Bill > HR1555

This bill, titled the International Tax Competitiveness Act of 2013, aims to reduce international tax avoidance and create a more level playing field for American businesses by amending the Internal Revenue Code of 1986. Key provisions include treating foreign corporations managed and controlled primarily within the United States as domestic corporations for income tax purposes, regardless of where they are legally incorporated, if their stock is publicly traded or they hold significant assets ($50 million or more). This aims to prevent companies from shifting profits to lower-tax jurisdictions by artificially locating management and control outside the U.S. The bill also modifies rules for taxing royalties and other income from intangibles received from controlled foreign corporations, a type of foreign subsidiary, by repealing a "look-through" rule for royalties and ensuring all royalties are taken into account, even if entities are disregarded for tax purposes. Additionally, it addresses the taxation of "boot," which is other property or money received in certain corporate reorganizations, by treating it as a dividend to the extent of earnings and profits, with specific rules for certain types of reorganizations.