Subpart F Tax Simplification Act

Summary

Subpart F Tax Simplification Act - Amends the Internal Revenue Code with respect to the tax imposed on a U.S. corporation for a foreign subsidiary's income attributable to the issuance of an insurance contract in connection with an activity in any country other than the subsidiary's home country. Reduces the exception to such tax for certain income subject to high foreign taxes for controlled foreign corporations from 90 percent of the U.S. tax rate to 80 percent. Provides for computing such tax without regard to any net operating losses (including adjustments allowable with respect to depreciation deductions) arising under the laws of the foreign country in years ending before December 3, 1991. Declares that the countries comprising the European Community shall constitute a single country for purposes of computing the income tax of controlled foreign corporations. (Specifies such countries as: Belgium, Denmark, France, Greece, the Republic of Ireland, Italy, Luxembourg, the Netherlands, Portgual, Spain, the Federal Republic of Germany, and the United Kingdom.) Excludes from foreign personal holding company income certain income derived in the active conduct of insurance business.

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2 official files

• Introduced in Senate (text)

  Introduced in Senate · EN

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• Introduced in Senate

  summary · EN · 20 September 1991

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