I 
112TH CONGRESS 
1ST SESSION 
H. R. 755 
To amend the Internal Revenue Code of 1986 to impose an excise tax 
on currency transactions. 
IN THE HOUSE OF REPRESENTATIVES 
FEBRUARY 17, 2011 
Mr. STARK (for himself, Mr. JACKSON of Illinois, Ms. LEE of California, and 
Mr. FILNER) introduced the following bill; which was referred to the 
Committee on Ways and Means, and in addition to the Committee on 
Foreign Affairs, for a period to be subsequently determined by the Speak-
er, in each case for consideration of such provisions as fall within the ju-
risdiction of the committee concerned 
A BILL 
To amend the Internal Revenue Code of 1986 to impose 
an excise tax on currency transactions. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE; FINDINGS. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Investing in Our Future Act of 2011’’. 
(b) FINDINGS.—Congress finds the following: 
(1) While Wall Street continues to reap massive 
profits, the 2008 global economic crisis they helped 
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cause has destabilized economies and impacted the 
budgets of the United States and impoverished na-
tions, compromising the ability of governments to 
address pressing needs. 
(2) The scope of the financial crisis distorted 
our national deficit. The Congressional Budget Of-
fice estimates that Federal deficit spending is now at 
a record $1.5 trillion. 
(3) Millions of people around the world have 
been pushed into poverty because of the global fi-
nancial crisis, through no fault of their own. 
(4) The impacts of climate change, disease, and 
ill health undermine the economies of developing na-
tions and their ability to contribute to a secure, sta-
ble world. 
(5) Predictable, adequate, sustainable, long- 
term, public funding to address global health and 
climate change in developing countries at the scale 
needed does not currently exist but it is urgently 
needed. 
(6) Cutting vital domestic programs such as 
education, health care, and nutrition assistance to 
reduce the national debt will have a harmful impact 
on the long-term prosperity of the country. Alter-
native revenue generating mechanisms must be con-
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sidered to reduce the national debt and meet inter-
national development and climate needs. 
(7) The financial institutions that caused the fi-
nancial crisis should play a significant role in pro-
viding funds that will help developing countries miti-
gate and adapt to climate change, fight global HIV/ 
AIDS, improve maternal and child health in impov-
erished nations, and reduce the national deficit. 
(8) Currency speculation by financial institu-
tions has destabilizing impacts on the real economy 
and can contribute to financial crises. 
(9) In 2008, $4 trillion in daily currency trans-
actions were undertaken, nearly 80 percent of which 
by a few major banks, without taxation. 
(10) A tax on the currency market would be 
paid by these same banks that caused the financial 
crisis and would generate funds to help reduce our 
deficit. 
(11) A small levy on currency would curb some 
speculative transactions, bringing greater stability 
into the currency market. 
(12) Collection of a small tax would not disrupt 
legitimate trading in the currency trading markets 
and would have no significant impact on individual 
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travelers or United States corporations doing busi-
ness. 
(13) The Secretary of State, Secretary of the 
Treasury, and the nations in the Organization for 
Economic Cooperation and Development should 
work together to implement a broader currency 
transaction tax to reduce the Federal deficit and 
fund global health, poverty, and climate change ini-
tiatives. 
SEC. 2. EXCISE TAX ON CURRENCY TRANSACTIONS. 
(a) IN GENERAL.—Chapter 36 of the Internal Rev-
enue Code of 1986 is amended by inserting after sub-
chapter B the following new subchapter: 
‘‘Subchapter C—Currency Transactions 
‘‘Sec. 4475. Currency transactions. 
‘‘SEC. 4475. CURRENCY TRANSACTIONS. 
‘‘(a) IN GENERAL.—There is hereby imposed a tax 
on each currency transaction made by, or on behalf of, 
a United States person. 
‘‘(b) EXCEPTION FOR LOW-VALUE TRANSACTIONS.— 
‘‘(1) IN
GENERAL.—Subsection (a) shall not 
apply to any currency transaction made by, or on 
behalf of, a United States person, if the aggregate 
value of the currencies acquired by such person in 
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all such transactions made during the calendar year 
does not exceed $10,000. 
‘‘(2) 
COORDINATION
WITH
WITHHOLDING 
RULES.—Subsection (e)(2) shall not apply to any 
currency transaction unless the value of the currency 
acquired by the United States person in such trans-
action exceeds $10,000. The preceding sentence 
shall not apply if the person who facilitates such 
currency transaction knows, or has reason to know, 
that the exception provided by paragraph (1) does 
not apply to such transaction. 
