I 
114TH CONGRESS 
1ST SESSION 
H. R. 413 
To establish the American Infrastructure Fund, to provide bond guarantees 
and make loans to States, local governments, and infrastructure providers 
for investments in certain infrastructure projects, and to provide equity 
investments in such projects, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
JANUARY 20, 2015 
Mr. DELANEY (for himself, Mr. FITZPATRICK, Mr. POLIS, Mr. BUCSHON, Mr. 
BERA, Mr. WHITFIELD, Mr. RUPPERSBERGER, Mr. RODNEY DAVIS of Il-
linois, Ms. GABBARD, Ms. SINEMA, Mr. ISRAEL, Mr. COLE, Mr. 
LOEBSACK, Mr. LYNCH, Mr. SEAN PATRICK MALONEY of New York, Mr. 
MURPHY of Florida, Mr. HECK of Nevada, Mr. JOLLY, Mr. MESSER, Mr. 
PITTENGER, Mr. HECK of Washington, Mr. JOYCE, Mr. CARNEY, Mr. 
BARR, Mr. MACARTHUR, Mrs. BUSTOS, Mr. PALLONE, Mr. CLAY, Mr. 
PETERS, Ms. KUSTER, Mr. KINZINGER of Illinois, and Mr. DOLD) intro-
duced the following bill; which was referred to the Committee on Trans-
portation and Infrastructure, and in addition to the Committee on Ways 
and Means, for a period to be subsequently determined by the Speaker, 
in each case for consideration of such provisions as fall within the juris-
diction of the committee concerned 
A BILL 
To establish the American Infrastructure Fund, to provide 
bond guarantees and make loans to States, local govern-
ments, and infrastructure providers for investments in 
certain infrastructure projects, and to provide equity in-
vestments in such projects, and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
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SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Partnership to Build 
America Act of 2015’’. 
SEC. 2. AMERICAN INFRASTRUCTURE FUND. 
(a) AMERICAN INFRASTRUCTURE FUND.— 
(1) IN GENERAL.—There is established a wholly 
owned Government corporation— 
(A) which shall be called the American In-
frastructure Fund (referred to in this Act as 
the ‘‘AIF’’); 
(B) which shall be headed by the Board of 
Trustees established under subsection (b); 
(C) which may have separate subaccounts 
or subsidiaries for funds used to make loans, 
bond guarantees, and equity investments under 
this section; 
(D) which shall be available to the AIF to 
pay for the costs of carrying out this section, 
including the compensation of the Board and 
other employees of the AIF; and 
(E) the funds of which may be invested by 
the Board in such manner as the Board deter-
mines appropriate. 
(2) DEPOSITS TO AIF.—All funds received from 
bond issuances, loan payments, bond guarantee fees, 
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and any other funds received in carrying out this 
section shall be held by AIF. 
(3) LIMITATIONS.—The charter of the AIF 
shall limit its activities to those activities described 
as the mission of the Board under subsection (b)(2). 
(4) OVERSIGHT.—The AIF shall register with 
the Securities and Exchange Commission and the 
Chairman shall report to Congress annually as to 
whether the AIF is fulfilling the mission of the 
Board under subsection (b)(2). 
(5) TREATMENT OF AIF.— 
(A) ACCOUNTS.—Title 31, United States 
Code, is amended in each of sections 9107(c)(3) 
and 9108(d)(2)— 
(i) by inserting ‘‘the American Infra-
structure Fund,’’ after ‘‘the Regional 
Banks for Cooperatives,’’; and 
(ii) by striking ‘‘those banks’’ and in-
serting ‘‘those entities’’. 
(B) BONDS.—Section 149(b)(3)(A)(i) of 
the Internal Revenue Code of 1986 is amended 
by inserting ‘‘American Infrastructure Fund,’’ 
after ‘‘Federal Home Loan Mortgage Corpora-
tion,’’. 
