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To amend the Internal Revenue Code of 1986 to make the look-thru rule for related controlled foreign corporations permanent.
HR #5240 | Last Action: 11/21/2019This 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).To amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.
HR #4509 | Last Action: 9/26/2019This bill amends the Internal Revenue Code to limit the scope of downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations.A bill to amend the Internal Revenue Code of 1986 to restore the limitation on downward attribution of stock ownership in applying the constructive ownership rules to controlled foreign corporations, and for other purposes.
S #2589 | Last Action: 9/26/2019This bill amends the Internal Revenue Code to limit the scope of downward attribution rules to 50% of stock ownership in applying constructive ownership rules to controlled foreign corporations.Advancing International and Foreign Language Education Act
S #342 | Last Action: 2/6/2019Advancing International and Foreign Language Education Act This bill reauthorizes through FY2025 and otherwise revises international education programs. These programs provide grants to institutions of higher education and related entities to (1) enhance instruction in international and foreign language studies, and (2) promote international business skills and education. First, the bill reauthorizes programs related to international and foreign language studies. Specifically, it extends (1) the Graduate and Undergraduate Language and Area Centers and Programs, which include the National Resource Centers program; (2) the Language Resource Centers; (3) the Undergraduate International Studies and Foreign Language Programs; and (4) the American Overseas Research Centers. Next, the bill reauthorizes the Foreign Language and Area Studies Fellowships program. It also revises the program to permit graduate students to receive a stipend for the beginning, intermediate, or advanced study of a foreign language related to the student's area of specialization. Further, the bill extends the Technological Innovation and Cooperation for Foreign Information Access program. It also modifies the program, such as by (1) revising the types of available grants, and (2) allowing the Department of Education to establish a national database on international and foreign language education. Finally, the bill reauthorizes programs related to international business skills and education. Specifically, it reauthorizes the Centers for Business Education program. It also reauthorizes the Education and Training program and otherwise makes changes to the program, including by (1) renaming the program; and (2) mandating certain program activities, such as the incorporation of specified programs and studies into professional education and technical training curricula.Advancing International and Foreign Language Education Act
HR #2562 | Last Action: 5/7/2019Advancing International and Foreign Language Education Act This bill reauthorizes through FY2025 and otherwise revises international education programs. These programs provide grants to institutions of higher education and related entities to (1) enhance instruction in international and foreign language studies, and (2) promote international business skills and education. First, the bill reauthorizes programs related to international and foreign language studies. Specifically, it extends (1) the Graduate and Undergraduate Language and Area Centers and Programs, which include the National Resource Centers program; (2) the Language Resource Centers; (3) the Undergraduate International Studies and Foreign Language Programs; and (4) the American Overseas Research Centers. Next, the bill revises the Foreign Language and Area Studies Fellowships program to permit graduate students to receive a stipend for the beginning, intermediate, or advanced study of a foreign language related to the student's area of specialization. Further, the bill replaces the existing Technological Innovation and Cooperation for Foreign Information Access program with an international research and innovation program. Additionally, the bill reauthorizes programs related to international business skills and education. Specifically, it reauthorizes the Centers for International Business Education program. It also reauthorizes the Education and Training program and otherwise makes changes to the program, including by (1) renaming the program; and (2) mandating certain program activities, such as the incorporation of specified programs and studies into professional education and technical training curricula. Finally, the bill permits the Department of Education to prioritize grant applications from minority-serving institutions.To amend the Internal Revenue Code of 1986 to encourage the transfer of intangible property from controlled foreign corporations to United States shareholders.
HR #7749 | Last Action: 7/23/2020This bill excludes from gross income, for income tax purposes, gains from distributions of intangible property by controlled foreign corporations to U.S. domestic corporations. The bill definesintangible propertyto include patents, copyrights, licenses, formulas, computer software, and similar items with substantial value.Stop Corporate Inversions Act of 2019
S #2140 | Last Action: 7/17/2019Stop Corporate Inversions Act of 2019 This bill amends the Internal Revenue Code to revise rules for the taxation of inverted corporations (i.e., U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States). The bill provides that a foreign corporation that acquires the properties of a U.S. corporation or partnership after May 8, 2014, shall be treated as an inverted corporation and thus subject to U.S. taxation if, after such acquisition (1) it holds more than 50% of the stock of the new entity (expanded affiliated group), or (2) the management or control of the new entity occurs primarily within the United States and the new entity has significant domestic business activities.To amend the Internal Revenue Code of 1986 to provide an exemption from FIRPTA for interests held by certain foreign insurance companies.
