[Congressional Bills 110th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2937 Introduced in House (IH)]







110th CONGRESS
  1st Session
                                H. R. 2937

 To amend the Internal Revenue Code of 1986 to provide that management 
    and administrative activities will not be taken into account in 
   determining if an entity has sufficient business activities in a 
      foreign country to avoid treatment as an expatriated entity.


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                    IN THE HOUSE OF REPRESENTATIVES

                             June 28, 2007

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

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                                 A BILL


 
 To amend the Internal Revenue Code of 1986 to provide that management 
    and administrative activities will not be taken into account in 
   determining if an entity has sufficient business activities in a 
      foreign country to avoid treatment as an expatriated entity.

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

SECTION 1. MANAGEMENT AND ADMINISTRATIVE ACTIVITIES NOT TREATED AS 
              BUSINESS ACTIVITIES FOR PURPOSES OF EXPATRIATED ENTITY 
              RULES.

    (a) In General.--Subsection (a) of section 7874 of the Internal 
Revenue Code of 1986 (relating to rules relating to expatriated 
entities and their foreign parents) is amended by adding at the end the 
following new paragraph:
            ``(4) Treatment of management and administrative 
        activities.--For purposes of paragraph (2)(B)(iii), any 
        management or administrative activities (including the location 
        of any corporate headquarters) in the foreign country in which, 
        or under the law of which, the entity is created or organized 
        shall not be taken into account as business activities.''.
    (b) Effective Date.--The amendment made by this section shall apply 
to acquisitions completed after the date of the enactment of this Act.
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