Bill > HR4429

This bill, titled the Permanent Active Financing Exception Act of 2014, aims to permanently extend an existing exemption within the U.S. tax code, specifically under "subpart F," which deals with how U.S. shareholders are taxed on certain income earned by their foreign corporations. The key provision is to make permanent an exemption for "active financing income," which refers to income derived from the active conduct of a banking, financing, or similar business, or from being a securities dealer or engaging in an insurance business. Currently, this exemption is temporary, and this bill seeks to remove the expiration date, ensuring that such income earned by foreign subsidiaries of U.S. companies is not immediately subject to U.S. taxation. The changes apply to taxable years of foreign corporations beginning after December 31, 2013, and the corresponding U.S. shareholders' taxable years.