(b) BOARD OF TRUSTEES.— 
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(1) IN GENERAL.—There is established a Board 
of Trustees of the AIF (referred to in this sub-
section as the ‘‘Board’’), which shall be composed of 
9 members who— 
(A) have substantial experience in bond 
guarantees or municipal credit; and 
(B) to the greatest extent practicable, have 
extensive experience working with municipal 
credit, risk management, and infrastructure fi-
nance. 
(2) MISSION.—The mission of the Board is— 
(A) to operate the AIF and its subsidiaries 
to be a low cost provider of bond guarantees, 
loans, and equity investments to State and local 
governments and infrastructure providers for 
urban and rural infrastructure projects that— 
(i) provide a positive economic impact; 
and 
(ii) meet such other standards as the 
Board may develop; 
(B) to operate the AIF in a self-sustaining 
manner so as to allow the AIF to repay its in-
frastructure bonds when such bonds are due; 
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(C) to not have a profit motive, but to seek 
at all times to pursue its mission of providing 
low cost bond guarantees and loans while— 
(i) covering its costs; 
(ii) maintaining such reserves as may 
be needed; and 
(iii) applying prudent underwriting 
standards; 
(D) to only consider projects put forth by 
State and local governments and not to seek 
projects directly; 
(E) to always make clear that no taxpayer 
money supports the AIF or ever will support 
the AIF; and 
(F) to engage in no other activities other 
than those permitted under this section. 
(3) MEMBERSHIP.— 
(A) INITIAL MEMBERS.— 
(i) APPOINTMENT.—Not later than 
150 days after the date on which bonds 
are first issued under subsection (d), the 
President shall appoint, with the advice 
and consent of the Senate, as members of 
the Board— 
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(I) 2 individuals from a list of at 
least 5 individuals selected by the 
Speaker of the House of Representa-
tives; 
(II) 2 individuals from a list of 
at least 5 individuals selected by the 
Minority Leader of the House of Rep-
resentatives; 
(III) 2 individuals from a list of 
at least 5 individuals selected by the 
Majority Leader of the Senate; 
(IV) 2 individuals from a list of 
at least 5 individuals selected by the 
Minority Leader of the Senate; and 
(V) 1 individual selected at will 
by the President. 
(ii) SUBMISSION OF LISTS.—Each of 
the lists described in clause (i) shall be 
submitted to the President not later than 
90 days after the date on which bonds are 
first issued under subsection (d). If any of 
such lists are submitted after the date re-
quired under this clause, the President 
may appoint the 2 members of the Board 
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who were to be selected from such list at 
will. 
(B) STAGGERED TERMS.—The members of 
the Board appointed pursuant to subparagraph 
(A)(i) shall serve staggered terms, with 2 each 
of the initial members of the Board serving for 
terms of 5, 6, 7, and 8 years, respectively, and 
the initial Chair selected under subparagraph 
(D) serving for 9 years. The decision of which 
Board members, other than the Chair, serve for 
which initial terms shall be made by the mem-
bers of the Board drawing lots. 
(C) ADDITIONAL MEMBERS.— 
(i) IN GENERAL.—Except as provided 
in subparagraph (A), if the term of a 
member of the Board expires or otherwise 
becomes vacant, the President shall ap-
point a replacement for such member, with 
the advice and consent of the Senate, from 
among a list of at least 5 individuals sub-
mitted by the Board. 
(ii) TERM OF SERVICE.— 
(I) IN GENERAL.—Each member 
of the Board appointed to replace a 
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member whose term is expiring shall 
serve for a 7-year term. 
(II) VACANCIES.—Any member 
of the Board appointed to fill a va-
cancy occurring before the expiration 
of the term to which that member’s 
predecessor was appointed shall be ap-
pointed only for the remainder of the 
term. 
(D) CHAIR.—The members of the Board 
shall choose 1 member to serve as the Chair of 
the Board for a term of 7 years, except that the 
initial Chair shall serve for a term of 9 years, 
pursuant to subsection (B). 
