‘‘(i) 3⁄4 of 1 percent of the aggregate
amount of capital and accumulated surplus
of the corporation as of December 31,
1987, or
‘‘(ii) $1,500,000.
‘‘(c) INSURANCE INCOME DEFINED.—For purposes
of this section, the term ‘insurance income’ means any in-
come which—
‘‘(1) is attributable to the issuing (or reinsur-
ing) of any insurance or annuity contract—
‘‘(A) in connection with property in, liabil-
ity arising out of activity in, or in connection
with the lives or health of residents of, a coun-
try other than the country under the laws of
which the controlled foreign corporation is cre-
ated or organized, or
‘‘(B) in connection with risks not described
in subparagraph (A) as the result of any ar-
rangement whereby another corporation receives
a substantially equal amount of premiums or
other consideration in respect of issuing (or re-
insuring) a contract described in subparagraph
(A), and
‘‘(2) would (subject to the modifications pro-
vided by paragraphs (1) and (2) of subsection (d))
be taxed under subchapter L of this chapter if such
income were the income of a domestic insurance
company.
‘‘(d) SPECIAL RULES.—In determining the amount
of insurance income—
‘‘(1) The following provisions of subchapter L
shall not apply:
‘‘(A) The small life insurance company de-
duction.
‘‘(B) Section 805(a)(5) (relating to oper-
ations loss deduction).
‘‘(C) Section 832(c)(5) (relating to certain
capital losses).
‘‘(2) The items referred to in—
‘‘(A) section 803(a)(1) (relating to gross
amount of premiums and other considerations),
‘‘(B) section 803(a)(2) (relating to net de-
crease in reserves),
‘‘(C) section 805(a)(2) (relating to net in-
crease in reserves), and
‘‘(D) section 832(b)(4) (relating to pre-
miums earned on insurance contracts),
shall be taken into account only to the extent they
are in respect of any reinsurance or the issuing of
any insurance or annuity contract described in sub-
section (a)(1).
‘‘(3) All items of income, expenses, losses, and
deductions shall be properly allocated or apportioned
under regulations prescribed by the Secretary.’’
(b) REPEAL OF EXPORT TRADE CORPORATION PRO-
VISIONS.—Subpart G of part III of subchapter N of chap-
ter 1 of such Code (relating to export trade corporations)
is hereby repealed.
(c) CONFORMING AMENDMENTS TO SUBPART F.—
(1) Subparagraph (A) of section 955(a)(1) of
such Code is amended by inserting ‘‘(as in effect for
taxable years beginning before 1987)’’ after ‘‘section
954(b)(2)’’.
(2) Subsection (b) of section 955 of such Code
is amended by striking ‘‘within the meaning of sec-
tion 954(d)(3)’’ and inserting ‘‘within the meaning
of section 964(a)’’.
(3) Paragraph (2) of section 956(c) of such
Code is amended—
(A) by striking ‘‘section 953(a)(1)’’ in sub-
paragraph 
(E) 
and 
inserting 
‘‘section
953(c)(1)’’, and
(B) by inserting ‘‘(as in effect on the day
before the date of the enactment of this par-
enthetical) or under section 952(a)(1)’’ after
‘‘section 952(b)’’ in subparagraph (H).
(4) Subsection (b) of section 957 of such Code
is amended—
(A) by striking ‘‘income described in sec-
tion 953(a)’’ and inserting ‘‘subpart F income
attributable to income described in section
953(c)’’, and
(B) by striking ‘‘section 953(a)(1)’’ and in-
serting ‘‘section 953(c)(1)’’.
(5) Subsection (b) of section 958 of such Code
is amended—
(A) by striking ‘‘954(d)(3), 956(b)(2), and
957’’ and inserting ‘‘956(b)(2), 957, and
964(a)’’, and
(B) by striking ‘‘954(d)(3)’’ the second
place it appears and inserting ‘‘964(a)’’.
(6) Subsection (b) of section 959 of such Code
is amended by striking ‘‘be also included in the gross
income’’ and inserting ‘‘be also included in the sub-
part F income’’.
(7) Subsection (a) of section 964 of such Code
is amended to read as follows:
‘‘(a) RELATED PERSON.—For purposes of this part,
a person is a related person with respect to a controlled
foreign corporation, if—
‘‘(1) such person is an individual, corporation,
partnership, trust, or estate which controls, or is
controlled by, the controlled foreign corporation, or
‘‘(2) such person is a corporation, partnership,
trust, or estate which is controlled by the same per-
son or persons which control the controlled foreign
corporation.
For purposes of the preceding sentence, control means,
with respect to a corporation, the ownership, directly or
indirectly, of stock possessing more than 50 percent of the
total voting power of all classes of stock entitled to vote
or of the total value of stock of such corporation. In the
case of a partnership, trust, or estate, control means the
ownership, directly or indirectly, more than 50 percent (by
value) of the beneficial interests in such partnership, trust,
or estate. For purposes of this paragraph, rules similar
to the rules of section 958 shall apply.’’
