,i  #aacth ,,congress  #b;d ,session    
,h4 ,r4 #ebea  ,,in ,,the ,,house ,,of  
,,representatives  ,july #bi1 #bjad ,mr4
 ,owens 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
 exempt foreign pensions from           
dispositions of investment in ,united   
,states real property4  #a4 ,short title
 ,this ,act may be cited as the         
,incentivizing ,foreign ,investment to  
,upgrade ,america's ,infrastructure ,act
 of #bjad4  #b4 ,exemption of foreign   
pensions from dispositions of investment
 in ,united ,states real property  7a7  
,in general ,section #hig of the        
,internal ,revenue ,code of #aihf is    
amended by adding at the end the        
following new subsection3  7k7 ,special 
rule for foreign pensions  7#a7 ,in     
general ,subsection 7a7 shall not apply 
in the case of a qualified foreign      
pension fund4  7#b7 ,qualified foreign  
pension fund ,for purposes of this      

subsection1 the term qualified foreign  
pension fund means any trust1           
corporation1 or other organization or   
arrangement--  7,a7 which is created or 
organized outside of the ,united        
,states1  7,b7 which is established to  
provide retirement or pension benefits  
to participants or beneficiaries that   
are current or former employees 7or     
persons designated by such employees7 of
 one or more employers in consideration 
for services rendered1  7,c7 which does 
not have a single participant or        
beneficiary with a right to more than #e
 percent of its assets1  7,d7 which is  
subject to government regulation and    
provides annual information reporting   
about its beneficiaries to the relevant 
tax authorities in the country in which 
it is established or operates1 and  7,e7
 with respect to which1 under the laws  
of the country in which it is           
established or operates--  7i7          
contributions to such trust1            
corporation1 organization1 or           

arrangement which would otherwise be    
subject to tax under such laws are      
deductible or excluded from the gross   
income of such entity or taxed at a     
reduced rate1 or  7ii7 taxation of any  
investment income of such trust1        
corporation1 organization1 or           
arrangement is deferred or such income  
is taxed at a reduced rate4  7#c7       
,regulations ,the ,secretary may        
prescribe such regulations as are       
necessary to carry out the purposes of  
this subsection4  4  7b7 ,withholding   
,paragraph 7#c7 of section #adde7;f7 of 
such ,code is amended by adding at the  
end the following3 ,such term shall not 
include a qualified foreign pension fund
 7as defined in section #hig7k7744  7c7 
,effective date ,the amendments made by 
this section shall apply to dispositions
 of ,united ,states real property       
interests more than #ij days after the  
date of the enactment of this ,act4