Personal Holding Company Tax Parity and Reinvestment Act

Personal Holding Company Tax Parity and Reinvestment Act - Amends the Internal Revenue Code to exclude dividends received by a U.S. shareholder from a controlled foreign corporation from the definition of "personal holding company income" for purposes of personal holding company taxation.

[Congressional Bills 113th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4589 Introduced in House (IH)]

113th CONGRESS
  2d Session
                                H. R. 4589

 To amend the Internal Revenue Code of 1986 to exclude dividends from 
controlled foreign corporations from the definition of personal holding 
   company income for purposes of the personal holding company rules.


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                    IN THE HOUSE OF REPRESENTATIVES

                              May 7, 2014

 Mr. Reichert (for himself and Mr. McDermott) 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 exclude dividends from 
controlled foreign corporations from the definition of personal holding 
   company income for purposes of the personal holding company rules.

    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 ``Personal Holding Company Tax Parity 
and Reinvestment Act''.

SEC. 2. EXCLUSION OF DIVIDENDS FROM CONTROLLED FOREIGN CORPORATIONS 
              FROM THE DEFINITION OF PERSONAL HOLDING COMPANY INCOME 
              FOR PURPOSES OF THE PERSONAL HOLDING COMPANY RULES.

    (a) In General.--Paragraph (1) of section 543(a) of the Internal 
Revenue Code of 1986 is amended--
            (1) by redesignating subparagraphs (C) and (D) as 
        subparagraphs (D) and (E), respectively, and
            (2) by inserting after subparagraph (B) the following:
                    ``(C) dividends received by a United States 
                shareholder (as defined in section 951(b)) from a 
                controlled foreign corporation (as defined in section 
                957(a)),''.
    (b) Effective Date.--The amendments made by this Act shall apply to 
taxable years ending on or after the date of the enactment of this Act.
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