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Johnson Introduces International Tax Simplification Act of 2006

House_of_representatives_2 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

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