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S 384 108th Congress Senate

Corporate Patriot Enforcement Act of 2003

Official title: A bill to amend the Internal Revenue Code of 1986 to prevent corporate expatriation to avoid United States income taxes.

Introduced: February 12, 2003 See on congress.gov
Taxation CommerceCorporate mergersCorporation taxesFinance and Financial Sector
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Foreign Trade and International FinanceForeign corporationsIncome taxPartnershipsStock exchangesStockholdersTax evasion
This bill died when the 108th Congress ended
It never became law before the 108th Congress (2003–2004) adjourned, and bills don't carry over to the next Congress. It would have to be reintroduced. You can still save it for reference, but it won't receive updates.
 Everywhere this bill has been 2 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Feb 12, 2003
Read twice and referred to the Committee on Finance.
Feb 12, 2003
Introduced in Senate
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 Latest action February 12, 2003

Read twice and referred to the Committee on Finance.

 Plain-English summary Congressional Research Service
Corporate Patriot Enforcement Act of 2003 - Amends the Internal Revenue Code by determining that acquiring corporations in"corporate expatriation transactions" shall be considered domestic corporations. Defines a "corporate expatriation transaction" as, with certain exceptions, one in which a "nominally foreign corporation" acquires substantially all of the properties held by a domestic corporation and in which, immediately after the transaction, more than 80 percent of the stock of the acquiring corporation is held by former shareholders of the domestic corporation. Lowers the 80 percent threshold to 50 percent when the acquiring "nominally foreign corporation" lacks substantial business activities in the foreign country in which it was created and organized compared to the total activities of the "expanded affiliated group" and the stock is publicly traded, with the principal market of trading being the United States. Defines the terms "nominally foreign corporation" and "expanded affiliated group."

Applies similar rules to partnership transactions.

Establishes that a series of related transactions relevant to the Act shall be handled as a single transaction.

 Related & companion bills 1
 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
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APA
U.S. Congress. (2026). S. 384: Corporate Patriot Enforcement Act of 2003. 108th Congress. Open America. https://openamerica.io/bill/108-S-384/
MLA
"S. 384: Corporate Patriot Enforcement Act of 2003." 108th Congress, 2026, Open America, https://openamerica.io/bill/108-S-384/.
Bluebook (legal)
S. 384, 108th Cong. (2026), https://openamerica.io/bill/108-S-384/.
Markdown link
[S. 384: Corporate Patriot Enforcement Act of 2003](https://openamerica.io/bill/108-S-384/)
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