‘‘(c) AMOUNT OF TAX.— 
‘‘(1) IN GENERAL.—The amount of the tax im-
posed under subsection (a) with respect to any cur-
rency transaction shall be equal to 0.005 percent of 
the value of the currency acquired in the trans-
action. 
‘‘(2) SPECIAL RULE FOR CURRENCY DERIVA-
TIVES.—In the case of any currency derivative, the 
value of the currency acquired in the transaction 
shall be treated for purposes of this section as being 
equal to— 
‘‘(A) in the case of a forward contract, the 
value of the currency purchased or sold for-
ward, 
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‘‘(B) in the case of a notional principal 
contract, the value of the notional principal 
amount of the contract, 
‘‘(C) in the case of an option, the value of 
the currency that would be acquired in the 
event the option were exercised, and 
‘‘(D) in the case of any other currency de-
rivative, the value as determined by the Sec-
retary. 
‘‘(3) VALUATION OF CURRENCY.—For purposes 
of this section, the valuation of any currency shall 
be determined in the taxpayer’s functional currency 
(within the meaning of section 985) at the spot rate 
on the date of the transaction. 
‘‘(d) CURRENCY TRANSACTION.—For purposes of 
this section— 
‘‘(1) IN GENERAL.—The term ‘currency trans-
action’ means— 
‘‘(A) the exchange of any currency for an-
other currency, and 
‘‘(B) entering into any currency derivative. 
‘‘(2) CURRENCY DERIVATIVE.—The term ‘cur-
rency derivative’ means— 
‘‘(A) any currency notional principal con-
tract, and 
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‘‘(B) any option, forward contract, short 
position, hedge, or similar financial instrument 
with respect to any currency or currency no-
tional principal contract. 
‘‘(e) LIABILITY FOR TAX; WITHHOLDING.— 
‘‘(1) LIABILITY
FOR
TAX.—The tax imposed 
under subsection (a) with respect to any currency 
transaction shall be paid by the United States per-
son referred to in subsection (a). Such person shall 
be allowed a credit against such tax in the amount 
withheld as tax under paragraph (2) with respect to 
such transaction. 
‘‘(2) WITHHOLDING
BY
CURRENCY
TRANS-
ACTION FACILITATORS.— 
‘‘(A) IN GENERAL.—Except as provided in 
subparagraph (B), each United States person 
which facilitates a currency transaction by, or 
on behalf of, a United States person shall de-
duct and withhold from the amount involved in 
such transaction a tax equal to the amount of 
the tax imposed under section 4475 with re-
spect to such transaction. 
‘‘(B) AMOUNTS WITHHELD ONLY ONCE.— 
The Secretary shall prescribe regulations or 
other guidance to ensure that only one United 
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‘‘(1) IN GENERAL.—For purposes of this sec-
tion, all members of the same expanded affiliated 
group shall be treated as one person for purposes of 
this section. 
‘‘(2) EXPANDED AFFILIATED GROUP.—For pur-
poses of this subsection, the term ‘expanded affili-
ated group’ means an affiliated group as defined in 
section 1504(a), determined— 
‘‘(A) by substituting ‘more than 50 per-
cent’ for ‘at least 80 percent’ each place it ap-
pears, and 
‘‘(B) without regard to paragraphs (2) and 
(3) of section 1504(b). 
A partnership or any other entity (other than a cor-
poration) shall be treated as a member of an ex-
panded affiliated group if such entity is controlled 
(within the meaning of section 954(d)(3)) by mem-
bers of such group (including any entity treated as 
a member of such group by reason of this sen-
tence).’’. 
(b) CLERICAL AMENDMENT.—The table of sub-
chapters for chapter 36 of such Code is amended by in-
serting after the item relating to subchapter B the fol-
lowing new item: 
‘‘SUBCHAPTER C. CURRENCY TRANSACTIONS’’. 
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(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to transactions after December 31, 
2011. 
SEC. 3. FUNDING FOR CHILD CARE. 
(a) CHILD CARE ASSISTANCE TRUST FUND.— 
(1) IN GENERAL.—There is established in the 
Treasury of the United States a trust fund to be 
known as the ‘‘Child Care Assistance Trust Fund’’, 
consisting of such amounts as may be appropriated 
or credited to the Child Care Assistance Trust Fund 
as provided in this section. 
(2) TRANSFER TO TRUST FUND OF AMOUNTS 
EQUIVALENT TO CERTAIN TAXES.—There are hereby 
appropriated to the Child Care Assistance Trust 
Fund, out of any money in the Treasury not other-
wise appropriated, amounts equivalent to 10 percent 
of the taxes received in the Treasury under section 
4475 of the Internal Revenue Code of 1986. 
