S. 2380 · 110th Congress
A bill to amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to…
Full title
A bill to amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions.
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Never voted on. It didn't reach a floor vote before the 110th Congress ended, so it expired. A bill has to be introduced again to be considered in a new Congress.
R
SmithSponsor1 cosponsor · 1 D
1 signed on when it was introduced; the rest joined later. Cosponsors who withdrew aren't shown.
Amends Internal Revenue Code provisions relating to taxation of U.S. shareholders of controlled foreign corporations to: (1) exclude from foreign personal holding company income rents and royalties attributable to computer software that is leased or licensed for use outside the United States and that was developed or marketed by a controlled foreign…
What it does: CRS summary · Introduced in Senate · Nov 16, 2007
Amends Internal Revenue Code provisions relating to taxation of U.S. shareholders of controlled foreign corporations to: (1) exclude from foreign personal holding company income rents and royalties attributable to computer software that is leased or licensed for use outside the United States and that was developed or marketed by a controlled foreign corporation or related person; (2) increase to $5 million (currently, $1 million) the de minimis dollar amount for determinations of foreign base company income; (3) permanently extend the look-thru rule for for the tax treatment of income received or accrued from a controlled foreign corporation; and (4) permanently extend the exemption from foreign personal holding company income for active financing income (income from insurance, banking, financing, or similar businesses) earned on business operations overseas.
Written by the nonpartisan Congressional Research Service. All summary versions on Congress.gov
About this bill and sources
Official title: A bill to amend the Internal Revenue Code of 1986 to modernize the application of the subpart F rules to computer software, to expand the subpart F de minimis rule, and to extend certain expiring provisions.
Latest action (Nov 16, 2007): Read twice and referred to the Committee on Finance.
Policy area: Taxation · Origin: Senate · Introduced: Nov 16, 2007
Official page on Congress.gov · Bill text (GovInfo) · Status record (XML)
No recorded floor vote found.