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H.R. 1430, Permanent CFC Look-Through Act of 2015 1 (September 22, 2015)

handle is hein.congrec/cbo2558 and id is 1 raw text is: CONGRESSIONAL BUDGET OFFICE COST ESTIMATE September 22, 2015 H.R. 1430 Permanent CFC Look-Through Act of 2015 As ordered reported by the House Committee on Ways andMeans on September 17, 2015 H.R. 1430 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, 2015. This treatment would be permanently effective for taxable years beginning after December 31, 2014. 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. 1430 would reduce revenues, thus increasing federal deficits, by about $21.8 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. 1430 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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