Summary: H.R.1278 — 104th Congress (1995-1996)All Information (Except Text)

There is one summary for H.R.1278. Bill summaries are authored by CRS.

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Introduced in House (03/21/1995)

Corporate Welfare Reduction Act of 1995 - Amends the Internal Revenue Code, with respect to determining the foreign tax credit, to replace the formula for reducing the amount of oil and gas extraction taxes taken into account. Disallows as creditable amounts: (1) any taxes paid or accrued to a foreign country with respect to foreign oil and gas income (including extraction income) which are not imposed under the country's generally applicable income tax law; and (2) any other taxes on such income to the extent that the country's law is structured or operates so that the tax amount imposed will generally be materially greater, over a reasonable period, than the amount generally imposed on other income. Separates such income, for purposes of certain limitations on the application of the credit, into foreign oil and gas extraction income and foreign oil related income.

Removes the deferral, for purposes of taxation of controlled foreign corporations, of tax on extraction income or income from consumption in the foreign country.

Provides that the Secretary of the Treasury's authority, in allocating income, deductions, credits, and allowances among taxpayers owned or controlled by the same interests, shall not be limited by any restriction on the ability of the entities to transfer or receive money or property.

Terminates, effective with taxable years beginning January 1, 1996, the exclusion of foreign earned income and the housing cost amounts of U.S. citizens or residents living abroad.

Treats the gain or loss of a nonresident alien individual or foreign corporation that is a ten-percent shareholder in a domestic corporation upon disposition of such a corporation's stock as if the taxpayer were engaged during the taxable year in a trade or business within the United States and such gain or loss attributable to a permanent U.S. trade or business establishment. Imposes a 26-percent minimum tax on nonresident alien individuals. Provides for the withholding of tax on such dispositions, except in the case of stock which is not regularly traded. Excepts such gain from the branch profits tax imposed on foreign corporations. Requires notice to the Secretary upon distributions by a U.S. person to a foreign person in redemption of stock or complete liquidation of a subsidiary.

Removes the exemption of ten-percent shareholders from the tax on interest of nonresident alien individuals received from portfolio debt investments. Redefines portfolio interest as only interest paid on obligations issued by governmental entities.

Provides special rules for determining the source of income from the sale of inventory property.