(3) EXPENDITURES
FROM
TRUST
FUND.— 
Amounts in the Child Care Assistance Trust Fund 
shall be available, as provided by appropriation Acts, 
for making expenditures to carry out subsection (b). 
(4) MANAGEMENT OF TRUST FUND.—For pur-
poses of subchapter B of chapter 98 of the Internal 
Revenue Code of 1986, the provisions of this sub-
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section shall be treated as provisions of subchapter 
A of such chapter. 
(b) CHILD CARE ASSISTANCE GRANTS.— 
(1) IN
GENERAL.—Any appropriation under 
subsection (a)(3) from the Child Care Assistance 
Trust Fund shall be allocated among the States as 
an increase in the amount determined under section 
418(a)(1) of the Social Security Act in the same 
proportion as the amount determined under such 
section with respect to such State (determined with-
out regard to this subsection) bears to the aggregate 
amounts so determined with respect to all of the 
States. 
(2) FUNDING TO BE ADDITIONAL.—It is the 
sense of the Congress that amounts made available 
under this subsection shall be in addition to (and 
shall not be a replacement for) other funding for 
child care assistance. 
SEC. 4. MULTILATERAL GLOBAL HEALTH PROGRAMS. 
(a) 
MULTILATERAL
GLOBAL
HEALTH
TRUST 
FUND.— 
(1) IN GENERAL.—There is established in the 
Treasury of the United States a trust fund to be 
known as the ‘‘Multilateral Global Health Trust 
Fund’’, consisting of such amounts as may be appro-
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priated or credited to the Multilateral Global Health 
Trust Fund as provided in this section. 
(2) TRANSFER TO TRUST FUND OF AMOUNTS 
EQUIVALENT TO CERTAIN TAXES.—There are hereby 
appropriated to the Multilateral Global Health Trust 
Fund, out of any money in the Treasury not other-
wise appropriated, amounts equivalent to 25 percent 
of the taxes received in the Treasury under section 
4475 of the Internal Revenue Code of 1986. 
(3) EXPENDITURES
FROM
TRUST
FUND.— 
Amounts in the Multilateral Global Health Trust 
Fund shall be available, as provided by appropria-
tion Acts, for making expenditures to carry out sub-
section (b). 
(4) MANAGEMENT OF TRUST FUND.—For pur-
poses of subchapter B of chapter 98 of the Internal 
Revenue Code of 1986, the provisions of this sub-
section shall be treated as provisions of subchapter 
A of such chapter. 
(b) MULTILATERAL GLOBAL HEALTH GRANT PRO-
GRAM.— 
(1) IN GENERAL.—The Secretary of State shall 
make grants to assist developing countries in ad-
dressing HIV/AIDS, tuberculosis, malaria, maternal 
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mortality, family planning, neglected diseases, and 
other health issues affecting developing countries. 
(2) ELIGIBILITY FOR GRANTS.—Grants under 
paragraph (1) may be made to— 
(A) the Global Fund to Fight AIDS, Tu-
berculosis and Malaria to provide grants de-
scribed in paragraph (1), and 
(B) other multilateral health funding 
mechanisms which the Secretary certifies— 
(i) provide a significant majority of 
their total funding to programs in the form 
of grants, 
(ii) include independent and external 
technical review of programs in the award-
ing of funding, 
(iii) include governance structures 
that involve donor governments, imple-
menting governments, civil society, and af-
fected communities as equal decision-
makers, 
(iv) provide funding based on plans 
developed 
by 
implementing 
countries 
through country-level processes that in-
clude equal and meaningful involvement of 
civil society and impacted communities, 
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(v) require measures of performance 
of all projects and formal mechanisms that 
condition continued financing on successful 
performance and outcomes, and 
(vi) include mechanisms for strict fi-
nancial accountability and provides trans-
parency of all decisions, evaluations, and 
finances through publically accessible docu-
ments. 
(3) FUNDING TO BE ADDITIONAL.—It is the 
sense of the Congress that grants made under this 
subsection shall be in addition to (and shall not be 
a replacement for) other funding for global health 
initiatives in developing countries. 
SEC. 5. GLOBAL CLIMATE CHANGE ADAPTATION AND MITI-
GATION. 
(a) GLOBAL CLIMATE CHANGE ADAPTATION AND 
MITIGATION TRUST FUND.— 
(1) IN GENERAL.—There is established in the 
Treasury of the United States a trust fund to be 
known as the ‘‘Global Climate Change Adaptation 
and Mitigation Trust Fund’’, consisting of such 
amounts as may be appropriated or credited to the 
Global Climate Change Adaptation and Mitigation 
Trust Fund as provided in this section. 
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