Teacher: In this task, you are given text for US Congressional and California state bills, your task is to generate a summary for this bill.
Teacher: Now, understand the problem? If you are still confused, see the following example:
SECTION 1. LIABILITY OF BUSINESS ENTITIES PROVIDING USE OF FACILITIES
TO NONPROFIT ORGANIZATIONS.

(a) Definitions.--In this section:
(1) Business entity.--The term ''business entity'' means a
firm, corporation, association, partnership, consortium, joint
venture, or other form of enterprise.
(2) Facility.--The term ''facility'' means any real
property, including any building, improvement, or appurtenance.
(3) Gross negligence.--The term ''gross negligence'' means
voluntary and conscious conduct by a person with knowledge (at
the time of the conduct) that the conduct is likely to be
harmful to the health or well-being of another person.
(4) Intentional misconduct.--The term ''intentional
misconduct'' means conduct by a person with knowledge (at the
time of the conduct) that the conduct is harmful to the health
or well-being of another person.
(5) Nonprofit organization.--The term ''nonprofit
organization'' means--
(A) any organization described in section 501(c)(3)
of the Internal Revenue Code of 1986 and exempt from
tax under section 501(a) of such Code; or
(B) any not-for-profit organization organized and
conducted for public benefit and operated primarily for
charitable, civic, educational, religious, welfare, or
health purposes.
(6) State.--The term ''State'' means each of the several
States, the District of Columbia, the Commonwealth of Puerto
Rico, the Virgin Islands, Guam, American Samoa, the Northern
Mariana Islands, any other territory or possession of the
United States, or any political subdivision of any such State,
territory, or possession.
(b) Limitation on Liability.--
(1) In general.--Subject to subsection (c), a business
entity shall not be subject to civil liability relating to any
injury or death occurring at a facility of the business entity
in connection with a use of such facility by a nonprofit
organization if--
(A) the use occurs outside of the scope of business
of the business entity;
(B) such injury or death occurs during a period
that such facility is used by the nonprofit
organization; and
(C) the business entity authorized the use of such
facility by the nonprofit organization.
(2) Application.--This subsection shall apply--
(A) with respect to civil liability under Federal
and State law; and
(B) regardless of whether a nonprofit organization
pays for the use of a facility.
(c) Exception for Liability.--Subsection (b) shall not apply to an
injury or death that results from an act or omission of a business
entity that constitutes gross negligence or intentional misconduct,
including any misconduct that--
(1) constitutes a crime of violence (as that term is
defined in section 16 of title 18, United States Code) or act
of international terrorism (as that term is defined in section
2331 of title 18) for which the defendant has been convicted in
any court;
(2) constitutes a hate crime (as that term is used in the
Hate Crime Statistics Act (28 U.S.C. 534 note));
(3) involves a sexual offense, as defined by applicable
State law, for which the defendant has been convicted in any
court; or
(4) involves misconduct for which the defendant has been
found to have violated a Federal or State civil rights law.
(d) Superseding Provision.--
(1) In general.--Subject to paragraph (2) and subsection
(e), this Act preempts the laws of any State to the extent that
such laws are inconsistent with this Act, except that this Act
shall not preempt any State law that provides additional
protection from liability for a business entity for an injury
or death with respect to which conditions under subparagraphs
(A) through (C) of subsection (b)(1) apply.
(2) Limitation.--Nothing in this Act shall be construed to
supersede any Federal or State health or safety law.
(e) Election of State Regarding Nonapplicability.--This Act shall
not apply to any civil action in a State court against a business
entity in which all parties are citizens of the State if such State
enacts a statute--
(1) citing the authority of this subsection;
(2) declaring the election of such State that this Act
shall not apply to such civil action in the State; and
(3) containing no other provision.
Solution: Shields a business entity from civil liability relating to any injury or death occurring at a facility of that entity in connection with a use of such facility by a nonprofit organization if: (1) the use occurs outside the scope of business of the business entity; (2) such injury or death occurs during a period that such facility is used by such organization; and (3) the business entity authorized the use of such facility by the organization.
Makes this Act inapplicable to an injury or death that results from an act or omission of a business entity that constitutes gross negligence or intentional misconduct, including misconduct that: (1) constitutes a hate crime or a crime of violence or act of international terrorism for which the defendant has been convicted in any court; or (2) involves a sexual offense for which the defendant has been convicted in any court or misconduct for which the defendant has been found to have violated a Federal or State civil rights law.
Preempts State laws to the extent that such laws are inconsistent with this Act, except State law that provides additional protection from liability. Specifies that this Act shall not be construed to supersede any Federal or State health or safety law.
Makes this Act inapplicable to any civil action in a State court against a business entity in which all parties are citizens of the State if such State, citing this Act's authority and containing no other provision, enacts a statute declaring the State's election that this Act shall not apply to such action in the State.
Reason: This Bill focuses on shielding business entities from civil liability relating to an injury or death depending on the conditions of injury, hence the generated summary is correct.

