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United States · Bill · S

S. 936 (102nd)

Foreign Tax Simplification Act of 1991

referredUnited States· United States Congress· EN

Introduced

25 April 1991

Last action

Status

Read twice and referred to the Committee on Finance.

Sponsors

Subjects

Discovery layer

Source updated

26 August 2025

Summary

Foreign Tax Simplification Act of 1991 - Amends the Internal Revenue Code to exempt foreign corporations that are not doing business in the United States from the uniform capitalization rules in determining earnings and profits. Makes a technical correction to the definition of passive foreign investment company. Applies a separate foreign tax credit limitation for foreign corporations in which U.S. parent companies do not own a controlling interest. Requires that foreign tax credits claimed on foreign income be translated in U.S. dollars at the same rate as the income. Provides that the look-through rules for controlled foreign corporations do not apply to companies with less than $1,000,000 in all of their separate categories.

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2 official files

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Sources

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