,i  #aafth ,,congress  #b;d ,session    
,h4 ,r4 #ggdi  ,,in ,,the ,,house ,,of  
,,representatives  ,july #bc1 #bjbj,mr4 
,la,hood 7for himself and ,mr4          
,ferguson7 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 encourage the        
transfer of intangible property from    
controlled foreign corporations to      
,united ,states shareholders4  #a4      
,special rules for transfers of         
intangible property from controlled     
foreign corporations to ,united ,states 
shareholders  7a7 ,in general ,subpart  
,f of part ,,iii of subchapter ,n of    
chapter #a of the ,internal ,revenue    
,code of #aihf is amended by adding at  
the end the following new section3      
#iff4 ,transfers of intangible property 
to ,united ,states shareholders  7a7 ,in
 general ,if a controlled foreign       
corporation holds intangible property on
 the date of the enactment of this      

section and thereafter distributes such 
property to a domestic corporation which
 is a ,united ,states shareholder with  
respect to such controlled foreign      
corporation-- 7#a7 for purposes of part 
,i of subchapter ,c and any other       
provision of this title specified by the
 ,secretary1 the fair market value of   
such property on the date of such       
distribution shall be treated as not    
exceeding the adjusted basis of such    
property immediately before such        
distribution1 and  7#b7 if any portion  
of such distribution is not a dividend--
 7,a7 no gain shall be recognized by    
such ,united ,states shareholder with   
respect to such distribution1 and  7,b7 
the adjusted basis of such property in  
the hands of such ,united ,states       
shareholder immediately after such      
distribution shall be the adjusted basis
 of such property in the hands of such  
controlled foreign corporation          
immediately before such distribution    
reduced by the amount 7if any7 of gain  

not recognized by reason of subparagraph
 7,a7 7determined after the application 
of paragraph 7#a774  7b7 ,intangible    
property ,for purposes of this section1 
the term intangible property means any--
 7#a7 patent1 copyright1 license1       
invention1 formula1 process1 design1    
pattern1 know-how1 or format1  7#b7     
method1 program1 system1 procedure1     
campaign1 survey1 study1 forecast1      
estimate1 or technical data1  7#c7      
computer software 7as defined in section
 #aig7;e77#c77;,b771 or  7#d7 any       
similar item1 which has substantial     
value independent of the services of any
 individual4  4  7b7 ,conforming        
amendments  7#a7 ,section               
#aig7;f77#b77;,b77i7 of such ,code is   
amended by inserting #iff7;a71 after    
#gca14  7#b7 ,the table of sections for 
subpart ,f of part ,,iii of subchapter  
,n of chapter #a of such ,code is       
amended by adding at the end the        
following new item3  ,sec4 #iff4        
,transfers of intangible property to    

,united ,states shareholders4  4  7c7   
,effective date ,the amendments made by 
this section shall apply to             
distributions made in taxable years of  
foreign corporations beginning after    
,december #ca1 #bjbj1 and to taxable    
years of ,united ,states shareholders in
 which or with which such taxable years 
of foreign corporations end4