Us Congress 2025-2026 Regular Session

Us Congress House Bill HB363 Compare Versions

Only one version of the bill is available at this time.

Old	New	Differences
1	1	I
2	2	119THCONGRESS
3	3	1
4	4	STSESSION H. R. 363
5	5	To amend the Internal Revenue Code of 1986 to exclude certain amounts
6	6	from the tested income of controlled foreign corporations, and for other
7	7	purposes.
8	8	IN THE HOUSE OF REPRESENTATIVES
9	9	JANUARY13, 2025
10	10	Ms. P
11	11	LASKETTintroduced the following bill; which was referred to the
12	12	Committee on Ways and Means
13	13	A BILL
14	14	To amend the Internal Revenue Code of 1986 to exclude
15	15	certain amounts from the tested income of controlled
16	16	foreign corporations, and for other purposes.
17	17	Be it enacted by the Senate and House of Representa-1
18	18	tives of the United States of America in Congress assembled, 2
19	19	SECTION 1. SHORT TITLE. 3
20	20	This Act may be cited as the ‘‘Territorial Economic 4
21	21	Recovery Act’’. 5
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24	24	•HR 363 IH
25	25	SEC. 2. INCOME OF CERTAIN QUALIFIED POSSESSION COR-1
26	26	PORATIONS EXCLUDED FROM TESTED IN-2
27	27	COME. 3
28	28	(a) I
29	29	NGENERAL.—Section 951A of the Internal Rev-4
30	30	enue Code of 1986 is amended— 5
31	31	(1) in subsection (c)(2)(A)(i), by striking ‘‘and’’ 6
32	32	at the end of subclause (IV), by striking ‘‘over’’ at 7
33	33	the end of subclause (V) and inserting ‘‘and’’, and 8
34	34	by adding at the end the following new subclause: 9
35	35	‘‘(VI) any income of a qualified 10
36	36	possession corporation that is effec-11
37	37	tively connected with the active con-12
38	38	duct of a trade or business within a 13
39	39	possession of the United States, 14
40	40	over’’; and 15
41	41	(2) by adding at the end the following new sub-16
42	42	sections: 17
43	43	‘‘(g) P
44	44	OSSESSION OF THE UNITEDSTATES.—For 18
45	45	purposes of this section, the term ‘possession of the United 19
46	46	States’ means Puerto Rico, the Virgin Islands, and any 20
47	47	specified possession described in section 931(c). 21
48	48	‘‘(h) Q
49	49	UALIFIEDPOSSESSIONCORPORATION.—For 22
50	50	purposes of this section, the term ‘qualified possession cor-23
51	51	poration’ means any controlled foreign corporation for any 24
52	52	taxable year, if, for the 3-year period (or the period during 25
53	53	which the controlled foreign corporation has been in exist-26
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56	56	•HR 363 IH
57	57	ence, if shorter) ending in the taxable year preceding the 1
58	58	taxable year in which the determination is made— 2
59	59	‘‘(1) 80 percent or more of the gross income of 3
60	60	such corporation was derived from sources within a 4
61	61	possession of the United States, and 5
62	62	‘‘(2) 75 percent or more of the gross income of 6
63	63	such corporation was effectively connected with the 7
64	64	active conduct of a trade or business within a pos-8
65	65	session of the United States.’’. 9
66	66	(b) E
67	67	FFECTIVEDATE.—The amendments made by 10
68	68	this section shall apply to taxable years of foreign corpora-11
69	69	tions beginning after December 31, 2023, and to taxable 12
70	70	years of United States shareholders in which or with which 13
71	71	such taxable years of foreign corporations end. 14
72	72	Æ
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