To amend the Internal Revenue Code of 1986 to make the look-thru rule for related controlled foreign corporations permanent.

This bill 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 116th Congress]
[From the U.S. Government Publishing Office]
[H.R. 5240 Introduced in House (IH)]

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116th CONGRESS
  1st Session
                                H. R. 5240

 To amend the Internal Revenue Code of 1986 to make the look-thru rule 
         for related controlled foreign corporations permanent.


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                    IN THE HOUSE OF REPRESENTATIVES

                           November 21, 2019

   Mr. Kind (for himself, Mr. Holding, Ms. Moore, Mrs. Walorski, Mr. 
 Suozzi, Mr. LaHood, Mr. Higgins of New York, Mr. Ferguson, Mr. Larson 
 of Connecticut, Mr. Estes, Ms. Sewell of Alabama, Mr. Schneider, and 
    Mr. Smith of Missouri) 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 the look-thru rule 
         for related controlled foreign corporations permanent.

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

SECTION 1. LOOK-THRU RULE FOR RELATED CONTROLLED FOREIGN CORPORATIONS 
              MADE PERMANENT.

    (a) In General.--Section 954(c)(6) 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, 
2019, and to taxable years of United States shareholders with or within 
which such taxable years of foreign corporations end.
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