HR 1515 IH
107th CONGRESS
1st Session
H. R. 1515
To amend the Internal Revenue Code of 1986 to clarify the treatment
for foreign tax credit limitation purposes of certain transfers of intangible
property.
IN THE HOUSE OF REPRESENTATIVES
April 4, 2001
Mr. SHAW introduced the following bill; which was referred to the Committee
on Ways and Means
A BILL
To amend the Internal Revenue Code of 1986 to clarify the treatment
for foreign tax credit limitation purposes of certain transfers of intangible
property.
Be it enacted by the Senate and House of Representatives of the United
States of America in Congress assembled,
SECTION 1. CLARIFICATION OF TREATMENT OF CERTAIN TRANSFERS OF INTANGIBLE
PROPERTY.
(a) IN GENERAL- Subparagraph (C) of section 367(d)(2) of the Internal
Revenue Code of 1986 is amended by adding at the end the following new
sentence: `For purposes of applying the foreign tax credit limitation
categories of section 904(d), any such amount shall be treated in the same
manner as if such amount were a royalty.'
(b) EFFECTIVE DATE- The amendment made by this section shall apply to
amounts treated as received pursuant to section 367(d)(2) of the Internal
Revenue Code of 1986 on or after August 5, 1997.
END