H.R. 6660 (112th): Personal Holding Company Tax Parity and Reinvestment Act

112th Congress, 2011–2013. Text as of Dec 13, 2012 (Introduced).

Status & Summary | PDF | Source: GPO

HR 6660 IH

112th CONGRESS

2d Session

H. R. 6660

To amend the Internal Revenue Code of 1986 to exclude dividends from controlled foreign corporations from the definition of personal holding company income for purposes of the personal holding company rules.

IN THE HOUSE OF REPRESENTATIVES

December 13, 2012

Mr. REICHERT (for himself, Mr. MCDERMOTT, Mr. SCHOCK, Mr. RANGEL, Ms. HERRERA BEUTLER, Mr. DICKS, and Mr. SMITH of Washington) introduced the following bill; which was referred to the Committee on Ways and Means

A BILL

To amend the Internal Revenue Code of 1986 to exclude dividends from controlled foreign corporations from the definition of personal holding company income for purposes of the personal holding company rules.

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

SECTION 1. SHORT TITLE.

    This Act may be cited as the ‘Personal Holding Company Tax Parity and Reinvestment Act’.

SEC. 2. EXCLUSION OF DIVIDENDS FROM CONTROLLED FOREIGN CORPORATIONS FROM THE DEFINITION OF PERSONAL HOLDING COMPANY INCOME FOR PURPOSES OF THE PERSONAL HOLDING COMPANY RULES.

    (a) In General- Paragraph (1) of section 543(a) of the Internal Revenue Code of 1986 is amended--

      (1) by redesignating subparagraphs (C) and (D) as subparagraphs (D) and (E), respectively, and

      (2) by inserting after subparagraph (B) the following:

        ‘(C) dividends received by a United States shareholder (as defined in section 951(b)) from a controlled foreign corporation (as defined in section 957(a)),’.

    (b) Effective Date- The amendments made by this Act shall apply to taxable years ending on or after the date of the enactment of this Act.