,i  #aagth ,,congress  #b;d ,session    
,h4 ,r4 #gija  ,,in ,,the ,,house ,,of  
,,representatives  ,may #bg1 #bjbb,mr4  
,schneider 7for himself1 ,mr4 ,golden1  
,mr4 ,bacon1 ,mr4 ,carbajal1 ,mr4       
,baird1 and ,mr4 ,kinzinger7 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 deny foreign 
tax credits or deductions with respect  
to taxes paid or accrued to the ,russian
 ,federation and the ,republic of       
,belarus1 to provide for the denial of  
certain other tax benefits in connection
 with the invasion of ,ukraine1 and for 
other purposes4  #a4 ,short title ,this 
,act may be cited as the ,support       
,ukraine ,through ,our ,tax ,code ,act4 
#b4 ,denial of foreign tax credit1 etc41
 with respect to taxes paid or accrued  
to the ,russian ,federation and the     
,republic of ,belarus  7a7 ,in general  
,section #ija7;j77#b7 of the ,internal  
,revenue ,code of #aihf is amended by   

adding at the end the following new     
subparagraph3  7,c7 ,special rule for   
,russia and ,belarus  7i7 ,in general   
,this subsection shall apply to the     
,russian ,federation and the ,republic  
of ,belarus during the period described 
in clause 7ii74  7ii7 ,period of        
application ,the period described in    
this clause with respect to any country 
is the period-- 7,i7 beginning on the   
date that is #ij days after the date of 
the enactment of this subparagraph1 and 
7,,ii7 ending on the date on which the  
resumption of the application of the    
rates of duty set forth in column #a of 
the ,harmonized ,tariff ,schedule of the
 ,united ,states to products of that    
country takes effect pursuant to section
 #d7;b7 of the ,suspending ,normal      
,trade ,relations with ,russia and      
,belarus ,act4  4  7b7 ,deduction denied
  7#a7 ,in general ,section #bge7;a7 of 
the ,internal ,revenue ,code of #aihf is
 amended by inserting after paragraph   
7#f7 the following new paragraph3  7#g7 

,income1 war profits1 and excess profits
 taxes paid or accrued 7or deemed paid  
under section #ifj7 to any country      
described in section                    
#ija7;j77#b77;,c77i7 with respect to    
income attributable to any period       
described in section                    
#ija7;j77#b77;,c77ii74  4  7#b7         
,conforming amendment ,section          
#ija7;j77#c7 of such ,code is amended by
 adding at the end the following new    
sentence3 ,the preceding sentence shall 
not apply to any taxes paid or accrued  
7or deemed paid under section #ifj7 to  
any country described in paragraph      
7#b77;,c77i7 with respect to income     
attributable to any period described in 
paragraph 7#b77;,c77ii744  7c7 ,special 
transition rules for taxpayers exiting  
countries for which foreign tax credit  
is denied  7#a7 ,in general ,if-- 7,a7  
any portion of a taxable year of a      
taxpayer occurs during the post-exit    
period1 and  7,b7 such taxpayer is an   
applicable taxpayer for such portion of 

the taxable year with respect to a      
foreign country to which section        
#ija7;j77#b77;,c7 of the ,internal      
,revenue ,code of #aihf 7as added by    
subsection 7a77 applies1  then1         
notwithstanding such section            
#ija7;j77#b77;,c71 sections             
#ija7;j77#a77;,b7 and #ieb7;a77#e7 of   
such ,code shall not apply to income    
derived by the taxpayer from such       
foreign country during such portion of  
such taxable year4  7#b7 ,applicable    
taxpayer  7,a7 ,in general ,a taxpayer  
is an applicable taxpayer with respect  
to a foreign country for any portion of 
a taxable year occurring during the     
post-exit period if-- 7i7 the gross     
receipts of the taxpayer for such       
portion derived from such foreign       
country 7determined under rules         
substantially similar to the rules of   
part ,i of subchapter ,n of chapter #a  
of the ,internal ,revenue ,code of      
#aihf7 are-- 7,i7 in the case of the    
period beginning with the first day of  

