Code Section 954
| Code Section | Effective Date | Name of Act | Name of Provision | 10yr Revenue Estimate ($millions) |
|---|---|---|---|---|
| 954(c)(6) | *12/31/2011 | The American Taxpayer Relief Act of 2012 | Look-thru treatment of payments between related controlled foreign corporations under foreign personal holding company rules | -1,503 |
| 953, 954 | *12/31/2011 | The American Taxpayer Relief Act of 2012 | Exceptions for active financing income | -11,225 |
| 954(c)(6) | *12/31/2009 | The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 | Look-thru treatment of payments between related controlled foreign corporations under foreign personal holding company rules | -1,505 |
| 953, 954 | *12/31/2009 | The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 | Exceptions for active financing income | -9,157 |
* Notes on Effective Date
The provision is effective for taxable years of U.S. shareholders with or within which such taxable years of such foreign corporations end.
Look-thru treatment of payments between related controlled foreign corporations under foreign personal holding company rules
Explanation of Provision
The provision extends for two years the application of the lookthru rule, to taxable years of foreign corporations ending before January 1, 2014, and for taxable years of U.S. shareholders with or within which such taxable years of foreign corporations end.
Exceptions for active financing income
Explanation of Provision
The provision extends for two years (for taxable years beginning before January 1, 2014) the present-law temporary exceptions from subpart F foreign personal holding company income, foreign base company services income, and insurance income for certain income that is derived in the active conduct of a banking, financing, or similar business, or in the conduct of an insurance business.
Look-thru treatment of payments between related controlled foreign corporations under foreign personal holding company rules
Explanation of Provision
The provision extends for two years the application of the look thru rule, to taxable years of foreign corporations beginning before January 1, 2012, and for taxable years of U.S. shareholders with or within which such taxable years of such foreign corporations end.
Exceptions for active financing income
Explanation of Provision
The provision extends for two years (for taxable years beginning before 2012) the present-law temporary exceptions from subpart F foreign personal holding company income, foreign base company services income, and insurance income for certain income that is derived in the active conduct of a banking, financing, or similar business, or in the conduct of an insurance business.
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