HR 1303
109th Congress
House
Taxation
Commerce
Corporation taxes
Finance and Financial Sector
Foreign Trade and International Finance
Foreign corporations
Income tax
International Affairs
Partnerships
Prices
Residence requirements
Stockholders
Subsidiary corporations
Tax deductions
Tax evasion
Tax havens
Tax rates
Tax treaties
Taxation of foreign income
Withholding tax
Fairness and Accountability in International Taxation Act of 2005
Everywhere this bill has been
2 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Mar 15, 2005
Referred to the House Committee on Ways and Means.
Mar 15, 2005
Introduced in House
Plain-English summary
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."
What's happening now
Referred to the House Committee on Ways and Means.
Committees of jurisdiction
1