Permanent CFC Look-Through Act of 2023
Legislative Progress
Momentum (last 30 days)
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vs 10,564 other HR bills in the 118th — cohort avg 68d
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).
These links require the bill number to appear in the filing's source-reported specific issue text. Client expenses and lobbying-firm income are separate disclosure fields.
Filing registrants (1)
2024 · second_quarter · Taxation/Internal Revenue Code
Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations; H.R. 7024, Tax Relief for American Families and Workers Act of 2024. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; United Nations tax convention. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues; T.D. 9959, Final Regulations on foreign tax credits; REG-120653-22, CHIPS Act advanced manufacturing tax credit; Notice 2023-63 and Notice 2024-12. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent, and potential Senate companion bill. H.R. 5988, United States-Taiwan Expedited Double-Tax Relief Act.
Referred to the House Committee on Ways and Means.
Introduced in House
Congress.gov source codes: 1000, Intro-H
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Sources: Congress.gov
Client expense: $1,980,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Security Council (NSC), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR), White House Office
2024 · first_quarter · Taxation/Internal Revenue Code
Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0; United Nations tax convention. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues; T.D. 9959, Final Regulations on foreign tax credits; REG-120653-22, CHIPS Act advanced manufacturing tax credit. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent, and potential Senate companion bill. H.R. 5988, United States-Taiwan Expedited Double-Tax Relief Act.
Client expense: $1,210,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, White House Office
2023 · third_quarter · Taxation/Internal Revenue Code
Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; H.R. 5371, S. 1077, Permanently Preserving America's Investment in Manufacturing Act; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent; and potential Senate companion bill. Bilateral Taiwan income tax agreement.
Client expense: $1,740,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of
2023 · fourth_quarter · Taxation/Internal Revenue Code
Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; Public Law no.117-169, Inflation Reduction Act, implementation and regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues; T.D. 9959, Final Regulations on foreign tax credits; REG-120653-22, CHIPS Act advanced manufacturing tax credit. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent; and potential Senate companion bill. U.S.-Chile bilateral income tax treaty; H.R 5988, United States-Taiwan Expedited Double-Tax Relief Act.
Client expense: $1,270,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, White House Office
2023 · third_quarter · Taxation/Internal Revenue Code
Legislative & Regulatory Issues Related to Domestic and International Tax, including Tax Treaties: Tax proposals related to Build Back Better Act; H.R. 5371, S. 1077, Permanently Preserving America's Investment in Manufacturing Act; Public Law no. 117-169, Inflation Reduction Act, implementation and regulations. Global Digital Taxes, e.g. DSTs; U.S. Treasury guidelines and related regulations on OECD, Addressing Tax Challenges of Digitalization, and BEPS 2.0. S. 866, American Innovation and Jobs Act of 2023 (R&D expensing); H.R. 2673, American Innovation and R&D Competitiveness Act of 2023 and related issues. H.R. 4357, To amend the Internal Revenue Code of 1986 to make the look-through rule for related controlled foreign corporations permanent; and potential Senate companion bill. Bilateral Taiwan income tax agreement.
Client expense: $1,580,000 · Firm income: Not reported
Government targets: HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of