I 
111TH CONGRESS 
2D SESSION 
H. R. 5473 
To amend the Internal Revenue Code of 1986 to exclude from personal 
holding company income dividends which are received from foreign affili-
ates and which are reinvested in the United States. 
IN THE HOUSE OF REPRESENTATIVES 
MAY 28, 2010 
Ms. LINDA T. SA´NCHEZ of California introduced the following bill; which was 
referred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to exclude 
from personal holding company income dividends which 
are received from foreign affiliates and which are rein-
vested in the United States. 
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 ‘‘Investing Income at 
Home Act of 2010’’. 
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SEC. 2. EXCLUSION FROM PERSONAL HOLDING COMPANY 
INCOME OF DIVIDENDS WHICH ARE RE-
CEIVED FROM FOREIGN AFFILIATES AND 
WHICH ARE REINVESTED IN THE UNITED 
STATES. 
(a) IN GENERAL.—Paragraph (1) of section 543(a) 
of the Internal Revenue Code of 1986 is amended by strik-
ing ‘‘and’’ at the end of subparagraph (C), by striking the 
period at the end of subparagraph (D) and inserting ‘‘, 
and’’, and by adding at the end the following new subpara-
graph: 
‘‘(E) foreign affiliate dividends designated 
for reinvestment in the United States (within 
the meaning of subsection (b)(5)).’’. 
(b) FOREIGN AFFILIATE DIVIDENDS DESIGNATED 
FOR REINVESTMENT.—Subsection (b) of section 543 of 
such Code is amended by adding at the end the following 
new paragraph: 
‘‘(5) FOREIGN
AFFILIATE
DIVIDENDS
DES-
IGNATED
FOR
REINVESTMENT.—For purposes of 
subsection (a)(1)(E)— 
‘‘(A) IN
GENERAL.—A dividend is de-
scribed in subsection (a)(1)(E) if— 
‘‘(i) the dividend is received by the 
taxpayer from an affiliated foreign cor-
poration, and 
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‘‘(ii) the taxpayer designates (on the 
taxpayer’s return for the taxable year in 
which received) the dividend for reinvest-
ment in the United States (as described in 
section 965(b)(4)(B)), including as a 
source for funding compensation and bene-
fits for both existing and newly hired work-
ers (other than for executives), by the tax-
payer or 1 or more members of an affili-
ated group which includes the taxpayer. 
‘‘(B) 
AFFILIATED
FOREIGN
CORPORA-
TION.—For purposes of subparagraph (A), the 
term ‘affiliated foreign corporation’ means any 
foreign corporation if stock possessing at least 
10 percent of the total combined voting power 
of all outstanding classes of stock entitled to 
vote is owned in the aggregate by the taxpayer 
and members of the an affiliated group which 
includes the taxpayer. 
‘‘(C) FAILURE
TO
REINVEST
WITHIN
YEARS.—If, at the end of the 5th taxable year 
following the taxable year in which the dividend 
is received, the dividend is not reinvested in the 
United States as described in subparagraph 
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(A)(ii), the taxpayer shall pay a tax equal to 
the sum of— 
‘‘(i) the product of— 
‘‘(I) the amount of the dividend 
not so reinvested, and 
‘‘(II) the rate of tax in effect 
under section 541 on the date that 
the dividend was received, and 
‘‘(ii) the amount of interest that 
would be assessed under section 6601 if 
the amount of tax determined under clause 
(i) were treated as an underpayment for 
the taxable year in which the dividend was 
received. 
‘‘(D) AFFILIATED GROUP.—For purposes 
of this paragraph, the term ‘affiliated group’ 
has the meaning given to such term by section 
1504(a).’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to dividends received in taxable 
years beginning on or after the date of the enactment of 
this Act. 
Æ 
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