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H.R. 1303 · 109th Congress

Fairness and Accountability in International Taxation Act of 2005

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IntroducedPassed one chamberPassed both chambersBecame law (gold)Resolution agreed to (full, dark)Failed or vetoed (gray)

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Never voted on. It didn't reach a floor vote before the 109th Congress ended, so it expired. A bill has to be introduced again to be considered in a new Congress.

Fairness and Accountability in International Taxation Act of 2005 - Amends the Internal Revenue Code to deny reduced withholding tax treaty benefits to a foreign entity on any deductible foreign payment (deductible payment made by a domestic entity to a related foreign entity) unless such entity is predominantly owned by individuals who are residents of…

What it does: CRS summary · Introduced in House · Mar 15, 2005
Fairness and Accountability in International Taxation Act of 2005 - Amends the Internal Revenue Code to deny reduced withholding tax treaty benefits to a foreign entity on any deductible foreign payment (deductible payment made by a domestic entity to a related foreign entity) unless such entity is predominantly owned by individuals who are residents of such foreign country. Exempts from such provision: (1) corporations with substantial business activities in a treaty country with specified tax rates; (2) payments received by controlled foreign corporations from U.S. shareholders; and (3) certain conduit payments made by foreign corporations.

Provides a special income and deduction allocation rule for related-party inbound (transfer price reduced by deflected tax haven income) and outbound (transfer price increased by deflected tax haven income) transactions. Defines "related-party inbound transaction," "related-party outbound transaction," and "deflected tax haven."

Written by the nonpartisan Congressional Research Service. All summary versions on Congress.gov

About this bill and sources

Official title: Fairness and Accountability in International Taxation Act of 2005

Latest action (Mar 15, 2005): Referred to the House Committee on Ways and Means.

Policy area: Taxation · Origin: House · Introduced: Mar 15, 2005

Official page on Congress.gov · Bill text (GovInfo) · Status record (XML)

No recorded floor vote found.