,i #aacth ,,congress #b;d ,session ,h4 ,r4 #eddc ,,in ,,the ,,house ,,of ,,representatives ,september #aj1 #bjad ,mr4 ,pocan 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 end tax deferrals on profits accumulated offshore and to terminate the deferral of active income of controlled foreign corporations4 #a4 ,short title ,this ,act may be cited as the ,putting ,america ,first ,corporate ,tax ,act4 #b4 ,inclusion in subpart ,f income of investments by controlled foreign corporations with respect to members of foreign group which includes ,united ,states shareholder 7a7 ,in general ,section #ief7;a77#a77;,a7 of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7,a7 such shareholder's pro rata share of the average of-- 7i7 the amounts of ,united ,states property1 and 7ii7 in the case of a controlled foreign corporation which is a member of an expanded affiliated group the common parent of which is not a ,united ,states person1 the amount of foreign group property1 held 7directly or indirectly7 by the controlled foreign corporation as of the close of each quarter of such taxable year1 over 4 7b7 ,foreign group property ,section #ief of such ,code is amended by redesignating subsections 7d7 and 7e7 as subsections 7e7 and 7f71 respectively1 and by inserting after subsection 7c7 the following new subsection3 7d7 ,foreign group property2 expanded affiliated group ,for purposes of this section-- 7#a7 ,foreign group property 7,a7 ,in general ,the term foreign group property means any stock or obligation of any foreign person which is not a controlled foreign corporation4 7,b7 ,exceptions ,such term shall not include-- 7i7 the stock or obligation of any entity if less than #be percent of the total combined voting power of such entity1 immediately after the acquisition of any stock in such entity by the controlled foreign corporation1 is owned 7directly or indirectly7 by the common parent referred to in subsection 7a77#a77;,a77ii71 and 7ii7 property described in subparagraph 7,c71 7,i71 7,j71 or 7,k7 of subsection 7c77#b71 applied by substituting foreign person for ,united ,states person in such subparagraphs 7,c7 and 7,j74 7#b7 ,expanded affiliated group ,the term expanded affiliated group means an affiliated group as defined in section #aejd7;a71 determined-- 7,a7 by substituting more than #ej percent for at least #hj percent each place it appears1 and 7,b7 without regard to paragraphs 7#b7 and 7#c7 of section #aejd7;b74 ,a partnership or any other entity 7other than a corporation7 shall be treated as a member of an expanded affiliated group if such entity controls 7as determined under section #ied7;d77#c771 or is controlled by 7as so determined71 members of such group 7including any entity treated as a member of such group by reason of this sentence74 7#c7 ,application to non-corporate entities ,in the case of any entity which is not a corporation-- 7,a7 any reference in this subsection to stock shall be treated as a reference to any equity or profits interest in such entity1 and 7,b7 except as otherwise provided by the ,secretary1 paragraph 7#a77;,b77i7 shall be applied by substituting #be percent 7by value7 of the beneficial interests in such entity for #be percent of the total combined voting power of such entity4 4 7c7 ,application of rules for pledges and guarantees ,section #ief7;e7 of such ,code1 as so redesignated1 is amended to read as follows3 7e7 ,pledges and guarantees ,for purposes of subsection 7a71 a controlled foreign corporation shall1 under regulations prescribed by the ,secretary1 be considered as holding-- 7#a7 an obligation of a ,united ,states person if such controlled foreign corporation is a pledgor or guarantor of such obligation1 and 7#b7 an obligation of a foreign person if such controlled foreign corporation or1 to the extent provided under such regulations1 any ,united ,states shareholder of such controlled foreign corporation1 is a pledgor or guarantor of such obligation4 4 7d7 ,application of limitation on amount of foreign taxes deemed paid with respect to section #ief inclusions ,notwithstanding section #bad7;b7 of ,public ,law #aaa-bbf1 section #ifj7;c7 of the ,internal ,revenue ,code of #aihf shall apply to acquisitions of foreign group property 7as defined in #ief7;d7 of such ,code1 as amended by this section7 after ,december #ca1 #bjaj1 in addition to acquisitions of ,united ,states property 7as defined in section #ief7;c7 of such ,code7 after such date4 7e7 ,effective date ,the amendments made by this section shall apply to taxable years of controlled foreign corporations ending after the date of the enactment of this ,act and to taxable years of ,united ,states shareholders in which or with which such taxable years of controlled foreign corporations end4 #c4 ,termination of deferral of active income of controlled foreign corporations 7a7 ,in general ,section #ieb of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7d7 ,special application of subpart 7#a7 ,in general ,for taxable years beginning after ,december #ca1 #bjad1 notwithstanding any other provision of this subpart1 the term subpart ,f income means1 in the case of any controlled foreign corporation1 the income of such corporation derived from any foreign country4 7#b7 ,applicable rules ,rules similar to the rules under the last sentence of subsection 7a7 and subsection 7d7 shall apply to this subsection4 4 7b7 ,effective date ,the amendment made by subsection 7a7 shall apply to taxable years beginning after ,december #ca1 #bjad4