HR #4598 | Last Action: 10/1/2019This bill exempts interests held by certain foreign insurance companies from provisions of the Foreign Investment in Real Property Tax Act of 1980 that tax foreign individuals or corporations on dispositions of investments in U.S. real property interests.To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules.
HR #5746 | Last Action: 2/3/2020This bill sets forth special tax rules for determining whether financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules.Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020
S #2583 | Last Action: 9/26/2019Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020 This bill provides FY2020 appropriations for the Department of State, foreign operations, and related programs. The bill provides appropriations to the State Department for * Administration of Foreign Affairs, * International Organizations, and * International Commissions. The bill provides appropriations for Related Agencies and Related Programs, including * the U.S. Agency for Global Media, * the Asia Foundation, * the U.S. Institute of Peace, * the Center for Middle Eastern-Western Dialogue Trust Fund, * the Eisenhower Exchange Fellowship Program, * the Israeli Arab Scholarship Program, * the East-West Center, and * the National Endowment for Democracy. The bill provides appropriations for Other Commissions, including * the Commission for the Preservation of America's Heritage Abroad, * the U.S. Commission on International Religious Freedom, * the Commission on Security and Cooperation in Europe, * the Congressional-Executive Commission on the People's Republic of China, and * the U.S.-China Economic and Security Review Commission. The bill provides appropriations to * the U.S. Agency for International Development (USAID), * the State Department and the President for International Security Assistance, * the President and International Financial Institutions for Multilateral Assistance, and * specified accounts for Overseas Contingency Operations/ Global War on Terrorism. The bill provides appropriations for Bilateral Economic Assistance to * the President; * the State Department; * Independent Agencies, including the Peace Corps, the Millennium Challenge Corporation, the Inter-American Foundation, and the U.S. African Development Foundation; and * the Department of the Treasury. The bill provides appropriations for Export and Investment Assistance to * the Export-Import Bank of the United States, * the U.S. International Development Finance Corporation, and * the U.S. Trade and Development Agency. The bill sets forth requirements and restrictions for using funds provided by this and other appropriations Acts.Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020
HR #2839 | Last Action: 5/20/2019Department of State, Foreign Operations, and Related Programs Appropriations Act, 2020 This bill provides FY2020 appropriations for the Department of State, foreign operations, and related programs. The bill provides appropriations to the State Department for * Administration of Foreign Affairs, * International Organizations, and * International Commissions. The bill provides appropriations for Related Agencies and Related Programs, including * the U.S. Agency for Global Media, * the Asia Foundation, * the U.S. Institute of Peace, * the Center for Middle Eastern-Western Dialogue Trust Fund, * the Eisenhower Exchange Fellowship Program, * the Israeli Arab Scholarship Program, * the East-West Center, and * the National Endowment for Democracy. The bill provides appropriations for Other Commissions, including * the Commission for the Preservation of America's Heritage Abroad, * the U.S. Commission on International Religious Freedom, * the Commission on Security and Cooperation in Europe, * the Congressional-Executive Commission on the People's Republic of China, * the U.S.-China Economic and Security Review Commission, and * the Western Hemisphere Drug Policy Commission. The bill provides appropriations to * the U.S. Agency for International Development (USAID), * the State Department and the President for International Security Assistance, * the President and International Financial Institutions for Multilateral Assistance, and * specified accounts for Overseas Contingency Operations/ Global War on Terrorism. The bill provides appropriations for Bilateral Economic Assistance to * the President; * the State Department; * Independent Agencies, including the Peace Corps, the Millennium Challenge Corporation, the Inter-American Foundation, and the U.S. African Development Foundation; and * the Department of the Treasury. The bill provides appropriations for Export and Investment Assistance to * the Export-Import Bank of the United States, * the U.S. International Development Finance Corporation, and * the U.S. Trade and Development Agency. The bill sets forth requirements and restrictions for using funds provided by this and other appropriations Acts.To prohibit offices of Congress from appointing interns who are citizens of certain countries which exert malign foreign influences in the United States.
