Permanent CFC Look-Through Act of 2014 - Amends the Internal Revenue Code to make permanent the tax rule exempting dividends, interest, rents, and royalties received or accrued from certain controlled foreign corporations by a related entity from treatment as foreign holding company income (thus permitting tax deferral of such income).
[Congressional Bills 113th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4464 Introduced in House (IH)]
113th CONGRESS
2d Session
H. R. 4464
To amend the Internal Revenue Code of 1986 to make permanent the look-
through treatment of payments between related controlled foreign
corporations.
_______________________________________________________________________
IN THE HOUSE OF REPRESENTATIVES
April 10, 2014
Mr. Boustany (for himself, Mr. Kind, Mr. Reed, Mr. Schock, Ms. Jenkins,
Mr. Tiberi, Mr. Pascrell, Mr. Larson of Connecticut, Mr. Young of
Indiana, Mr. Matheson, and Mr. Crowley) 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 look-
through treatment of payments between related controlled foreign
corporations.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. LOOK-THROUGH TREATMENT OF PAYMENTS BETWEEN RELATED
CONTROLLED FOREIGN CORPORATIONS MADE PERMANENT.
(a) In General.--Paragraph (6) of section 954(c) of the Internal
Revenue Code of 1986 is amended by striking subparagraph (C).
(b) Effective Date.--The amendment made by this section shall apply
to taxable years of foreign corporations beginning after December 31,
2013, and to taxable years of United States shareholders with or within
which such taxable years of foreign corporations end.
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Introduced in House
Introduced in House
Referred to the House Committee on Ways and Means.
Committee Consideration and Mark-up Session Held.
Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 22 - 14.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 113-428.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 113-428.
Placed on the Union Calendar, Calendar No. 316.
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