,,ii #aaith ,,congress #ast ,session ,s4 #cfi ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,february #c1 #bjbe,mr4 ,scott of ,florida introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to deny certain green energy tax benefits to companies associated with foreign adversaries4 #a4 ,short title ,this ,act may be cited as the ,no ,official ,giveaways ,of ,taxpayers' ,income to ,oppressive ,nations ,act or the ,,no ,,gotion ,act4 #b4 ,denial of green energy tax benefits to companies associated with foreign adversaries 7a7 ,in general ,chapter #gg of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new section3 #geca4 ,denial of green energy tax benefits to companies associated with foreign adversaries 7a7 ,in general ,in the case of any disqualified company1 this title shall be applied without regard to sections #cj;,c1 #dj1 #dj;,a1 #dj;,b1 #de1 #de,q1 #de,u1 #de,v1 #de,w1 #de,x1 #de,y1 #de,z1 #dh1 #dh;,c1 #dh;,e1 #agi;,d1 #fdbf7;c71 #fdbf7;d71 #fdbf7;e71 and #fdbg7;e74 7b7 ,disqualified company 7#a7 ,in general 7,a7 ,definition ,for purposes of this section1 the term disqualified company means any entity described in subparagraphs 7,b7 through 7,d74 7,b7 ,foreign adversary parties ,the entities described in this subparagraph consist of the following3 7i7 ,the government of a foreign adversary1 any agency or government instrumentality of a foreign adversary1 or any entity which is directly or indirectly owned1 controlled1 or directed by any such government1 agency1 or government instrumentality4 7ii7 ,any entity organized under the laws of a foreign adversary 7or any political subdivision thereof7 or whose headquarters is located within a foreign adversary4 7,c7 ,owned1 controlled1 directed1 or influenced by foreign adversary parties ,the entities described in this subparagraph consist of the following3 7i7 ,any entity for which1 on any date during the taxable year1 not less than #aj percent of the outstanding equity interests 7by value1 voting1 governance1 board appointment1 or similar rights or influence7 are held directly or indirectly by1 or on behalf of1 #a or more of the entities described in subparagraph 7,b71 including through interests in co-investment vehicles1 joint ventures1 or similar arrangements4 7ii7 ,any entity which is directly or indirectly controlled1 directed1 or materially influenced by any entity described in subparagraph 7,b74 7iii7 ,any entity for which the actions1 management1 ownership1 or operations of such entity are subject to the direct influence of an entity described in subparagraph 7,b74 7iv7 ,any entity for which an interest in such entity is held by an entity described in subparagraph 7,b7 7referred to in this clause as the beneficiary firm7 as a derivative financial instrument or through a contractual arrangement between the beneficiary firm and such entity1 including any financial instrument or other contract between the beneficiary firm and the entity which seeks to replicate any financial return with respect to such entity or interest in such entity4 7,d7 ,debt or other arrangements with foreign adversary parties 7i7 ,in general ,an entity is described in this subparagraph if1 as a result of any prohibited obligation or arrangement-- 7,i7 the actions1 management1 or operations of such entity are subject to the direct or indirect influence of #a or more entities described in subparagraph 7,b7 or 7,c71 or 7,,ii7 such entity provides a substantial benefit to #a or more entities described in subparagraph 7,b7 or 7,c74 7ii7 ,prohibited obligation or arrangement ,for purposes of this subparagraph1 the term prohibited obligation or arrangement means any-- 7,i7 debt1 7,,ii7 lease or sublease arrangement1 7,,iii7 management or operating arrangement1 7,,iv7 contract manufacturing arrangement1 7,v7 license or sublicense agreement1 or 7,,vi7 financial derivative4 7iii7 ,exception 7,i7 ,in general ,for purposes of clause 7i77,,ii71 the purchase of equipment or manufacturing inputs in an arm's length transaction shall not1 in and of itself1 be deemed to provide a substantial benefit4 7,,ii7 ,arm's length ,for purposes of this clause1 the term arm's length has the meaning given in section #a4dhb-a of title #bf1 ,code of ,federal ,regulations4 7,e7 ,other definitions ,for purposes of this paragraph-- 7i7 ,control ,the term control has the meaning given in section #hjj4bjh of title #ca1 ,code of ,federal ,regulations 7as in effect on the date of enactment of the ,no ,official ,giveaways ,of ,taxpayers' ,income to ,oppressive ,nations ,act74 7ii7 ,foreign adversary ,the term foreign adversary has the meaning given the term covered nation in section #dhgb7;d77#b7 of title #aj1 ,united ,states ,code1 except that such term shall also include-- 7,i7 the ,republic of ,cuba1 and 7,,ii7 the ,boliverian ,republic of ,venezuela during any period of time during which ,nicholas ,maduro is ,president of the ,republic4 7#b7 ,administration ,the ,secretary may issue such guidance as is necessary to carry out the purposes of this section1 including establishment of rules for-- 7,a7 implementation of paragraph 7#a77;,c77i7 for determination of whether the percentage requirements with respect to outstanding equity interests have been satisfied in the case of an entity for which the stock of such entity is traded on an established securities market in the ,united ,states or any foreign country1 and 7,b7 preventing entities from evading1 circumventing1 or abusing the application of the requirements under this section4 4 7b7 ,clerical amendment ,the table of sections for chapter #gg of such ,code is amended by adding at the end the following new item3 ,sec4 #geca4 ,denial of green energy tax benefits to companies associated with foreign adversaries4 4 7c7 ,effective date ,the amendments made by this section shall apply to taxable years beginning after the date of the enactment of this ,act4