S. 750Senate109th Congress (2005-2007)In Committee

A bill to amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between related foreign corporations.

Sponsored by Jon KylSen. Jon Kyl (R-AZ)
Introduced April 11, 2005

Legislative Activity

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2 earlier actions
SenateIntro Referral Latest Action

Read twice and referred to the Committee on Finance.

April 11, 2005

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SenateIntro Referral

Introduced in Senate

April 11, 2005

SenateIntro Referral

Sponsor introductory remarks on measure. (CR S3424)

April 11, 2005

SenateIntro Referral

Read twice and referred to the Committee on Finance.

April 11, 2005

Floor Debate

24 members

What members said about S. 750 on the floor

6 Republicans18 Democrats
Chuck Grassley
Sen. Chuck GrassleyR-IA · May 11, 2006

Mr. President, am I right that we are prepared to proceed to the text of the conference reconciliation report? Mr. President, before I explain what is in the conference report, I want to make clear…

Max Baucus
Sen. Max BaucusD-MT · May 11, 2006

Madam President, in consultation with the chairman of the committee, I ask consent that the filing deadline for the second-degree amendments to S. 1955 occur at 3 p.m. today. Madam President, I begin…

Richard J. Durbin
Sen. Richard J. DurbinD-IL · May 11, 2006

Reserving the right to object, I thank the chairman of the committee for being so thoughtful as to include the substitute as a possible vote after cloture. I ask the Senator if he would consider…

Kent Conrad
Sen. Kent ConradD-ND · May 11, 2006

Mr. President, I want to thank my very able colleague from Delaware, Senator Carper. I always enjoy listening to him and his perspective on these issues. I think he is somebody who is rock solid on…

Trent Lott
Sen. Trent LottR-MS · May 11, 2006

Mr. President, I ask unanimous consent to get an agreement for the lineup of speakers over the next several minutes. It has been cleared by both managers here in the Senate. I ask unanimous consent…

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John F. Kerry
Sen. John F. KerryD-MA · May 11, 2006

Mr. President, today we are debating a $70 billion tax reconciliation bill and the centerpiece of this bill is a provision to extend the lower tax rates on capital gains and dividends that do not…

Rick Santorum
Sen. Rick SantorumR-PA · May 11, 2006

Mr. President. Mr. President, I am happy to be here in strong support of a bill that I guess I was somewhat responsible for in giving its title to: the Tax Increase Prevention Act. We first called…

Barack Obama
Sen. Barack ObamaD-IL · May 11, 2006

Mr. President, I rise today to speak in opposition to the tax reconciliation conference report. The Federal Government is the rare institution that can spend money it just doesn't have. We spend and…

Judd Gregg
Sen. Judd GreggR-NH · May 11, 2006

Mr. President, I appreciate the Senator from Mississippi granting me this time on this very important piece of legislation. I want to pick up on the statement made by the junior Senator from…

George V. Voinovich
Sen. George V. VoinovichR-OH · May 11, 2006

Mr. President, I rise to speak on the reconciliation bill that is before the Senate. There are three reasons we should oppose the tax cuts that are currently before the Senate, as well as tax cuts…

Mark Dayton
Sen. Mark DaytonD-MN · May 11, 2006

Mr. President, this bill should be a billboard for the corruption of the public interest in Washington. It is a disgrace, it is an abomination, and it should be rejected by the Senate. Last year,…

Byron L. Dorgan
Sen. Byron L. DorganD-ND · May 11, 2006

Mr. President, I like my colleague from Iowa. We work together on a lot of things. But I know he will give me room to disagree today. I disagree very strongly about the philosophy, the approach, and…

Christopher J. Dodd
Sen. Christopher J. DoddD-CT · May 11, 2006

Mr. President, I begin by thanking my friend and colleague from Iowa, chairman of the Finance Committee, and the Senator from Montana for the hard work they and their staffs put in on this…

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Ron Wyden
Sen. Ron WydenD-OR · May 11, 2006

