S. 1006Senate110th Congress (2007-2009)In Committee

A bill to amend the Internal Revenue Code of 1986 to deny qualified dividend income treatment to certain foreign dividends.

Introduced March 28, 2007

Legislative Activity

Stay on top of the latest movement without scrolling through every action

2 earlier actions
SenateIntro Referral Latest Action

Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S4053-4054)

March 28, 2007

View full timeline
SenateIntro Referral

Introduced in Senate

March 28, 2007

SenateIntro Referral

Sponsor introductory remarks on measure. (CR S4053)

March 28, 2007

SenateIntro Referral

Read twice and referred to the Committee on Finance. (text of measure as introduced: CR S4053-4054)

March 28, 2007

Floor Debate

10 members

What members said about S. 1006 on the floor

5 Republicans4 Democrats1 Independent
John F. Kerry
Sen. John F. KerryD-MA · Mar 28, 2007

Mr. President, I rise today with my colleague Senator Hagel, the Senator from Nebraska, to introduce the Military Reservist and Veteran Small Business Reauthorization Act of 2007. There are currently…

Michael B. Enzi
Sen. Michael B. EnziR-WY · Mar 28, 2007

Mr. President, Wyoming's late, great country music star Chris LeDoux has a song Some Things Never Change. I wish that were the case for Wyoming's hardworking livestock producers. As production…

Richard G. Lugar
Sen. Richard G. LugarR-IN · Mar 28, 2007

Mr. President, I rise to introduce the ``United States Brazil Energy Cooperation Pact.'' This bill would direct the Secretary of State to work with the Government of Brazil and other foreign…

Richard J. Durbin
Sen. Richard J. DurbinD-IL · Mar 28, 2007

Mr. President, today, Senator Hagel and I introduced the bipartisan Global Climate Change Security Oversight Act. We were joined by Senator Feinstein. Our bill states that the consequences of global…

Joseph R. Biden Jr.
Sen. Joseph R. Biden Jr.D-DE · Mar 28, 2007

Mr. President, for nearly 35 years I've been working on this floor to address the all too real public health and safety issues associated with drug and alcohol addiction. Stiff prosecution of…

Show 6 more
Mel Martinez
Sen. Mel MartinezR-FL · Mar 28, 2007

Mr. President, I am here to discuss a topic of great meaning to American families: educating our children. We all want what is best for our children, and to provide them with the tools they need to…

Chuck Hagel
Sen. Chuck HagelR-NE · Mar 28, 2007

Mr. President. I rise today to join Senator Durbin in introducing the Global Climate Change Security Oversight Act. Global climate change has implications beyond economic, environmental and energy…

John F. Kerry
Sen. John F. KerryD-MA · Mar 28, 2007

Mr. President, today I am introducing legislation that will clarify which dividends are eligible for a lower rate of 15 percent for upper-income taxpayers or a 5 percent rate for lower-income…

John D. Rockefeller IV
Sen. John D. Rockefeller IVD-WV · Mar 28, 2007

Mr. President, I rise today to join my distinguished colleague, Senator Thad Cochran, in sponsoring the reauthorization of the National Writing Project. We have worked together for many years on the…

Bernard Sanders
Sen. Bernard SandersI-VT · Mar 28, 2007

Mr. President, today I am introducing legislation that would provide greater assurance to the citizens of our Nation that their elected officials will do everything within their power to provide the…

Thad Cochran
Sen. Thad CochranR-MS · Mar 28, 2007

Mr. President, today I am joined by my distinguished colleague and friend from West Virginia, Mr. Rockefeller, in introducing the National Writing Project Act of 2007. The National Writing Project…

Bill Text

Latest available legislative text

Reading Mode
Latest
Introduced in SenateIssued March 28, 2007

II

110th CONGRESS

1st Session

S. 1006

IN THE SENATE OF THE UNITED STATES

March 28, 2007

Mr. Kerry 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 deny qualified dividend income treatment to certain foreign dividends.

1.

Certain foreign dividends not treated as qualified dividend income

(a)

In general

Clause (ii) of section 1(h)(11)(B) of the Internal Revenue Code of 1986 (relating to certain dividends excluded) is amended by striking and at the end of subclause (II), by striking the period at the end of subclause (III) and inserting , and, and by adding at the end the following new subclause:

(IV)

any nonqualified dividend from a foreign corporation.

.

(b)

Nonqualified dividend from a foreign corporation

Paragraph (11) of section 1(h) of such Code (relating to dividends taxed as net capital gain) is amended by redesignating subparagraph (D) as subparagraph (E) and by inserting after subparagraph (C) the following new subparagraph:

(D)

Nonqualified dividend from a foreign corporation

For purposes of subparagraph (B)(ii)(IV), the term nonqualified dividend from a foreign corporation means any dividend from a foreign corporation if—

(i)

any amount is allowable as a deduction to any person at any time under the taxation law of any foreign country (or any amount is otherwise creditable against the tax imposed under such law) with respect to such dividend,

(ii)

for the taxable year of the corporation in which the distribution is made, or the preceding taxable year—

(I)

such corporation is not treated as a corporation for purposes of the taxation laws of any foreign country to which it would be subject to tax if it were treated as a corporation,

(II)

such corporation is exempt from tax under the taxation laws of any foreign country to which (but for such exemption) it would otherwise be subject to tax (except for exemption on the basis of nonresidence, nondomicile, or similar criteria), or

(III)

such corporation is a passive foreign investment company (as defined in section 1297 (without regard to subsection (e) thereof)), or

(iii)

such dividend is paid with respect to an instrument which is treated as other than stock (or a similar equity interest) under the taxation laws of any foreign country with respect to which the payment is taken into account.

.

(c)

Conforming amendment

Subparagraph (C) of section 1(h)(11) of such Code is amended by striking clause (iii) and by redesignating clause (iv) as clause (iii).

(d)

Effective date

The amendments made by this section shall apply to dividends received after the date of the enactment of this Act.

2.

Modification to the definition of qualified foreign corporation

(a)

In general

Clause (ii) of section 1(h)(11)(C) of the Internal Revenue Code of 1986 (relating to dividends on stock readily tradable on United States securities market) is amended by striking by such corporation if the stock and all that follows and inserting

by such corporation if—

(I)

the stock with respect to which such dividend is paid is readily tradable on an established securities market in the United States, and

(II)

such corporation is created or organized under the laws of a foreign country which has a comprehensive income tax system which the Secretary determines is satisfactory for the purposes of this paragraph.

.

(b)

Effective date

The amendment made by this section shall apply to dividends received after the date of the enactment of this Act.