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H.R. 4464, Permanent CFC Look-Through Act of 2014 1 (May 1, 2014)

handle is hein.congrec/cbo1624 and id is 1 raw text is: CONGRESSIONAL BUDGET OFFICE COST ESTIMATE May 1, 2014 H.R. 4464 Permanent CFC Look-Through Act of 2014 As ordered reported by the House Committee on Ways and Means on April 29, 2014 H.R. 4464 would amend the Internal Revenue Code to make permanent the look-through rule that applied to the taxable years of foreign corporations beginning after December 31, 2005 and before January 1, 2014. This treatment would be permanently effective for taxable years beginning after December 31, 2013. The look-through rule determines the tax treatment of payments between related controlled foreign corporations (CFCs) under foreign personal holding company rules. Under this rule, dividends, interest, rents, and royalties received or accrued by one CFC from a related CFC are not treated as foreign personal holding company income for tax purposes if they meet certain characteristics. The staff of the Joint Committee on Taxation (JCT) estimates that enacting H.R. 4464 would reduce revenues, thus increasing federal deficits, by about $20 billion over the 2014-2024 period. The Statutory Pay-As-You-Go Act of 2010 establishes budget-reporting and enforcement procedures for legislation affecting direct spending and revenues. Enacting H.R. 4464 would result in revenue losses in each year beginning in 2014. The estimated increases in the deficit are shown in the following table. JCT has determined that the bill contains no intergovernmental or private-sector mandates as defined in the Unfunded Mandates Reform Act. The CBO staff contact for this estimate is Logan Timmerhoff. The estimate was approved by David Weiner, Assistant Director for Tax Analysis.

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