[Congressional Bills 103th Congress]
[From the U.S. Government Publishing Office]
[H.R. 1410 Introduced in House (IH)]

103d CONGRESS
  1st Session
                                H. R. 1410

    To amend the Internal Revenue Code of 1986 to provide that the 
 deduction for State and local income and franchise taxes shall not be 
                  allocated to foreign source income.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                             March 18, 1993

   Mr. Thomas of California introduced the following bill; which was 
              referred to the Committee on Ways and Means

_______________________________________________________________________

                                 A BILL


 
    To amend the Internal Revenue Code of 1986 to provide that the 
 deduction for State and local income and franchise taxes shall not be 
                  allocated to foreign source income.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. ALLOCATION OF DEDUCTION FOR STATE AND LOCAL INCOME AND 
              FRANCHISE TAXES FOR FOREIGN TAX CREDIT PURPOSES.

    (a) In General.--Subsection (b) of section 904 of the Internal 
Revenue Code of 1986 (relating to taxable income for purpose of 
computing limitation) is amended by adding at the end thereof the 
following new paragraph:
            ``(5) Deduction for state and local income and franchise 
        taxes.--For purposes of computing taxable income under this 
        subpart, any deduction for any State or local income or 
        franchise tax shall not be allocated or apportioned to gross 
        income from sources without the United States.''
    (b) Effective Date.--The amendment made by this section shall apply 
to taxable years beginning after December 31, 1976.

                                 <all>