I 
114TH CONGRESS 
1ST SESSION H. R. 2225 
To amend the Internal Revenue Code of 1986 to allow a temporary dividends 
received deduction for repatriated foreign earnings, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
MAY 1, 2015 
Mr. MEADOWS introduced the following bill; which was referred to the Com-
mittee on Ways and Means, and in addition to the Committee on the 
Budget, for a period to be subsequently determined by the Speaker, in 
each case for consideration of such provisions as fall within the jurisdic-
tion of the committee concerned 
A BILL 
To amend the Internal Revenue Code of 1986 to allow a 
temporary dividends received deduction for repatriated 
foreign earnings, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Prioritizing Reinvest-
ment in Infrastructure and Military while Eliminating 
Debt Act of 2015’’ or the ‘‘PRIMED Act’’. 
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SEC. 2. DIVIDENDS RECEIVED DEDUCTION FOR REPATRI-
ATED FOREIGN EARNINGS. 
(a) PERIOD FOR REPATRIATION.—Paragraph (1) of 
section 965(a) of the Internal Revenue Code of 1986 is 
amended by adding at the end the following: ‘‘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 exten-
sions) 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’’ each 
place it occurs and inserting ‘‘June 30, 2014’’. 
(2) INDEBTEDNESS
DETERMINATION
DATE.— 
Subparagraph (B) of section 965(b)(3) of such Code 
is amended by striking ‘‘October 3, 2004’’ and in-
serting ‘‘May 1, 2015’’. 
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(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years ending after the 
date of the enactment of this Act. 
SEC. 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 re-
ceived by corporations which are United States 
shareholders, 
an amount equal to 1⁄3 of such taxes, reduced by 1⁄3 of 
the amount of the foreign tax credit allowed under section 
901 which is attributable to the non-deductible portion of 
such eligible 965 dividends, shall be used to reduce the 
Federal debt (in such manner as the Secretary of the 
Treasury considers appropriate). 
(b) DEFINITIONS.—For purposes of subsection (a), 
the terms ‘‘eligible 965 dividend’’ and ‘‘non-deductible 
portion’’ shall have the respective meanings given such 
terms in section 9503(b)(7) of the Internal Revenue Code 
of 1986. 
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SEC. 4. HIGHWAY TRUST FUND. 
Section 9503(b) of the Internal Revenue Code of 
1986 is amended by adding at the end the following new 
paragraph: 
‘‘(7) OTHER TRANSFERS TO HIGHWAY TRUST 
FUND.— 
‘‘(A) IN GENERAL.—There are hereby ap-
propriated 
to 
the 
Highway 
Trust 
Fund 
amounts equivalent to the excess of— 
‘‘(i) 1⁄3 of the taxes received in the 
Treasury which are attributable to eligible 
965 dividends received by corporations 
which are United States shareholders, over 
‘‘(ii) 1⁄3 of the amount of the foreign 
tax credit allowed under section 901 which 
is attributable to the non-deductible por-
tion of such eligible 965 dividends. 
‘‘(B) DEFINITIONS.—For purposes of this 
subsection— 
‘‘(i) ELIGIBLE
965
DIVIDEND.—The 
term ‘eligible 965 dividend’ means any 
amount received from a controlled foreign 
corporation for which a deduction is al-
lowed under section 965, as determined 
based on estimates made by the Secretary. 
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‘‘(ii) NON-DEDUCTIBLE
PORTION.— 
The term ‘non-deductible portion’ means 
the excess of the amount of any eligible 
965 dividend over the deductible portion 
(as defined in section 965(d)(3)) of such 
amount.’’. 
SEC. 5. ADJUSTMENT TO DEFENSE DISCRETIONARY SPEND-
ING 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 se-
curity 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 ad-
justed by the amount described in subsection (b). 
(b) ADJUSTMENT AMOUNT.—The adjustment pro-
vided in subsection (a) is equal to— 
(1) 1⁄3 of the taxes received in the Treasury 
during the most recently ended calendar year which 
are attributable to eligible 965 dividends received by 
corporations which are United States shareholders, 
over 
(2) 1⁄3 of the amount of the foreign tax credit 
allowed during the most recently ended calendar 
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year under section 901 which is attributable to the 
non-deductible portion of such eligible 965 dividends. 
(b) DEFINITIONS.—For purposes of subsection (b), 
the terms ‘‘eligible 965 dividend’’ and ‘‘non-deductible 
portion’’ shall have the respective meanings given such 
terms in section 9503(b)(7) of the Internal Revenue Code 
of 1986. 
Æ 
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