,i  #aacth ,,congress  #ast ,session    
,h4 ,r4 #aeef  ,,in ,,the ,,house ,,of  
,,representatives  ,april #ae1 #bjac    
,mr4 ,doggett 7for himself1 ,mr4        
,de,fazio1 ,ms4 ,de,lauro1 ,mr4         
,dingell1 ,mr4 ,moran1 ,ms4 ,lee of     
,california1 ,mr4 ,rush1 ,mr4           
,garamendi1 ,ms4 ,schakowsky1 ,mr4      
,mc,dermott1 ,mr4 ,cicilline1 and ,mr4  
,cohen7 introduced the following bill2  
which was referred to the ,committee on 
,ways and ,means  ,a ,,bill  ,to amend  
the ,internal ,revenue ,code of #aihf to
 prevent corporations from exploiting   
tax treaties to evade taxation of       
,united ,states income4  #a4 ,short     
title ,this ,act may be cited as the    
,fairness in ,international ,taxation   
,act4  #b4 ,limitation on treaty        
benefits for certain deductible payments
  7a7 ,in general ,section #hid of the  
,internal ,revenue ,code of #aihf       
7relating to income affected by treaty7 
is amended by adding at the end the     
following new subsection3  7d7          

,limitation on treaty benefits for      
certain deductible payments  7#a7 ,in   
general ,in the case of any deductible  
related-party payment1 any withholding  
tax imposed under chapter #c 7and any   
tax imposed under subpart ,a or ,b of   
this part7 with respect to such payment 
may not be reduced under any treaty of  
the ,united ,states unless any such     
withholding tax would be reduced under a
 treaty of the ,united ,states if such  
payment were made directly to the       
foreign parent corporation4  7#b7       
,deductible related-party payment ,for  
purposes of this subsection1 the term   
deductible related-party payment means  
any payment made1 directly or           
indirectly1 by any person to any other  
person if the payment is allowable as a 
deduction under this chapter and both   
persons are members of the same foreign 
controlled group of entities4  7#c7     
,foreign controlled group of entities   
,for purposes of this subsection--  7,a7
 ,in general ,the term foreign          

controlled group of entities means a    
controlled group of entities the common 
parent of which is a foreign            
corporation4  7,b7 ,controlled group of 
entities ,the term controlled group of  
entities means a controlled group of    
corporations as defined in section      
#aefc7;a77#a71 except that--  7i7 more  
than #ej percent shall be substituted   
for at least #hj percent each place it  
appears therein1 and  7ii7 the          
determination shall be made without     
regard to subsections 7a77#d7 and       
7b77#b7 of section #aefc4  ,a           
partnership or any other entity 7other  
than a corporation7 shall be treated as 
a member of a controlled group of       
entities if such entity is controlled   
7within the meaning of section          
#ied7;d77#c77 by members of such group  
7including any entity treated as a      
member of such group by reason of this  
sentence74  7#d7 ,foreign parent        
corporation ,for purposes of this       
subsection1 the term foreign parent     

corporation means1 with respect to any  
deductible related-party payment1 the   
common parent of the foreign controlled 
group of entities referred to in        
paragraph 7#c77;,a74  7#e7 ,regulations 
,the ,secretary may prescribe such      
regulations or other guidance as are    
necessary or appropriate to carry out   
the purposes of this subsection1        
including regulations or other guidance 
which provide for--  7,a7 the treatment 
of two or more persons as members of a  
foreign controlled group of entities if 
such persons would be the common parent 
of such group if treated as one         
corporation1 and  7,b7 the treatment of 
any member of a foreign controlled group
 of entities as the common parent of    
such group if such treatment is         
appropriate taking into account the     
economic relationships among such       
entities4  4  7b7 ,effective date ,the  
amendment made by this section shall    
apply to payments made after the date of
 the enactment of this ,act4