International Tax Simplification for American Competitiveness Act of 1999

Summary

International Tax Simplification for American Competitiveness Act of 1999 - Title I: Treatment of Controlled Foreign Corporations - Amends the Internal Revenue Code (IRC) with respect to subpart F (Controlled Foreign Corporations) to set forth provisions concerning, among other things: (1) permanently extend the subpart F exemption for active financing income earned on business operation overseas; (2) direct the Secretary of the Treasury to conduct a study on the feasibility of treating all countries included in the European Union as a single country for purposes of applying the same country exceptions under subpart F; (3) provide for the determination of subpart F earnings and profits under generally accepted U.S. accounting principles; (4) exclude from the definition of "foreign base company oil related income" the pipeline transportation of oil or gas within such foreign country; and (5) exclude from the definition of the term "foreign base company services income" income derived in connection with the performance of services which are related to the transmission of high voltage electricity. Title II: Provisions Relating to Foreign Tax Credit - Revises section 904 (Limitation On Credit) of the (IRC) to, among other things: (1) extend the period to which excess foreign taxes may be carried; (2) define overall domestic loss and sets forth provisions for determining taxable income for any taxpayer sustaining such a loss; (3) provide an exception for interest on certain securities; (4) revise provisions concerning the of application of look-thru rules to dividends from noncontrolled section 902 corporations to provide, in general, that any dividend from a noncontrolled section 902 corporation with respect to the taxpayer shall be treated as income in a separate category in proportion to the ratio of the portion of earnings and profits attributable to income in such category to the total amount of earnings and profits; (5) repeal the 90 percent limitation on the utilization of the foreign tax credit; and (6) repeals section 907 (Special Rules In Case of Foreign Oil and Gas Income) of the IRC. Title III: Other Provisions - Applies constructive ownership rules for purposes of determining certain post-1986 undistributed U.S. earnings. Applies capitalization rules to nonresident aliens and foreign corporations. Repeals the special rule for military property with respect to exempt foreign trade income. Revises the definition of U.S. property to exclude certain assets acquired by dealers in the ordinary course of business. Exempts from the taxes on nonresident aliens and foreign corporations certain regulated investment company dividends. Directs the Secretary of the Treasury, with respect to the Puerto Rico and possession tax credit, to exclude from the definition of the term "intangible property" any preliminary agreement which is not legally enforceable. Sets forth provisions concerning airline mileage awards to certain foreign persons. Repeals subpart G (Export Trade Corporations) of part III of subchapter N of chapter 1 of the Internal Revenue Code. Prohibits the Secretary from requiring a corporation to report any information with respect to any foreign person which is a related person if the aggregate value of the transactions between the corporation and the related person does not exceed $5 million.

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3 official files

• Introduced in House

  summary · EN · 8 June 1999

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• Introduced in House (text)

  Introduced in House · EN · 7 June 1999

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• Introduced in House (PDF)

  Introduced in House · EN · 7 June 1999

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