S.2091 - United States Job Creation and International Tax Reform Act of 2012

A bill to amend the Internal Revenue Code of 1986 to reform the international tax system of the United States, and for other purposes. view all titles (2)

All Bill Titles

  • Short: United States Job Creation and International Tax Reform Act of 2012 as introduced.
  • Official: A bill to amend the Internal Revenue Code of 1986 to reform the international tax system of the United States, and for other purposes. as introduced.

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Introduced
 
Senate
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House
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President
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02/09/12
 
 
 
 
 
 
 

Official Summary

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 foreig

Official Summary

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).

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