S 861
99th Congress
Senate
Taxation
Accounting
Corporation taxes
Corporations and Stocks
Foreign Trade and Investments
Income tax
International corporations
Research
Research and development
Science and technology
Tax administration
Tax deductions
A bill to amend the Internal Revenue Code of 1954 to treat deductions for research and experimental expenses attributable to activities conducted in the United States as allocable to income from…
Show full title
Everywhere this bill has been
3 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Apr 11, 1985
Committee on Finance requested executive comment from OMB, Treasury Department.
Apr 3, 1985
Read twice and referred to the Committee on Finance.
Apr 3, 1985
Introduced in Senate
Ask about this bill
Have a question about what this bill does? Ask in plain English; the answer is drawn from the bill's actual text and official record, and it'll tell you when something isn't in the text rather than guess.
Plain-English summary
Amends the Internal Revenue Code to permit U.S. businesses with operations in foreign countries to treat all of their domestic research and experimental expenditures as deductions against U.S. source income. (Current IRS regulations require the allocation of a portion of such expenses against foreign source income.)
What's happening now
Committee on Finance requested executive comment from OMB, Treasury Department.
Committees of jurisdiction
1
Cosponsors
1
Cite this page
U.S. Congress. (2026). S. 861: A bill to amend the Internal Revenue Code of 1954 to treat deductions for research and experimental expenses attributable to activities conducted in the United States as allocable to income from sources within the United States.. 99th Congress. Open America. https://openamerica.io/bill/99-S-861/
"S. 861: A bill to amend the Internal Revenue Code of 1954 to treat deductions for research and experimental expenses attributable to activities conducted in the United States as allocable to income from sources within the United States.." 99th Congress, 2026, Open America, https://openamerica.io/bill/99-S-861/.
S. 861, 99th Cong. (2026), https://openamerica.io/bill/99-S-861/.
[S. 861: A bill to amend the Internal Revenue Code of 1954 to treat deductions for research and experimental expenses attributable to activities conducted in the United States as allocable to income from sources within the United States.](https://openamerica.io/bill/99-S-861/)