE STARK D CA 13 2010-09-22 False B001230 Rep. Baldwin, Tammy [D-WI-2] Tammy Baldwin D WI 2 2010-09-23 False Taxation Corporate finance and management Foreign and international corporations Income tax credits Interest, dividends, interest rates Tax administration and collection, taxpayers Taxation of foreign income Taxation

00 2010-07-20 Introduced in House 2010-12-06T15:24:49Z Close Foreign Tax Loopholes: Make it in America Act of 2010 - Amends the Internal Revenue Code, with respect to the taxation of foreign income and the foreign tax credit, to: (1) suspend the recognition of foreign tax credits until the related foreign income is taken into account for U.S. tax purposes; (2) deny a foreign tax credit for foreign income not subject to U.S. taxation due to a covered asset acquisition (defined as an acquisition that results in an increase in tax basis for U.S. tax purposes but not for foreign tax purposes); (3) apply a separate foreign tax credit limitation for each item of income that would be treated as derived from sources within the United States and that would be treated as arising from sources outside the United States under a treaty obligation (if the taxpayer chooses the benefits of such treaty); (4) limit the amount of foreign tax credits that may be claimed by a U.S. domestic corporation with respect to a deemed dividend paid by a foreign subsidiary; (5) prevent a reduction in earnings in profits of a foreign corporation in an acquisition if more than 50% of the dividends arising from such acquisition would not be subject to U.S. taxation or would be includible in the earnings and profits of a controlled foreign corporation; (6) treat a foreign corporation as a member of an affiliated group for interest allocation and apportionment purposes if more than 50% of its gross income is effectively connected with a U.S. trade or business and at least 80% of either the vote or value of its outstanding stock is owned directly or indirectly by members of the affiliated group; (7) repeal tax rules exempting foreign source income attributable to the active conduct of a foreign trade or business from withholding of tax requirements; (8) treat as income received in the United States amounts received from noncorporate residents or domestic corporations with respect to guarantees and amounts paid by any foreign person if such amounts are connected with income that is effectively connected with the conduct of a trade or business in the United States; and (9) provide that the statute of limitations for assessing any tax on certain foreign transactions shall apply only to items related to a failure to provide information to the Internal Revenue Service (IRS) due to reasonable cause and not willful neglect.

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Display Title Official Title as Introduced Introduced in House IH Short Titles as Introduced Introduced in House 2010-07-20T04:00:00Z https://www.govinfo.gov/content/pkg/BILLS-111hr5793ih/xml/BILLS-111hr5793ih.xml 2010-07-20 Referred to the House Committee on Ways and Means. text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. Congressional Research Service, Library of Congress This file contains bill summaries and statuses for federal legislation. A bill summary describes the most significant provisions of a piece of legislation and details the effects the legislative text may have on current law and federal programs. Bill summaries are authored by the Congressional Research Service (CRS) of the Library of Congress. As stated in Public Law 91-510 (2 USC 166 (d)(6)), one of the duties of CRS is "to prepare summaries and digests of bills and resolutions of a public general nature introduced in the Senate or House of Representatives". For more information, refer to the User Guide that accompanies this file.