Sec. 4204. Active financing exception extended with limitation for low-taxed foreign income
329 words·~1 min read·
/bill/113/hr/1/ih/section-4204A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Paragraph
(9)of section 954(h) is amended by striking January 1, 2014 and inserting January 1, 2019 . Paragraph
(10)of section 953(e) is amended— by striking January 1, 2014 and inserting January 1, 2019 , and by striking December 31, 2013 and inserting December 31, 2018 . Paragraph
(1)of section 954(h) is amended to read as follows: For purposes of subsection (c)(1), in the case of an eligible controlled foreign corporation, foreign personal holding company income shall not include— qualified banking or financing income which is subject to an effective rate of income tax imposed by a foreign country which is at least 50 percent of the maximum rate of tax specified in section 11, and 50 percent of any other qualified banking or financing income of such eligible controlled foreign corporation. . Paragraph
(1)of section 954(i) is amended to read as follows: For purposes of subsection (c)(1), in the case of a qualifying insurance company, foreign personal holding company income shall not include— any qualified insurance income which is subject to an effective rate of income tax imposed by a foreign country which is at least 50 percent of the maximum rate of tax specified in section 11, and 50 percent of any other qualified insurance income of such qualifying insurance company. . Subsection
(c)of section 960, as amended by the preceding provisions of this Act, is amended by striking Solely for purposes of subsection
(a)and all that following and inserting the following: Solely for purposes of subsection (a)— section 954(a)(1)(B) shall be applied by substituting 100 percent for 50 percent , and the exclusions under subsections (h)(1)(B) and (i)(1)(B) of section 954 shall not apply, in determining amounts included under section 951(a)(1). . The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2013, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.