[20200110]IF11392_H、 R1865年和相关受控外国公司之间付款的透视处理.pdf

https:/crsreports.congress.gov Updated January 10, 2020H.R. 1865 and the Look-Through Treatment of Payments Between Related Controlled Foreign CorporationsThe House amendment to the Senate amendment to H.R. 1865, the Further Consolidated Appropriations Act, 2020, extended certain expiring provisions, including a number that were last extended through 2019 by the Consolidated Appropriations Act of 2016 (P.L. 114-113). This legislation was signed into law on December 20, 2019 (P.L. 116-94). Among these provisions are the look-through rules, which allow certain payments between related corporations to be excluded. The Joint Committee on Taxation estimates that extending the look-through rules for a year will cost $0.7 billion. The look-through rules were originally enacted in the Tax Increase Prevention and Reconciliation Act of 2005 (P.L. 109-222), for 2006 through 2008, and subsequently extended. General Rules for Taxing Foreign Subsidiaries of U.S. Parents Income earned abroad by foreign-incorporated subsidiaries is taxed in full, not taxed at full rates, or not taxed at all. For passive income (such as interest income) and certain types of payments that can be easily manipulated