I 
112TH CONGRESS 
1ST SESSION 
H. R. 937 
To amend the Internal Revenue Code of 1986 to reduce the corporate rate 
of tax and to change to a more territorial method of taxing corporations. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 4, 2011 
Mr. SCOTT of South Carolina 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 reduce 
the corporate rate of tax and to change to a more terri-
torial method of taxing corporations. 
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 ‘‘The Rising Tides Act 
of 2011’’. 
SEC. 2. CORPORATE INCOME TAX RATE REDUCED TO 23 
PERCENT. 
(a) IN GENERAL.—Paragraph (1) of section 11(b) of 
the Internal Revenue Code of 1986 is amended— 
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(1) by adding ‘‘and’’ at the end of subpara-
graph (A), 
(2) by striking ‘‘25 percent’’ in subparagraph 
(B) and inserting ‘‘23 percent’’, and 
(3) by striking ‘‘but does not exceed $75,000’’ 
and all that follows through ‘‘or (ii) $100,000’’. 
(b) PERSONAL
SERVICE
CORPORATIONS.—Para-
graph (2) of section 11(b) of such Code is amended by 
striking ‘‘35 percent’’ and inserting ‘‘23 percent’’. 
(c) CONFORMING AMENDMENTS.— 
(1) Subsection (a) of section 1201 of such Code 
is amended— 
(A) by striking ‘‘35 percent (determined 
without regard to the last 2 sentences of section 
11(b))’’ and inserting ‘‘23 percent’’, and 
(B) by striking ‘‘35 percent’’ each place it 
appears (other than in the matter preceding 
paragraph (1)) and inserting ‘‘23 percent’’. 
(2) Paragraphs (1), (2), and (6) of section 
1445(e) of such Code are each amended by striking 
‘‘35 percent’’ and inserting ‘‘23 percent’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
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SEC. 3. TEMPORARY DIVIDENDS RECEIVED DEDUCTION 
FOR DIVIDENDS RECEIVED BY CORPORA-
TIONS FROM CONTROLLED FOREIGN COR-
PORATIONS MADE PERMANENT. 
(a) IN GENERAL.—Section 965 of the Internal Rev-
enue Code of 1986 is amended— 
(1) by striking subsection (b) and by redesig-
nating subsections (c), (d), (e), and (f) as sub-
sections (b), (c), (d), and (e), respectively, 
(2) in subsection (b) (as so redesignated) by 
striking paragraphs (1), (2), and (5) and by redesig-
nating paragraphs (3) and (4) as paragraphs (1) 
and (2), respectively, 
(3) in subsection (c) (as so redesignated) by 
striking paragraph (3) and by redesignating para-
graph (4) as paragraph (3), and 
(4) by striking subsection (e) (as so redesig-
nated) and inserting the following: 
‘‘(e) ELECTION.— 
‘‘(1) IN GENERAL.—An election under this sec-
tion shall be made at such time and in such manner 
as the Secretary may prescribe. Any such election 
shall apply to all dividends received from controlled 
foreign corporations for the first taxable year for 
which such election was made and all taxable years 
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thereafter, and, once made, may be revoked only 
with the consent of the Secretary. 
‘‘(2) CONTROLLED
GROUPS.—If an election 
under this section is made by a member of a con-
trolled group of corporations (within the meaning of 
section 1563(a), except that ‘more than 50 percent’ 
shall be substituted for ‘at least 80 percent’ each 
place it appears therein) then, except as otherwise 
provided by the Secretary, such election shall apply 
to all members of such controlled group.’’. 
(b) CLERICAL AMENDMENTS.— 
(1) The heading for section 965 of such Code 
is amended by striking ‘‘TEMPORARY DIVIDENDS’’ 
and inserting ‘‘DIVIDENDS’’. 
(2) The item relating to section 965 in the table 
of sections for subpart F of part III of subchapter 
N of chapter 1 of such Code is amended to read as 
follows: 
‘‘Sec. 965. Dividends received deduction.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
Æ 
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