[Congressional Bills 114th Congress]
[From the U.S. Government Publishing Office]
[H.R. 3083 Introduced in House (IH)]

114th CONGRESS
  1st Session
                                H. R. 3083

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


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                             July 15, 2015

 Mr. Williams 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 make permanent the 
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 ``Bring Jobs Back to America Act of 
2015''.

SEC. 2. MODIFICATION AND PERMANENT EXTENSION OF THE INCENTIVES TO 
              REINVEST FOREIGN EARNINGS IN THE UNITED STATES.

    (a) Repatriation Subject to 5 Percent Tax Rate.--Section 965(a)(1) 
of the Internal Revenue Code of 1986 is amended by striking ``85 
percent'' and inserting ``85.7 percent''.
    (b) Permanent Extension To Elect Repatriation.--Section 965(f) of 
such Code is amended to read as follows:
    ``(f) Election.--The taxpayer may elect to apply this section to 
any taxable year only if made on or before the due date (including 
extensions) for filing the return of tax for such taxable year.''.
    (c) Repatriation Includes Current and Accumulated Foreign 
Earnings.--
            (1) In general.--Section 965(b)(1) of such Code is amended 
        to read as follows:
            ``(1) In general.--The amount of dividends taken into 
        account under subsection (a) shall not exceed the sum of the 
        current and accumulated earnings and profits described in 
        section 959(c)(3) for the year a deduction is claimed under 
        subsection (a), without diminution by reason of any 
        distributions made during the election year, for all controlled 
        foreign corporations of the United States shareholder.''.
            (2) Conforming amendments.--
                    (A) Section 965(b) of such Code is amended by 
                striking paragraph (2) and by redesignating paragraphs 
                (3) and (4) as paragraphs (2) and (3), respectively.
                    (B) Section 965(c) of such Code is amended by 
                striking paragraphs (1) and (2) and by redesignating 
                paragraphs (3), (4), and (5) as paragraphs (1), (2), 
                and (3), respectively.
                    (C) Section 965(c)(3) of such Code, as redesignated 
                by subparagraph (B), is amended to read as follows:
            ``(3) Controlled groups.--All United States shareholders 
        which are members of an affiliated group filing a consolidated 
        return under section 1501 shall be treated as one United States 
        shareholder.''.
    (d) Clerical Amendments.--
            (1) The heading for section 965 of such Code is amended by 
        striking ``temporary''.
            (2) The table of sections for subpart F of part III of 
        subchapter N of chapter 1 of such Code is amended by striking 
        ``Temporary dividends'' and inserting ``Dividends''.
    (e) Effective Date.--The amendments made by this section shall 
apply to taxable years ending after the date of the enactment of this 
Act.
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