(E) CONTINUATION
OF
SERVICE.—Each 
member of the Board may continue to serve 
after the expiration of the term of office to 
which that member was appointed until a suc-
cessor has been appointed. 
(F) CONFLICTS OF INTEREST.—No mem-
ber of the Board may have a financial interest 
in, or be employed by, a Qualified Infrastruc-
ture Project (‘‘QIP’’) related to assistance pro-
vided under this section or any entity that has 
purchased bonds under subsection (d). Owning 
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municipal credit of any State or local govern-
ment or owning the securities of a diversified 
company that engages in infrastructure activi-
ties, provided those activities constitute less 
than 20 percent of the company’s revenues, or 
investing in broadly held investment funds shall 
not be deemed to create a conflict of interest. 
The Board may issue regulations to define 
terms used under this subparagraph. 
(4) COMPENSATION.—The members of the 
Board shall be compensated at an amount to be set 
by the Board, but under no circumstances may such 
compensation be higher than the rate prescribed for 
level IV of the Executive Schedule under section 
5315 of title 5, United States Code. 
(5) STAFF.—The Board shall employ and set 
compensation for such staff as the Board determines 
as is necessary to carry out the activities and mis-
sion of the AIF, and such staff may be paid without 
regard to the provisions of chapter 51 and sub-
chapter III of chapter 53, United States Code, relat-
ing to classification and General Schedule pay rates. 
(6) PROCEDURES.—The Board shall establish 
such procedures as are necessary to carry out this 
section. 
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(7) CORPORATE GOVERNANCE STANDARDS.— 
(A) BOARD
COMMITTEES
GENERALLY.— 
The Board shall maintain all of the committees 
required to be maintained by the board of direc-
tors of an issuer listed on the New York Stock 
Exchange as of the date of the enactment of 
this section. 
(B) RISK MANAGEMENT COMMITTEE.—The 
Board shall maintain a risk management com-
mittee, which shall— 
(i) employ additional staff who are 
certified by the Board as having significant 
and relevant experience in insurance un-
derwriting and credit risk management; 
and 
(ii) establish the risk management 
policies used by the Board. 
(C) STANDARDS.—The Board shall, to the 
extent practicable, follow all standards with re-
spect to corporate governance that are required 
to be followed by the board of directors of an 
issuer listed on the New York Stock Exchange 
as of the date of the enactment of this section. 
(8) BIENNIAL REPORTS.—Not less frequently 
than once every 2 years, the Board shall produce a 
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report that describes, of the materials, goods, and 
products that were used to construct, or to support 
the construction of, qualified infrastructure projects 
(as described in subsection (c)) and received financ-
ing from the American Infrastructure Fund within 
the most recent 2 calendar years, the percentage of 
such materials, goods, and products that were cre-
ated, sourced, or manufactured in the United States. 
(c) INFRASTRUCTURE INVESTMENT.— 
(1) ENTITIES ELIGIBLE FOR ASSISTANCE.—The 
AIF may provide assistance to State and local gov-
ernment entities, nonprofit infrastructure providers, 
private parties, and public-private partnerships (re-
ferred to in this section as ‘‘eligible entities’’) to help 
finance qualified infrastructure projects (referred to 
in this subsection as ‘‘QIPs’’). 
(2) FORMS OF ASSISTANCE.—The AIF may— 
(A) provide bond guarantees to debt issued 
by eligible entities; 
(B) make loans, including subordinated 
loans, to eligible entities; and 
(C) make equity investments in QIPs. 
(3) QUALIFIED INFRASTRUCTURE PROJECTS.— 
A project qualifies as a QIP under this section if— 
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(A) the project is sponsored by a State or 
local government; 
(B) the infrastructure is, or will be, owned 
by a State or local government; 
(C) the project involves the construction, 
maintenance, improvement, or repair of a trans-
portation, energy, water, communications, or 
educational facility; 
(D) the recipient of bond guarantees, 
loans, equity investments, or any other innova-
tive financing technique authorized under this 
Act provides written assurances prescribed by 
the AIF that the project will be performed in 
compliance with the requirements of all Federal 
laws that would otherwise apply to similar 
projects to which the United States is a party; 
and 
(E) in the case of a public transportation 
capital project as defined in section 5302 of 
title 49, United States Code, the recipient of 
bond guarantees, loans, equity investments, or 
any other innovative financing technique au-
thorized under this Act complies with the grant 
requirements applicable to grants made under 
section 5309 of such title. 
