3 International Tax Provision in the Extenders Bill Which is head to President Obama for Signature!

The U.S. House of Representatives agreed to a $622 billion tax package that would extend several expiring tax breaks, including clean energy incentives, and make a number of changes to both individual and corporate taxation, including real estate and medical device taxes.

The bill contains several international tax provisions including:

1. Making permanent the Subpart F exception under Secs. 953(e)(10) and 954(h)(9) for active financing income.
2. A five-year extension, until December 31 2019, of Sec. 954(c)(6), which provides for lookthrough treatment of payments of dividends, interest, rents, and royalties received or accrued from related controlled foreign corporations under the foreign personal holding company rules. and
3. Foreign taxpayers selling a interest in US real property will be subject to a higher 15% withholding tax as opposed to the previous tax of 10%.

On December 18, 2015, the Senate voted 65-33 to pass combined legislation to fund the government and renew or make permanent dozens of expired tax breaks, sending the trillion-dollar legislation to the president.

Sources

Journal of Accountancy

Law360