HR #8940 | Last Action: 12/10/2020This bill prohibits a congressional office from appointing an intern who is a citizen of a specified foreign country (e.g., Russia, Iran, North Korea, or China).No Tax Breaks for Outsourcing Act
S #780 | Last Action: 3/13/2019No Tax Breaks for Outsourcing Act This bill modifies the tax treatment of the foreign source income of domestic corporations. The bill includes provisions that * eliminate an exemption for certain returns from tangible investments made overseas, * eliminate deductions for a domestic corporation's foreign-derived intangible income and global intangible low-taxed income, * repeal a provision that excludes foreign oil and gas extraction income from the tested income of a controlled foreign corporation, * limit the tax deduction for the interest expenses of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards), * modify the rules for the taxation of inverted corporations (U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States), and * treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes.No Tax Breaks for Outsourcing Act
HR #1711 | Last Action: 3/13/2019No Tax Breaks for Outsourcing Act This bill modifies the tax treatment of the foreign source income of domestic corporations. The bill includes provisions that * eliminate an exemption for certain returns from tangible investments made overseas, * eliminate deductions for a domestic corporation's foreign-derived intangible income and global intangible low-taxed income, * repeal a provision that excludes foreign oil and gas extraction income from the tested income of a controlled foreign corporation, * limit the tax deduction for the interest expenses of a U.S. corporation that is a member of a financial reporting group (i.e., a group that prepares consolidated financial statements according to generally accepted accounting principles or international financial reporting standards), * modify the rules for the taxation of inverted corporations (U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States), and * treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes.Protecting Against International Terrorism Act of 2019
S #2939 | Last Action: 11/21/2019Protecting Against International Terrorism Act of 2019 This bill reauthorizes through December 15, 2027, statutory provisions that allow the government to (1) access certain business records for foreign intelligence and international terrorism investigations, and (2) treat individual terrorists as agents of foreign powers in certain instances. The bill also terminates the government's authority to access call records on an ongoing basis as part of foreign intelligence and international terrorism investigations.Get Foreign Money Out of U.S. Elections Act
HR #746 | Last Action: 1/24/2019Get Foreign Money Out of U.S. Elections Act This bill bans campaign contributions and expenditures by corporations, limited liability corporations, and partnerships that are controlled, influenced, or owned by foreign nationals. The bill prohibits foreign nationals and such corporations, limited liability corporations, and partnerships from making disbursements to political committees that accept donations or contributions that do not comply with the limitations, prohibitions, and reporting requirements of the Federal Election Campaign Act of 1971. Corporate political action committees may make contributions and expenditures only if they comply with limitations on the involvement of foreign nationals and such corporations, limited liability corporations, and partnerships.Department of State, Foreign Operations, and Related Programs Permanent General Provisions Act of 2019
S #1819 | Last Action: 6/12/2019Department of State, Foreign Operations, and Related Programs Permanent General Provisions Act of 2019 This bill makes permanent various foreign relations-related provisions. These include * a general requirement that expenditures under certain Department of State contracts for consulting services are made public; * a general prohibition against providing certain types of foreign assistance to a country whose duly elected head of government has been deposed in a military coup d'etat, a country in default of certain U.S. government loans, or a country that supports international terrorism; * a general prohibition against assistance by the Export-Import Bank or the Overseas Private Investment Corporation for the non-U.S. production of a commodity for export that will likely be in surplus and where such surplus will cause substantial injury to U.S. producers; * various requirements relating to how the U.S. Agency for International Development (USAID) handles funds for certain types of assistance; * a provision generally authorizing aircraft procured for certain State Department programs to be used in any other program or region; * a provision authorizing the extension of the employment of certain USAID personnel for up to four years; * a provision generally requiring certain foreign-relations-related programs to provide timely access to documents to the relevant Inspector General office; and * a provision authorizing assistance to certain countries for such countries to commercially lease certain defense articles from U.S. commercial suppliers.Office of International Disability Rights Act
S #3880 | Last Action: 6/3/2020Office of International Disability Rights Act This bill establishes disability inclusion measures at the Department of State, including the creation of the Office of International Disability Rights. Specifically, the bill establishes the Office of International Disability Rights, which shall coordinate U.S. efforts regarding human rights for people with disabilities and advance the status of people with disabilities in U.S. foreign policy. The bill also requires the State Department to develop and adopt a formal policy for disability inclusion in U.S. foreign assistance programming and disaster response programming. The State Department must take specified steps to prioritize accessibility practices when hiring, recruiting, and assigning civil service employees and foreign service officers with disabilities. Further, the State Department must ensure that embassies, consulates, and their services are accessible to people with disabilities. Additionally, the State Department must require mandatory disability inclusion training for all civil service and foreign service personnel, which shall include country-specific and cultural considerations.Removing Incentives for Outsourcing Act
S #1610 | Last Action: 5/22/2019Removing Incentives for Outsourcing Act This bill modifies the tax treatment of foreign source income of domestic corporations to (1) eliminate a provision that allows companies to deduct a portion of the tangible assets of their controlled foreign corporations (CFCs) before the tax on foreign income applies, and (2) require net CFC tested income to be determined on a country-by-country basis rather than globally. The bill also requires the Joint Committee on Taxation to study options for reforming laws related to the taxation of income from international sources.To repeal certain foreign affairs reporting requirements.