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(4) APPLICATION FOR ASSISTANCE.— 
(A) IN GENERAL.—A State or local gov-
ernment that wishes to receive a loan or bond 
guarantee under this section shall submit an 
application to the Board in such form and man-
ner and containing such information as the 
Board may require. 
(B) REQUIREMENT FOR PUBLIC SPONSOR-
SHIP OF PRIVATE ENTITIES.—A private entity 
may only receive a bond guarantee, loan, or eq-
uity investment under this section if the State 
or local government for the jurisdiction in which 
the nonprofit infrastructure provider or private 
partner is located submits an application pursu-
ant to subparagraph (A) on behalf of such non-
profit infrastructure provider or private part-
ner. 
(5) LIMITATIONS ON SINGLE STATE AWARDS.— 
(A) ANNUAL
LIMITATION.—The Board 
shall set an annual limit, as a percentage of 
total assistance provided under this section dur-
ing a year, on the amount of assistance a single 
State (including local governments and other 
infrastructure providers within such State) may 
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receive in assistance provided under this sec-
tion. 
(B) 
CUMULATIVE
LIMITATION.—The 
Board shall set a limit, as a percentage of total 
assistance provided under this section out-
standing at any one time, on the amount of as-
sistance a single State (including local govern-
ments and other infrastructure providers within 
such State) may receive in assistance provided 
under this section. 
(6) LOAN SPECIFICATIONS.—Loans made under 
this section shall have such maturity and carry such 
interest rate as the Board determines appropriate. 
(7) BOND
GUARANTEE.—The Board shall 
charge such fees for Bond guarantees made under 
this section as the Board determines appropriate. 
(8) EQUITY INVESTMENTS.—With respect to a 
QIP, the amount of an equity investment made by 
the AIF in such QIP may not exceed 20 percent of 
the total cost of the QIP. 
(9) PUBLIC-PRIVATE
PARTNERSHIP
REQUIRE-
MENTS.—At least 35 percent of the assistance pro-
vided under this section shall be provided to QIPs 
for which at least 10 percent of the financing for 
such QIPs comes from private debt or equity. 
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(10) PROHIBITION
ON
PRINCIPAL
FORGIVE-
NESS.—With respect to a loan made under this sec-
tion, the Board may not forgive any amount of prin-
cipal on such loan. 
(d) AMERICAN INFRASTRUCTURE BONDS.— 
(1) IN GENERAL.—Not later than 90 days after 
the date of the enactment of this Act, the Secretary, 
acting through the AIF, shall issue bonds, which 
shall be called ‘‘American Infrastructure Bonds’’. 
The proceeds from the American Infrastructure 
Bonds shall be deposited into the AIF. 
(2) FORMS AND DENOMINATIONS; INTEREST.— 
American Infrastructure Bonds shall— 
(A) be in such forms and denominations as 
determined by the Secretary, and shall have a 
50-year maturity; and 
(B) bear interest of 1 percent. 
(3) NO
FULL
FAITH
AND
CREDIT.—Interest 
and principal payments paid to holders of American 
Infrastructure Bonds shall be paid from the AIF, to 
the extent funds are available, and shall not be 
backed by the full faith and credit of the United 
States. 
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(4) AMOUNT OF BONDS.—The aggregate face 
amount of the bonds issued under this subsection 
shall be $50,000,000,000. 
