I 
112TH CONGRESS 
1ST SESSION H. R. 1036 
To amend the Internal Revenue Code of 1986 to allow temporarily a reduced 
rate of tax with respect to repatriated foreign earnings. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 11, 2011 
Mr. BILBRAY 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 allow tem-
porarily a reduced rate of tax with respect to repatriated 
foreign earnings. 
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 Job Creation and 
Innovation Investment Act of 2011’’. 
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SEC. 2. EXTENSION AND MODIFICATION OF DIVIDENDS RE-
CEIVED DEDUCTION FOR CERTAIN REPATRI-
ATED FOREIGN EARNINGS. 
(a) IN GENERAL.—Subsection (f) of section 965 of 
the Internal Revenue Code of 1986 is amended to read 
as follows: 
‘‘(f) ELECTION.—The taxpayer may elect to apply 
this section to— 
‘‘(1) the taxpayer’s last taxable year which be-
gins before the date of the enactment of the Rein-
vest in America Act of 2011, or 
‘‘(2) the taxpayer’s first taxable year which be-
gins during the 1-year period beginning on such 
date. 
Such election may be made for a taxable year only if made 
on or before the due date (including extensions) for filing 
the return of tax for such taxable year.’’. 
(b) ELIMINATION OF LIMITATION.—Subsection (b) of 
section 965 of such Code is amended by striking para-
graph (1). 
(c) MODIFICATION
OF
INVESTMENT
REQUIRE-
MENT.—Paragraph (4) of section 965(b) of the Internal 
Revenue Code of 1986 is amended to read as follows: 
‘‘(4) SPECIAL
RULE
FOR
INVESTMENT
IN 
UNITED STATES PURSUANT TO QUALIFIED DOMES-
TIC REINVESTMENT PLAN.— 
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‘‘(A) IN GENERAL.—In the case of any div-
idend (or portion thereof)— 
‘‘(i) with respect to which the tax-
payer elects the application of this para-
graph, and 
‘‘(ii) which is reinvested in the United 
States pursuant to a qualified domestic re-
investment plan, 
subsection (a)(1) shall be applied by sub-
stituting ‘100 percent’ for ‘85 percent’. 
‘‘(B) QUALIFIED
DOMESTIC
REINVEST-
MENT
PLAN.—For purposes of this para-
graph— 
‘‘(i) IN GENERAL.—The term ‘quali-
fied domestic reinvestment plan’ means a 
plan which— 
‘‘(I) is approved by the tax-
payer’s president, chief executive offi-
cer, or comparable official before the 
payment of such dividend and subse-
quently approved by the taxpayer’s 
board of directors, management com-
mittee, executive committee, or similar 
body, and 
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‘‘(II) provides for the reinvest-
ment of such dividend (or portion 
thereof) in the United States, not 
later than 3 years after the payment 
of such dividend, as a source funding 
for research and development ex-
penses, expansion of facilities, proof of 
concept centers, early stage venture 
capital investment (including original 
investment), or manufacturing start- 
up costs (including plant, equipment, 
infrastructure, and contract manufac-
turing). 
‘‘(ii) PROOF OF CONCEPT CENTER.— 
The term ‘proof of concept center’ includes 
activities within public and private institu-
tions and universities, which advance in-
ventions by assessing and validating com-
mercial feasibility of products or processes, 
including prototype development.’’. 
(d) THRESHOLD PERIOD.—Section 965 of such Code 
is amended by striking ‘‘June 30, 2003’’ each place it oc-
curs and inserting ‘‘June 30, 2010’’. 
(e) INDEBTEDNESS DETERMINATION DATE.—Sub-
paragraph (B) of section 965(b)(3) of such Code is 
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