[Congressional Bills 113th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4464 Reported in House (RH)]

                                                 Union Calendar No. 316
113th CONGRESS
  2d Session
                                H. R. 4464

                          [Report No. 113-428]

 To amend the Internal Revenue Code of 1986 to make permanent the look-
   through treatment of payments between related controlled foreign 
                             corporations.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                             April 10, 2014

Mr. Boustany (for himself, Mr. Kind, Mr. Reed, Mr. Schock, Ms. Jenkins, 
   Mr. Tiberi, Mr. Pascrell, Mr. Larson of Connecticut, Mr. Young of 
Indiana, Mr. Matheson, and Mr. Crowley) introduced the following bill; 
         which was referred to the Committee on Ways and Means

                              May 2, 2014

         Additional sponsor: Ms. Linda T. Sanchez of California

                              May 2, 2014

  Reported with an amendment, committed to the Committee of the Whole 
       House on the State of the Union, and ordered to be printed
 [Strike out all after the enacting clause and insert the part printed 
                               in italic]


_______________________________________________________________________

                                 A BILL


 
 To amend the Internal Revenue Code of 1986 to make permanent the look-
   through treatment of payments between related controlled foreign 
                             corporations.


 


    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

<DELETED>SECTION 1. LOOK-THROUGH TREATMENT OF PAYMENTS BETWEEN RELATED 
              CONTROLLED FOREIGN CORPORATIONS MADE PERMANENT.</DELETED>

<DELETED>    (a) In General.--Paragraph (6) of section 954(c) of the 
Internal Revenue Code of 1986 is amended by striking subparagraph 
(C).</DELETED>
<DELETED>    (b) Effective Date.--The amendment 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 
with or within which such taxable years of foreign corporations 
end.</DELETED>

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Permanent CFC Look-Through Act of 
2014''.

SEC. 2. LOOK-THROUGH TREATMENT OF PAYMENTS BETWEEN RELATED CONTROLLED 
              FOREIGN CORPORATIONS MADE PERMANENT.

    (a) In General.--Paragraph (6) of section 954(c) of the Internal 
Revenue Code of 1986 is amended by striking subparagraph (C).
    (b) Effective Date.--The amendment 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 with or within 
which such taxable years of foreign corporations end.
                                                 Union Calendar No. 316

113th CONGRESS

  2d Session

                               H. R. 4464

                          [Report No. 113-428]

_______________________________________________________________________

                                 A BILL

 To amend the Internal Revenue Code of 1986 to make permanent the look-
   through treatment of payments between related controlled foreign 
                             corporations.

_______________________________________________________________________

                              May 2, 2014

  Reported with an amendment, committed to the Committee of the Whole 
       House on the State of the Union, and ordered to be printed