Code Section 953

Code Section	Effective Date	Name of Act	Name of Provision	10yr Revenue Estimate ($millions)
953, 954	*12/31/2011	The American Taxpayer Relief Act of 2012	Exceptions for active financing income	-11,225
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.

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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.

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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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