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H.R. 961, Permanent Active Financing Exception Act of 2015 1 (September 22, 2015)

handle is hein.congrec/cbo2557 and id is 1 raw text is: CONGRESSIONAL BUDGET OFFICE
COST ESTIMATE
September 22, 2015
H.R. 961
Permanent Active Financing Exception Act of 2015
As ordered reported by the House Committee on Ways andMeans on September 17, 2015
H.R. 961 would amend the Internal Revenue Code to permanently allow the deferral of tax
on certain income earned in foreign companies when calculating taxable income. Under
Subpart F rules in the Internal Revenue Code, U.S. shareholders that hold 10 percent or
more of a controlled foreign corporation are subject to U.S. tax annually on certain income
earned by that corporation, whether or not that income is distributed to shareholders.
H.R. 961 would make permanent the temporary exceptions from Subpart F tax treatment
for income from active banking, financing, insurance, or similar business that generally
expired after December 31, 2014.
The staff of the Joint Committee on Taxation (JCT) estimates that enacting H.R. 961 would
reduce revenues, thus increasing federal budget deficits, by about $78 billion over the
2016-2025 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. 961
would result in revenue losses in each year beginning in 2016. 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 Peter Huether. The estimate was approved by
David Weiner, Assistant Director for Tax Analysis.

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