A bill to amend the Internal Revenue Code of 1954 to repeal the 30 percent withholding tax on interest received by foreigners on certain portfolio investments.

Summary

Amends the Internal Revenue Code to exempt from income taxation interest income received by a nonresident alien individual or foreign corporation on investments in a U.S. corporation or partnership, if such alien does not own, either directly or constructively, ten percent or more of the voting power of the corporation or ten percent or more of the capital or profits interest of the partnership. Sets forth criteria for determining the attribution of interests in such corporations or partnerships to a nonresident alien from other corporations, partnerships, or trusts. Provides for the denial of such tax exemption if the Secretary of the Treasury determines that the exchange of information between the United States and a foreign country is inadequate to enable the Secretary to identify the recipients of exempt interest income and that the exchange of such information is necessary to prevent evasion of taxes.

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Documents

1 official file

• Introduced in Senate

  summary · EN · 19 November 1980

  Open at official source

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