S 3494 · 93th Congress · Taxation
A bill to amend the Internal Revenue Code of 1954 with respect to foreign tax credits, tax deferral, personal exemptions, and social security payroll taxes.
Bill Progress
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Introduced2
Committee3
Senate Vote4
House5
EnactedLatest: Referred to Senate Committee on Finance.(1974-05-14)
Plain Language Summary
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Provides that individuals, not corporations, shall be allowed a tax credit under the Internal Revenue Code for taxes of foreign countries and United States possessions paid by such individual. Prescribes creditable amounts for citizens, which is to be the amount of any income, war profits and excess profits taxes paid or accrued during the year to any foreign county or United States possessions. Deletes the special rule for application of foreign tax credit when the overall limitation applies from the provisions on computation and payment of the consolidated returns provisions. Requires United States shareholders of controlled foreign corporations to include in their gross income their pro rata share of the corporations earning and profits. Defines pro rata share, earnings and profits, and controlled foreign corporation. Sets forth rules for determining stock ownership for purposes of this Act. Provides that the earnings and profits for a taxable year of a foreign corporation attributable to amounts which are, or have been, included in the gross income of a United States shareholder under this Act shall not, when such amounts are distributed directly, or indirectly through a chain …
Summarized by Claude AI · Non-partisan · For informational purposes only