(8) Section 964 of such Code is amended by
striking subsection (b).
(9) The table of sections for subpart F of part
III of subchapter N of chapter 1 of such Code is
amended by striking the items relating to sections
952, 953 and 954 and inserting the following:
‘‘Sec. 952. Subpart F income.
‘‘Sec. 953. Special rules for certain insurance companies.’’
(f) OTHER CONFORMING AMENDMENTS.—
(1) Paragraph (2) of section 552(c) of such
Code is amended—
(A) by amending subparagraph (A) to read
as follows:
‘‘(A) is received from a related person
which (i) is a corporation created or organized
under the laws of the same foreign country
under the laws of which the foreign corporation
involved was created or organized, and (ii) has
a substantial part of its assets used in its trade
or business located in such same foreign coun-
try, and’’, and
(B) by striking ‘‘954(d)(3)’’ and inserting
‘‘964(a)’’.
(2) Subparagraph (B) of section 861(c)(2) of
such Code is amended by striking ‘‘954(d)(3)’’ and
inserting ‘‘964(a)’’.
(3) Subparagraph (A) of section 864(d)(5) of
such Code is amended by striking clauses (ii), (iii),
and (iv).
(4) Subparagraph (A) of section 881(c)(5) of
such Code is hereby repealed.
(5) Subparagraph (D) of section 884(d)(2) of
such Code is amended by striking ‘‘953(c)(3)(C)’’
and inserting ‘‘953(a)(3)(C)’’.
(6) Subparagraph (A) of section 898(b)(3) of
such Code is amended—
(A) by striking ‘‘953(c)(2)’’ and inserting
‘‘953(a)(2)’’, and
(B) by striking ‘‘953(c)(1) and inserting
‘‘953(a)(1)’’.
(7) Clause (i) of section 904(d)(2)(A) of such
Code is amended by inserting ‘‘, as in effect on the
day before the date of the repeal of such section’’
after ‘‘section 954(c)’’.
(8) Subclause (III) of section 904(d)(2)(C)(ii)
of such Code is amended by striking ‘‘953(a)’’ and
inserting ‘‘953(c)’’.
(9) Subparagraph (D) of section 904(d)(2) of
such Code is amended—
(A) by inserting ‘‘, as in effect on the day
before the date of the repeal of such section’’
after ‘‘954(f)’’, and
(B) by inserting ‘‘or passive income’’ be-
fore the period at the end thereof.
(10) Subparagraph (H) of section 904(d)(2) of
such Code is amended by striking ‘‘954(d)(3)’’ and
inserting ‘‘964(a)’’.
(11) Subparagraph (E) of section 904(d)(3) of
such Code is hereby repealed.
(12) Subparagraph (C) of section 988(a)(3) of
such Code is amended by striking ‘‘954(d)(3)’’ and
inserting ‘‘964(a)’’.
(13) Subsection (c) of section 999 of such Code
is amended—
(A) by striking ‘‘, 952(a)(3),’’ in para-
graph (1), and
(B) by striking ‘‘, the addition to subpart
F income under section 952(a)(3),’’ in para-
graph (2).
(14) Subsection (a) of section 6046 of such
Code is amended by striking ‘‘953(c)’’ and inserting
‘‘953(a)’’.
(15) The table of subparts for part III of sub-
chapter M of chapter 1 of such Code is amended by
striking the item relating to subpart G.
(g) EFFECTIVE DATE.—The amendments made by
this section shall apply to taxable years of controlled for-
eign corporations beginning after December 31, 1995, and
to the taxable years of United States shareholders with
which (or in which) such taxable years of controlled for-
eign corporations end.
SEC. 9. EXTENSION OF STATUTE OF LIMITATIONS FOR CER-
TAIN FOREIGN–RELATED DEFICIENCIES.
(a) GENERAL RULE—Subsection (c) of section 6501
of the Internal Revenue Code of 1986 (relating to limita-
tions on assessment and collection) is amended by adding
at the end thereof the following new paragraph:
‘‘(10) 
CERTAIN
FOREIGN-RELATED
DEFI-
CIENCIES.—
‘‘(A) IN GENERAL.—If, before the expira-
tion of the time prescribed by this section for
the assessment of any foreign-related deficiency
(determined with regard to extensions under
paragraph (4))—
‘‘(i) the Secretary determines that
such deficiency cannot be accurately as-
sessed before the expiration of such period
by reason of delay or other actions of the
taxpayer which prevented the timely as-
sessment of such deficiency, and
‘‘(ii) The Secretary sends by certified
or registered mail a notice of such deter-
mination to the taxpayer,
the Secretary may extend the period during
which such deficiency may be assessed by an
additional period of not more than 3 years. Not
more than 1 extension may be made under the
preceding sentence with respect to any defi-
ciency.
