6a0
<PRE>[DOCID: f:h1515ih.txt]






107th CONGRESS
  1st Session
                                H. R. 1515

To amend the Internal Revenue Code of 1986 to clarify the treatment for 
    foreign tax credit limitation purposes of certain transfers of 
                          intangible property.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                             April 4, 2001

   Mr. Shaw introduced the following bill; which was referred to the 
                      Committee on Ways and Means

_______________________________________________________________________

                                 A BILL


 
To amend the Internal Revenue Code of 1986 to clarify the treatment for 
    foreign tax credit limitation purposes of certain transfers of 
                          intangible property.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. CLARIFICATION OF TREATMENT OF CERTAIN TRANSFERS OF 
              INTANGIBLE PROPERTY.

    (a) In General.--Subparagraph (C) of section 367(d)(2) of the 
Internal Revenue Code of 1986 is amended by adding at the end the 
following new sentence: ``For purposes of applying the foreign tax 
credit limitation categories of section 904(d), any such amount shall 
be treated in the same manner as if such amount were a royalty.''
    (b) Effective Date.--The amendment made by this section shall apply 
to amounts treated as received pursuant to section 367(d)(2) of the 
Internal Revenue Code of 1986 on or after August 5, 1997.
                                 &lt;all&gt;

0