GovTrack’s Bill Summary
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Library of Congress Summary
The summary below was written by the Congressional Research Service, which is a nonpartisan division of the Library of Congress.
United States Job Creation and International Tax Reform Act of 2012 - Amends the Internal Revenue Code, with respect to the taxation of foreign income, to allow:
(1) a 95% tax deduction for the foreign source portion of dividends that a domestic corporation receives from a controlled foreign corporation of which it is a U.S. shareholder,
(2) domestic corporations to treat gain on the sale or exchange of stock of a foreign corporation held for at least one year as dividends eligible for the 95% tax deduction,
(3) a 50% tax deduction for the foreign intangible income of a domestic corporation, and
(4) a U.S. shareholder of a controlled foreign corporation to elect a 70% tax deduction for certain amounts received from such a corporation.
Includes certain low-taxed foreign income as subpart F income (e.g., certain passive income, insurance income, foreign-base company income, income from countries subject to international boycotts, illegal bribes, kickbacks, and similar payments, and income from countries where the United States has severed diplomatic relations).
Makes permanent exemptions from treatment as subpart F income for:
(1) certain payments of dividends, interest, rents, and royalties received from a related controlled foreign corporation; and
(2) active financing income.
Modifies rules relating to the foreign tax credit to create a separate income category for foreign intangible income.
Accelerates the effective date of the worldwide interest allocation rules to taxable years beginning after December 31, 2012 (currently, after December 31, 2020).
House Republican Conference Summary
The summary below was written by the House Republican Conference, which is the caucus of Republicans in the House of Representatives.
No summary available.
House Democratic Caucus Summary
The House Democratic Caucus does not provide summaries of bills.
So, yes, we display the House Republican Conference’s summaries when available even if we do not have a Democratic summary available. That’s because we feel it is better to give you as much information as possible, even if we cannot provide every viewpoint.
We’ll be looking for a source of summaries from the other side in the meanwhile.