3.0.0 2091 2019-11-15T21:52:15Z 2022-05-20T16:27:20Z Senate S S 2012-02-09 112 ssfi00 Finance Committee Senate Standing Referred to 2012-02-09T21:46:26Z To amend the Internal Revenue Code of 1986 to make permanent the look-through treatment of payments between related controlled foreign corporations. 112 2735 HR 2011-08-01 Referred to the House Committee on Ways and Means. Related bill CRS 2012-02-09 ssfi00 Finance Committee Senate Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S498-502) IntroReferral 2012-02-09 Sponsor introductory remarks on measure. (CR S497-498) IntroReferral B00100 9 Library of Congress 2012-02-09 Introduced in Senate IntroReferral 10000 9 Library of Congress E000285 Sen. Enzi, Michael B. [R-WY] MICHAEL ENZI R WY B. N Taxation Corporate finance and management Foreign and international corporations Income tax credits Income tax deductions Income tax rates Interest, dividends, interest rates Securities Tax administration and collection, taxpayers Taxation of foreign income Taxation 00 2012-02-09 Introduced in Senate 2012-05-02T18:54:09Z United States Job Creation and International Tax Reform Act of 2012 - Amends the Internal Revenue Code, with respect to the taxation of foreign income, to allow: (1) a 95% tax deduction for the foreign source portion of dividends that a domestic corporation receives from a controlled foreign corporation of which it is a U.S. shareholder, (2) domestic corporations to treat gain on the sale or exchange of stock of a foreign corporation held for at least one year as dividends eligible for the 95% tax deduction, (3) a 50% tax deduction for the foreign intangible income of a domestic corporation, and (4) a U.S. shareholder of a controlled foreign corporation to elect a 70% tax deduction for certain amounts received from such a corporation.

Includes certain low-taxed foreign income as subpart F income (e.g., certain passive income, insurance income, foreign-base company income, income from countries subject to international boycotts, illegal bribes, kickbacks, and similar payments, and income from countries where the United States has severed diplomatic relations).

Makes permanent exemptions from treatment as subpart F income for: (1) certain payments of dividends, interest, rents, and royalties received from a related controlled foreign corporation; and (2) active financing income.

Modifies rules relating to the foreign tax credit to create a separate income category for foreign intangible income.

Accelerates the effective date of the worldwide interest allocation rules to taxable years beginning after December 31, 2012 (currently, after December 31, 2020).

]]> United States Job Creation and International Tax Reform Act of 2012 Short Titles as Introduced United States Job Creation and International Tax Reform Act of 2012 Display Title United States Job Creation and International Tax Reform Act of 2012 Official Title as Introduced A bill to amend the Internal Revenue Code of 1986 to reform the international tax system of the United States, and for other purposes. Introduced in Senate 2012-02-09T05:00:00Z https://www.govinfo.gov/content/pkg/BILLS-112s2091is/xml/BILLS-112s2091is.xml 2012-02-09 Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S498-502) 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.