IB 
Union Calendar No. 316 
113TH CONGRESS 
2D SESSION 
H. R. 4464 
[Report No. 113–428] 
To amend the Internal Revenue Code of 1986 to make permanent the look- 
through treatment of payments between related controlled foreign cor-
porations. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 10, 2014 
Mr. BOUSTANY (for himself, Mr. KIND, Mr. REED, Mr. SCHOCK, Ms. JEN-
KINS, Mr. TIBERI, Mr. PASCRELL, Mr. LARSON of Connecticut, Mr. 
YOUNG of Indiana, Mr. MATHESON, and Mr. CROWLEY) introduced the 
following bill; which was referred to the Committee on Ways and Means 
MAY 2, 2014 
Additional sponsor: Ms. LINDA T. SA´NCHEZ of California 
MAY 2, 2014 
Reported with an amendment, committed to the Committee of the Whole 
House on the State of the Union, and ordered to be printed 
[Strike out all after the enacting clause and insert the part printed in italic] 
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A BILL 
To amend the Internal Revenue Code of 1986 to make 
permanent the look-through treatment of payments be-
tween related controlled foreign corporations. 
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Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. LOOK-THROUGH TREATMENT OF PAYMENTS 
BETWEEN RELATED CONTROLLED FOREIGN 
CORPORATIONS MADE PERMANENT. 
(a) IN GENERAL.—Paragraph (6) of section 954(c) 
of the Internal Revenue Code of 1986 is amended by strik-
ing subparagraph (C). 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to taxable years of foreign corpora-
tions beginning after December 31, 2013, and to taxable 
years of United States shareholders with or within which 
such taxable years of foreign corporations end. 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Permanent CFC Look- 
Through Act of 2014’’. 
SEC. 2. LOOK-THROUGH TREATMENT OF PAYMENTS BE-
TWEEN 
RELATED 
CONTROLLED 
FOREIGN 
CORPORATIONS MADE PERMANENT. 
(a) IN GENERAL.—Paragraph (6) of section 954(c) of 
the Internal Revenue Code of 1986 is amended by striking 
subparagraph (C). 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to taxable years of foreign corporations 
beginning after December 31, 2013, and to taxable years 
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of United States shareholders with or within which such 
taxable years of foreign corporations end. 
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Union Calendar No. 316 
113TH CONGRESS 
2D SESSION 
H. R. 4464 
[Report No. 113–428] 
A BILL 
To amend the Internal Revenue Code of 1986 to 
make permanent the look-through treatment of 
payments between related controlled foreign cor-
porations. 
MAY 2, 2014 
Reported with an amendment, committed to the Com-
mittee of the Whole House on the State of the Union, 
and ordered to be printed 
VerDate Mar 15 2010 
20:44 May 02, 2014
Jkt 039200
PO 00000
Frm 00006
Fmt 6651
Sfmt 6651
E:\BILLS\H4464.RH
H4464
tkelley on DSK3SPTVN1PROD with BILLS