,i  #aadth ,,congress  #ast ,session    
,h4 ,r4 #cjhc  ,,in ,,the ,,house ,,of  
,,representatives  ,july #ae1 #bjae ,mr4
 ,williams 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 make permanent the   
dividends received deduction for        
repatriated foreign earnings1 and for   
other purposes4  #a4 ,short title ,this 
,act may be cited as the ,bring ,jobs   
,back to ,america ,act of #bjae4  #b4   
,modification and permanent extension of
 the incentives to reinvest foreign     
earnings in the ,united ,states  7a7    
,repatriation subject to #e percent tax 
rate ,section #ife7;a77#a7 of the       
,internal ,revenue ,code of #aihf is    
amended by striking #he percent and     
inserting #he4g percent4  7b7 ,permanent
 extension ,to elect repatriation       
,section #ife7;f7 of such ,code is      
amended to read as follows3  7f7        
,election ,the taxpayer may elect to    

apply this section to any taxable year  
only if made on or before the due date  
7including extensions7 for filing the   
return of tax for such taxable year4  4 
7c7 ,repatriation includes current and  
accumulated foreign earnings  7#a7 ,in  
general ,section #ife7;b77#a7 of such   
,code is amended to read as follows3    
7#a7 ,in general ,the amount of         
dividends taken into account under      
subsection 7a7 shall not exceed the sum 
of the current and accumulated earnings 
and profits described in section        
#iei7;c77#c7 for the year a deduction is
 claimed under subsection 7a71 without  
diminution by reason of any             
distributions made during the election  
year1 for all controlled foreign        
corporations of the ,united ,states     
shareholder4  4  7#b7 ,conforming       
amendments  7,a7 ,section #ife7;b7 of   
such ,code is amended by striking       
paragraph 7#b7 and by redesignating     
paragraphs 7#c7 and 7#d7 as paragraphs  
7#b7 and 7#c71 respectively4  7,b7      

,section #ife7;c7 of such ,code is      
amended by striking paragraphs 7#a7 and 
7#b7 and by redesignating paragraphs    
7#c71 7#d71 and 7#e7 as paragraphs 7#a71
 7#b71 and 7#c71 respectively4  7,c7    
,section #ife7;c77#c7 of such ,code1 as 
redesignated by subparagraph 7,b71 is   
amended to read as follows3  7#c7       
,controlled groups ,all ,united ,states 
shareholders which are members of an    
affiliated group filing a consolidated  
return under section #aeja shall be     
treated as one ,united ,states          
shareholder4  4  7d7 ,clerical          
amendments  7#a7 ,the heading for       
section #ife of such ,code is amended by
 striking ,temporary4  7#b7 ,the table  
of sections for subpart ,f of part ,,iii
 of subchapter ,n of chapter #a of such 
,code is amended by striking ,temporary 
dividends and inserting ,dividends4  7e7
 ,effective date ,the amendments made by
 this section shall apply to taxable    
years ending after the date of the      
enactment of this ,act4