[Congressional Bills 103th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4626 Introduced in House (IH)]

103d CONGRESS
  2d Session
                                H. R. 4626

To amend the Internal Revenue Code of 1986 to clarify the treatment of 
 foreign source income of United States-owned multinational insurance 
                          agents and brokers.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                             June 22, 1994

Mr. Cardin (for himself and Mr. Archer) 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 clarify the treatment of 
 foreign source income of United States-owned multinational insurance 
                          agents and brokers.

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

SECTION 1. SHORT TITLE.

    (a) Short Title.--This Act may be cited as the ``Insurance Broker 
Foreign Source Income Clarification Act of 1994''.
    (b) Amendment of 1986 Code.--Except as otherwise expressly 
provided, whenever in this Act an amendment or repeal is expressed in 
terms of an amendment to, or repeal of, a section or other provision, 
the reference shall be considered to be made to a section or other 
provision of the Internal Revenue Code of 1986.

SEC. 2. CLARIFICATION OF RULES APPLICABLE TO UNITED STATES-OWNED 
              MULTINATIONAL INSURANCE AGENTS AND BROKERS.

    Subsection (b) of section 1296 is amended by adding at the end 
thereof the following new subsection:
            ``(4) Treatment of certain insurance agents or brokers.--In 
        the case of any foreign corporation which is a controlled 
        foreign corporation (as defined in section 957(a)), the term 
        `passive income' does not include any income derived from 
        insurance brokerage or agency services. Income earned on 
        fiduciary funds held by an insurance agent or broker shall not 
        be passive income and such funds shall be treated as having a 
        tax basis equal to their original purchase price.''.

SEC. 3. EFFECTIVE DATE.

    The amendment made by this Act shall apply to tax years ending 
after the date of enactment.

                                 <all>