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Proposed U.S. House Bill Would Permanently Extend Subpart F Exception

23 April 2014

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Proposed Changes

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United States

Bill H.R. 4429 was introduced on April 8th, 2014 and referred to the House Committee on Ways and Means. The bill, if enacted, would amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income of controlled foreign companies (CFC). The exception applies primarily to active banking, financing, or similar business income of CFCs. The permanent extension of the exception, if enacted, would apply to tax years of a foreign corporation beginning after December 31, 2013, and to tax years of U.S. shareholders with or within which such tax years of the foreign...