Fairness and Accountability in International Taxation Act of 2003

Summary

Fairness and Accountability in International Taxation Act of 2003 - Amends the Internal Revenue Code to deny reduced withholding tax treaty benefits to a foreign entity on any deductible foreign payment (deductible payment made by a domestic entity to a related foreign entity) unless such entity is predominantly owned by individuals who are residents of such foreign country. Exempts from such provision: (1) corporations with substantial business activities in a treaty country with specified tax rates; (2) payments received by controlled foreign corporations from U.S. shareholders; and (3) certain conduit payments made by foreign corporations. Provides a special income and deduction allocation rule for related-party inbound (transfer price increased by deflected tax haven income) and outbound (transfer price increased by deflected tax haven income) transactions. Defines "related-party inbound transaction," "related-party outbound transaction," and "deflected tax haven."

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Documents

3 official files

• Introduced in House (text)

  Introduced in House · EN · 21 May 2003

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• Introduced in House (PDF)

  Introduced in House · EN · 21 May 2003

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• Introduced in House

  summary · EN · 21 May 2003

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