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Permanent CFC Look-Through Act of 2023
12/15/2023, 3:59 PM
Summary of Bill HR 4357
Bill 118 hr 4357, also known as the Permanent CFC Look-Through Act of 2023, is a piece of legislation currently being considered by the US Congress. The bill aims to make permanent a provision in the tax code that allows certain controlled foreign corporations (CFCs) to be treated as pass-through entities for tax purposes.
Under current law, CFCs are subject to US taxation on their income, but certain income earned by a CFC from transactions with related parties is not subject to US tax. The look-through provision allows this income to be treated as if it were earned directly by the CFC's US shareholders, who are then taxed on that income.
The Permanent CFC Look-Through Act of 2023 seeks to make this provision permanent, providing certainty to businesses and investors who rely on this tax treatment. Proponents of the bill argue that making the provision permanent will encourage investment and economic growth by reducing the tax burden on US shareholders of CFCs. Opponents of the bill may argue that it could lead to a loss of tax revenue for the US government, as income that would have been taxed at the corporate level will now be taxed at the individual level. They may also raise concerns about potential abuse of the provision by multinational corporations seeking to avoid US taxation. Overall, the Permanent CFC Look-Through Act of 2023 is a complex piece of legislation with potential implications for US tax policy and international business. It is currently being debated in Congress, and its ultimate fate remains uncertain.
Under current law, CFCs are subject to US taxation on their income, but certain income earned by a CFC from transactions with related parties is not subject to US tax. The look-through provision allows this income to be treated as if it were earned directly by the CFC's US shareholders, who are then taxed on that income.
The Permanent CFC Look-Through Act of 2023 seeks to make this provision permanent, providing certainty to businesses and investors who rely on this tax treatment. Proponents of the bill argue that making the provision permanent will encourage investment and economic growth by reducing the tax burden on US shareholders of CFCs. Opponents of the bill may argue that it could lead to a loss of tax revenue for the US government, as income that would have been taxed at the corporate level will now be taxed at the individual level. They may also raise concerns about potential abuse of the provision by multinational corporations seeking to avoid US taxation. Overall, the Permanent CFC Look-Through Act of 2023 is a complex piece of legislation with potential implications for US tax policy and international business. It is currently being debated in Congress, and its ultimate fate remains uncertain.
Congressional Summary of HR 4357
Permanent CFC Look-Through Act of 2023
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).
Current Status of Bill HR 4357
Bill HR 4357 is currently in the status of Bill Introduced since June 23, 2023. Bill HR 4357 was introduced during Congress 118 and was introduced to the House on June 23, 2023. Bill HR 4357's most recent activity was Referred to the House Committee on Ways and Means. as of June 23, 2023
Bipartisan Support of Bill HR 4357
Total Number of Sponsors
1Democrat Sponsors
0Republican Sponsors
1Unaffiliated Sponsors
0Total Number of Cosponsors
4Democrat Cosponsors
4Republican Cosponsors
0Unaffiliated Cosponsors
0Policy Area and Potential Impact of Bill HR 4357
Primary Policy Focus
TaxationComments
Sponsors and Cosponsors of HR 4357
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