Bill > HR694

This bill, the Corporate Tax Fairness Act, aims to prevent U.S. corporations from avoiding taxes on income earned in foreign countries. It proposes to eliminate the deferral of taxes on foreign-source income for taxable years beginning after December 31, 2013, meaning U.S. companies will have to pay taxes on this income annually rather than delaying it. Additionally, the bill denies foreign tax credits to large integrated oil companies that are considered "dual capacity taxpayers" – entities subject to a foreign levy and receiving specific economic benefits from that country – if the foreign country doesn't have a generally applicable income tax or if the payment exceeds what would be owed under such a tax. It also limits the ability to use foreign tax credits to offset income that is already subject to U.S. tax. Finally, the bill treats foreign corporations whose management and control are primarily located in the United States as domestic corporations for U.S. tax purposes, regardless of where they are incorporated, if they meet certain asset or trading thresholds.