PRIMED Act

To amend the Internal Revenue Code of 1986 to allow a temporary dividends received deduction for repatriated foreign earnings, and for other purposes. 1. Short title This Act may be cited as the Prioritizing Reinvestment in Infrastructure and Military while Eliminating Debt Act of 2015 PRIMED Act 2. Dividends received deduction for repatriated foreign earnings (a) Period for repatriation Paragraph (1) of section 965(a) Only cash dividends received during the period beginning after the date of the enactment of the Prioritizing Reinvestment in Infrastructure and Military while Eliminating Debt Act of 2015, and ending on December 31, 2016, shall be taken into account under subsection (a). (b) Extension Subsection (f) of section 965 of such Code is amended to read as follows: (f) Election The taxpayer may elect to apply this section to any taxable year that includes the period described in subsection (a)(1). Such election may be made only for one taxable year that includes such period and only if made on or before the due date (including extensions) for filing the return of tax for such taxable year. . (c) Conforming amendments (1) Threshold period Section 965 of such Code is amended by striking June 30, 2003 June 30, 2014 (2) Indebtedness determination date Subparagraph (B) of section 965(b)(3) of such Code is amended by striking October 3, 2004 May 1, 2015 (d) Effective date The amendments made by this section shall apply to taxable years ending after the date of the enactment of this Act. 3. Debt reduction (a) In general In the case of any taxes which— (1) are received in the Treasury during a fiscal year for which there is not Federal budget deficit, and (2) are attributable to eligible 965 dividends received by corporations which are United States shareholders, an amount equal to 1/3 1/3 (b) Definitions For purposes of subsection (a), the terms eligible 965 dividend non-deductible portion section 9503(b)(7) 4. Highway Trust Fund Section 9503(b) (7) Other transfers to Highway Trust Fund (A) In general There are hereby appropriated to the Highway Trust Fund amounts equivalent to the excess of— (i) 1/3 (ii) 1/3 (B) Definitions For purposes of this subsection— (i) Eligible 965 dividend The term eligible 965 dividend (ii) Non-deductible portion The term non-deductible portion . 5. Adjustment to defense discretionary spending limitations (a) In general On the date that is 30 days after the date of enactment of this Act, and on February 1 of each of calendar years 2016 through 2020, the revised security category in section 251(c) of the Balanced Budget and Emergency Deficit Control Act of 1985 for fiscal year 2016 and the fiscal year beginning on September 1st of such applicable calendar year, respectively, shall be adjusted by the amount described in subsection (b). (b) Adjustment amount The adjustment provided in subsection (a) is equal to— (1) 1/3 (2) 1/3 (b) Definitions For purposes of subsection (b), the terms eligible 965 dividend non-deductible portion section 9503(b)(7)

Summary: Prioritizing Reinvestment in Infrastructure and Military while Eliminating Debt Act of 2015 or the PRIMED Act This bill amends the Internal Revenue Code to allow corporate taxpayers to elect a tax deduction for cash dividends received from a controlled foreign corporation during the period beginning after the bill's enactment date and ending on December 31, 2016. The dividends received are subject to an effective tax rate of 5.25% when repatriated in the United States. The bill divides tax revenues attributable to such repatriated earnings equally for: (1) federal debt reduction, (2) transfers to the Highway Trust Fund, and (3) adjustments to limitations on defense discretionary spending.