the first month beginning after the     
first day of the post-exit period and   
ending with the last day of the first   
taxable year ending on or after such    
date1 less than #ae percent of such     
gross receipts derived during the       
pre-exit period1 and  7,,ii7 in the case
 of any taxable year beginning after the
 first day of the post-exit period1 less
 than #e percent of such gross receipts 
derived during the pre-exit period1 or  
7ii7 the taxpayer meets such other      
requirements as the ,secretary of the   
,treasury 7or the ,secretary's delegate7
 may by regulation or guidance prescribe
 to determine whether a taxpayer has    
exited from doing business in such      
foreign country4  7,b7 ,rules for       
determining gross receipts  7i7         
,aggregation rules ,the rules of section
 #ddh7;c77#b7 shall apply for purposes  
of this paragraph1 except that-- 7,i7 in
 applying section #eb7;a71 the exception
 for foreign corporations under section 
#aefc7;b77#b77;,c7 shall be disregarded1

 and  7,,ii7 in applying section        
#eb7;b71 the principles which apply     
under section #eb7;a7 shall include the 
modification under subclause 7,i7 and   
the term trade or business shall include
 any activity treated as a trade or     
business under paragraph 7#e7 or 7#f7 of
 section #dfi7;c7 7determined without   
regard to the phrase1 ,to the extent    
provided in regulations in such         
paragraph 7#f774  7ii7 ,special rules   
,the rules of section #ddh7;c77#c7 shall
 apply for purposes of this paragraph1  
except that in applying subparagraph    
7,b7 thereof to a taxable year in which 
the entire taxable year does not occur  
during the post-exit period1 the portion
 of the year during such period shall be
 treated as a short taxable year for    
purposes of determining annualized gross
 receipts4  7iii7 ,receipts related to  
humanitarian purposes ,for purposes of  
this subsection1 gross receipts shall   
not include amounts-- 7,i7 which are    
covered under general or specific       

licenses of the ,office of ,foreign     
,assets ,control of the ,department of  
the ,treasury which have been identified
 by the ,secretary of the ,treasury 7or 
the ,secretary's delegate7 as licenses  
to which this clause applies1 or  7,,ii7
 which the ,secretary of the ,treasury  
7or the ,secretary's delegate7 has      
otherwise identified as humanitarian in 
nature4  7#c7 ,periods ,for purposes of 
this subsection-- 7,a7 ,pre-exit period 
,the term pre-exit period means-- 7i7   
except as provided in clause 7ii71 the  
#ab-month period ending on ,december    
#ca1 #bjba1 and  7ii7 in the case of a  
taxpayer with a taxable year which ends 
on or after ,november #cj1 #bjba1 and   
before ,february #bd1 #bjbb1 such       
taxable year4  7,b7 ,post-exit period   
,the term post-exit period means1 with  
respect to any foreign country1 the     
period during which section             
#ija7;j77#b77;,c7 of the ,internal      
,revenue ,code of #aihf 7as added by    
subsection 7a77 applies to such foreign 

country 7determined without regard to   
this subsection74  7d7 ,effective date  
,the amendments made by this section    
shall take effect on the date of the    
enactment of this ,act4  #c4 ,denial of 
certain other tax benefits in connection
 with the invasion of ,ukraine  7a7 ,in 
general ,in the case of any person to   
whom this section applies-- 7#a7 section
 #hib7;a7 of the ,internal ,revenue     
,code of #aihf 7relating to income of   
foreign governments7 shall not apply to 
income received during the period this  
section applies to such person1  7#b7   
notwithstanding section #hid of such    
,code1 such ,code shall be applied to   
such person without regard to any treaty
 obligation of the ,united ,states      
during the period this section applies  
to such person1  7#c7 section #hie of   
such ,code 7relating to income derived  
by a foreign central bank of issue from 
obligations of the ,united ,states or   
from bank deposits7 shall not apply to  
any central bank of such person1  7#d7  

