I 

114TH CONGRESS 

1ST SESSION H. R. 3083 

To amend the Internal Revenue Code of 1986 to make permanent the dividends received deduction for repatriated foreign earnings, and for other 

purposes. 

IN THE HOUSE OF REPRESENTATIVES 

JULY 15, 2015 

Mr. WILLIAMS introduced the following bill; which was referred to the 

Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to make 

permanent the dividends received deduction for repatriated foreign earnings, and for other purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Bring Jobs Back to 

5 America Act of 2015’’. 


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1 SEC. 2. MODIFICATION AND PERMANENT EXTENSION OF 

2 THE INCENTIVES TO REINVEST FOREIGN 

3 EARNINGS IN THE UNITED STATES. 

4 (a) REPATRIATION SUBJECT TO 5 PERCENT TAX

5 RATE.—Section 965(a)(1) of the Internal Revenue Code 

6 of 1986 is amended by striking ‘‘85 percent’’ and inserting 

7 ‘‘85.7 percent’’. 

8 (b) PERMANENT EXTENSION TO ELECT REPATRI9 ATION.—Section 965(f) of such Code is amended to read 

10 as follows: 

11 ‘‘(f) ELECTION.—The taxpayer may elect to apply 

12 this section to any taxable year only if made on or before 

13 the due date (including extensions) for filing the return 

14 of tax for such taxable year.’’. 

15 (c) REPATRIATION INCLUDES CURRENT AND ACCU16 MULATED FOREIGN EARNINGS.— 

17 (1) IN GENERAL.—Section 965(b)(1) of such 

18 Code is amended to read as follows: 

19 ‘‘(1) IN GENERAL.—The amount of dividends 

20 taken into account under subsection (a) shall not ex21 ceed the sum of the current and accumulated earn22 ings and profits described in section 959(c)(3) for 

23 the year a deduction is claimed under subsection (a), 

24 without diminution by reason of any distributions 

25 made during the election year, for all controlled for26 eign corporations of the United States shareholder.’’. 


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1 (2) CONFORMING AMENDMENTS.— 

2 (A) Section 965(b) of such Code is amend3 ed by striking paragraph (2) and by redesig4 nating paragraphs (3) and (4) as paragraphs 

5 (2) and (3), respectively. 

6 (B) Section 965(c) of such Code is amend7 ed by striking paragraphs (1) and (2) and by 

8 redesignating paragraphs (3), (4), and (5) as 

9 paragraphs (1), (2), and (3), respectively. 

10 (C) Section 965(c)(3) of such Code, as re11 designated by subparagraph (B), is amended to 

12 read as follows: 

13 ‘‘(3) CONTROLLED GROUPS.—All United States 

14 shareholders which are members of an affiliated 

15 group filing a consolidated return under section 

16 1501 shall be treated as one United States share17 holder.’’. 

18 (d) CLERICAL AMENDMENTS.— 

19 (1) The heading for section 965 of such Code 

20 is amended by striking ‘‘TEMPORARY’’. 

21 (2) The table of sections for subpart F of part 

22 III of subchapter N of chapter 1 of such Code is 

23 amended by striking ‘‘Temporary dividends’’ and in24 serting ‘‘Dividends’’. 


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1 (e) EFFECTIVE DATE.—The amendments made by 

2 this section shall apply to taxable years ending after the 

3 date of the enactment of this Act. 

Æ 


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