Now, solve this instance: SECTION 1. SHORT TITLE.

This Act may be cited as the ''Fairness and Accountability in
International Taxation Act of 2003''.

SEC. 2. DENIAL OF TREATY BENEFITS FOR CERTAIN DEDUCTIBLE PAYMENTS.

(a) In General.--Section 894 of the Internal Revenue Code of 1986
(relating to income affected by treaty) is amended by adding at the end
the following new subsection:
''(d) Denial of Treaty Benefits for Certain Deductible Payments.--
''(1) In general.--A foreign entity shall not be entitled
under any income tax treaty of the United States with a foreign
country to any reduced rate of any withholding tax imposed by
this title on any deductible foreign payment unless such entity
is predominantly owned by individuals who are residents of such
foreign country.
''(2) Deductible foreign payment.--For purposes of
paragraph (1), the term 'deductible foreign payment' means any
payment--
''(A) which is made by a domestic entity directly
or indirectly to a related person which is a foreign
entity, and
''(B) which is allowable as a deduction under this
chapter.
''(3) Domestic and foreign entities; related person.--For
purposes of this subsection--
''(A) Domestic entity.--The term 'domestic entity'
means any domestic corporation or domestic partnership.
''(B) Foreign entity.--The term 'foreign entity'
means any foreign corporation or foreign partnership.
''(C) Related person.--The term 'related person'
has the meaning given such term by section 954(d)(3)
(determined by substituting 'domestic entity' for
'controlled foreign corporation' each place it
appears).
''(4) Predominant ownership.--For purposes of this
subsection--
''(A) In general.--An entity is predominantly owned
by individuals who are residents of a foreign country
if--
''(i) in the case of a corporation, more
than 50 percent (by value) of the stock of such
corporation is owned (within the meaning of
section 883(c)(4)) by individuals who are
residents of such foreign country, or
''(ii) in the case of a partnership, more
than 50 percent (by value) of the beneficial
interests in such partnership are so owned.
''(B) Publicly traded corporations.--A foreign
corporation also shall be treated as predominantly
owned by individuals who are residents of a foreign
country if--
''(i)(I) the stock of such corporation is
primarily and regularly traded on an
established securities market in such foreign
country, and
''(II) such corporation has activities
within such foreign country which are
substantial in relation to the total activities
of such corporation and its related persons, or
''(ii) such corporation is wholly owned
(directly or indirectly) by another foreign
corporation which is described in clause (i).
''(C) Special rule.--
''(i) In general.--A foreign corporation
shall be treated as meeting the requirements of
subparagraph (A) if--
''(I) such requirements would be
met if '30 percent' were substituted
for '50 percent' in subparagraph
(A)(i),
''(II) the treaty country is a
member of a multinational economic
association such as the European Union,
and
''(III) at least 50 percent of the
value of the stock of the corporation
is owned (within the meaning of section
883(c)(4)) by individuals who are
residents of the treaty country or
other qualified foreign countries.
''(ii) Qualified foreign country.--For
purposes of this subparagraph, the term
'qualified foreign country' means any foreign
country if--
''(I) such foreign country is a
member of the multinational economic
association of which the treaty country
is a member, and
''(II) such foreign country has a
tax treaty with the United States
providing a withholding tax rate
reduction which is not less than the
withholding tax rate reduction
applicable (without regard to this
subsection) to the payment received by such foreign corporation.
''(5) Exception for corporations with substantial business
activities in treaty country.--Paragraph (1) shall not apply to
a payment received by a foreign corporation if such corporation
has substantial business activities in the treaty country and
if such corporation establishes to the satisfaction of the
Secretary that the payment is subject to an effective rate of
income tax imposed by such country greater than 90 percent of
the maximum rate of tax specified in section 11.
''(6) Exception for payments received by controlled foreign
corporation.--Paragraph (1) shall not apply to any deductible
foreign payment made by a corporation if the recipient of the
payment is a controlled foreign corporation and the payor is a
United States shareholder (as defined in section 951(b)) of
such corporation.
''(7) Conduit payments.--Under regulations prescribed by
the Secretary, paragraph (1) shall not apply to a payment
received by a foreign entity referred to in paragraph (1) if--
''(A) within a reasonable period after such entity
receives such payment, such entity makes a comparable
payment directly or indirectly to another related
person,
''(B) such related person is a resident of a
foreign country with which the United States has an
income tax treaty,
''(C) such related person is predominantly owned by
individuals who are residents of such country, and
''(D) the withholding tax rate applicable under
such treaty is equal to or greater than the withholding
tax rate applicable (without regard to this paragraph)
to the payment received by such foreign entity.
A similar rule shall apply where the payment is includible in
the gross income of a related person by reason of a foreign law
comparable to subpart F of part III of subchapter N.''
(b) Effective Date.--The amendment made by this section shall take
effect on the date of the enactment of this Act.

