Tax Fairness and Transparency Act

Bill: 115-hr-2057
Sponsor: Rep. Pocan, Mark [D-WI-2]
Introduced: 2017-04-06 in the House
Policy area: Taxation
Subjects: Accounting and auditing
Business records
Corporate finance and management
Financial services and investments
Foreign and international corporations
Government information and archives
Income tax deductions
Interest, dividends, interest rates
Securities
State and local taxation
Taxation of foreign income

Summary:
action_date: 2017-04-06
text: 

Tax Fairness and Transparency Act 

 
This bill amends the Internal Revenue Code to limit the tax deduction of the interest expense of a U.S. corporation that is a member of a financial reporting group (a group that prepares consolidated financial statements according to accepted accounting principles or international financial reporting standards) to: (1) the amount of interest on indebtedness of the corporation includible in the corporation's gross income for the taxable year plus its proportionate share of the group's net interest expense in the taxable year computed under U.S. income tax principles; or (2) not more than 10% of the corporation's adjusted taxable income, if the corporation fails to substantiate its proportionate share of interest expense or so elects. 
 
The bill exempts from the limitation a corporation that is predominantly engaged in the active conduct of a banking, financing, or similar business or that has less than $5 million of net interest expense for the taxable year. 
 
The bill also modifies the definition of subpart F income (i.e., income of a controlled foreign corporation earned outside the United States that is not tax-deferred) to include income of a controlled foreign corporation derived from any foreign country. This modification is applicable to taxable years beginning after December 31, 2017. 
 
The bill amends the Securities Exchange Act of 1934 to require each issuer of a security who is required to file an annual or quarterly report to disclose specified: (1) details regarding pre-tax profits and taxes paid; and (2) corporate financial information, aggregated on a country-by-country basis, for each of its subsidiaries. 


Legislative actions:
action_date: 2017-04-06
text: Referred to the Committee on Ways and Means, and in addition to the Committee on Financial Services, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
action_date: 2017-04-06
text: Referred to the Committee on Ways and Means, and in addition to the Committee on Financial Services, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
action_date: 2017-04-06
text: Referred to the Committee on Ways and Means, and in addition to the Committee on Financial Services, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
action_date: 2017-04-06
text: Introduced in House
action_date: 2017-04-06
text: Introduced in House