I 
117TH CONGRESS 
2D SESSION 
H. R. 7901 
To amend the Internal Revenue Code of 1986 to deny foreign tax credits 
or deductions with respect to taxes paid or accrued to the Russian 
Federation and the Republic of Belarus, to provide for the denial of 
certain other tax benefits in connection with the invasion of Ukraine, 
and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
MAY 27, 2022 
Mr. SCHNEIDER (for himself, Mr. GOLDEN, Mr. BACON, Mr. CARBAJAL, Mr. 
BAIRD, and Mr. KINZINGER) introduced the following bill; which was re-
ferred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to deny foreign 
tax credits or deductions with respect to taxes paid or 
accrued to the Russian Federation and the Republic 
of Belarus, to provide for the denial of certain other 
tax benefits in connection with the invasion of Ukraine, 
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 ‘‘Support Ukraine 
Through Our Tax Code Act’’. 
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SEC. 2. DENIAL OF FOREIGN TAX CREDIT, ETC., WITH RE-
SPECT TO TAXES PAID OR ACCRUED TO THE 
RUSSIAN FEDERATION AND THE REPUBLIC 
OF BELARUS. 
(a) IN GENERAL.—Section 901(j)(2) of the Internal 
Revenue Code of 1986 is amended by adding at the end 
the following new subparagraph: 
‘‘(C) SPECIAL
RULE
FOR
RUSSIA
AND 
BELARUS.— 
‘‘(i) IN
GENERAL.—This subsection 
shall apply to the Russian Federation and 
the Republic of Belarus during the period 
described in clause (ii). 
‘‘(ii) PERIOD OF APPLICATION.—The 
period described in this clause with respect 
to any country is the period— 
‘‘(I) beginning on the date that is 
90 days after the date of the enact-
ment of this subparagraph, and 
‘‘(II) ending on the date on 
which the resumption of the applica-
tion of the rates of duty set forth in 
column 1 of the Harmonized Tariff 
Schedule of the United States to 
products of that country takes effect 
pursuant to section 4(b) of the Sus-
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pending Normal Trade Relations with 
Russia and Belarus Act.’’. 
(b) DEDUCTION DENIED.— 
(1) IN GENERAL.—Section 275(a) of the Inter-
nal Revenue Code of 1986 is amended by inserting 
after paragraph (6) the following new paragraph: 
‘‘(7) Income, war profits, and excess profits 
taxes paid or accrued (or deemed paid under section 
960) 
to 
any 
country 
described 
in 
section 
901(j)(2)(C)(i) with respect to income attributable 
to any period described in section 901(j)(2)(C)(ii).’’. 
(2) 
CONFORMING
AMENDMENT.—Section 
901(j)(3) of such Code is amended by adding at the 
end the following new sentence: ‘‘The preceding sen-
tence shall not apply to any taxes paid or accrued 
(or deemed paid under section 960) to any country 
described in paragraph (2)(C)(i) with respect to in-
come attributable to any period described in para-
graph (2)(C)(ii).’’. 
(c) SPECIAL TRANSITION RULES FOR TAXPAYERS 
EXITING COUNTRIES FOR WHICH FOREIGN TAX CREDIT 
IS DENIED.— 
(1) IN GENERAL.—If— 
(A) any portion of a taxable year of a tax-
payer occurs during the post-exit period, and 
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(B) such taxpayer is an applicable tax-
payer for such portion of the taxable year with 
respect to a foreign country to which section 
901(j)(2)(C) of the Internal Revenue Code of 
1986 (as added by subsection (a)) applies, 
then, notwithstanding such section 901(j)(2)(C), sec-
tions 901(j)(1)(B) and 952(a)(5) of such Code shall 
not apply to income derived by the taxpayer from 
such foreign country during such portion of such 
taxable year. 
(2) APPLICABLE TAXPAYER.— 
(A) IN GENERAL.—A taxpayer is an appli-
cable taxpayer with respect to a foreign country 
for any portion of a taxable year occurring dur-
ing the post-exit period if— 
(i) the gross receipts of the taxpayer 
for such portion derived from such foreign 
country (determined under rules substan-
tially similar to the rules of part I of sub-
chapter N of chapter 1 of the Internal 
Revenue Code of 1986) are— 
(I) in the case of the period be-
ginning with the first day of the first 
month beginning after the first day of 
the post-exit period and ending with 
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the last day of the first taxable year 
ending on or after such date, less 
than 15 percent of such gross receipts 
derived during the pre-exit period, and 
(II) in the case of any taxable 
year beginning after the first day of 
the post-exit period, less than 5 per-
cent of such gross receipts derived 
during the pre-exit period, or 
(ii) the taxpayer meets such other re-
quirements as the Secretary of the Treas-
ury (or the Secretary’s delegate) may by 
regulation or guidance prescribe to deter-
mine whether a taxpayer has exited from 
doing business in such foreign country. 
