A bill to repeal the credit against U.S. taxes for foreign taxes paid, and allow a deduction; and to repeal the deferral of United States tax on the income of foreign subsidiaries of United States companies (as permitted under present law), and tax profits of foreign subsidiaries currently to their United States parents in the same manner as domestic companies.

Summary

Amends the Internal Revenue Code to repeal provisions allowing the foreign tax credit. Requires the immediate inclusion in gross income of U.S. taxpayers' pro rata shares of controlled foreign corporations' net profits which can legally be distributed. Allows domestic corporations an exclusion from gross income of previously taxed earnings and profits of a foreign corporation of which they own, directly or indirectly, specified portions of the voting stock. Allows individuals an election to be taxed at corporate rates under these provisions.

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• Introduced in Senate

  summary · EN · 20 February 1981

  Open at official source

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