,i  #aacth ,,congress  #ast ,session    
,h4 ,r4 #cgic  ,,in ,,the ,,house ,,of  
,,representatives  ,december #ai1       
#bjac,mr4 ,maffei 7for himself1 ,mr4    
,castro of ,texas1 ,ms4 ,shea-,porter1  
,mr4 ,sean ,patrick ,maloney of ,new    
,york1 ,mr4 ,ryan of ,ohio1 ,mr4        
,courtney1 ,mr4 ,loebsack1 ,mr4         
,de,fazio1 ,ms4 ,pingree of ,maine1 ,mr4
 ,heck of ,washington1 ,mr4 ,doggett1   
,mr4 ,langevin1 ,mr4 ,barber1 ,ms4      
,gabbard1 ,mr4 ,butterfield1 ,ms4       
,wilson of ,florida1 ,mr4 ,michaud1 ,ms4
 ,kuster1 ,mr4 ,vela1 ,mr4 ,walz1 ,ms4  
,wasserman ,schultz1 ,mr4 ,kildee1 ,ms4 
,hanabusa1 ,mr4 ,peters of ,michigan1   
,ms4 ,bordallo1 ,mr4 ,o',rourke1 ,ms4   
,michelle ,lujan ,grisham of ,new       
,mexico1 ,mr4 ,grayson1 ,mr4 ,garamendi1
 ,mr4 ,perlmutter1 ,mrs4 ,bustos1 ,ms4  
,castor of ,florida1 ,ms4 ,schwartz1    
,ms4 ,edwards1 ,mr4 ,tonko1 ,mr4 ,braley
 of ,iowa1 and ,mr4 ,larson of          
,connecticut7 introduced the following  
bill2 which was referred to the         

,committee on ,ways and ,means1 and in  
addition to the ,committee on ,armed    
,services1 for a period to be           
subsequently determined by the ,speaker1
 in each case for consideration of such 
provisions as fall within the           
jurisdiction of the committee concerned 
,a ,,bill  ,to restore full military    
retirement benefits by closing corporate
 tax loopholes4  #a4 ,short title ,this 
,act may be cited as the ,military      
,retirement ,restoration ,act4  #b4     
,repeal of reductions made by           
,bipartisan ,budget ,act of #bjac       
,section #djc of the ,bipartisan ,budget
 ,act of #bjac is repealed as of the    
date of the enactment of such ,act4  #c4
 ,treatment of foreign corporations     
managed and controlled in the ,united   
,states as domestic corporations  7a7   
,in general ,section #ggja of the       
,internal ,revenue ,code of #aihf is    
amended by redesignating subsection 7p7 
as subsection 7q7 and by inserting after
 subsection 7o7 the following new       

subsection3  7p7 ,certain corporations  
managed and controlled in the ,united   
,states treated as domestic for income  
tax  7#a7 ,in general ,notwithstanding  
subsection 7a77#d71 in the case of a    
corporation described in paragraph 7#b7 
if-- 7,a7 the corporation would not     
otherwise be treated as a domestic      
corporation for purposes of this title1 
but  7,b7 the management and control of 
the corporation occurs1 directly or     
indirectly1 primarily within the ,united
 ,states1  then1 solely for purposes of 
chapter #a 7and any other provision of  
this title relating to chapter #a71 the 
corporation shall be treated as a       
domestic corporation4  7#b7 ,corporation
 described  7,a7 ,in general ,a         
corporation is described in this        
paragraph if-- 7i7 the stock of such    
corporation is regularly traded on an   
established securities market1 or  7ii7 
the aggregate gross assets of such      
corporation 7or any predecessor         
thereof71 including assets under        

management for investors1 whether held  
directly or indirectly1 at any time     
during the taxable year or any preceding
 taxable year is #ej1jjj1jjj or more4   
7,b7 ,general exception ,a corporation  
shall not be treated as described in    
this paragraph if-- 7i7 such corporation
 was treated as a corporation described 
in this paragraph in a preceding taxable
 year1  7ii7 such corporation-- 7,i7 is 
not regularly traded on an established  
securities market1 and  7,,ii7 has1 and 
is reasonably expected to continue to   
have1 aggregate gross assets 7including 
assets under management for investors1  
whether held directly or indirectly7 of 
less than #ej1jjj1jjj1 and  7iii7 the   
,secretary grants a waiver to such      
corporation under this subparagraph4    
7#c7 ,management and control  7,a7 ,in  
general ,the ,secretary shall prescribe 
regulations for purposes of determining 
cases in which the management and       
control of a corporation is to be       
treated as occurring primarily within   

the ,united ,states4  7,b7 ,executive   
officers and senior management ,such    
regulations shall provide that-- 7i7 the
 management and control of a corporation
 shall be treated as occurring primarily
 within the ,united ,states if          
substantially all of the executive      
officers and senior management of the   
corporation who exercise day-to-day     
responsibility for making decisions     
involving strategic1 financial1 and     
operational policies of the corporation 
are located primarily within the ,united
 ,states1 and  7ii7 individuals who are 
not executive officers and senior       
management of the corporation 7including
 individuals who are officers or        
employees of other corporations in the  
same chain of corporations as the       
corporation7 shall be treated as        
executive officers and senior management
 if such individuals exercise the       
day-to-day responsibilities of the      
corporation described in clause 7i74    
7,c7 ,corporations primarily holding    

investment assets ,such regulations     
shall also provide that the management  
and control of a corporation shall be   
treated as occurring primarily within   
the ,united ,states if-- 7i7 the assets 
of such corporation 7directly or        
indirectly7 consist primarily of assets 
being managed on behalf of investors1   
and  7ii7 decisions about how to invest 
the assets are made in the ,united      
,states4  4  7b7 ,effective date ,the   
amendments made by this section shall   
apply to taxable years beginning on or  
after the date which is #b years after  
the date of the enactment of this ,act1 
whether or not regulations are issued   
under section #ggja7p77#c7 of the       
,internal ,revenue ,code of #aihf1 as   
added by this section4