(B) RULES FOR DETERMINING GROSS RE-
CEIPTS.— 
(i) AGGREGATION RULES.—The rules 
of section 448(c)(2) shall apply for pur-
poses of this paragraph, except that— 
(I) in applying section 52(a), the 
exception for foreign corporations 
under section 1563(b)(2)(C) shall be 
disregarded, and 
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(II) in applying section 52(b), the 
principles which apply under section 
52(a) shall include the modification 
under subclause (I) and the term 
‘‘trade or business’’ shall include any 
activity treated as a trade or business 
under paragraph (5) or (6) of section 
469(c) (determined without regard to 
the phrase, ‘‘To the extent provided in 
regulations’’ in such paragraph (6)). 
(ii) SPECIAL
RULES.—The rules of 
section 448(c)(3) shall apply for purposes 
of this paragraph, except that in applying 
subparagraph (B) thereof to a taxable year 
in which the entire taxable year does not 
occur during the post-exit period, the por-
tion of the year during such period shall be 
treated as a short taxable year for pur-
poses of determining annualized gross re-
ceipts. 
(iii) RECEIPTS RELATED TO HUMANI-
TARIAN PURPOSES.—For purposes of this 
subsection, gross receipts shall not include 
amounts— 
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(I) which are covered under gen-
eral or specific licenses of the Office 
of Foreign Assets Control of the De-
partment of the Treasury which have 
been identified by the Secretary of the 
Treasury (or the Secretary’s delegate) 
as licenses to which this clause ap-
plies, or 
(II) which the Secretary of the 
Treasury (or the Secretary’s delegate) 
has otherwise identified as humani-
tarian in nature. 
(3) PERIODS.—For purposes of this sub-
section— 
(A) PRE-EXIT
PERIOD.—The term ‘‘pre- 
exit period’’ means— 
(i) except as provided in clause (ii), 
the 12-month period ending on December 
31, 2021, and 
(ii) in the case of a taxpayer with a 
taxable year which ends on or after No-
vember 30, 2021, and before February 24, 
2022, such taxable year. 
(B) POST-EXIT PERIOD.—The term ‘‘post- 
exit period’’ means, with respect to any foreign 
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country, the period during which section 
901(j)(2)(C) of the Internal Revenue Code of 
1986 (as added by subsection (a)) applies to 
such foreign country (determined without re-
gard to this subsection). 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 3. DENIAL OF CERTAIN OTHER TAX BENEFITS IN CON-
NECTION WITH THE INVASION OF UKRAINE. 
(a) IN GENERAL.—In the case of any person to whom 
this section applies— 
(1) section 892(a) of the Internal Revenue Code 
of 1986 (relating to income of foreign governments) 
shall not apply to income received during the period 
this section applies to such person, 
(2) notwithstanding section 894 of such Code, 
such Code shall be applied to such person without 
regard to any treaty obligation of the United States 
during the period this section applies to such person, 
(3) section 895 of such Code (relating to in-
come derived by a foreign central bank of issue from 
obligations of the United States or from bank depos-
its) shall not apply to any central bank of such per-
son, 
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(4) sections 871(h) (relating to repeal of tax on 
interest of nonresident alien individuals received 
from certain portfolio debt investments) and 881(c) 
(relating to repeal of tax on interest of foreign cor-
porations received from certain portfolio debt invest-
ments) of such Code shall not apply to interest re-
ceived during the period this section applies to such 
person, 
(5) section 864(b) of such Code (relating to 
trade or business within the United States) shall be 
applied without regard to paragraph (2) thereof (re-
lating to exception for trading in securities or com-
modities) with respect to the period during which 
this section applies to such person, 
(6) section 883 of such Code (relating to exclu-
sion of income from shipping, etc.) shall not apply 
to income or earnings received during the period this 
section applies to such person, and 
(7) notwithstanding section 897(l) of such 
Code, any trust, corporation, or other organization 
or arrangement established by such person shall not 
be treated as a qualified foreign pension fund under 
section 897 of such Code during the period this sec-
tion applies to such person. 
(b) PERSONS TO WHOM THIS SECTION APPLIES.— 
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(1) IN GENERAL.—This section shall apply to— 
(A) any person with respect to which sanc-
tions have been imposed by the United States 
in relation to the invasion of Ukraine by the 
Russian Federation that began on February 24, 
2022, 
(B) the government of any foreign country 
to which section 901(j)(2)(C) of the Internal 
Revenue Code of 1986 applies, and 
(C) any other person identified by the Sec-
retary as— 
(i) a person described in paragraph 
(2), and 
(ii) a person with respect to which the 
application of this section would advance 
efforts to restore and maintain the peace, 
security, stability, sovereignty, and terri-
torial integrity of Ukraine (as determined 
by the Secretary in consultation with the 
Secretary of State). 
(2) PERSONS
DESCRIBED.—A person is de-
scribed in this paragraph if such person— 
(A) is a person that— 
(i) is participating or has participated 
in the invasion of Ukraine, and 
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