SEC. 3. TRANSFER PRICE REDUCED BY DEFLECTED TAX HAVEN INCOME.

(a) In General.--Section 482 of the Internal Revenue Code of 1986
(relating to allocation of income and deductions among taxpayers) is
amended by inserting ''(a) In General.--'' before ''In the case of two
or more'' and by adding at the end the following new subsection:
''(b) Special Rule for Related-Party Inbound and Outbound
Transactions.--
''(1) In general.--In the case of property or services to
which this subsection applies, the transfer price under this
section for such property or service shall be the transfer
price determined without regard to this subsection--
''(A) in the case of a related-party inbound
transaction, reduced by the deflected tax haven income
with respect to such property or service, or
''(B) in the case of a related-party outbound
transaction, increased by the deflected tax haven
income with respect to such property or service.
''(2) Property or services to which subsection applies.--
''(A) In general.--This subsection applies to any
property or services if there is a related-party
inbound or outbound transaction with respect to such
property or services.
''(B) Related-party inbound transaction.--A
related-party inbound transaction is any transaction
where--
''(i) property is acquired directly or
indirectly by a foreign-controlled domestic
corporation from a foreign related person, or
''(ii) the services are performed directly
or indirectly for a foreign-controlled domestic
corporation by a foreign related person.
''(C) Related-party outbound transaction.--A
related-party outbound transaction is any transaction
where--
''(i) property is sold directly or
indirectly by a foreign-controlled domestic
corporation to a foreign related person, or
''(ii) services are performed directly or
indirectly by a foreign-controlled domestic
corporation for a foreign related person.
''(3) Deflected tax haven income.--For purposes of this
subsection--
''(A) In general.--The term 'deflected tax haven
income' means income (whether in the form of profits,
commissions, fees, or otherwise) derived by a foreign
related person in connection with any transaction
related to property or services to which this
subsection applies if such income would be treated as
foreign base company sales income (as defined in
section 954(d)) or foreign base company services income
(as defined in section 954(e)) were such foreign
related person treated as a controlled foreign
corporation.
''(B) Exception for income subject to foreign
taxes.--
''(i) High taxes.--Such term shall not
include any item of income with respect to
which the requirements of section 954(b)(4) are
met.
''(ii) Other taxes.--If the taxpayer
establishes to the satisfaction of the
Secretary that an item of income was subject to
an income tax imposed by a foreign country and
the effective rate of such tax (and such
effective rate was not greater than 90 percent
of the maximum rate of tax specified in section
11), the term 'deflected tax haven income'
shall not include the same proportion of such
income as such effective rate of tax bears to
90 percent.
''(4) Other definitions.--For purposes of this subsection--
''(A) Foreign related person.--The term 'foreign
related person' means any foreign person who is related
(within the meaning of subsection (a)) to the foreign-
controlled domestic corporation.
''(B) Foreign-controlled domestic corporation.--The
term 'foreign-controlled domestic corporation' means
any domestic corporation which is 25-percent foreign-
owned (as defined in section 6038A(c)).''
(b) Effective Date.--The amendment made by this section shall apply
to property acquired, and services performed, after ____.
Student:
Fairness and Accountability in International Taxation Act of 2003 - Amends the Internal Revenue Code to deny reduced withholding tax treaty benefits to a foreign entity on any deductible foreign payment (deductible payment made by a domestic entity to a related foreign entity) unless such entity is predominantly owned by individuals who are residents of such foreign country. Exempts from such provision: (1) corporations with substantial business activities in a treaty country with specified tax rates; (2) payments received by controlled foreign corporations from U.S. shareholders; and (3) certain conduit payments made by foreign corporations.Provides a special income and deduction allocation rule for related-party inbound (transfer price increased by deflected tax haven income) and outbound (transfer price increased by deflected tax haven income) transactions. Defines "related-party inbound transaction," "related-party outbound transaction," and "deflected tax haven."