[Congressional Bills 114th Congress]
[From the U.S. Government Publishing Office]
[H.R. 2225 Introduced in House (IH)]

114th CONGRESS
  1st Session
                                H. R. 2225

    To amend the Internal Revenue Code of 1986 to allow a temporary 
dividends received deduction for repatriated foreign earnings, and for 
                            other purposes.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                              May 1, 2015

 Mr. Meadows introduced the following bill; which was referred to the 
 Committee on Ways and Means, and in addition to the Committee on the 
 Budget, for a period to be subsequently determined by the Speaker, in 
   each case for consideration of such provisions as fall within the 
                jurisdiction of the committee concerned

_______________________________________________________________________

                                 A BILL


 
    To amend the Internal Revenue Code of 1986 to allow a temporary 
dividends received deduction for repatriated foreign earnings, and for 
                            other purposes.

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

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Prioritizing Reinvestment in 
Infrastructure and Military while Eliminating Debt Act of 2015'' or the 
``PRIMED Act''.

SEC. 2. DIVIDENDS RECEIVED DEDUCTION FOR REPATRIATED FOREIGN EARNINGS.

    (a) Period for Repatriation.--Paragraph (1) of section 965(a) of 
the Internal Revenue Code of 1986 is amended by adding at the end the 
following: ``Only cash dividends received during the period beginning 
after the date of the enactment of the Prioritizing Reinvestment in 
Infrastructure and Military while Eliminating Debt Act of 2015, and 
ending on December 31, 2016, shall be taken into account under 
subsection (a).''.
    (b) Extension.--Subsection (f) of section 965 of such Code is 
amended to read as follows:
    ``(f) Election.--The taxpayer may elect to apply this section to 
any taxable year that includes the period described in subsection 
(a)(1). Such election may be made only for one taxable year that 
includes such period and only if made on or before the due date 
(including extensions) for filing the return of tax for such taxable 
year.''.
    (c) Conforming Amendments.--
            (1) Threshold period.--Section 965 of such Code is amended 
        by striking ``June 30, 2003'' each place it occurs and 
        inserting ``June 30, 2014''.
            (2) Indebtedness determination date.--Subparagraph (B) of 
        section 965(b)(3) of such Code is amended by striking ``October 
        3, 2004'' and inserting ``May 1, 2015''.
    (d) Effective Date.--The amendments made by this section shall 
apply to taxable years ending after the date of the enactment of this 
Act.

SEC. 3. DEBT REDUCTION.

    (a) In General.--In the case of any taxes which--
            (1) are received in the Treasury during a fiscal year for 
        which there is not Federal budget deficit, and
            (2) are attributable to eligible 965 dividends received by 
        corporations which are United States shareholders,
an amount equal to \1/3\ of such taxes, reduced by \1/3\ of the amount 
of the foreign tax credit allowed under section 901 which is 
attributable to the non-deductible portion of such eligible 965 
dividends, shall be used to reduce the Federal debt (in such manner as 
the Secretary of the Treasury considers appropriate).
    (b) Definitions.--For purposes of subsection (a), the terms 
``eligible 965 dividend'' and ``non-deductible portion'' shall have the 
respective meanings given such terms in section 9503(b)(7) of the 
Internal Revenue Code of 1986.

SEC. 4. HIGHWAY TRUST FUND.

    Section 9503(b) of the Internal Revenue Code of 1986 is amended by 
adding at the end the following new paragraph:
            ``(7) Other transfers to highway trust fund.--
                    ``(A) In general.--There are hereby appropriated to 
                the Highway Trust Fund amounts equivalent to the excess 
                of--
                            ``(i) \1/3\ of the taxes received in the 
                        Treasury which are attributable to eligible 965 
                        dividends received by corporations which are 
                        United States shareholders, over
                            ``(ii) \1/3\ of the amount of the foreign 
                        tax credit allowed under section 901 which is 
                        attributable to the non-deductible portion of 
                        such eligible 965 dividends.
                    ``(B) Definitions.--For purposes of this 
                subsection--
                            ``(i) Eligible 965 dividend.--The term 
                        `eligible 965 dividend' means any amount 
                        received from a controlled foreign corporation 
                        for which a deduction is allowed under section 
                        965, as determined based on estimates made by 
                        the Secretary.
                            ``(ii) Non-deductible portion.--The term 
                        `non-deductible portion' means the excess of 
                        the amount of any eligible 965 dividend over 
                        the deductible portion (as defined in section 
                        965(d)(3)) of such amount.''.

SEC. 5. ADJUSTMENT TO DEFENSE DISCRETIONARY SPENDING LIMITATIONS.

    (a) In General.--On the date that is 30 days after the date of 
enactment of this Act, and on February 1 of each of calendar years 2016 
through 2020, the revised security category in section 251(c) of the 
Balanced Budget and Emergency Deficit Control Act of 1985 for fiscal 
year 2016 and the fiscal year beginning on September 1st of such 
applicable calendar year, respectively, shall be adjusted by the amount 
described in subsection (b).
    (b) Adjustment Amount.--The adjustment provided in subsection (a) 
is equal to--
            (1) \1/3\ of the taxes received in the Treasury during the 
        most recently ended calendar year which are attributable to 
        eligible 965 dividends received by corporations which are 
        United States shareholders, over
            (2) \1/3\ of the amount of the foreign tax credit allowed 
        during the most recently ended calendar year under section 901 
        which is attributable to the non-deductible portion of such 
        eligible 965 dividends.
    (b) Definitions.--For purposes of subsection (b), the terms 
``eligible 965 dividend'' and ``non-deductible portion'' shall have the 
respective meanings given such terms in section 9503(b)(7) of the 
Internal Revenue Code of 1986.
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