(5) SALE
OF
AMERICAN
INFRASTRUCTURE 
BONDS.— 
(A) COMPETITIVE
BIDDING
PROCESS.— 
The Secretary shall sell $50,000,000,000 of 
American Infrastructure Bonds— 
(i) through a competitive bidding 
process that encourages aggressive bidding; 
(ii) with prospective purchasers bid-
ding on how low of a multiplier they will 
accept (for purposes of subsection (b)(1) of 
section 966 of the Internal Revenue Code 
of 1986) when purchasing the American 
Infrastructure Bonds, for purposes of ap-
plying the foreign earnings exclusion de-
scribed under that section; and 
(iii) in a manner that ensures no enti-
ties participating in the bidding may 
collude or coordinate their bids. 
(B) 
LIMITATION.—The 
multiplier 
de-
scribed in subparagraph (A)(ii) may not be 
greater than 6. 
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(6) REIMBURSEMENT OF COSTS.—The Board 
shall repay the Secretary, from funds in the AIF, for 
the costs to the Secretary in carrying out this sub-
section. 
(e) ADDITIONAL BONDS.— 
(1) IN GENERAL.—The Board may issue such 
other bonds as the Board determines appropriate, 
the proceeds from which shall be deposited into the 
AIF. 
(2) NO
FULL
FAITH
AND
CREDIT.—Interest 
and principal payments paid to holders of bonds 
issued pursuant to paragraph (1) shall be paid from 
the AIF, to the extent funds are available, and shall 
not be backed by the full faith and credit of the 
United States. 
(f) DEFINITIONS.—For purposes of this section: 
(1) INFRASTRUCTURE
PROVIDER.—The term 
‘‘infrastructure provider’’ means an entity that seeks 
to finance a QIP. 
(2) SECRETARY.—The term ‘‘Secretary’’ means 
the Secretary of the Treasury. 
(3) STATE.—The term ‘‘State’’ means each of 
the several States, the District of Columbia, any ter-
ritory or possession of the United States, and each 
Federally recognized Indian tribe. 
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SEC. 3. FOREIGN EARNINGS EXCLUSION FOR PURCHASE OF 
INFRASTRUCTURE BONDS. 
(a) IN GENERAL.—Subpart F of part III of sub-
chapter N of chapter 1 of the Internal Revenue Code of 
1986 is amended by adding at the end the following new 
section: 
‘‘SEC. 966. FOREIGN EARNINGS EXCLUSION FOR PURCHASE 
OF INFRASTRUCTURE BONDS. 
‘‘(a) EXCLUSION.—In the case of a corporation which 
is a United States shareholder and for which the election 
under this section is in effect for the taxable year, gross 
income does not include an amount equal to the qualified 
cash dividend amount. 
‘‘(b) QUALIFIED CASH DIVIDEND AMOUNT.—For 
purposes of this section, the term ‘qualified cash dividend 
amount’ means an amount of the cash dividends which 
are received during a taxable year by such shareholder 
from controlled foreign corporations equal to— 
‘‘(1) the multiplier determined under section 
2(d)(5) of the Partnership to Build America Act of 
2015 for such shareholder, multiplied by 
‘‘(2) the face amount of qualified infrastructure 
bonds acquired at its original issue (directly or 
through an underwriter) by such shareholder. 
‘‘(c) LIMITATIONS.— 
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‘‘(1) IN GENERAL.—The amount of dividends 
taken into account under subsection (a) for a tax-
able year shall not exceed the lesser of— 
‘‘(A) the cash dividends received by the 
taxpayer for such taxable year, or 
‘‘(B) the amount shown on the applicable 
financial statement as earnings permanently re-
invested outside the United States. 
‘‘(2) DIVIDENDS MUST BE EXTRAORDINARY.— 
The amount of dividends taken into account under 
subsection (a) shall not exceed the excess (if any) 
of— 
‘‘(A) the cash dividends received during 
the taxable year by such shareholder from con-
trolled foreign corporations, over 
‘‘(B) the annual average for the base pe-
riod years of the cash dividends received during 
each base period year by such shareholder from 
controlled foreign corporations. 
