Rep. Sam Johnson (R-TX), a senior member of the House Ways & Means Committee, today introduced the International Tax Simplification Act of 2006, which would make a number changes to various international tax rules:
- Permanent Subpart F exemption for active financing income
- Permanent look-thru rule for related controlled foreign corporations
- Repeal of foreign base company sales and services income rules
- Repeal of foreign base company oil related income rules
- Repeal of special rules for applying foreign tax credit in case of foreign oil and gas income
- Extension of carryforward period for excess foreign taxes
- Subpart F earnings and profits determined under generally accepted accounting principles
- Acceleration of election to allocate interest on a worldwide basis
- Expansion of de minimis rule under subpart F