HR #1677 | Last Action: 3/11/2019This bill repeals certain reporting requirements related to foreign affairs, specifically requirements for periodic reports on (1) world military expenditures and arms transfers, (2) U.S. activities related to the Organization for Security and Cooperation in Europe, (3) Foreign Services positions that require foreign language competence, and (4) U.S. assistance related to international terrorism.Foreign Civil Aviation Authority Assistance Act of 2020
S #3959 | Last Action: 6/15/2020Foreign Civil Aviation Authority Assistance Act of 2020 This bill provides Federal Aviation Administration (FAA) support for foreign civil aviation authorities. In addition to the current requirement that the FAA promote and achieve global improvements in the safety, efficiency, and environmental effect of air travel, the bill requires the FAA to engage both bilaterally and multilaterally, including with the International Civil Aviation Organization, to bolster international collaboration, data sharing, and harmonization of international aviation safety requirements. The FAA must seek to expand technical assistance in support of enhancing international aviation safety, and it is authorized to provide technical assistance related to all aviation safety-related training and operational services in connection with bilateral and multilateral agreements. The bill also authorizes support for the implementation of certain recommendations to address pilots' dependency on automation.International Regulatory Cooperation Improvement Act
HR #4696 | Last Action: 11/8/2019International Regulatory Cooperation Improvement Act This bill allows the Commodity Futures Trading Commission to incur expenses for incidentals such as meals and transportation when hosting certain foreign officials. The bill also allows the commission to receive assistance such as personnel and support services from other departments and agencies within the federal government and from certain foreign authorities.To amend the Internal Revenue Code of 1986 to clarify that payment of taxes on deferred foreign income in installments shall not prevent credit or refund of overpayments or increase estimated taxes.
HR #2985 | Last Action: 5/23/2019This bill amends the Internal Revenue Code to provide that installment payment of taxes on deferred foreign income shall not prevent a credit or refund of overpayments of tax or an increase in estimated taxes.Stop Tax Haven Abuse Act
S #779 | Last Action: 3/13/2019Stop Tax Haven Abuse Act This bill authorizes the Department of the Treasury to impose restrictions on foreign jurisdictions or financial institutions to counter money laundering and efforts to significantly impede U.S. tax enforcement. The bill amends the Internal Revenue Code to * expand reporting requirements for certain foreign investments and accounts held by U.S. persons, * establish a rebuttable presumption against the validity of transactions by institutions that do not comply with reporting requirements under the Foreign Account Tax Compliance Act, * treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes, * treat swap payments sent offshore as taxable U.S. source income, * require reporting of United States beneficial owners of foreign-owned financial accounts, * impose additional requirements for third party summonses used to obtain information in tax investigations that do not identify the person with respect to whose liability the summons is issued (i.e., John Doe summons), and * modify the rules for the taxation of inverted corporations (U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States). The bill amends the Securities Exchange Act of 1934 to (1) require corporations to disclose certain financial information on a country-by-country basis, and (2) impose penalties for failing to disclose offshore holdings. The bill makes investment advisers and persons engaged in forming new business entities subject to new anti-money laundering requirements.Stop Tax Haven Abuse Act
HR #1712 | Last Action: 3/13/2019Stop Tax Haven Abuse Act This bill authorizes the Department of the Treasury to impose restrictions on foreign jurisdictions or financial institutions to counter money laundering and efforts to significantly impede U.S. tax enforcement. The bill amends the Internal Revenue Code to * expand reporting requirements for certain foreign investments and accounts held by U.S. persons, * establish a rebuttable presumption against the validity of transactions by institutions that do not comply with reporting requirements under the Foreign Account Tax Compliance Act, * treat certain foreign corporations managed and controlled primarily in the United States as domestic corporations for tax purposes, * treat swap payments sent offshore as taxable U.S. source income, * require reporting of United States beneficial owners of foreign-owned financial accounts, * impose additional requirements for third party summonses used to obtain information in tax investigations that do not identify the person with respect to whose liability the summons is issued (i.e., John Doe summons), and * modify the rules for the taxation of inverted corporations (U.S. corporations that acquire foreign companies to reincorporate in a foreign jurisdiction with income tax rates lower than the United States). The bill amends the Securities Exchange Act of 1934 to (1) require corporations to disclose certain financial information on a country-by-country basis, and (2) impose penalties for failing to disclose offshore holdings. The bill makes investment advisers and persons engaged in forming new business entities subject to new anti-money laundering requirements.