‘‘(3) REDUCTION OF BENEFIT IF INCREASE IN 
RELATED PARTY INDEBTEDNESS.—The amount of 
dividends which would (but for this paragraph) be 
taken into account under subsection (a) shall be re-
duced by the excess (if any) of— 
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‘‘(A) the amount of indebtedness of the 
controlled foreign corporation to any related 
person (as defined in section 954(d)(3)) as of 
the close of the taxable year for which the elec-
tion under this section is in effect, over 
‘‘(B) the amount of indebtedness of the 
controlled foreign corporation to any related 
person (as so defined) as of the close of the pre-
ceding taxable year. 
‘‘(4) TREATMENT
OF
CONTROLLED
FOREIGN 
CORPORATIONS.—All controlled foreign corporations 
with respect to which the taxpayer is a United 
States shareholder shall be treated as 1 controlled 
foreign corporation for purposes of this subsection. 
The Secretary may prescribe such regulations as 
may be necessary or appropriate to prevent the 
avoidance of the purposes of this subsection, includ-
ing regulations providing that cash dividends shall 
not be taken into account under subsection (a) to 
the extent such dividends are attributable to the di-
rect or indirect transfer (including through the use 
of intervening entities or capital contributions) of 
cash or other property from a related person (as so 
defined) to a controlled foreign corporation. 
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‘‘(d) DEFINITIONS AND SPECIAL RULES.—For pur-
poses of this section— 
‘‘(1) QUALIFIED
INFRASTRUCTURE
BONDS.— 
The term ‘qualified infrastructure bond’ means a 
bond issued under section 2(d) of the Partnership to 
Build America Act of 2015. 
‘‘(2) APPLICABLE
FINANCIAL
STATEMENT.— 
The term ‘applicable financial statement’ means, 
with respect to a taxable year— 
‘‘(A) with respect to a United States 
shareholder which is required to file a financial 
statement with the Securities and Exchange 
Commission (or which is included in such a 
statement so filed by another person), the most 
recent audited annual financial statement (in-
cluding the notes which form an integral part 
of such statement) of such shareholder (or 
which includes such shareholder)— 
‘‘(i) which was so filed for such tax-
able year, and 
‘‘(ii) which is certified as being pre-
pared in accordance with generally accept-
ed accounting principles, and 
‘‘(B) with respect to any other United 
States shareholder, the most recent audited fi-
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nancial statement (including the notes which 
form an integral part of such statement) of 
such shareholder (or which includes such share-
holder)— 
‘‘(i) which is certified as being pre-
pared in accordance with generally accept-
ed accounting principles, and 
‘‘(ii) which is used for the purposes of 
a statement or report— 
‘‘(I) to creditors, 
‘‘(II) to shareholders, or 
‘‘(III) for any other substantial 
nontax purpose. 
‘‘(3) BASE PERIOD YEARS.— 
‘‘(A) IN GENERAL.—The base period years 
are the 3 taxable years— 
‘‘(i) which are among the 5 most re-
cent preceding taxable years ending before 
the taxable year, and 
‘‘(ii) which are determined by dis-
regarding— 
‘‘(I) 1 taxable year for which the 
amount 
described 
in 
subsection 
(c)(2)(B) is the largest, and 
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‘‘(II) 1 taxable year for which 
such amount is the smallest. 
‘‘(B) SHORTER PERIOD.—If the taxpayer 
has fewer than 5 taxable years ending before 
the taxable year, then in lieu of applying sub-
paragraph (A), the base period years shall in-
clude all the taxable years of the taxpayer end-
ing before such taxable year. 
‘‘(C) MERGERS, ACQUISITIONS, ETC.— 
‘‘(i) IN
GENERAL.—Rules similar to 
the rules of subparagraphs (A) and (B) of 
section 41(f)(3) shall apply for purposes of 
this paragraph. 
