US Codex
Bill
Notes

Personal Holding Company Tax Parity and Reinvestment Act

H.R. 4589 · 113th Congress · May 7, 2014 · Lineage

A BILL

To amend the Internal Revenue Code of 1986 to exclude dividends from controlled foreign corporations from the definition of personal holding company income for purposes of the personal holding company rules.

Section 1 Short title

This Act may be cited as the “Personal Holding Company Tax Parity and Reinvestment Act”.

Sec. 2 Exclusion of dividends from controlled foreign corporations from the definition of personal holding company income for purposes of the personal holding company rules

(a)
In general— Paragraph (1) of section 543(a) of the Internal Revenue Code of 1986 is amended—
(1)
by redesignating subparagraphs (C) and (D) as subparagraphs (D) and (E), respectively, and
(2)
by inserting after subparagraph (B) the following:

“(C) dividends received by a United States shareholder (as defined in section 951(b)) from a controlled foreign corporation (as defined in section 957(a)),”

(b)
Effective date— The amendments made by this Act shall apply to taxable years ending on or after the date of the enactment of this Act.