US Congress Senate Bill 2091 (Prior Session Legislation)

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Spectrum: Partisan Bill (Republican 1-0)
Status: Introduced on February 9 2012 - 25% progression, died in committee
Action: 2012-02-09 - Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S498-502)
Pending: Senate Finance Committee
Text: Latest bill text (Introduced) [PDF]

United States Job Creation and International Tax Reform Act of 2012 - Amends the Internal Revenue Code, with respect to the taxation of foreign income, to allow: (1) a 95% tax deduction for the foreign source portion of dividends that a domestic corporation receives from a controlled foreign corporation of which it is a U.S. shareholder, (2) domestic corporations to treat gain on the sale or exchange of stock of a foreign corporation held for at least one year as dividends eligible for the 95% tax deduction, (3) a 50% tax deduction for the foreign intangible income of a domestic corporation, and (4) a U.S. shareholder of a controlled foreign corporation to elect a 70% tax deduction for certain amounts received from such a corporation. Includes certain low-taxed foreign income as subpart F income (e.g., certain passive income, insurance income, foreign-base company income, income from countries subject to international boycotts, illegal bribes, kickbacks, and similar payments, and income from countries where the United States has severed diplomatic relations). Makes permanent exemptions from treatment as subpart F income for: (1) certain payments of dividends, interest, rents, and royalties received from a related controlled foreign corporation; and (2) active financing income. Modifies rules relating to the foreign tax credit to create a separate income category for foreign intangible income. Accelerates the effective date of the worldwide interest allocation rules to taxable years beginning after December 31, 2012 (currently, after December 31, 2020).

United States Job Creation and International Tax Reform Act of 2012

Sen. Michael Enzi [R-WY]

Date	Chamber	Action
2012-02-09	Senate	Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S498-502)
2012-02-09	Senate	Sponsor introductory remarks on measure. (CR S497-498)

HB2735 (Related) 2011-08-01 - Referred to the House Committee on Ways and Means.

Type	Source
Summary	https://www.congress.gov/bill/112th-congress/senate-bill/2091/all-info
Text	https://www.congress.gov/112/bills/s2091/BILLS-112s2091is.pdf