Permanent CFC Look-Through Act of 2023

Bill: 118-hr-4357
Sponsor: full_name: Rep. Tenney, Claudia [R-NY-24]
Introduced: 2023-06-23
Policy area: Taxation
Latest action: action_date: 2023-06-23
text: Referred to the House Committee on Ways and Means.

Summaries:
action_date: 2023-06-23
action_desc: Introduced in House
text: <p> <strong>Permanent CFC Look-Through Act of 2023 </strong></p> <p>This rule makes permanent the look-through rule for related controlled foreign corporations (CFCs). That rule provides that dividends, interest, rents and royalties one CFC receives from a related CFC are not treated as foreign personal holding company income (thus permitting the deferral of tax on such income).</p>

tv_txt: I 118th CONGRESS 1st Session H. R. 4357 IN THE HOUSE OF REPRESENTATIVES June 23, 2023 Ms. Tenney (for herself and Ms. Sewell ) 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 make the look-through rule for related controlled foreign corporations permanent.

1. Short title This Act may be cited as the Permanent CFC Look-Through Act of 2023 . 2. Look-through rule for related controlled foreign corporations made permanent (a) In general Section 954(c)(6) of the Internal Revenue Code of 1986 is amended by striking subparagraph (C). (b) Effective date The amendment made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2023, and to taxable years of United States shareholders with or within which such taxable years of foreign corporations end.