sections #hga7;h7 7relating to repeal of
 tax on interest of nonresident alien   
individuals received from certain       
portfolio debt investments7 and #hha7;c7
 7relating to repeal of tax on interest 
of foreign corporations received from   
certain portfolio debt investments7 of  
such ,code shall not apply to interest  
received during the period this section 
applies to such person1  7#e7 section   
#hfd7;b7 of such ,code 7relating to     
trade or business within the ,united    
,states7 shall be applied without regard
 to paragraph 7#b7 thereof 7relating to 
exception for trading in securities or  
commodities7 with respect to the period 
during which this section applies to    
such person1  7#f7 section #hhc of such 
,code 7relating to exclusion of income  
from shipping1 etc47 shall not apply to 
income or earnings received during the  
period this section applies to such     
person1 and  7#g7 notwithstanding       
section #hig7l7 of such ,code1 any      
trust1 corporation1 or other            

organization or arrangement established 
by such person shall not be treated as a
 qualified foreign pension fund under   
section #hig of such ,code during the   
period this section applies to such     
person4  7b7 ,persons to whom this      
section applies  7#a7 ,in general ,this 
section shall apply to-- 7,a7 any person
 with respect to which sanctions have   
been imposed by the ,united ,states in  
relation to the invasion of ,ukraine by 
the ,russian ,federation that began on  
,february #bd1 #bjbb1  7,b7 the         
government of any foreign country to    
which section #ija7;j77#b77;,c7 of the  
,internal ,revenue ,code of #aihf       
applies1 and  7,c7 any other person     
identified by the ,secretary as-- 7i7 a 
person described in paragraph 7#b71 and 
7ii7 a person with respect to which the 
application of this section would       
advance efforts to restore and maintain 
the peace1 security1 stability1         
sovereignty1 and territorial integrity  
of ,ukraine 7as determined by the       

,secretary in consultation with the     
,secretary of ,state74  7#b7 ,persons   
described ,a person is described in this
 paragraph if such person-- 7,a7 is a   
person that-- 7i7 is participating or   
has participated in the invasion of     
,ukraine1 and  7ii7 either-- 7,i7 owns1 
directly or indirectly1 at least        
#a1jjj1jjj of assets in the ,united     
,states1 or  7,,ii7 has1 for the most   
recent calendar year1 at least          
#a1jjj1jjj of income from sources within
 the ,united ,states1  7,b7 is an entity
 that-- 7i7 is organized in1 or a tax   
resident of1 a foreign country          
7including any subdivision thereof7 to  
which section #ija7;j77#b77;,c7 of such 
,code applies1  7ii7 is not a controlled
 foreign corporation 7as defined in     
section #ieg of such ,code71 and  7iii7 
has provided or sold goods or services  
to a government 7including any          
instrumentality thereof7 to which       
section #ija7;j77#b77;,c7 of such ,code 
applies1  7,c7 is an executive1 board   

member1 or officer of an entity         
described in subparagraph 7,b71 or  7,d7
 is a person that is related to any     
other person to which this section      
applies4  7#c7 ,special rules for       
controlled entities ,under regulations  
provided by the ,secretary-- 7,a7 ,in   
general ,the ,secretary may treat a     
person controlled 7within the meaning of
 section #ied7;d77#c7 of the ,internal  
,revenue ,code of #aihf7 by a person    
described in paragraph 7#a7 as a person 
to whom this section applies without    
regard to whether such controlled person
 has been identified by the ,secretary  
under paragraph 7#a77;,c74  7,b7        
,notification  7i7 ,in general ,the     
,secretary may require any person       
treated as a person to whom this section
 applies by reason of subparagraph 7,a7 
to provide notice to the ,secretary and 
to each withholding agent of such person
 that this section applies to such      
person4  7ii7 ,penalties ,for purposes  
of applying part ,,ii of subchapter ,b  

