Fairness, Simplification and Competitiveness for American Business Act of 2003

Bill: 108-hr-285
Sponsor: Rep. Houghton, Amo [R-NY-29]
Introduced: 2003-01-08 in the House
Policy area: Taxation
Subjects: Accounting
Administrative procedure
Affiliated corporations
Airline passenger traffic
Alien property
Aliens
American investments
Bank holding companies
Brokers
Capital gains tax
Commerce
Congress
Congressional reporting requirements
Consumer discounts
Contracts
Corporate debt
Corporation taxes
Department of the Treasury
Dividends
Earnings
Energy
Estate tax
Excise tax
Export finance
Export trading companies
Finance and Financial Sector
Financial institutions
Financial services
Foreign Trade and International Finance
Foreign banks and banking
Foreign corporations
Foreign exchange
Foreign investments
Foreign tax credit
Futures trading
Gas industry
Gas pipelines
Government Operations and Politics
Government paperwork
Holding companies
Immigration
Income tax
Insurance companies
Interest
International banking
Law
Losses
Minimum tax
Mutual funds
Partnerships
Petroleum industry
Petroleum pipelines
Profit
Securities industry
Service industries
Stockholders
Stocks
Subsidiary corporations
Tax administration
Tax deductions
Tax exclusion
Tax exemption
Tax rates
Tax returns
Taxation of foreign income
Translating and interpreting
Transportation and Public Works
Withholding tax

Summary:
action_date: 2003-01-08
text: Fairness, Simplification and Competitiveness for American Business Act of 2003 - Revises Internal Revenue Code rules relating to U.S. businesses operating abroad.
Revises provisions concerning treatment of controlled foreign corporations, including: (1) expanding the de minimis rule; (2) excluding from the definition of "foreign base company oil related income" the pipeline transportation of oil or gas within such foreign country; (3) repealing rules applicable to foreign personal holding companies and foreign investment companies; (4) amending the definition of foreign personal holding company income to include income from certain personal services contracts and sale of such contracts; (5) repealing controlled foreign corporation rules on foreign base company sales and service income; (6) reducing foreign tax credit baskets; and (7) not treating interest, dividends, rents, and royalties from a related controlled foreign corporation as foreign personal holding company income.
Sets forth provisions concerning foreign tax credit, including: (1) extending the period in which excess foreign taxes may be carried; (2) defining overall domestic loss and setting forth provisions for determining taxable income for any taxpayer sustaining such a loss; (3) issuing special rules relating to financial services income; (4) dictating rules for the treatment of dividends from certain corporations and extending the look-through treatment for such corporations; (5) extending the carryforward period for foreign tax credits; (6) repealing the limitation of such credits under the alternative minimum tax; and (7) eliminating limitation on such credits with regard to oil or gas extraction taxes.
Exempts certain foreign corporations from uniform capitalization rules.
Sets forth provisions concerning airline mileage awards to certain foreign persons.
Repeals the special capital gains tax on certain nonresident aliens.
Exempts dividends paid by a foreign corporation to a nonresident alien from 30 percent taxation.
Permits, for interest allocation rule purposes, treating each electing worldwide affiliated group as an affiliated group, subject to exceptions.
Makes permanent the subpart F exception for active income financing (presently, the exception expires for taxable years beginning after December 31, 2006).

Legislative actions:
action_date: 2003-01-08
text: Referred to the House Committee on Ways and Means.
action_date: 2003-01-08
text: Sponsor introductory remarks on measure. (CR E54)
action_date: 2003-01-08
text: Introduced in House
action_date: 2003-01-08
text: Introduced in House