‘‘(ii) SPIN-OFFS, ETC.—If there is a 
distribution to which section 355 (or so 
much of section 356 as relates to section 
355) applies during the 5-year period re-
ferred to in subparagraph (A)(i) and the 
controlled corporation (within the meaning 
of section 355) is a United States share-
holder— 
‘‘(I) the controlled corporation 
shall be treated as being in existence 
during the period that the distributing 
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corporation (within the meaning of 
section 355) is in existence, and 
‘‘(II) for purposes of applying 
subsection (c)(2) to the controlled cor-
poration and the distributing corpora-
tion, amounts described in subsection 
(c)(2)(B) which are received or includ-
able by the distributing corporation or 
controlled corporation (as the case 
may be) before the distribution re-
ferred to in subclause (I) from a con-
trolled foreign corporation shall be al-
located between such corporations in 
proportion to their respective interests 
as United States shareholders of such 
controlled foreign corporation imme-
diately after such distribution. 
‘‘(iii) EXCEPTION.—Subclause (II) of 
clause (ii) shall not apply if neither the 
controlled corporation nor the distributing 
corporation is a United States shareholder 
of such controlled foreign corporation im-
mediately after such distribution. 
‘‘(4) DIVIDEND.—The term ‘dividend’ shall not 
include amounts includable in gross income as a div-
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idend under section 78, 367, or 1248. In the case 
of a liquidation under section 332 to which section 
367(b) applies, the preceding sentence shall not 
apply to the extent the United States shareholder 
actually receives cash as part of the liquidation. 
‘‘(5) COORDINATION WITH DIVIDEND RECEIVED 
DEDUCTION.—No deduction shall be allowed under 
section 243 or 245 for any dividend which is ex-
cluded from income by subsection (a). 
‘‘(6) CONTROLLED GROUPS.—All United States 
shareholders which are members of an affiliated 
group filing a consolidated return under section 
1501 shall be treated as one United States share-
holder. 
‘‘(7) REPORTING.—The Secretary shall require 
by regulation or other guidance the reporting of 
such information as the Secretary may require to 
carry out this section. 
‘‘(e) DENIAL OF FOREIGN TAX CREDIT; DENIAL OF 
CERTAIN EXPENSES.— 
‘‘(1) FOREIGN TAX CREDIT.— 
‘‘(A) IN GENERAL.—No credit shall be al-
lowed under section 901 for any taxes paid or 
accrued (or treated as paid or accrued) with re-
spect to the excluded portion of any dividend. 
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‘‘(B) DENIAL OF DEDUCTION OF RELATED 
TAX.—No deduction shall be allowed under this 
chapter for any tax for which credit is not al-
lowable by reason of the preceding sentence. 
‘‘(2) EXPENSES.—No deduction shall be al-
lowed for expenses directly allocable to the exclud-
able portion described in paragraph (1). 
‘‘(3) EXCLUDABLE PORTION.—For purposes of 
paragraph (1), unless the taxpayer otherwise speci-
fies, the excludable portion of any dividend or other 
amount is the amount which bears the same ratio to 
the amount of such dividend or other amount as the 
amount excluded from income under subsection (a) 
for the taxable year bears to the amount described 
in subsection (c)(2)(A) for such year. 
‘‘(4) COORDINATION WITH SECTION 78.—Sec-
tion 78 shall not apply to any tax which is not allow-
able as a credit under section 901 by reason of this 
subsection. 
‘‘(f) APPLICATION OF SECTION.—This section shall 
apply with respect to the taxable year of the taxpayer in 
which the taxpayer acquires qualified infrastructure bonds 
at its original issue (directly or through an underwriter) 
under section 2(d)(5) of the Partnership to Build America 
Act of 2015.’’. 
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(b) CLERICAL AMENDMENT.—The table of sections 
for subpart F of part III of subchapter N of chapter 1 
of such Code is amended by adding at the end the fol-
lowing new item: 
‘‘966. Foreign earnings exclusion for purchase of infrastructure bonds.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to dividends received for taxable 
years ending after the date of the enactment of this Act. 
Æ 
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