of chapter #fh of the ,internal ,revenue
 ,code of #aihf-- 7,i7 any notice       
required to be provided to the          
,secretary under clause 7i7 shall be    
treated as an information return        
described in section #fgbd7;d77#a7 of   
such ,code1 and  7,,ii7 any notice      
required to be provided to a withholding
 agent under clause 7i7 shall be treated
 as a payee statement described in      
section #fgbd7;d77#b7 of such ,code4    
7c7 ,period for which this section      
applies ,for purposes of this section-- 
7#a7 ,in general ,this section applies  
to any person described in subsection   
7b7 during the period-- 7,a7 except as  
provided in paragraph 7#b71 beginning on
 the date that is #cj days after the    
later of-- 7i7 the date of the enactment
 of this ,act1 or  7ii7 the date such   
person is first described in subsection 
7b71 and  7,b7 ending on the date such  
person is no longer described in        
subsection 7b74  7#b7 ,special rules for
 portfolio interest  7,a7 ,in general   

,for purposes of applying subsection    
7a77#d71 except as provided in          
subparagraph 7,b71 the period described 
in paragraph 7#a7 shall begin on the    
later of-- 7i7 the date that is #ahj    
days 7#fj days in the case of           
obligations issued on or after the date 
of the enactment of this ,act7 after the
 date of enactment of this ,act1 or     
7ii7 #fj days after the date such person
 first becomes described in subsection  
7b74  7,b7 ,significant modifications   
,if1 after the date of the enactment of 
this ,act1 there is a significant       
modification of an obligation issued    
before the date of the enactment of this
 ,act1 then1 for purposes of applying   
subsection 7a77#d71 the period described
 in paragraph 7#a7 shall begin on the   
later of-- 7i7 the earlier of-- 7,i7 the
 day that is #fj days after the date of 
such significant modification1 or       
7,,ii7 the day that is #ahj days after  
the date of the enactment of this ,act1 
or  7ii7 the date that is #fj days after

 the date such person first becomes     
described in subsection 7b74  7d7       
,definitions ,for purposes of this      
section-- 7#a7 ,secretary ,the term     
,secretary means the ,secretary of the  
,treasury4  7#b7 ,related ,a person     
7hereinafter in this paragraph referred 
to as the related person7 is related to 
any person if-- 7,a7 the related person 
bears a relationship to such person     
which is-- 7i7 specified in section     
#bfg7;b7 or #gjg7;b77#a7 of the         
,internal ,revenue ,code of #aihf1 or   
7ii7 specified in the regulations       
prescribed under subsection 7f71 or     
7,b7 the related person and such person 
are engaged in trades or businesses     
under common control 7within the meaning
 of subsections 7a7 and 7b7 of section  
#eb of such ,code1 determined after the 
application of the rules of section     
#b7;c77#b77;,b77i774  7e7 ,reports ,not 
later than #a year after the date of the
 enactment of this ,act1 and annually   
thereafter1 the ,secretary shall submit 

to ,congress a report detailing the     
parameters1 processes1 and              
justifications by which a person is     
identified by the ,secretary under      
7b77#a77;,c7 of this section4  7f7      
,regulations ,the ,secretary shall      
prescribe such regulations1 rules1 or   
other guidance as the ,secretary        
determines necessary or appropriate to  
carry out the purposes of this section4 
#d4 ,suspension of tax information      
exchanges ,if there is a tax convention 
7within the meaning of section          
#faje7;c77#b7 of the ,internal ,revenue 
,code of #aihf7 providing for the       
exchange of tax information between the 
,united ,states and any foreign country 
to which section #ija7;j77#b77;,c7 of   
such ,code 7as added by section #b7;a77 
applies1 the ,secretary of the ,treasury
 7or the ,secretary's delegate7 shall   
not exchange such tax information with  
such foreign country during the period  
that such section applies to such       
foreign country4  #e4 ,treaty           

obligations ,this ,act and the          
amendments made by this ,act shall be   
applied without regard to any treaty    
obligation of the ,united ,states4