Mr. President, before he leaves the floor, I wish to say to the distinguished Senator from Mississippi that I am certainly not interested in class warfare. But what I am interested in is giving all…

Harry Reid
Sen. Harry ReidD-NV · May 11, 2006

Mr. President, this is one of the rare times that we have been able to move forward on a bipartisan basis. The procedural aspects of this immigration debate are over with. The two leaders want a…

Russell D. Feingold
Sen. Russell D. FeingoldD-WI · Apr 11, 2005

Mr. President, I rise today to introduce the Corps of Engineers Modernization and Improvement Act of 2005. I am pleased to be joined by the senior Senator from Arizona, Mr. McCain, who worked with me…

Dianne Feinstein
Sen. Dianne FeinsteinD-CA · May 11, 2006

Reserving the right to object, Mr. President, could I ask a question? I believe I am recognized for 15 minutes. I thank the Chair. Madam President, I don't think any single bill or issue more…

Jack Reed
Sen. Jack ReedD-RI · May 11, 2006

Madam President, I rise in opposition to this tax reconciliation conference report. At a time when we are all already shouldering a large budget deficit and fighting a war, this is an irresponsible…

Daniel K. Akaka
Sen. Daniel K. AkakaD-HI · May 11, 2006

Mr. President, the chairman of the Finance Committee is a very good friend, and I know him as a good friend and a very passionate person who takes his work very seriously and is a hard worker in this…

Robert C. Byrd
Sen. Robert C. ByrdD-WV · Apr 11, 2005

Mr. President, today I am introducing the International Clean Energy Deployment and Global Energy Markets Investment Act of 2005. This is a forward-thinking, made-in-America action plan that can…

Frank R. Lautenberg
Sen. Frank R. LautenbergD-NJ · May 11, 2006

Mr. President, I wish to call attention to a saying that is kicked around here quite often: When you are in a hole, quit digging. We are approaching $10 trillion in debt, and the majority--and I…

Charles E. Schumer
Sen. Charles E. SchumerD-NY · May 11, 2006

Mr. President, I ask unanimous consent that I be ceded 15 minutes from our side's time. Mr. President, everyone here knows we are going to vote on a $70 billion reconciliation bill later today, and…

William H. Frist
Sen. William H. FristR-TN · May 11, 2006

Mr. President, in a moment, we will begin consideration of the conference report to accompany the Tax Relief Act. Our order from last night provides for up to 8 hours of debate from the statutory…

Tom Harkin
Sen. Tom HarkinD-IA · May 11, 2006

Mr. President, if you want to know why this Republican- controlled Congress's approval rating has plunged to 22 percent and why President Bush's approval rating is an equally dismal 31 percent,…

Bill Text

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Introduced in SenateIssued April 11, 2005

II

109th CONGRESS

1st Session

S. 750

IN THE SENATE OF THE UNITED STATES

April 11, 2005

Mr. Kyl introduced the following bill; which was read twice and referred to the Committee on Finance

A BILL

To amend the Internal Revenue Code of 1986 to allow look-through treatment of payments between related foreign corporations.

1.

Look-through treatment of payments between related controlled foreign corporations under the foreign personal holding company rules

(a)

In general

Section 954(c) of the Internal Revenue Code of 1986 (relating to foreign personal holding company income) is amended by adding at the end the following new paragraph:

(6)

Look-thru rule for related controlled foreign corporations

For purposes of this subsection, dividends, interest, rents, and royalties received or accrued from a controlled foreign corporation which is a related person shall not be treated as foreign personal holding company income to the extent attributable or properly allocable (determined under rules similar to the rules of subparagraphs (C) and (D) of section 904(d)(3)) to income of the related person which is not subpart F income. For purposes of this paragraph, interest shall include factoring income which is treated as income equivalent to interest for purposes of paragraph (1)(E). The Secretary shall prescribe such regulations as may be appropriate to prevent the abuse of the purposes of this paragraph.

.

(b)

Effective date

The amendment made by this section shall apply to taxable years of foreign corporations ending after January 1, 2005, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end.