United States 112th Congress Status: Died 1 R cosponsors

S 2091 — United States Job Creation and International Tax Reform Act of 2012

Last action — Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S498-502)

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  1. ✓
    Introduced
  2. ✓
    In Committee
  3. Died in session

This bill died with 112th Congress. It reached “In Committee” and never advanced before the session ended, so it can no longer move — a new version would have to be reintroduced in the current session.

This bill is no longer active — its legislative session has ended, so there is no live prognosis. It would have to be reintroduced in the current session to move again.

Summary

United States Job Creation and International Tax Reform Act of 2012 - Amends the Internal Revenue Code, with respect to the taxation of foreign income, to allow: (1) a 95% tax deduction for the foreign source portion of dividends that a domestic corporation receives from a controlled foreign corporation of which it is a U.S. shareholder, (2) domestic corporations to treat gain on the sale or exchange of stock of a foreign corporation held for at least one year as dividends eligible for the 95% tax deduction, (3) a 50% tax deduction for the foreign intangible income of a domestic corporation, and (4) a U.S. shareholder of a controlled foreign corporation to elect a 70% tax deduction for certain amounts received from such a corporation. Includes certain low-taxed foreign income as subpart F income (e.g., certain passive income, insurance income, foreign-base company income, income from countries subject to international boycotts, illegal bribes, kickbacks, and similar payments, and income from countries where the United States has severed diplomatic relations). Makes permanent exemptions from treatment as subpart F income for: (1) certain payments of dividends, interest, rents, and royalties received from a related controlled foreign corporation; and (2) active financing income. Modifies rules relating to the foreign tax credit to create a separate income category for foreign intangible income. Accelerates the effective date of the worldwide interest allocation rules to taxable years beginning after December 31, 2012 (currently, after December 31, 2020).

Bill Text

We don't have the full text on file for this bill yet.

Read S 2091 on the official United States source →

Action History

  1. Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S498-502)

  2. Sponsor introductory remarks on measure. (CR S497-498)

Sponsors

Sponsorship breakdown

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1 sponsors · 0 co-sponsors · 546 not signed on

Sponsors (1)

Co-sponsors (0)

None.

Not signed on (546)

546 members have not signed on to this bill.

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"Not signed on" means a member has not sponsored or co-sponsored this bill — it does not imply opposition. Members flagged Voted No have a recorded No vote on this bill.

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Subjects

taxation finance
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Frequently asked questions

What does S 2091 do?
United States Job Creation and International Tax Reform Act of 2012 - Amends the Internal Revenue Code, with respect to the taxation of foreign income, to allow: (1) a 95% tax deduction for the foreign source portion of dividends that a domestic corporation receives from a controlled foreign corporation of which it is a U.S. shareholder, (2) domestic corporations to treat gain on the sale or exchange of stock of a foreign corporation held for at least one year as dividends eligible for the 95% tax deduction, (3) a 50% tax deduction for the foreign intangible income of a domestic corporation, and (4) a U.S. shareholder of a controlled foreign corporation to elect a 70% tax deduction for certain amounts received from such a corporation. Includes certain low-taxed foreign income as subpart F income (e.g., certain passive income, insurance income, foreign-base company income, income from countries subject to international boycotts, illegal bribes, kickbacks, and similar payments, and income from countries where the United States has severed diplomatic relations). Makes permanent exemptions from treatment as subpart F income for: (1) certain payments of dividends, interest, rents, and royalties received from a related controlled foreign corporation; and (2) active financing income. Modifies rules relating to the foreign tax credit to create a separate income category for foreign intangible income. Accelerates the effective date of the worldwide interest allocation rules to taxable years beginning after December 31, 2012 (currently, after December 31, 2020).
Who sponsors S 2091?
S 2091 is sponsored by Michael Enzi (R).
What is the current status of S 2091?
This bill died with 112th Congress. It reached “In Committee” and never advanced before the session ended, so it can no longer move — a new version would have to be reintroduced in the current session.
Where can I track S 2091?
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