A bill to amend the Internal Revenue Code of 1986 to provide for the taxation of income of controlled foreign corporations attributable to imported property.
Offshoring Prevention Act This bill amends the Internal Revenue Code to include imported property income in foreign base company income, for purposes of determining the income of controlled foreign corporations. The bill defines "imported property income" as, with certain exceptions, income derived in connection with: manufacturing, producing, growing, or extracting imported property; the sale, exchange, or other disposition of imported property; or the lease, rental, or licensing of imported property. The bill also provides for a separate application of limitations on the foreign tax credit for imported property income.
Foreign and international corporationsIncome tax creditsTaxation of foreign income
A bill to amend the Internal Revenue Code of 1986 to provide for the taxation of income of controlled foreign corporations attributable to imported property.
USA115th CongressS-863| Senate
| Updated: 4/6/2017
Offshoring Prevention Act This bill amends the Internal Revenue Code to include imported property income in foreign base company income, for purposes of determining the income of controlled foreign corporations. The bill defines "imported property income" as, with certain exceptions, income derived in connection with: manufacturing, producing, growing, or extracting imported property; the sale, exchange, or other disposition of imported property; or the lease, rental, or licensing of imported property. The bill also provides for a separate application of limitations on the foreign tax credit for imported property income.