‘‘(B) FOREIGN-RELATED
DEFICIENCY.—
For purposes of subparagraph (A), the term
‘foreign-related deficiency’ means—
‘‘(i) any deficiency of a domestic cor-
poration which is 25-percent foreign-owned
to the extent such deficiency is attributable
to a transaction directly or indirectly with
a related party who is a foreign person,
and
‘‘(ii) any deficiency of a foreign cor-
poration with respect to the taxes imposed
pursuant to sections 882 and 884.
‘‘(C) JUDICIAL PROCEEDINGS.—
‘‘(i) REVIEW.—Notwithstanding any
law or rule of law, any taxpayer to which
a notice of a determination under subpara-
graph (A) has been mailed shall have the
right to begin a proceeding to review such
determination not later than the 90th day
after the day on which such notice was
mailed. If such a proceeding is not begun
on or before such 90th day, such deter-
mination by the Secretary shall be binding
and shall not be reviewed by any court.
‘‘(ii) 
JURISDICTION.—The 
United
States district court for the district in
which the taxpayer resides or is found
shall have jurisdiction to hear any proceed-
ing brought under clause (i). Any order or
other determination in such a proceeding
shall be treated as a final order which may
be appealed.
‘‘(iii) SUSPENSION
OF
STATUTE
OF
LIMITATIONS.—If the taxpayer brings a
proceeding under clause (i), the running of
any period of limitations under this section
or section 6531 with respect to the defi-
ciency to which the proceeding relates shall
be suspended for the period beginning on
the date on which the notice under sub-
paragraph (A) was mailed and ending on
the date on which there is a final deter-
mination in the proceeding. In no event
shall any such period expire before the
90th day after the day on which there is
a final determination in such proceeding.
‘‘(D) DEFINITIONS.—For purposes of this
paragraph, the terms ‘25-percent foreign-
owned’, ‘foreign person’, and ‘related party’
have the respective meanings given such terms
by section 6038A(c).’’
(b) EFFECTIVE DATE.—The amendment made by
subsection (a) shall apply to any deficiency—
(1) for any taxable year ending after the date
of the enactment of this Act, or
(2) any taxable year ending on or before such
date of enactment if the period during which such
deficiency may be assessed under section 6501 of the
Internal Revenue Code of 1986 (determined without
regard to the amendments made by subsection (a))
has not expired before such date of the enactment.
SEC. 10. REDUCTION OF OUTSTANDING LOAN, GUARANTEE,
AND INSURANCE AUTHORITY OF THE EX-
PORT-IMPORT BANK OF THE UNITED STATES.
(a) IN GENERAL.—Section 6(a) of the Export-Import
Bank Act of 1945 (12 U.S.C. 635e(a)) is amended by
striking 
‘‘$75,000,000,000’’ 
and 
inserting
‘‘$37,500,000,000’’.
(b) AUTHORITY TO IMPOSE FINANCING FEES BASED
ON CREDIT RISK.—Section 2 of the Export-Import Bank
Act of 1945 (12 U.S.C. 635) is amended by adding at
the end the following:
‘‘(f) IMPOSITION OF FINANCING FEES BASED ON
CREDIT RISK.—The Bank shall charge and collect a fee
for the provision of a guarantee, the provision of insur-
ance, the extension of credit, or the participation of the
Bank in an extension of credit, under this Act, which shall
be—
‘‘(1) based on the credit risk associated with
the transaction involved; and
‘‘(2) not less than the fee that would be
charged for similar purposes in an arms-length
transaction in the private sector.’’.
(c) EFFECTIVE DATE.—The amendments made by
this section shall take effect on October 1, 1995.
SEC. 11. ABOLITION OF OVERSEAS PRIVATE INVESTMENT
CORPORATION.
(a) ABOLITION.—The Overseas Private Investment
Corporation is abolished, effective October 1, 1995.
(b) ADMINISTRATION OF EXISTING OBLIGATIONS.—
The Secretary of State shall carry out the functions per-
formed on September 30, 1995, by the Overseas Private
Investment Corporation only for purposes of administering
insurance, reinsurance, financing, and other contracts or
agreements issued or entered into by the Corporation that
are effective on October 1, 1995. Such functions shall ter-
minate when all such insurance, reinsurance, financing,
and other contracts or agreements expire.
(c) TERMINATION OF PROVISIONS.—Title IV of chap-
ter 2 of part I of the Foreign Assistance Act of 1961 (22
U.S.C. 2191 and following) shall cease to be effective on
October 1, 1995, except that such title shall continue in
effect with respect to the functions performed by the Sec-
retary of State under subsection (b).
(d) TERMINATION OF AFFAIRS.—The Director of the
Office of Management and Budget shall take the nec-
essary steps to terminate the affairs of the Overseas Pri-
vate Investment Corporation.
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