110 HR 2937 IH: To amend the Internal Revenue Code of 1986 to provide U.S. House of Representatives 2007-06-28 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.

I 110th CONGRESS 1st Session H. R. 2937 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 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.

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.